ML20237E056
| ML20237E056 | |
| Person / Time | |
|---|---|
| Issue date: | 08/20/1998 |
| From: | Todd Jackson, Roberts M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20237E054 | List: |
| References | |
| REF-PROJ-M-32 NUDOCS 9808280227 | |
| Download: ML20237E056 (9) | |
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4 r' U.S. NUCLEAR REGULATORY COMMISSION REGION I INSPECTION REPORT l
Report No.- 98-02 i
Facility: U.S. Department of Energy, West Valley Demonstration Project Westem New York Nuclear Service Center Location: West Valley, New York Dates: June 29-July 2,1998 Monitor: I -l9 - 78 Todd J. JIcWon, CHP date Health Physicist -
I Approved By: ' b-N' 7!
Mark C. Roberts, CHP, Chief date Decommissioning and Laboratory Branch Division of Nuclear Materials Safety i
l 9908290227 980820 PDR PROJ M-32 PDR 1
9 EXECUTIVE
SUMMARY
U.S. Department of Energy West Valley Demonstration Project NRC Monitoring Report No. 98-02 A routine monitoring visit was conducted June 29-July 2,1998, to observe site operations and current project status at the West Valley Demonstration Project. Operational areas reviewed included recent organizational and personnel changes, vitrification operations and metter status, recent significant events, self-assessments and program reviews, the 1997 offsite dose assessment, low-level waste shipping plans and preparations, north plateau groundwater contamination, high level waste canister welding issue, melter noble metals buildup monitoring, and the Citizens Task Force. As a result of this review, the monitor determined that the contractor has established and maintained controls, processes, and pregrams, which are adequate to protect public health and safety.
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4 REPORT DETAILS
- l. Project Status Overview ]
The monitor observed activities in progress at the West Valley Demonstration Project (WVDP),
held discussions with Department of Energy (DOE) and West Valley Nuclear Services (WVNS) personnel, and reviewed related documentation. This was a routine periodic monitoring visit to observe site operations and current project status at WVDP. DOE and WVNS personnel presented status briefings on site activities, with emphasis on the following:
Organizational and personnel changes Vitrification and other site activities Vitrification cell welding machine ground-current investigation Recent significant operational events WVNS self-assessment and trending programs 1997 offsite dose assessment Low-level waste shipping plans and preparations North plateau groundwater contamination Metter noble metals buildup Citizens Task Force
- 11. Organizational Changes ;
Effective since the last monitoring visit in March 1998, Barbara Mazurowski became Acting Director for DOE at the WVDP, replacing Tom Rowland. DOE personnel informed the monitor j
that DOE recently renewed the contract with WVNS to operate the WVDP for DOE for an i additional two years with an option for a third. i I
WVNS added Linda Calderon as new Manager of Industrial Hygiene & Safety, and Jackle Jackson as Manager of Waste Characterization and Shipping. WVNS personnel noted that an
- agreement had been reached by the parent company of WVNS and Westinghouse Electric Company to sell Westinghouse, including WVNS. The transaction was not expected to be completed before the end of the 1998 calendar year.
Ill. Status of Site Operations During this visit, the melter was pouring into canister 218, with 55 high level waste (HLW) transfers from tank 8D2 to the Concentrator Feed Makeup Tank completed. With the 55th transfer, the cumulative total activity transferred was approximately 9.9 million curies of 1 Monitoring Report No. 98-02 G:CNMScoCWoRKTINSPRPT\WV_0698.WPD
radioactive strontium and cesium. Phase i of the vitrification project was completed on June 10 ,
1998, signaled by vitrification of 9.32 million curies. Phase ll continues, with the objective of '
removing as much residual radioactivity as possible from the HLW storage tanks. The time necessary to prepare glass-former feed batches and fill a canister has been increasing because each HLW transfer is more dilute and contains less radioactivity as processing proceeds. More transfers have also become necessary recently in order to produce a single feed batch. Thus additional time is necessary to concentrate the solution by boiling, to make a batch satisfactory for feeding to the melter.
WVNS had several activities in progress to improve the ability to mobilize more radioactivity from the residual materials in the tanks. Improvement strategies include lowering the mobilization pumps to get the suction point as close to the tank bottom as possible, as well as )
i installation of the completed mechanical arm, designed to enable high pressure water to be directed at suspected areas in the tank where solids have so far been inaccessible. The f j
monitor observed the mechanical arm, which had been set up on the site test platform for final '
testing in anticipation of installation into 801 to assist in removing residual zeolite from earlier processing activities.
