ML17039B033
| ML17039B033 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 01/30/2017 |
| From: | Bower B US Dept of Energy, West Valley Demonstration Project |
| To: | Matthew Meyer NRC/NMSS/DDUWP/MDB |
| A. Snyder NMSS/DUWP/MDB 415-6822 T-8E45 | |
| References | |
| WVDP-575 | |
| Download: ML17039B033 (12) | |
Text
Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799 January 30, 2017 Matthew R. Meyer, Chief (Acting)
Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Two White flint North 11545 Rockville Pike Rockville, MD 20852-273 8
SUBJECT:
U.S. Department of Energy West Valley Demonstration Project (DOE-WVDP)
Responses to the U.S. Nuclear Regulatory Commission (NRC) Comments on DOE WVDP Vitrification Facility Decommissioning & Demolition Plan, WVDP-575, Rev. 3, dated July 6, 2016
REFERENCE:
Letter (368973), M. R. Meyer to B. C. Bower, U.S. Nuclear Regulatory Commission Comments on U.S. Department of Energy West Valley Demonstration Project Vitrification facility Decommissioning & Demolition Plan, WVDP-575, Rev. 3, dated July 6, 2016 (Docket No. POOM-0032),
dated September 12, 2016.
Dear Mr. Meyer:
The DOE-WVDP is submitting responses to the NRC comments on the Vitrification Facility Decommissioning & Demolition Plan as submitted by the NRC with the above referenced letter.
The attached table lists the NRC comments and provides responses with the information and explanation to address each comment.
Please contact Moira Maloney of my staff at (716) 942-4255 if you have any questions, need additional information, or if you would like to schedule a conference call to discuss the attached.
Sincerely, (B C. Bower, Director West Valley Demonstration Project
Enclosure:
Comment and Response Table for the U.S. NRC Comments on the WVDP Vitrification facility Decommissioning & Demolition Plan cc: SeePage2 ZZZ:369807 450.4
Mr. Matthew R. Meyer January 30, 2017 cc: S. W. Chase, CHBWV, WV-1OPLEX, w/enc.
T. D. Dogal, CHBWV, WV-1OPLEX, w/enc.
D. P. Kienk, CHBWV, WV-YOPLEX, w/enc.
R. E. Steiner, CHBWV, WV-PL6, w/enc.
M. N. Maloney, DOE-WVDP, AC-DOE, w/enc.
Z. Z. Zadins, DOE-WVDP, AC-DOE, w/enc.
A. Snyder, NRC, w/enc., amy.snyder@nrc.gov P. Bembia, NYSERDA, AC-NYS, w/enc.
ZZZ:3 69807 450.4
U.S. NUCLEAR REGULATORY COMMISSION COMMENTS ON WEST VALLEY DEMONSTRATION PROJECT VITRIFICATION FACILITY DECOMMISSIONING & DEMOLITION PLAN, WVDP-575, REV.3 Comment NRC Comment WVDP Response I) Section 5.3, Deactivation Activities Remaining: Provide the justification The criteria for fixing contamination and leaving contaminated or rationale explaining why additional decontamination is not reasonable materials/equipment in place for removal during demolition is an ALARA prior to disassembling/demolishing the structure. Also, discuss the evaluation to determine if further decontamination efforts are justified in lieu of criteria or rationale for fixing and leaving contaminated beginning demolition activities with fixatives applied. Additional materiallequipment in place for renioval during demolition, decontamination is not reasonable if disassembly/demolition of the structure already meets prescribed limits for open air demolition, using the ALARA principles, including cost-benefit analysis of these programs (10 CFR 20.1003 and NUREG-1530). A New Section 6.4.1 on ALARA will be added to the document during the next revisionsee Attachment 1.
Removing the radiological materials with long reach equipment during demolition results in lower total personnel dose than would be realized if additional hands on deactivation or removal activities were to be performed.
Air dispersion models, AERMOD and CAP-88, along with radionuclide source term estimates are used to estimate potential radiological dose to workers and the public, respectively, during demolition. This modeling is then supported by continuous monitoring during demolition to ensure all levels are within regulatory limits.
