ML17270A119
| ML17270A119 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, P00M-032 |
| Issue date: | 09/28/2017 |
| From: | Amy Snyder Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Bower B US Dept of Energy (DOE) |
| A Snyder NMSS DUWP | |
| References | |
| Download: ML17270A119 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 28, 2017 Bryan C. Bower, Director West Valley Demonstration Project U.S. Department of Energy 10282 Rock Springs Road West Valley, NY 14171-9799
SUBJECT:
U.S. DEPARTMENT OF ENERGY WEST VALLEY DEMONSTRATION PROJECT MAIN PLANT PROCESS BUILDING DECOMMISSIONING &
DEMOLITION PLAN, WVDP-586, REVISION 1 (DOCKET NO. 05000201 (POOM-032))
Dear Mr. Bower:
The U.S. Nuclear Regulatory Commission (NRC) is responding to the U.S. Department of Energys (DOE) March 23, 2017, transmittal of the subject work plan (Agencywide Documents Access and Management System [ADAMS] Accession No. ML17090A299). Enclosed, please find the NRC staffs comments.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions or need any additional information regarding our comments, please contact me at 301-415-6822.
Sincerely,
/RA/
Amy Snyder, Senior Project Manager Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards
Enclosure:
NRC staff comments cc/with
Enclosure:
P. J. Bembia, NYSERDA
B. Bower 2
SUBJECT:
U.S. DEPARTMENT OF ENERGY WEST VALLEY DEMONSTRATION PROJECT MAIN PLANT PROCESS BUILDING DECOMMISSIONING &
DEMOLITION PLAN, WVDP-586, REVISION 1 (DOCKET NO. 05000201 (POOM-032)) SEPTEMBER 28, 2017 DISTRIBUTION:
G. Chapman C. Barr R. Powell, RI M. Roberts, RI ML17270A119 OFC DUWP DUWP DUWP DUWP NAME ASnyder CHolston SKoenick ASnyder DATE 9-26-17 9-28-17 9-28-17 9-28-17 OFFICIAL RECORD COPY
NRC STAFF COMMENTS ON MAIN PLANT PROCESS BUILDING DECOMMISSIONING & DEMOLITION PLAN, REVISION 1, WVDP-586 Page 15 of 94 Table 2 shows an example of radioactivity levels for several areas based on the characterization data. Data collected are utilized for dose modeling to support demolition sequencing and limits (i.e., maximum number of square feet in a given area that can be removed or demolished in a given time period). Radiological surveys and samples continue to be collected to characterize and make a determination that each area is ready for demolition.
Comment 1: Please clarify the removable fraction for the surficial concentrations listed in Table 2. Please clarify what efforts were made to determine if the materials are volumetrically contaminated (e.g., provide additional detail on sampling and measurement methods).
Page 15 of 94 Also, grout will be placed in below-grade portions of the MPPB and on the 100 foot plant elevation floor (i.e., ground level) prior to demolition, as necessary to reduce the radiological dose to workers and provide a protective barrier during demolition. Additional material such as gravel may also be used to protect the underlying surfaces.
Information on residual radioactivity levels of these surfaces will be collected prior to grouting, but this radioactivity is not included in the dose modeling to support open air demolition since the surfaces will not be disturbed during this demolition.
Comment 2: At this point in the document, it is unclear what portions of the MPPB will remain at the end of the demolition. Clarify the intended disposition of the grouted surfaces; and whether the grouted surfaces will remain or will be removed during this or future demolitions to provide support for the statement that the inventory on the surfaces will not be included in dose modeling because the surfaces will not be disturbed during demolition. Clarify what is meant by providing a protective barrier (i.e., the grout serves as a barrier to prevent damage to below-grade or 100 foot plant elevation surfaces from demolition of above-grade portions of the MPPB, and/or to prevent release of radioactivity).
Page 15 of 94 Table 3 shows the radioactivity levels in two of the areas of the MPPB (Process Sample Cell-2 and Extraction Cell-2) where data have been collected and the determination made that the areas are ready for demolition. This is an example of the data that will be collected for the various areas of the MPPB and used to determine that the overall building is ready for demolition with the implementation of appropriate radiological controls. Calculations using AERMOD and the radioactivity levels for a given area are performed to show that the remaining activity levels are below the maximum that can be left behind to comply with worker dose limits.
B. Bower 2 Comment 3: Data in Table 3 appear to be based on Cs-137 concentrations and the use of scaling factors. Please clarify the basis for and expected error associated with use of scaling factors.
