Text

Radioactive Waste Process Control Program Manual
	ML13214A063
Person / Time
Site:	Oconee
Issue date:	03/21/2013
From:	Vaught D; Duke Energy Corp
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML13214A063 (123)
	v • d • e

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM REVISION NUMBER ISSUE DATE 15 1/30/08_

Reviews and Approvals Documented in PIP G-06-00560 & G-07-00841 Prepared by/ Date: DL Vaught/ 11/14/07_ Review by/ Date: GT Johnson / 11/16/07__

NGO Radwaste Staff NGO Radiation Protection CATAWBA MCGUIRE OCONEE Reviewed By/ Date Reviewed By/ Date: Reviewed By/ Date:

BN Kimray/ 12/6/07___ JR Litaker/_11/15/07_____ RA Bowser/ 12/1/07___

Station Radiation Protection Station Radiation Protection Station Radiation Protection Reviewed By/ Date Reviewed By/ Date Reviewed By/ Date WK Carroll/ 11/14/07 ___OM Reid/12/7/07 __ _JA Cashion/ 11/19/07_____

Station Radwaste Chemistry Station Radwaste Chemistry Station Radwaste Chemistry Approved By/Date Approved By/Date Approved By/Date

__RS Beagles/ _1/3/08______ PA Hull/ 12/2/07_______ GM Barker/ 12/31/07__

Chemistry Manager Chemistry Manager Chemistry Manager Approved By/Date Approved By/Date Approved By/Date

___JA Pitesa/ _1/3/08____________ __RT Repko/ _12/2/07_______ __DA Baxter/ 12/31/07__________

Station Manager Station Manager Station Manager Issued By: ____Dewey P Rochester/ 1/28/08____________

Technical Manager, Nuclear Chemistry NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM TABLE OF CONTENTS

1. INTRODUCTION......................................................................................................................... 1 1.1 Purpose................................................................................................................................... 1 1.2 Radioactive Waste Process Control Program Description..................................................... 2 1.3 Radioactive Waste PCP Manual Contents............................................................................. 2

2. APPLICABILITY......................................................................................................................... 4 2.1 Liquid and Wet Radioactive Waste Disposal ........................................................................ 4 2.2 Mixed Waste Disposal ........................................................................................................... 4 2.3 Radioactive Waste Oil Disposal ............................................................................................ 5 2.4 Radioactive Waste Interim Storage ....................................................................................... 6

3. REGULATORY REFERENCES ................................................................................................ 6 3.1 Regulatory Requirements....................................................................................................... 6 3.2 Regulatory Guidance ............................................................................................................. 7

4. DUKE ENERGY PROGRAMMATIC REFERENCES ........................................................... 8 4.1 Oconee Technical Specification 5.6.2 Annual Radiological Environmental Operating Report................................................................................................................................... 8 4.2 Site-specific Selected Licensee Commitments ...................................................................... 8 4.3 Oconee UFSAR Chapter 11................................................................................................... 8 4.4 Catawba UFSAR Chapter 11 ................................................................................................. 8 4.5 McGuire UFSAR Chapter 13................................................................................................. 8 4.6 Duke Power Company QA Program Topical Report......................................................... 8 4.7 CNS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program.... 8 4.8 MNS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program... 8 4.9 ONS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program ... 8 4.10 Duke Energy Information Retention Policy .......................................................................... 8 4.11 NSD 701 Records Management ......................................................................................... 9 4.12 NSD 703 Administrative Instructions for Technical Procedures....................................... 9 4.13 Catawba, McGuire & Oconee Environmental Work Practice (EWP) 2.8 Used Oil .......... 9 4.14 Catawba, McGuire & Oconee EWP 2.9 Mixed Waste ...................................................... 9 CORP PCP i NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 4.15 Supply Chain Document (SCD) 510 Approved Suppliers List.......................................... 9 4.16 SCD 520 Audits of Suppliers ............................................................................................. 9 4.17 SCD 285 Procurement of QA Condition 2, 3, and 4 Items ................................................ 9 4.18 Operating Experience (OE) & Problem Investigation Process (PIP) .................................... 9

5. DEFINITIONS .............................................................................................................................. 9 5.1 Safety Analysis Report (SAR) ............................................................................................... 9 5.2 Selected Licensee Commitments (SLCs)............................................................................... 9 5.3 10CFR Part 61 Licensing Requirements for Land Disposal of Radioactive Waste......... 10 5.4 Free Standing Liquid (FSL) ................................................................................................. 10 5.5 Liquid Radioactive Wastes .................................................................................................. 10 5.6 Wet Radioactive Wastes ...................................................................................................... 10 5.7 Solidification........................................................................................................................ 10 5.8 High Integrity Container (HIC) ........................................................................................... 11 5.9 Dewatering........................................................................................................................... 11 5.10 Unwatering (Gross Dewatering) .......................................................................................... 11 5.11 Mixed Waste ........................................................................................................................ 11 5.12 QA Approved Supplier List ................................................................................................. 12 5.13 Waste Batch ......................................................................................................................... 12 5.14 Waste Batch Mixing ............................................................................................................ 12 5.15 Process Parameters............................................................................................................... 12 5.16 Boundary Conditions/ Acceptance Criteria ......................................................................... 12 5.17 Topical Report (PIPs O-03-0624, M-03-2515, C-03-3385) ................................................ 13

6. RESPONSIBILITIES ................................................................................................................. 13 6.1 Nuclear General Office ........................................................................................................ 13 6.2 Nuclear Safety Review Board.............................................................................................. 14 6.3 Nuclear Stations ................................................................................................................... 15

7. ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS ................................. 16 7.1 PCP Manual Administration ................................................................................................ 16 7.2 PCP Revision Reports to the NRC ...................................................................................... 16 7.3 PCP Audit Process ............................................................................................................... 16 CORP PCP ii NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 7.4 PCP Manual Revision Record Retention Requirements...................................................... 16 7.5 Periodic cross-checks & comparisons (PIP O-03-0624 CAPR) .......................................... 17 7.6 PCP Implementing Procedure Requirements....................................................................... 17

8. APPROVAL PROCESS FOR QA APPROVED SUPPLIERS .............................................. 18 8.1 Technical Review and Approval.......................................................................................... 18 8.2 QA Supplier Evaluation....................................................................................................... 18 8.3 QA Approved Supplier Program ......................................................................................... 18

9. PCP REQUIREMENTS FOR VENDOR PROCESSES AND SERVICES .......................... 19 9.1 Topical Report (or equivalent)............................................................................................. 19 9.2 10CFR61 Waste Form Compliance ..................................................................................... 19 9.3 10CFR61Waste Classification Compliance......................................................................... 19 9.4 Minimum Requirements for Onsite Process Vendors ......................................................... 20 9.5 Minimum Requirements for Offsite PCP Process Vendors................................................. 21

10. PCP SOLIDIFICATION PROCESS DESCRIPTION ........................................................... 21 10.1 Waste Characterization ........................................................................................................ 21 10.2 Mixed Waste Characterization............................................................................................. 21 10.3 Minimum Solidification Acceptance Criteria...................................................................... 22 10.4 Representative Waste Sample.............................................................................................. 22 10.5 Bench Scale Test Solidification ........................................................................................... 23 10.6 Full Scale Solidification....................................................................................................... 26 10.7 Product Verification of Full Scale Solidification................................................................. 26 10.8 Inoperable Equipment (SLC Remedial Action Requirements) ........................................... 28 10.9 Solidification Document Retention...................................................................................... 28

11. PCP DEWATERING PROCESS DESCRIPTION ................................................................. 29 11.1 Dewatering Mechanical Filters (e.g., cartridge, bag, membrane)........................................ 29 11.2 Dewatering Slurries ............................................................................................................. 30 11.3 Additional Conservatism in Slurry Dewatering Procedures to Address Variation from the Topical Report (PIP O-03-0624, M-03-2515, C-03-3385).................................................. 31 11.4 Dewatering Process Requirements ...................................................................................... 33 11.5 Product Verification............................................................................................................. 34 CORP PCP iii NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 11.6 Inoperable Equipment (SLC Remedial Action Requirements) ........................................... 36 11.7 Dewatering Document Retention......................................................................................... 36 CORP PCP iv NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

1. INTRODUCTION 1.1 Purpose The Duke Energy Radioactive Waste Process Control Program Manual addresses all the requirements for the Solid Radioactive Waste section in Selected Licensing Commitment 16.11, Radiological Effluent Controls at each of the Duke Energy nuclear stations.