To estimate the dose to the public, CAP-88 is used with air emissions calculated using the alternative methodology for radionuclide source term calculations as described in the January 25, 2016 letter from DOE-WVDP to the U.S. EPA. This methodology is referred to as the Alternative Calculation in the subsequent responses.
- 2) Section 6,1, General Decommissioning Approach and Technologies The action levels at the perimeter of the site will be 0.02 DAC which is the and Section 6.4, Radiation Protection and Radiological Controls: maximum average concentration according to the AERMOD calculation and Describe the strategy or the guidelines that will be followed prior to activity on the deposition mats of 20 dpm/1 00cm2 alpha and 1000 dpmll 00cm2 beginning demolition (e.g., smearable levels are less than X, airborne beta-gamma. AERMOD modeling of residual contamination obtained from contamination is less than Y, and direct measurement is less than Z, radiological surveys will be used to determine if contaminationincluding the etc.) that ensure that the radiological controls for building demolition demolition approaches used in a specific area (Cut, Shear, Break, Drop),
remain appropriate for the radiological conditions that are anticipated fixative applications, and misting controlswill ensure that DAC objectives are during building demolition, met (0.02 DAC at the perimeter boundary).
Air sampling, deposition monitoring and other job support surveys will be completed durinq demolition to verify estimated results.
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- 3) Section 6.1, General Decommissioning Approach and Technologies Specific steps and sequencing are detailed in the Work Instruction Package and Section 6.4, Radiation Protection and Radiological Controls: Given (WIP) along with diagrams that identify safety and radiological considerations, the nature and progression of the work (use of water/suppressants to precautions and notes. The approach for water collection, including water used keep contamination down; eventually the cell will be open to the for dust suppression, and management is described in an appendix to the WIP environment, possibly for a couple of months, and lay down areas will be and is summarized below.
open to the environment for further disassembly and staging of debris and waste), provide more detail with regard to the strategy on water Water control barriers shall be in place prior to and maintained during all uselrunoff. How will water used for dust suppression be managed during phases of demolition. The lower portion of the Vitrification Facility (VF) cell and application to suppress dust and how will the volume of water be a berm set up around the demolition area will provide control and containment contmlled to avoid potential impact to other systems (i.e., gmundwatei for dust suppression water and precipitation. The water will be tested in spread of contamination within work zone and outside work zone, etc.)? accordance with site procedures and transferred for treatment through the WVDP low-level waste treatment facility.
Efforts will be made to minimize the volume of water by using misting techniques and a surfactant. Waler will be dispositioned from the containment areas mentioned above before the areas become full. Storm drain inlets within the bermed area will be sealed to avoid potential impact to other systems (i.e.,
groundwater, spread of contamination within and outside the work zone).
- 4) Section 6.1 General Decommissioning Approach and Technologies and a) Prior to placing grout in the VF cell; an engineering analysis was performed Section 6.2 Equipment to be Utilized and Available: to determine the thickness of the 1,200 psi grout needed to avoid floor damage a) How does the U.S. Department of Energy (DOE) support the from dropped debris during demolition. The analysis determined the thickness assumption that the surfaces that are grouted will not be inadvertently of grout needed to protect the floor if the assumed heaviest piece of debris disturbed during demolition? (steel crane rail support beam weighing 2,037 Ibs) fell the 32 ft from its support above the floor. To provide an additional margin of protection, concrete demolition debris will be placed over the grouted floor surface prior to removing and lowering the piece of debris used in the calculation.
b) What portion of the inventory will be included in the source term b) The source term calculations are part of a transparent process and are calculations? will DOE be transparent in assigning inventories in the documented in a calculation record, including material at risk (MAR), which is source term calculations (e.g., including the total inventory present for stored in the projects records system, subject to Government recordkeeping the material at risk and using the demolition ratio to account for the requirements.
portion of the inventory that will be impacted as a result of the demolition activity?) Note: terms material at risk and demolition ratio are found in [It appears that where the comment refers to demolition ratio this should be DOEs Methodology for Radionuclide Source Term Calculations for Air damage ratio as used in the January 2016 paper on the Alternative Emissions from Demolition Activities dated January 2016. Calculation.]
