ONS-2015-043, Radioactive Waste Process Control Program Manual, Revision 15
ML15138A136 | |
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Site: | Oconee ![]() |
Issue date: | 01/28/2008 |
From: | Rochester D Duke Energy Carolinas |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
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ONS-2015-043 | |
Download: ML15138A136 (126) | |
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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).
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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:
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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.
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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.
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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)
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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.
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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).
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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.
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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:
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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.
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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.
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- 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
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- 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.
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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.
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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.
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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
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- 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.
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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.
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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:
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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.
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- 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.
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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).
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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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of the 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 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 16 __9/24/14____
Reviews and Approvals Documented in PIP Revision 16: G-14-00619 Prepared by/ Date: _D.L. Vaught / 5/27/14___ Review by/ Date: G.T. Johnson /_5/28/14_
NGO Chemistry NGO Radiation Protection OCONEE REVIEW AND APPROVALS Review By/ Date: Review By/ Date:
__J.D. Wald / _6/4/14_______ _S.L. Morgan / _6/24/14_ __
ONS Radwaste ONS Radiation Protection Approved By/ Date __S.S. Dalton /__7/2/14____
ONS Chemistry Manager Approved By/ Date _ J.G. Hrynda /_9/17/14____________
Nuclear AOM Shift Issued By: __ J.A. Mockridge 9/18/14 ______
Supervising Scientist, Nuclear Chemistry 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.
- 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 During the transfer of the Chemistry department operating programs to the Operations department, the PCP implementing procedures used by Chemistry Radwaste will be superseded by the new Operations procedures as the new procedure implementation requirements are completed. As each new procedure is implemented and the Chemistry operating procedure is no longer used it will be no longer available in NEDL. Both procedures are being listed for this revision in order to assure either may be used when needed by the site.
Chemistry Radwaste 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 ONS PCP Page 1 of 2 Rev. 16 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM 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 CP/0/A/5400/013 "Radwaste Powdex Liner Dewatering & Operating Guidelines" Operations Radwaste Procedures 3.7 OP/0/A/1104/072 Resin Recovery System 3.8 OP/0/A/1104/078 Radwaste HIC Dewatering & Operating Guidelines 3.9 OP/0/A/1104/070 Radwaste Powdex Liner Dewatering and Operating Guidelines 3.10 OP/0/A/1104/080 LW Demineralizers Sluice and Reload and BFST Transfer 3.11 OP/0/A/1104/082 Resin Batch Tank Sluice Radiation Protection Procedures (These are unaffected by the organization changes) 3.12 HP/0/B/1006/012 "Handling Procedure for CNS High Integrity Containers" 3.13 SH/0/B/2004/002 Preparation and Shipment of Radioactive Wastes
- 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. 16 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 8/28/14 19 Reviews and Approvals Documented in PIP Revision 19: G-14-00619 Prepared by/ Date: D.L. Vaught / 5/27/14______ Review by/ Date: G.T. Johnson / 5/29/14 _
NGO Chemistry NGO Radiation Protection McGUIRE REVIEW AND APPROVALS Reviewed By/ Date: Reviewed By/ Date:
O.M. Reid / 6/23/14 _ __J.R. Litaker / 6/2/14___
MNS Radwaste Chemistry MNS Radiation Protection Approved By/ Date: _J.C. Gabbert / 6/26/14__________
MNS Chemistry Manager Approved By/ Date: __ C.D. Cornwell / 6/27/14____________
Nuclear AOM Shift Issued By: ___ _J.A. Mockridge / 8/28/14_________
Supervising Scientist, Nuclear Chemistry 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.
- 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 During the transfer of the Chemistry department operating programs to the Operations department, the PCP implementing procedures used by Chemistry Radwaste will be superseded by the new Operations procedures as the new procedure implementation requirements are completed. As each new procedure is implemented and the Chemistry operating procedure is no longer used it will be no longer available in NEDL. Both procedures are being listed for this revision in order to assure either may be used when needed by the site.
3.1 CP/0/B/8600/011 Sampling Batching Tank and Resin Sample Preparation Chemistry Radwaste Operating Procedures 3.2 OP/0/A/6200/032 Solid Waste System Operation 3.3 OP/0/B/6200/064 Transfer and Dewatering of Media 3.4 OP/0/B/6200/083 WM Process Skid Demineralizers Sluice, Load, and Maintenance MNS PCP Page 1 of 2 Rev. 19 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM Operations Radwaste Procedures 3.6 OP/0/A/6200/532 Solid Waste System Operation 3.7 OP/0/B/6200/564 Transfer and Dewatering of Media 3.8 OP/0/B/6200/583 WM Process Skid Demineralizers Sluice, Load, and Maintenance Radiation Protection Procedures (These are unaffected by the organization changes) 3.9 SH/0/B/2004/002 Preparation and Shipment of Radioactive Waste 3.10 HP/0/B/1004/012 Utilization of Polyethylene High Integrity Containers 3.11 HP/0/B/1004/032 Procedure for Packaging Radioactive Filters
- 4. DRAWING INDEX Plant Interfaces:
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.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM REVISION NUMBER ISSUE DATE 13 1/15/15 Reviews and Approvals Documented in G-14-00619 Prepared by/ Date: DL Vaught/ 10/14/14_
NGO Chemistry Review by/ Date: R.C. Lemons / 11/24/14 Review by/ Date: L.A. Hammel / 11/6/14__
NGO Radiation Protection NGO Radiation Protection CATAWBA REVIEW AND APPROVALS Reviewed By/ Date: Reviewed By/ Date:
C.D. Williams/ 12/17/14_ D.L. Campbell/ 12/9/14 CNS Radwaste CNS Radiation Protection Approved By/ Date H.D. Cantrell/ 12/22/14__
CNS Chemistry Manager Approved By/ Date M.D. Heavner/ 1/7/15____________
Nuclear AOM Work Control Issued By: __ J.A. Mockridge / 1/15/15_____________
Supervising Scientist, Nuclear Chemistry NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM
- 1. PURPOSE The Catawba Nuclear Station (CNS) 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 disposal facility. The PCP is applicable only to the solidification or dewatering of liquid or wet solid radioactive waste.
- A title page documenting approval of changes to the CNS Process Control Program per Appendix E of the PCP Manual
- A list of all the procedures used at CNS that implement the requirements of the Corporate Process Control Program
- Catawba Nuclear Station diagrams, drawings or drawing numbers showing interfaces between CNS radwaste systems and solidification and dewatering equipment
- Exceptions to the Corporate PCP section
- 3. IMPLEMENTING PROCEDURES During the transfer of the Chemistry department operating programs to the Operations department, the PCP implementing procedures used by Chemistry Radwaste will be superseded by the new Operations procedures as the new procedure implementation requirements are completed. As each new procedure is implemented and the Chemistry Radwaste operating procedure is no longer used it will be no longer available in NEDL. Both procedures are being listed for this revision in order to assure either may be used when needed by the site.
Chemistry Radwaste Operating Procedures 3.1 OP/0/B/6500/111 Nuclear Solid Waste (WS) Disposal System (PIP C-04-2308) 3.2 OP/0/B/6500/046 Transferring and Dewatering Bead resin in WSF 3.3 OP/0/B/6500/069 Monitor Tank Building (MTB) Ion Exchange and Filtration Media Operations 3.4 OP/0/B/6500/082 Dewatering Secondary Contaminated Resin CNS PCP Page 1 of 2 Rev. 13 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM Operations Radwaste Procedures 3.5 OP/0/B/6500/122 "Transferring and Dewatering Bead Resin in WSB" 3.6 OP/0/B/6500/128 "MTB Resin Sluice to PST" 3.7 Op/0/B/6500/131 "Secondary Contaminated Resin Operations" 3.8 OP/0/B/6500/132 "MTB PST Spent Media Operations" 3.9 OP/0/B/6500/133 "MTB Resin Sluice to HIC" 3.10 OP/0/B/6500/148 "Spent Resin Storage Tank Operations" 3.11 OP/1/B/6500/071 "Transfer and Dewatering of Secondary Resin" 3.12 OP/2/B/6500/071 "Transfer and Dewatering of Secondary Resin" Radiation Protection Procedures (These are unaffected by the organization changes) 3.13 SH/0/B/2004/002 Preparation and Shipment of Radioactive Waste
- 4. DRAWING INDEX Plant Interfaces:
4.1 CN-1566-1.6 4.2 CN-1565-3.2 All system interfaces are shown on diagrams or described in the applicable station procedure.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D Rev. 3 APPROVED SUPPLIERS OF PCP SERVICES Prepared By/ Date: Reviewed By/ Date:
DL Vaught/ 11/27/12____ _GT Johnson/ 12/7/12__
NGO Radwaste Support NGO Radiation Protection Issued By/ Date: Approval Documented in PIP G-12-00188
_Larry A Wilson / _1/16/13____________
Supervising Scientist, Nuclear Chemistry NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES SUPPLIER QUALIFICATIONS
- 1. EVALUATION AND PREAPPROVAL The radwaste vendors listed in the qualified supplier table have met the following requirements:
1.1 They have obtained approval per the processor technical evaluation as outlined in Appendix G Waste Processor Checklist of the PCP Manual 1.2 They have been approved for incorporation into the Nuclear QA Approved Supplier Program
- 2. SERVICE CONTRACT REQUIREMENTS Radwaste vendors in the QA approved supplier program are required to meet the applicable quality requirements set forth in the purchase order governing their service contract.
Examples of such requirements are:
Provide radioactive waste processing and disposal (e.g., packaging, transportation, volume reduction, dewatering and/or solidification) activities for Duke Energy's nuclear stations in accordance with the requirements defined within this attachment and as applicable, the Supplier's Process Control Program (PCP) for providing radioactive waste processing activities.
2.1 SUPPLIER REQUIREMENTS:
2.1.1 Suppliers shall meet the applicable requirements of:
- 10 CFR 20 - Standards for Protection against Radiation
- 10 CFR part 71 - Packaging and Transportation of Radioactive Material
- 49 CFR Chapter I Subchapter C - Hazardous Materials Regulations
- 10 CFR Part 61 - 'Licensing Requirements for Land Disposal of Radioactive Waste' 2.1.2 Supplier shall satisfy applicable requirements of the certificates of compliance for High Integrity Containers (HICs) and shipping packages provided.
2.1.3 Provide controlled copies of current revisions of applicable procedures for handling and dewatering or solidifying approved HICs prior to their utilization by Duke Energy. These should be sent to Duke Energy 526 South Church St.
(Mail Code) EC07D Charlotte, NC 28202, Attention: Nuclear Chemistry Radwaste Support.
PCP APP D Page 1 of 4 Rev. 3 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES 2.1.4 PCP Services Only - Any failure of PCP test solidification and corrective measures taken shall be communicated to the customer site prior to performing the final full scale solidification.
2.1.5 PCP Services Only - Any failure of a dewatering PCP process and corrective measures taken shall be communicated to the customer site prior to disposal.
2.2 DOCUMENTATION
Documentation is required for Duke records for each waste container processed offsite using a PCP to meet 10CFR61disposal requirements.
2.2.1 PCP Solidification Services Only - In addition to the documentation specified on the purchase order, sSolidification PCP documentation shall be provided to the generating site radwaste shipping contact and shall include the verification of successful laboratory scale test solidification as required by the Duke Energy PCP.
2.22 All PCP Services Only - Copies of approved completed PCP procedures, documenting compliance with PCP requirements, shall be provided to the customer site prior to disposal of the final waste container for waste dewatered or solidified at the vendor's facility to meet 10CFR61 waste form requirements.
These procedures should document any problems or PCP failures and the corrective measures taken to meet the PCP requirements.
2.3 DUKE RECEIVING REQUIREMENTS PERFORMED BY THE SITE / GO SPONSOR:
Verify requirements identified in this attachment have been completed satisfactorily.
This requirement will be met when authorization for payment of the invoice by the sponsor has been performed.
PCP APP D Page 2 of 4 Rev. 3 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES QUALIFIED SUPPLIERS VENDOR SOLIDIFICATION DEWATERING MIXED WASTE COMMENTS NAME Energy Solidification Services - Dewatering Services - Duratek may be used to Envirostone solidification Solutions Mobile Cement Ref: Topical Report CNSI- process this type of waste by compound, manufactured by U.S.