1.1.1 The Process Control Program (PCP) describes the administrative and operational controls used for the solidification of liquid or wet radioactive wastes and the dewatering of wet radioactive wastes. Its purpose is to assure that the final disposal waste product meets applicable Federal, State and Disposal Site waste form requirements for burial at a 10CFR61 licensed Low Level Waste (LLW) disposal site per the Commitment section of the Solid Radioactive Wastes section in SLC 16.11.

1.1.2 Waste processing (solidification or dewatering as described below) equipment and services may be provided by Duke Energy or vendors. Any process used shall meet all applicable requirements of the Process Control Program.

1.1.3 This Corporate PCP section specifically describes the processes required to meet the Remedial Action requirements and Surveillance Requirements of ONS SLC 16.11.5, MNS SLC 16.11.11 and CNS SLC 16.11-11. These are summarized below:

1.1.3.1 Actions required prior to the next shipment for disposal of solidified or dewatered wastes if applicable regulatory requirements for solidified or dewatered wastes are not satisfied (See Corporate PCP Sections 10 & 11).

1.1.3.2 Actions required prior to next solidification for shipment of waste for disposal at a 10CFR61 disposal site if a solidification test fails to verify solidification (See Corporate PCP Section 10).

1.1.3.3 Actions required whenever solidification or dewatering for disposal is not performed in accordance with the PCP (See Corporate PCP Sections 10 & 11).

1.1.3.4 Actions required with the solid waste equipment incapable of meeting SLC 16.11 Solid Radioactive Waste requirements, or not in service (See Corporate PCP Sections 10 & 11).

CORP PCP Page 1 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 1.1.3.5 The Surveillance Requirement pertains only to solidification and is contained in section 10. The Process Control Program shall be used to verify the Solidification of at least one representative test specimen from at least every tenth batch of each type of radioactive waste to be solidified for disposal at a 10CFR61 disposal site per the COMMITMENT of this SLC.

1.1.4 It is the responsibility of the LLW generator to ensure that PCP requirements are met and that the condition of the waste is acceptable upon arrival at the disposal site.

1.2 Radioactive Waste Process Control Program Description The Radioactive Waste PCP Manual meets NRC requirements for a Process Control Program. It is published as a manual and controlled copies are maintained in the following locations:

Online PCP Manual: NEDL (Portal)/Licensing/ELL Document

Nuclear General Office (NGO) Chemistry copy of the PCP Manual: NGO Chemistry Satellite File

Archived film copies of revisions are maintained as described in APPENDIX F Administration of the PCP and Support Documents 1.3 Radioactive Waste PCP Manual Contents The PCP manual is comprised of:

1.3.1 CORPORATE PROCESS CONTROL PROGRAM The Corporate Process Control Program (PCP) describes the technical and operational requirements that shall be met by each nuclear station to ensure final solidification or dewatering radioactive waste products meet applicable federal and state disposal regulations. It also includes documentation of the required approvals for the current revision of the Corporate PCP. The requirements comprise a system wide program and are applicable to all of the nuclear stations as defined in their individual PCP program appendices described below.

1.3.2 APPENDIX A OCONEE NUCLEAR STATION PCP Each station has a site specific PCP describing the Nuclear Generation documents used for implementing the requirements of the Corporate PCP. The station PCPs are contained in APPENDIX A, B and C. Each site PCP contains the following:

CORP PCP Page 2 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

Documentation of the required approvals for the current revision of the station PCP per APPENDIX E

A list of Nuclear Generation procedures used to implement the Corporate PCP requirements

A list of drawings showing plant radwaste systems interfaces with solidification and dewatering equipment used to meet the Corporate PCP

Exceptions to the Corporate PCP 1.3.3 APPENDIX B Mc GUIRE NUCLEAR STATION PCP (for content see 1.3.2) 1.3.4 APPENDIX C CATAWBA NUCLEAR STATION PCP (for content see 1.3.2) 1.3.5 APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES This table contains the following:

List of vendors approved for PCP services

Describes approved services and specific requirements 1.3.6 APPENDIX E PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS This table describes who shall perform the reviews and approvals for each section of the PCP Manual.

1.3.7 APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS This appendix is a comprehensive administrative guideline for control and distribution of the PCP manual and its supporting documents. Its contents are summarized below.

1.3.7.1 Administrative processes for the PCP manual

Revisions, reviews and approvals

Electronic publication 1.3.7.2 Administrative processes for Nuclear Generation implementing procedures

Revisions

Retention requirements CORP PCP Page 3 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 1.3.7.3 Administrative processes for use of vendor documents

Revision review and evaluation for impact

Control, distribution and retention of vendor documents 1.3.8 APPENDIX G WASTE PROCESSOR CHECKLIST This is a template of technical review criteria used by NGO Radiation Protection and Chemistry to pre-approve and renew radwaste vendors for inclusion in the QA Approved Supplier List.

1.3.9 APPENDIX H REVISION

SUMMARY

- LICENSEE INITIATED CHANGES This appendix summarizes changes for current PCP manual revisions for reference during reviews and for record retention.

2. APPLICABILITY 2.1 Liquid and Wet Radioactive Waste Disposal 2.1.1 Final Safety Analysis Report Chapter 16, Selected Licensee Commitments, Section 11 requires that the Solid Radwaste System or an approved alternative process be used in accordance with a PCP for the solidification of liquid or wet radioactive wastes or the dewatering of wet radioactive wastes to be shipped for direct disposal at a 10CFR61 licensed disposal site such that the final product meets all applicable disposal site requirements.

2.1.2 These Process Control Program requirements are applicable to all liquid or wet radioactive wastes that are being prepared for direct disposal at a 10CFR61 LLW disposal facility.

2.1.3 Radioactive wastes shipped for off site processing in accordance with the processor's specifications and transportation requirements are not required to be solidified or dewatered to meet disposal requirements and are not subject to the solidification or dewatering requirements of this PCP.

2.2 Mixed Waste Disposal 2.2.1 Environmental Work Practice 2.9 Mixed Waste defines the Mixed Waste program at Duke Energy nuclear stations.

2.2.2 The PCP is only applicable when Mixed Waste is solidified for disposal at a 10CFR61 disposal site.

CORP PCP Page 4 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 2.2.3 NGO Chemistry shall approve the use of solidification for disposal of Mixed Waste.

2.2.4 If Mixed Waste is to be disposed of as LLW at a 10CFR61 disposal site by rendering it non-hazardous using solidification, the solidification shall be done according to PCP requirements.

2.2.5 Disposal of Mixed Waste at a Low Level Radioactive Waste disposal site is prohibited except under the following conditions:

2.2.5.1 The waste shall meet the 40 CFR part 266 exemption criteria, 10 CFR part 61 disposal requirements and all applicable state and disposal site requirements.

2.2.5.2 Approval for disposal shall be obtained from the disposal site prior to disposal. (e.g., Barnwell):

A. No mixtures of radioactive waste and hazardous waste (Mixed Waste), as defined by 40CFR261 and S.C.

Management Registration 61-79.261, are acceptable for burial in Barnwell.

B. However, a Mixed Waste which was classified as hazardous solely because it exhibited one or more characteristics defined in 40CFR261 Subpart C, but has been treated in a manner such that it no longer exhibits any of these characteristics, will be reviewed on a case-by-case basis for burial acceptance.

2.2.6 All vendors supplying solidification services for Mixed Waste shall meet the requirements of applicable PCP sections and be listed in Appendix D Approved PCP Service Suppliers.

2.3 Radioactive Waste Oil Disposal 2.3.1 Radioactively contaminated oil is to be managed as described in the EWP 2.8 Used Oil.

2.3.2 Each disposal site defines the acceptable threshold for incidental levels of waste petroleum-based oil (e.g., less than 1% by volume). Solidified waste containing oil shipped to a 10CFR61 disposal site shall meet the applicable requirements of this Process Control Program and all applicable disposal site acceptance criteria.

CORP PCP Page 5 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 2.3.3 If a disposal site accepts greater than incidental concentrations of oil to be solidified for disposal, an oil-specific procedure that meets the requirements of this PCP and the acceptance criteria of that disposal site shall be used (e.g.,

on a case-by-case basis, SCDHEC may approve solidification of synthetic oils for burial at the Barnwell, SC LLW disposal site).

2.4 Radioactive Waste Interim Storage Nuclear Generation procedures shall be established to ensure that all of the following interim storage requirements are met.

2.4.1 Any processed (i.e., solidified or dewatered) radioactive waste that is stored for an interim period in a disposal container shall be packaged such that there is no interaction between the waste and its container.

2.4.2 If applicable, Certificates of Compliance shall be maintained at each station for all waste disposal containers used for interim storage.

2.4.3 Vendor supplied containers used for storage shall be handled and stored according to applicable guidance in vendor procedures, including chemical compatibility requirements.