Page 26 of 94 The demolition approach may include the limited use of localized, portable ventilation controls to insure worker protection and public health and safety.
Comment 4: Elaborate on exactly what conditions would require use of temporary enclosures/ventilation during the decommissioning. Specifically, is this approach expected to be necessary during demolition of the structure vs equipment contained within the structure? If so, the plan should include more detail on this subject.
Page 27 of 94 Run-off water will be controlled and dispositioned in accordance with WVDP procedures (e.g.,
treated and discharged through the sites State Pollutant Discharge Elimination System
[SPDES] permitted system). A berm or berms will be set up around the demolition area(s) to provide containment for dust suppression water and precipitation. The water will be tested as directed by site procedures and transferred for treatment through the SPDES permitted low-level waste treatment facility. Efforts will be made to minimize the volume of water by using misting techniques and a surfactant. Storm drain inlets within the bermed area will be sealed.
These practices will effectively control the volume of water to be controlled, as well as avoiding impacts to other systems, including groundwater, to minimize the potential for the spread of contamination both inside and outside work areas.
Comment 5: Please further explain in the plan how water will be collected for testing and how groundwater impacts will be mitigated.
Page 27 of 94 The MPPB floors and below-grade structures will be coated with a fixative and/or grouted, as necessary to maintain dose ALARA, protect the surfaces from damage during demolition, minimize equipment contamination, and deter water intrusion. Prior to placing grout, an engineering analysis will be performed to determine the thickness of grout needed to avoid damage to the underlying surfaces. Items such as filters, cell debris, piping, and miscellaneous equipment with high levels of radioactivity will already have been removed from the building or stabilized during deactivation.
Comment 6: Because the plan does not particularly address the decommissioning of the sub-grade structures nor provide any schedule for their being addressed, elaborate on how the site will be secured/stabilized once the decommissioning in accordance with the plan is complete. Specifically, will the sub-grade structures be enclosed, ventilated, and a mechanism provided for water extraction should it be necessary? If any such approaches are needed, how long will they be needed before the sub-grade structures are decommissioned? If such approaches are not needed, explain why.
B. Bower 3 Page 28 pf 94 If necessary, additional fixatives can be applied during the demolition work process.
Comment: The plan should describe the types of situations or conditions that would cause additional fixatives to be applied.
Page 57 of 94 The WIP will include a radiological monitoring plan with action levels. There will be alerts set up on the Continuous Air Monitors (CAMs) that will alert the workers before a stop work level would be reached. Based on such an alert, the ongoing work will be evaluated to determine if the increase in activity is anticipated and what actions, if any, may be needed.
Comment 7: The plan should clarify how the CAMS will be utilized. For example, what exactly will the CAMs be used to monitor (alpha, beta/gamma, etc.); how will the action levels be established; explain whether the action levels will address all radionuclides potentially emitted; and explain where these CAM units will be located relative to the actual work that will occur under this work plan?
Page 58 of 94 Contamination surveys at the 30 meter perimeter locations will be performed during demolition, and demolition equipment will also be surveyed.
Comment 8: The plan should provide a more detailed description of the 30 meter perimeter sampling locations and contamination survey methods.
Page 60 of 94 The action levels at the perimeter of the site will be 0.02 Derived Air Concentration (DAC) which is the maximum weekly average concentration according to the AERMOD calculation and activity on the deposition mats of 20 dpm/100cm2 alpha and 1000 dpm/100cm2 beta-gamma.
Comment 9: Several times in the plan, the perimeter is referred to rather ambiguously.
Please clarify in the plan, when not already specified, whether the perimeter being discussed is the demolition boundaries (demolition work site perimeter?) as discussed on pages 61 and 62 of the plan, the WVDP perimeter as discussed on page 61, or has some other meaning.
Page 63 of 94 Radiological Characterization of the demolition debris will also be conducted in accordance with WM-210, Waste Stream Characterization for the demolition waste streams and to establish the isotopic scaling factors for the waste. Characterization of the IM containers or other containers of demolition debris will be performed in accordance with WM-250, Waste Container Characterizations and WM-230, Determining Radioactivity in a Waste Package.
B. Bower 4 Comment 10: Please provide WM-210 and WM-250 to NRC for review or otherwise the plan should provide additional details on characterization of the waste and waste packages destined for disposal.
General Comment 11: Because the site has fissile materials and it is apparent that Nuclear Criticality Safety (NCS) will be considered from the attached forms in the plan, the plan should provide a general overview of the NCS program and qualifications of personnel performing this function sufficient to assure that NCS will be appropriately addressed during the implementation of the Main Plant Process Building work plan.