ML20247K285
| ML20247K285 | |
| Person / Time | |
|---|---|
| Issue date: | 04/23/1998 |
| From: | Ronald Bellamy, Todd Jackson, Joseph Nick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247K282 | List: |
| References | |
| REF-WM-1 NUDOCS 9805220055 | |
| Download: ML20247K285 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.:
98-001 Facility:
U.S. Department of Energy, West Valley Demonstration Project Westem New York Nuclear Service Center Location:
West Valley, New York Dates:
March 16-20,1998
( //
Monitor:
[/ 627 Todd J. Jacks Health Physicist I [
iv y~ n Joseph L. NiWV V
Health Physicist
\\w Approved by:
Rohald R. Bellamy, Ph.D., Chief Decommissioning & Lab Branch l
9805220055 980423 PDR WASTE WM-1 peg OFMCIALRECORD COPY n.
IE:07 1
RETURN ORIGINAL TQ REGION!
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EXECUTIVE
SUMMARY
i U.S. Department of Energy West Valley Demonstration Project NRC Monitoring Report 98-001 A routine monitoring visit was conducted March 16-20,1998, to observe site operations and current project status at the West Valley Demonstration Project. A primary focus of this monitoring visit was the review of the site intemal and extemal dosimetry programs.
Other operational areas reviewed included vitrification operations and metter status, high level waste canister welding issue status, West Valley Nuclear Services (WVNS) organizational changes, WVNS self-assessments, the waste tank farm personnel contamination event of December 1997, recent reportable events, ongoing work to remove and replace the tank 802 transfer pump, tank 8D2 mobilization pump activities, low-level waste shipments, north plateau status, and the melter noble metals buildup l
' monitoring. The monitor also attended the meeting of the Citizens' Task Force on March 17,1998.
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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.
WVNS management described the organizational and personnel changes which had occurred since the last monitoring visit. DOE and WVNS personnel presented status briefings on site activities, emphasizing the following areas of interest to the monitor.
Intemal and extemal radiation dosimetry programs Status of site operations Vitrification cell welding machine ground current effect
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{
Waste tank farm personnel contamination event of December 1997
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Other recent reca~ fable events WVNS self-assessment and trending programs Low-level waste shipping status North plateau status Melter noble metal buildup Citizens' task force meeting
- 11. Personnel Dosimetry The WVDP intemal and extemal dosimetry programs were observed through a review of program documents and records, interviews with WVDP employees, and tours of the facility. Documents reviewed included the draft DOE implementation Guides for intemal and extemal dosimetry program implementation (DOE G 441.3-1 and DOE G 441.4-1),
the WVDP Radiological Controls Manual, the WVDP technical basis documents for the intemal and extemal dosimetry programs, various WVDP operating procedures, and numerous program records. The WVDP intemal and extemal dosimetry programs were assessed for program compliance with the program documents and commitments, and compared with good program practices from nuclear power reactors and other nuclear facilities.
NRC inspection methods were used for general reference and a sampling approach was used to review details of various aspects of the intemal and extemal dosimetry program.
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The monitor observed a very good program for intemal and extemal dosimetry.
Specifically, the monitor observed the following program elements: adequate facilities, instrumentation, and equipment; knowledgeable personnel and evident management support for the programs; good maintenance of records and reporting of dose to personnel; good handling and storage of thermoluminescent (TLD) badges; appropriate administrative controls for declared pregnant workers; and adequate handling and chain-of-custody for bioassay samples.
Several initiatives and recent improvements to the programs were noted. An upgrade to the whole body counting system, with new detectors for increased counting efficiency and new software, should improve the quality of the intemal bioassay program. The facility had been recently expanded and a new technician was added to the staff. The TLD system computer was in the process of a hardware upgrade due to the age of the older system. The staff had upgraded the quality of the annual radiation exposure l
reports to personnel and the reports were being prepared. The staff had also initiated a review of the post-anneal dose remaining on processed TLD badges, as part of the evaluation of potential false positive radiation dose assignments to personnel.
Numerous recent audits and assessments had provided the staff with many opportunities for improvement in the dosimetry programs.