3. REGULATORY REFERENCES 3.1 Regulatory Requirements The use of and content of the PCP addresses requirements found in the following regulations:

3.1.1 10CFR20, Standards for Protection Against Radiation 3.1.2 10CFR50, Domestic Licensing of Production and Utilization Facilities 3.1.3 10CFR61, Licensing Requirements for Land Disposal of Radioactive Waste 3.1.4 10CFR7l, Packaging and Transportation of Radioactive Materials 3.1.5 40CFR, Protection of Environment 3.1.6 40 CFR Part 266 Storage, Treatment, Transportation, and Disposal of Mixed Waste 3.1.7 Licensed radioactive waste burial site criteria CORP PCP Page 6 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 3.1.8 State hazardous waste regulations 3.2 Regulatory Guidance In order to assure compliance with the above regulations, the NRC has provided guidance in the following documents:

3.2.1 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants 3.2.2 NUREG-0452, Standard Technical Specifications for Westinghouse PWR's (Superseded by NUREG 1431) 3.2.3 NUREG-1431 Standard Technical Specifications Westinghouse Plants 3.2.4 NUREG-1430 Standard Technical Specifications Babcock and Wilcox Plants 3.2.5 NUREG-800 Standard Review Plan, Section 11.4 Solid Waste Management Systems 3.2.6 NUREG 800, Section 11.4, Appendix -A, Design Guidance for Temporary Onsite Storage of Low Level Radioactive Waste 3.2.7 Branch Technical Position - ETSB 11-3, Design Guidance of Solid Radioactive Waste Management Systems 3.2.8 NRC Review Criteria for Solid Waste Management Systems 3.2.9 Regulatory Guide 1.143, Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Plants 3.2.10 NRC "TECHNICAL POSITION ON WASTE FORM" Revision 1 (January 1991) 3.2.11 ANSI/ANS-40.37-1993 mobile radioactive waste processing systems CORP PCP Page 7 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

4. DUKE ENERGY PROGRAMMATIC REFERENCES 4.1 Oconee Technical Specification 5.6.2 Annual Radiological Environmental Operating Report 4.2 Site-specific Selected Licensee Commitments 4.2.1 Catawba SLC 16.11-11 Solid Radioactive Waste 4.2.2 Catawba SLC 16.11-16 Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report 4.2.3 McGuire SLC 16.11.11 Solid Radioactive Waste 4.2.4 McGuire SLC 16.11.17 Radioactive Effluent Release Report 4.2.5 Oconee SLC 16.11.5 Solid Radioactive Waste 4.3 Oconee UFSAR Chapter 11 4.4 Catawba UFSAR Chapter 11 4.5 McGuire UFSAR Chapter 13 4.6 Duke Power Company QA Program Topical Report 4.7 CNS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program 4.8 MNS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program 4.9 ONS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program 4.10 Duke Energy Information Retention Policy Ref: (Legal 109, 10CFR20 Appendix G (III.A.3), 10CFR61.80)

CORP PCP Page 8 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 4.11 NSD 701 Records Management 4.12 NSD 703 Administrative Instructions for Technical Procedures 4.13 Catawba, McGuire & Oconee Environmental Work Practice (EWP) 2.8 Used Oil 4.14 Catawba, McGuire & Oconee EWP 2.9 Mixed Waste 4.15 Supply Chain Document (SCD) 510 Approved Suppliers List 4.16 SCD 520 Audits of Suppliers 4.17 SCD 285 Procurement of QA Condition 2, 3, and 4 Items 4.18 Operating Experience (OE) & Problem Investigation Process (PIP) 4.18.1 G-99-00349 (NGO Radwaste Support PCP evaluation) 4.18.2 C-99-05094 (SLC 16.11 Issues related to PCP requirements) 4.18.3 G-00-401 (QA Audit -General Office Assessment SA-00-29(GO) (RA))

4.18.4 O-00-4680 (ONS filter dewatering procedure use) 4.18.5 C-01-02522 (2001 CNS NRC Audit) 4.18.6 O-01-01067 (Filter HIC dewatering clarification) 4.18.7 G-02-00272 (QA Audit -Assessment GO-02-31(NPA) NSD) 4.18.8 O-03-0624, M-03-2515, C-03-3385 (ONS FSL Failure Root Cause)

5. DEFINITIONS 5.1 Safety Analysis Report (SAR)

The stations Technical Specifications (Tech Specs) updated final safety analysis report, licensee commitments, safety evaluation reports and the facility operating license.

5.2 Selected Licensee Commitments (SLCs)

Commitments to control important plant equipment and operating conditions not controlled elsewhere. Operational commitments which are to be removed from existing station Tech Specs may be included in the SLC program. Also included in this program can be selected NRC commitments contained in licensing documents such as the CORP PCP Page 9 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM station's SERs, LERs, violation responses, generic letter and bulletin responses, submittal documents and other Duke letters to the NRC.

5.3 10CFR Part 61 Licensing Requirements for Land Disposal of Radioactive Waste This NRC regulation requires that low-level radioactive waste (LLW) meet certain waste form acceptance criteria in order to be received for disposal at NRC and Agreement State licensed radioactive waste disposal sites.

5.4 Free Standing Liquid (FSL)

FSL is liquid that is in a disposal container but is not bound by the waste in the container. FSL is the liquid available for release if disposal container integrity is lost (e.g., punctured). The amount of FSL in a radioactive waste disposal container shall be less than a specified threshold in order to meet 10CFR61, state and disposal site requirements for disposal.

5.5 Liquid Radioactive Wastes Radioactive wastes comprised primarily of water containing a combination of dissolved and suspended solids (e.g., evaporator concentrates, lab wastes, floor and equipment drain water, laundry, wet waste decant or drainage, etc.).

5.6 Wet Radioactive Wastes Wet radioactive wastes are solid radioactive wastes containing loosely bound liquid that can collect in the disposal container as FSL (e.g., slurry wastes are comprised primarily of solid particles suspended in loosely bound interstitial water, spent mechanical filters are solid materials that are adsorbent or porous and retain liquid).

5.7 Solidification Solidification is a process that converts radioactive waste into a product meeting 10CFR61, State and disposal site requirements for waste-form stability and FSL.

Solidification is accomplished by mixing measured amounts of liquid or wet radioactive waste, binder and required additives that, after sufficient curing time, produce a solid homogeneous, freestanding monolith. At the end of the curing period, the absence of excessive FSL is verified either by confirmation that the PCP was followed or by physical verification/testing.

CORP PCP Page 10 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 5.8 High Integrity Container (HIC)

Disposal containers that have been approved by the NRC for disposal of Class A unstable, Class B or Class C LLW and meet the long term stability requirements of 10CFR61 and the disposal site.

5.9 Dewatering Dewatering as used in this document is the removal of liquid using a process that is required to meet the requirements of this PCP. Dewatering removes the loosely bound liquid from a wet radioactive waste such that accumulation of Free Standing Liquid in the disposal container is unlikely to approach the disposal limit threshold values as defined by applicable regulations and disposal site criteria. NRC regulations require that the process used to dewater radioactive wastes to meet disposal criteria shall be governed by a PCP.

5.9.1 10CFR61 FSL criteria requires less than 0.5% FSL by waste volume per container or less than 1.0% FSL if a high integrity container (HIC) is used.

5.9.2 Typically, liquid and wet wastes are pre-staged in vented tanks or containers and are therefore degassed prior to the dewatering process. However, all vendor-required venting practices should be adhered to.

5.10 Unwatering (Gross Dewatering)

Unwatering as used in this document is the removal of water using a process that is not required to meet the requirements of this PCP. Unwatering removes loosely bound excess or freeboard water from wet radioactive wastes such that only the requirements for transportation set forth in 49CFR are satisfied (e.g., unwatering may be used to prepare waste for shipment to an approved offsite processor who will perform additional processing that will meet the final disposal requirements).

5.11 Mixed Waste Defined in Resource Conservation Recovery Act (RCRA) as amended by the Federal Facility Compliance Act of 1992, a Mixed Waste contains both RCRA hazardous waste and source, special nuclear, or byproduct material subject to the Atomic Energy Act of 1954, as amended. The use of solidification to render Mixed Wastes non-hazardous shall ensure that the final product meets all waste form requirements applicable to radioactive waste disposal at a 10CFR61 disposal site (Ref: 3.1.6. 40 CFR Part 266).

CORP PCP Page 11 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 5.12 QA Approved Supplier List Radwaste vendors approved to provide PCP processing are included on the QA Approved Supplier List and are subject to the requirements and audits of that program.

5.13 Waste Batch A "batch" shall be defined as an isolated quantity of waste to be processed having essentially consistent physical and chemical characteristics.

