ML042950097

Attachment III, Administrative Procedure AP 31A-100, Revision 4, Solid Radwaste Process Control Program.

ML042950097
Person / Time
Site:	Wolf Creek
Issue date:	03/01/2002
From:	Wolf Creek
To:	Office of Nuclear Reactor Regulation
References
AP 31A-100, Rev 4
Download: ML042950097 (36)

Text

ATTACHMENT III Wolf Creek Nuclear Operating Corporation Administrative Procedure AP 31A-1 00, Revision 4, "Solid Radwaste Process Control Program"

WELF CREEK NUCLEAR OPERATING CORPORATION AP 31A-100 SOLID RADWASTE PROCESS CONTROL PROGRAM Responsible Manager Manager Chemistry/Radiation Protection Revision Number . 4 Use Category Reference Administrative Controls Procedure Yes Infrequently Performed Procedure No Program Number 25A DC12 03/01/2002

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 ]

Reference Use l Page 1 of 34 ]

TABLE OF CONTENTS SECTION TITLE PAGE 1.0 PURPOSE 2 2.0 SCOPE 2

3.0 REFERENCES

AND COMMITMENTS 6 4.0 DEFINITIONS 8 5.0 RESPONSIBILITIES 12 6.0 PROCEDURE 13 7.0 RECORDS 31 8.0 FORMS 31 ATTACHMENT A TECHNICAL SPECIFICATION AMENDMENT CHANGES 32

1.0 PURPOSE 1.1 This procedure provides instructional guidance and a description of the solid waste Process Control Program.(PCP). The PCP describes the methods used for processing wet low-level radioactive waste into a waste form acceptable for disposal, in accordance with 10 CFR 61 requirements, at.a licensed land disposal facility.

2.0 SCOPE 2.1 This procedure describes current and planned practice for sampling, sample evaluation, classification, processing and packaging of radioactive material. This procedure does not address irradiated hardware which will be managed-on a case-by-case basis under the direction of the Manager Chemistry/Radiation Protection. System descriptions and operating practices are described in the following steps.

2.2 Waste Steam Identification - The station has initially identified eight different waste streams and treats each separately for classification purposes. The'identification listing may be consolidated, expanded and streams.deleted at the discretion of radwaste management without revising the PCP.

o Dry Active Waste (DAW) o Steam Generator Blowdown Bead Resin o Chemical and Volume Control System Bead Resin (1) (CVCS) o Reactor Coolant System Filters o Ultra Filtration Skid Waste o Spent Fuel Pool Filters o Radwaste Resins o Steam Generator Blowdown Filters (2)

(1) May contain combination of CVCS, Diversified, and Spent Fuel Pool Resins (2) May be disassembled and components handled as DAW 2.3 Non-Waste.Stream Identification - The station has identified two different sources and treats each separately for classification purposes.

o Non-irradiated material removed from the Spent Fuel Pool.

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 3 of 34

• o Any other radioactive material generated by the station.

2.4 Disposition of Radioactive Material Sent to a Vendor for Intermediate Processing - Practices include sending radioactive material packages generated by the station to Duratek or other vendors for volume reduction (VR)/processing instead of directly to a burial site.

2.4.1 This procedure addresses the requirements for 10 CFR 61.55 (Waste Classification) for radioactive material sent to vendor facilities.

2.4.2 This procedure does NOT address the requirements for.

10 CFR 61.56 (Waste Characteristics), since the final processing and packaging are performed at the vendor facilities.

2.4.3 Possible types of radioactive material include, but are NOT limited to the following:

o DAW o Surface Contaminated Objects o Bead Resins and Charcoal o Cartridge Filters o Contaminated Oil o Contaminated Soil 2.5 Disposition of Waste Sent Directly to a Burial Site - This procedure addresses both the 10 CFR 61.55 and 61.56 requirements for the waste streams listed in Step 2.2.

2.6 Waste Management Practices 2.6.1 DAW o This waste stream consists of plastic, wood, paper, metal, cloth, etc. generated at various locations within the station.

o The material may be sent to intermediate processors or directly to a burial site.

o The station may preprocess DAW by compacting.

Revision: 4 SOLID RADWASTE PROCESS CONTROL. AP 31A-100 PROGRAM .

Reference Use Page 4 of 34 o Practices include shipping DAW classified as either SCO or LSA in numerous possible containers,-such as:

- 30 to 85 gallon drums

- B-25 type boxes

- SeaLand containers

- Large. liners o Prepacking inspection criteria includes the removal of liquid, protective clothing and equipment, paints, solvents, lead, instruments, gages and other valuable plant equipment.

2.6.2 Steam Generator Blowdown Bead Resin (S/G BD) o This waste stream consists of only S/G blowdown resin. The depleted resins are sluiced from the individual processing vessels to the S/G Blowdown Resin Storage Tank and then to a CNSI 6-80 or 8-120 High Integrity Container (HIC),. OR any other container approved by the Health Physics Supervisor Radwaste (HPSR).

o Once a container is full, the resins are then dewatered using plant equipment and approved vendor dewatering procedures.

o Practice may include shipping resins to a volume reduction processor for incineration or release.

2.6.3 Chemical and Volume Control System Bead Resin (CVCS) o This waste stream consists of CVCS,.various DURATEK media and Spent Fuel Pool resins. The depleted charcoal filter media and resins are sluiced from the individual processing vessels to a common Spent Resin Storage Tank. The media is then transferred in a batch mode to a CNSI 6-80 or.8-120*HIC, OR any other container approved by the HPSR.

o Once a container is full or the transfer has been terminated, the filter media (charcoal) and resins are then dewatered per RPP 07-131, BEAD RESIN/ACTIVATED CARBON DEWATERING PROCEDURE FOR CNSI 14-215 OR SMALLER LINERS.

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 5 of 34 2.6.4 Cartridge Filters o This category includes several waste streams which were defined in Step 2.2 and includes all filters generated by the station.

o Filters are removed from service based on operating parameters determined by the Operations Department.

o The filter housings are drained prior to filter removal. The filters are then gravity drained prior to being placed into an intermediate storage container OR the final disposal container.

o With containers equipped with a dewatering internal, a final dewatering verification is performed on the disposal container after it has been loaded with filters.

o Absorbent material may be added to the disposal liner after final dewatering verification at the discretion of the HPSR.

