B13134, Clarifies Plants Position Re Using Vendor Process Control Program.Plants Will Not Request NRC Approval to Utilize Vendor Program Since Regulations Allow for Use of non-NRC Approved Topical Rept Upon Showing Compliance

Clarifies Plants Position Re Using Vendor Process Control Program.Plants Will Not Request NRC Approval to Utilize Vendor Program Since Regulations Allow for Use of non-NRC Approved Topical Rept Upon Showing Compliance

ML20247B470
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	05/04/1989
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B13134, NUDOCS 8905240132
Download: ML20247B470 (5)

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9 NORTTIEAST UTILITIES o.nor.i Ome.. . som n sir..i. somn. Connecticut 9 r [cI uN c5aI

""'**"****"*"" P.O. BOX 270 HARTFORD, CONNECTICUT 06141-0270 L L J ZZZ%7.,,! (203) 665-5000 May 4, 1989 Docket Nos. 50-213 50-245 50-336 50-423 B13134 Re: Processing of Low Level Radioactive Waste U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3 Mobile Vendor Services for Solidification or Dewatering of Wet low Level Radioactive Waste On June 17, 1988, a meeting was held between the NRC and Northeast Nuclear Energy Company (NNECO) to discuss issues related to the use of a vendor process control program (PCP) which resulted in a liner at Millstone Unit No. I being overfilled. During this meeting there was some confusion as to whether NNEC0 should have submitted changes to the vendor PCP for NRC review and approval.

The purpose of this letter is to clarify NNEC0's and the Connecticut Yankee Atomic Power Company's (CYAPC0) positioq Mith respect to using a vendor's PCP.

Consistent with current NRC regulations"', NNECO and CYAPC0 will not request NRC approval to utilize a vendor's PCP. Current regulations allow a utility to use a non-NRC approved topical report providing the licensee can show compliance with the requirements for classifying or stabilizing waste during an NRC inspection. PCP qualification test data will be maintained on file for waste streams not covered by the vendor's topical report. This data will be available for NRC review upon request.

Northeast Utilities Service Company (NUSCO) on behalf of NNECO and CYAPC0 has developed a bid specification for future vendor mobile services for solidifi-cation and dewatering of wet low level radioactive waste for the Haddam Neck Plant and Millstone Unit Nos. 1, 2, and 3. This bid specification will establish a comprehensive program which closely monitors mobile vendor (1) 48 federal Register 40512, September 8,1983.

8905240132 890504 d@)( 1 \

PDR ADOCK 05000213 P PDC

U.S. Nuclear Regulatory Commission 1 B13134/Page 2 May 4, 1989 services and ensures that solidification or dewatering of wet low level waste is properly qualified prior to waste disposal. NNECO and CYAPC0 are providing the information contained in Attachment 1 in order that the NRC S 4 4 may have a better understanding of the program that NNECO and CYAPC0 inten; to utilize during solidification or dewatering of wet low level radioactive waste.

NNECO and CYAPC0 are confident that this enhanced program will ensure that the solidification and dewatering of wet low level radioactive waste will continue to be properly performed. Should you have any additional questions or comments, please feel free to contact my staff.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY b d N rce '

E. J. Mroczka Senior Vice President 6L0tLL By: C. F. Sears Vice President cc: W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant l

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. Docket Nos. 50-213 50-245 50-336 50-423 B13134 i

Attachment 1 Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3 Mobile Vendor Service for Solidification or Dewatering of Wet Low Level Radioactive Waste May 1989

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Attachment 1 B13134/Page 1 DEVELOPMENT OF SPECIFICATION FOR VEND 0R BID RE0 VEST NUSCO developed a bid specification which solicits bids from vendors to  ;

provide mobile services for the solidification or dewatering of wet low level radioactive waste. Portions of this program may be modified in the future as necessary.

NUSCO will provide to the vendor a list of wet waste streams (including any special waste streams e.g., decon solutions) generated at the Haddam Neck Plant and Millstone Nuclear Power Station, Unit Nos.1, 2, and 3. The vendor will be required to submit proprietary Topical Reports with details on the equipment, laboratory and full-scale qualification tests, chemicals, addi-tives, binders or other ingredients used to process the waste streams identi-fied by NUSCO.

The vendor will also be required to submit a copy of their QA programs for  ;

NUSCO's review and show that thg program is in compliance with the NRC Technical Position on Waste enrm and the applicable regulatory require-ments.

VENDOR BID REVIEW Upon receipt of the vendor bids, NUSCO and appropriate plant departments will review the bids for conformance to the bid specification and plant require-ments.

A technical review of the Topical Reports submitted will be performed. The review will include, but not be limited to, the data in the Topical Reports, completeness of the tests performed, and compliance to the NRC Technical Position on Waste Form. Comparison of the typical waste streams processed by the vendor with those normally generated by the plant will be done. This would identify the need for additional qusiification tests which would be required prior to processing waste streams that exhibit physical and chemical characteristics that are not similar to the waste streams qualified by the vendor. Additional processes performed by the vendor at other plants will also be reviewed for qualification of added waste streams not previously approved by the plants.

The NUSCO Quality Services Department (QSD) will verify that the vendor QA programs meet NUSCO's -QA requirements and the applicable laws, codes, rules and regulations of the burial sites, federal, state, and other regulatory authorities. Compliance with the NRC Technical Position on Waste Form will also be verified.

(1) NRC-83, U.S. Nuclear Regulatory Commission, Technical Position on Waste Form, Rev. O, May 1983.

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Attachment 1 B13134/Page 2 L

l Vendors who have had their QA program approved previously by the NUSCO QSD

-will be reviewed in areas that were updated or were beyond the scope of the l original approval. Approved vendors are also required to confirm that their QA program has not changed since their last evaluation by the NUSCO QSD.

CONTRACT IMPLEMENTATION AND PLANT PROCEDURAL CONTROL i Once the vendors have been selected, the vendors, when required, will submit l processing procedures for incorporation into the plant procedures. The l procedures submitted by the vendors will be incorporated after review and l approval by the Plant Operations Review Committee (PORC).

The procedures will be reviewed and approved for specific types of waste streams to be processed. Chemical and physical properties of the waste streams will have to be similar to the approved waste stream prior to the

. start of the solidification or dewatering process.

A waste stream that has chemical and physical characteristics that are not l similar to the approved waste streams would have to be qualified by the vendor (by submittal of the qualification test data to the plant for review and approval) or require additional qualification tests. Qualification test data will be maintained by NUSCO and made available for NRC review. The new waste stream would then be added to the list of approved waste streams that can be processed at the plant by that vendor.

Prior to processing each batch of wet waste, a small scale PCP test shall be performed to verify that the end product is, as a minimum, a free-standing monolith with no free liquid. All qualification and PCP tests will be completed prior to any processed waste being shipped from the plant to ' a licensed burial site. The acceptable waste form properties will clearly be defined in the plant procedures along with corrective actions to be taken, if required, to produce a waste form that would be acceptable for disposal at the burial site.

In addition to NUSCO and plant controls, the QSD provides oversight through a program of inspections or surveillance.

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