5.14 Waste Batch Mixing A Waste Batch shall be adequately mixed using a proceduralized process such as agitation via mixers, air sparging or recirculating flow which meets a specified minimum rate that has been determined to provide a representative sample for the vessel.

5.15 Process Parameters Those conditions measured or observed during a solidification or dewatering process to ensure an acceptable product. These are determined for each waste type and are specific to the process method used.

5.16 Boundary Conditions/ Acceptance Criteria 5.16.1 Solidification Boundary Conditions or Acceptance Criteria are defined as, the bounding numerical values for solidification process parameters that produce an acceptable product.

5.16.1.1 The Boundary Conditions are verified by using a Bench Scale Test Solidification.

5.16.1.2 A Bench Scale Test Solidification is performed on a small representative sample of the Waste Batch using the prescribed formulation and conditions that model those parameters critical to the full scale solidification process 5.16.1.3 The Bench Scale Test product is then verified to meet the acceptance criteria for that waste form.

5.16.1.4 For Mixed Waste solidification, the Boundary Condition values also ensure that the final solidified product is rendered non-hazardous and are verified through lab testing of the Bench Scale Test product.

CORP PCP Page 12 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 5.16.2 Dewatering Boundary Conditions or Acceptance Criteria are defined as the bounding numerical values for process parameters that ensure free standing liquid requirements are met.

5.16.2.1 Media: Acceptance Criteria for dewatering process media in disposal containers (e.g., HICs) have been determined by vendor tests using real or simulated waste to demonstrate the adequacy of the dewatering process for each combination of waste type and container. These tests are documented in dewatering Topical Reports, or equivalent, that shall be approved by the NRC before the containers are certified for use. The Acceptance Criteria are then incorporated into the dewatering procedures for each combination of waste type and container.

5.16.2.2 Filters: Acceptance criteria for mechanical filters (e.g., cartridge, bag, membranes, etc.) are derived from tests performed on the various types of filters in use. Tests performed by Duke Energy should be documented in a retrievable manner (e.g., PIP, Memo in Master file, etc.). Acceptance criteria are then incorporated into the applicable procedure for each filter type (e.g., drainage time, drainage conditions, etc.).

5.17 Topical Report (PIPs O-03-0624, M-03-2515, C-03-3385)

A Topical Report provides the basis for a PCP technology & process. It documents test results that demonstrate regulatory requirements were met during the regulatory required testing for solidification or dewatering technologies and processes. All currently approved processes developed to dewater or solidify waste have been approved by the NRC based their review of the Topical Report for that process. Topical report testing was designed to envelope the worst case dewatering scenarios given the industry's then current practices. As with any topical based program, the critical conditions and parameters identified during testing are incorporated into the implementing process with enough conservative margin to ensure success if you operate within the enveloping conditions and assumptions of the tests performed. When actual conditions vary from the conditions in the specific tests performed for the Topical Report, the correlation with the Topical testing is diminished and degree of conservatism must increase to compensate.

6. RESPONSIBILITIES 6.1 Nuclear General Office 6.1.1 NGO Chemistry is the owner, sponsor and administrator for the PCP including the following activities:

CORP PCP Page 13 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 6.1.1.1 Revises and publishes PCP Manual per APPENDIX F Administration of the PCP and Support Documents 6.1.1.2 Technical contact for PCP issues 6.1.1.3 Ensures corporate Chemistry program complies with applicable PCP requirements 6.1.1.4 Supports nuclear site Chemistry programs in complying with applicable PCP requirements 6.1.1.5 Provides review and approval of PCP service providers 6.1.1.6 Authors and approves PCP Manual revisions per APPENDIX E PCP Manual Review and Approval Requirements 6.1.2 Nuclear General Office Radiation Protection (RP) 6.1.2.1 Ensures corporate RP program complies with applicable PCP requirements 6.1.2.2 Supports nuclear site RP programs in complying with applicable PCP requirements 6.1.2.3 Provides review and approval of radioactive waste processors 6.1.2.4 Reviews PCP revisions per APPENDIX E PCP Manual Review and Approval Requirements 6.1.3 Nuclear Supply Chain 6.1.3.1 Maintains PCP vendors in Approved QA supplier list 6.1.3.2 Communicates NUPIC QA audits and issues related to PCP vendors to NGO Chemistry Radwaste support staff 6.2 Nuclear Safety Review Board Audits of the Process Control Program and implementing procedures for Solidification of radioactive wastes shall be performed under the cognizance of the NSRB per Duke Power Company QA Program Topical Report.

CORP PCP Page 14 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 6.3 Nuclear Stations The PCP applies to all liquid or wet radioactive waste generated at the nuclear site when it is solidified or dewatered for direct disposal at a 10CFR61 disposal site. Any group that has responsibility for activities that generate or manage these wastes shall ensure their programs and processes comply with and support compliance with the applicable portions of the PCP. The following responsibilities are currently identified within specific groups or positions, but will be applicable to any group that has the responsibility. Any changes in these responsibilities and the groups to whom they are assigned should be evaluated for impact and potential incorporation into the PCP Manual.

6.3.1 Station Manager approves PCP revisions per APPENDIX E PCP Manual Review and Approval Requirements 6.3.2 Station Line Management responsible for programs impacting the PCP ensures those programs comply with the site PCP. Currently identified program owners:

6.3.2.1 Station Chemistry Manager approves PCP revisions per APPENDIX E PCP Manual Review and Approval Requirements 6.3.2.2 Station Chemistry General Supervisors ensure Chemistry programs and resources comply with and support the PCP Manual, (e.g., site PCP, dewatering procedures) 6.3.2.3 Station RP Management ensures RP programs and resources comply with and support the PCP Manual, (e.g., site PCP, filter dewatering, shipping process interface with PCP activities) 6.3.3 Station Staff and Line Supervisors ensure applicable area-specific procedures and activities comply with the PCP 6.3.3.1 Station Chemistry Staff A. Ensures site PCP complies with the Corporate PCP B. Ensures Chemistry dewatering or solidification procedures comply with the Corporate PCP C. Serves as Subject Matter Expert on Chemistry PCP processes at the site CORP PCP Page 15 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM D. Reviews PCP revisions per APPENDIX E PCP Manual Review and Approval Requirements 6.3.3.2 Station Radiation Protection Staff and/or RM&C Supervision A. Ensure RP procedures comply with applicable PCP Manual requirements (e.g., filter dewatering/disposal, shipping procedures, shipping and disposal paperwork)

B. Reviews PCP revisions per APPENDIX E PCP Manual Review and Approval Requirements 6.3.4 Station Technicians ensure current documents are used to implement PCP-related activities 6.3.4.1 Station Chemistry Technicians implement applicable portions of the site PCP, (e.g., dewatering process media) 6.3.4.2 Station Radiation Protection Technicians implement applicable portions of the site PCP, (e.g., dewatering mechanical filters) 6.3.5 Regulatory Compliance incorporates the PCP revision summary report into the site Annual Effluent report.

7. ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 7.1 PCP Manual Administration See APPENDIX F Administration of the PCP and Support Documents 7.2 PCP Revision Reports to the NRC Revisions to the PCP shall be reported to the NRC each year as described in APPENDIX F Administration of the PCP and Support Documents.

7.3 PCP Audit Process The Duke Power Company QA Program Topical Report describes the internal auditing requirements for the Corporate PCP and Nuclear Generation implementing procedures under the cognizance of the NSRB at each station and the General Office.

7.4 PCP Manual Revision Record Retention Requirements See APPENDIX F Administration of the PCP and Support Documents CORP PCP Page 16 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 7.5 Periodic cross-checks & comparisons (PIP O-03-0624 CAPR)

Periodic cross-checks & comparisons of each nuclear sites dewatering process guidance, dewatering techniques and equipment will be performed as part of the following activities:

7.5.1 Every other year during the annual Chemistry Functional Area Evaluation as part of section 8.4 Implementation of Process Control Program of the Performance Attributes Matrix 7.5.2 Other benchmarking opportunities (e.g., benchmark trips by Radwaste personnel, annual Radwaste workshop discussion groups identify current industry practices and site contacts for comparison of practices 7.6 PCP Implementing Procedure Requirements 7.6.1 Nuclear Generation procedures shall be established to ensure that all requirements for solidification or dewatering are met when performed by site-assigned personnel.

7.6.2 The administrative requirements for PCP implementing procedures are described in APPENDIX F Administration of the PCP and Support Documents.

7.6.2.1 Completed procedures documenting the solidification verification records described in section 10 shall be maintained by Duke Power Company on each vessel of solidified waste as described in section 5.5 of APPENDIX F.