The monitor noted some minor areas for improvement or enhancement to the existing programs. There were no apparent administrative controls for taking equipment out of service beyond oral communication through tumovers or work discussions. A review of existing procedures regarding preparation of equipment prior to use is recommended to determine the need for additional controls such as tags or signs to alert personnel of restrictions on equipment.
Other areas for improvement were noted related to program quality controls. There was no process for confirmatory measurements in the bioassay program to verify that the respiratory protection and airbome radioactive workplace monitoring programs were effective. Although routine periodic measurements were required for all radiation workers and operational / diagnostic monitoring was performed in response to an event or incident, random sampling of personnel working in potential airbome areas or respiratory protection is recommended. In another area of quality control, the blind spike program for the bioassay laboratory was not in accordance with procedure specification. The spiking was being performed, but not at the recommended frequency specified in the procedure (RC-DOS-3, titled " Blind Performance Testing").
The monitor also noted administrative discrepancies in existing procedures, caused by a recent programmatic change in the frequency of routine periodic TLD processing (monthly to qua;terly) for personnel monitoring. Various operating procedures and the Radiological Controls Manual still referenced " monthly processed dosimeter badges personnel", rather that the revised quarterly frequency.
The dosimetry programs are very solid programs with little need for improvement beyond what was already identified in various audits and assessments or discussed above. The monitor also noted the staff was committed to continuous improvement and had performed the tasks of the dosimetry programs in a responsible manner.
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Ill. Status of Vitrification and Waste Tank Farm Operations The metter was in idle during this monitoring visit. No transfers of high level waste from tank 8D2 had occurred since January 19,1998, due to failure of the transfer pump. As of the last transfer the cumulative total activity transferred was approximately 8.3 million curies of radioactive strontium and cesium.
Activities were in progress to remove the failed transfer pump from tank 8D2. The i
monitor observed the preparations to perform this task, and also examined the replacement pump which was being set-up on a test stand. A box had been built to contain the failed pump during transfer to a shielded storage vault, and this box was staged over the pump above tank 8D2. Extensive planning was conducted in preparation for removal and replacement of the transfer pump. The monitor observed the ALARA committee meeting to review the pump removal job, which incorporated participation by all site work groups involved in the work. Subsequent to the exit meeting for this monitoring visit, DOE personnel informed the monitor that the pump was successfully removed on March 20,1998.
Preparations were also in progress for replacement of the M-5 waste mobilization pump in tank 8D2. It had been determined that the pump required replacement because of the need to more effectively mobilize the residual solid materials on the bottom of the tank.
Among the elements of the strategy to improve removal of the residual materials is installation of a different design M-5 pump, and also to install a similar design pump in the M-7 riser. An attempt on March 2,1998, to remove the pump at M-5 had been aborted because the radiation dose rates were excessive. Further planning was in progress to perform additional decontamination of the pump and to store it in another location, if necessary, to enable installation of the new pump. Different waste mobilization strategies are necessary in order to enable removal of the remaining solids materials at the bottom of the tank. Radiation surveys indicate that significant activity i
remains in these sediments, and experience has shown them to be difficult to mobilize.
WVNS engineering efforts were focusing on the design of mobilization equipment to best accomp!ish material removal.
i Canister Lid Weldina Issue A Nonconformance Report (NR) was written in January 1998 to address the discovery of i
a previously unidentified ground current on the welding machine of the vitrification cell canister welding station. This NR is potentially significant because the ground current differs from the hardware and process parameters documented for canister welding in i
the Waste Form Qualification Report (WQR). Therefore it is necessary for WVNS to l
demonstrate that the unquantified ground current does not cause variation beyond the limits of the design bases for the welded canisters. Work to address the NR war in-process, and included controlled tests of an identical welder and configuration at the i
l V;trification Test Facility to determine the revisions to the WQR necessary to make it consistent with measured conditions on the installed equipment. Additional test welds were planned at the vitrification cell welding station with instrumentation installed to quantify the ground current and its effects. WVNS was vigorously pursuing resolution of this issue, and based on the information obtained so far, staff believed that the 3
completed canister welds would be shown to be acceptable when all testing was completed.