(Duratek, Solidification System, DW-11118-01. solidification to render it Gypsum, has been approved by Chem- Ref: Topical Report non-hazardous as described Chem-Nuclear Systems, Inc.
Nuclear) CNSI-2 (4313-01354- Approved Media: in the Duke Energy (Energy Solutions (was Duratek))
01P-A). Corporate PCP. and Duke Energy for NOTE: During 1. granular media solidification of specific Class A the transition Approved waste streams:
from Duratek 2. bead ion exchange resin 1. All other solidification unstable wastes that are and from 1. boric acid evaporator requirements in this characteristic mixed wastes.
- 3. zeolite Process Control Program Chem-Nuclear concentrates vendor 4. activated carbon shall be met. This waste may be treated by in-documents 2. spent bead resin (course particle size, house personnel using this media retain a mixture 2. A description of the
- 3. spent powdered resin GAC 40) treatment process and in compliance with this Process of the names
- 5. pre-coat media: results of the analytical Control Program.
and for 4. filters purposes of the tests of the final waste, PCP manual 5. filter backwash slurry a. Ecodex' The media shall not contain more using the Toxicity will be treated 6. resin regenerative b. Powdex' than one percent oil by volume.
as equivalent Characteristic Leaching chemical wastes c. Epifloc' Procedure required by
- 7. sludges d. Solka -floc' and/or 40CFR261.24, shall be diatomaceous earth reviewed by Duke Energy and Chem-
- 6. Other media requires Nuclear Systems, Inc.
Energy Solutions (was prior to shipment.
Duratek) prior approval PCP APP D Page 3 of 4 Rev. 3 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES VENDOR PROCESS, REHYDRATE & PACKAGE COMMENTS NAME SPENT RESIN AND PROCESS MEDIA Studsvik Approved for Volume Reduction of Spent Resin The Studsvik Thor process residue was approved by SC DHEC and Process Media using the Steam Reformation for disposal at Barnwell, SC in a memo dated 10/13/98. The process. Process includes the rehydration of the approved product is a Steam Reformed dry product rendered Steam Reformed residue to render it non- non-dispersible by adding a water-based wetting agent. The dispersible for disposal in a HIC using the Studsvik rehydration is controlled by the Studsvik PCP that assures the PCP. The final package is approved for disposal at final product meets disposal site FSL requirements. Ref:
a 10CFR61 disposal site or for storage. Studsvik procedure OP-011: Residue Packaging PCP G-04-00113 Documents the review and approval of the Studsvik Processing Facility, LLC. (Ref: Radioactive Waste Process Control Program (PCP) Manual requirements)
Waste WMG is approved for use of the Filter Shredding G-12-00188 Documents the review and approval of the offsite Management and Solidification Processing with their PCP for radwaste processor, Waste Management Group (WMG), as a Group the Cement Solidification of Shredded Filters and QA Supplier using their PCP for use by Duke Nuclear sites.
packaging of Duke Energy LLW for disposal at a (Ref: Radioactive Waste Process Control Program (PCP)
(WMG) 10CFR61 disposal site or for storage. Manual requirements.
PCP APP D Page 4 of 4 Rev. 3 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX E PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS PCP APP E Rev. 3 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX E PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS REVISION NUMBER ISSUE DATE 3 10/10/14 Reviews and Approvals Documented in PIP Revision 3: G-14-00619 REVIEW AND APPROVALS Prepared by/ Date: D.L. Vaught / 9/8/14______
NGO Chemistry Review by/ Date: R.C. Lemons / 10/1/14 _
NGO Radiation Protection Review by/ Date: L.A. Hammel / 10/2/14 _
NGO Radiation Protection Issued By: ___ _J.A. Mockridge / 10/9/14_________
Supervising Scientist, Nuclear Chemistry PCP APP E Rev. 3 NEDL SDQA C
Table E-1: Revision Review and Approval Technical PCP Manual Section Title Approvals Author & Review Nuclear CFAM Chemistry NGO Chemistry Author Manager, Nuclear Fleet Scientific Services CORPORATE PROCESS CONTROL PROGRAM NGO Radiation Protection Supervising Scientist, Nuclear Chemistry Station Radwaste Staff DEC Station Managers Station Radiation Protection DEC Nuclear AOM Shift DEC Sites Chemistry Managers NGO Chemistry Author Supervising Scientist, Nuclear Chemistry NGO Radiation Protection Staff APPENDIX A: OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM Nuclear AOM Shift ONS Radwaste ONS Chemistry Manager ONS Radiation Protection NGO Chemistry Author Supervising Scientist, Nuclear Chemistry APPENDIX B: McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM NGO Radiation Protection Nuclear AOM Shift MNS Radwaste MNS Chemistry Manager MNS Radiation Protection NGO Chemistry Author Supervising Scientist, Nuclear Chemistry APPENDIX C: CATAWBA NUCLEAR STATIONPROCESS CONTROL PROGRAM NGO Radiation Protection Nuclear AOM Shift CNS Radwaste CNS Chemistry Manager CNS Radiation Protection NGO Chemistry Author APPENDIX D: Approved Suppliers of PCP Services Supervising Scientist, Nuclear Chemistry NGO Radiation Protection NGO Chemistry Author APPENDIX E: PCP Manual Review & Approval Requirements Supervising Scientist, Nuclear Chemistry NGO Radiation Protection NGO Chemistry Author APPENDIX F: Administration of the PCP & Support Documents Supervising Scientist, Nuclear Chemistry NGO Radiation Protection NGO Radiation Protection APPENDIX G: Waste Processor Checklist N/A NGO Chemistry Author APPENDIX H: Revision Summary - Licensee Initiated Changes NGO Chemistry Author N/A PCP APP E Page 1 of 2 Rev. 3 NEDL SDQA C
Table E-2: Minor Change Review and Approval PCP Manual Section Title Technical Approvals Author & Review NGO Chemistry Author NGO Radiation Protection CORPORATE PROCESS CONTROL PROGRAM Supervising Scientist, Nuclear Chemistry Station Radwaste Staff Station Radiation Protection NGO Chemistry Author NGO Radiation Protection Staff ONS Radwaste Supervising Scientist, Nuclear Chemistry APPENDIX A: OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM ONS Radiation Protection NGO Chemistry Author NGO Radiation Protection MNS Radwaste Supervising Scientist, Nuclear Chemistry APPENDIX B: McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM MNS Radiation Protection NGO Chemistry Author NGO Radiation Protection CNS Radwaste Supervising Scientist, Nuclear Chemistry APPENDIX C: CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM CNS Radiation Protection NGO Chemistry Author NGO Radiation Protection Supervising Scientist, Nuclear Chemistry APPENDIX D: Approved Suppliers of PCP Services NGO Chemistry Author NGO Radiation Protection Supervising Scientist, Nuclear Chemistry APPENDIX E: PCP Manual Review & Approval Requirements NGO Chemistry Author NGO Radiation Protection Supervising Scientist, Nuclear Chemistry APPENDIX F: Administration of the PCP & Support Documents NGO Radiation Protection Supervising Scientist, Nuclear Chemistry APPENDIX G: Waste Processor Checklist NGO Chemistry Author N/A APPENDIX H: Revision Summary - Licensee Initiated Changes NGO Chemistry Author PCP APP E Page 2 of 2 Rev. 3 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS REVISION NUMBER ISSUE DATE 2
2/26/09 Reviews and Approvals Documented in PIP C-08-05953 Prepared by/ Date: _DL Vaught/ 1/28/09 Review by/ Date: GT Johnson/2/10/09 NGO Radwaste Staff NGO Radiation Protection CATAWBA MCGUIRE OCONEE Approved By/Date Approved By/Date Approved By/Date RM Wallace/ 2/2/09 OM Reid / 2/6/09__ JA Cashin/ 2/4/09 Radwaste Chemistry Radwaste Chemistry Radwaste Chemistry Issued By: ___DP Rochester/ 2/18/09_______
Technical Manager, Nuclear Chemistry
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS TABLE OF CONTENTS
- 1. PURPOSE ...................................................................................................................................... 1
- 2. REFERENCES .............................................................................................................................. 1 2.1 Duke Energy Corporation Quality Assurance Program Topical Report ............................... 1 2.2 Nuclear Policy Manual Chapter 2 .......................................................................................... 1 2.3 Nuclear System Directive (NSD) 100 Instructions for Administrative Procedures ........... 1 2.4 NSD 703 Administrative Instructions for Station Procedures ........................................... 1 2.5 NSD 704 Technical Procedure Use and Adherence ........................................................... 1 2.6 NSD 209 10 CFR 50.59 Evaluations ................................................................................. 1 2.7 NSD 319 Vendor Technical Information (VTI) Program .................................................. 1 2.8 NSD 702 Document Management ..................................................................................... 1 2.9 NSD 800 Software and Data Quality Assurance................................................................ 1 2.10 NSD 301 Nuclear Station Modifications............................................................................ 1 2.11 Corporate Process Control Program ...................................................................................... 1 2.12 Chapter 16 FSAR Selected Licensing Commitments ........................................................ 1 2.13 Procedure Writer's Manual .................................................................................................... 1
- 3. DEFINITIONS AND DESCRIPTIONS ..................................................................................... 2 3.1 Safety Analysis Report (SAR) ............................................................................................... 2 3.2 Selected Licensing Commitments (SLC)............................................................................... 2 3.3 10CFR Part 61 Licensing Requirements for Land Disposal of Radioactive Waste........... 2 3.4 Approved Radwaste Vendor/ QA Approved Supplier........................................................... 2 3.5 Radwaste Vendor Document ................................................................................................. 3 PCP APP F i Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS
- 4. RESPONSIBILITIES FOR PCP RELATED DOCUMENTATION....................................... 3 4.1 Nuclear General Office (NGO) Chemistry (Nuclear Chemistry) .......................................... 3 4.2 Station Chemistry................................................................................................................... 3 4.3 NGO Radiation Protection (RP) ............................................................................................ 4
- 5. PROCEDURE ............................................................................................................................... 4 5.1 PCP Manual Revision and Review ........................................................................................ 4 5.2 PCP Manual Revision Record Retention Requirements........................................................ 6 5.3 PCP Manual Revision Publication Process............................................................................ 6 5.4 Administration of Nuclear Generation Procedures for Implementing PCP Activities .......... 6 5.5 Retention Requirements for PCP Implementing Procedures ................................................. 7 5.6 Use of Vendor Procedures in Chemistry Procedures ............................................................. 8 5.7 Exclusion of Vendor Procedures from NSD 228 Applicability Determination ................. 9 5.8 Chemistry Control of PCP Related Vendor Documents ...................................................... 10
- 6. ENCLOSURES ........................................................................................................................... 10 6.1 PCP Manual Revision Publication Process.......................................................................... 11 6.2 Chemistry Distribution of Radwaste Vendor Documents ................................................... 17 6.3 NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry ............................................................................................................................. 20 PCP APP F ii Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS
- 1. PURPOSE This document describes the administrative process for the Radioactive Waste Process Control Program (PCP) Manual and its supporting documents. These include but are not limited to documents used to accomplish the requirements of the PCP. (e.g., nuclear station implementing procedures, Radwaste vendor documents, etc.) It is intended to facilitate compliance with applicable Nuclear Generation Department (NGD) administrative procedures, Nuclear System Directives (NSD) and provide details of the process that are not described in those documents. This document also contains a description of the Electronic publication processes for the PCP and the vendor documents used to implement the PCP. It is referenced in the SDQA plan for the PCP Manual.