7.6.2.2 Documentation of the dewatering verification records described in section 11 shall be maintained by Duke Power Company on each vessel of dewatered waste as described in section 5.5 of APPENDIX F.

7.6.3 Vendors providing onsite PCP services may use their own vendor procedures to perform PCP services using non-installed equipment as described in NSD 703 provided they meet the applicable requirements of the PCP Manual.

7.6.4 Vendor documents directing solidification or dewatering activities of site assigned personnel shall be incorporated into site implementing procedures as described in APPENDIX F.

CORP PCP Page 17 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

8. APPROVAL PROCESS FOR QA APPROVED SUPPLIERS Any supplier shall be approved and incorporated into the QA Approved Supplier Program prior to being contracted for PCP services.

8.1 Technical Review and Approval Before vendors can provide PCP related services, they shall be evaluated against the Duke Energy Radioactive Waste PCP Manual and approved by the Technical Manager, Nuclear Chemistry or his designee.

8.1.1 Prior to awarding a contract to a supplier for processing site radioactive waste, vendors are subjected to a review using criteria outlined in APPENDIX G Waste Processor Checklist 8.1.2 If the vendor provides PCP related services, the vendor PCP and other related program documents are evaluated to ensure they meet the applicable requirements of the Duke Energy Radioactive Waste PCP Manual as described in section 9 below.

8.1.3 The results of these reviews should be documented in a PIP for future reference.

8.2 QA Supplier Evaluation Upon meeting the requirements of the technical review, the supplier is evaluated for incorporation into the QA Supplier program in accordance with the requirements of Duke Energy Nuclear Quality Assurance Program.

8.3 QA Approved Supplier Program All vendors approved to provide PCP related services are included in the QA Approved Suppliers List. The QA processes that apply are described in the following Supply Chain documents 8.3.1 SCD 510 Approved Suppliers List 8.3.2 SCD 520 Audits of Suppliers 8.3.3 SCD 285 Procurement of QA Condition 2, 3, and 4 Items CORP PCP Page 18 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

9. PCP REQUIREMENTS FOR VENDOR PROCESSES AND SERVICES 9.1 Topical Report (or equivalent)

Any vendor service or vendor supplied processes utilized for solidification or dewatering by Duke Energy shall have a Topical Report or other form of certification documenting appropriate regulatory approval of the process and associated containers, or shall supply to Duke Energy sufficient documentation of the process and test results to demonstrate that an acceptable product will be produced using the described solidification or dewatering process.

9.2 10CFR61 Waste Form Compliance 9.2.1 The vendor(s) approved for solidification or dewatering services shall have regulatory certification documenting compliance with waste form requirements in the final product, or shall supply Duke Energy sufficient documentation to demonstrate waste form compliance.

9.2.2 Any vendor providing High Integrity Containers (HICs) to Duke Energy shall provide proof of regulatory approval documenting compliance with waste form requirements, or shall supply Duke Energy sufficient documentation to demonstrate waste form compliance.

9.2.3 All vendor Topical Reports or equivalent shall certify that the final product conforms to the appropriate waste form for Class A, B, or C waste.

9.2.4 Vendor PCP Service Quality Requirements QA Approved PCP Service Suppliers shall meet the applicable quality requirements set forth in their Purchase Order. Examples of such requirements are described in APPENDIX D Approved PCP Service Suppliers.

9.3 10CFR61Waste Classification Compliance 9.3.1 Each container of processed (i.e., solidified or dewatered) waste shall be classified as Class A, B, or C waste using the 10 CFR Part 61 Waste Classification and Waste Form Implementation Program for the applicable station.

9.3.2 Each container of processed waste shall be certified to the appropriate waste form for Class A, B or C waste. Greater-than-Class C waste may be approved for disposal on a case-by-case basis with appropriate approval from the disposal site and agreement state.

CORP PCP Page 19 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 9.3.3 Each container of processed Mixed Waste shall be certified to be non-hazardous.

9.4 Minimum Requirements for Onsite Process Vendors 9.4.1 Vendors providing PCP services onsite shall fulfill all of the applicable requirements in the Radioactive Waste PCP Manual and the applicable quality requirements set forth in the Purchase Order prior to shipment of the solidified or dewatered waste offsite for disposal.

9.4.2 Onsite Vendor System/Equipment Interface Requirements:

9.4.2.1 The vendor Topical Report or documentation supplied to Duke Energy shall include a detailed system or process description of all vendor interfaces with installed plant equipment.

9.4.2.2 Drawings or diagrams shall be included detailing all solidification and dewatering system interfaces with installed plant systems and equipment.

9.4.2.3 Solidification system ventilation discharge is treated or routed to the plant's auxiliary building or radwaste facility ventilation system to meet effluent discharge requirements.

9.4.2.4 Decanted radioactive liquid is processed as required or routed to the station liquid radwaste systems.

9.4.2.5 This information may be included as part of a Topical Report furnished by the equipment manufacturer or supplier or as part of the station specific Final Safety Analysis Report.

9.4.3 Onsite Vendor System Design Requirements 9.4.3.1 The vendor Topical Report or equivalent documentation supplied to the Duke Energy shall include a statement that the design, construction, operation and quality assurance provisions are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143.

9.4.3.2 Permanent or portable solidification and dewatering systems used at nuclear sites shall meet the design, construction, operation and quality assurance provisions of NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143.

CORP PCP Page 20 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 9.5 Minimum Requirements for Offsite PCP Process Vendors Vendors providing PCP services offsite shall meet the requirements of their PCP process and the applicable quality requirements set forth in the Nuclear Supply Chain Purchase Order prior to disposal of the final product.

10. PCP SOLIDIFICATION PROCESS DESCRIPTION Waste solidification at Duke Energy nuclear stations shall be performed in a manner equivalent to the process described below using approved procedures in a controlled and quality fashion which ensures that all applicable regulatory and disposal site criteria are met. Procedures used to direct solidification shall include the adequate detail to implement a process equivalent to that described below.

NOTE: Whenever a solidification process is used to meet 10CFR61 disposal site requirements, Surveillance Requirements in ONS SLC 16.11.5, MNS SLC 16.11.11 and CNS SLC 16.11-11 shall be fulfilled by using procedures that meet or surpass the Bench Scale Test solidification verification and frequency requirements below or by verifying these requirements are met by the vendor program/process being used.

10.1 Waste Characterization The waste sample shall be characterized chemically, physically and radiologically.

Sample analyses such as the following shall be performed as outlined in site-specific procedures for the applicable waste form and solidification media to be used.

10.1.1 Waste pH 10.1.2 Waste density 10.1.3 Waste boron concentration 10.1.4 Waste oil content 10.1.5 Gamma Analysis 10.2 Mixed Waste Characterization 10.2.1 Process knowledge may be used for hazardous waste characterization with approval by the appropriate knowledgeable individual.

10.2.2 If process knowledge cannot be used, the hazardous characteristics shall be determined before solidification using an approved method.

CORP PCP Page 21 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 10.2.3 The disposal site shall be notified to obtain pre-approval for disposal whenever a waste determined to be a Mixed Waste is being rendered non-hazardous by solidification.

10.3 Minimum Solidification Acceptance Criteria Minimum Solidification Acceptance criteria are listed below, but additional criteria may be added by the disposal site and shall be included in the verification process:

10.3.1 FSL Criteria: Liquid wastes, or wastes containing liquid, shall be converted into a form that contains as little free standing and non-corrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 1% of the volume of the waste when the waste is in a disposal container designed to ensure stability, or 0.5% of the volume of the waste for waste in a disposal container not designed to meet stability requirements and/or waste processed to meet waste form stability requirements independent of the disposal container.

10.3.2 Physical Criteria: the solidified product shall be a free-standing, non-friable and homogeneous monolith.

10.3.3 Chemical Criteria: The solidified product of a Mixed Waste shall be rendered non-hazardous.

10.4 Representative Waste Sample A representative sample of the waste to be solidified shall be obtained by a process equivalent to the following as outlined in approved procedures for the applicable waste form and solidification media.

10.4.1 A representative waste sample shall include the characteristics of the waste that are critical to the solidification process being used 10.4.2 The contents of the container to be sampled shall be adequately mixed to achieve a homogeneous mixture 10.4.3 During the mixing and sampling period, the vessel shall not be placed in a transfer mode nor shall additional waste be received 10.4.4 Vessel level readings or input isolation shall be documented at the time of mixing initiation, sampling, and process initiation 10.4.5 Recirculation or mixing time shall be uninterrupted until sample collection CORP PCP Page 22 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 10.5 Bench Scale Test Solidification The boundary conditions are demonstrated by producing a solidified product during the Bench Scale Test that meets the minimum acceptance criteria described above. The test-proven boundary conditions will then be used to perform a full scale solidification that meets these same criteria. A Bench Scale Test Solidification shall be performed using a process similar to the following:

10.5.1 Frequency of Bench Scale Testing (Ref: Solid Waste SLC Surveillance Requirement) 10.5.1.1 The minimum frequency for performing Bench Scale Testing shall be as described in the Solid Waste SLC Surveillance requirement: The PCP shall be used to verify at least one test specimen from at least every tenth batch of each type of waste to be solidified for disposal at a 10CFR61 disposal site.