IV. Recent Recordable Safety Events A. Waste Tank Farm Description On December 15,1997, in preparation for removal and replacement of the M-5 riser waste mobilization pump, two individuals were contaminated by liquid dripping from equipment at the waste tank farm. The leak occurred following a flushing operation to decontaminate the mobilization pump. After the flush, the personnel performing the work decided to purge the flush line with utility air to remove the water. The Work Order for the task did not address the equipment configuration for performing the purge, and therefore personnel in the field had significant latitude in determining how to accomplish the task. During the air purge process, liquid was forced through a regulator and dripped onto one individual's hand. The liquid was erroneously assumed to be clean l
condensate water and was wiped up with a cloth, which was handed to a Radiological Controls Technician to be checked for contamination. Both individuals were determined tc be contaminated after the cloth was found contaminated. The contaminated personnel responded well, preventing further spread of contamination to other personnel or areas. Bioassay results showed that no personnel had any intemal contamination due to the event. WVNS and DOE initiated investigation teams to review the event and determine the root cause.
Corrective Actions Findings of the WVNS investigation team identified as root causes a lack of adequate design control and hazard analysis, failure to comply with the work instructions and to include explicit work instructions, and the approach taken to contain the spill was non-conservative. Identified contributing causes of the event included failure to recognize the hazards involved, less than rigorous control of nonroutine work involving work orders as compared with operating procedures, and lack of adequate peer review. A Corrective Action Plan was developed, dated January 26,1998, which included 15 actions assigned to appropriate site organizations for implementation. WVNS and DOE personnel stated that the corrective actions have assured that work control mechanisms used at the site are now adequately controlled through a comprehensive revision to Engineering Procedure EP-5-002, " Work Instruction Preparation". Some new features of work control process review which were added to EP-5-002 include peer review of work orders, the requirement for a walk-down of facilities and equipment by a work group supervisor responsible for performing the work, specific requirements for acceptable pen-and-ink changes to drawings used in performance of work, and addition of a final authorization to perform work by the appropriate facility manager. WVNS also issued a guidance document, WV-921, " Hazards identification and Analysis", as part of the corrective actions in response to this event.
Similarities to the November 1996 Event Several aspects of the December 1997 contamination were similar to the November 1996 event in which high level waste backed-up into a demineralized water line at the vitrification facility. In both cases the mechanism for controlling the work allowed broad 4
flexibility in the field with less rigorous review requirements than for most procedures. In both cases that flexibility was used to perform actions in a sequence which produced unanticipated and undesirable consequences. In both cases the work which caused the event was different than previous tasks, and the procedural controls for review of the evolution were minimal. Following the November 1996 event several procedural control systems covered by SOP 00-02, " Preparing, Issuing, Field Changing, and Revising Developmental, Standard Operating Procedures (SOPS), and Special Instruction Procedures (SIPS)," were modified to better control field work. The Work Order process, which was used to control the December 15,1997 work at the waste tank farm, was not included in the corrective actions following the November 1996 event. One of the subsequent corrective actions for the December 1997 contamination event included a review of other work control processee at West Valley. Engineering Procedure EP 002, " Work Instruction Preparation", was revised to incorporate and supersede SOP 00-02, now specifying procedural controls for SOPS, SIPS, Developmental Operating Procedures, Work Orders, and Shop Orders. This is now the comprehensive and all-inclusive guidance document covering all mechanisms for controlling work at WVDP.
WVNS recognized the similarities in the November 1996 and December 1997 events.
The November 1996 root cause evaluation identified that equipment should be reviewed in which high level waste slurry was contained by a single barrier. This corrective action was carried out for equipment within and at the boundaries of the vitrification cell, and the December 1997 WVNS root cause evaluation stated, "This previously identified recommendation was adequate in scope, but did not go far enough in its application to other facilities. The corrective actions for the December 1997 event encompass not only the Waste Tank Farm, but all other systems on site containing significant concentrations of radioactive contamination or hazardous material".