2.6.5 Solidification/Encapsulation Methods o Present and planned practice is NOT to solidify or encapsulate any waste streams.

o All liquid waste is dewatered to less than 0.5 percent or 1 percent depending on the container type by volume prior to shipment.

2.6.6 Operation and Maintenance of dewatering Systems and Equipment o Present and planned practice is to utilize station personnel to operate and maintain dewatering systems and equipment using station procedures.

o All disposal liners are manufactured by and purchased from QA approved vendors.

2.6.7 High Integrity Container Usage o High Integrity Containers (fabricated from high density cross-linked polyethylene) may be used as the disposal package for any waste.

o All classes of waste, unless specifically exempted by the South Carolina Department of Health and Environmental Control must be disposed in vaults (approved concrete overpack structures) at the Barnwell burial site.

lRevision: 4 SOLID RADWASTE PROCESS CONTROL l AP 31A-100 PROGRAM Reference Use Page 6 of 34 J 2.7 Amendment No. 42 to the Operating License deleted portions of Technical Specification that were incorporated into the Process Control Program (Rev. 6). Prior to issue of PCP. Revision 5, a new procedure (RPP 07-102) was issued which incorporated applicable portions of PCP Revision 4. ATTACHMENT A reflects those changes that were made to the PCP per Amendment No. 42.

3.0 REFERENCES

AND COMMITMENTS 3.1 References 3.1.1 WCGS Technical Specifications, Section 6.13 (TR 5.5.4) 3.1.2 RPP 07-101, CONTROL OF RADIOACTIVE MATERIAL MANAGEMENT SOFTWARE AND DATA BASES 3.1.3 RPP 07-120, PREPARATION AND SHIPMENT OF RADIOACTIVE WASTE 3.1.4 RPP 07-121, PREPARATION AND SHIPMENT OF RADIOACTIVE MATERIAL 3.1.5 RPP 07-131, BEAD RESIN/ACTIVATED CARBON DEWATERING PROCEDURE FOR CNSI 14-215 OR SMALLER LINERS 3.1.6 10 CFR 20, "Standard For Protection Against Radiation".

3.1.7 10 CFR 61, "Licensing Requirements for Land Disposal of Radioactive Waste" 3.1.8 10 CFR 71, "Packaging and Transportation of Radioactive Materials" 3.1.9 40 CFR 302, "Reportable Quantity Adjustment -

Radionuclides" 3.1.10 49 CFR 171, "General Information, Regulations, and Definitions" 3.1.11 49 CFR 172, "Shippers' General Requirements-for Shipments and Packaging" 3.1.12 49 CFR 177, "Carriage by Public Highway" 3.1.13 Barnwell Waste Management Facility Site Disposal Criteria; CNSI-S20-AD-010 3.1.14 CNSI's South Carolina Department of Health and Environmental Control (DHEC) Radioactive Materials License No. 097 3.1.15 South Carolina DHEC Regulation 61-83, Transportation of Radioactive Waste Into or Within South Carolina

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 7 of 34

• 3.1.16 USNRC Branch Technical Position on Radioactive Waste Classification, May 1983 3.1.17 USNRC Branch Technical Position on Waste Form, January 1991 3.1.18 USNRC Branch Technical Position on Concentration Averaging and Encapsulation, Revision in Part To Waste Classification Technical Position, January 1995 3.1.19 NRC Bulletin No. 79-19, "Packaging of Low Level Radioactive Waste for Transport and Burial" 3.1.20 NRC Information Notice No. 80-24, "Low Level Radioactive Waste Burial Criteria" 3.1.21 NRC Information Notice No. 83-33, "Non-Representative Sampling of Contaminated Oil" 3.1.22 NRC Information Notice No. 85-92, "Surveys of Wastes Before Disposal from Nuclear Reactor Facilities" 3.1.23 NRC Information Notice No. 86-20, "Low Level Radioactive Waste Scaling Factors, 10 CFR 61" 3.1.24 NRC Information Notice No.88-101, "Shipment of Contaminated Equipment Between Nuclear Power Stations" 3.1.25 WMG-SW-006, "Computer Software Quality Assurance Program"-

3.1.26 WMG-QA-001, "Quality Assurance Program" 3.1.27 WMG-P-065 "RADMAN Operating Manual" 3.1.28 RADMAN Computer Code, Main Topical Report to the USNRC 3.1.29 WMG-P-069, "FILTRK Operating Procedure" 3.1.30 WMG-P-070, "RAMSHP Operating Procedure" 3.1.31 WMG-P-075, "OSM Operating Procedure" 3.1.32 WMG Report #9006, "Computer Program Dose to Curie Methodology Verification and Validation" 3.1.33 U.S. Nuclear Regulatory Commission, "Radiological Effluent Technical Specifications for PWRs," NUREG-0472 3.1.34 NRC Guidelines for Preparation and Implementation of Solid Waste Process Control Program "DRAFT," Revision 4, October 1986

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 8 of 34 3.1.35 CNSI FO-AD-002, "Operating Guidelines for Use of Polyethylene High Integrity Containers" 3.1.36 CNSI, FO-OP-023, "Bead Resin/Activated Carbon Dewatering Procedure for CNSI 14-215 or Smaller Liners" 3.1.37 NRC Generic Letter No. 91-02, "ReportinggMishaps Involving LLW Forms Prepared For Disposal" 3.1.38 WMG-9217, "10 CFR 61 Practice Assessment at Wolf Creek Generating Station, 1992"-

3.1.39 AP 25-001, RADIATION PROTECTION QUALITY PROGRAM REQUIREMENTS 3.1.40 Letter from Rodney Wingard to Jimmy Still .concerning the disposal of dried solids (HP 01-00601).

3.2 Commitments 3.2.1 None 4.0 DEFINITIONS 4.1 Activity Correction Factor 4.1.1 The piCi/cc or pCi/g values may have to be corrected (plus or minus) if the waste stream specific 10 CFR 61 sample results (independent laboratory) and the replicate in-house specific activity values differ by more than 20 percent, and the differences cannot be resolved to the satisfaction of the HPSR.