- 2. REFERENCES 2.1 Duke Energy Corporation Quality Assurance Program Topical Report 2.2 Nuclear Policy Manual Chapter 2 2.3 Nuclear System Directive (NSD) 100 Instructions for Administrative Procedures 2.4 NSD 703 Administrative Instructions for Station Procedures 2.5 NSD 704 Technical Procedure Use and Adherence 2.6 NSD 209 10 CFR 50.59 Evaluations 2.7 NSD 319 Vendor Technical Information (VTI) Program 2.8 NSD 702 Document Management 2.9 NSD 800 Software and Data Quality Assurance 2.10 NSD 301 Nuclear Station Modifications 2.11 Corporate Process Control Program 2.12 Chapter 16 FSAR Selected Licensing Commitments 2.13 Procedure Writer's Manual PCP APP F 1 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS
- 3. DEFINITIONS AND DESCRIPTIONS 3.1 Safety Analysis Report (SAR)
The stations technical specifications, updated final safety analysis report, licensee commitments, safety evaluation reports and the facility operating license.
3.2 Selected Licensing Commitments (SLC)
Commitments to control important plant equipment and operating conditions not controlled elsewhere. Operational commitments which are to be removed from existing station Technical Specifications (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 station's SERs, LERs, violation responses, generic letter and bulletin responses, submittal documents and other Duke letters to the NRC.
3.3 10CFR Part 61 Licensing Requirements for Land Disposal of Radioactive Waste The applicable portion of 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.
3.4 Approved Radwaste Vendor/ QA Approved Supplier Vendors that provide dewatering or solidification processes shall be evaluated against Duke Energy PCP requirements for approval. Approved vendors are incorporated into the Duke Energy QA Approved Supplier Program as described in Corporate PCP section of the PCP Manual. Vendors offer the following kinds of services and products:
3.4.1 Turnkey onsite service contracts including their mobile equipment and operators for the equipment 3.4.2 Offsite intermediate processing of radwaste including packaging, shipping and final disposal at a licensed disposal site or return for disposition by the customer 3.4.3 Disposal containers and controlled copies of the associated documents and procedures for dewatering the containers to PCP requirements PCP APP F 2 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 3.5 Radwaste Vendor Document A document provided by a vendor whose process has been approved for PCP processing. In order to implement the requirements of the PCP, Nuclear Generation operating procedures are developed that contain the applicable requirements described in the PCP manual. When the dewatering or solidification process used is based on a vendor developed process, or using vendor provided containers/components they are required to provide two types of documentation:
3.5.1 Documents that were used to evaluate the vendors program compliance with NRC, State, disposal site and Duke Energy PCP requirements in order to approve them for PCP services AND 3.5.2 Controlled copies of operating procedures for the vendors dewatering or solidification process that are used to develop and maintain the PCP implementing procedures at each of the sites
- 4. RESPONSIBILITIES FOR PCP RELATED DOCUMENTATION 4.1 Nuclear General Office (NGO) Chemistry (Nuclear Chemistry) 4.1.1 Radwaste Support of NGO Chemistry (NGO Radwaste) is responsible for administration of the PCP and its supporting documents 4.1.2 NGO Radwaste also manages and distributes the vendor documents used by site Chemistry to implement the PCP.
4.2 Station Chemistry 4.2.1 Station Radwaste Chemistry approves this section of the PCP Manual.
4.2.2 The assigned staff and responsible Chemistry General Supervisor are responsible for ensuring that the site PCP related documents are properly updated, maintained and used to meet the requirements of this section of the PCP Manual.
4.2.3 Members of Chemistry Management and Staff are responsible for ensuring that all Chemistry personnel properly use PCP related documents as described in this document.
PCP APP F 3 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 4.2.4 Each qualified member of the Chemistry group is expected to verify and use the most current and properly reviewed documents to perform PCP activities.
4.3 NGO Radiation Protection (RP) 4.3.1 NGO RP is responsible for maintaining and distributing current vendor documents used by site RP Radioactive Materials Control (RMC) to manage the site radioactive materials handling, packaging and shipping programs.
4.3.2 NGO RP reviews this document and ensures applicable RP program documents comply with its requirements.
- 5. PROCEDURE 5.1 PCP Manual Revision and Review 5.1.1 PCP Manual revisions and minor changes are prepared by NGO Chemistry Radwaste Support.
5.1.2 The reviews and approvals required for PCP Manual changes are described in the Radioactive Waste PCP APPENDIX E PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS. The applicability of Appendix E is described as follows:
5.1.2.1 REVISIONS: Technical or significant changes to the PCP Manual shall be implemented as a Revision to the affected sections and shall include the reviews and approvals described in Table E-1of Appendix E.
5.1.2.2 MINOR CHANGES: If the change meets the following criteria it does not require a revision and the reviews and approvals in Table E-2 of Appendix E apply:
A. The change does not alter the scope, results, requirements, or methods by which the dewatering or solidification process as described in the Corporate PCP is performed.
B. The change does not alter the responsibilities of site personnel in meeting the PCP requirements.
PCP APP F 4 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS C. The change does not alter a PCP QA approved provider dewatering or solidification process, responsibilities for fulfilling PCP requirements or the vendor interface with the station personnel or work processes.
OR D. The change is editorial in nature; e.g., spelling, grammar, format, numbering, procedure name change, adding, deleting or changing a reference, administration of the manual affecting only the corporate author.
5.1.3 Minor Changes will be documented in PIP and the changes summarized in the PCP Manual Appendix H Revision Summary - Licensee Initiated Changes.
5.1.4 Revisions to the Corporate PCP or station PCPs (Appendix A, B or C) shall be sent to the NRC in each stations Annual Radioactive Effluent Report for the period in which the changes were implemented. This requirement is found in the following references:
5.1.4.1 NUREG-1431 Standard Technical Specifications Westinghouse Plants 5.1.4.2 NUREG-1430 Standard Technical Specifications Babcock and Wilcox Plants 5.1.4.3 Oconee Technical Specification 5.6.2 Annual Radiological Environmental Operating Report 5.1.4.4 Catawba SLC 16.11-16 Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report 5.1.4.5 McGuire SLC 16.11.17 Radioactive Effluent Release Report 5.1.5 Proposed technical PCP revisions affecting the dewatering or solidification processes used shall be reviewed against applicable Technical Specifications, all applicable NRC guidance, and all applicable hazardous waste management regulations to ensure all requirements of a Process Control Program have been addressed. Documents reviewed shall include at a minimum the applicable documents listed in sections 3 and 4 of the Corporate PCP.
PCP APP F 5 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 5.2 PCP Manual Revision Record Retention Requirements PCP records described in this section shall be retained in a retrievable form using an approved method as described in NSD 701 Records Management for a period of time no less than as defined in the referenced record number of the Information Retention Policy.
5.2.1 PCP Manual Revision Reviews & Approvals Documentation of the reviews/ approvals and revisions of the following sections of the PCP Manual shall be retained for a period of time no less than as defined in the Information Retention Policy record # 006644.
- CORPORATE PROCESS CONTROL PROGRAM
- APPENDIX A OCONEE NUCLEAR STATION PCP
- APPENDIX B MCGUIRE NUCLEAR STATION PCP
- APPENDIX C CATAWBA NUCLEAR STATION PCP
- APPENDIX H REVISION
SUMMARY
- LICENSEE INITIATED CHANGES 5.2.2 A microfilm record of the historical PCP revision reviews/approvals through 2001 is stored in the vault on roll # 2096 per retention record #
006644. All revisions after 2001 shall be archived as described above.
5.3 PCP Manual Revision Publication Process The PCP Manual is published for viewing in the NEDL Portal under Electronic Licensing Library (ELL). The PCP Manual files are viewable under the document subtype ODCM-PCP. The process for publication is summarized in ENCLOSURE 6.1 PCP Manual Revision Publication Process.
5.4 Administration of Nuclear Generation Procedures for Implementing PCP Activities 5.4.1 Technical implementing procedures shall be established to ensure that all requirements for solidification or dewatering are met when performed by Nuclear Generation personnel.
5.4.2 The Nuclear Generation technical PCP implementing procedures are maintained per NSD 703 Administrative Instructions for Technical Procedures.
PCP APP F 6 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 5.4.3 All PCP implementing procedures are identified in the station specific PCP contained in APPENDIX, A, B or C of the PCP Manual.
5.4.4 The technical PCP implementing procedures shall identify the fact that they are PCP related to ensure NSD 228 Applicability reviews consider the PCP requirements.
5.4.5 All revisions to technical PCP implementing procedures listed in the site PCPs shall be reviewed to determine if they alter or inhibit the procedure's performance of the Corporate PCP requirements.
5.4.6 Documents used to support the technical implementing procedures that are listed as PCP Support Documents in the station PCP, Appendices A, B or C shall be managed according to applicable administrative guidance and are not subject to the same program requirements as the technical implementing procedures. (e.g., Lab Methods, reference documents, etc.
are not addressed by NSD 703 or 228) 5.4.7 NGO Radwaste is responsible for the interpretation and implementation of the PCP and shall be notified when any changes, deviations or questions concerning the interpretation of a requirement in the solidification or dewatering of a radioactive waste is encountered which may affect the Duke Energy Radioactive Waste Process Control Program Manual.
5.5 Retention Requirements for PCP Implementing Procedures 5.5.1 Chemistry PCP procedures shall document the Radioactive Shipment Record (RSR) number for each dewatered or solidified container to provide a cross reference in the Chemistry record to the RMC shipment record.
5.5.2 Applicable documentation in Chemistry PCP procedures shall be forwarded to RMC for inclusion with the shipping and disposal paperwork and archival as part of the shipping record per SH/0/B/2004/002. {C 05953}.
5.5.3 Offsite vendor documentation of PCP compliance shall be returned to RMC (the site shipping contact) as described in the Purchase Order quality requirements.
5.5.4 PCP documentation from offsite PCP vendors shall be incorporated into the shipping record when applicable.
PCP APP F 7 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 5.5.5 RMC shipment files (including PCP documentation either from Chemistry or vendor) shall be sent to Master file under the retention code for Radioactive Material Control Records, Classification: QA Record as directed in procedure SH/0/B/2004/002.
5.6 Use of Vendor Procedures in Chemistry Procedures 5.6.1 Technical review of all vendor documents and procedures pertaining to PCP processing shall be performed by knowledgeable station and NGO Chemistry staffs as described in Enclosure 6.3 NSD 319 VTI Impact Assessment Process for Radwaste Vendor Documents Used in Chemistry.
5.6.2 Current revisions of vendor procedures that direct the use of vendor containers or processes for solidification or dewatering to meet PCP requirements are received per the vendor control document program and maintained as references for Nuclear Generation operating procedures.
5.6.3 The vendor procedure steps that direct PCP solidification or dewatering performed by station assigned individuals shall be incorporated into Nuclear Generation procedures and maintained in the technical procedure electronic repository for use by station personnel (e.g., NEDL/Scribe) as follows:
5.6.3.1 The vendor document is used as a reference.
5.6.3.2 The information from the vendor document is incorporated into the body and/or enclosures of the nuclear station implementing procedure.
5.6.3.3 The information is reformatted per the Procedure Writers Manual and NSD 703 except as described in 5.6.4.
5.6.3.4 The incorporation of vendor process information into the NEDL electronic procedure constitutes a technical procedure revision per NSD 703 including NSD 228 Applicability Determination and QR approval.
5.6.4 Some vendor procedure enclosures that document compliance with the vendor process or container certification requirements are required to accompany the container during shipment and receipt at the disposal site.
The following are two approaches that may be used to maintain the standardized formatting of the form:
PCP APP F 8 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 5.6.4.1 These enclosures may be referenced in the Nuclear Generation procedure rather than being incorporated into the NEDL electronic procedure.
A. When performing solidification or dewatering activities, a working copy of the enclosure is printed from the current controlled copy of the vendor procedure and incorporated as an enclosure in the working copy of the Nuclear Generation procedure.
B. This approach precludes revisions to the nuclear station procedure every time the vendor enclosure is revised.
5.6.4.2 The vendor document enclosures may be incorporated into the Nuclear Generation procedure electronically while maintaining the original vendor format.
A. This approach will require that formatting conflicts with applicable Nuclear Generation Writer's Manual guidelines be addressed.
B. The incorporation of revised vendor information into the NEDL electronic procedure constitutes a technical procedure revision per NSD 703, including NSD 228 Applicability Determination and QR approval.
