ML20265A355
| ML20265A355 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, P00M-032 |
| Issue date: | 09/22/2020 |
| From: | Amy Snyder Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Bower B US Dept of Energy, West Valley Demonstration Project |
| Amy Snyder | |
| References | |
| Download: ML20265A355 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 22, 2020 Bryan C. Bower, Director West Valley Demonstration Project U.S. Department of Energy 10282 Rock Springs Road West Valley, NY 14171-9799
SUBJECT:
U.S. DEPARTMENT OF ENERGY WEST VALLEY DEMONSTRATION PROJECT MAIN PLANT PROCESS BUILDING DECOMMISSIONING &
DEMOLITION PLAN, WVDP-586, REVISION 4, DATED MAY 07, 2020 (DOCKET NO. 05000201 (POOM-032))
Dear Mr. Bower:
The U.S. Department of Energy West Valley Demonstration Project (DOE-WVDP) transmitted the subject document to the U.S. Nuclear Regulatory Commission (NRC) staff for review in a letter dated May 18, 2020 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML20209A534). In this letter, DOE-WVDP stated that that the revision serves to reflect the current status of the pre-demolition activities including an update to the demolition approach.
The NRC staff have reviewed the document and have comments. Please, find their comments enclosed.
As indicated in the DOE-WVDPs June 19, 2019, letter, once the Main Plant Process Building (MPPB) characterization and analyses are complete, the West Valley Demonstration Project (WVDP) personnel will meet with NRC staff to review the supporting information and summarize how the planned MPPB demolition will meet the prescribed limits for open-air demolition. Also, DOE-WVDP will provide the NRC with the MPPB radionuclide inventory and analyses verifying the MPPB demolition will not exceed the National Emissions Standards for Hazardous Air Pollutants limits (Title 40 of the Code of Federal Register Part 61). The NRC staff looks forward to this meeting and review of the analyses, as well as reviewing the response to the NRC staff comments on Rev. 4 of the MPPB Decommissioning & Demolition Plan.
In accordance with Title 10 of the Code of Federal Register Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
B. Bower 2
If you have any questions or need any additional information regarding our comments, please contact Ms. Marlayna Doell at Marlayna.Doell@NRC.gov or 301 415 - 3178.
Sincerely, Amy Snyder, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards
Enclosure:
Comments on Main Plant Process Building Decommissioning &
Demolition Plan, WVDP-586, Rev. 4 cc w/enc: P. J. Bembia, NYSERDA West Valley List Serv Amy M. Snyder Digitally signed by Amy M. Snyder Date: 2020.09.22 13:48:37 -04'00'
BWatson*
ASnyder*
DATE 9/21/20 9/21/20 9/22/20
Enclosure Comments on Main Plant Process Building Decommissioning & Demolition (D&D) Plan, WVDP-586, Rev. 4
- 1. Demolition Approach:
In Section 6.3, Demolition Approach, of the Main Plant Process Building Decommissioning &
Demolition (MPPB) Plan (Plan), Rev. 3, the U.S Department of Energy - West Valley Demonstration Project (DOE-WVDP) states:
The overarching demolition approach and planned sequencing for the MPPB is to perform the demolition in a stepwise manner from the known radiologically "cleanest" areas (the outer support areas, interior support areas, and interior aisles) to those areas more impacted by prior processes (CPC [Chemical Process Cell], PMC [Process Mechanical Cell], LWC (Liquid Waste Cell), Extraction Cells, VWR [Ventilation Wash Room], Hot Cells) and from top to bottom.
In Section 6.3, Demolition Approach, of the Plan, Rev. 4, DOE-WVDP states:
The overarching demolition approach for the MPPB is to perform the demolition in a stepwise manner based on structural evaluation from support areas (stairways, aisles, roofs) to main process areas (CPC, PMC, LWC, Extraction Cells, VWR, Hot Cells) and from top to bottom.
The rationale DOE-WVDP provides for this change remains the same as provided in Rev. 3 of the Plan:
This will minimize the potential for cross-contamination of facility areas, minimize migration of contamination and will reduce the time and resources associated with decontaminating equipment and materials from one area to another. This conceptual sequencing approach was successfully implemented during D&D of the WVDP 01-14 Building and during VF (Vitrification Facility) demolition.
As noted, in Attachment F, Main Plant Process Building (MPPB) Facility Demolition Schedule, the demolition sequencing has changed. However, as noted in Section 5.2, Deactivation Activities Remaining, [D]econtamination activities will continue to progress until such time that the structure meets prescribed limits for open air demolition. Actions such as painting surfaces and using a water curtain are being used to keep exposure during demolition ALARA (as-low-as reasonably-achievable). Does the sequence of demolition influence exposure?
The U.S. Nuclear Regulatory Commission (NRC) staff seeks further clarification on the reason and technical basis for the change in demolition approach and sequencing. Specifically, are there any impacts on radiological health and safety of worker and public, to include waste management or water management as a result of the change in approach and sequencing? If so, please elaborate.
- 2. Characterization:
- 2. a. Section 1.3, Scope, states that the MPPB contains, among other things, a summary of characterization information and an overview of the management approach. Although DOE-WVDP describes its characterization approach for accessible areas, it is unclear how
2 DOE-WVDP plans to address areas or items that need special handling, such as contaminated piping that will remain before demolition begins and will be removed during demolition.
2.b. In Section 3.1, Radiological Characterization, DOE-WVDP states:
Surfaces of the facility will generally be painted (i.e., fixative applied) before MPPB demolition to reduce the remaining loose activity levels. Data collected (emphasis added) are utilized for dose modeling to support demolition sequencing and limits (i.e., maximum number of square feet in a given area that can be removed or demolished in a given time period).