10.5.1.2 Where variability of critical waste parameters is known to be great or is uncertain, the following more conservative frequency shall be followed:

A. An initial Bench Scale Test solidification shall be performed prior to the full-scale solidification of each distinct batch of waste.

B. Where multiple solidifications of the same batch of waste occur after the successful initial Bench Scale Test, a Bench Scale Test shall be repeated at a frequency of no less than once per ten solidifications of that batch.

10.5.2 Establish process parameters and boundary conditions Process parameters and boundary conditions (or a method by-which to establish them) are usually given in vendor procedures which have already been certified for a given radioactive waste type. Process parameters should include any of the following that are applicable:

Waste form

Waste to solidification agent ratio

Amount of each solidification additive

Waste pH

Waste boron concentration

Waste density CORP PCP Page 23 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

Waste oil content

Mixer speed

Mixing time

Curing time

Specific activity

Pre-solidification hazardous waste characterization 10.5.3 Mixed Waste (additional requirements) 10.5.3.1 Vendor procedures used to solidify Mixed Waste shall be certified to be applicable to the specific waste stream being processed.

10.5.3.2 For Mixed Waste solidified by Duke Energy personnel, a Nuclear Generation procedure shall be developed based on an approved demonstrated process for each specific Mixed Waste stream.

10.5.4 Bench Scale Test Solidification product verification:

Physical testing and laboratory analysis, as described below, shall be utilized to determine if the Bench Scale Test solidified waste sample is a free-standing monolith with the % FSL volume within the acceptance criteria. This testing shall consist of:

10.5.4.1 The % by volume FSL criteria shall be verified by visual inspection or by physical measurement of any visible FSL 10.5.4.2 Physical testing to determine if a solidified waste is a free-standing monolith shall consist of:

A. Visual inspection AND B. Probe penetration testing to demonstrate non-friability 10.5.5 Mixed Waste Bench Scale Test Solidification product verification:

10.5.5.1 In addition to the physical tests listed above, laboratory analysis using approved EPA methods shall be performed to determine if a solidified Mixed Waste has been rendered non-hazardous.

10.5.5.2 Note that the solidified Mixed Waste need only be analyzed for those hazardous properties it exhibited prior to solidification or those that may have been introduced by the solidification process.

CORP PCP Page 24 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 10.5.6 Bench Scale Test Solidification failures (Ref: SLC Remedial Action Requirements) 10.5.6.1 Full Scale Solidification for disposal shall not be performed unless the Bench Scale Test Solidification is acceptable.

10.5.6.2 If any Bench Scale Test Solidification fails to meet the acceptance criteria set forth in section 10.3 Minimum Solidification Acceptance Criteria, the following actions shall be taken prior to the next solidification for disposal at a 10CFR61 disposal site:

A. Suspend solidification of the batch under test B. Obtain additional representative samples from the current waste batch of waste C. Perform additional test solidifications until alternate solidification parameters are determined and solidification verified D. Modify the PCP and or procedures as required to assure successful solidification of subsequent batches of waste 10.5.6.3 If the initial Bench Scale Test solidification fails SLC Remedial Actions requires that:

A. Representative test sampling solidifications from each consecutive batch of the same type of waste shall be performed using alternate solidification parameters until at least 3 consecutive initial test solidifications meet the minimum solidification acceptance criteria.

B. Modify the PCP and or procedures as required to assure successful solidification of subsequent batches of waste.

10.5.7 Bench Scale Test Solidification results performed onsite shall be submitted to Station Chemistry for review and authorization prior to initiating full scale waste solidification including the following:

10.5.7.1 Sample analysis 10.5.7.2 Test solidification results CORP PCP Page 25 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 10.5.7.3 Prescribed boundary conditions 10.5.7.4 Specific activity to ensure packaging limits of the disposal container will not be exceeded 10.5.8 Bench Scale Test Solidification results performed by an offsite processor shall be handled as follows:

10.5.8.1 Bench Scale Test Solidification failures shall be communicated to the originating site Chemistry supervision prior to performing full scale solidification for disposal.

10.5.8.2 Successful Bench Scale Test Solidification documentation shall be sent to the originating site in the completed PCP documentation for record retention.

10.6 Full Scale Solidification Actual full scale solidification shall be performed using approved procedures which ensure that the solidification process is operated within the established boundary conditions.

10.6.1 Full scale solidification procedures should contain stepwise instructions with documentation of completion for the following activities:

10.6.1.1 The Bench Scale Test Solidification process described above 10.6.1.2 The full scale formulation of waste additives including mixing requirements 10.6.1.3 The verification described below 10.6.1.4 Documentation of verification that PCP requirements were met 10.6.2 Full Scale Solidification performed in drums shall use new drums (not reconditioned) that meet the requirements of 49CFR.

10.7 Product Verification of Full Scale Solidification Product verification shall be performed to ensure the acceptance criteria have been met.

10.7.1 Documentation that the Process Control Program was followed and successfully completed may serve as verification of the final solidified product.

CORP PCP Page 26 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 10.7.2 Non PCP verification (Ref: SLC Remedial Action Requirements)

If the Process Control Program was not followed or if any unusual condition existed during processing that invalidates the PCP boundary conditions the following actions shall be taken:

10.7.2.1 Reprocess the waste in accordance with PCP requirements, OR 10.7.2.2 Physical testing may be used to verify that disposal site requirements are met:

A. Visual inspection for FSL on top of the waste B. Probe penetration testing and C. Puncturing the bottom of the vessel D. Visual inspection shall be utilized to determine if a solidified waste is a free-standing monolith.

10.7.2.3 Mixed Waste Additional Testing A. In addition to the above physical testing, laboratory analysis using approved EPA methods shall be performed to determine if a solidified Mixed Waste has been rendered non-hazardous.

B. The solidified Mixed Waste need only be analyzed for those hazardous properties it exhibited prior to solidification or those that may have been introduced by the solidification process.

10.7.2.4 Make programmatic changes as necessary to address any problems identified.

10.7.3 Full scale solidification does not meet the PCP Acceptance Criteria requirements or physical tests described above.

Any full scale solidification vessel that does not pass the verification requirements described above shall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product (Ref: SLC Remedial Action Requirements). Prior to next shipment for disposal of solidified wastes:

CORP PCP Page 27 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 10.7.3.1 Suspend shipments of the defectively packaged/inadequately processed solid radioactive wastes from the site AND 10.7.3.2 Initiate action to correct the PCP, procedures, or solid waste equipment as necessary to prevent recurrence 10.7.4 Mixed Waste Pre-approval:

Any solidified Mixed Waste that passes these tests shall not be shipped to a burial site until that burial site has given approval.

10.8 Inoperable Equipment (SLC Remedial Action Requirements)

With the waste solidification equipment incapable of meeting PCP requirements or not in service:

10.8.1 Restore the equipment to operable status, OR 10.8.2 Provide alternative capability as necessary to process wastes per this PCP 10.9 Solidification Document Retention Solidification records shall be maintained on each vessel of solidified waste as described in section 7.4 of the Corporate PCP and section 5.5 of APPENDIX F Administration of the PCP and Support Documents. All of the following records that are applicable should be included:

10.9.1 Representative sampling documentation 10.9.2 Sample analysis results 10.9.3 Test solidification results and prescribed boundary conditions.

10.9.4 Documentation of Acceptance Criteria verification from completed Nuclear Generation or vendor solidification procedures such as:

10.9.4.1 FSL verification 10.9.4.2 Free-standing monolith verification 10.9.4.3 If applicable, verification that solidified Mixed Waste is non-hazardous.

CORP PCP Page 28 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

11. PCP DEWATERING PROCESS DESCRIPTION The methods used for removal of liquid from wet wastes for final disposal shall comply with the specific requirements of the disposal site at which the waste is being disposed. Dewatering of wet wastes shall be performed in a manner equivalent to the process described below using approved procedures in a controlled and quality fashion which ensures that all applicable Selected Licensee Commitments and disposal site criteria are met. Procedures used to direct dewatering shall include enough detail to implement a process that addresses the applicable requirements described below.

11.1 Dewatering Mechanical Filters (e.g., cartridge, bag, membrane)

The guidance below addresses dewatering methods and PCP issues unique to disposal of mechanical filters.