5.7 Exclusion of Vendor Procedures from NSD 228 Applicability Determination 5.7.1 The vendor documents used to support PCP activities are exempted from the requirements of NSD 228 and NSD 703 per 703 subsection addressing Procedures for Site Equipment NOT Installed.
5.7.2 Applicability Determination (NSD 228), review, and approval under the site program are not required for the Radwaste vendor procedures or any subsequent revisions if all of the following criteria are met:
5.7.2.1 The Radwaste vendor procedures are from a vendor on the QA Approved Suppliers List.
5.7.2.2 The procedures direct activities on "NOT installed" plant equipment. e.g., Mobile Radioactive Waste Process (MRWP)
PCP APP F 9 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 5.7.2.3 The vendor dewatering and solidification procedure addresses activities that could be performed off-site.
5.8 Chemistry Control of PCP Related Vendor Documents 5.8.1 PCP related controlled vendor documents are distributed to NGO Radwaste per the vendor controlled document process.
5.8.2 NGO Radwaste is the Nuclear Generation Chemistry recipient for all Radwaste vendor documents used in PCP implementing Chemistry procedures.
5.8.3 Hard copies of controlled vendor documents are maintained as received in a Nuclear Generation Satellite File located in the NGO Chemistry area.
5.8.4 When NGO Radwaste receives vendor document revisions, they are distributed as described in Enclosure 6.2 Chemistry Process for Publication of PCP Related Vendor Documents.
5.8.5 All PCP related vendor document revisions are reviewed by NGO Radwaste to determine their impact on Nuclear Generation Chemistry programs and procedures.
5.8.6 Radwaste vendor documents that are incorporated into Nuclear Generation Chemistry PCP implementing procedures are subjected to a vendor technical impact assessment as described in Enclosure 6.3 NSD 319 VTI Impact Assessment Process for Radwaste Vendor Documents Used in Chemistry.
- 6. ENCLOSURES 6.1 PCP Manual Revision Publication Process 6.2 Chemistry Distribution of Radwaste Vendor Documents 6.3 NSD 319 VTI Impact Assessment Process For PCP Related Vendor Documents Used In Chemistry PCP APP F 10 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 PCP Manual Revision Publication Process 6.1 PCP Manual Revision Publication Process The PCP Manual is published for viewing in the NEDL Portal under ELL. The PCP Manual files are stored under the document subtype ODCM-PCP in an approved read-only format (e.g., PDF). The following process is used to publish the PCP Manual and ensure SDQA requirements are met:
6.1.1 PCP Manual Word File Management The PCP Word document files are managed in a secure server location
(//ngofs1/Chemgo) using the following subfolders:
- Revision PCP Word Files Contains the Word files under revision (i.e., the revision Word files)
- Current PCP PDF Files Contains copies of the current PDF files published for viewing in the NEDL Portal
- Revision PCP PDF Files Contains the PDF files under revision (i.e.,
the revision PDF files)
- Archive PCP PDF Files Contains copies of superseded PDF files 6.1.2 PCP Manual Revision and Publication Process 6.1.2.1 Copy the current PCP Word file to the subdirectory, Revision PCP Word Files when editing is needed 6.1.2.2 This revision file shall be named to differentiate it from the current file 6.1.2.3 Edit the revision PCP Word file PCP APP F 11 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 PCP Manual Revision Publication Process 6.1.2.4 Convert revision PCP Manual Word files to PDF files in the Revision PCP PDF Files subfolder with internal TOC links in the following sections:
- CORPORATE PCP
- APPENDIX F ADMINISTRATION OF THE PCP AND ASSOCIATED DOCUMENTS 6.1.2.5 Route the revision PDF for the required reviews and approvals A. Email the instructions for review and approval B. Include the revision PDF as an attachment OR C. Include instructions for accessing the file on the Intranet D. PIP may also be used to track the review and approval process E. Approved PCP Manual revisions that are technically significant and may impact training materials should be reviewed by the applicable training groups and documented using the appropriate process. (e.g., PIP) 6.1.2.6 Have reviewers and approvers respond via email with their "approval" or comments and/ or in the assigned PIP CA.
6.1.2.7 After all changes are approved, edit the signature page in the revision Word files with approver Names/ Dates and Issued Dates.
6.1.2.8 Create a PDF file of each revised Word document.
6.1.2.9 Verify the completed title and approval page of each revised PCP PDF file.
6.1.2.10 Copy the current PCP PDF file into the Archive PCP PDF Files subfolder .
6.1.2.11 Review the final PDF file containing updated title and approval page against the revision PDF file that was routed for review and approval to verify that only the approval Names/ Dates and Issued Dates entries changed.
PCP APP F 12 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 PCP Manual Revision Publication Process 6.1.2.12 Save as final the revision PDF file with approval documentation in the Current PCP PDF Files subfolder.
6.1.2.13 Save a copy the current Word file into the Archive PCP Word Files subdirectory 6.1.2.14 Save the final of the revision Word file in the Current PCP Manual Word Files 6.1.3 Adding a new PCP File to Scribe 6.1.3.1 Logon to Scribe Electronic Licensing Library (ELL) 6.1.3.2 Click the New Document icon in tool bar 6.1.3.3 Enter or select from the drop down menus the following information under Document Properties in the Add Document screen:
A.
Title:
Radioactive Waste PCP Manual: PCP SECTION TITLE rev #
B. Document Sub Type: Select ODCM-PCP C. Status: Select Current D. Doc Rev: enter the current revision #
E. Doc State: Select Issued F. Unit: Select the proper applicable initials for the PCP section.
(e.g., since the Corporate PCP applies to all units at all three sites select OCM)
G. Section Name: PCP SECTION TITLE (e.g., ONS PCP)
H. Document Date: enter the Issued date for this revision (e.g.,
12/01/02)
I. Retention Record Number: per then current guidance e.g.,
006644 PCP APP F 13 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 PCP Manual Revision Publication Process J. Author: Initial (e.g., " D) 6.1.3.4 NGO Radwaste reviews the current PDF in NEDL Portal against the control copy to verify all is correct 6.1.4 Revising an existing PCP Manual File in Scribe 6.1.4.1 Logon to Scribe Electronic Licensing Library 6.1.4.2 Checkout the current PCP Manual PDF file 6.1.4.3 Check in the revised PDF 6.1.4.4 Revise the Document Property values in the Check-in Document screen to reflect the changes (e.g., rev # in the Document Title, Document Date, Doc Rev #, etc.)
6.1.4.5 NGO Radwaste reviews the current PDF in NEDL Portal against the revised version to verify all is correct 6.1.5 PCP Manual Revision and Approvals Record Retention Transmit a copy of the following to NGO Document Support:
6.1.5.1 Verified current PDF (hard copy or electronic "read-only" file) 6.1.5.2 Email approvals or include PIP references in revision 6.1.5.3 The appropriate transmittal information (e.g., Nuclear Work Request Transmittal Form, email) with the following information:
A. Record/ Retention
Title:
Process Control Program B. Retention # : per then current guidance e.g., 006644 C. QA Condition: N/A D. Document
Title:
PCP Manual - Section Name rev # (ref:
PCP Revision History - Rolling Frame # 2096)
PCP APP F 14 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 PCP Manual Revision Publication Process NOTE: Rolling frame # 2096 contains the PCP historical record of revisions prior to 2002.
Example entry: PCP Manual-APPENDIX A ONS PCP rev 13 (ref: PCP Revision History - Rolling Frame # 2096)
E. Include the Document Title information on the front of the hard copy (e.g., PCP Manual-APPENDIX A ONS PCP rev 13(ref: PCP Revision History - Rolling Frame # 2096)) or in the electronic transmittal.
F. NGO Document Support transmits the published copy of the PCP Manual section and the email approvals (if applicable) and sends the film to the vault or uses the electronic archival process as appropriate.
G. NGO Document Support adds the Microfiche reference information to the index in Scribe.
6.1.6 NGO Satellite File Print out hard copy to place in the NGO Chemistry Satellite File 6.1.7 NRC Review of PCP Manual Revisions PCP Manual revisions shall be sent to the NRC in each stations Annual Effluent Report each year. If no revisions occurred, a communication shall be transmitted to Regulatory Compliance at each site documenting that no revisions occurred. During those years revisions do occur:
6.1.7.1 The transmittal shall be done in time to meet the May 1 deadline for the Annual Effluent Report.
6.1.7.2 The transmittal shall include a cover letter explaining the transmittal contents.
6.1.7.3 The transmittal shall include copies of all revisions to the PCP Manual effective during the report year using the media preferred by the NRC.
(e.g., CD ROM, hard copy, etc.)
6.1.7.4 The transmittal shall include the current revisions of the following:
PCP APP F 15 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 PCP Manual Revision Publication Process
- The CORPORATE PCP
- The applicable site-specific PCP section, (i.e., APPENDIX A, B, and C) for each site
- APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES
- APPENDIX E PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS
- APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS
- APPENDIX G WASTE PROCESSOR CHECKLIST
- APPENDIX H REVISION
SUMMARY
- LICENSEE INITIATED CHANGES
- A description of all intermediate but superseded revised sections that were created during the report period is in APPENDIX H for information.
6.1.7.5 NGO Document Support updates the Scribe index with the transmittal information.
PCP APP F 16 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.2 Chemistry Distribution of Radwaste Vendor Documents 6.2 Chemistry Distribution of Radwaste Vendor Documents 6.2.1 Controlled Radwaste vendor documents are received by NGO Radwaste via the vendor document transmittal process.
6.2.2 Radwaste Vendor Document Review 6.2.2.1 The document is reviewed to determine the type of document and the revision scope 6.2.2.2 If it is a supporting document not referenced in Chemistry PCP implementing procedures, A. It is reviewed for impact but no VTI impact assessment is done.
B. The controlled hard copy is placed in the NGO satellite file C. If the change affects the Duke PCP or operating procedures the sites are notified of the change, a PIP is generated and corrective actions created to address changes needed.
6.2.2.3 If the document is used or referenced in a PCP implementing procedure, A. The sites are notified of the document revision and pending assessment in case planned or current field activities or operating procedure revisions could be impacted.
B. The NSD 319 VTI impact assessment is performed as described in Enclosure 6.3.
6.2.3 Radwaste Vendor Document Publication and Storage 6.2.3.1 Required vendor documents received by Nuclear Chemistry are filed as hard copies in the GO Nuclear Chemistry Satellite File located as described in the NGO Satellite File List. The publication and archival of vendor documents are based on the categories below.
PCP APP F 17 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.2 Chemistry Distribution of Radwaste Vendor Documents A. Vendor documents used in Nuclear Generation Chemistry PCP implementation procedures are published electronically in NEDL Miscellaneous Library and also filmed for archival per then current guidance e.g., # 006644.
B. Radwaste Vendor documents that were used to approve a PCP vendor for the QA Approved Supplier List are not published but are filmed for archival per then current guidance e.g., # 006644 C. Miscellaneous vendor documents that NGO Radwaste maintains for PCP QA, program & contract support are not published, but may be filmed for reference.
6.2.4 Radwaste Vendor Document Preparation for Electronic Publication 6.2.4.1 NGO Radwaste is responsible for distribution of Radwaste vendor documents for Chemistry use 6.2.4.2 Controlled Radwaste vendor documents are received by NGO Radwaste in hard copy format. To accomplish electronic distribution, an approved read-only electronic format (e.g., PDF) is created by one of the following methods:
A. Hard copies are scanned into an approved read-only electronic file format using a software application approved for such use by the applicable Nuclear Generation administrative program, OR B. NGO Radwaste obtains electronic files from the vendor and the electronic files are converted to the approved read-only software application format.
6.2.4.3 Verify the read-only electronic file against the control copy.
6.2.5 Electronic publication in NEDL, 6.2.5.1 Notify NGO Document Support of the revision with an email attachment of the read-only revision file.
PCP APP F 18 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.2 Chemistry Distribution of Radwaste Vendor Documents 6.2.5.2 NGO Document Support transitions the current NEDL revision of the read-only file to WORK IN PROGRESS 6.2.5.3 NGO Document Support Checks out the file.
