ML20148C602

Rept on Preoperational Monitoring of Integrated Supernatant Treatment Sys,Liquid Waste Treatment Sys,Cement Solidification Sys & Radwaste Treatment Sys at West Valley Demonstration Project,Jan 1988

ML20148C602
Person / Time
Issue date:	01/31/1988
From:	NRC
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ML20148C551	List: ML20148C545 ML20148C575 ML20148C602
References
REF-PROJ-M-32 NUDOCS 8803220448
Download: ML20148C602 (32)

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, , . .? $9, > . acnn h REPORT ON THE PREOPERATIONAL MONITORING OF THE INTEGRATED SUPERNATANT TREATMENT SYSTEM, LIQUID WASTE TREATMENT SYSTEM, CEMENT SOLIDIFICATION SYSTEM AND THE RADWASTE TREATMENT SYSTEM AT THE WEST VALLEY DEMONSTRATION PROJECT JANUARY 1988

1. Introduction In accordance with the West Valley Demonstration Project Act of 1980, the Nuclear Regulatory Commission (NRC) is required to monitor the Project from the standpoint of the health and safety of the public.

On December 10, 1987, we informed the West Valley Department of Energy Project Office (DOE or the Department) of our intention to visit the Project site to monitor the operational readiness of the Supernatant.. -

Treatment, the Liquid Waste Treatment, the Cement Solidification and the Radwaste Treatment Systems. During the January 4-8, 1988 visit, we also monitored several administrative controls associated with safe operation of the facility and the programs related to offsite monitoring of radio-active materials. Earlier monitoring visits were undertaken at the site during March 1983, August 1985 and September 1985.

The programs reviewed by the Monitoring Team were established by the DOE contractor, West Valley Nuclear Services, Inc. (WVNS), a subsidiary of the Westinghouse Electric Corporation, in accordance with applicable DOE Orders. The Department provided us with the appropriate DOE Orders and WVNS Program Manuals including the Policy and Procedures Manual. We evaluated the programs in accordance with good laboratory and industry practices, and the guidance provided to us t.r/ the Department.

The intent of this report is to make observations and/or recommendations, as appropriate, to the Department on possible improvements to the pro-grams reviewed based on our direct observation of your programs and our experiences with other similar programs. In making observations during our visit, we considered the unique nature of the Project, both with respect to the technical approach taken and the fact that those systems

! will be operated for only about two years prior to dismantlement. Our intent was to focus on hardware quality and programs in systems important to the safety of the public to obtain a "vertical slice" perspective of that item or program. As such, any observation or recommendation made concerning any one program or item should be reviewed for possible implications with respect to the other programs or items at the site.

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2. Observations - Recommendations

a. Procedure Control (1) All SOPS need to be revised to reflect changes in position titles and functional responsibilities resulting from a recent organizational change.

(2) SOP 00-1, "Control of Facilities Work Instruction Documents",

and S0P 00-2, "Guidelines for the Preparation of Facilities Work Instruction Documents", should be revised to delineate the organizational units for document control so that there is no confusion with regard to authority and responsibility.

(3) The Document Control System should provide for the review and.

revision of documents on an established time cycle to assure that they are applicable to current operations.

(4) A time limit should be established for requiring the inclusion of field changes into an SOP. -

(5) 50P 00-1 and/or 00-2 should be revised to define minor changes to procedures that do not require the complete review cycle and should also specify review requirements for each type of procedure.

(6) Safety Committee procedure review requirements should be clearly stated in 50P 00-1 or 00-2.

b. Training (1) Assure that the training program for supervisory, management and professional personnel is clearly defined.

c. Welding (1) DOE and its contractor should Write nonconformance reports (NCRs) on inadequate shop and field radiographs associated with the 802 to STS piping.

1 Conduct a review of all 802 to STS piping radiographs by a LEVEL III radiographer qualified to read the films.

Identify each finding that does not meet code requirements or applicable documentation guidelines.

Resolve findings with particular attention to conformance of welds to code requirements and ability of radiographs to I indicate the size and significance of indications.

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Review findings to determine disposition of each radio-graphic problem and any indications found.

Conduct a final evaluation by engineering and responsible NDE personnel to determine if piping is suitable for the intended service.

Sample radiographs for the balance of the plant piping to determine acceptability.

Provide a report of the above activities to the NRC for review prior to use of the pipe with high level radioactive fluid.

d. Quality Assurance -

(1) Establish an audit program to assure that all aspects of the QA Program are reviewed at an established interval and that the 002.-

Project Office request that more frequent and more comprehensive audits of the contractors QA Program be conducted by DOE-Idaho.. ,

(2) Establish a program to assure that all off-site vendor fabri-cation facilities are audited to ensure proper implementation of their respective Quality Assurance requirements and initiate a program to assure that on-site QA audits of contractors are conducted.

(3) Provide each manager with current position description that defines their authorities, duties and responsibilities.

(4) Establish an approved records storage capability or other procedurally controlled strategies at the site to provide interim protection of those records from the time of generation to the time of transfer to the approved records storage facility in Buffalo.

(5) Provide instructions in vendor specifications to assure that stainless steel components are properly stored to prevent chloride contamination.

(6) Clearly identify which NQA-1 revision was to be used in order to preclude confusion on the part of WVHS Project personnel,

e. Ventilation Systems (1) Evaluate the effect of not conducting all required ventilation system tests on those systems that cannot be tested.

(2) Reevaluate iodine-129 releases on the basis of ALARA to det ar-mine the advisability of installing charcoal filters into the ventilation systems.

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4 (3) Interlock the entrances to the STS ventilation system filter room to assure that both doors cannot be opened simultaneously.

(4) Evaluate each ventilation system to determine the effects of a fire and to determine if fire detection and/or suppression systems are required.

f. Effluent Monitoring (1) Evaluate sampling line losses for each ventilation system, that has been equipped with line splitters, during initial startup testing with radioactive material so that actual releases from the stacks can be calculated.

g. Effluent Sample Analyses (1) Establish proper procedures to minimize counting uncertainties when calibrating instruments.

(2) Assure that appropriate calibration standards are being used.

(3) Use a gamma spectrometry counting geometry which will improve the photon efficiency and permit the use of a larger sample volume, such as a Marinelli beaker.

(4) Use the charcoal cartridge collection efficiency in the calculation of I-129 in ef fluent releases.

(5) Establish control charts for all counting instrumentation.

(6) Prepare a quench curve for the liquid scintillation counter using the same cocktail and sample volumes used for sample I analysis.

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(7) Provide adequate laboratory work space.

(8) Participate in an interlaboratory QC program, such as the EPA crosscheck program, which provides crosschecks at a fixed frequency with samples containing activity levels near those j being measured.

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h. Emergency Planning (1) Clarify the Emergency Plan to state the intended purpose of l the plan with respect to expected offsite response. Any imple-l menting procedure dealing with offsite protective response recommendations should be revised accordingly.

(2) The specific size of each Emergency Planning Zone (EPZ) should be determined on the basis of FSAR worst case accidents and hazards.

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5 (3) The Plan was prepared in accordance with DOE Order 5500.2 which was cancelled on February 26, 1987. Although draft (replacement) orders were available, official guidance to be used for future revisions of the Plan could not be identified and should be provided to the contractor.

(4) Quantify each emergency initiating condition with a specific instrument reading or severity level to allow discrete gradations of response actions.

(5) Assure that the classification of security incidents are consistent with the requirements of the 00E Orders.

