ML20216F259
| ML20216F259 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1999 |
| From: | Bellamy R, Todd Jackson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20216F256 | List: |
| References | |
| NUDOCS 9909210226 | |
| Download: ML20216F259 (9) | |
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,7 l U.S. NUCLEAR REGULATORY COMMISSION REGION I MONITORING REPORT Report No. 99-02 Site Visited: U.S. Department of Energy West Valley Demonstration Project Location: 10282 Rock Spring Road West Valley, NY 14171-0191 Visit Dates: August 23 - 27,1999 Monitor: /8 Sp /0,/997 Todd J. Jilmic % CHP date Health Physicist Approved By: O 'O' onald R. Bellamy, Chief date Decommissioning and Laboratory Branch Division of Nuclear Materials Safety 1
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EXECUTIVE
SUMMARY
US Department of Energy West Valley Demonstration Project NRC Monitoring Report No. 99-02 A routine monitoring visit was conducted August 23-27,1999, to observe site operations and current project status at the West Valley Demonstration Project. Operational areas reviewed included recent site events, vitrification operations, high level waste tank operations, head end cell work, decommissioning projects, and radioactive waste management. As a result of this review, the monitor determined that the Department of Energy's contractor has established and maintained controls, processes, and programs, which are adequate to protect public health and safety. i l
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REPORT DETAILS I. Introduction This report documents the second routine monstonng visit of calendar year 1999 to observe site -
operations and current project status at the West Valley Demonstration Project (WVDP). The monitor observed activities in progress, held discussions with Department of Energy (DOE) and West Valley Nuclear Services (WVNS) personnel, and reviewed related documentation. DOE and WVNS personnel presented status briefings on site activities since the last monitoring visit in April 1999, with emphasis on the following:
Organization Changes Recent Site Events (Reportable and Non-Reportable)
High Level Radioactive Waste Operations Site Operations and Facility Closure Projects Radioactive Waste Management Spent Fuel Project
- 11. Organization Changes Several organizational changes had occurred since the previous monitoring visit in April 1999.
Susan Brechbill became Director of DOE's Ohio Field Office, which incorporates the WVDP. At WVDP, Elizabeth Lowes was named the Deputy Director, and the organization was restructured into itwo offices: the Office of Project Completion, and the Office of Compliance and Support.
The contractor for DOE described the staffing and super /.=ry changes made since April 1999 within WVNS.
til. Recent Site Events Details of selected recent events at the site were reviewed by the monitor. Reviews focused on '
the thoroughness and completeness of investigations, and on effectiveness of corrective actions. Two events reviewed in detail, Occurrence Reports OH-WV-WVNS-LWTS-1999 0002 (Double Shoe Contamination During Evaporator Operations) and OH-WV-WVNS-VFS-1999-0005 (Level Indication Lines Filled with Radioactive Liquid) were still actively being investigated.
WVNS staff described the known details of these events, indicated that final reports would be available when the investigations were completed, and committed to provide copies to the monitor.
Critiaue CM 99020. Imorooer Execution / Control of Decommissianina and Decontamination (D&D) Work The monitor discussed with WVNS staff the investigation of circumstances documented in this critique, which described the cutting of abandoned piping outside the former low-level liquid waste processing plant (identified as the "O-2 plant") and caused about 3000 gallons of water to inadvertently drain from the abandoned clarifier. Several procedural and administrative barriers had failed to prevent this event from happening. The monitor reviewed the details of these banier failures, the WVNS evaluation of the event, and the corrective actions planned. Failed 1 Monitoring Report No. 99-02 B:ONMS Documentsynsp ReportPaocxx.9942.wpd
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barriers included the hazard screening (did not identify the hazard of water in the clarifier), the i peer review process (did not identify non-specific work scope or faulty hazard screening), the .