11.1.1 Dewatering is required so subsequent accumulation of free standing liquid in the disposal container is not likely to approach disposal site limits.

11.1.2 Wet spent mechanical filters can be dewatered by allowing liquid to drain freely from the filter, blowing the filter down with air, compacting the filter, etc.

11.1.3 The method of dewatering shall be in accordance with a previously defined, evaluated, and documented process.

11.1.4 The parameters of the process, referred to as boundary conditions, shall be defined and used to ensure quality in the process, which in turn serves to ensure an acceptable characteristic of the waste. An example of a boundary condition is the specified period of time for which a mechanical filter shall be allowed to drain freely to ensure FSL will be less than disposal requirements.

NOTE: Removal of free standing liquid from a disposal container shall not be considered the PCP method for dewatering mechanical filters.

11.1.5 Filters placed in a filter disposal container designed for removal of FSL shall meet the PCP boundary conditions for dewatering independent of removal of FSL from the container. If PCP boundary conditions are met after placing the filter in the disposal container, the container shall be unwatered to ensure FSL meets disposal requirements.

11.1.5.1 If the PCP boundary conditions have been met prior to placing the filters in the disposal container, dewatering the container to remove incidental FSL is optional.

CORP PCP Page 29 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 11.1.5.2 Case-by case circumstances, such as the following, should be considered in the determining the appropriateness of performing additional filter disposal container dewatering:

The time interval between removal of the filters from wet service and placement into the disposal container

Size of the disposal container relative to the moisture content in the filters

The number of filters

The variety of filter types in a single container

The environmental conditions of filter staging and interim storage 11.1.6 Use of absorbent package material in mechanical filter disposal containers is subject to the requirements of the disposal site acceptance criteria.

11.2 Dewatering Slurries The guidance below addresses dewatering issues associated with slurry wastes.

11.2.1 Dewatering of slurried wet wastes (e.g., resin, carbon, Zeolite, filter precoat, filter backwash solids) removes the loosely bound interstitial liquid from solids such that the disposal container meets applicable regulatory and burial site FSL criteria for disposal.

11.2.2 Wet spent process media dewatering shall be performed using processes, containers and procedures that have met the requirements described in section 9, Process Control Program Requirements.

11.2.3 Typical container dewatering processes use a vacuum pump that takes suction from the vessel through a filter system in the vessel. The water is returned to a station liquid radwaste system and the waste solids are retained in the vessel by the container filter(s).

CORP PCP Page 30 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 11.3 Additional Conservatism in Slurry Dewatering Procedures to Address Variation from the Topical Report (PIP O-03-0624, M-03-2515, C-03-3385)

Dewatering processes based on Topical Reports are applied to actual conditions that can vary from the conditions of the Topical Report testing. The results of a Root Cause investigation at ONS (O-03-0624) identified several issues and resolutions that should be incorporated into future revisions of dewatering implementing procedures. Vendor procedures applicable to the technologies and processes used by Duke Energy in implementing the PCP provide the basis for minimal requirements in PCP implementing procedures. In addition the guidelines below have been added based on the Root Cause findings at ONS:

11.3.1 All PCP dewatering procedures shall include flexibility/ guidance for Chemistry to add conservatism to the dewatering process if waste content and/

or process conditions are atypical in a non conservative manner relative to the testing performed for the Topical report (e.g., greater than normal non media solids, dewatering boundary parameters are not easily met, higher than normal volume of FSL is collected during the final dewatering cycle, etc.)

11.3.1.1 Additional conservatism can include but is not limited to the following examples:

A. Additional dewatering cycles B. Additional settling time between pumping periods C. Additional processing by an approved offsite vendor to verify FSL prior to disposal 11.3.2 Guidance for dewatering all liners using a PCP for direct disposal at Barnwell (PIP O-03-0624 CAPR) 11.3.2.1 Require liner functional testing prior to filling liner with waste to ensure there are no leaks in the liner dewatering system. This testing should include:

A. filling the liner with water B. testing each level of the liner dewatering laterals using the dewatering procedure to unwater the liner, C. verifying that vacuum is not broken prior to exposing the filters for each set of laterals as described in the procedure CORP PCP Page 31 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 11.3.2.2 Ensure ambient temperature guidance for dewatering will preclude localized freezing conditions during the dewatering sequence. After most of the water is removed during the first dewatering cycle, subsequent cycles pull air through the interstitial spaces of the media and the loss of heat due to evaporation can depress the temperature on surface of the media and dewatering filters below ambient temperature.

A. Follow guidance in the vendor documentation for the process in use B. If no other guidance is provided, dewatering should not be performed unless ambient temperature of air entering the liner is 40 degrees Fahrenheit or higher (FO-OP-022) 11.3.2.3 Ensure final water collection sample point is representative (e.g.,

as close as possible to the pump discharge) 11.3.3 Mixed Media: Additional guidance for dewatering liners containing Mixed Media with significant non media solids using a PCP for direct disposal at Barnwell (PIP O-03-0624 CAPR)

The guidance below applies to liners containing combinations of different media with significant quantities of non media solids (e.g., spent zeolite, carbon, resin, etc. containing filtered particulate) 11.3.3.1 Require Ecodex filter system in all liners that contain mixed media with significant non-media solids 11.3.3.2 Clearly specify media loading sequence if media is not homogeneously mixed to minimize potential blinding of the lowest level of filters. (e.g., for layered media, largest diameter media in the bottom of the liner) 11.3.3.3 Require additional dewatering Cycles (e.g. minimum of 3 additional cycles after the acceptance criteria in the vendor procedure have been met) 11.3.3.4 Require longer settling periods during the additional dewatering cycles (e.g., 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months instead of the 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months required in the vendor procedure)

CORP PCP Page 32 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 11.3.3.5 Require dewatering through bottom 2 laterals during liner filling (Topical Report requirement to establish proper media compaction and capillary conditions) 11.4 Dewatering Process Requirements The procedures directing dewatering processes shall address all of the following activities that apply to the specific waste type being dewatered.

11.4.1 Waste Characterization Dewatering procedures shall describe how each type of waste is characterized.

The characterization information determines what disposal and container requirements apply and may also be utilized to determine shipment packaging requirements (e.g., shielding). Much of the required information for slurried waste is obtained using a representative sample of the waste media.

Characterization requires the following types of information:

11.4.1.1 Radioactivity content A. To determine 10CFR61 waste class, form and container requirements B. To provide waste content characterization for packaging and disposal requirements 11.4.1.2 Waste compatibility with disposal container and process method A. Chemical Compatibility: Process knowledge can be applied to determine chemical compatibility with the container.

B. Hazardous Characteristics: Process knowledge can be applied to determine if the waste is a Mixed Waste.

C. If process knowledge is uncertain due to a potential input of incompatible or hazardous materials, then chemical analysis using an approved method shall be performed to determine chemical compatibility or hazardous characteristics.

11.4.2 PCP process parameters shall be identified in implementing procedures.

Typical parameters are:

11.4.2.1 Waste form CORP PCP Page 33 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM 11.4.2.2 Settling time 11.4.2.3 Drain (or pump) time 11.4.2.4 Drying time 11.4.2.5 Specific activity 11.4.3 PCP boundary conditions shall be established for applicable process parameters to verify FSL threshold limits are met.

11.4.4 Sample analysis results and boundary conditions shall be reviewed by the appropriate knowledgeable individual responsible for the dewatering process.

11.4.5 Actual dewatering shall be performed using approved procedures that ensure the process is performed within the established boundary conditions.

11.5 Product Verification The amount of free-standing liquid shall be verified to be within disposal site criteria for each container of dewatered waste prior to disposal (e.g., 10CFR61 requires that each container shall have less than 0.5% free-standing liquids by waste volume or less than 1.0% free-standing liquid if a High Integrity Container (HIC) is used).

11.5.1 PCP Verification Verification may be accomplished by documenting that the Process Control Program was followed.

11.5.2 Non PCP Verification (SLC Remedial Action Requirements, PIP O-02-7159)

If the PCP was not followed or a non process control method is used:

11.5.2.1 Reprocess the waste in accordance with PCP requirements using an onsite process or approved offsite vendor process, OR 11.5.2.2 Use physical testing of the final dewatered product container to verify that the free-standing liquid content meets disposal site requirements. Physical testing shall be based on a process approved by the appropriate regulator, disposal site operator, or applicable disposal site requirements document.

A. A disposal site may define a product verification testing method approved for use in lieu of a process control method.

CORP PCP Page 34 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM

1. That approved product verification process may be used for that category of disposal on a case-by-case basis, (e.g., bulk waste non-containerized disposal).

