IR 05000201/2023001

West Valley Demonstration Project - U.S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2023001

ML23081A080
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	03/28/2023
From:	Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch
To:	Bower B US Dept of Energy (DOE)
References
IR 2023001
Download: ML23081A080 (1)

Text

March 28, 2023

SUBJECT:

WEST VALLEY DEMONSTRATION PROJECT - U.S. NUCLEAR REGULATORY COMMISSION MONITORING VISIT REPORT NO.

05000201/2023001

Dear Bryan C. Bower:

On February 22 - 23, 2023, the Nuclear Regulatory Commission (NRC) conducted an announced monitoring visit at the U.S. Department of Energys West Valley Demonstration Project site to review ongoing decommissioning activities. The monitoring visit consisted of observations by the NRC representatives, interviews with site personnel, a review of procedures and records, and site walkdowns supplemented by in-office reviews and periodic phone calls.

The results of the monitoring visit were discussed with you on February 23, 2023, and are provided in the enclosed report. No public health and safety issues of more than minor significance were identified.

No reply to this letter is required. Please contact Katherine Warner of my staff at (610) 337-5389 if you have any questions regarding this matter.

Sincerely, Digitally signed by Anthony M. Anthony M. Dimitriadis Date: 2023.03.28 Dimitriadis 15:03:31 -04'00'

Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security Docket No. 05000201 License No. CSF-1 Enclosure:

Report No. 05000201/2023001

EXECUTIVE SUMMARY

U.S. Department of Energy (DOE)

West Valley Demonstration Project (WVDP)

NRC Monitoring Visit Report No. 2023001 An announced monitoring visit was conducted on February 22 - 23, 2022 by U.S. Nuclear Regulatory Commission (NRC) staff at the DOE WVDP site in West Valley, New York supplemented by in-office reviews and periodic phone calls. NRC staff also attended the DOE quarterly public meeting held on February 22, 2023. The monitoring visit included reviews of programs and activities associated with the West Valley site decommissioning project. The monitoring visit consisted of observations by the NRC staff, interviews with site personnel and New York State Energy Research and Development Agency (NYSERDA) personnel; a review of procedures and records, and walkdowns of the facility. The program for conducting NRC monitoring visits at the WVDP is described in Inspection Manual Chapter (IMC) 0111, Region I Monitoring Activities for the Department of Energy West Valley Demonstration Project.

Based on the results of these activities, no public health and safety issues of more than minor significance were identified.

REPORT DETAILS

1.0 Introduction In accordance with the WVDP Act of 1980 and as implemented by a Memorandum of Understanding between the DOE and the NRC, an announced routine monitoring visit was conducted on February 22 - 23, 2023 by NRC staff at the DOE WVDP site in West Valley, New York supplemented by in-office reviews and periodic phone calls. NRC staff also attended the DOE quarterly public meeting on February 22, 2023. The program for conducting NRC monitoring visits at the WVDP is described in IMC 0111. The monitoring visit included reviews of programs and activities associated with the WVDP site decommissioning project.

2.0 Main Plant Process Building (MPPB) Demolition

a. Inspection Scope

The MPPB was the main facility used for commercial nuclear fuel reprocessing; the MPPB was built between 1963 and 1966 and used by Nuclear Fuel Services from 1966 to 1972. The building consists of a series of cells, aisles, and rooms that are mostly above grade with a couple extending below ground surface. Portions of the MPPB were modified over the past four decades by the WVDP to support mission activities such as solidifying high-level waste.

The NRC reviewed DOEs MPPB Demolition Work Instruction Package (WIP) and MPPB demolition activities, including recent revisions to the WIP and technical basis documents. The monitoring visit consisted of interviews with DOE staff and contractor personnel, including discussions with cognizant personnel on the demolition activities.

NRC staff performed walkdowns of the site, including areas around the outside of the MPPB, the rail operations area, the waste storage building, the remote-handled waste facility, the water management system, including the series of frac tanks, waste preparation and load out areas, and the radiological control room.

b. Observations and Findings

In September 2022, CH2M HILL BWXT West Valley, LLC (CHBWV) began the phase of its contracted work to demolish the MPPB to grade level (100 +/- 3 ft) safely. All below-grade structures were previously grouted with controlled low-strength material in preparation for demolition activities. At the time of this visit, demolition had progressed without incident and included the upper warm aisle, lower warm aisle, and extraction cells. During the monitoring visit, NRC staff observed demolition in the southwest corner of the MPPB, including the Extraction Chemical Room monorail, and noted the appropriate use of dust suppression. Site personnel discussed the effectiveness of dust suppression and actions taken when visible dust was observed, or wind conditions caused interference. Inclement weather during the monitoring visit provided an opportunity to discuss stop work criteria for weather conditions, and the work groups appeared to be making appropriately conservative decisions in prioritizing worker safety.

The use of dust suppression during demolition is a protected assumption in the WIP.