All of the inventory present wilt be assigned to the MAR and the Damage Ratio (DR) in the calculations will be used to account for inventory that is impacted.
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- 5) Section 6.4, Radiation Protection and Radiological Controls:
a) Before actual building demolition work begins, provide the air a) Calculation packages for AERMOD and the Alternative Calculation will be dispersion model reports for review. This should include a description of transmitted separately to the NRC.
the assumptions and rationale used to perform the modeling.
b) It is unclear how cut, shear, break, and drop demolition activities b) The activities described in Section 6.1 of the demolition plan are intended to listed in Section 6.1, (and equipment listed in Section 6.2) compare to the give an overall description of aspects of the demolition process.
list of activities described in Methodology for Radionuclide Source Term Calculations for Air Emissions from Demolition Activities, and if all The primary method used for drop operations in the January 2016 Alternative activities and all controls that will be employed are listed in the Calculation paper is from mechanical shearing. The Airborne Release Fraction methodology document (e.g.. how are emissions from drop demolition (ARF) selected is 1 E-03, which is based on dropping an object into a pile of activities calculated?). powder. Langer (See section 4.4.3.3.2 of the DOE Handbook DOE-HDBK 3010-94) dropped large rocks onto various powders and measured ARFs for each type of powdered material. The highest value measured was I E-03 (for A1203), which is the same ARF used in the Alternative Calculation. For the Hydraulic Hammer demolition method, which also might include a drop component, the estimated emissions also use an ARF of 1E-03, again, based on the Langer study of dropping large rocks into a pile of powder. In both cases, the drop operation was considered in developing the alternative calculation methods.
c) Many factors (e.g., damage ratio, airborne release fraction, leak path c) Comment noted. The source term calculations are part of a transparent factor) listed in Methodology for Radionuclide Source Term Calculations process and are documented in a calculation record, including MAR, which is for Air Emissions from Demolition Activities appear to be based on stored in the projects records system and will be transmitted separately to the professional judgement as experience and data are limited to determine NRC.
parameters to use in the calculations. Therefore, it will be important to be transparent regarding what activities will be conducted and what Methods for the Alternative Calculation are based on experimental data as information is available to support source term calculations for these documented in the references. However, as part of the approval process with activities, and to manage uncertainty associated with the calculations EPA, an emissions study will be conducted during demolition to validate the (e.g., through conservative assumptions when data is unavailable or very Alternative Calculation methods.
limited).
d) What is the strategy if a significant release or exposure is detected d) Included in the work document is a radiological monitoring plan including while doing the work? Include, how the overall significance would be action levels. Alerts will be established for Continuous Air Monitors (CAMs) to determined and what actions would be expected to take place including alert the workers before a stop work level is reached. At an alert, an evaluation the actions levels that would necessitate such action, and any additional of the ongoing work will take place to determine if the increase in activity was plans that would be invoked, if necessary. anticipated, and what actions, if any, are needed. Preset levels for alerts will be provided by the radiological controls department. The final WIP will present the Alerts, and actions to take in the event that Alerts are exceeded (including in the event of a significant release).
e) Clarify whether data received early on and/or throughout the e) The radiological data is analyzed each day and approval to proceed by the demolition process will be used to validate parameter assumptions and radiological controls department is required each morning based on the data.
preliminary calculations. Clarify whether there is a feedback mechanism (This approval will be identified in the daily status log by the Radiological to update worker and member of the public risk assessments and to Controls Supervisor (RCS).) Any abnormality in the data will be analyzed and inform radiation protection measures for future activities. addressed the next morning with the work crews.
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Comment WVDP Response NRC Comment Number As part of the approval process with EPA, an emissions study will be conducted during demolition to validate the Alternative Calculation methods for estimating dose to the public.