(6) Reference to the General Emergency classification should be deleted from the Plan.

(7) Consider having radiation detection instruments available for use at the medical facility in order to facilitate surveys of contaminated injured individuals during medical emergencies.

(8) The Letter of Agreement with the West Valley Volunteer Fire Department should be updated and should describe what support is expected.

(9) Provide a formal mechanism to highlight deficiencies found during drills and to ensure deficiencies are corrected.

i. Fire Protection (1) Isolation valves on two pressure switches associated with the fire pump controllers and the diesel engine cooling water supply line should be supervised or locked open.

(2) Equip the pump house with an emergency light.

(3) Assure that the fire fighters' gear stored in the pump house was not missing gloves, flashlights, etc.

l (4) A fire in the pump house would damage both fire pumps and leav'e the plant unprotected.

(5) A wrench used to operate the cascade air supply for the fire fighters SCBAs was not chained, and was subject to misappro-priation or loss.

(6) Assure that the fire equipment cabinet, located outside the door to this area, and used to store fire fighting gear such as l hoses, wrenches, etc., remains accessible when snow is present.

(7) Reduce the quantity of flammable liquids stored in the laboratories to a one to two month supply.

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6 (8) Install hard piping or tubing between the acetylene tank and equipment located in the third floor laboratory.

(0) Evaluate the fire suppression system installed in the Lubricating Oil Storage Room to assure that it is adequate.

(10) Ground the skid used to hold dispensing 55 gallon drums of flammable liquids in the Lubricating 011 Storage Room.

(11) Improve housekeeping in the Lubricating Oil Storage Room to reduce the fire load.

(12) Assure that the cabinets containing flammable materials in the Test and Storage Building are installed and used in accordance with NFPA guidance.

(13) Evaluate the effect of a fire in the electrical switchgear room and subsequent loss of electrical power to all facilities, including ventilation systems, at the site.

J. Industrial Safety (1) Post standard design "Caution - Laser" signs where required.

(2) Evaluate the effects of inadvertent mixing of incompatible chemicals as a result of a spill from the tanks located to the east of the main process building.

3. Administrative Controls

a. Procedure Control Ouring a previous review of ventilation systems conducted on October 19-22, 1987, members of the Monitoring Team determined that individual procedures for the conduct of Dioctyl Phthalate (DOP) tests on High Efficiency Particulate Absolute (HEPA) filters asso-ciated with five different ventilation systems were not consistent.

As a result, the Monitoring Team questioned the processes for the preparation, review, and distribution of procedures to' assure that j they are consictent. As a result of this observation, WNS personnel l initiated actions to improve the facility docum:nt control systems.

The Monitoring Team noted during this review that implementation of those corrective actions appears to be improving the docuent control system so that a recurrence of the problem identified above should not occur.

An indepth review of the site document control system was conducted during the current visit. That review consisted of a detailed examination of the basic documents, S0P 00-1 with three field changes and S0P 00-2 with four field changes, which prescribe the document control system. The Standard Operating Procedures (S0Ps), Standard t

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Implementing Procedures (SIPS), field changes, work orders (W0s),

and drawings associated with the LWTS and CSS were then reviewed to ascertain adherence to SOP 00-1 and 00-2 requirements.

The following observations and recommendations were made by the Monitoring Team with regard to procedure control:

All SUPS need to be revised to reflect changes in position titles and functional responsibilities resulting from a recent organizational change.

S0P 00-1, "Control of Facilities Work Instruction Documents",

and SOP 00-2, "Guidelines for the Preparation of Facilities Work Instruction Documents", should be revised to delineate the organizational units for document control so that there is no confusion with regard to authority and responsibility, i.e., Operations Support Document Control, Project Engineering Document Control, and Records Management Document Control.

While the personnel involved with the procedures understand the controls, new personnel or personnel not routinely involved with the document control system may inadvertently be furnished with incomplete procedures or with procedures that are not the latest revision.

The Document Control System should provide for the review and revision of documents on an established time cycle to assure that they are applicable to current operations.

A time limit should be established for requiring the inclusion of field changes into an SOP.

SOP 00-1 and/or 00-2 should be revised to define minor changes to procedures that do not require the complete review cycle and should also specify review requirements for each type of procedure.

Safety Committee procedure review requirements should be clearly stated in SOP 00-1 or 00-2.

In general, the team determined that the Document Control System, as it exists, adequately controlled all of the procedures reviewed.

b. Training Programs One of the most important aspects for the successful operation of a facility is the proper training of individuals. In order to evaluate the facility training program, the Monitoring Team attempted to answer the following questions:

Are there policy documents requiring personnel training?

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Are all elements of an adequate program present?

Are the requirements effectively reduced into training and lesson plans?

Is the training being performed?

Are audits of the program performed, are they effective, are they reviewed and are findings resolved in a timely manner?

Through examination of records and discussions with DOE and DOE contractor (WVNS) personnel, the Monitoring Team determined that the 00E contractor was required to meet the requirements of 00E Orders that establish policy for all phases of facility operation.

The contrac'.or established the training policy in concert with the site Quality Assurance Program. That training policy is described in Procedure QM 2-1 dated November 20, 1987, "Training and Indoctrination." Implementation of the training policy is further defined in the site Policy and Procedures Manual under Procedure Number W-538, dated July 17, 1987, "Personnel Indoctrination and Training." That procedure defines the specific responsibilities for all training activities at the site. The document states that the program (department) managers are responsible for developing training programs for their personnel based on the perceived training needs as defined by that manager. These training plans are submitted to the Training Department who is responsible to provide the training. In some cases, technical training is provided within the program group, i.e., health physics and laboratory technician training.

The team determined that the training policy and the procedures were-adequate to provide acceptable training in all program areas except the training of supervisory, professional and management personnel.

Training for plant operators was generally acceptable and the "specifications" (qualification standards) had been developed to provide the training necessary to perform a job. Training records showed that, except for two isolated cases, operator training had been completed as requi 1 With regard to superviso.y, management and professional personr , few training plans or "specifications" had been prepared by management and submitted to the Training Department for implementation. This problem was first noted dur-ing a 00E-Idaho audit conducted in 1984. Subsequent 00E audits and internal WNS audits identified that the problem still existed as late as November 1987. The team determined that the Training l l Department had attempted to resolve the problem but has not received

_ adequate cooperation from the program managers. i l

l The team also examined selected qualification standards established I for plant operators. They were well written and comprehensive. In l addition, the lesson plans in several subject areas within the qualification standards were reviewed. They also were well written l

and were presented in an organized, understandable manner. Several )

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instructors were interviewed. They appeared to be qualified to #

instruct their assigned course.

In summary, the training program at West Valley has been successful in effectively training personnel that will be required to operate the processes. Documentation is present to show that this has been accomplished. However, the required training courses for super-visory, management and professional personnel has not been clearly defined. As previously stated, this.is an uncorrected criticism of the facility training program that has been identified during pro-gram audits since 1984. The Monitoring Team recommended that WNS management immediately take actions to immediately correct this ongoing deficiency in the training program.

4. Operational Controls

a. Welding (1) Welding Program Review The WNS welding program was reviewed in detail as part of a previous Monitoring Team visit during July 1985. At that time, the team determined that WNS and its subcontractors were not following all welding procedural requirements and certain good welding industry practices. During the current monitoring visit, the Monitoring Team examined changes made in the weld-ing program as a result of the previous visit and evaluated the corrective actions and significance to plant safety of the previously identified welding problems. Subsequent to the 1985 visit, WNS added a full-time welding engineer to the Quality Assurance staff and modified the WNS welding program controls.

