ML20137N843
| ML20137N843 | |
| Person / Time | |
|---|---|
| Issue date: | 04/03/1997 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rowland T ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 9704090067 | |
| Download: ML20137N843 (9) | |
Text
m
.-i
'r
?
,t I
r APR 31997 Mr. Thomas Rowland,' Director
-i U. S. Department of Energy, Ohio Field Office
. West Valley Demonstration Project l
P.O.; Box 191 West Valley, New York 14171
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION MONITORING VISIT MARCH 7-11,1997.
l
Dear Mr. Rowland:
i 4
On March 7-11,1997, a monitonng visit was made to the Department of Energy
- Nu 'ea Serv ce o
any n, th O c ntracto. Spe ifi al y th pur o e of the.
monitoring visit was to review the status of the contractor's program for the operation of the vitrification facility relative to its impact on public health and safety from a radiological standpoint. This visit focused on the conduct of operations and followup to recent events. The monitoring visit was conducted by Mr. Todd Jackson, Project
- Engineer -; West Valley, of this office. Details of this review are provided in Enclosure l1. Some of.the individuals contacted during the visit are indicated in Enclosure 2. Mr.
_j Jackson was accompanied on this visit by Mr. William Tetley of the New York State Department of Environmental Conservation.
j As a result of this review, the monitor determined that the contractor has established I
and nientained controls, processes, and programs, which appear adequate to protect j
public health and safety. Through March 9,1997, the contractor had filled 74 canisters of vitrified high-level radioactive waste.
j i
i If you have any questions about this report, please contact me at (610)337-5200.
i Sincerely, 1
Original S!.owd By:
Bonald R. Della.my Ronald R. Bellamy, Ph.D., Chief Decommissioning and Lab Branch 1
Division of Nuclear Materials Safety
Enclosures:
- 1. Review of the Project Status :
y
- 2. Contact List
\\
OFFICIAL RECORD COPY d
090003'
"" "'"f 4 Rf ; P w IE.27 IMEpp5M.4 i
9704090067 970403 z v, PDR PROJ A
M-32 F9R L
. i w-
. - ~, '. F c
4 T.R.' Rowland, Director l cc w/encis:
1 I
1 P. Piciulo, Program Director, Radioactive Waste Management Program,- NYSERDA.
W. Tetley, NYF DEC:'
i
' State of New York j
i i
e I
l P
L I
i i
J
$1 i
s A
.f 1
l 4
4 G
d
'I i
4
)
OFFICIAL RE' orb COPY C
d k '-
,,+'-
~v
' rr t'*
- '*v'
+~
Y*
1r
l
)
e' T.R. R wl:nd, Dirictor :
)
Distribution:
PUBLIC
- Nuclear Safety Information Center (NSIC)
.W. Dean, OEDO D. Screnci, PAO -
)
G. Comfort, NMSS i
G. Pangburn,'.NMSS NRC File Center -
C. Gordon, RI T. Jackson,' RI i
i l
i DOCUMENT NAME: R:\\WPS\\MLDL\\WVMAR97.LTR To,eceive e copy of tNo document, Indcate in the bos:
'C' = Copy w/o attach /enct
- E' = Copy w/ ettach/enci
- N' = No copy OFFICE DNMS/RI lE DNMS/RI
,l l
NAME -
TJackson/tjj f)
RBellamy/ P '
DATE 04/02/97 04/v/97 04/ /97 04/ /97 L
OFFICIAL RECORD COPY
l 4
I
..O 7
ENCLOSURE 1 REVIEW OF THE PROJECT STATUS -
l The monitor observed selected activities in progress at the site, held discussions with cognizant DOE - West Valley Demonstration Project (WVDP) and West Valley Nuclear l
Services (WVNS) personnel, and reviewed related documentation. This visit was a routine i
periodic monitoring visit to observe site operations and the current status of the project.
l The monitor was accompanied on this visit by Mr. William Tetley, Environmental Radiation c
Specialist from the Bureau of Pesticides & Radiation, Division of Solid & Hazardous Materials, New York State Department of Environmental Conservation.