- 1) On Page 33 of 66 of the Plan, it states, Monitoring during demolition U The 0.02 DAC comes from federal regulations (10 CFR 835) that would of the building includes air monitoring in the vicinity of the demolition trigger mandatory personnel monitoring (100 person-mremlyr) and the actions for radiotogical releases to protect worker health and safety. This contamination levels are the levels for a Contamination Area which the intent is monitoring will also serve as an indication of potential airborne to remain below in the area outside the 3Dm boundary.
hazardous constituent releases. Should releases be detected above preset levels, work will be stopped and additional controls will be For the ambient air monitoring stations, compliance with the dose standard, evaluated and implemented, as necessary. Ambient air monitoring and thereby protection of the public, is determined on a yearly basis by stations located around the perimeter of the WVDP [West Valley comparing potential (major) isotopic concentrations to those listed in the Demonstration Project] will monitor for airborne radioactivity and confirm regulation (4OCFR61 Appendix E, Table 2).
protection of the public.
What am the preset levels, and how am they calculated? Although at the WVDP, ambient air measurement data are examined routinely at multiple times (bench level, monthly, quarterly and annually) the timeliest formal examination of exception& occurs as the sample data is entered into the WVDPs environmental database (the Environmental Laboratory Information Management System, the ELIMS).
For quarterly isotopic data and monthly charcoal data, warning limits are based upon a result exceeding the WVDP contract required detection limiL Alarm limits are based on the quarterly result exceeding 5% of the NESHAP Concentration Level for Environmental Compliance.
For biweekly alpha/beta data, warning and alarm limits are based on sample mean and standard deviation as derived from the network samples collected during the first quarter of operation.
For biweekly sample flow, upper and lower warning limits are based on preset limits:
Upper warning total flow exceeding 1.3 times the biweekly target flow Lower warning total flow below 0.8 times the biweekly target flow.
Any value for alpha/beta, isotopic, or sample flow data entered that is outside of these ranges (warning or alarm) is captured on a LIMS Exception Report that is generated weekly.
g) On page 36 of 66 of the Plan, it states The WVDP [West Valley g) For the first part of the question, please see the first paragraph in the Demonstration Project] submitted a request for approval to EPA response to comment 5.fl, abova
[Environmental Protection Agency] to utilize alternative methodology for radionuclide source-term calculations for air emissions from WVDP The statement on page 36 was intended to communicate that meeting worker demolition activities as permitted by 40 CFR [Code of Federat protection limits will also help protect the public, who are located farther away Regulation] Part 61.g6(b). This request was submitted in January 2016, from active demolition. However, this is not what is relied upon to assure and and following EPA review and approval, calculations will be performed to document proteclion of the public.
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Comment Number NRC Comment estimate radiological emissions and demonstrate compliance with rad I W\.lj1 Response NESHAP [National Emissions Standards for Hazardous Air Pollutants] The EPA has approved an alternative method for estimating emissions from requirements. Results from these calculations will also be used to the demolition activities as it relates to compliance with 40 CFR 61 Subpart H establish worker protection limits to maintain airborne concentrations The alternative method will be used to demonstrate that the emissions from below acceptable criteria at an established perimeter from the active demolition will result in a dose to the maximally exposed individual that would demolition zone. Maintaining this worker protection limit will also be not exceed 0.1 mremlyr. The maximum Federal Limit for an exposed public protective of the public. individual, which is protective of the public, as promulgated in 40 CFR 61 Subpart H is 10 mrem/yr. Therefore, a margin of 10,000% has been What worker protection limits/constraints are being used (e.g., air established based on using the alternative calculation method, concentrations, doses, etc.) and what are their bases?
How do the worker limits/constraints assure that the public will be protected?
h) On page 36 of 66 of the Plan, it states, Radiological surveys will also h) A peer reviewed calculation (CALC-2016-036 VIT Demolition Readiness) be performed and documented following final preparations for demolition identifies the as is activity and demolition readiness. This calculation has including final grout placement and fixative application to walls and other been provided to and reviewed by DOE-WVDP.
surfaces. Air dispersion modeling using these survey results will be performed to confirm and document that open air demolition of the yE The source term developed with the Alternative Calculation is a release source
[Vitrification Facility] can safely commenc& These calculations and term (not an airborne concentration) and does not include any air dispersion.
documentation will undergo internal review by CHBWV [CH2M Hill BWXT All of the radiological inventory estimated based on the surveys will be West Valley, LLC] and also by DOE-WVDP [Department of Energy-West assigned to the Material At Risk (MAR), and the Damage Ralio (DR) in the Valley Demonstration Project]. calculations will be used to account for the inventory that is impacted.