Upon review of the implemented welding program controls, the Monitoring Team concluded that WVNS presently has a welc'ing program in place that can avoid procedural and performance weld problems typt:al of those identified in 1985.

The Monitoring Teau also determined that WNS apparently took adequate actions to correct previously identified field welding problems. For instance, problems related to weld root pass burnthru and improper or inadequate root pass purge gas coverage were properly investigated as indicated by a review of available test results.

(2) Examination of Tank 802 to Supernatant Treatment System (STS)

High Level Liquid Waste Piping The piping between 802 and STS consists of three double wall lines (2 inch diameter pipe inside a in 4 inch diameter pipe) and one single wall (2 inch) drain line all contained inside a 20 inch diameter schedule 40 pipe. This piping is 304L

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10 stainless steel, built to the ANSI B31.3 "Code for Chemical Plant and Petroleum Refinery Piping". The inner pipe of the double wall piping is designated as Class M, 831.3 and is intended to safely carry the highly radioactive supernatant fluid from tank 802. The Monitoring Team reviewed construction practices, Quality Assurance, Quality Control, Nondestructive Testing (NDE) records, construction records (work travelers) and conducted interviews with personnel involved in those activities.

The piping shown on Drawing 1044-86-D2 was shop fabricated by the Rovanco Corporation, with field installation by the Quackenbush Company. Work travelers for field welding, visual inspection penetrant examination (PT), compilation of radiography and control of nonconformances appeared to be complete with appropriate signoff by supervision and Quality Control inspectors. The purchase requirements and test reports for PT materials and marking pens for use on piping indicated that controls were in place to prevent contamination ofithe piping by material with a potential to cause pipe degradation, such as chlorides. .y ,

With regard to radiography (RT) of the inner (2 ") process fluid radioactive piping, the Monitoring Team noted that WVNS or its subcontractors did not conform to several of the RT requirements specified in ANSI B31.3 or the ASME Code Section V, Article 2, in that for:

Shop Radiography (29 welds) - Rovanco

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For Radiographs 1 through 24, the geometric unsharpness (Ug) and the penetrameter and weld densities were not shown on the RT reader sheets.

Radiograph marked #24 is most likely #29.

Radiographs marked #25, 26, 27, 28 and 29 are dated 1986. The radiography was performed in March 1987.

The radiograph of weld number 11 showed a section of weld wire approximately 1" long stuck to the inside l

of the pipe on one end. The RT reader sheet did not provide a record of this condition. This weld is on the drain piping such that if the wire dislodged, it would not get caught in a valve.

The penetrameter 4T holes were not visible or were poorly defined on Radiographs 1 through 10 and 19 through 24.

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11 g, Field Radiography (204 welds) - Quackenbush The penetrameter on the radiographs was placed on the film side and requires an "F* marker Of the radiographs sampled, "F" did not appear on hdto-graphs RV-2, 4, 23, 24, 42 and 63.

The ASME Code Section V, Part T291, requires the detail of the radiographic examination setup to accompany the radiographs. This detail did not .

accompany the radiographs.

The above radiographic problems were described on a Nonconform-ance Report (NCR) prepared during the week of January 4,1988, following identification by the Monitoring Team, and review of the radiographs and documentation was initiated by the contrac-tor's responsible NDE Level III. Through discussions with the NDE Level III and a review of records, the Monitoring Team determined that the Level III has extensive experience in, and has demonstrated proficiency in, specifying, training, prepar-ing and performing nondestructive examination teckiques, ande..

evaluating test results in eccordance with applicable industry practices, Quality Assurance standards and codes and WVNS policies, procedures and written practice on NDE. He was certified by letter to WVNS management dated November 6,1987 and his areas of qualification include radiography (RT), ultra-sonics (UT), magnetic particle (MT), liquid penetrant (PT) and eddy current (ET) inspection methods, plus visual testing (VT) and the bubble method of leak testing (BT). That certification is valid for five (5) years following the date of qualification.

The nonconformances with the code in regard to radiographs identified above were discussed at the exit interview on January 8, 1988. The Monitoring Team was informed that, on the basis of the preliminary review by the responsible NDE Level III, no unacceptable defects were present in the radio-graphed welds. This preliminary conclusica was concurred in l by the Monitoring Team with respect to those radiographs that I

were examined by members of the team.

Examination of testing documents for the 802 to STS piping run indicated that each section of the pipe was hydrostatically pressure tested to a minimum of 275 psig. Through this method, it was determined that no significant leaks were present in the pipe. In fact, sections of pipe in other parts of the system (pipe run 04-9) were pressure tested to 450 psig following repair of a poor weld.

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e . - y *n . c ;.y y 12 As a result of the above observations, the Monitoring Team recommended that DOE and its contractor should:

Write nonconformance reports (NCRs) on inadequate shop and field radiographs associated with the 802 to STS piping.

Conduct a review of all 802 to STS piping radiographs by a LEVEL III radiographer qualified to read the films.

Identify each finding that does not meet code requirements or applicable documentation guidelines.

Resolve findings with particular attention to conformance of welds to code requirements and ability of radiographs to indicate the size and significance of indications.

Review findings to determine disposition of each radio-graphic problem and any indications found.

Conduct a final evaluation by engineering and responsible .

NDE personnel to determine if piping is sui. table- for the intended service.

Sample radiographs for the balance of the plant piping to determine acceptability.

Provide a report of the above activities to the NRC for review prior to use of the pipe with high level radioactive fluid.

(3) Examination of Supernatant Treatment System (STS) to Liquid Waste Treatment System (LVTS) to Cement Solidification System (CSS) Piping The work travelers and Nondestructive Examination (NDE) records, including selected radiographs, for the STS to LWTS and LWTS to CSS piping were examined by the Monitoring Team.

No inadequacies were identified with the work travelers or the NDE records. In addition, the procedures prepared to facilitate pipe bending and Quality Control inspection of the bending were reviewed. That review indicated that WVHS provided adequate controls on pipe bending activities at the site.  :

(4) Field Observations The Monitoring Team visually examined portions of new system ,

piping to observe application of the pipe bending and welding i procedures. Those pipes examined included the exterior of the l 20 inch protective pipe on the 802 to STS line, piping on both sides of the STS valve aisle and sections of other new system piping. Visual examination of the external areas of the pipes

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indicated that the welding appeared to be performed using good workmanship and bends were of good quality.

(5) Liquid Waste T-eatment System (LVTS) Anchor Bolts On April 24, 1987 the Quality Assurance Manager was advised that certain tank anchor bolts had been improperly installed into the concrete wall of the XC-3 area of the facility during installa-tion of tanks as a part of the LVTS Phase 1 construction in that the anchor bolts were inadequately welded to a backing plate instead of being installed into the wall. This occurrence was documented in Unusual Occurrence Report No. WVHS-87-11-LWTS-2.

The Monitoring Team reviewed documents describing the event, the scope ^f the problem, and corrective actions taken by the contractor, WVNS. This problem appears to have been adequately investigated, the scope was adequately defined, the effect on structural integrity was evaluated and adequate corrective actions were taken. The Monitoring Team had no further ques-tions on this issue. N u-

b. Quality Assurance -

Examination of Quality Assurance and control implementation was made through a review of the Supernatant Treatment System's (STS) design, construction, installation and testing. This review focused on the piping run between the high level waste storage tank 802 and the STS as previously described in Paragraph 4.a(2). The review also included a visual inspection of the accessible portions of the installed piping, interviews with cognizant personnel, reviews of quality documentation and records, reviews of QC and QA staffing and program, reviews of onsite WVNS QA audits and QC activities, and reviews of external audits.