Following the November 1996 event the DOE Office of Environment, Safety, and Health, Office of Oversight identified a concem that an inadequate hazards analysis had been performed for that work. WVNS stated in the Root Cause Evaluation for the December 1997 event that, "The hazard analysis did not identify the potential for backflow of contamination from the pump column during blowdown". WVNS corrective action will be incorporated in the implementing procedures for the integrated Safety Management System (ISMS), which will require an adequate job hazard analysis be performed as part of the work planning process. DOE is formally implementing the ISMS program at the West Valley site during FY98.
The monitor observed that since the November 1996 event WVNS management and staff had devoted significant effort and resources to addressing the identified root causes of the event and preventing recurrence. Each site organization has been working at improving the scope and quality of their individual self-assessment and trending programs. WVNS efforts have also included the Conduct of Operations team observations, improved performance monitoring, clarifications of management expectations for worker procedure compliance, organizational and personnel changes, improvements to procedures (such as Vitrification Operations taking responsibility for their own procedures), and the conduct of table-top discussions to optimize the procedures. Not included in the WVNS Root Cause Analysis report or corrective actions for the December 1997 event was any discussion of the changes that could be made to the Self-Assessment or performance monitoring programs to better identify the 5
i precursors to such undesirable events before they occur. Advance awareness of conditions and trends conducive to accidents is an objective of the Self-Assessment program, which was not successfulin preventing the December 15,1997 event. The
' WVNS Root Cause Analycis report described data indicative of deteriorating barriers that, in retrospect, may have established the framework which allowed the event to
. happen. These indicators may be useful in identifying precursor conditions for preventing future events. For example,
- ... administrative barriers which were either ineffective or lacking included... lack of adequate peer review by a person who is knowledgeable of the system design requirements and the potential hazards of the design and work documents; deviation from the approved work document...; non-conservative assumptions as to the nature of the liquid dripping from the regulator;...the absence of a stop and review mentality before the blowdown was initiated... awareness training on a previous back flush event in the Vitrification Facility...The engineer involved in this event had not attended this training because the training focused primarily on personnel involved in the Vitrification Facility." (p. 11, ' Administrative Barriers')
In particular, the above excerpt regarding "..the absence of a stop and review mentality.." and the potential over-reliance en training as a corrective action following the November 1996 event are representative indicators offering insight into subtle pror,rammatic changes which have slcwly occurred over time, presenting significant challenge to the self-assessment programs. The monitor discussed with DOE and WVNS how the self-assessment program, and other monitoring programs, could be modified to better maximize the probability of successfully preventing such adverse performance trends. Changes to the programs will be reviewed in a future visit.
Other Reportable' Events WVNS presented information on the 11 other reportable events that had occurred at WDVP since the last monitoring visit in November 1997. Event causes were still being investigated in several cases, however it appeared that causes for events in the Waste Management staging area and the Vitrification Facility included equipment failures, personnel errors, procedure problems, and noncompliance with procedures.
V. Self Assessment and Tronding Programs Efforts to improve the self-assessment programs were continuing. WVNS summarized activities in Main Plant, Vitrification Operations, and Radiological Controls. Recent emphasis continued on observations of plant activities and collection of data for trending. The Radiological Controls organization was implementing the program for observed evolutions, similarly to the Main Plant and Vitrification organizations. Data was presented on the number of activities observed and regarding future plans. WVNS management stated that the quality of findings was increasing as more evolutions were observed, and current emphasis was focused on the " walk-your-spaces" program and lock-out/ tag-out operations. Management observations were characterized as i
generating increased supervisor awareness of field activities. "On the Spot" correction of correctable issues was being emphasized, concurrent with the need for complete 6
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documentation to capture data for trending. Self-assessment programs were in the process of incorporating revisions to reflect improvements identified following the December 1997 personnel contamination event.
Results were presented for the Conduct of Operations Self-Assessment conducted October 20-24,1997. A report had been issued November 20,1997, and included 146 findings that generated four areas of concem. The four concems documented in the Report were: 1) the lack of adequate definition, communication and enforcement of management expectations,2) lock and tag deficiencies are continuing to be identified, in spite of recent site-wide efforts to improve performance, 3) the need to continue improvement of field practices was confirmed, having also been identified by several earlier assessments, and 4) configuration control must be improved to better support operations personnel. Work was in progress to address the findings, with 41 findings closed and the remaining 105 being actively worked.