How will radiological survey data be used in air dispersion modeling and To calculate the air concentration, air dispersion calculations must be how will this information supplement or replace other preliminary source performed. Two dispersion models will be used. CAP-SB will be used to term calculations described in Methodology for Radionuclide Source estimate dose to the public, as required by EPA and DOE regulations.
Term Calculations forAir Emissions (mm Demolition Activities?
EPAs AERMOD software will be used to estimate airborne concentrations which are then converted to DAC values for worker protection. AERMOD modeling of residual contamination obtained from radiological surveys will be used to determine if contamination that are encounteredincluding the demolition approaches used in a specific area (Cut, Shear, Break, Drop),
fixative applications, and misting controlswill ensure that DAC objectives are met (0.02 DAC at the perimeter boundary).
In addition, in the case of the Vitrification Facility demolition, AERMOD will also be used to estimate airborne concentrations at an ambient sampler that will be sited at the WVDP for use solely to establish the validity of the methods in the Alternative Calculation.
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- 6) General comment: How will DOE address variability in meteomlogical The calculation to demonstrate demolition readiness for the Vitrification Facility conditions during demolition activities when evaluating potential wother (CALC-2016-036) includes the AERMOD data which uses 5 years of onsite and member of the public risk (and establishing necessaiy controls) meteorological data. A monitoring program will be in place to verify conditions through use of air dispersion modeling? DOE should provide example are within expected parameters.
air dispersion model files (CAP-Ba [Clean Air Act Assessment Package -
19881, and AERMOD) and results used in preliminary calculations. How Per the EPA approval of the Alternative Calculation, a sampler will be sited at will DOE use offsite air monitoring to validate models and demonstrate the WVDP with a sole purpose of validating the alternative calculation compliance with radiological criteria? methods. As samples are taken from this sampler, the onsite meteorological data will be processed for the time period that the sampler was operating during demolition. This meteorological data, along with an estimate of the source term over that period due to demolition, will be input into AERMOD and the results compared against the sampler data. Adjustments in demolition controls and with the Alternative Calculation method can be made based on this data. Note that this sampler will be located on site, near the demolition activities and is not an off-site sampler.
It is expected that the off-site samplers will continue to read at or near background concentrations. Such low values would not provide statistically meaningful data as it related to the Alternative Calculation method for emissions. Therefore, there are no plans to try to correlate the off-site sampler data with the Alternative Calculation method validation.
- 7) On page 8 of 66 of the Plan, it states: The specific D&D The lessons learned (LL) from the specified projects are being incorporated
[Decommissioning & Demolitionj approaches, techniques, work into the Work Instruction Package (WIP) for demolition of the Vitrification sequencing and schedule are based on currently available information Facility. Some of the LL include:
and planning and lessons learned from demolition of the WVDP 01-14
- The WIP for demolition is a multi-phased work package developed to Building. Demolition of the 01-14 Building was conducted as a proof of minimize the resources needed to develop several smaller work concept for safe and compliant open air demolition of a radiological packages to allow the crew to better understand the entire project and building. whats coming next.
On page 20 of 66 of the Plan, it states: Lessons learned from the 2013
- Specific steps and sequencing are detailed in the WIP along with demolition of the 01-14 Building at the WVDP, the Separations Process building diagrams that identify safety and radiological considerations, Research Unit (SPRU) D&D activities at Knolls Atomic Power Laboratory, precautions and notes.
and other DOE facilities will be factored into the planning for the VF
- Utilization of real time air monitors and reviews of daily radiological data demolition, to ensure results are within anticipated limits.
Also, the NRC staff reviewed the summary of the 5 lessons learned
- Careful consideration of dust suppression methods as well as the rate found at https://opexshare.doe.gov/lessoncfm/2014/7/3014406/Open-Air- of application and wind speed and direction.