(1) h'VNS Quality Assurance program The WVNS Quality Assurance program was restructured on September 10, 1986 to establish a graded approach to quality assurance in order to provide control over items commensurate with importance to safety and consequences of failure. A*

classification of items is incorporated into the QA program by definition and a Q-list (Quality list) has been provided to identify the specific classification of each item. The restructured program readily permits the contractor to focus limited resources on those items of importance to public health and safety. The QA program is designed to implement the 18 criteria of ANSI /ASME NQA-1-1983.

The WVNS QA program is further defined through the use of a Quality Management Manual and a series of WNS policies, procedures and instructions.

P QMWsne 4%%W4 aid 14 During the monitoring visit conducted in July 1985, NQA-1-1979, "Quality Assurance Program Requirements for Nuclear Facilities,"

was identified as the controlling document. A September 10, 1986 WVHS Quality Assurance Program Plan specified the NQA-1-1983 revision as the controlling document. During dis-cussions with the QA Manager, the Monitoring Team was informed that the QA program has been upgraded to the requirements of NQA-1-1986; however, no formal directive has been provided to QA department personnel to document use of the 1986 revision.

In additin, several other QA dvartment documents referred to the use of the 1979 and 1983 revisions. As a result, the Moni-toring Team recommended that WVNS clearly identify which NQA-1 revision was to be used in order to preclude confusian on the part of WVNS project personnel.

(2) WVNS Quality Assurance Organization and Staff The WVNS Quality Assurance organization was recently restructured and the Quality Assurance Manager currently has three organizations reporting to him as follows: Quality Engineering, Inspection Services, and Analytical and Process -

Chemistry. The Monie: ring Team reviewed staffing of the Quality Engineering and Inspection Services organizations. The Quality Engineering group c6nsisted of a manager and five Quality Engi-neers in addition to one temporary college student. There was one unfilled quality engineering vacancy. The manager stated that his staff was expected to be increased by two positions during 1988. The Inspection Services group consisted of a manager, one construction quality control engineer and five technicians. The manager stated that a staffing increase of one technician was expected in 1988 and six technicians in 1989.

A review of the functional responsibilities of the three organi-zations under the QA manager by the Monitoring Team indicated that none of the QA organization managers were provided copies of current position descriptions defining their authorities, duties and responsibilities. This is contrary to requirements of NQA-1. Therefore, the Monitoring Team recommended that WVNS provide each manager with current position descriptions that define their authorities, duties and responsibilities.

Qualification and training records of QA lead auditors and QC technicians were selectively checked. All were found to meet qualification requirements.

(3) Quality Assurance Audits Through discussions with WVNS personnel and a review of records, the Monitoring Team determined that a management plan did not exist to assure that a sufficient number of QA audits of Project

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1 activities were conducted to provide comprehensive coverage of I all aspects of the quality assurance program including the NQA-1 1 18 Basic Requirement criteria.

As a result of the review of scheduled and completed audits for 1986 and 1987, the team determined that not all NQA-1 18 criteria had been audited. This is contrary to NQA-1, 1 criterion 18. As a result of this review, the Monitoring Team concluded that WNS audits, both external and internal, were not  ;

frequent enough or comprehensive enough to prr vide management with responsive feedback upon which to base prompt corrective action for identified deficiencies. During an examination of external audits of the WVNS QA Program, the team determined that only one DOE-Idaho audit and no Westinghouse Corporate audits were conducted on Project activities during 1987. Even that one DOE audit did not evaluate WVNS actions concerning all eighteen NQA-1 criteria. Since the lack of audit coverage of all aspects of the QA program provides the opportunity for deficiencies to exist for extended periods of time in uncovered areas, the Monitoring Team recommended that WNS establish an audit pro-gram to assure that all aspects of the QA Program are reviewed at an established interval. In addition, it was recoun6nded that the 00E Project Office request more frequent and more comprehensive QA audits be conducted by 00E-Idaho of the contractor's QA Program.

(4) WVNS Quality Control (QC) Program Since the NRC monitoring visit in July 1985, WNS has made a marked improvement and upgrade to provide quality control over the site construction work to comply with ANSI /ASME NQA-1, "Quality Assurance Program Requirements for Nuclear Facilities."

The WVHS QC inspection coverage of site construction work was found to have been augmented with contractor personnel.

Monitoring Team review of selected completed STS work indicated that the WVNS QC effort was well documented. Through interviews with persons involved, the Monitoring Team substantiated that the overall QC coverage of construction work was in accordance with the WVNS QA program.

(5) WNS Quality Assurance Program Records Storage The Monitoring Team conducted a review to ascertain that important-to-safety records which furnished documentary evidence of quality were being legibly prepared, were identifiable and retrievable, were controlled, maintained, stored and protected.

Specific observations were made regarding the above attributes during the course of the NRC monitoring visit as records were examined. In addition, interviews were held specific to record ,

handling and storage. WVNS Policies and Procedures Manual l

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procedure W-730, "Records Management and Storage," and the Quality Management (QA) manual, procedure QM 17, "Quality Records," provide the management controls for complying with NQA-1, Criterion 17.

From interviews with records management personnel, the Monitor-ing Team determined that approximately 441 boxes and 274. rolls of microfilm of quality records had been sent to an approved record storage facility in Buffalo, New York. It was also determined that approximately 130 boxes of quality records remained on-site without being located in an approved record storage facility. Several fire resistant safes were noted to be in use on-site. However, there was no approved interim record storage facility on-site. The existing on-site records storage practice did not meet the intent of NQA-1, Criterion 17,.

regarding protecting on-site records against potential damage, deterioration, or loss. The Monitoring Team racommended that the contractor either establish an approved records storage capability or implement other procedurally controlled. strategies at the site to provide interim protection of those records from the time of generation to the time of transfer to the. approved records storage facility in Buffalo, for example, duplicate records in separate locations until records are placed in an approved storage facility.

(6) WVNS Quality Assurance Program Implementation As previously discussed in Paragraph 4.a(2), the Monitoring Team selected the high level liquid waste piping between the 802 tank and the Supernatant Treatment System (STS) for examination to verify the quality of the piping installation at the facility and the implementation of the QA Program. During this review, the Monitoring Team determined that WVNS contracted construc-tion and installation of this piping to the Quackenbush Company, Inc. Quackenbush subcontracted shop fabrication of the piping to Rovanco Corporation, Joliet, Illinois. Rovanco in turn sub-contracted to Magnaflux (HQS) to perform radiography on the shop welds made on the piping. Quackenbush retained responsibility for installation of the shop fabricated piping'at the West i Valley site.

t As a result of this review, the Monitoring Team determined that the Quackenbush QA program at the West Valley site was implemented. However, there is no documented evidence that Quackenbush conducted overview QA audits of Rovanco's pipe l fabrication work at the Joliet, Illinois facility or of the

{ NDE subcontractor, Magnaflux (MQS).