4.2 Batch 4.2.1 An isolated quantity of feed waste to be processed having essentially constant physical and chemical characteristics. (The addition or removal of water will not be considered to create a new batch).

4.3 Chelating Agents 4.3.1 EDTA, DTPA, hydroxyl-carboxylic acids, citric acid, carbolic acid and glucinic acid.

4.4 Confirmatory Analysis 4.4.1 Verification of Gross radioactivity measurements using MCA and independent laboratory sample data.

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use . Page 9 of 34 4.5 Density Correction 4.5.1 Density corrections may be required to convert sample data reported in pCi/g to pCi/cc or vice versa when comparing sample data with unlike units.

4.6 Dewatered Waste 4.6.1 Dewatered Waste refers to wet waste that has been processed by means other than solidification, encapsulation, or absorption to meet the free standing liquid requirements of 10 CFR 61.56 (a)(3) and (b)(2).

4.7 Encapsulation 4.7.1 Encapsulation is a means of providing stability-for certain types of waste by surrounding the waste by an appropriate encapsulation media.

4.8 Gamma-Spectral Analysis 4.8.1 Also known as IG, MCA, GE/Li and gamma spectroscopy.

4.9 Gross Radioactivity Measurements 4.9.1 More commonly known as Dose to Curies conversion for packaged waste characterization and classification.

• 4.10 Homogeneous 4.10.1 Of the same kind or nature; essentially alike. Most waste streams are considered to have the radioactivity distributed throughout for purposes of waste classification.

4.11 Low-Level Radioactive Waste (LLW) 4.11.1 Those low-level radioactive wastes containing source, special nuclear, or by-product material that are acceptable for disposal in a land disposal facility.

For the purposes of this definition, low-level radioactive waste has the same meaning as in the Low-Level Waste Policy Act, that is, radioactive waste not classified as high-level radioactive waste, transuranic waste, spent nuclear fuel, or by-product material as defined in Section 113.(2) of the Atomic Energy Act (uranium or thorium tailings and waste).

4.12 Measurement of Specific Radionuclides 4.12.1 More commonly known as core sample or package sample using MCA data for packages waste characterization and classification.

Revision: 4 SOLID RADWASTE PROCESS CONTROL l AP 31A-100 PROGRAM Reference Use .Page 10 of 34 4.13 Operable 4.13.1 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable' of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component,. or device to perform its function(s) are also capable of performing their related support function(s).

4.14 Pre-qualification Program 4.14.1 The testing program implemented to demonstrate that the proposed method of wet waste processing will-result in a waste form acceptable to the land disposal facility.

4.15 QA Verification Sample 4.15.1 A representative sample of the waste that 'is tested to demonstrate 'control of the waste processing'. The sample shall be obtained from at least every tenth batch of each type of wet radioactive waste processed for stabilization.

4.16 Quality Assurance/Quality Control 4.16.1 As used in this'document, "quality assurance" comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.

Quality assurance includes quality control, which comprises those quality assurance actions related to control of the physical characteristics and quality of a material structure, component, or system to predetermined requirements.

4.17 Sampling Plan 4.17.1 A sampling program implemented to ensure that representative samples from the feed waste and the final waste form are obtained and tested for conformance with parameters stated in the PCP and waste form acceptance criteria.'

4.18 Scaling Factor 4.18.1 A dimensionless number which relates the concentration of an easy to measure nuclide (gamma emitter) to one which is difficult to measure (beta/alpha emitters).

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 11 of 34 4.19 Shipping Paper 4.19.1 At WCGS the shipping paper consists of an NRC form 540 (or equivalent). Additional documentation may be provided (i.e., bill of lading) but is not consecutively number as part of the shipping papers.

4.20 Significant Quantity 4.20.1 For purposes of sample evaluation, waste classification and manifesting radionuclides on shipping papers, the following radionuclide limits shall be considered significant:

o Any LLD value for a 10 CFR Part 20, Appendix G required radionuclide.

o Any radionuclide representing greater than 5 percent of the relative A2 fraction hazard.

o Any radionuclide specifically listed in 10 CFR Part 61.55.

o Any radionuclide representing greater than 1 percent of the total activity.

o Any radionuclide greater than 0.5 RQ value.

4.21 Special Nuclides 4.21.1 RADMAN Computer Code term for 10 CFR Part 20, Appendix G required nuclides.

4.22 Stability 4.22.1 As used in this document, "stability" means structural stability. Stability requires that the waste form maintain its structural integrity under the expected disposal conditions.

4.23 Waste Container 4.23.1 A vessel of any shape, size, and composition used to contain the final or intermediate processed waste.

4.24 Waste Form 4.24.1 Waste in a stable waste form or container acceptable for disposal at a licensed disposal facility.

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 12 of 34 4.25 Waste Processing 4.25.1 Changing, modifying, packaging the commercial nuclear power plant generated wet radioactive waste into a form that is acceptable to a disposal facility.

4.26 Waste Stream 4.26.1 A station specific and constant source of waste with a distinct radionuclide content and distribution.

4.27 Waste Type 4.27.1 A single packaging configuration tied to.a specific-waste stream, or multiple package types tied to the same waste stream.

4.28 Abbreviations 4.28.1 APG - Activity Per Gram 4.28.2 BTP - Branch Technical Position 4.28.3 CNSI - Chem Nuclear System, Inc.

4.28.4 HPS - Health Physics Supervisor 4.28.5. LLD - Lower Limit of Detection 4.28.6 MCA - Multi-Channel Analyzer 5.0 RESPONSIBILITIES 5.1 Health Physics Supervisor Radwaste is responsible for:

5.1.1 Implementing this procedure.

5.1.2 Ensuring that radioactive waste is classified and characterized in. accordance with 10 CFR 61.55 and 61.56 and receiving facility criteria.

5.1.3 Designating other approved procedures (if required) to be implemented in the packaging of any specific batch of waste.

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 13 of 34 6.0 PROCEDURE 6.1 The precautions/limitations of this procedure are listed below.