t 1.0 PROJECT STATUS OVERVIEW DOE and WVNS personnel presented updated status briefings on activities at the site.
l Presentations focused on areas reviewed by the monitor during this visit:
i Current Status of Site Operations 4
f 4
Followup to Previous NRC Monitor Comments t
Followup to Recent Vitrification Operations Events Repairs to Main Stack Effluent Monitoring System I
Recent Conduct of Operations (ConOps) Reviews i
j '
CO, Decontamination Unit Status Plans for Future Work, including the High Level Waste (HLW) Tanks, Processing of Contaminated Site Soil, and Radwaste Shipments Site Environmenta: Monitoring Program Overview Status of the Citizens' Task Force Activities i
'2.0 CURRENT STATUS OF VITRIFICATION OPERATIONS f
j i
Vitrification was apped on March 3,1997, when the melter was placed in idle to perform i
maintenance acti. ties. During the week of March 3, laboratory analytical results were j
expected for completion of Chemical Feed Makeup Tank (CFMT) batch transfer, with i
melter operation expected to begin after satisfactory lab results were obtained. The 75*
l canister had been partially filled before the metter was idled. The monitor observed the survey of a recently decontaminated HLW canister during the week. As of March 3, l
approximately 3 million curies of radioactive strontium and cesium in 22 HLW transfers had j
been moved from tank 8D2 to the Vitrification Facility.
3.0 FOLLOWUP TO PREVIOUS NRC MONITOR COMMENTS WVNS personnel provided the monitor with a current status of actions taken related to the l
i L-.
+
w
- L----
2 comments in the previous NRC monitoring report (dated January 31,1997). WVNS senior management had recently emphasized to management at the site the significance and importance of a renewed commitment to operational rigor. Recent management organizational changes were also described.
A number of specific corrective actions were listed which had been taken to resolve procedure discrepancies. Additionally, a Procedure Compliance Team (PCT) had been formed to systematically address the broader issues of compliance with procedures, and to examine the methods for controlling changes to procedures, including field and temporary changes. The PCT represents a significant enhancement of the scope of the corrective actions and will be described in more detail in Section 6.0 of this report.
Through the renewed WVNS management emphasis on conduct of operations (ConOps) and the mission of the PCT, WVNS had initiated efforts to identify the mechanisms necessary to sustain high performance levels in the conduct of operations. Efforts had begun to better define what procedures require strict adherence, and what degree of worker discretion (if any) is appropriate for different groups of procedures.
One of the responsibilities assigned to the PCT was the review of the system designed to capture personnel input on needed revisions to procedures, to track the status of these issues, to promptly disposition the revision, and to provide closure feedback information to the originator. And finally, the PCT will review communications issues in procedures to assure adequate coordination and control when procedural evolutions are performed from different locations within the plant.
The monitor was provided with a copy of the final report for the analytical and process laboratories. The assessment had been conducted December 3-5,1996 by Rust Federal Services of Hanford, Inc.
4.0 FOLLOWUP REVIEW OF RECENT VITRIFICATION OPERATIONS EVENTS 4.1 November 16,1996, Event Wrap-up WVNS personnel described the immediate corrective actions, all of which had been completed, for the November event in which high level radioactive waste had backed-up into a demineralized water line. The causes and contributing factors for the event were also considered in the recently initiated WVNS management emphasis on ConOps (Section 6.0). Included in the plan for corrective actions was the increased presence in the field by WVNS staff management (minimum objective was two hours per week by supervisors).
The monitor discussed with WVNS and DOE personnel potential objectives and expectations for management personnel to accomplish during the increased field observation time, and will review the area during a future monitoring visit.
4.2 Worker Contamination Event Two individuals were contaminated on February 4,1997, after performing a contamination survey in the Vitrification Facility. As a result of this event, one individual was internally contaminated and a portion of the Vitrification Facility lower east operating aisle was
~
3 contaminated. WVi4S created an investigation team to determine the root causes of the event. Three root c_uses were identified: inadequate utilization / understanding of the available pre-job radiological data used for planning the work (due to erroneous calculations and misunderstandings of the radiological data, the job planning was not adequate);
erroneous conversion calculation of mathematical units and inadequate understanding of the radiological data generated by the survey of component internals; and failure to survey J
the sample swab used to survey the component internals before removing it from the contamination area.