In addition, although there is sufficient documented evidence that WVNS followed installation work from a quality control perspective at the West Valley site, WVNS conducted no vendor QA i

I

MetN4i M.MN M) 17

~I audits of Quackenbush either on-site or off-site. WNVS also did not conduct quality contro? type inspections and surveillances at Quackenbush or Rovanco off site facilities. Failure of WNS to conduct QA audits of the Quackenbush QA program implementation both on-site and off-site is contrary to NQA-1, Criterion 18, which specifies "that audits shall be performed to verify compliance with all aspects of the quality assurance program and to determine its effectiveness." The lack of QA audits may have contributed to failure of the WVNS QA Program to identify the recordkeeping and documentation code violations identified by the Monitoring Team. This similarly applies to Quackenbush's QA program's failure to conduct audits / inspections of Rovanco and its subcontractors. The Monitoring Team recommended that WVNS establish a program to assure that all off-site vendor fabrication facilities are audited to ensure proper implemen-tation of their respective Quality Assurance requirements.

Similarly, WVNS should initiate a program to assure that on-site QA audits of contractors are conducted.

(7) Storage of Materials The Monitoring Team examined documents associated with the STS piping to determine if requirements have been established to preclude chloride contamination of the stainless steel piping.

The STS specification did not specifically address controls to preclude chloride contamination of stainless steel piping and there were no specific QA or QC surveillances identified that specifically addressed the subject. However, the Quackenbush QA program in item 8.2 addressed "Storage of Items and Materials" and Quackenbush QA surveillance reports did require corrective action for stainless steel piping and fittings that were found improperly stored. The WVNS specification for STS was viewed to be weak in the area of preventing chloride contamination of stainless steel piping. The Monitoring Team recommended that the VVNS specification be improved relative to preventing potential chloride contamination of stainless steel piping.

c. Ventilation Systems The Monitoring Team examined the ventilation systems for the Plant Ventilation System (PVS), Cement Solidification System (CSS),

Supernatant Treatment System (STS), Contact Size Reduction Facility (CSRF) and the Supercompactor. The PVS and CSS ventilation systems were a part of the original reprocessing plant systems and radio-logical conditions precluded visual examination by the team. All of these systems are 00P tested in accordance with ANSI N 510 on an annual cycle or whenever the pressure drop requires a filter change.

The STS ventilation system was designed by MSA, the CSRF ventilation system was designed by Charcoal Services Corpnration and the Super-compactor ventilation system was designed by .ittman Nuclear.

. #8M9.;$M57fM$an$Whe 18 1 Through discussions with W15 personnel, the Monitoring Team determined that each operating group within WNS was responsible for the design, construction, installation, and operation of their assigned ventilation systems. As such, the design considerations and operating procedures vary from system to system.

On the basis of a detailed evaluation of the CSRF ventilation system, the team determined that the design requirements of ANSI N 509 had been incorporated but that the means for testing per ANSI N 510 was limited to in place Dioctyl Phthalate (DOP) mist tests. Table 1 of ANSI N 510 "Tests cnd Recommended Test Frequency," states that Airflow Capacity and Distribution and Air-Aerosol Mixing Uniformity Tests are required on acceptance after initial construction and after major system modification or repair. However, no provision was made by WVNS to perform these tests. In addition, none of.the ventilation system procedures reviewed called for performing a visual inspection.

That visual inspection is required prior to the conduct of any test on a ventilation system. The Monitoring Team concurred with the WVNS staff that radiological conditions preclude visual inspection on the PVS and CSS. However, -the ventilation systems for the remain-ing units were accessible and visual inspections should be performed.

During a review of STS and CSS safety analysis reports, the team noted that each report required that the applicable ventilation system be tested in accordance with the ANSI N 510 requirements.

However, as stated above, several of the required tests were not conducted. As a result, the Monitoring Team recommended that WVNS conduct an evaluation if the specific ventilation system tests required by the Standard are not conducted.

The Liquid Waste Treatment Systee (LWTS) processes the liquid radioactive supernate from the STS and provides process water to the CSS. The LWTS ventilation system is connected to the PVS via the Vessel Off-Gas (V0G) system located in the fc cmer reprocessing plant. The V0G system consists of a condenser, scrubber, heater, HEPA filter and exhaust. Exhaust air passes through a second HEPA filter bank before release. There are no charcoal absorber beds installed in this ventilation system. Since there were no charcoal beds installed, the Monitoring Team requested information relative to the projected release of iodines from this facility during operation. The contractor stated that the projected releases of iodine-129 amounted to 300 percent of the current DOE and NRC limits or about 87 percent of the proposed 00E and NRC limits.

The Monitoring Team recommended that the iodine-129 releases be

[

reevaluated on the basis of ALARA (as low as reasonably achievable)

! concepts to determine the advisability of installing a charcoal l filter into the System.

The High Efficiency Particulate (HEPA) filtration system on the STS ventilation system was also reviewed by the Monitoring Team. The filtration system was designed in accordance with ANSI N 509 and l

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tested in accordance with ANSI N 510 except as previously indicated.

During filter change, the RN&S group will construct a containment tent to control radioactive materials and personnel performing the filter change will be equipped with supplied air masks. Ventilation for containment will be supplied from the room into the tent contain-ment and then through the STS filter train. The Monitoring Team observed that the filter room was accessed through a separate room which exits to the outside. During this review, the Monitoring Team identified a concern in that no barrier exists to prevent having both doors to this room open at the same time. This would be especially critical during filter change or if the filter room was subsequently contaminated. The Monitoring Team recommended that WNS consider interlocking the entrances to the STS ventila-tion system filter room to assure that both doors cannot be opened simultaneously.

During examination of the various ventilation systems, the Monitoring Team determined that only the CSRF system has been provided with fire detection capability and none of the systems have been provided with fire suppression capability. The CSRF system has been provided with a thermistor heat sensor that will close dampers to isolate the HEPA ,.

filters in case of a fire. Therefore, it was recommended that each ventilation system be evaluated to determine the effects of a fire and to determine if fire detection and/or suppression systems are required.

During discussions with DOE and WNS personnel and examination of documents associated ,<ith the maintenance of ventilation systems, during the October 1987 visit, the Monitoring Team was informed of an incident that occurred concerning the inadvertent change of HEPA filters instead of roughing filters on -the CSS ventilation system.

After three hours, the error was identified and new HEPA filters were installed and 00P tested. The corrective action identified by the contractor addressed restoration of the system by correct filter installation, but did not address procedural weaknesses, operator training, or the fact that no oversight function was established to ensure proper implementation of the filter change procedure. Sub-sequent to the October 1987 visit, the contractor took corrective actions to improve the filter change procedure, more uniquely identify banks of HEPA and roughing filters, improve training and establish filter change oversight procedures to ensure proper filter changes.

d. Analytical and Process Chemistry Laboratories (WNS)

A review of the contractor's radiochemistry program as it relates to radioactive waste measurements was performed by a review of records and data, discussions with personnel, and direct observations. No inadequacies were noted. The contractor has good laboratory facil-ities, state of the art equipment and a competent laboratory staff.

In addition, all recommendations for program improvements made during

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20 a previous NRC review in this area (the week of September 30,1985) were implemented by the contractor.

5. Effluent Monitoring, Sampling and Analyses

a. Effluent Monitoring (1) Ventilation Systems The Monitoring Team examined the ventilation system effluent monitoring and sampling devices for the Plant Ventilation System (PVS), Cement Solidification System (CSS), Supernatant Treatment System (STS), Contact Size Reduction Facility (CSRF) and the Supercompactor. In general, the monitoring and sampling equipment consists of redundant alpha and beta continuous air moaitors which alarm locally, in the main control room and at the guard house. The sampling pump will automatically change over to the alternative sampling system on a loss of flow or on no flow of the first pump and will alarm on loss of flow of the second pump. The sample lines are equipped with charcoal and particulate filters which are changed weekly. Provisions are .w made to sample for radiotodine and tritium. Tritium monitoring is achieved through silica gel absorber beds which can then be dried to determine the released quantities. Samples will be counted initially and after a predetermined (two weeks) time period to allow for the decay of radon daughters.