Demolition-of-Radiologicaily-Contaminated-Building-O1-14-at-the-West-
- Emphasizing the use of stop work authority for any unplanned change Valley-Demonstration-Proiect. . in conditions.
It is unclear what lessons learned were applied and how they were applied to the Plan. Additional LL, have also been implemented during facility deactivation such as:
- Thorough characterization of the facility.
- Utilization of personnel familiar with the facility and associated hazards.
- Application of fixatives to control the spread of contamination.
- Removal of smaller, contaminated items that would be difficult to remove with larger demolition equipment.
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- 8) Page 7 of 66 in the Plan it states, In 2015, the US. Environmental Comment noted. The correct citation will be used in the next revision.
Protection Agency (EPA) approved the use of ambient environmental measurementC pursuant to 40 CFR 61 .93(b)(5) for estimating off-site dose from airborne emissions and to demonstrate compliance with 10 CFR 61, Subpart ft Comment: 10 CFR 61 should be 40 CFR 61.
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ATTACHMENT I ALARA SECTION TO BE ADDED TO THE VITRIFICATION FACILITY DECOMMISSIONING & DEMOLITION PLAN 1750CM8 WD:2017:0001
6.4.1 ALARA As low as reasonably achievable (ALARA) is a philosophy of striving for excellence in the practice of health physics and is an important aspect of radiation-safety regulations. The National Council on Radiation Protection and Measurements has stated ALARA is simply the continuation of good radiation-protection programs and practices which traditionally have been effective in keeping the average and individual exposures for monitored workers well below the limits (NCRP 1993). The application of ALARA clearly includes the consideration of economic and social factors, and thus will inherently be different for different sources or facilities. From 10 CFR 20.1003:
ALA PA means making every reasonable effort to maintain exposures to radiation as far below the dose limits in this part as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest The 10 CFR 20.1103 standard for ALARA is similar to that in DOE-STD-1 098-2008:
10 CFR 835 requires DOE activities to develop and implement plans and measures to maintain occupational radiation exposures as low as is reasonably achievable (A LA PA) [see 10 CFR 835.101 and 835.10011 As applied to occupational radiation exposure, the ALARA process does not require that exposures to radiological hazards be minimized without further consideration, but that such exposures be optimized, taking into account both the benefits arising out of the activity and the detriments arising from the resultant radiation exposures and the controls to be implemented.
The ALARA concept is founded on the professional judgment of radiation-safety managers and personnel and is not, therefore, able to be used as a measure as to whether or not a particular radiation-safety program is adequate in comparison with other programs. Additionally, the ALARA concept does not provide a numerical limit below which the ALARA concept is achieved; ALARA makes every reasonable effort to maintain exposure as far below regulatory limits as possible.
Quantitative ALARA analyses include societal, technological, economic, and public policy considerations.
In addition, these ALARA analyses consider NRC and DOE guidance for performing the following ALARA assessments:
- Identification of possible radiation protection systems, such as alternative operating methods or controls, that is reasonably achievable, The options range from the most rudimentary (base case) to the most technologically sophisticated systems.
- Quantification of exposures and doses to workers and the public in the vicinity of the work through air monitoring and dosimetry.
- Quantification of the economic factors, including the costs of purchasing, installing, operating, and maintaining the radiological equipment, and the potential health effects associated with the exposure of people and any other direct or indirect cost resulting from exposures to radiation during investigations andlor remediation.
- Identification and estimation of other health and non-health detriments and benefits, such as equipment loss and accidents.
- Evaluation of process alternatives using a quantitative cost-benefit analysis, when possible (NUREG-1 530, 10 CFR 50 Appendix I, REG GUIDE 8.37).
- Implementation of the ALARA principles and monitoring of the results.
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The following specific factors were used in performing a quantitative ALARA analysis:
- Dose to workers, the public, and the environment before and during work processes using AERMOD
- Residual dose to the local population (CAP-88 Modeling)
- Applicable alternative processes (treatments, operating methods, or controls) for site investigations or remediation
- Costs for each alternative evaluated compared to standards listed in NUREG-1 530 and/or REG Guide 837
- Societal and environmental (positive and negative) impacts associated with alternatives 175OCMB WD:2017:0001