Work Review Group (WRG) review (did not question work scope definition or hazard er,e yeis),
and the pre-job bnefing (the ccgru.rit engineer, who was familiar with system status, was not invited to the briefing). The proossses of peer review, WRG presentation and review, and the.
expectation that kr-rif-A personnel would be active in pre job briefings, were part of past corrective actions designed to reeolve contributing causes of past events at the site. These -
barriers were established to improve the work planning process andi i.Jerit recurrence of work planning, coordmation and communication problems. In this event the improved planning and I review processes were not used or did not function as they had been designed, and the bamers therefore failed to prevent the event. Consistent adherence to the work planning process and procedures would have presented several opportunities to avoid the event.
There is no limitation on how much time may pass between the WRG review of the work package and the performance of the work. In this case four months elapsed before the job was l performed. Especially for decommissioning work, work-site conditions and hazards are subject to rapid changes which could render the planning and hazard screen incomplete or incorrect before the work begins. WVNS staff stated they will examine whether or not a standard should be established for the maximum elapsed time for planned work until it is performed.
Cntioues related to Hazardous Wanta Marinaament !
l WVNS personnel described five separate critiques of events or problems occurring in the charactenzation, handling and rm;c4MnA g for hazardous and industrial waste materials.
Building on the early 1998 experience of Waste Management Services (WMS) personnel re-engineering the programs and procedures for handling radioactive waste, the hazardous waste program area was also re-engmeered beginning in late 1998. Despite re engineering, WMS management determined that the issues identified in 1999 and documented in the five critiques indicated a need for fundamental changes in the manner in which hazardous waste was characterized. A detailed corrective action plan to address IE=-f+C procedural detail and the entire scope of waste characterization and handling was de;;% ped to revise the re-engineered process. Additional supervisory and technical resources were assigned to implement the i correchve action plan, and an independent assessment by offsite experts was conducted to l assure complebness of the corrective action program. While significant work remains to complete this effort, this is also an excellent example in which performance data was used to ,
analyze causes of problems and develop comprehensive corrective actions, not solely address the specific problem first identified.
Flame Observed Durina HEPA Filter Testina Usina Polvalohaolefin (PAO) (OH-WV-WVNS-CF- !
1999-0002 In-place HEPA filter testing was being conducted on a main plant filter bank April 28, ~1999, '
using a thermal aerosol generator producing a test aerosol of PAO. During the testing, a 2-3 foot long flame was emitted from the generator discharge port. The flame did not resuit in any personnel injury or significant equipment damage, however it was an unanticipatec occurrence which could have produced serious consequences and was therefore thoroughly 2 Monitoring Report No. 99-02 exmans oocumentsunsp RepomRxxxx.99 02mpd
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l investigated. The aerosol generators had been moddied in accordance with manufacturer's -
e instructions to operate with PAO, replacing the former method of testing with DOP aerosol.
WVNS confirmed that the equipment was property modified and was correctly operated in 1 accordance with procedures. The generator manufacturer participated in the event investigation and determined that the moddied design was inadequate. The modified generator used a heater block set to operate at 725'F, a temperature high enough to cause the quantity of PAO necessary to perform teshng on the main plant filter to ignite. The manufacturer determined that the heater block should be set to operate at not more than 625'F. WVNS suspended all filter testing onsite when the event occurred, and testing was not resumed until all site test aerosol generators had been moddied to limit heater block temperature, and until the WVNS operating procedures had been appropriately revised. The monitor noted that this event could occur in any testing performed using similarly modified test aerosol generators.
Cracked Cell Viewina Window (OH-WV-WVNS-CF-1999-0003)
On May 13,1999 the shiekt window into the Process Mechanical Cell (PMC) Crane Room (CR) was cracked when a hydrochloric acid cleaning solution bemg introduced into the window's liquid-filled cavity was over pressurized, The acid was introduced into the cavity to clean the residual zinc bromide in preparation for window replacement. Although approximately 40 gallons of the acid leaked into the cell, there was no cell breach, personnel contamination or spread of contamination. The cause of the event was the failure to follow procedure by the contractor performing the window cleaning. An entry was made into the PMC-CR to check for residual acid, and no acid was found. WVNS concluded the acid reacted with dust on the PMC-CR floor and evaporated.