The Monitoring Team noted that the sampling lines on the STS ventilation system were equipped with a series of splitters which bifurcate the sample line into two lines which in turn are split into two channels. Therefore, each sampling line has been split twice before being monitored. The data for the potential for line losses or impingement due to these splitters was unavailable at the site. Subsequent to this monitoring visit, the Monitoring Team contacted the manufacturer of the line splitters to obtain information relating to line losses associated with the splitters. According to the manufacturer, no evaluations of line losses in the sampling system, including the line splitters, have been conducted. Therefore, the Monitoring Team recommended that line losses be evaluated on each system during initial startup testing with radioactive material so that the actual releases from the stack can L.

calculated.

In addition, the team reviewed calculations for the sizing of nozzles for isokinetic sampling on all ventilation systems and found them to be adequate. Sample lines currently in use were heat traced and insulated; lines on the newer facilities (CSRF, STS, LWTS) are heat traced but have not, as yet, been insulated.

No inadequacies were identified.

1 1

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fJ 21 g l Finally,theMonitoringTeamreviewedthemethodologyusedbh WNS to comply with the 0.1 microcurie per second release rate l specified in the Technical Specifications. The cethod used considered all release points at the site. The alarming setpoint for the PVS was established to assure that the 0.1 microcurie per second release rate cannot be exceeded for more than one hour. Any alarm will be responded to by the environ-mental group technical staff. The release may be averaged over one month and is evaluated on the basis of daily count rate checks and weekly analysis V i.i'2rs.

(2) Liquid Effluents Liquid effluent releases are made from lagoon #3 to the environment. Pre-release grab samples are taken to deter-mine compliance with DOE or NRC limits, whichever is the most restrictive, and State pollution discharge permit limits. Radiological releases are sunened using a unity equation and released at 75% of applicable limits. Samples are also obtained at the start and during the release at the weir. Environmental samples are taken at site 006 located on. ~

Franks Creek and at Buttermilk Creek. No inadequacies were identified.

b. Effluent Sample Analyses A review of the contractor's radiochemistry analytical program as it relates to radioactive effluents was performed by a review of records and data, discussions with personnel, and direct observations.

The contractor possesses state of the art counting instrumentation for gamma spectrometry, liquid scintillation counting, and gas flow proportional count;ng. However, laboratory space is limited with inadequate areas for sample and standards preparation.

Sample analysis meth fology is that previously described in the September 1985 monitoring report. That report contained recommen-dations or observations for program improvements. Implementation of those recommendations / observations were examined during this review. Out of a total of ten recommendations / observations, six were implemented, three were reviewed and not implemented by the contractor, and one, the establishment of control charts, was not acted upon.

The results of the U.S. Department of Energy's Radiological and Environmental Sciences Laboratory (RESL) intercomparison program were also reviewed. The Monitoring Team observed that the analyti-cal results for some of the radioisotopes in the liquid samples were poor. This poor result was attributed to the use of weak calibration standards. The poor results reported for part.iculate filters and charcoal cartridges were due to the use of improper calibration

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.s gecmetry in that the contractor used a point source geometry for the filter and cartridge calibration. The actual geometry of the filters and cartridges should have been used to establish the proper counting correction factors. This counting geometry, however, is not routinely used by the contractor and will no longer be reported.

As a result of this review, the Monitoring Team made the following reccmmendations concerning the facilities and methods used to measure radioactivity in effluents:

Calibration standards should be counted to determine the minimum number of counts needed to minimize the counting uncertainty.

Usually a minimum of 10,000 counts or more are required.

Fresh calibration standards should be used in calibrating the gamma spectrometry system so that a sufficient number of energy-efficiency pairs can be determined in order to draw a smooth calibration curve. Those standards should be purchased in a timely manner, n

Use a gamma spectrometry counting geometry which will improve the photon efficiency and permit the use n.' a larger sample volume, such as a Marinelli beaker.

Use the charcoal cartridge collection efficiency in the calculations for I-129 in effluent releases.

Establish control charts for all counting instrumentation.

Prepare a quench curve for the liquid scintillation counter using the same cocktail and sample volumes used for sample analysis.

Provide adequate laboratory work space.

Participate in an interlaboratory QC program, such as the EPA crosscheck program, which provides crosschecks at a fixed frequency with activity levels near those being seasured in the laboratory,

c. Confirmatory Measuremerits i

! During this visit, two liquid samples were split between the contractor and the NRC for the purpose of intercomparison. One liquid sample was taken from lagoon #2. Lagoon #2 is the storage location for all onsite process and cooling water. The water is processed to remove radionuclides, placed into lagoons #4 and #5 prior to analysis and release to lagoon #3. The processed and analyzed water is released to the environment from lagoon #3.

The second liquid sample was taken from lagoon #3.

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The contractor's Analytical and Process Chemistry Laboratories will analyze a sample of lagoon #2 liquid for gross alpha, gross beta, Sr-90, gamma isotopic, Pu-isotopic and total uranium. The NRC reference laboratory, RESL, will perform the same analyses. The contractor's Environmental Laboratory will perform gross alpha, gross beta, tritium, Sr-90, and a gamma isotopic analysis on a sample of lagoon

1. 3 liquid. In addition, a sample of lagoon #3 Ifquid will be sent to the Environmental Laboratory's vendor laboratory for Pu-isotopic, U-isotopic, I-129, C-14, and Tc-99 analyses. The NRC reference laboratory will perform the above analyses. The results will be compared and the results of that comparison will be documented in a subsequent monitoring report.

d. Environmental NRC TLD Monitoring Program During the September 1985 monitoring visit, the Monitoring Team established independent thermoluminescent dosimeter (TLD) stations on and around the site as an independent overcheck of the contractor's TLD monitoring program. Since that time, the TLDs have been removed by State of New York personnel and analyzed in the NRC Region I TLD laboratory. The TLDs (twelve) were placed on and around the site at -

the locations described in Appendix 1. M' Shown in Appendix 2 are the TLD monitoring results for the TLDs placed on ano around the West Valley site for the period June 25, 1987 to October 23, 1987. The column identified as Net Exposure Rate gives the exposure in millirem per 90 day period as adjusted from the gross exposure values. Stations 10, 11 and 12 are located onsite and were expected to have somewhat higher exposure rates. The value for Station 11, 1383 millirem /90 days was higher than expected but is similar in value to the TLDs placed in the area by the DOE contractor (WVNS). According to contractor personnel, the high value was caused by radiation from a radioactive material storage building which was l located within 100 yards of the fenceline. The contractor identified the unexpectedly high values during December 1985, immediately ordered and installed additional shielding for the storage building, and reduced the ambient radiation level at Station 11 to about 50 i

percent of the original level. Station 9, also found to be somewhat elevated, was located just outside the West Valley site. This ele-vated radiation level was also caused by proximity to the storage building. Although somewhat elevated, the radiation level at Station 9 was still well within the 500 millirem per year limit for exposure to the public.

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6. Incident Respo.ise

a. Emergency Planning (1) Emergency Plan and Program Administration The Monitoring Team reviewed the West Valley Nuclear Services, Inc. (WNS) Emergency Plan, Revision 1, dated September 1986.