WVNS personnel described additional ongoing actions in the area of radiological controls as a result of the referenced contamination event. An initiative by the Radiation Protection (RP) Department was underway to review Department procedures for correctness, to 2
assure that steps were in correct sequence, and that steps could be followed as written.
Other long-term actions were also being developed related to those already being addressed concerning conduct of operations, including increased management surveillance time in the field. The monitor discussed with WVNS personnel plano for future integration of the ongoing RP Department review efforts into the broader multi-departmental focus of the ConOps and PCT work, which was expected to provide long-term mechanisms to sustain an improved performance level. The RP efforts were in early stages of development at the time of the monitoring visit and will be reviewed again in a future monitoring visit.
6.0 REPAIRS TO MAIN STACK EFFLUENT MONITORING SYSTEM On two occasions during January, problems were encountered with the main stack sampling and monitoring systems due to frozen condensate blocking the lines. On January 15,1997, both sampling and monitoring was unavailable for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 45 minutes due to ice blockage, and on January 20,1997, the sampling line was again blocked by ice for 11 minutes, although monitoring was available for the second event. The cause of the ice formation was determined to be failed heat tracing, which has since been replaced. The heat tracing failed because of its age, and the replacement work also installed a backup circuit which will be available in case the new circuit in service fails. The monitor observed the repaired sample line and heat tracing on the outside of the main stack.
Although data was lost for the periods of equipment failure, WVNS either shut down processes or maintained conditions stable for the duration of the monitor and sampler outages in order to further reduce the chance of any transient causing a release of radioactivity during the time. WVNS did not observe any transients which would have been expected to cause an unmonitored release, and concluded that releases were unchanged (did not increase) during the period. The corrective action to install redundant heat tracing was expected to improve the reliability of the system to prevent a similar failure in the future.
6.0 RECENT CONDUCT OF OPERATIONS (CONOPS) REVIEWS As discussed above, WVNS management had irttiated a re-emphasis of fundamental aspects of the Conduct of Operations, including WVNS corporate guidance and the principles of the DOE Conduct of Operations Manual. Action items had been assigned to
l -l*
4 each senior manager, with implementation status tracked on a weekly basis.
The Procedures Compliance Team (PCT) initiative is a key element of this WVNS effort, and was included as one of the action items being tracked. The monitor discussed PCT activities and plans in detail with Team members. The focus of the PCT began with procedure SOP-00 02, " Preparing, Issuing, Field Changing, and Revising Developmental Procedures, Standard Operating Procedures, and SpecialInstruction Procedures". Several potential areas of improvement had been identified, such as defining and removing barriers to efficient use of procedures, and compliance with procedures. For example, personnel described an issue for administrative changes to procedures in which there are clear typographical errors or editorial problems which do not affect the operational content of the procedure. There had not been an efficient and rapid method to enable field revision of procedures without impacting work, which had appa ently encouraged the development of informal revision processes in the past.
The PCT had also planned an organized and systematic performance-based review of procedures based on direct observation of implementation in the field. PCT personnel have made a significant effort to observe activities with a different perspective than has been used previously, and tr iderstand what incentives and disincentives may exist regarding personnel compliance with site procedures. To date the PCT has been emphasizing sponsorship and involvement by supervisors, content and quality of training, the clear definition of management expectations for workers at alllevels, individual and group
" ownership" or responsibility for each procedure, and the existing degree of personnel ownership and commitment to ConOps principles. As of this monitoring visit the PCT had observed performance of 20 procedures, with plans to cover 7 different operating 1
organizations within WVNS. Radiation controls was not one of the original 7 areas i
identified for review by the PCT, and parallel efforts were ongoing as a result of the February contamination event. At the time of this visit it not been determined how and when the parallel efforts would come together.
The monitor met several times with the PCT team leader and some of the team members i
and found the personnel to be enthusiastic and well-motivated. WVNS senior management expressed a clear and personal commitment of support for the objectives and mission of the PCT.