IV. High-Level Waste Operations Vitnfication The metter was in idle during this monitoring visit. WVNS efforts continued to focus on removing high level waste (HLW) heels from the HLW storage tanks. A total of 241 canisters of v tnfied HLW have been filled, with about 11 million curies "7Cs and "Sr transferred from tank 8D-2 to the concentrator feed makeup tank (CFMT). Radioactmty remaining in the tanks is shown in the following table, provided by WVNS:
250,000 291,000 541,000
<10,000 54,000 64,000 260,000 355,000 605,000
- As of July 27,1999 (based on 1/1/96 activity estimate).
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- are expected to reconcile computer modelmg estimates, tank contents sampling results,' and the ~
radioactivity already transferred to the CFMT. i Resumption of molter operation is also dependent on recovery from the effects of the August 10, 1999 ovent in which radioedive hquid backed-up into ievel indication steam lines. The first pnority being worked on is to sush the contaminated lines to enable access to replace piping.
Personnel exposure rates will be reduced by this action, which is expected to enable full recovery of vitrtlication operations.
WasteTank Farm WVNS had completed installation of a third video camera into tank 8D-1. Using the new camera in combination with the two cameras previously installed, WVNS also euw-?t i a detailed video inspection of the materialin the bottom of the tank. Video of the inspection was observed by the monitor. In Fiscal Year 1999 there have been seven transfers of residual zeolite material (visible in the tank inspedion video), containing 436,000 curies of *Cs and "Sr, from 8D-1 to 8D-2.
WVNS staff desenbod a recently identified issue of increasing mercury concentrabons in the liquid effluents downstream of the Liquid Waste Treatment System (LWTS) Evaporator.
Mercury, which was used to suppress radioiodine emissions during the former fuel reprocessing operations, is becoming increasingly concentrated in the remaining waste water. Concentration is occurring har= = mercury is not retained in the vitrified glass matrix and instead is recovered by the gaseous waste treatment system, or is retained in the ion exchange media (zeolite) within the HLW tanks. An additional treatment to remove trace mercury, possibly at the effluent from the LWTS Evaporator, may be necessary to remove sufficient mercury from waste water process streams to reduce the concentration in low level waste streams enough to achieve cummt and future environmental discharge limitations on mercury. WVNS is continuing work to develop and implement the additional treatment methods necessary to maintain compliance with discharge limits and not constrain vitrification or other liquid waste processing.
V. Site Operations and Facility Closure Projects
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Head-End Cells Video camera inspections of all cells have been completed. Work continued on numerous projects necessary to enable removal of waste materials from cell interiors. In the PMC, !
progress was made toward replacing the overhead crane and remote manipulator. The 'D' shield window in the PMC was refurt>ished, and the PMC-CR shield window refurbishment was completed.
WVNS had developed an approach to analyzing the potential in the General Purpose Cell )
(GPC) for an inadvertent criticality. NRC had stipulated a criticality review be performed prior to '
commencing decommissioning activities in the GPC. WVNS proposes to use in the criticality analysis conservative assumptions based upon the mcst limiting enrichment of fuel reprocessed 4 Monitoring Report No. 99-02 sxwe4S DocumentsVnsp RepomRxxxx.9902mpd
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by Nuclear Fuel Services during plant operation, rather than expend significant resources and
' time to sample and analyze the large number of uncharacterized objects in the GPC.' Video i
inspechons of the cell have confirmed the presence of water in the GPC, as well as significant amounts of debris induding fuel rod hulls. Based on the video inspection it has not been possible to confirm that all the hulls are empty and do not contain spent fuel. WVNS therefore proposes to make conservative calculational assumptions regarding water presence and the quanhty of fissionable material available. The monitor suggested to the WVNS and DOE personnel that it would be appropriate to make this presentabon to the NRC staff who will be evaluating the arr,c.