The Emergency Planning and Preparedness Coordinator in conjunc-tion with the DOE Project Director, are responsible for carrying out the major functions of the emergency preparedness program and for ensuring implementation of emergency procedures. The Plan contains adequate detail in the following essential program areas: organization, assessment actions, activation, notifica-tions, facilities and equipment, training, and maintenance of emergency preparedness. The description appears to provide an adequate framework for the emergency planning program to allow response to a spectrum of accidents (radiological, nonradiologi-cal, and natural phenomena) during operation of the low-level and high-level solidification processes. The Plan must be audited and reviewed annually. Those audits and reviews cover.

organization, procedures, qualification of emergency personnel, equipment and supplies, and Letters of Agreement with offsite organizations. An independent audit was performed by the Department's Idaho Operations Office during 1987 and comments were resolved by the Department's West Valley Project Office (WVPO). Distribution of the document is made in accordance with Document Control Procedure W-103. The Plan was revised in December 1987 (Revision 2) and at the time of this monitor-ing visit, was still under review by WNS management.

The following items were found during review of the WDP Emergency Plan and should be considered for possible corrective action:

Page I-II of the Plan indicates that public relocation is not expected to be required in the event of credible accidents. Conversely, the introduction in Chapter II indicates that certain radiological emergency conditions '

could have an impact outside the facility boundary and could result in members of the general public exceeding established exposure limits. It is this premise on which much of the Plan is based. Protective response recommen-dations (PRR) are determined on projected doses to the general population of 1-5 Rem and 5-25 Rem, respectively.

Review of the dose assessment procedure (Appendix B) implies that such doses could not be achieved, but notification procedures for State and local authorities (Figure I-4) address consideration of PRRs for sheltering and evacuation of the public out to 10 miles. Clarifica-tion should be made on the intended purpose of the Plan

W m W GCc;nef6t m :

25 with respect to expected offsite responses and any implo-menting' procedures dealing with PRRs should be revised accordingly.

For offsite response the Plan uses the concept of the 10 mile plume exposure a,nd 50 mile ingestion pathway Emergency Planning Zones (EPZ) as are instituted by nuclear power plants. Instead, consideration should be given to FSAR worst-case hazards associated with facility operation (radiological and nonradiological). Then the specific size of each EPZ should be determined on that basis.

The Plan was prepared in accordance with DOE Orders 5500.2, "Emergency Planning, Preparedness, and Response for Opera-tions," dated 8-13-81, and 5500.3, "Reactor and Nonreactor _

Nuclear Facility Emergency Planning, Preparedness and Response Program for 00E Operations," dated August 13, 1981, and is a comprehensive document which received formal DOE approval on September 24, 1987. On February 26, 1987, 00E Order 5500.1A, "Emergency Management System" was issued-cancelling 5500.2. Although draft (replacement) orders were available, official guidance to be used for future revisions of the Plan could not be identified and should be provided to the contractor by the DOE West Valley Project Office.

Table II.4, "Criteria for Establishing Emergency Response Levels," provides general response information for non-radiological initiating conditions (e.g., industrial accidents, ventilation pressurization, bomb threat, and filter failure) but does not quantify each condition with a specific instrument reading or severity level to allow discrete gradations of response actions.

For security threats, described on page III-8, the expected response action levels are based upon increasing severity, but the classification of the incidents are not consistent with the requirements of the 00E Orders.

Based upon analysis of the most serious types of incidents which could occur at the site, no of fsite release or event relating to the definition of General Emergency appears possible. Therefore, the General Emergency classification used by the power reactor community and understood by New York State decision making authorities is not warranted.

As a result, reference to the General Emergency classifica-tion should be deleted from the Plan.

. .. w di,y2 g,; m .-- w

-g 26 (2) Facilities and Equipment The Monitoring Team toured the following facilities designated for emergency response: Emergency Control Center (ECC), Tech-nical Support Center (TSC), Medical Facility, environmental laboratory, and assembly areas. The ECC and TSC are newly designated facilities which are more than adequate to permit direction, control, and communication of response activities.

Emergency kits and lockers, communication equipment, radio-logical survey instruments (not dedicated but available from

, the Radiation and Nuclear Safety Office), respiratory protec-tion, first aid supplies, and vehicles available for emergency use were also examined. Facilities were as described in the Emergency Plan and are adequate for response to different accidents at the site. Since ECC habitability does not appear to be a concern, an alternate facility has not been considered.

Equipment lockers used for the storage of respiratory equipment and protective clothing were located at several locations within the plant. Inspection of lockers indicated that equipment which would be used during emergencies was maintained and readily accessible.

One minor exception was noted. No radiation detection instru-mentation was available at the medical facility and a delay could occur in providing medical treatment to a victim who becomes injured and contaminated in that a radiation safety technician would have to be called on to bring an instrument to the medical facility in order to perform a survey of the injury. The Monitoring Team recommended that WNS consider having radiation detection instruments available for use at the medical facility in order to facilitate surveys of con-taminated injured individuals during medical emergencies.

(3) Notification and Communications The primary means of emergency communications used throughout the site is the "812 Emergency All Page System." This is supplemented by the Plant Page System and commercial telephone system. When emergency facilities are activated, communications are maintained between the ECC, TSC, Media Center, and DOE offices. A WDP portable radio network is also available that links security, operations, and radiation and nuclear safety personnel with the ECC. All emergencies are required to be reported to the 00E-10 On-Site Representative (the DOE WPO Director) via the Initial Notification Checklist. Subsequent notifications are made to offsite governmental agencies, DOE Headquarters, and New York State via call-lists. The form appears adequate for transmittal of key information such as event description, radiological /non-radiological release, dose projections, meteorological data, and status of incident.

+p.h r %, tah ..* INi^5:4ik[M.f88t-6 27 No recommendations for improvement regarding notifications and communications capability were made by the Monitoring Team.

(4) Coordination with Offsite Groups The Monitoring Team reviewed Appendix 0 of the WVMS Emergency Plan which contains Letters of Agreement with the West Valley Fire Department (dated June 7,1982) and Bertrand Chaffee Hospital (current) and Appendix E which describes the procedure for handling radiation accident cases and contaminated patients.

Members of the team also met with offsite agency support per-sonnel to determine their role and interface with DOE and WVNS personnel during incidents at the site. Offsite support groups contacted included the Cattaraugus County Sheriff's Department -

local law enforcement and traffic controls; New York State. Civil Defense - evacuee assistance; West Valley Fire Department - fire safety and ambulance; and Bertrand Chaffee Hospital - medical treatment of contaminated / injured personnel. Site representa-tives have established good working relationships with offsite groups and group representatives expressed a clear understanding regarding their agency's role in response to emergencies. mon , . .

January 21, 1987 a meeting was held with New York State and County representatives to discuss facility operation and emer-gency response. Agency representatives stated that they have attended site orientatior. tours (open houses) and were familiar with hazards associated with site operations.

As a result of this review, the Monitoring Team recommended that the Letter of Agreement with the West Valley Volunteer Fire Department should be updated and should describe what support is expected.

(5) Emergency Training Although onsite training of personnel was not evaluated in detail during this review, lesson plans were available for a variety of dif ferent emergecy personnel. The Monitoring Team ,

reviewed results of drills and exercises performed at the site.

It was found that drills are held at regular frequencies to test emergency response capability to medical, transportation, site evacuations, fire fighting, and security incidents. Monitors (observers) are assigned to observe drills and provide comments to the Emergency Planning and Preparedness Coordinator, who in turn prepares a report of results. Reports are approved by the Manager, Radiation and Safety. From review of reports, it was not clear how corrective actions are taken after the reports are approved to correct identified deficiencies, in general, drill reports were complete and indicate that responses by both onsite and offsite emergency personnel were adequate in most cases.