VI. Low-Level Waste No waste has been shipped from the site since September 1997. Waste is being packaged in preparation for shipment, however there are issues to be resolved before l
more shipments will be made. A question had arisen about U-233 not being an acceptable contaminant at one of the burial sites. The attemate burial site is substantially more expensive, prompting exploration of potential other options. Another option being explored for the ion exchange resin is to ship it offsite for processing and I
volume reduction, followed by burial. Until the outstanding issues are resolved, WVNS anticipates packaging for shipment and storing on site the North Plateau resin and dry active waste generated at the site.
Vll. North Plateau Status Additional characterization of the North Plateau groundwater plume occurred during July and October 1997, providing recent data on plume movement and concentrations.
Three recovery wells for pumping and treating groundwater continue to be effective in l
slowing the spread of the plume, and WVNS estimates that 90% of the Sr-90 in the primary lobe of the plume is captured and removed by the treatment system. A technical peer review group was convened in October 1997 to provide independent, extemal technical review and comments on WVNS activities and plans regarding the Sr-90 plume. Comments and input from the Peer Review Group were considered in development of the " Summary Plan for the North Plateau Groundwater Plume", which is intended to integrate planning for characterization and control of the core of the plume, and management of the plume leading edge. The plan includes the following elements:
continue operation of the current pump and treat system; complete characterization of the eastem plume lobe; perform cost-benefit analysis of tha current pump and treat i
system; evaluate options for control of the plume eastem lobe; prepare sampling and analysis plan for the core area of the plume; initiate the core sampling and analysis plan; and start evaluating technologies applicable for core area control. Work on each of the plan's elements is scheduled for FY98 and will be reviewed during future monitoring visits.
Vill. Molter Noble Metal Buildup 7
Buildup of noble metals in the melter had closely followed the model as predicted by WVNS during the period since the last monitoring visit. It was estimated that 5-10% of the noble metals present in the high level waste slurry transferred to the melter remain in the metter vessel. The problem has continued to be closely studied, and WVNS continues to conclude that noble metal accumulation should not limit the useful life of the melter at WVDP. Nevertheless, WVNS is exploring modeling refinements and altemative equipment that might be usefulin making better measurements or supplementing melter equipment in case of unanticipated degradation of metter performance.
IX. Citizens Task Force The monitor attended a Citizens' Task Force ( Meeting on March 17,1998. The focus of the meeting was achieving consensus on the wording of a draft " General Principles" i
document, planned to be part of the report and recommendations the CTF expects to l
produce.
l X. Management Meetings l
The monitor presented the results of this visit to senior DOE and WVNS management l
and staff at the conclusion of the visit on March 20,1998.
l XI. References The following documents are referenced in this monitoring report:
1.
" Independent DOE Investigation and Analysis of Waste Tank Farm Contamination l
Event on December 15,1997". Memo WFH:024-55728-234.2 dated March 27, 1998, W.F. Hamel to T.J. Rowland.
2.
1ndependent Root-Cause Analysis of the December 15,1997, Waste Tank Farm j
Contamination Events". Memo BA:98:0001 dated January 26,1998, J.L. Little to R.R. Campbell.
3.
" West Valley Nuclear Services Self-Assessment of Conduct of Operations (October l
20-24, 1997)". Memo JJ:97:0004 dated November 20,1997, W.R. Chiquelin to Distribution.
