ML20091C224

DOE West Valley Project Ofc Operational Readiness Review Plan for Resumption of Integrated Radwaste Treatment Sys Operations,High Level Waste Treatment Phase II - Sludge Wash

ML20091C224
Person / Time
Site:	West Valley Demonstration Project
Issue date:	07/24/1991
From:	Rowland T, Yaezel J ENERGY, DEPT. OF
To:
Shared Package
ML20091C219	List: ML20091C214 ML20091C224
References
REF-PROJ-M-32 PROC-910724, NUDOCS 9108060091
Download: ML20091C224 (11)

Text

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COE WEST */ ALLEY ?ROJECT OFFICE c ? EFATICNAL PEAD::'ESS FE'/IEU CLA!1

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1 Concurrence:

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J. A. Yeazel, IRTS & Vitrification Date Operations Manager West Valley Pro]ect office 4 '

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sww Rokland, Director 7 M 7)

Date  :

West Valley Project Office D.B. Engelman, Director Cate Waste Management 2'.vlsion Plan Approval:

T.F. Burns, Acting Assistant 4anacer Date Invironnental Rest: ration and Naste Management, Authori:Ina ::f _;u 9108060091 910726 PDR PROJ M-32 PDR

1 REVIEWED ACTIVITY

1. Facility: West Valley Demonstration Project IRTS (Integrated Radwaste Treatment System)

Phase II, iiigh Level Waste Treatment - Sludge Wash

2. C_ogallantyivision Director: D.Engel=an, Director, Waste Management Division

3. Completion MilestoDo: Final report and recommendation submitted to ID Manager on Wednesday, October 2, 1991

4. ORR Number:

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'mFPOSE By DOE Order 5480.5, Satety of !1uclear Facilities, DOE Idaho order 5480.5A, Safety of 11uclear Facilitias, and as described by ER&WM Procedure 603, DOE is required to review the operational readiness of a high/ moderate hazard system or facility which is to be

" operated in a now or significantly different mode".

This is an " independent" DOE review ind is in addition to the internal reaciness review cncuctec cy :ne on site operating contracttr West " alley !!uclear Services Co. , Inc.

SCOPE This Plan addresses the resumption at !RTS Coerations for sludge wash protreatment of high-level waste (HLW). Pretreatment of the HLW Supernatant was the first er several radioactive waste treatment steps, or pnases, plannec for the IRTS which is composed of several cuesystems three of wnich began operations in May of 1988. Sludge Wash follows as the next step of HLW treatment. For Supernatant treatment the f eedstock was the HLW liquid covering the s]udge stored in tank 8D2 since the days of fuel reprocessing in the '60's. Approximately 70% of the supernatant was successfully stripped of its hign-level Cesium component with the resultant low-level stream converted to a Class C coment waste form.

The f eedstock f or the second phase of the operations will originate f rom the same waste tank (8D2) , however, the feed will be the water used to " wash" the HLW sludge mixed with the remnant " heel" of supernatant remaining from the first processing step. The washing process, driven by several in-tank mixing pumps, will cause certain chemical " salts" now in the sludge, to dissolve. The resultant liquid, af ter sludge settling, will again te f ed to the IRTS as in the supernatant pnase. And again the high-level waste components, which now include not only cesium remnants but also Plutonium, and other possible radionuclides, will be stripped out of the feedstock and the resultant low-level waste converted to a Class C cement waste form.

It is important to recognize that this proposed operation is not a start-up of a new cperational facility, nor is it the re-start of a previous operation snut down for safety reasons or equipment failure. Both of these conditions are explicitly covered in the DOE Orders and have prescribed authorizations for start-up. In this case, the proposed operation is the resumption of an existing operation with a few minor modifications of the process chemistry and equipment added to handle the wash water feedstock. Two new subsystems have been aided: The Cludge Mobilization Pumps and the Caustic Addition system.  !!ew replacement equipment has been tided to repair failed parts or sucsystem elements where needed. In addition, the ion exenange material has been changed by adding a titanium coating to the base naterial (zeolite) to capture dissolved pluton)um. These items will receive additional scrutiny by the CRRB s;nce they represent chances to the approved operational baselite.