Work continued on replacement of failing roofs on the main plant. Efforts focused on completing as much of the work as possible during good weather in 1998. Work had begun on stabilizing the old low level waste processing facility, since the new low level waste treatment facility (LLWTF) had been put into service. WVNS planned to stabilize conditions in the old facility and include further remediation work in planning for other decommissioning at the site.
The new LLWTF had begun operating in March 1998. Since that time, about 2 million gallons of liquid waste had been processed with approximately 30% gain in efficiency compared to the old facilities.
IV. Vitrification Canister Lid Welding i
An unintended ground current caused by a grounding strap on the welding machine had f
caused the welding current to be higher than was expected for completed welds (this issue was described in the previous monitoring report from March 1998). The unintended ground current was discovered during calibration of a spare welder, located outside the vitrification cell. WVNS reported that testing of the welder ground current had been completed.
WVNS had evaluated the ground current on the vitrification cell welding machine and determined that all completed waste canister welds were acceptable. Testing had shown that true weld corrent for completed welds was 5-10% higher than had been recorded. Based on the continuous visualinspection of all welds when performed and control of other weld parameters WVNS concluded that completed welds were within acceptable design bounds. When the recorded currents for canister welds were corrected to account for the true current values, '
WVNS confirmed that the adjusted currents were within the range of acceptance. This testing completed the investigation, and supported the conclusion that the existing welds are acceptable.
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l l' .
, V. Recent Reportable Events WVNS personnel described the details of nine reportable events, which had occurred since the i previous monitoring visit. Three of these events appeared to involve personnel not following l procedures, or inadequate procedures. Of particular interest were reportable event OH-WV-l WVNS-LLW2-1998-0001 (spill of low-level contaminated resins) and critique CM98010 (work l performed outside the scope of the work order). WVNS was still investigating some of the details related to these events, and it had not yet been determined what were the reasons why l involved personnel had decided not to follow the applicable procedures. The motivation for personnel to choose the actions they took appeared key to understanding what will be the l appropriate correchve actions to effectively prevent recurrence. In both cases, a major contributor to the events was personnel not following procedures, a recurrent causal factor contributing to previous significant events at the site, such as a personnel contamination at the tank farm in December 1997 (see Monitoring Report dated April 23,1998) and the November 1996 backup of high level waste into a demineralized water line in the vitrification facility (see Monitoring Report dated January 31,1997). Since November 1996, there have been signifx: ant efforts invested in implementing corrective actions at WVDP, however they have not been effective at correcting the problem of noncompliance with procedural guidance.
The example conceming work performed outside the scope of the work order at the old low-level waste facility centrifuge was especially pertinent considering the WVDP intent to change the site " culture" so that personnel will be more likely to willingly comply with procedural requirements. In this case, a group of workers determined in the pre-job briefing that the work order for the task was inappropriate and decided to perform the work differently than described in the work order. This action was not in accordance with accepted WVNS practices for pre-job l briefings. Proper action would have included revising the work order before working, yet the group chose not to revise the work order. Instead, the group proceeded to perform the work according to their " improved" plan, thus creating a potential airbome radioactivity hazard, in the case of the resin contamination at the LLWTF, operators did not follow the procedure. A step which had been in the system testing procedure had been removed from the operational procedure, yet was still performed by the operator. Although the procedural step was successful during system testing, it drove contaminated resin out of the system when performed for operation. The procedure should have been reviewed prior to performing the task, however the procedure change would also have been appropriate to cover in the pre job briefing. The
. engineer responsible for revising the procedure was not available at the time of the briefing and therefore did not participate. WVNS personnel indicated that it was standard practice for the i cognizant engineer, responsible for the procedure being used, to participate in the pre-job briefing. As in the previous example, conduct of the pre-job briefing appeared to deviate from standard practice, and yet the associated work proceeded anyway. Additionally, it appeared in this case that there was inadequate communications during procedure development between the cognizant engineer who wrote the procedure and the operat: s responsible for performing the procedure.