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PARTIAL LIST OF PERSONS CONTACTED Department of Enerav - West Vallev Demonstration Project Thomas Rowland, Director Richard Provencher, Associate Director William Hamel, Operations and Engineering Team Leade-David Cook, General Engineer T.J. Jackson, Safety, Health & QA Team Leader Herman Moore, Remedial Projects & Waste Management Team Leader West Vallev Nuclear Services. Incorporated Robert Campbell, President James Little, Executive Vice President Paul Valenti, Vitrification Operations Manager Richard Marcellin, Waste Tank Farm Operations Manager John Garcia, Radiation Protection Manager Jeff Slawson, Dosimetry Health Physicist Michael Kubiak, Dosimetry Health Physicist Robert Lawrence, Transition Projects Manager Stuart MacVean, Site Operations Manager Robert Fussner, Vitrification S' ift Operations Manager n
David Shugars, Quality Assurance Manager j
Ellery Savage, Environmental, Safety, Quality Assurance, and Lab Operations Manager Dan Meess, Tank Farm and IRTS Engineering Manager Mae Wright, Waste Management Manager Tom Cottrell, Operations Projects & Support Manager Bruce Covert, Operations Technical Support Manager Jack Gerber, Safety Analysis & Integration Manager Steve Bames, Vitrification Process and WQR Compliance Manager Tom Kocialski, Vitrification Systems Engineer Craig Repp, Transition Environmental Programs Manager Mark Hemann, Project Engineer John Chamberlain, Public and Employee Communications Manager 9
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l of the plan's elements is scheduled for FY98 and will be reviewed during future monitoring visits.
Vlli. Molter Noble Metal Buildup Buildup of noble nietals in the melter had closely followed the model as predicted by WVNS during the period since the last monitoring visit. It was estimated that 5-10% of the noble metals present in the high level waste slurry transferred to the melter remain in the melter vessel. The problem has continued to be closely studied, and WVNS continues to conclude that noble metal accumulation should not limit the useful life of the melter at WVDP. Nevertheless, WVNS is exploring modeling refinements and attemative equipment that might be usefulin making better measurements or supplementing melter equipment in case of unanticipated degradation of melter performance.
IX. Citizens Task Force The monitor attended a Citizens' Task Force ( Meeting on March 17,1998. The focus of the meeting was achieving consensus on the wording of a draft " General Principles" document, planned to be part of the report and recommendations the CTF expects to produce.
X. Management Meetings The monitor presented the results of this visit to senior DOE and WVNS management and staff at the conclusion of the visit on March 20,1998.
XI. References The following documents are referenced in this monitoring report:
1.
" Independent DOE Investigation and Analysis of Waste Tank Farm Contamination Event on December 15,1997". Memo WFH:024-55728-234.2 dated March 27, 1998, W.F. Hamel to T.J. Rowland.
2.
1ndependent 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.
3.
" West Valley Nuclear Services Self-Assessment of Conduct of Operations (October l
20-24, 1997)". Memo JJ:97:0004 dated November 20,1997, W.R. Chiquelin to Distribution.
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PARTIAL LIST OF PERSONS CONTACTED Department of Enerav - West Vallev Demonstration Project Thomas Rowland, Director Richard Provencher, Associate Director William Hamel, Operations and Engineering Team Leader David Cook, General Engineer T.J. Jackson, Safety, Health & QA Team Leader Hennan Moore, Remedial Projects & Waste Management Team Leader West Vallev Nuclear Services. Incorporated Robert Campbell, President James Little, Executive Vice President Paul Valenti, Vitrification Operations Manager Richard Marcellin, Waste Tank Farm Operations Manager John Garcia, Radiation Protection Manager Jeff Slawson, Dosimetry Health Physicist Michael Kubiak, Dosimetry Health Physicist Robert Lawrence, Transition Projects Manager i
Stuart MacVean, Site Operations Manager Robert Fussner, Vitrification Shift Operations Manager David Shugars, Quality Assurance Manager Ellery Savage, Environmental, Safety, Quality Assurance, and Lab Operations Manager Dan Meess. Tank Farm and IRTS Engineering Manager Mae Wright, Waste Management Manager Tom Cottrell, Operations Projects & Support Manager Bruce Covert, Operations Technical Support Manager Jack Gerber, Safety Analysis & Integration Manager Steve Bames, Vitrification Process and WQR Compliance Manager Tom Kocialski, Vitrification Systems Engineer Craig Repp, Transition Environmental Programs Manager Mark Hemann, Project Engineer John Chamberlain, Public and Employee Communications Manager 9
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