The DOE Operational Readiness Review (ORR) Plan is designed to allow the members of an ORR Board to systematically examine the readiness of the West '/ alley Organization, facilities, and equipment needed to proceed with the sludge washing operation.

Even though this is an " independent" and separate review by DOE, it will take advantage of much of the work being done by the operating contractor - WVNS (West Valley Nuclear Services). The work scope will focus on two levels of review: First, the work performed by ,

WVNS will be "overviewed" to ascertain its coverage, completeness, and depth of readiness assessment; second, the review will " sample" specific items in depth, i.e., detailed assessments 7f the condition of selected items of equipment, procedures, technology or personnel will be done.

READINESS REVIEW ORGANI;ATION l

To determine " readiness" a team of reviewers will be assembled  !

forming an of ficial DOE Operational Readiness Review Bosrd (ORRB) .

The team will consist of a variety of experts in a , tide range of disciplines - safety, nuclear criticality, environment, engineering design / construction, operations, etc. In addition to the of ficial Board members, a number of " observers" will be invited to ,

participate in the process. l The Board will meet periodically in accordance with the established schedule, and will prepare, approve and utilize an ORR " tree" and a " checklist" covering che proposed operations. The Board's objective will be to issue a recommendation of acceptance of the state of readiness of WVNS and the proposed Sludge Wash Operation to the approving official. Final recommendations will be by majority vote; however, minority opinions will not be precluded from the record.

Appendix A is the makeup of the Board showing both members and observers.

APPROVAL AUTHORITY Authority to start or restart operations of nuclear facilities is described in DOE Order 5480.5, Safety of Nuclear E. ilities. Other recent orders, letters, and SEN-16A-90 also address the issue of start-up of nuclear facilities. None of these explicitly address the concept of resumotion of coerations where the same system is to be used with a dif ferent f eed, or with modifications not related to

-Safety.

To be conservative, the WVPO has chosen to utilize the provisions of DOE Order 5480.5, para: 7.e.(5)&(6) which authorize the Field Office Manager to approve the:

" initial operation of a new hign/ moderate hazard nuclear f acility . . . " or " Authorite. . . modifications that involve an unreviewed safety questien only after assuring that:

( v. ) Approval has been octained from the cognizant PSO with selecrea moderate hazard facilities wnen an unreviewed sarety question exists."

Se proposed Sludge Wasn System doesn't fit either of these conditions, i.e., it is not a _new system, nor does an unreviewed gfety question exist. However, DOE Idaho, ER&WM Procedure 503 doen address operations of systems which are to be " operated in a new or significantly dif ferent mode". The original authorization for IRTS operations was provided by the Field Office Manager in 1988. This Plan follows the precedent established dn 198'8 and the currently available guidance on readiness reviews.

Therefore, for the purpose of resuming IRTS Operations for HLW Sludge Washing, the DOE-WVPO ORR Eoard will prepare an independent report characterizing the readiness condition of the proposed operations for presentation to the ID Field Office Manager for his approval.

Si3MMARY WORK PLAH The readiness review work plan is laid out in accordance with a logical sequence of steps commonly referred to as an ORR " tree",

designed to examine "reaciness" from the top down anc over a broad range of interrelated areas. These will cover operations management; equipment and hardware; traceability of documentation from requirements to design, to as-built conditions and equipment; technology; safety and environmental protection analysis; emergency provisions, as well as procedures and training.

Table 1 provides a summary breakdown of the areas to be reviewed:

1. Orcanization and Personnel: Both the DOE and WVNS organizations will be examined to determine whether the responsible groups have sufficient resources to provide sustained support for the operations of the sludge wash system. This will include the status of the management control and reporting systems, "off-normal" reporting, emergency control, and procedures by which management and support groups provide assistance to the operations of the sludge wash process.

Engineering support will be examined to ascertain if sufficient technical support is available to provide technical resolution of upset conditions, corrective action needs, and technical consultation on a sustained basis.

Operations itself will be reviewed to determine if sufficier' manpower is dedicated to sustain full scale operations and if sufficient resources are provided to properly maintain and upgrade the system as needed.

2. Facilities and Hardware; The Integrated Radwaste Treatment System (IRTS), the system proposed for sludge Washing, will be eva]7atea f rcm a "mecnanical readiness" viewpoint keeping in mind the fact that this system is currently " operational' and is not a new system.