6.2.5.4 The new revision read-only file is Checked In.
6.2.5.5 NGO Document Support transitions the current revision file to REVISED and the new revision file to ISSUED.
6.2.5.6 NGO Radwaste is notified and the document view in NEDL is verified against the control copy.
6.2.6 Archival
Transmit a hard copy or electronic file of the verified new revision to NGO Document Support with the appropriate transmittal form or information, (e.g., Micrographics Nuclear Work Request form) including the following information:
6.2.6.1 Record/ Retention
Title:
Process Control Program 6.2.6.2 Retention #: per then current guidance e.g., "006644" 6.2.6.3 QA Condition: N/A 6.2.6.4 Document
Title:
PCP-XX-XX-XXX, Rev XX (PCP- should precede the vendor assigned document number) 6.2.6.5 Handwrite the Document Title information on the front of the hard copy (e.g., PCP-FO-OP-023, Rev 20) 6.2.6.6 NGO Document Support submits the published copy for filming and storage in the vault 6.2.6.7 NGO Document Support adds the Microfiche reference info to the index in Scribe.
PCP APP F 19 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.3 NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry 6.3 NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry 6.3.1 Vendor Documents are received by NGO Radwaste 6.3.2 The document is reviewed and its applicability is determined 6.3.3 If the document is a supporting reference document that is not specifically used in the Nuclear Generation Chemistry operating procedures for dewatering wet wastes, the formal VTI assessment is not performed.
6.3.3.1 The procedure is reviewed to determine if the changes are significant enough to be communicated to the sites.
6.3.3.2 If the change is significant, the changes are summarized in a communication to the sites, OR 6.3.3.3 If the change affects the site procedures or PCP Manual, a PIP is generated to document the changes and track site review and any Corrective Actions required.
6.3.3.4 If the changes are editorial or otherwise not significant, then the hard copy is placed into the NGO Radwaste controlled vendor document manual.
6.3.4 If it is a procedure used in a Nuclear Generation Chemistry PCP implementation operating procedure, the VTI assessment is initiated.
6.3.4.1 NGO Radwaste does a preliminary review of the procedure to determine how significant the changes are.
6.3.4.2 NGO Radwaste contacts the sites with the revision information and provides the preliminary review results.
6.3.4.3 The sites each determine whether the changes appear significant and make a decision about placing the related Duke procedure on hold pending completion of the VTI Assessment.
PCP APP F 20 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.3 NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry 6.3.4.4 NGO Radwaste creates the electronic file per ENCLOSURE 6.2 6.3.4.5 The read-only file is published per ENCLOSURE 6.2 and becomes the current revision for site to use 6.3.5 VTI Assessment Process Steps 6.3.5.1 After Radwaste Support performs the VTI assessment for each site using the guidance in NSD 319 it is transmitted, e.g., emailed, posted, etc. to the sites with a copy of the revised file for review.
6.3.5.2 A GO PIP is initiated to document the VTI assessments for all three sites in the PIP Problem ID and track any corrective actions.
Corrective actions are created as follows:
A. A CA for NGO Radwaste to determine actions required to address the impact to Duke PCP documents.
B. NGO Radwaste documents the site reviews:
- 1. If procedure changes are not needed, no additional Corrective Actions are created. OR
- 2. If a procedure change is needed, Corrective Actions are created accordingly to track the Duke procedure revision.
6.3.6 If no other Corrective Actions are needed, the PIP is closed.
PCP APP F 21 of 21 Rev 2 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev 1 WASTE PROCESSOR CHECKLIST REVIEWED BY/ DATE: __GT Johnson/ 8/22/05_____ _ _DL Vaught/ 8/16/05________
NGO Radiation Protection NGO Chemistry NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev 1 WASTE PROCESSOR CHECKLIST NOTE: (This Checklist is a template and should be edited, as appropriate, for each individual companys Review)
Process Control Program (For Vendors who use a PCP to process wet wastes for disposal at a 10CFR61 licensed disposal site)
- 1. Verify that the vendors Process Control Program (PCP), Quality Assurance program and other Dewatering or Solidification process related documents as described in the Radioactive Waste PCP for Duke Energy meet the requirements of the PCP.
This is a PCP requirement.
Site License
- 1. Review the Vendors Radioactive Material License and ensure that the specific license requirements are being meet.
State Regulations
- 1. Review the applicable State Regulations and ensure that any specific requirements are being met.
DOT Regulations
- 1. Does the Vendor meet the requirements of 49 CFR 172 Subpart H-Training?
Requirement: Each employer is required to provide general awareness, function specific, and safety awareness training for each Hazmat employee.
Training record keeping is required.
- 2. Does the Vendor meet the requirements of 49 CFR 172 Subpart I-Radiation Protection Program?
Requirement: Each employer is required to develop, implement, and maintain a written Radiation protection program. The Vendor should perform and document an audit of the RP program annually.
Pre-planning
- 1. Has the shipper been trained in D.O.T. hazardous materials requirements?
- 2. Has the shipper or other site designee been trained to sign a waste manifest?
- 3. Has the waste been characterized and a profile approved with the Treatment, Storage or Disposal Facility (TSDF)?
- 4. Are there State-specific ID numbers that must be obtained by the shipper or carrier?
- 5. Is the release criteria for low-level radioactive waste documented?
- 6. Can it be demonstrated that instruments used to determine release criteria have been calibrated?
PCP APP G 1 (Revision 8-22-05)
NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev 1 WASTE PROCESSOR CHECKLIST
- 7. Does the carrier have a hazardous waste/radioactive waste transporter permit valid in all states that will be traveled?
- 8. Insurance coverage in the amounts required by DOT and the relevant states?
- 9. Has the route to the TSDF from the site been planned in advance with the carrier?
- 10. Does this route cross any states that require a shippers permit (Examples: Mississippi, Colorado) or a carriers temporary trip permit (Examples: Georgia, Maryland) for hazardous or radioactive materials/wastes?
- 11. If yes to # 9, has the shipper or carrier obtained these permits in advance of the ship date (allow at least 30 days lead- time for a shippers permit)?
- 12. In South Carolina, has a specific route been documented for low-level radioactive waste?
Packaging
- 1. Does the package meet D.O.T. specifications?
- 2. Is the package in good condition (no signs of weakness, deterioration or staining)?
- 3. Is the package securely closed/sealed?
- 4. Is there a package inspection process/documentation?
- The D.O.T. proper shipping name?
- The D.O.T. hazard class and corresponding labels?
- The UN/NA number?
- To and From addresses?
- EPA hazardous waste or Non-hazardous waste label?
- Manifest number?
- EPA Waste I.D. Number
- TSDFs Waste profile/approval code?
Manifest and Attachments
- 1. Are State or supplier-specific data provided in the state manifest block?
- 2. Is the generator identification complete and correct including phone number?
- 3. Are the page numbers clearly marked?
- 4. If photocopies are used, is the original identified as such in contrasting color?
- 5. Is the transporters ID and correct phone number provided?
- 6. Are the D.O.T. descriptions correct and do they match the packaging?
- 7. Is the package count and weight correct?
- 8. Are waste codes and profile/approval codes entered?
- 9. Is a 24-hour emergency contact phone number provided? Is information truly available through this contact during off-hours? Are drills conducted?
- 10. Is the generators printed name, signature, and date entered correctly?
- 11. Is the drivers printed name, signature, and date entered correctly?
- 12. Is a land disposal restriction (LDR) form attached for hazardous waste? If applicable:
- Does the LDR have the correct generator name/location?
PCP APP G 2 (Revision 8-22-05)
NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev 1 WASTE PROCESSOR CHECKLIST
- The EPA ID number?
- The manifest number?
- The waste profile/approval number and corresponding description, treatability group, waste constituents, and universal treatment standards?
- Generators printed name, title, signature, and date?
- 13. For low-level radioactive waste in South Carolina, is the Drivers Instruction Sheet attached?
- 14. Has it been confirmed with the TSDF that the third-signature manifest is returned to the generator within 20 days for low-level radioactive waste or 30 days for hazardous waste?
Transporter
- 1. Is there a vehicle inspection documented prior to departure?
- 2. Does the driver have a Commercial Drivers License with Hazardous Materials endorsement?
- 3. Does the driver keep the manifest and other shipping documents within reach in the truck?
- 4. Has the driver been instructed on the route for low-level radioactive waste?
- 5. Does the driver have copies of any shipper or temporary carrier permits needed for this route/trip?
Radiological Conditions
- 1. Are all radiological postings legible/consistent?
- 2. Are all radiological labels is legible/consistent?
- 3. Are RWPs posted?
- 4. Do workers read/understand the RWP?
- 6. Do the workers know the dose limits of their RWP?
- 7. Are workers properly wearing/reading/recording their dosimetry?
Waste Tracking
- 1. How does the vendor track each customers waste through the different waste processes?
- 2. How does the vendor account for the waste activity through each process/disposal site?
- 3. How does the vendor determine Type Quantity/Waste Class on a package with several customers waste?
- 4. Does the vendor consider (and document compliance with) requirements of the BTP on Concentration Averaging?
PCP APP G 3 (Revision 8-22-05)
NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev 1 WASTE PROCESSOR CHECKLIST Security (Ref: PIP C-04-06442)
- 1. Discuss Duke security requirements with Vendor
- 2. Discuss the Duke package search requirements with the Vendor
- 3. If possible, make arrangements for the use of Duke approved package seals on the vendor packages
- 4. If practical, make arrangements for Duke security personnel to observe and seal packages at the vendor site PCP APP G 4 (Revision 8-22-05)
NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes Section Revision #
Appendix H Revision or
- PCP MANUAL SECTIONS CHANGED Minor Change (Issued) Note: Minor Changes retain the same Rev # and Issue Date (Issued)
APPENDIX A: "ONS PCP" Rev 16 Rev 16 (9/18/14)
APPENDIX B: MNS PCP" Rev 19 Rev 19(8/24/14) 10 APPENDIX C: "CNS PCP" Rev 13 Rev 13(1/15/15)
(Feb 2015)
APPENDIX E: PCP Manual Review and Approval Requirements Rev 3(10/9/14)
Rev 3 Minor Change Appendix A ONS PCP Rev 15 (Issued 9/16/10) (3/21/13) 9 Appendix D Approved Suppliers of PCP Services Rev 3 Rev 3(1/16/13)
(Mar 2013 ) Appendix E PCP Manual Review and Approval Requirements Rev 2 (1/16/13)
Rev2 8 Minor Change (Jun 2011) Appendix B MNS PCP Rev 18 (Issued 1/30/08) (6/15/11) 7 Rev 15 (9/16/10)
(Sep 2010) Appendix A ONS PCP Appendix A ONS PCP Rev 14 (6/19/09)
Minor Change 6 Appendix B MNS PCP Rev 18 (Issued 1/30/08) (4/23/09)
(Sep 2009)
Appendix F "Administration of the PCP Manual and Associated Rev 2 (2/26/09)
Documents Appendix E "PCP Manual Review and Approval Requirements Rev 1 (2/18/09)
Corporate PCP Rev15 Appendix A ONS PCP Rev13 5 Appendix B MNS PCP Rev18 (May 2007)
Appendix C CNS PCP Rev 12 Appendix D Approved Suppliers of PCP Services Rev 2 Appendix F "Administration of the PCP Manual and Associated Rev 1 Documents 4
(Aug 2005) Appendix G Waste Processor Checklist Rev 1 3 Appendix B MNS PCP Rev 17 (Nov 2004)
(Mar 2004) Appendix D: Approved Suppliers of PCP Services Rev 1 1 Corporate PCP Rev 14 i
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes Section Revision #
Appendix H Revision or
- PCP MANUAL SECTIONS CHANGED Minor Change (Issued) Note: Minor Changes retain the same Rev # and Issue Date (Issued)
(Nov 2003)
Corporate Process Control Program Rev 13 Appendix A Oconee Nuclear Station PCP Rev 12 Appendix B McGuire Nuclear Station PCP Rev 16 0 Appendix C Catawba Nuclear Station PCP Rev 10 (Mar 2003)
Appendix D Approved Suppliers of PCP Services Rev 0 Appendix E PCP Manual Review and Approval Requirements Rev 0 Appendix F Administration of the PCP And Support Documents Rev 0 Appendix G Waste Processor Checklist Rev 0 ii
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes START OF CURRENT APPENDIX H REVISION 10
SUMMARY
SUMMARY
OF PCP MANUAL CHANGES The PCP Manual revisions described in this summary were implemented as a result of the project to transfer the Chemistry department operating programs to the Operations department. PIP G-14-00619 describes the PCP Manual changes and documents the reviews and approvals. These revisions also reflect the organizational and program/ process changes from the Duke Energy & Progress Energy merger .