6.1.1 All plant personnel that have any involvement with the RADMAN, TRASHP, and FILTRK computer codes shall be familiar with its functions, operation, and maintenance.

6.1.2 Only authorized personnel will characterize or package radioactive waste or radioactive materials.

6.1.3 Radioactive materials shall be handled in accordance with applicable Radiation Protection Procedures.

6.1.4 Pressure and heat may be encountered during the operation of liquid waste processing systems.

1. Caution must be exercised during disassembly and disconnection of lines or equipment and valve realignments.

6.1.5 Each HIC is matched with specific closure components and seals at time of manufacture.

1. All components are identified using a common serial number.

2. Should components become mismatched, contact the HPSR for instructions prior to use.

6.1.6 Waste must NOT be packaged for disposal in cardboard or fiberboard boxes.

6.1.7 Liquid waste must be solidified or packaged in sufficient absorbent material to absorb twice the volume of the liquid.

6.1.8 Solid waste containing liquid shall contain as little free standing and non-corrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 1 percent of the volume.

6.1.9 Waste must NOT be readily capable of detonation or of explosive decomposition or reaction at normal pressures and temperatures, or of explosive reaction with water.

6.1.10 Waste must NOT contain, or be capable of generating, quantities of toxic gases, vapors, or fumes harmful to persons transporting, handling, or disposing of the waste. This does NOT apply to radioactive gaseous waste packaged in accordance with Step 6.1.12 of this section.

[Revision: 4 SOLID RADWASTE PROCESS CONTROL l AP 31A-100 PROGRAM Reference Use Page 14 of 34 6.1.11 Waste must NOT be pyrophoric. Pyrophoric materials contained in waste shall be treated, prepared, and packaged to be non-flammable.

6.1.12 Waste in a gaseous form must be packaged--at a pressure that does not exceed 1.5 atmospheres at 200C. Total activity must not exceed 100 curies per container.

6.1.13 Waste containing hazardous, biological, pathogenic, or infectious material must be treated to reduce to the maximum extent practicable the potential hazard from the non-radiological materials. -

6.1.14 All data entries should use three significant figures only (i.e., X.XXE-x). IF more significant'-figures are provided, round off to generate three significant figures.

6.1.15 Use only those isotopes reported as real values, ignore all isotopes reported as LLD values, except those.

nuclides listed in Step 6.6.7.

6.1.16 Ignore all radioisotopes with half-lives less than five (5) days.

6.1.17 Changes to this procedure shall be documented with a form APF 31A-100-04, PROCESS CONTROL PROGRAM CHANGE RECORD submitted with the revised procedure and form APF 15C-004-01, DOCUMENT REVISION REQUEST. Form APF 31A-100-04 shall contain (Step 3.1.1):.

1. Sufficient information to support the change together with the appropriate analyses or evaluation justifying the change(s).

AND

2. A determination that the change will maintain the overall conformance of the waste product to existing requirements of Federal, State, or other applicable regulations.

6.2 Special equipment, material, and parts needed to perform tasks are shown below.

6.2.1 Required tools and equipment will vary depending on the specific process and waste container that is used.

6.2.2 The various tools and equipment which may be required are detailed in the vendor procedures listed in Steps 3.1.36 and 3.1.37.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 15 of 34 6.3 Prerequisites before beginning work with this procedure.

6.3.1 Ensure that a current set of DOT, NRC and burial site regulations is maintained at the station and is available for reference.

6.3.2 Ensure that representative sample data is on file for each waste stream. Data is considered to be current if it meets the following:

1. The waste stream must be sampled at least every two years for NRC Class A waste.

2. The waste stream must be sampled at least every year for NRC Class B or C waste.

3. Non-waste radioactive material shall be sampled on an annual or as generated basis with (non-irradiated) fuel pool material differentiated from balance of plant material.

6.3.3 A training program shall be developed and implemented for personnel having responsibilities related to waste processing operations to ensure the waste processing shall be performed within the requirements of the PCP.

1. The training program shall be repeated and the personnel requalified on a periodic schedule, not to exceed three years.

2. The individual's training records shall be maintained and available for audit and inspection.

6.3.4 Additional requirements for contracted vendors processing waste.

1. Management shall review vendor(s) topical reports.

NOTE' The PCP does NOT have to include the vendors Topical Report if it has NRC approval, or has been previously submitted to the NRC.

a. This review will assure the vendors operations and requirements are compatible with the responsibilities and operation of the plant.

b. The training requirements and records listed in Step 6.3.3 also apply to contracted vendors.

c. The station shall maintain copies of records to verify training of vendor personnel.

[Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAMl AP 31A-100

[Reference Use Page 16 of 34 6.3.5 Voluntarily report waste from mishaps to the NRCs Director of the Division of Low-Level Waste Management and Decommissioning and to the designated State Disposal-Site Regulatory Authority of the three classes of information outlined in Generic Letter 91-02.

1. The failure of high integrity containers used to ensure a stable waste form. (Not applicable at the Barnwell disposal facility).-

2. The misuse of high integrity containers, evidenced by a quantity of free liquid greater than one (1) percent of container volume, or by an excessive void space within the container.

3. The production of a solidified Class B or C waste form that has any of the following characteristics:

a. Contains free liquid in quantities exceeding 0.5 percent of the volume of the waste.

b. Contains waste with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the regulatory agency, which could lead to errors in assessment of waste class.

c. Contains a significantly different waste loading than that used in qualification testing accepted by the regulatory agency.

d. Contains chemical ingredients not present in qualification testing accepted by the regulatory agency, and those quantities are sufficient to unacceptably degrade the waste product.

e. Shows instability evidenced by crumbling, cracking, spalling, voids, softening, disintegration, nonhomogeneity, or dimensional changes.

f. Evidence of processing phenomena that exceed the limiting processing condition identified in applicable topical reports on process control plans, e.g., foaming, temperature extremes, premature or slow hardening, and production of volatile material.

6.4 Procedure For Performing Work 6.4.1 Methods and frequency for determining the radionuclide concentration for each waste stream.

1. Ensure samples are representative of the final waste form.

2. Determine the density for each waste stream (NOT applicable for DAW and filters). The density is determined in the laboratory by determining the weight of a known volume of waste. The mass divided by the volume equals the density.