Documentation assuring that the IRTS has been maintained during the perica at moaification and changeover to

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sludge wash will be reviewed. New equipment and systems such as the Mobilization Pumps and Caustic Addition System will be examined for documentation beginning with the approved requirements such as Functional and operational Requirements (or equivalent), followed by design criteria, and final approved construction and fabrication documents will be reviewed for completeness, approvals, change control, quality and the incorporation of the appropriate DOE requirements derived from Orders, standards, regulations, etc.

3. Procedural Readiness: Procedural readiness will be examined by reviewing the procedures, technical requirements (Tech. Requts.), operational safety requirements (OSR's), as well as operator training and certification.

The procedures will include a full set for each of the process steps involved in the process. Fcr example, sludge mobilization, operational control and monitoring or the waste tank, the ion exchange system (STS), the evaporator cycle, cement solidification system (CSS),

cross site waste transfer, Drum Cell storage operations, etc. Integration of the procedures for each of the interrelated operational steps will be examined, and the provisions for handling operational upsets, or

" disconnects" cetween steps will be considered.

Provisions for Emergency responses and tie-ins to the West Valley Emergency Plan will be examined.

The Tech Specs and OSRs will be compared to the proposed operations and procedures. A systematic review to judge the operational options available for "workarounds" and recovery from upset conditions will be done.

Training and certification of operators will be examined.

Training records and operator certifications will be reviewed for currency and technical application. The composition of shift crews will be evaluated for the proper nix of experienced and novice operators.

4. p chnoloav Assessment: A review of the " technical record" leading to the selection of the proposed operational process will be done. The documentation and selection logic for the foundation chemistry and support testing for sludge washing will be reviewed.

Similar reviews for the selection of Titanated Zeolite as the STS ion exchange media will be done. The technical basis and testing will be reviewed for comprehensiveness and "close-out" of other options.

The development process for the cement waste f orm will be examined. The methodology and scientific approach used to perform the testing and qualification of the " recipe" will be judged from a risk basis. The completeness of the documentation will be evaluated as well.

5. Documentation Como11ance Review - ES rind H/OA: In this area, the review will focus on the adequacy of the implementation of DOE Orders, ES&H requirements, Quality Assurance and related regulatory requirements throughout the proposed system. Satisfactory " closure" of environmental /NEPA issues will be examined. Adequacy of the quality assurance programs applico to the sludge wash activities will be reviewed. Approvals and closure of all' Safety Analysis work and documentation will be included.

Appendix B is the ORRB Checklist to be used by the Board to assist in examining each of the areas described above. The checklist is l as comprehensive as can be done in advance, however, additions may l be made during the review process as new information is made available to the Board.

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I SCHEDULE I The ORR will be scheduled to coincide with tne devclopment of I documents needed by WVNS to fully characterize the " state of I readiness" of the Sludge Washing Process. Appendix C is the ,

proposed schedule. As the readiness of the Sludge Wash system  !

maturos, this schedule may change; the DOE' Board will be required l to adjust accordingly.

APPENDIX A DOE WEST VALLEY PROJECT OFFICE OPERATIONAL READINESS REVIEW BOARD for RESUMPTION Or IRTS OPERATIONS -SLUDGE WASH MEMBERS Members are assigned " official" board status and responsibility ,

which includes one vote each to be used for reaching final l decisions on recommendations for operational readiness.

Chairman W. Stephen Ketola DOE-WVPO l

i Members Alan Yeasel DOE-WVPO, Operations Rick Provencher DOE-WVPO, ES&H/QA Joe Desormeau DOC-WVPO Dr. Alfred Schneider N.Y. State Consultant Ted Sonntag NYSERDA John Orr DOE-ID Boyd Hinkclay DOE-ID Jack Sanders DOE-ID Joel Case 00E-ID Observers Ted McIntosh DOE-EM-30, Program DOE-EM-20, QA John Psaras - ? OCE-NS-??, Nuclear Safety COE-EH-??, ES&H Davis Hurt, others? NRC- ??, 1 or more??

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APPBNDIx a checklist to be provided at "orlentation" l

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