PCP MANUAL SECTIONS CHANGED APPENDIX A: "ONS PCP" REV 16 APPENDIX B: MNS PCP" REV 19 APPENDIX C: "CNS PCP" REV 13 APPENDIX E: PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS REV 3 DESCRIPTION OF CHANGES BY SECTION APPENDICES A, B & C
SUMMARY
OF CHANGES The Site PCP Sections Appendix A, B & C were all changed in the following manner:
- 1. Added the new Operations PCP implementing procedures developed from the Radwaste Chemistry procedures (both are listed to support the transition)
- 2. Changes in the management approvals: replaced site Station Manager with Nuclear AOM Shift approval (Manager over Operations Radwaste Core Team)
- 3. Chemistry Manager Approval remains in place since Chemistry will provide technical support to the PCP METHODOLOGY During the transfer of the Chemistry department operating programs to the Operations department, the PCP implementing procedures that were used by Chemistry Radwaste will be superseded by the new Operations procedures as the new procedure implementation requirements are completed.
These revisions to the site PCP sections of the PCP Manual change the organization of the site PCP sections to address the transitional conditions of the step-wise process used in training, qualification and procedure validation that the transition to the new procedures requires. This format allows the following methodology to be used:
- Both procedures are listed in the site PCP section for this revision so either may be used when needed by the site.
PCP APP H Page 1 of 2 APP H Rev. 10 NEDL SDQA C
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes
- As each new Operations procedure is implemented, the Chemistry procedure will no longer be available in NEDL.
APPENDIX E: PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS REV 3 Changed the technical reviews and management approvals designated for each section of the PCP Manual affected by the project to move operating functions from Chemistry to Operations.
Table E-1: Revision Review and Approval
- 1. Corporate PCP Section;
- Changed to specify DEC Station Managers approvals since the PCP Manual has not yet been revised to incorporate the DEP Sites
- Specified DEC Chemistry Managers Approvals
- Changed Technical review from Station Chemistry Staff to Station Radwaste Staff
- 2. Site Specific PCP Sections: Appendix A, B & C
- Changed site technical review from Chemistry to Radwaste
Table E-2: Minor Change Review and Approval Changed technical review from Chemistry to Radwaste END OF CURRENT APPENDIX H REVISION 10
SUMMARY
PCP APP H Page 2 of 2 APP H Rev. 10 NEDL SDQA C
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes START OF PREVIOUS APPENDIX H REVISION 9
SUMMARY
SUMMARY
OF PCP MANUAL CHANGES PCP MANUAL SECTIONS CHANGED APPENDIX A: "ONS PCP" Rev 15 Minor Change APPENDIX D: Approved Suppliers of PCP Services Rev 3 APPENDIX E: PCP Manual Review and Approval Requirements Rev 2 DESCRIPTION OF CHANGES BY SECTION APPENDIX A: "ONS PCP" Rev 15 Minor Change A Minor Change was published to address the following NOS Audit Deficiency identified during the 2012 ONS Radiological Effluent Controls Audit:
Problem Statement: The Oconee Process Control Program (PCP) Manual (Appendix A) is outdated (two procedures referenced in the manual have been revised from "B" to "A" procedures).
- 1. The PCP Manual, Appendix A, ONS PCP, identifies chemistry Procedure CP/0/B/5200/048, Resin Recovery System Operation, as an applicable procedure. The title of this procedure has changed to CP/0/A/5200/048, Resin Recovery System Operation. The PCP needs to be updated to reflect this procedure change.
- 2. The PCP Manual, Appendix A, ONS PCP, identifies chemistry Procedure CP/0/B/5200/054, Radwaste Liquid Waste Processing, as part of the PCP; however, review of the procedure determined that it is not part of the PCP.
- 3. Two editorial changes were included to correct procedure title wording BASIS: PIP O-12-12544 The PCP Manual Appendix A ONS PCP need to be updated to incorporate changes in two procedure numbers whose designations have been revised from "B" to "A" procedures.
APPENDIX D: Approved Suppliers of PCP Services Rev 3 CHANGES:
- 1. Added Waste Management Group (WMG) to the Approved Suppliers of PCP Services table.
- 2. Edited details of the DOCUMENTATION section to clarify applicability.
- 3. Added the PIP reference G-04-00113 that documents the review and approval of the Studsvik Processing Facility, LLC previously added to the table.
- 4. Deleted section 2.2 due to changes in internal Duke administrative processes outside the PCP Manual purview.
PCP APP H Page 1 of 2 APP H Rev. 10 NEDL SDQA C
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes BASIS: PIP G-12-00188 Documents the review and approval of the offsite radwaste processor, Waste Management Group (WMG), as a QA Supplier using their PCP for use by Duke Nuclear sites. (Ref:
Radioactive Waste Process Control Program (PCP) Manual requirements APPENDIX E: PCP Manual Review and Approval Requirements Rev 2 CHANGES:
- 1. Changed titles to reflect post merger.
- 2. Changed the approval protocol for the PCP Manual sections to simplify the approval process by lowering the management approval level required based on significance of the section being changed and whether it is a revision or a minor change.
- the station managers will not approve revisions to sections other that the Corporate PCP section
- Nuclear Chemistry Supervising Scientist is the NGO approver
- the Chemistry Peer Group Managers will be the highest level of site approval for the Site PCP Sections that just list the implementing procedures END OF PREVIOUS APPENDIX H REVISION 9
SUMMARY
PCP APP H Page 2 of 2 APP H Rev. 10 NEDL SDQA C
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes START OF PREVIOUS APPENDIX H REVISION 8
SUMMARY
SUMMARY
OF PCP MANUAL CHANGES JUNE 2011 PCP MANUAL SECTIONS CHANGED APPENDIX B: "MNS PCP" Rev 18 Minor Change DESCRIPTION OF CHANGES BY SECTION Minor Change: Added procedure OP/0/B/6200/083 WM Process Skid Demineralizers Sluice, Load, and Maintenance as a PCP implementing procedure.
This is a minor change per the definition in Appendix F: ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS Section 5.1.2.2 for the following reasons:
- The change does not alter the scope, results, requirements, or methods by which the dewatering or solidification process as described in the Corporate PCP is performed.
- The change does not alter the responsibilities of site personnel in meeting the PCP requirements.
- The change does not alter a PCP QA approved provider dewatering or solidification process, responsibilities for fulfilling PCP requirements or the vendor interface with the station personnel or work processes.
- The procedure OP/0/B/6200/083 is not a new procedure, its scope and use in the PCP dewatering process has not changed.
BASIS: MNS PIP M-10-06651 INOS Audit 10-15(INOS)(REC)(MNS) 2010 Radiological Effluent Control Program Audit The procedure OP/0/B/6200/083 is used in combination with Procedure OP/0/B/6200/064 Transfer and Dewatering of Media to perform PCP related activities. Procedure OP/0/B/6200/064 contains the final dewatering for disposal activities; however, Procedure OP/0/B/6200/083 is identified as a PCP implementing procedure in the Purpose statement of the procedure because it includes instructions (noted below) that important to the dewatering process.
- the requirement for using the two bottom laterals (L&P # 2.26 "Dewatering Legs #1 and #2 shall be used to dewater mixed media.")
- the requirement for the strainer in the dewatering pump discharge: (L&P # 2.29 "Y-strainer or similar device shall be installed in discharge path of dewatering pump to catch media in case internal filter fails. ")
END OF PREVIOUS REVISION 8
SUMMARY
PCP APP H Page 1 of 1 APP H Rev. 10 NEDL SDQA C
APPENDIX H Rev 10 Revision Summary - Licensee Initiated Changes START OF PREVIOUS APPENDIX H REVISION 7
SUMMARY
SUMMARY
OF PCP MANUAL CHANGES 2010 PCP MANUAL SECTIONS CHANGED APPENDIX A: "ONS PCP" Rev 14 to Rev 15 DESCRIPTION OF CHANGES BY SECTION G-9-00901: Document the changes, review and approval of a revision to the PCP Manual Appendix A "ONS PCP" due to changes in the PCP implementing procedures at ONS.
- 1. Change the list of implementing procedures to reflect that CP/0/B/5400/001 "RADWASTE HIC DEWATERING & OPERATING GUIDELINES" has been changed to an "A" procedure:
CP/0/A/5400/001.
- 2. Add the new procedure CP/0/A/5400/013 "RADWASTE POWDEX LINER DEWATERING &
OPERATING GUIDELINES" to the list of implementing procedures.
BASIS:
Incorporation of new procedures for Energy Solutions Self-Engaging Dewatering System (S.E.D.S)
- CS-OP-PR-009 Rev1 - Ecodex Precoat-Powdex-Solka-Floc-DE-Zeolite-Dewatering ES 14-215 or Smaller Liners Utilizing SEDS
- CS-OP-PR-010 Rev1 - Bead Resin or Activated Carbon Dewatering ES 14-215 Or Smaller Liners, Utilizing ES SEDS
- CS-OP-PR-008 Rev1 - Setup And Operation Of EnergySolutions Self-Engaging Dewatering System Fillhead END OF PREVIOUS REVISION 7
SUMMARY
PCP APP H Page 1 of 1 APP H Rev. 10 NEDL SDQA C
APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes START OF PREVIOUS APPENDIX H REVISION 6
SUMMARY
SUMMARY
OF PCP MANUAL CHANGES 2009 PCP MANUAL SECTIONS CHANGED
- APPENDIX E: PCP Manual Review and Approval Requirements" Rev 0 to Rev 1
- APPENDIX F: Administration of the PCP and Support Documents Rev 1 to Rev 2 DESCRIPTION OF CHANGES BY SECTION APPENDIX A: "ONS PCP" REV 13 to Rev 14 G-08-01066: 2008 ONS Radiological Effluent Controls Audit 08-21(INOS)(REC)(ONS)
Added two documents to APPENDIX A: "ONS PCP", one that is used in support of the process control program and one that documents the dewatering process used on filters and the filter HICs:
A. LM/0/E005, Rev 003, "ONS Paint Filter Liquids Test". ONS Radwaste Chemistry personnel use the paint filter liquids test for FSL (i.e., free standing liquid) verification of media shipments to the Clive Bulk Low Level Waste Disposal Facility in Utah.
B. ONS HP/0/B/1006/012, Rev 006, "Handling Procedure for CNS High Integrity Containers".
ONS RP RMC personnel use this procedure to document the filter dewatering and to remove incidental water from Energy Solutions FEXM High Integrity Containers (HICs) containing dewatered filters. This procedure is maintained as an operating procedure per guidance in NSD 703 and NSD 228.
LM/0/E005 is not an operating procedure but is used in support of the PCP. Some Duke dewatering procedures listed as PCP implementing procedures reference the paint filter lab method as a PCP test verification method for bulk resin/media disposal at Clive Lab Method procedures do not have to comply with the same administrative requirements for PCP implementing procedures because Lab Methods are not maintained per NSD 703 and are not subject to NSD 228 Applicability reviews.
APPENDIX F of the Process Control Program Manual was revised to allow for the inclusion of procedures or documents that describe processes which support PCP implementing procedures but are subject to less rigorous program requirements than PCP implementing procedures which detail operating processes. The ONS HIC handling procedure is a verification of no FSL in the filter HIC after meeting the PCP requirements for filters independent of the HIC dewatering. This procedure is under revision to clarify the documentation of the dewatering process for the filters and the verification for HIC.
PCP APP H Page 1 of 3 APP H Rev. 10 NEDL SDQA C
APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes APPENDIX B: "MNS PCP" Rev 18 MINOR CHANGE M-08-07570 Documents the Recommendations for Performance Improvement identified during the 2008 MNS Radiological Effluent Controls Audit 08-22(INOS)(REC)(MNS).