This provides one indication that the training program appears effective. The Monitoring Team recommended that the contractor

M W$far&% -

28 should provide a formal mechanism to highlight deficiencies found during drills and to ensure deficiencies are corrected.

b. Fire protection The Monitoring Team reviewed the fire protection program to verify that the facility has the fire protection hardware to fight potential fires and that this equipment is properly maintained and tested to assure operation when needed. The team also reviewed the training given to employees assigned fire brigade tasks to assure that those persons are knowledgeable of their duties and capable of combating fires until the local fire departments arrive. Plant '

housekeeping conditions were examined to verify that controls exist to prevent the unwanted accumulation of combustibles.

(1) Fire Fighting Hardware During examination of fire fighting hardware installed or .

located throughout the site, the Monitoring Team observed that in the fire pump house:

The isolation valves on two pressure switches associated with the fire pump controllers were not supervised or locked open. An inadvertent closure of these valves would prevent the operation of the fire pumps. Similarly, three valves on the cooling water supply line to the diesel engine jacket were not supervised or locked. Closure of these valves would cause the diesel engine to overheat.

The pump house is not equipped with an emergency light. Loss of power during a fire will hinder the fire fighters from obtaining the required gear stored in this room.

The fire fighters' gear stored in this room was not complete in that it was missing gloves, flashlights, etc.

Both fire pumps and their controllers were in the same room. A fire in this room would damage both pumps and leave the plant unprotected.

A wrench used to operate the cascade air supply for the fire fighters SCBAs was not chained, and was subject to misappropriation or loss.

The fire equipment cabinet, located outside the door to this area and used to store fire fighting gear such as hoses, wrenches, etc., was inaccessible because of snow.

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l Actions were immediately taken by WNS personnel to tag the pressure switch isolating and the diesel engine cooling jacket valves in the proper position to assure proper operation of this equipment during an emergency. Further actions were taken to provide periodic audits and surveillances, in the future, to assure that these valves remain in the proper position.

(2) Facility Tours During tours of the facilities, the Monitoring Team observed the following adverse conditions:

Excessively large amounts of flammable liquids were being stored in some of the laboratories. While the storage and handling of these liquids appeared to be proper, the quantity of flammables available increased the fire hazard in the laboratories. The team recommended that WNS main-tain a one to two month supply of these liquids in the laboratories rather than a two to three year supply.

It was noted that an acetylene tank located in the cold analytical laboratory on the third floor of the main processing building was piped to laboratory equipment using rubber tubing. The team recommended that the rubber tubing be replaced with hard piping or tubing to preclude acetylene leaks.

During examination of the Lubricating 011 Storage Room located next to the maintenance shop, it was observed that the installed fire suppression system appeared to be inadequate, that the skid used to hold 55 gallon drums of flammable liquids, that may be dispensed from, was not grounded, and that housekeeping in the area was not

adequate.

Ouring examination of the Test and Storage Building, it was noted that several flammable material storage cabinets had been installed. Each of those cabinets was full of paint cans. None of the cabinets appeared to be vented in accordance with National Fire Protection Association (NFPA) code guidance and the team members were unable to determine if the cabinets were grounded. The team recommended that WNS assure that those cabinets are installed and used in accordance with NFPA guidance.

During examination of the electrical switchgear room, located on the east side of the main processing building, the Monitoring Team determined that there was no fire suppression system installed in that room. All offsite electrical power to the site and onsite emergency power is l distributed to the various facilities on the site from that l

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30 room. A fire in that room, in the Utility Room located adjacent to that room or in the offsite power transformer located just outside the room would disrupt electrical power to all facilities at the site. The Monitoring Team recommended that WVNS evaluate the effect of a fire in the t

electrical switchgear room and the subsequent loss of electrical power to all facilities, including ventilation systems, at the site.

7. Industrial Safety During tours of the various facilities, the Monitoring Team identified the following industrial safety concerns that should be corrected or evaluated by the contractor:

A homemade sign rather than a sign of standard design, which read "Caution - Laser" was posted at the class II laser usea in the CSS building to read bar codes on the cement filled drums.

Three large storage tanks containing incompatible chemicals (nitric acid, sodium hydroxide and diesel fuel oil) wera located in what appeared to be a common dike area. Because of the quantity of snow in the area, it was not possible to determine if the diked area was common for all the tanks. In any case, there was a common drain from the diked area into the waste water receptor ditch.

.ce.~ M&fk ysu APPENDIX 1 NRC TLD DIRECT RADIATION ENVIRONMENTAL MONITORING LOCATIONS AT WEST VALLEY STA. DIST(mi) DIR DESCRIPTION 1 4.0 250 Springville Downtown Parking lot 2 3.6 144 Pine Cliff Rd., West Valley (Utility Pole AAD 3) 3 1.5 92 Heinz Road at the Site Boundary 4 1.2 51 Zeffer Farm, Route 240 5 2.1 10 Emerson Farm, Thomas Corner Rd.

6 1.7 319 Rock Spring and Dutch Hill Rd.

7 1.2 262 Outch Hill & Head Row (Utility Pole 20) 8 1.4 234 Outch Hill & Pine (Utility Pole 28) 9 0.3 300 Rock Spring at Quarry Creek 10 On-site 43 Switch Gear Fence 11 On-site 334 BWE Fence Line (about 10 ft. from the Fence) 12 On-site 83 Utility Oitch at Security Fence

APPENDIX 2 WEST VALLEY NRC TLD DIRECT ENVIRONMENTAL RADIATION MONITORING RESULTS Anneal date  : 6/25/87 Field placement date  : 7/7/87 Retrieval date  : 10/13/87 Readout date  : 10/23/87 Gross Monitoring Period  : 121 days (10/23/87 - 6/25/87)

Field Monitoring Period  : 99 days (10/13/87 - 7/7/87)

Transit Period  : 22 days Station Distance Direction Gross Exposure Net Exposure Number (miles) (degrees) (mR / 121 days) (mR / 90 days) 1 4.0 350 21.9 i 0.7 ; 3.3 19.3 1 0.7 ; 4.1 2 3.6 144 20.1 0.6 ; 3.0 17.6 0.6 ; 3.9 3 1.5 92 21.1 0.3 ; 3.2 18.6 0.4 ; 4.0 4 1.2 51 19.4 i 0.6 ; 2.9 17.0 i 0.6 ; 3.8 5 2.1 10 21.5 1 0.7 ; 3.2 18.9 0.7 ; 4.0 6 1.7 319 22.5 0.7 ; 3.4 19.8 0.7 ; 4.1 7 1.2 262 14.6 0.4 ; 2.2 12.6 0.5 ; 3.4 8 1.4 234 22.8 0.7 ; 3.4 20.1 1 0.7 ; 4.1 9 0.3 300 43.7 i 1.3 ; 6.6 39.1 i 1.2 ; 6.6 10 On-site 43 38.1 1.1 ; 5.7 34.0 1 1.0 ; 5.9 11 On-site 334 1522 2 46 ; 228 1383 1 42 ; 207 12 On-site 83 98.8 i 3.0 ; 14.8 89.2 i 2.7 ; 13.7 Transit Exposure = 0.7 0.3 ; 3.0 Results are reported as Measurement +/- Random error ; Systematic error

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