Following the December 1997 waste tank farm personnel contamination, the WVNS root cause evaluation stated, corrective action "...was adequate in scope, but did not go far enough in its 3 Monitoring Report No. 98-02 G:ONMSOoCWoRKilNSPRPT\WV_0698.WPD
application to other facilities." Although the reference was to facilities in which high level waste was handled, corrective actions applied following the November 1996 and December 1997 events may also have prevented these two more recent events in the new LLWTF and the old
- l LLW treatment facility if they had been more broadly applied to these other site organizations.
l Deviation from the approved work order was a common factor between the two events. A significant corrective action taken in Vitrification Operations following the November 1996 event was to organizationally and funcbonally bring procedure wnters and procedure performers / operators closer together. The intent was to reduce the type of communications problems that occurred recently at the LLWTF.
WVNS and DOE continued to investigate the circumstances causing the described events. The monitor will review these investigations when complete.
VI. Self-Assessment and Trending Programs WVNS presented the current status of the Radiation Protection (RP) self-assessment program, which includes field evaluations and programmatic compliance assessments. Field evaluations included observation of plant evolutions, such as work activities, pre-job briefings, procedure use, and communications. Additional examples of field evaluations performed are plant area inspections, training observations, adequacy reviews of radiological sampling and monitoring systems, and reviews of operator aids, logs, and postings. As described in the previous monitoring report (March 1990), the program also continued to focus on " corrected on the spot" items, which provides immediate feedback to personnel while capturing data for trending.
RP programmatic assessments covered selected functional area elements defined by the DOE regulations in 10 CFR 835. Corrective actions for findings developed during the assessments were being tracked to completion in the WVNS open items tracking system. Also included were procedure table-top reviews, similar to reviews being performed by other WVNS operating organizations. RP had an ambitious self-assessment scheduled for calendar year 1998.
Performance-based self assessments continued within other WVNS organizations. Since March 1998, the program focused on maintaining coordination among the various site organizations, had incorporated more of the Conduct of Operations Manual chapter areas, had expanded beyond operations functions to incorporate some engineering functional areas, and had begun to develop new areas of assessment in management reviews, training records, and quality assurance. WVNS continued to track the 184 corrective actions for the 146 findings identified during the October 1997 Conduct of Operations Self-Assessment. Ninety-one percent of the corrective actions were complete, with the remainder on track for completion by the end
'of calendar year 1998. An additional smaller-scope self-assessment was conducted in April 1998. WVNS personnel also described status of corrective actions resulting from that review.
' ' Independent Root-Cause Analysis of the December 15,1997 Waste Tank Farm Contamination Events".
Memo BA:98:0001 dated January 26,1998, J.L. Little to R.R. Campbell.
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Vll.1997 Offsite Dose Assessment
'WVNS summarized the conclusions presented in the Site Environmental Report for Calendar Year 1997. During the 1997 environmental monitoring program, WVNS performed more than j 60,000 analyses on about 11,200 samples. The total estimated dose equivalent from all pathways to the " Maximally Exposed Off-Site Individual" (a hypothetical person assumed to be ,
at the site urse&l led area boundary for the entire year) was 0.073 mrom, which is similar to 1 the 1996 total of 0.076 mrom. The 1997 total is 0.073% of the DOE Standard for maximum j offsite dose of 100 mrem /y.
As shown in the table below, airborne releases were greater in 1997 than 1996 due to operations at the site. The decrease in liquid releases for 1997 offset the airbome increase, j
- resulting in a total calculated dose similar to 1996.
WVDP Offsite Doses Calculated (mromty)
Airbome Pathway Liauid Pathway Airbome Permitted North Plateau Discharges
.1997 0.0490 0.012 0.012 0.073 1996 0.0086 0.043 'O.024 0.076 I
Vill. Low LevelWaste Shipping Shipments of low level waste to licensed disposal sites were being used as part of the overall strategy to manage radioactive waste at the site. WVNS planned to increase the amount of waste shipped compared to the seven shipments made in Fiscal Year (FY) 1997. Regular shipments of dry active waste (DAW) to available burial sites were expected to begin in July 1998, to avoid the need for additional onsite storage space. WVNS expected that wastes would be shipped to a vendor for processing (volume reduction and/or dewatering verification) and repackaging before shipping to an appropriate burial site. WVNS planned to routinely ship at least one truckload of DAW every other week. Shipments were expected to consist of high integrity containers with North Plateau resin and B-25 overpack boxes.