PREVIOUS REVISION
SUMMARY
APPENDIX H Rev 6 An editorial change was made to Appendix B of the McGuire PCP. The title of Procedure OP/0/B/6200/064 Rev 024 should be revised to reflect the correct title of "Transfer and Dewatering of Media." The title is currently shown as "Transfer and Dewatering of Bead Resin."
APPENDIX E: PCP Manual Review and Approval Requirements" Rev 0 to Rev 1 A table for minor change approvals was added that lists technical review requirements and reduces the number of management approvals required for minor changes as defined in Appendix F Section 5.1 PCP Manual Revision and Review. This second table is in addition to the existing approval table for changes that are substantive enough to be revisions as described in Appendix F. This change was requested by the Chemistry Managers to streamline the PCP administrative process based upon the significance of the change.
APPENDIX F: Administration of the PCP and Support Documents Rev 2
- 1. Added a minor change process to the administration guidance for the PCP Manual to more appropriately utilize management involvement. This new process is in addition to the existing revision process described in Appendix F. The criteria for minor changes are explained in section 5.1 PCP Manual Revision and Review of Appendix F. The required reviews and approvals for minor changes and revisions are tabulated in Rev 1 of Appendix E PCP Manual Review and Approval Requirements as described below.
- 2. Removed references to Record Retention Rule # 004928.
- 3. Revised Appendix F section 5.4 Administration of Nuclear Generation Procedures for Implementing PCP Activities to include the listing of PCP support documents that are not technical procedures but may be listed in the site PCP sections, Appendices A, B & C at the sites discretion.
- 4. Edited the publication processes in the Appendix F Enclosures to clarify and update to better utilize PIP and electronic administrative processes available.
- 5. Some editorial word changes for clarity and readability.
PCP APP H Page 2 of 3 APP H Rev. 10 NEDL SDQA C
APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes BASES FOR APPENDIX F CHANGES C-08-05953 CA # 7 - 2008 CNS Radiological Effluent Controls Audit 08-20(INOS)(REC)(CNS):
Remove the references to Record Retention Rule #004928 from the PCP Manual Appendix F.
Applicable documentation in Chemistry PCP procedures, which is forwarded to RMC for inclusion with the shipping and disposal paperwork, should be stored under Record Retention Rule #00278.
Note: Documentation is currently stored in both places, this enhancement will eliminate the need for it to be stored at the unintended location.
PREVIOUS REVISION
SUMMARY
APPENDIX H Rev 6 O-08-06705 - 2008 ONS Radiological Effluent Controls Audit 08-21(INOS)(REC)(ONS): The following enhancements should be made during the next revision of the PCP Manual, Appendix F:
Remove the references to Record Retention Rule #004928 from the PCP Manual Appendix F.
Applicable documentation in ONS Chemistry Procedure CP/0/B/5400/001, Rev 029, Radwaste Dewatering & Operating Guidelines, is forwarded to RMC for inclusion with the shipping and disposal paperwork. The requirement to provide a copy of the completed dewatering procedure to RMC for inclusion in the shipping record is adequate. The proper retention record number is identified in SH/0/B/2004/002.
END OF PREVIOUS REVISION 6
SUMMARY
PCP APP H Page 3 of 3 APP H Rev. 10 NEDL SDQA C
APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes START PREVIOUS REVISION
SUMMARY
APPENDIX H REV 5 REVISED SECTIONS
- Rev15 Corporate PCP
- Rev13 APPENDIX A "Oconee Nuclear Station Process Control Program"
- Rev18 APPENDIX B "McGuire Nuclear Station Process Control Program"
- Rev 12 APPENDIX C "Catawba Nuclear Station Process Control Program"
- Rev 2 APPENDIX D " Approved Suppliers of PCP Services"
- Rev 1 APPENDIX F "Administration of the PCP Manual and Associated Documents" The Duke Energy Radioactive Waste PCP Manual was revised to address the issues described below:
- PIP G06-00560: Summarized findings and Areas For Improvement (AFI) from the 2006 Annual Chemistry Functional Area Evaluation. The Duke Energy Process Control Program Manual and associated documents were audited during this assessment and the administrative changes were implemented as described in this section.
- PIP G-7-00244: Revised ADDENDIX D to reflect the vendor name change from Duratek to Energy Solutions per PIP G-07-00244 that documents the Vendor Technical Impact evaluation of Energy Solutions procedure FO-OP-023 rev 23.
- Non-technical editorial changes were also made to each revised section as appropriate to improve wording clarity, grammatical and punctuation errors. Some administrative process flow changes were made in APPENDIX F to reflect updated Duke administrative processes
- PIP G-07-0841: Deleted section 11.3.3.6 that required initial liner unwatering upon completion of final waste transfer to liner (e.g., dewater to loss of vacuum in bottom dewatering laterals to establish capillary dewatering conditions). The changes are summarized below by section.
Corporate PCP Section:
Ref: PIPs G06-00560 & PIP G-07-0841 In Section 1.2 "Radioactive Waste Process Control Program Description", instructions for archival film copies of PCP Manual are referred to APPENDIX F Administration of the PCP and Support Documents" eliminating the specific reference to the record retention numbers that are in a state of transition due to corporate program changes. This eliminates the need for a Corporate PCP section revision whenever the retention numbers are changed.
Section 4.2, Duke Energy Programmatic
References:
4.2.3, 4.2.6 and 4.2.8. refer to SLC 16.13-2 "Technical Review and Control" which has been deleted from the Selected Licensee Commitments Manual at each site. Removed all references to the SLC 16.13-2 "Technical Review and Control".
Section 6.2 "Nuclear Safety Review Board": Removed requirement in subsection 6.2.2 that copies of the Radioactive Waste PCP manual are reviewed by the NSRB per SLC 16.13.2. This SLC has been deleted.
PCP APP H Page 1 of 4 APP H Rev. 10 NEDL SDQA C
APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION
SUMMARY
APPENDIX H REV 5 DESCRIPTION OF PCP MANUAL CHANGES Section 6.3.6: Deleted reference to SLC 16.13.2 requirement that the Manager, Safety Assurance assures the performance of a review by a knowledgeable individual/organization of changes to the PCP. This SLC has been deleted.
Section 9.1 and 9.2.2: Reworded approval from 'NRC' to "appropriate regulatory" since the NRC no longer approves Topical Reports for conformance to the "Waste Form" BTP. Disposal technology and processes are approved by the agreement states hosting the LLW disposal sites.
Section 10.9 "Solidification Document Retention" states that records shall be maintained on each vessel of solidified waste as described in Section 7.5 of the Corporate PCP and Section 5.5 of APPENDIX F. This was revised to reference section 7.4 instead of 7.5.
Section 11.2.1: Reworded step to replace the word "sludge" with the word "solids".
Section 11.3: Changed "DPCo" to Duke Energy.
Section 11.3.3.5: Changed "establishes"' to "establish".
Section 11.3.3.6 was deleted to address the conclusions in PIP G-07-0841 as summarized below.
This requirement was added during a 2003 problem investigation at Oconee Nuclear Station and incorporated in revision 14 of the Corporate PCP as described in Revision 1 to this Appendix H as a requirement. Vendor guidance now indicates that this should be a discretionary decision balanced with ALARA and other priorities. The vendor program and current industry practices do not place a time constraint on the initiation of dewatering after filling the HIC as a critical variable in the dewatering process. The vendor PCP and procedures for the dewatering of the particular HICs in use do not have a time constraint for initiating unwatering and no test history indicates the need for the requirement as written. This requirement as written is non conservative relative to the ALARA performance of the task and was removed be from the Duke Energy Corporation PCP and procedures.
Section 11.7 states that records shall be maintained as described in Section 7.5 of the Corporate PCP.
This was revised to correctly reference section 7.4 instead of 7.5.
APPENDIX A: ONS PCP Ref: PIP G06-00560 Section 3 "Implementing Procedures" Removed reference for procedure TC/0/B/5400/001 since this procedure has been deleted.
Added the following procedures to the implementing procedures list because they require the user to enter the process control program by referral to the dewatering procedures used to prepare a shipment for disposal:
- CP/0/B/5200/054A, "LW Demineralizers Sluice and Reload and BFST Transfer" PCP APP H Page 2 of 4 APP H Rev. 10 NEDL SDQA C
APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION
SUMMARY
APPENDIX H REV 5 DESCRIPTION OF PCP MANUAL CHANGES
- CP/0/B/5200/073, "Resin Batch Sluice Procedure"
- CP/0/B/5200/054, "Radwaste Liquid Waste Processing.
APPENDIX B: MNS PCP Ref: PIP G06-00560 The title of a procedure in Section 3 did not agree with the procedure title in the controlled document. Revised the title for HP/0/B/1004/012 "Utilization of Polyethylene High Integrity Overpacks" to correctly read HP/0/B/1004/012 "Utilization of Polyethylene High Integrity Containers".
The following procedures were removed from the list of Implementing Procedures under CA 8 since they no longer contain PCP dewatering guidance.
- 1 OP/1/B/6200/102 "Unit 1 CM Backwash Tank Operation"
- 2 OP/2/B/6200/102 "Unit 2 CM Backwash Tank Operation"
- 3 OP/1/B/6700/016 "Operating Unit 1 Steam Generator Blowdown Demineralizers"
- 4 OP/2/B/6700/016 "Operating Unit 2 Steam Generator Blowdown Demineralizers" The Plant Interface Drawing Index was revised to update the numbering protocol to current nomenclature. MNS flow diagrams are now designated with "MCFD" instead of "MC" and the numbering system includes a two digit nomenclature requiring additional zeroes to accurately represent the correct drawing numbers. The drawing reference in item 4.7 MC-1604-1.1 was deleted because it does not contain any PCP related plant interfaces and the drawing reference MCFD-2590-01.03 was added to reflect the Unit 2 version of the interface reflected in the Unit 1 drawing MCFD-2590-01.03.
APPENDIX C: "CNS PCP" Ref: PIP G06-00560 Section 3 "Implementing Procedures" Item 3.1: Deleted OP/1/B/6250/016 Condensate Polishing Demineralizer Backwash Tank Subsystem - Unit 1" because PCP dewatering activities have been removed.
Item 3.2: Deleted OP/2/B/6250/016 Condensate Polishing Demineralizer Backwash Tank Subsystem - Unit 2" Because PCP dewatering activities have been removed.
Item 3.3: The procedure title for OP/0/B/6500/111 was revised to agree with the procedure title in the controlled document "Nuclear Solid Waste (WS) Disposal System".
PCP APP H Page 3 of 4 APP H Rev. 10 NEDL SDQA C
APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION
SUMMARY
APPENDIX H REV 5 DESCRIPTION OF PCP MANUAL CHANGES Item 3.4: The procedure title for OP/0/B/6500/046 was revised to agree with the procedure title in the controlled document "Transferring and Dewatering Bead Resin in WSF".
Item 3.5: The procedure title for OP/0/B/6500/069 was revised to agree with the procedure title in the controlled document "Monitor Tank Building (MTB) Ion Exchange and Filtration Media Operations".
APPENDIX D: Approved Suppliers of PCP Services Ref: PIP G07-00244
- Changed the vendor name from Duratek to Energy Solutions
- Updated the section 2. "SERVICE CONTRACT REQUIREMENTS" to reflect recent changes to the Quality Requirements for radwaste vendor contracts.
APPENDIX F: "Administration of the PCP and Support Documents" Ref: PIP G06-00560 Section 5.1.3: Deleted requirement that revisions to the PCP and a description of the revisions be sent to the NSRB based on SLC 16.3.2. This SLC has been deleted.
Deleted wording in 5.4.2 that was redundant with 5.4.5 pertaining to review requirements for implementing procedures.
Changes were made to reflect current Duke processes for publishing documents using email and electronic document transmittals associated with Duke software NEDL Portal and Scribe. This revision also revised some of the processes for manual changes and vendor documents to adopt recent changes to the PIP process to take advantage of the new integrated data base.