The site experienced some difficulties with the application of dust suppression, but techniques had improved with additional DOE and contractor oversight. No releases above alert limits occurred. There have also been challenges to a protected assumption in the WIP related to the required timeframe for removal of debris following demolition activities. These challenges had been addressed, including but not limited to tracking protected assumption compliance and additional quality assurance criteria for contractors, and performance had improved. No releases or dose impacts have been associated with debris remaining on the ground longer than the specified timeframe.

Airborne activity monitoring at the site was provided by environmental continuous air monitors (ECAMs) and fixed air samplers (FASs) around the perimeter of the demolition area. The ECAMs transmit near-real-time data to the control room, where activity levels are monitored against three escalating action levels. NRC staff found all 14 ECAMs operational and communicating with the control room at the time of the monitoring visit.

On February 15, 2023, a Level 3 alarm was received from one of the ECAMs, which was later determined to be a false alarm caused by a malfunction of the detector. No work was being performed at the time of the alarm due to wind conditions. The site Emergency Operations Center (EOC) was activated, radiological surveys were performed to verify conditions, and the ECAM filter was analyzed. No detectable contamination was identified. NRC staff reviewed the radiological survey data and independently verified that levels were below alarm setpoints. Discussions with site personnel indicated that the response to the alarm from site staff was satisfactory.

The technical basis documents for Air Dispersion Modeling, Estimated Radiological Air Emission, and Radionuclide Inventory were revised to account for a change in the demolition technique used for the Acid Recovery Cell (ARC) floor. Originally the floor was to be cut into blocks and removed, however COVID supply chain disruptions and delays in manufacturing necessitated the use of a different saw. Due to limitations of the cutting saw, the perimeter of the floor required a change of methodology to hammer demolition for effective deconstruction. The WIP was revised through the field change process to raise the minimum demolition time for the Acid Recovery Pump Room (ARPR) from 30 to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> based on the new analysis to include the hammering of the ARC floor perimeter. Minimum demolition times are calculated using the EPA air quality dispersion model AERMOD. Field Change 6 to the WIP also included additional adjustments in minimum demolition time for several other demolition activities to align with newly calculated AERMOD times based on radiological boundary limitations rather than physical demolition times. The NRC staff reviewed the changes and verified that estimated doses from air emissions during demolition remained well below the 10 mrem/year limit.

c. Conclusions

No public health and safety issues of more than minor significance were identified.

4.0 Public Meetings DOE WVDP Quarterly Public Meetings NRC staff attended the DOE quarterly public meeting on February 22, 2023. DOE staff and contractors provided updates on various project milestones and future plans, including upcoming sampling activities in the tank farm and the Probabilistic Performance Assessment model for Phase 2 decision making. The meeting was held in hybrid format (virtual and in-person presence), and NRC staff attended in-person.

5.0

Exit Meeting Summary

The NRC Region I representatives discussed the monitoring visit results with Bryan C.

Bower, Director of the WVDP on February 23, 2023.

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Department of Energy Staff and Contractors

B. Bower, Director WDVP

J. Dundas, Safety and Site Programs Team Leader

B. Freaney, Work Group Supervisor

J. Prowse, DOE Contractor

NYSERDA

P. Bembia, Program Director

A. Mellon, Project Manager

P. Vlad, Program Manager

PARTIAL LIST OF DOCUMENTS REVIEWED

Monthly WVDP Project Performance Reports (various)

Weekly WVDP Project Status Reports (various)

RWP 2023-2001 Revision 0

W1094751, Work Instruction Package Main Plant Process Building Demolition, Field Change 6

WVDP-602, Main Plant Process Building (MPPB) Demolition Contamination and Radiological

Air Monitoring Plan, Revision 2

Radiation and Contamination Survey Report 204512 15 Feb 2023

WVDP-605, Estimated Radiological Air Emission During Open Air Demolition, Main Plant

Process Building, Revision 5

WVDP-605, Estimated Radiological Air Emission During Open Air Demolition, Main Plant

Process Building, Revision 4

WVDP-607, Air Dispersion Modeling for Open Air Demolition, Main Plant Process Building,

Revision 5

WVDP-606, Main Plant Process Building Radionuclide Inventory for 40 CFR 61 Subpart H,

Revision 4

EM-OH-WVDP-CHBW-DD-2023-0001, Occurrence Report for EOC Activation Following Level 3

Alarm on ECAM 1

LIST OF ACRONYMS USED

ARC Acid Recovery Cell

ARPR Acid Recovery Pump Room

CHBWV CH2M HILL BWXT West Valley, LLC

CFR Code of Federal Regulations

DOE Department of Energy

ECAM Environmental Continuous Air Monitor

EOC Emergency Operations Center

FAS Fixed Air Sampler

IMC Inspection Manual Chapter

MPPB Main Plant Processing Building

NRC Nuclear Regulatory Commission

NYSERDA New York State Energy Research and Development Authority

WIP Work Instruction Package

WVDP West Valley Demonstration Project

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