2. Any such product verification process shall be approved by the Nuclear GO Chemistry and Radiation Protection groups.

B. Physical testing may include actual measurement of the volume of FSL in each container as follows:

1. Puncture the bottom of the dewatered disposal container and collect the FSL.

2. Measure the collected FSL and verify it meets the disposal site requirements.

3. Punctured containers shall be repaired in order to meet all applicable regulatory and disposal site requirements prior to disposal.

11.5.2.3 Documentation of the method used for product verification and the results shall be included in the dewatering record as described in the Dewatering Record Retention section below.

11.5.2.4 Make programmatic changes as necessary to address any problems identified.

11.5.3 Off-normal process or container conditions If any off-normal condition existed during processing that could invalidate boundary conditions the following guidance applies:

11.5.3.1 Reprocess the waste in accordance with PCP requirements using an onsite process or approved offsite vendor process, OR 11.5.3.2 Contact the process vendor for technical guidance. The vendor may be able to provide a contingency process to meet disposal requirements. The following examples may be considered:

A. If a dewatering lateral in a container fails to meet the process variable boundary requirement in the dewatering procedure, the vendor may be able to provide procedural guidance to successfully complete the dewatering CORP PCP Page 35 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM B. If a contingency dewatering process cannot be successfully completed refer to the dewatering failures guidance below 11.5.3.3 Make programmatic changes as necessary to address any problems identified 11.5.4 Dewatering verification failures (SLC Remedial Action Requirements) 11.5.4.1 Any dewatered vessel failing the product verification requirements shall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product.

11.5.4.2 If applicable regulatory requirements for a dewatered waste container are not satisfied, the following actions shall be taken prior to next shipment of dewatered wastes for disposal:

A. Suspend shipments of defectively packaged/inadequately processed radioactive wastes from the site AND B. Initiate action to correct the PCP, procedures, or solid waste equipment as necessary to prevent recurrence.

C. If the process is a vendor process, obtain technical guidance from the vendor in resolving the problem D. The reprocessing of a failed dewatering may be accomplished using an onsite process or approved offsite vendor process 11.6 Inoperable Equipment (SLC Remedial Action Requirements)

With the waste dewatering equipment incapable of meeting PCP requirements or not in service:

11.6.1 Restore the equipment to operable status, OR 11.6.2 Provide alternative capability as necessary to process wastes per this PCP 11.7 Dewatering Document Retention Dewatering records shall be maintained on each vessel of dewatered waste as described in section 7.4 of the Corporate PCP and section 5.5 of APPENDIX F Administration of CORP PCP Page 36 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM the PCP and Support Documents. All of the following records that are applicable should be included:

11.7.1 Sample analysis and boundary conditions 11.7.2 Dewatering record from completed Nuclear Generation or vendor dewatering procedures 11.7.3 Free-standing liquid verification CORP PCP Page 37 of 37 Rev.15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM REVISION NUMBER ISSUE DATE 15 _9/16/10__

Reviews and Approvals Documented in PIP Revision 15: G-09-00901 Minor Change: O-12-12544 Prepared by/ Date: __DL Vaught/ 12/12/12___ Review by/ Date: GT Johnson/ 12/13/12_

NGO Chemistry NGO Radiation Protection OCONEE REVIEW AND APPROVALS MC Reviewed By/ Date: MC Reviewed By/ Date:

__Jac Cashin/ 1/21/13__ _Eric Lampe / 3/19/13 ____

ONS Radwaste Chemistry ONS Radiation Protection Rev Approved By/ Date

__Carrie Dunton /_6/29/10______

ONS Chemistry Manager Approved By/ Date__T P Gillespie/ 8/16/10___

ONS Station Manager Issued By: __ Larry A Wilson/ _3/20/13____________

Supervising Scientist, Nuclear Chemistry Minor Changes Issued: __3/21/13_____

NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM

1. PURPOSE The Oconee Nuclear Station (ONS) Process Control Program (PCP) lists the documents used to implement all applicable requirements of the Corporate Process Control Program for each container of solidified radioactive or mixed waste and dewatered radioactive waste shipped for burial at a licensed burial facility. This PCP is applicable only to the solidification or dewatering of liquid or wet solid radioactive waste.

2. COMPOSITION The ONS PCP consists of:

A title page documenting approval of changes to the ONS Process Control Program per Appendix E of the PCP Manual

A list of all the procedures used at ONS that implement the requirements of the Corporate Process Control Program

Oconee Nuclear Station diagrams, drawings or drawing numbers showing interfaces between ONS radwaste systems and solidification and dewatering equipment

Exceptions to the Corporate PCP section

3. IMPLEMENTING PROCEDURES 3.1 CP/0/A/5200/048 Resin Recovery System Operation 3.2 CP/0/A/5400/001 Radwaste HIC Dewatering and Operating Guidelines 3.3 SH/0/B/2004/002 Preparation and Shipment of Radioactive Wastes 3.4 CP/0/B/5200/054A, "LW Demineralizers Sluice and Reload and BFST Transfer" 3.5 CP/0/B/5200/073, "Resin Batch Tank Sluice Procedure" 3.6 HP/0/B/1006/012, "Handling Procedure for CNS High Integrity Containers" 3.7 CP/0/A/5400/013 "Radwaste Powdex Liner Dewatering & Operating Guidelines" ONS PCP Page 1 of 2 Rev. 15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM

4. DRAWING INDEX All system interfaces are shown on diagrams or described in the applicable station procedure.

5. EXCEPTIONS TO THE CORPORATE PCP SECTION None

6. SUPPORTING DOCUMENTS 6.1 LM/0/E005, Rev 003, "ONS Paint Filter Liquids Test" ONS PCP Page 2 of 2 Rev. 15 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM REVISION NUMBER ISSUE DATE 18 ___1/30/08__

Reviews and Approvals Documented in PIP Revision 18: G-06-00560 Minor Change: M-10-06651 Prepared by/ Date: DL Vaught/ 4/6/11 Review by/ Date: GT Johnson/ 4/6/11 _

NGO Chemistry NGO Radiation Protection McGUIRE REVIEW AND APPROVALS MC Reviewed By/ Date: MC Reviewed By/ Date:

____OM Reid/ _5/4/11____ __JR Litaker/ 4/6/11_

MNS Radwaste Chemistry MNS Radiation Protection Rev Approved By/ Date PA Hull/ _11/30/07 MNS Chemistry Manager Rev Approved By/ Date

______ RT Repko/ 12/2/07_______

MNS Station Manager MC Issued By: ___LA Wilson_ / _6/14/11______

Supervising Scientist, Nuclear Chemistry Minor Changes Issued: __6/15/11___

NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM

1. PURPOSE The McGuire Nuclear Station (MNS) Process Control Program (PCP) lists the documents used to implement all applicable requirements of the Corporate Process Control Program for each container of solidified radioactive or mixed waste and dewatered radioactive waste shipped for burial at a licensed burial facility. The PCP is applicable only to the solidification or dewatering of liquid or wet solid radioactive waste.

2. COMPOSITION The MNS PCP consists of:

A title page documenting approval of changes to the MNS Process Control Program per Appendix E of the PCP Manual

A list of all the procedures used at MNS that implement the requirements of the Corporate Process Control Program

McGuire Nuclear Station diagrams, drawings or drawing numbers showing interfaces between MNS radwaste systems and solidification and dewatering equipment

Exceptions to the Corporate PCP section

3. IMPLEMENTING PROCEDURES 3.1 CP/0/B/8600/011 Sampling Batching Tank and Resin Sample Preparation 3.2 SH/0/B/2004/002 Preparation and Shipment of Radioactive Waste 3.3 HP/0/B/1004/012 Utilization of Polyethylene High Integrity Containers 3.4 HP/0/B/1004/032 Procedure for Packaging Radioactive Filters 3.5 OP/0/A/6200/032 Solid Waste System Operation 3.6 OP/0/B/6200/064 Transfer and Dewatering of Media 3.7 OP/0/B/6200/083 WM Process Skid Demineralizers Sluice, Load, and Maintenance

4. DRAWING INDEX Plant Interfaces:

MNS PCP Page 1 of 2 Rev. 18 NEDL SDQA C

RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM 4.1 MC-1100-01.02 4.2 MCFD-1566-01.00 4.3 MCFD-1566-01.01 4.4 MCFD-1566-02.00 4.5 MCFD-1566-03.00 4.6 MCFD-1590-01.03 4.7 MCFD-2590-01.03 All system interfaces are shown on diagrams or described in the applicable station procedure.

5. EXCEPTIONS TO THE CORPORATE PCP SECTION None MNS PCP Page 2 of 2 Rev. 18 NEDL SDQA C