7.0 USE OF THE CARBON DIOXIDE DECONTAMINATION UNIT A CO, mobile decontamination unit had been in use at the site since late 1996. The unit uses CO, pellets shot at contaminated objects to mechanically remove contamination, with the benefit of not producing additional liquid or solid waste as the pellets sublimate.
WVNS had achieved success in decontaminating a wide variety of objects. Some of the lessons learned about the method included that it has worked better on smallitems, it has not worked well on steelitems, it has been cost-effective for decon of lead (to reduce contamination in preparation for disposal), and to reduce contamination so that equipment can be returned to use in controlled areas. As an example of the method's success, WVNS had decontaminated more than 4700 pounds of lead for free-release and unrestricted use. This lead would have required disposal as mixed waste if it could not have been decontaminated, i
5 8.0 PLANS FOR FUTURE WORK The Monitor reviewed selected plans for future activities, including the high level waste (HLW) tank farm, processing / sorting of contaminated soil, and radwaste shipments. A number of activities were being planned for the HLW tanks such as replacement of failed equipment, decon and removal of an unnecessary heat exchanger, and possible repairs to a mobilization pump, as well as installation of an additional pump, in order to optimize decanting of waste from tank 8D 2.
A large volume of potentially contaminated soil excavated from areas on site is being held in storage boxes at the site. A trial program to manually survey the soilin 13 boxes and sort the contaminated soil had been successful, producing 8 boxes of soil which could be released. WVNS had been exploring an automated method to enable the remaining 1452 boxes to be surveyed, with the objective of completing the surveys by summer 1997.
WVNS made one shipment of radwaste offsite in February,1997. Significant efforts have been focused on waste minimization, including sorting and repackaging of waste stored at the site. Existing storage capacity has become limited, and therefore shipping of some waste for disposal is being done as part of the strategy to optimize available resources for waste storage and handling. Limited shipments are planned as part of the optimization program.
9.0 ENVIRONMENTAL MONITORING PROGRAM WVNS personnel presented an overview of the site environmental monitoring program.
The monitor observed several of the environmental stations where direct radiation exposure rates were measured with TLDs, including TLDs piaced by the NRC. The Monitor obtained coordinate measurements for the locations of these stations, using a portable global positioning system (GPS) receiver.
10.0 CITIZENS TASK FORCE ACTIVITIES The Monitor attended a meeting of the Citizens Task Force (CTF) on Wednesday, March 5, 1997. Other NRC staff participated in the meeting by videoconference from Rockville, Md.
The objective of this meeting was for WVNS and other DOE contractors to present to CTF members information on site conditions and issues, with DOE and NRC personnel available to answer questions.
A 8, /77 7 Project Engineer:
I Todd J. Jac'TonMHP date k
Health Physicist
~
ENCLOSURE 2 1.0 Department of Energy - West Valley Demonstration Project W. Hamel, Operations & Engineering Team Leader T. Jackson, Safety, Health & QA Team Leader B. Mazurowski, Deputy Director-R. Provencher, Associate Director for Operations and Safety-E. Lowes, Regulatory Strategy & Stakeholders Interface Team Leader W. Hunt, Facility Representative D. Cook, Facility Representative 2.0-West Valley Nuclear Services, Inc.
I
- W.~ Poulson, President J. Little, Executive Vice President i
S. McVean, Site Operations Manager R. Fussner, Vitrification Operations Shift Manager P. Valenti, Vitrification Operations Manager D. Harward, Radiation Protection Manager R. Humphrey, Construction and Project Administration Manager W. Chiquelin, Procedure Compliance Team Leader M. Sheridan, Senior Engineer S. Schneider, Environmental Affairs Manager
"~
C. Winkler, Vitrification Facility Engineering Support Manager 1
T. Kocialiski, Project Manager J. Chamberlain, Community Relations Manager l
3.0 State of New York P. Piciulo, Program Director, NYSERDA C. Gurwitz, Regulatory Compliance Manager, NYSERDA W. Tetley, Environmental Radiation Specialist, NYSDEC
[
i 4
)
v 4.
,