NOTE For WCGS, waste stream radionuclide content is considered to be distributed throughout for purpose of waste classification.

6.4.2 Treat each waste stream separately for classification purposes.

6.4.3 Send all NRC Class A waste samples to an independent laboratory for gamma, beta and alpha analysis at least once every two years.

1. Perform an in-house analysis for gamma emitting radionuclides for each sample sent to an independent lab for future comparison.

2. Periodically perform in-house analysis for gamma emitting nuclides for comparison to the current data base values for gamma emitters (the current data base is usually based on the most recent independent laboratory results).

6.4.4 Send all NRC Class B and C waste samples to an independent laboratory for gamma, beta and alpha analysis at least once a year. The additional steps required are identical to Substeps 1 and 2 of Step 6.4.3.

6.4.5 Determine the status (real value, LLD or not present) of the 10 CFR 20 Appendix G required nuclides for each waste stream from the recent independent laboratory data.

6.4.6 Document and track all samples per RPP 07-101, CONTROL OF RADIOACTIVE MATERIAL MANAGEMENT SOFTWARE AND DATA BASES.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM 'AP 31A-100 l Reference Use Page 18 of 34 J 6.5 Current and planned practice for each waste stream is as 6.5 Current and planned practice for each waste stream is as follows:

6.5.1 DAW

1. Obtain composite smears from various contaminated areas of the plant on a semi-annual basis and analyze (IG) them in-house for gamma. emitters.

2. Compare the results of the semi-annual'samples to the data base to ensure adequacy of sample frequency.

3. Send the most recent group of composite smears to an independent laboratory for analysis biennially or more often IF determined necessary by the HPSR.

4. Maintain records for all samples for nuclide identification, distribution and scaling factors.

NOTE The specific activity (pCi/cc or pCi/g) is NOT required since all characterization/classification calculations are performed using a dose/curie methodology which only relies on fractional abundance and scaling factors.

5. Both in-house and independent laboratory results are normally reported in pCi/sample.

6. Forward results to the HP Dosimetry/Calibration Lab.

6.5.2 S/G Blowdown Resin

.1. Obtain several (as determined by the HPSR) composite samples from the resin transfer line during liner loading operations on an "as generated" basis.

NOTE Each liner is considered a different batch for sampling and classification purposes.

2. Analyze the samples in-house (IG) and retain the results for future comparison to the replicate independent laboratory results.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 19 of 34

3. Send the samples to an independent laboratory for analysis biennially or as generated.

4. Maintain records for all samples for nuclide identification, distribution and scaling factors.

5. Both in-house independent laboratory results are normally reported in the same units (pCi/g or pCi/cc).

6.5.3 CVCS Resin

1. The sampling procedure is exactly the same as listed above for S/G Blowdown Resin in Step 6.5.2 except the analysis frequency is annual or as generated.

6.5.4 Filters

1. Obtain samples from each individual filter waste stream defined in Step 2.2 on an annual OR as generated basis.

NOTE Samples may be taken from the actual filter media, from a smear of the filter media, from a smear of the filter housing, or a crud sample, as determined by the HPSR.

2. Perform an in-house (IG) analysis of the sample (or replicate sample) and retain the output record for future comparison to the independent laboratory results.

3. Send the sample to an independent laboratory for analysis once per year or more often if determine necessary by the HPSR.

4. Maintain records for all samples for nuclide identification, distribution and scaling factors.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 20 of 34 NOTE The specific activity (pCi/cc or gCi/g) is not required since all characterization/classification calculations are performed using a dose/curie methodology which only relies on fractional abundance and scaling factors.

5. Both in-house and laboratory results are normally reported in jiCi/sample.

6.6 Sample Evaluation 6.6.1 Infrequent or Abnormal Waste Types

1. Infrequent or abnormal waste types that may be generated must be evaluated on a case-by-case basis.

2. The HPSR will determine if the waste can be correlated to an existing waste stream.

3. If the radioactive material cannot be correlated to an existing waste stream, the HPSR shall determine specific off-site sampling and analysis requirements necessary to properly classify the material.

6.6.2 Examples of these radioactive materials include, but are not limited to:

o Contaminated Soil o Contaminated Oil o Special Filters or Resin o A mixture of radioactive material types in one container.

6.6.3 Requirements for analysis to be performed by an off-site vendor are as follows:

1. All sample results must reference the quantity received.

2. All sample results shall be decay corrected to a reference date provided by the station which is normally the sample date.

3. The sample results shall be reported in pCi/sample, ptCi/g or pCi/cc as determined the HPSR.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 21 of 34]

r 1 NOTE Outside analysis is NOT performed for any radionuclides with a half-life less than five days.

6.6.4 The vendor shall perform analysis for the following radionuclides listed in Table 1 of 10 CFR 61.55.

1. C-14, Tc-99, I-129, Pu-241, Cm-242 and the following alpha emitting transuranics (TRUs) with half-lives greater than five years, Np-237, Pu-238, Pu-239/240, Pu-242, Am-241, and Cm-243/244.

a. Additionally Ni-59 and Nb-94 are required for Rx cavity and fuel pool filters.

NOTE If evaluation of several sets (i.e., three or more) of waste stream specific historical sample data shows that some TRUs with half-life greater than five years are consistently reported as LLD values, sample analysis may be discontinued for those specific radionuclides.

2. Analysis for the "activated metal" radionuclides listed in Table 1 of 10 CFR Part 61 are only required for the fuel pool filters and reactor cavity filters waste streams identified at WCNOC.

3. It is NOT necessary to contract for an offsite vendor to perform analysis for enriched uranium or other naturally occurring radionuclides not delineated in this procedure.

4. Radionuclides listed in Table 1 of 10 CFR 61.55 shall be specifically identified and the quantities reported on shipping manifests if they are significant for purposes of classification.

6.6.5 The vendor shall perform analysis for the following radionuclides listed in Table 2 of 10 CFR 61.55.

1. H-3, Co-60, Ni-63, Sr-90 and Cs-137

2. Radionuclides listed in Table 2 of 10 CFR 61.55 shall be specifically identified and the quantities reported on shipping manifests if they are significant for purposes of classification.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 22 of 34 6.6.6 The vendor shall perform analysis for the following radionuclides NOT listed in Table 1 or Table 2 of 10 CFR 61.