Characterization data will also be used to model potential dose to onsite workers (i.e., using AERMOD, air dispersion modeling system and WVDP-593, Air Monitoring of Radioactive Releases During the Uncontained Demolition of the West Valley Vitrification Facility) and the public (i.e. the maximally exposed off-site individual [MEOSI] using CAP88 dose modeling software).
It is unclear how does DOE-WVDP plans to address radiological characterization and dose modeling before demolition of the sealed rooms, any other parts of the MPPB that are not accessible for data collection for radiological characterization (inventory) and dose modeling.
- 2. c. Further, in Section 7.1.2, Radiological Characterization, DOE-WVDP states:
Waste package characterizations will utilize the same unit-by-unit source term estimates being prepared to substantiate the acceptability for open-air demolition. The disposition of each unit/component will be tracked to individual waste packages and summed to provide the total radioactivity content of a given package.
Please clarify DOE-WVDPs strategy for inaccessible areas and items that need special handling during demolition to determine the maximum number of square feet in a given area that can be removed or demolished in a given time period to protect worker and public health and safety during demolition.
- 3. Waste Generation:
Section 6.1 states: The following general performance criteria will be incorporated into the work scope for the MPPB D&D:
during the decommissioning and demolition work, CHBWV will minimize the generation of difficult to dispose of waste streams such as transuranic (TRU) and mixed-TAUTRU waste and mixed low-level waste (MLLW);
Clarify whether DOE-WVDP expects the generation and disposal of all the above-mentioned waste streams. If so, please elaborate on the approach to manage such waste streams and identify the estimated waste quantities the MPPB decommissioning.
- 4. Waste Debris Controls Strategy:
In reviewing the Hanford Plutonium Finishing Plant corrective action report, controls were put in place for the project after December 2017 to better manage waste. Strategies or guidance for the movement of materials that needed special handling during demolition; waste segmentation; waste loading, and staging were put in place. Also, requirements for not allowing waste piles to
3 accumulate were instituted. In Section 6.0, of the Rev. 4 of the Plan, DOE-WVDP added the following lessons learned that it stated will be factored into the planning of the MPPB demolition:
control of debris piles, including waste loading speed, less aggressive waste conditioning, and use of dust suppression; preparing an adequate supply of waste containers ready for loading; Section 6.1, of the Plan states that [D]ebris piles will be sprayed with a suppressant at the end of each day or more frequently and that the [A]pplication of additional fixative will be considered for demolition materials/debris that require further processing on the ground or are awaiting packaging into waste containers. Further, the Plan briefly mentions staging of waste, but there is limited information on the strategy on how the demolition waste debris and waste packages will be staged or move for segmentation or material added to the already existing waste piles located on the ground.
4a. The NRC staff seeks further elaboration on strategy for staging demolition debris and loading.
4b. What is DOEs strategy for how long that demolition debris should be on the ground accumulating before it is packaged, regardless of whether additional fixative is applied.
4c. Please explain the guidance or criteria for when additional fixative should be applied to the debris that is on the ground, besides at the end of the day.
4d. During the Vitrification Facility demolition, DOE-WVDP announced that it completed demolition and then addressed the remaining demolition debris. Please elaborate whether this will be the same strategy for the more contaminated MPPB demolition.
- 5. Monitoring:
Will there be multiple measurements downwind to detect dispersion of dusts? For the MPPB demolition this approach may be more critical than the Vitrification Facility demolition since the source term is more risk significant and could become airborne. At the Hanford Plutonium Finishing Plant demolition, a metal plate system was used. Does DOE plan to use such an approach for the MPPB D&D?
- 6. Work Control Strategy.
6 a. Based on the Hanford Plutonium Finishing Plant Demolition Resumption Expert Panel Final Report, it appears prudent for the MPPB Work Instruction Packages (WIPs) to include specific stop work requirements, based on the modeling insights that include weather, i.e., wind speed, direction, weather forecasts, precipitation. Also, explain whether management will be involved in making such stop work decisions based on weather and how they would be aware of all meteorological issues.
6b. While it appears that there has been significant source reduction based on the pre-demolition activity updates in Rev. 4 of the Plan, NRC staff suggests that DOE-WVDP address the strategy or commitments for:
The type of surveys needed and what was done and will be done to control potential hide-out of high levels of contamination in interstitial gaps: floor to floor, floor to wall, wall to wall, wall to ceiling given that the MPPB is highly compartmentalized.
Radiological inventory strategy for sealed rooms.
4 Based on the processes performed in the MBPP (spent fuel chopping) and the use of fixatives, once demolition is being performed, there is the possibility for hot particles.
The Radiation Program should include surveys geared to hot particle detection on workers and address surveys for the lands once the waste debris is removed.
- 7. As a part of the lessons learned from the Vitrification Facility Demolition, will DOE-WVDP comment on how efficient the water collection system was during demolition? How much water was recovered compared to the amount used? Has DOE-WVDP enhanced its water collection strategy and berming approach as compared to that used for the Vitrification Facility demolition.
- 8. Dose Modeling:
In reviewing Rev. 4 of the Work Plan, the NRC staffs questions submitted on April 27, 2020 (Agencywide Documents Access and Management System Accession No. ML20115E497), as related to the MPPB demolition still stand. The NRC staff would like to understand how its April 27, 2020, comments on dose modeling as related to the MPPB were addressed and whether there were any changes to the Plan as a result of the NRC staff comments.