WVNS also described the restructuring of the Waste Management organization. The new organization is expected to enable more effective and efficient shipping of waste materials.
WVNS anticipates that future site activities will increase the challenges to waste management, as more work is focused on decontamination and decommissioning (D&D). A team had been established to re-engineer the overall shipping procesa to enable waste to be ready to ship l within 6 months of generation.
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(.
s IX. North Plateau Groundwater Monitoring ,
A significant improvement in efficiency _using and handling lon exchange resin for the No'rth Plateau pump-and-treat process had been realized with startup of the new low level waste treatment facility (LLWTF). Groundwater from the three North Plateau recovery wells was pumped out of the ground and to the LLWTF for Sr-90 removal. Resin had previously been located in temporary structures close to the well-heads, where processing constraints limited efficient resin use and it had been difficult to handle the resin for processing.
The pump-and-treat approach has successfully slowed the movement of Sr-90 down gradient in the first, most advanced groundwater plume lobe near the wells and in preventing contaminated water from reaching the surface. Costs to operate the ion exchange system are expected to be reduced through the LLWTF system use. Additional work was planned for further plume charactenzation and mapping, and to evaluate treatment options for the second groundwater plume lobe, which is deeper and moving more slowly.
Work was nearing completion for main parking lot paving and removal of unnecessary trailers near the parking lot. This work improved surface water runoff flows, which is expected to reduce some of the groundwater hydraulic pressure driving expansion of the Sr-90 plume.
X. Molter Noble Metals Update WVNS described current status regarding monitoring of the buildup of noble metals in the comers of the metter, creating a "short circuit' electrical current that reduces resistance in the metter and thus limits heating capabilities necessary to sustain the molten state of the glass.
Effects on melter performance had changed little since the March 1998 Monitoring visit. l Operating data collected from the metter continued to track closely with the mathematical model of performance, which predicts relatively stable electrode resistance that will not limit the useful life of the metter. Although noble metal deposits may reduce glass throughput, WVNS l anticipates that the installed power supplies wili be adequate for the planned metter service requirements.
XI. Citizens Task Force The Citizens Task Force (CTF) had completed work on their recommendations report. The CTF had conducted 34 meetings since January 1997, with significant investigation of pertinent issues and discussion among the members. Pending final approval by all participants, the recommendations were ready to be submitted to the DOE. ,
Xil. Management Meeting The monitor presented the results of this visit to senior DOE and WVNS management and staff at the conclusion of the visit on July 1,1998.
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PARTIAL LIST OF PERSONS CONTACTED Deoartment of Enerav Barbara Mazurowski, Acting Director l Richard Provencher, Associate Director l William Hamel, Operations and Engineering Team Leader T.J. Jackson, Safety, Health & QA Team Leader l Herman Moore, Remedial Projects & Waste Management Elizabeth Lowes, Regulatory Planning & Stakeholder hierface Team Leader West Vallev Nuclear Services Robert Lawrence, Transition Projects Manager !
Paul Valenti, Vitrification Operations Manager l Richard Marcellin, Waste Tank Farm Operations Manager i John Garcia, Radiation Protection Manager Stuart MacVean, Site Operations Manager Ellery Savage, Environmental, Safety, Quality Assurance, and Lab Operations Manager Karl Sanders, Vitrification Shift Operations Liaison Officer Dan Meess, Tank Farm and IRTS Engineering Manager Joe Jablonski, Main Plant Operations Manager Mae Wright, Waste Management Manager Tom Kocialski, Vitrification Systems Engineering Manager ,
Tom Cottrell, Operations Projects & Support Manager )
Bruce Covert, Operations Technical Support Manager ;
Jack Gerber, Safety Analysis & Integration Manager .
l John Cwynar, Conduct of Operations Team Steve Bames, Vitrification Process and WQR Compliance Manager Anthony Nagel, Principal Environmental Engineer, Environmental Affairs Craig Repp, Transition Environmental Programs Manager Mark Hemann, Project Engineer Sonja Allen, Public and Employee Communications l 7 Monitoring Report No. 98-02 G:ONMSOOCWoRK\lNSPRPDWV_0698.WPD