1. Activation Products - Cr-51, Mn-54,'Fe-55, Co-58, Fe-59, Sb-124, Sb-125, Zn-65, Ag-liOM and any other nuclides identified in significant quantities by in-house IG equipment.

2. Fission Products - Zr-95, Nb-95,,Ru-103, Ru-106, Cs-134, Ce-141, Sr-89, Ce-144 and any other nuclides identified in significant'quantities by in-house IG equipment.

6.6.7 A waste stream specific data base must.include the following radionuclides, even if they are reported as LLD values:

1. H-3, C-14, Tc-99, I-129 required by 10 CFR 20 Appendix G (H-3 is considered real or LLD for DAW because "not present" cannot be substantiated).

2. Co-60, Cs-137, and Ce-144 (only if TRUs are reported) required by the RADMAN computer code.

They are used as the primary scaling radionuclides.

6.7 Sample Analysis and Comparison 6.7.1 Whenever a sample is sent off-site for analysis, count the same sample (or replicate) in-house with the station IG system.

NOTE Isotopic results that are not considered statistically positive at the 99.9% confidence level are considered "suspect" values and shall be discarded as necessary.

6.7.2 Comparison of on-site versus off-site analysis shall be evaluated by the HPSR to identify and resolve any discrepancies. As a minimum, the comparison shall include:

o Specific activity by gamma emitting radionuclides.

(NOT applicable for DAW or filter samples'.)

o Co-60/Cs-137 Ratio o Presence or absence of radionuclides o Predominant radionuclides

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 23 of 34 o Individual radionuclide fractional abundance o Scaling factors 6.7.3 Records of on-site and off-site sample analysis and evaluations by waste type are maintained by the HPSR.

6.7.4 IF a comparison between the in-house and independent laboratory results shows a variance of 20 percent or greater for specific activity, the MCA results may be adjusted until the discrepancy is resolved. Reported MDC should be consistent with the measurement uncertainty. The relative uncertainty (la) of the measurement should be -30% at the MDC and should get smaller as the measured concentration increases above the MDC level.

1. Any discrepancies should be resolved (if possible) in-house or with the independent laboratory as soon as possible.

2. The use of these activity correction factors is only valid if other conditions defined in Step 6.7.2 above compare favorably, otherwise the sample set should be considered suspect and the data should not be used. This would require another sample as soon as possible. (3.1.38) 6.7.5 Radionuclides with a half-life less than five days are also ignored from internal MCA reports.

6.7.6 New sample data shall be periodically obtained and evaluated.

6.7.7 New sample data may be either off-site analysis or in-house MCA analysis.

6.7.8 Once a data base has been established, based on off-site analysis, the MCA results are primarily used as a "flag" to obtain and send additional samples off-site. Exceptions to this may occur during crud burst situations were it is necessary to adjust the scaling factor relationship of the activation products.

An example would be the 58 Co/ 60Co ratio after hydrogen peroxide additions.

6.7.9 The SCAL utility program may be'utilized to evaluate multiple sets of data.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use l lPage 24 of 34 NOTE Isotopic results that are NOT considered statistically positive at the 99.9% confidence level are considered "suspect" values and shall be discarded as necessary.

6.7.10 Several comparisons to the existing data base shall be considered when evaluating new sample data.

1. Radionuclide fractional abundance and scaling factor relationships

2. Specific activity by radionuclide

3. Swings in driving classifications radionuclides

4. Radionuclides present in data base, but NOT present in new sample or vice versa

5. Total activity by sample set 6.8 Sample Frequency 6.8.1 The following may require increased sampling:

1. Increase in failed fuel fraction as determined by:

o D.E.I. 25% of Technical Specification limit o Increase of I-131/I-133 o Np-239 greater than 0.01 .LCi/cc in reactor coolant o Positive in-house gross alpha sample results on any type of smear survey

2. Crud burst during 100% load rejection or chemical cleaning

3. Extended reactor shutdown (>90 days)

4. Changes to liquid waste processing, such as bypassing filters, utilizing filters or a change in ion exchange media

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 25 of 34 6.9 Scaling Factors 6.9.1 WCGS has established an inferential measurement program, whereby, concentrations of radioisotopes which cannot be readily measured are estimated.through ratioing to concentrations of radioisotopes which can be readily measured.

6.9.2 Scaling factors have been developed on a facility and waste stream specific basis, and are periodically confirmed through direct measurements.

6.9.3 Correlations between measured and inferred radionuclides are currently'as follows:

1. Ce-144 to transuranic nuclides

2. Co-60 to activation product nuclides and C-14

3. Cs-137 to fission product nuclides 6.10 Waste Classification NOTE The volume and mass of the waste form (not the waste container) is used for most waste classification calculations.

6.10.1 Determine the waste classification (Class A stable or unstable, Class C) by the concentration of certain radionuclides in the final waste form as listed in 10 CFR 61.55.

6.10.2 Determine the radionuclide concentrations per RPP 07-120, PREPARATION AND SHIPMENT OF RADIOACTIVE MATERIAL, as follows:

1. DAW - "Gross Radioactivity Measurements" in conjunction with the RADMAN computer code or hand calculations

2. Filters - "Gross Radioactivity Measurements" in conjunction with the FILTRK computer code or hand calculations

3. All other waste streams - "Direct Measurement of Individual Radionuclides" in conjunction with the RADMAN computer code or hand calculations

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 26 of 34 6.11 Quality Control For Sampling And Classification 6.11.1 The RADMAN computer code provides a mechanism to assist WCGS in conducting a quality control program to aid in compliance with the waste classification requirements listed in 10 CFR 61.55.

6.11.2 Management audits of the WCNOC Sampling and Classification Program shall be performed in accordance with AP 25-001, RADIATION PROTECTION QUALITY PROGRAM REQUIREMENTS..