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Other Projects D&D projects recently completed included removal of a waste tank from the Scrap Removal Room (SRR) in the main plant. The tank contents had incorporated settled concrete dust, which had been removed prior to removing the tank. In the old O-2 plant all the indoor process piping and the cold ventilation system had been removed as part of the project to decommission and release the facety for unrestricted use. A new counting room for Radiation Protection had been completed and was operational for analyzing samples. The new counhng facihty is outside the main plant and has a reduced level of background radiabon compared to the previous facility.
Replacement of Main Plant roofs had conhnued dunng the summer months.
VI. Waste, Fuel, and Environmental Projects Radioactive Waste Management Twenty eight shipments oflow-level waste have been shipped offsite in FY1999. These shipments totaled 28,936 cubic feet of waste. The shipments enabled recovery of significant on-site storage space for other use. Replacement of the I.SA 4 waste storage structure had begun, and will provide a more ;;d rinvef and durable new structure. The cloth covering had been removed in preparabon for construction of a steel structure. The new structure will also provide a sheltered enclosure in which trucks can be loaded.
Repackaging of spent resin from the old 0-2 plant was in progress. This project will repackage resin stored in 1,050 drums into High integrity Containers (HICs) and dewater the resin for long-term storage or disposal. To date,13 HlCs have been filled and dewatered, eliminating 236 55-gallon drums.
Soent Fuel Proiect WVNS activities to prepare for disposition of the remaining spent fuel in the site storage pool were presented. Spent fuel programs at other DOE sites at Savannah River and Idaho National Engineering Lab have been examined for companson and to leam about experience at those i sites. A training program for Certified Fuel Handlers was developed for WVDP. Preparation '
and testing are underway to assure that building cranes and other equipment necessary for handling transp0 Men casks and fuel will be ready. Discussions continue with NRC regarding the transportation casks to be used and potential modifications that may be required. Finally, 5 Monitoring Report No. 9942 a: ness ooounwnsvnsp RepomRxxxx.9902.wpd
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,-p, WVNS is determining what actions are necessary to make the on-site rail spur useable for transportaten. Track for the railroad spur runs over a culvert on Buttermilk Creek, and erosion around the culvert has been a concem. An engineering evaluation of the erosion and possible mitigating actions is also in progress.
OtherProiocts Conceptual design was completed for a new facility to remotely handle and package radwaste.
Installation had begun on a permeable groundwater treatment waN on the North Plateau. The wall will be a below grade stmeture intended to intercept one lobe of the "Sr groundwater plume, removing "Sr by lon exchange as the groundwater moves through the wall.
Construction actmhes related to installation of the wall were observed by the monitor.
Vll. Exit RAeeting The monitor pr.eerre the resuRs of this visit to senior DOE management on August 26, and to WVNS management on August 27,1999.
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PARTIAL LIST OF PERSONS CONTACTED Department of Enemy. Ohio Field Office-West Vallev Demonstration Pmiect Barbara Mazurowski, Director Bill Hamel, High Level Waste Projects Team Leader Ken O'Connor, Engineer i
West Vallev Nuclear Services l Robert Campbell, President Robert Lawrence, Wasta, Fuel, and Environmental Projects Manager Paul Valenti, High Level Waste Projects Manager Stuart MacVeen, Site Operations and Facility Closure Projects Manager Bob Fussner, High-Level Waste Operations Joe Jablonski, Main Plant Operations Manager Jack Gerber, Environmental Affairs Manager Jim Graming, C+: =rT' ':-t.g Planning Manager Ken Schneider, Head End Cells Project Manager Robert Keel, Operations Support Manager John Cwynar, Conduct of Opershons Team Leader Craig Repp, Environmental Projects Manager Bob Steiner, Senior Envimnmental Engineer Lettie Chilson, Safety Analysis and integration Manager Tom Cottrell, Site Operations Projects and Support Manager J. Wolniemcz, Head End Cells Project D. Wallon, Sr. Engineer, Tank Farm and IRTS Engineering New York State Enemy Research and C=:':-:-T,is,t Authonty Paul Piciulo, Program Director !
Colleen Gervitz, Regulatory Compliance Manager I i
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