6.11.3 The audits are performed and documented by any of the following:

• Health Physics Department

• Corporate Radwaste and Document Services Department

• Quality Assurance Department OR

• Qualified Vendors 6.12 Non-Waste Classification 6.12.1 Determine the radioactive material classification (Limited Quantity, LSA, SCO, Type A, >Type A or Type B) by the total activity or activity as listed in DOT regulations and the receiver's radioactive material licenses.

6.12.2 Determine the radionuclide concentrations per RPP 07-121, PREPARATION AND SHIPMENT OF RADIOACTIVE MATERIAL, as follows:

1. Non-irradiated material removed from the spent fuel pool - "Gross Radioactivity Measurements," "Direct Measurement of Individual Radionuclides", or "Measurement of Surface Contamination Levels" for non-radioactive material contaminated with radioactive material in conjunction with the RAMSHP computer code or hand calculations.

2. Any other radioactive material generated by the station - The same methods listed for fuel pool material may be used with a separate radionuclide data base.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 27 of 34 6.13 Processing General Requirements NOTE The dewatering capabilities are verified by vendor Topical Reports or operating and testing procedures.

6.13.1 Verify the wastes contain only trace amounts of drainable liquid, and in NO case may the volume of free liquid exceed one percent of the waste volume when wastes are disposed of in containers designed to provide stability.

NOTE The following verification is performed on a case-by-case basis for each package using independent laboratory data and MCA data in conjunction with computer codes or hand calculations.

6.13.2 Verify that resins are NOT processed that have loadings which will produce greater than 1.0 E+8 rads (350 pCi/cc) total accumulated dose.

6.13.3 The as generated waste must be compatible with the disposal container.

6.14 Processing Requirements During Dewatering Operations 6.14.1 Perform all dewatering operations per RPP 07-131, BEAD RESIN/ACTIVATED CARBON DEWATERING PROCEDURE FOR CNSI 14-215 OR SMALLER LINERS.

NOTE This procedure may only be used to dewater CNSI's14-215 or smaller liners containing bead-type ion exchange resins and activated carbon with less than 1 percent oil.

6.14.2 Complete form RPF 07-131-01, HIC DEWATERING COMPLETION RECORD, for each liner prior to final closure.

6.14.3 Form RPF 07-131-01, HIC DEWATERING COMPLETION RECORD, must be included in the shipping paperwork package with the shipment.

6.14.4 The final transfer/dewatering cycle shall be counted as the first pumping cycle IF after the transfer is completed, the liner is dewatering per this procedure.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 28 of 34 6.14.5 Final dewatering verification is determined by the 6.14.5 Final dewatering verification is determined by the following:

1. 1% Free-Standing Water or Less

a. After a minimum of two (2) pumping cycles for bead resins or five (5) cycles for activated carbon, a measured volume of less-than five (5) gallons on the next .eight (8).hours of pumping shall be the acceptance criteria.

b. IF five (5) gallons or more are collected, the waiting/pumping cycle shall be repeated'until less than five (5) gallons are collected.

2. 0.5% Free-Standing Water or Less

a. After a minimum of five (5) pumping cycles for bead resins or eight (8) pumping cycles for activated carbon, a measured volume of less than two (2) gallons on the next eight (8) hours of pumping shall be the acceptance criteria.

b. IF two (2) gallons or more are collected, the waiting/pumping cycle'shall be repeated until less than two (2) gallons are collected.

6.15 Packaging General Requirements NOTE The following general requirements are normally verified by review of a HIC's Certificate of Compliance (C of C) and State/NRC approval.

6.15.1 Ensure that the waste is in a container or structure that provides stability after disposal.

6.15.2 Ensure that the container is resistant to degradation caused by radiation effects.

6.15.3 Ensure the container is resistant to bio-degradation.

6.15.4 Verify that the container will remain stable under the compressive loads inherent in the disposal environment.

6.15.5 Verify that the container will remain stable if exposed to moisture or water after disposal.

6.15.6 Ensure that the "as generated" waste is compatible with the container.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 29 of 34 6.16 Packaging Vendor Requirements 6.16.1 Perform all inspection, handling and loading operations per CNSI, FO-AD-002.

NOTE Prior to use, each user will have on file within Chem-Nuclear System, Inc. Regulatory Affairs Department a "Polyethylene High Integrity Container Certification Statement."

6.16.2 IF not already on file, complete form FO-AD-002 HIC USER'S CHECKLIST, and transmit it to CNSI, maintain a copy of file in the HPSR office.

6.16.3 Complete form FO-AD-002 HIC USER'S CHECKLIST, for each HIC liner to be shipped to CNSI.

6.16.4 Form FO-AD-002 HIC USER'S CHECKLIST, must be included in the shipping paperwork package with the shipment.

6.16.5 Complete form FO-AD-002 CERTIFICATION STATEMENT FOR DISPOSAL OF POLYETHYLENE HIGH INTEGRITY CONTAINERS, for each HIC liner to be shipped to CNSI.

6.16.6 Form FO-AD-002 CERTIFICATION STATEMENT FOR DISPOSAL OF POLYETHYLENE HIGH INTEGRITY CONTAINERS, must be included in the shipping paperwork package with the shipment.

6.16.7 Storage Conditions NOTES o Containers stored out-of-doors in direct sunlight must be used within one year of fabrication.

o The design of the storage facility must preclude the possibility of a wet or damp environment and any prolonged exposure of the container to any source of ultraviolet light.

1. Ensure that containers are stored out of direct sunlight (if possible) and away from any other sources of ultraviolet radiation.

2. Store all containers in such a way that the bottom is flat and that no weight is located over the manway/fill port area.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use Page 30 of 34

3. Each container shall be stored with its designated closure assemblies to prevent mismatching.

4. Following filling and closure of the container, it may be stored on-site prior to shipment for burial.

6.16.8 Inspection Prior To Use

1. Visually inspect thread and seal areas' to verify they are free of foreign matter that could impair the seal or thread engagement.

2. Visually inspect the exterior surfaces for damage that may have occurred during transport or storage that could lessen container integrity.

6.16.9 Handling And Lift Requirements NOTE Due to the nature of the container material, some bowing and deformation may be evident during lifting.

1. Use only lift band(s), lift lugs and slings provided with the liner for lifting.

2. Inspect the underdrain assembly prior to use if the container was dropped or banged against another object.

6.17 Additional Barnwell Waste Management Facility Requirements 6.17.1 Each package of waste must be clearly labeled to identify whether it is Class A, Class B, or Class C waste, in accordance with 10 CFR 61.55.

6.17.2 All waste received at the Barnwell facility must be disposed in approved disposal overpacks.

6.17.3 Void spaces within the waste and between the waste and its packaging shall be reduced to the extent practicable, but in NO case shall the container be less than eighty-five percent (85%) full. This requirement is not applicable to waste in DHEC approved HICs and irradiated hardware containers.

Revision: 4 SOLID RADWASTE PROCESS CONTROL AP 31A-100 PROGRAM Reference Use Page 31 of 34 NOTE The South Carolina DHEC and CNSI recognize that filters and irradiated hardware will NOT routinely meet the 85% condition.

Provided that.containers of these waste types are packaged to the fullest extent practicable, no written justification is required.

6.17.4 The HPSR must apply for a variance request prior to shipment if the 85 percent fill requirement is NOT achievable.

6.17.5 Ensure that a copy of the Certificate of Compliance (C of C) for the approved High Integrity Container(s) as issued and amended by DHEC is on file with Barnwell Regulatory Affairs/Licensing Department.

7.0 RECORDS 7.1 The following QA Records are generated by this procedure.

7.1.1 Completed HIC USER'S CHECKLIST (FO-AD-002) 7.1.2 Completed CERTIFICATION STATEMENT FOR DISPOSAL OF POLYETHYLENE HIGH INTEGRITY CONTAINERS (FO-AD-002) 7.1.3 Completed PROCESS CONTROL PROGRAM CHANGE RECORD (APF 31A-100-04) 7.2 The following Non-QA Record is generated by this procedure.

7.2.1 Completed POLYETHYLENE HIGH INTEGRITY CONTAINER CERTIFICATION STATEMENT (FO-AD-002) 8.0 FORMS 8.1 FO-AD-002, HIC USER'S CHECKLIST 8.2 FO-AD-002, CERTIFICATION STATEMENT FOR DISPOSAL OF POLYETHYLENE HIGH INTEGRITY CONTAINERS 8.3 FO-AD-002, POLYETHYLENE HIGH INTEGRITY CONTAINER CERTIFICATION STATEMENT 8.4 APF 31A-100-04, PROCESS CONTROL PROGRAM CHANGE RECORD

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Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM 'AP 31A-100 Reference Use Page 32 of 34 ATTACHMENT A (Page 1 of 3)

TECHNICAL SPECIFICATION AMENDMENT CHANGES Solidification The conversion of wet wastes into a form that meets shipping and burial ground requirements.

ADMINISTRATIVE CONTROLS AND REPORTING REQUIREMENTS Limiting Condition of Operation Radioactive wastes shall be solidified or dewatered in accordance with the Process Control Program to meet shipping and transportation requirements during transit, and disposal site requirement when received at the disposal site.'

Applicability At all times Remedial Action

a. With solidification or dewatering not meeting disposal site and shipping and transportation requirements, suspend shipment of the inadequately processed wastes and correct the Process Control' Program, the procedures and/or the Solid Wastes System as necessary to prevent recurrence.

b. With solidification or dewatering not performed'in accordance with the Process Control Program, test the improperly processed waste ir each container to ensure that it meets burial ground shipping requirements and take appropriate administrative action to prevent recurrence.

Surveillance Requirements Solidification of at least one representative test specimen from at least every tenth batch of each type of wet radioactive wastes (e.g.,

filter sludges, spent resins, evaporator bottoms, boric acid solutions and sodium sulfate solutions) shall be verified in accordance with the Process Control Program:

ATTACHMENT A (Page 2 of 3)

TECHNICAL SPECIFICATION AMENDMENT CHANGES

a. If any test specimen fails to verify solidification, the solidification of the batch under test shall be suspended until such time as additional test specimens can be obtained, alternative solidification parameters can be determined in accordance with the Process Control Program, and a subsequent test verifies solidification.

Solidification of the batch may then be resumed using the alternative solidification parameters determined by the Process Control Program;

b. If the initial test specimen from a batch of waste fails to verify solidification, the Process Control Program shall provide for the collection and testing of representative test specimens from each consecutive batch of the same type of wet waste until at least three consecutive initial test specimens demonstrate solidification. The Process Control Program shall be modified as required, as provided in WCGS Technical Specifications 6.13 (TR 5.5.4), to assure solidification of subsequent batches of waste; and

c. With the installed equipment incapable of meeting this Administrative Control or declared out-of-service, restore the equipment to operable status or provide for contract capability to process wastes as necessary to satisfy all applicable transportation and disposal requirements.

Basis This Administrative Control implements the requirements of 10 CFR 50.36.a and General Design Criteria 60 Appendix A to 10 CFR 50.

The process parameters included in establishing the Process Control Program may include, but are not limited to, waste type, waste pH, waste/liquid/solidification agent/catalyst ratios, waste oil content, waste principal chemical constituents, and mixing and curing times.

Revision: 4 SOLID RADWASTE PROCESS CONTROL PROGRAM AP 31A-100 Reference Use . Page 34 of 34 ATTACHMENT A (Page 3 of 3)

TECHNICAL SPECIFICATION AMENDMENT CHANGES REPORTING REQUIREMENTS Annual Radioactive Effluent Release Report The Annual Radioactive Effluent Release Reports covering the operation of the unit during the previous calendar.year shall be submitted before May 1 of each year. The report shall include a summary of the quantities of radioactive liquid, gaseous effluents and solid waste released from the Unit. The material provided shall be.(1) consistent with the objectives outline in the ODCM and PCP, and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.

Changes to the PCP

a. Shall be documented and records of reviews performed shall be retained for the duration of the Unit Operating License. This documentation shall contain:

1. Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s).

2. The determination that the change will maintain the overall conformance of solidified waste product to existing requirements of Federal, State, or other applicable regulations.

b. Shall become effective after review and acceptance by the PSRC and the approval of the Plant Manager.

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