END OF PREVIOUS REVISION 5
SUMMARY
PCP APP H Page 4 of 4 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes START PREVIOUS REVISION
SUMMARY
APPENDIX H REV 4 DESCRIPTION OF PCP MANUAL CHANGES AUGUST 2005 APPENDIX G Waste Processor Checklist was revised to incorporate guidance defined in PIP C-04-06442 written to address revised security search requirements for materials entering new Security Barriers. The audits of waste processors are performed under the Corporate Process Control Program, Section 8.0, Approval Process for QA approved Suppliers, and Appendix G, Waste Processor Checklist. The following section was added to Appendix G:
Security
- 1) Discuss Duke Security requirements with Vendor
- 2) Discuss the Duke package search requirements with the Vendor
- 3) If possible, make arrangements for the use of Duke approved package seals on the vendor packages
- 4) If practical, make arrangements for Duke security personnel to observe and seal packages at the vendor site END OF PREVIOUS REVISION 4
SUMMARY
REF: August 2005 Revision APPENDIX G: Rev 1 Waste Processor Checklist PCP APP H Page 1 of 1 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION
SUMMARY
APPENDIX H REV 3 DESCRIPTION OF PCP MANUAL CHANGES NOVEMBER 2004 APPENDIX B: McGuire Nuclear Station Process Control Program Rev 17 The procedures described below were removed from the MNS PCP Implementing Procedure list due to the following changes:
CP/0/B/8300/022 Handling of Laboratory Quantities of Spent Resin was deleted because there are RP processes and controls that address this type of radioactive material.
OP/0/B/6200/068 Process Control Program for CNSI Cement Solidification Units was deleted because the procedure is not used or needed.
OP/0/B/6200/084 Solidification of Grit Waste was deleted because the procedure is not used or needed.
OP/1/B/6200/104 Unit 1 Operating, Dewatering, and Shipping Liners Filled with Powdered Media and/or Bead Resin was deleted. A new procedure was written that addresses the steps for unwatering for shipment to a vendor for reprocessing so by definition the PCP does not apply to the new procedure, OP/1/B/6200124 Unit 1 Secondary Solid Waste Container Processing OP/2/B/6200/104 Unit 2 Operating, Dewatering, and Shipping Liners Filled with Powdered Media and/or Bead Resin was deleted. A new procedure was written that addresses the steps for unwatering for shipment to a vendor for reprocessing so by definition the PCP does not apply to the new procedure, OP/2/B/6200/124 Unit 2 Secondary Solid Waste Container Processing.
OP/0/B/6200/094 Transfer and Dewatering Radwaste Media - Radlok High Integrity Containers was deleted because it is no longer used. The vendor for this process is no longer in business.
APPENDIX C: Catawba Nuclear Station Process Control Program Rev11 The CNS PCP Implementing Procedures list was revised to reflect the following procedure changes:
OP/1/B/6500/053 and OP/2/B/6500/053 Transfer and Dewatering of Contaminated Secondary Resins (Unit 1 & 2) are being removed from the CNS PCP Implementing Procedure list because they were revised to remove the PCP dewatering activities. The revised procedures OP/1 and 2/B/6500/053 Transfer and Unwatering of Secondary Resin will now be used only for unwatering Secondary resin that is not being prepared for direct disposal at a 10CFR61 disposal site, so by definition the PCP does not apply to the new procedures.
PCP APP H Page 1 of 2 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes OP/0/B/6500/082 Dewatering Secondary Contaminated Resin is being added to the CNS PCP Implementing Procedure list. This new procedure was written to address the PCP dewatering of contaminated Secondary side resin removed from OP/1&2/ B/6500/053 to be performed by the Radwaste Chemistry group.
OP/0/B/6500/013 Operating Procedure for the Nuclear Solid Waste (WS) Disposal System which is listed in the CNS PCP Implementing Procedure list has been renumbered and is now OP/0/B/6500/111. The content is the same, only the number has changed due to PIP C-04-2308.
This PIP required procedures that have the same number as other groups procedures to be changed to eliminate a human error trap.
END OF PREVIOUS REVISION 3
SUMMARY
REF: Nov 2004 Revision APPENDIX B McGuire Nuclear Station Process Control Program Rev 17 REF: Nov 2004 Revision APPENDIX C Catawba Nuclear Station Process Control Program Rev11 PCP APP H Page 2 of 2 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes START PREVIOUS APPENDIX H REV 2
SUMMARY
OF MARCH 2004 REVISION 1 OF APPENDIX D: APPROVED SUPPLIERS OF PCP SERVICES Appendix D of the Radioactive Waste PCP Manual was revised to remove the ATG from the approved suppliers list and to add Studsvik to the list.
The bases for the changes made are described below:
ATG declared bankruptcy in 2002 and various other companies purchased portions of their assets and programs.
The vendor Studsvik was evaluated and approved for the VR services described in the revision 1 of the APPENDIX D section of the Radioactive Waste PCP Manual. The approval was based on the requirements of the Corporate PCP section of the PCP Manual and APPENDIX G: Waste Processor Checklist section of the PCP Manual. The approval included a review of Studsvik documents describing the QA program, Process Control Program, and RP programs/ practices. A NUPIC audit report dated February 20, 2002 was reviewed.
The report of the evaluation and approval of Studsvik is summarized in PIP G-04-0113.
END OF PREVIOUS REVISION 2
SUMMARY
REF: March 2004 REVISION 1 of APPENDIX D of the PCP Manual PCP APP H Page 1 of 1 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 1
SUMMARY
OF NOVEMBER 2003 REVISION 14 OF CORPORATE PCP (CONSERVATIVE GUIDANCE FROM ROOT CAUSE)
Revision 14 to the Corporate PCP section of the Radioactive Waste Process Control Program Manual incorporates additional guidance for dewatering activities to ensure adequate conservatism is provided by the PCP implementing procedures. An event involving the failure of a dewatered HIC to meet the free standing liquid (FSL) limits at Barnwell and the subsequent root cause investigation identified changes that would provide greater confidence in meeting the FSL requirements. Also some editorial changes not related to the root cause evaluation were made. The changes are summarized below.
Added the PIP references associated with the Root Cause in O-03-0624, and the applicability evaluation PIPs at MNS and CNS, M-03-2515 and C-03-3385 to section 4, DUKE ENERGY PROGRAMMATIC REFERENCES.
Added two additional Regulatory Guidance references to Section 3, Regulatory References 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 Added item 5.17 in section 5, DEFINITIONS to describe the Topical Report, its significance in the development of the PCP and how its applicability to actual conditions can impact the degree of conservatism needed.
Added section 7.5, entitled Periodic cross-checks & comparisons that addresses a requirement from the Root Cause evaluation for benchmarking the ONS dewatering processes.
Added section 11.3 entitled Additional Conservatism in Slurry Dewatering Procedures to Address Variation from the Topical Report (PIP O-03-0624, M-03-2515, C-03-3385) to incorporate the specific additional guidance needed in dewatering procedures at all 3 sites. The Root Cause identified corrective actions required to prevent recurrence (CAPR) and other enhancements that were evaluated for consideration on a site by site basis. Only the corrective actions that were applicable to all three sites have been incorporated into the Corporate PCP. Those corrective actions that were more site-specific have been incorporated in the site implementing procedures as needed.
Added section 11.3.1 that describes the need to include procedural flexibility/ guidance for Chemistry to add conservatism to any PCP dewatering process if waste content and/ or process conditions are atypical in a non conservative manner and provides examples of such actions.
PCP APP H Page 1 of 2 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 1
SUMMARY
OF NOVEMBER 2003 REVISION 14 OF CORPORATE PCP (CONSERVATIVE GUIDANCE FROM ROOT CAUSE)
Added section 11.3.2 that provides guidance for procedures used to dewater liners using a PCP for direct disposal at Barnwell based on the PIP O-03-0624 CAPRs summarized below:
- requires liner functional testing prior to filling liner with waste to ensure there are no leaks in the liner dewatering system
- requires that ambient temperature guidance for dewatering will preclude localized freezing conditions during the dewatering sequence
- requires that the final water collection sample point must be representative (e.g., as close as possible to the pump discharge)
Added section 11.3.3 to address PCP dewatering procedures for Mixed Media with significant non-media solids:
- requires use of Ecodex filter system in all liners that contain mixed media with significant non-media solids
- requires that procedures clearly specify media loading sequence if media is not homogeneously mixed to minimize potential blinding of the lowest level of filters
- requires additional dewatering Cycles for mixed media liners after the acceptance criteria in the vendor procedure have been met
- requires longer settling periods during the additional dewatering cycles
- requires dewatering through bottom 2 laterals during liner filling based on the Topical Report requirement to establishes proper media compaction and capillary conditions
- requires initial liner unwatering upon completion of final waste transfer to liner In Sections 11.5.2.1, 11.5.3.1, 11.5.4.2 D added wording to clarify that FSL verification can be accomplished using either an onsite PCP process or an approved offsite vendor process.
END OF PREVIOUS REVISION 1
SUMMARY
Ref: November 2003 REVISION 14 of CORPORATE PCP PCP APP H Page 2 of 2 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 0
SUMMARY
OF MARCH 2003 MANUAL REWRITE OVERVIEW The Duke Energy Radioactive Waste Process Control Program Manual is a rewrite of the original DPCo PCP. The Corporate PCP and Introduction chapters of the DPCo PCP have been revised many times to incorporate critical changes, but have not been rewritten since the original publication.
During the ensuing period many new programs and processes have been developed within Duke Energy, disposal site requirements and availability have changed and new process options are now available in the commercial Radwaste industry. This rewrite attempts to incorporate these changes, integrate the PCP Manual with other programs within Duke Energy and create flexibility for future administration.
The reissued manual attempts to address specific issues identified in numerous audits and Problem Investigation Process (PIP) reports. The PIPS listed below identified changes needed or were associated with this revision:
- G-00-0401 (QA Audit of NGO PCP & support documents. This PIP incorporated corrective actions from C-01-02522, O-01-01067, G-99-00349, C-99-05094)
- C-01-02522 (NRC CNS Audit - Offsite Vendors)
- O-00-4680 (ONS Filter dewatering procedure use)
- G-99-00349 (NGO Radwaste Support PCP Evaluation)
- C-99-05094 (SLC Change Issues)
DETAILED DISCUSSION OF CHANGES
- 1. MANUAL ORGANIZATION AND FORMAT CHANGES The reorganization of the PCP segregates technical requirements from administrative information to reduce the necessity for performing revisions with their associated management approvals every time administrative and non-technical changes occur. (i.e., the Corporate PCP defines the program requirements, the administrative appendices provide details of how the program and associated documents are managed) The regulatory and SLC requirements are contained in the Corporate PCP section of the manual. Where guidance is addressed in more PCP APP H Page 1 of 10 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 0
SUMMARY
OF MARCH 2003 MANUAL REWRITE OVERVIEW detail by other Duke Energy programs, a reference to that program replaced the redundant information in the earlier version of PCP. (e.g., EWP 2.8 Waste Oil and 2.9 Mixed Waste)
The details of the manual reorganization are discussed below.
1.1 Old PCP Manual Organization The superseded DPCo Process Control Program was organized as follows:
I. Introduction II. Corporate PCP Rev 12 III. ONS PCP Rev 11 IV. MNS PCP Rev 16 V. CNS PCP Rev 10 VI-IX. Contained FOR INFO ONLY regulatory and historical reference information that was not considered part of the controlled document.
1.2 New PCP Manual Organization The new PCP Manual is organized as follows:
CORPORATE PROCESS CONTROL PROGRAM Rev 13 The Corporate Process Control Program (PCP) contains the technical requirements previously contained in Chapters I and II in the DPCo PCP. The details of this revision are summarized in section 2 below, Corporate PCP Changes.
APPENDIX A OCONEE NUCLEAR STATION PCP Rev 12 This revision of the Oconee PCP incorporates the new manual formatting and the removes the exception to the Corporate PCP pertaining to vendor approvals. Previously each site PCP contained an exception to the Corporate PCP requirement that the Station Manager or his designee had to approve solidification or dewatering services. This exception was incorporated into the Corporate PCP such that only corporate review and approval of vendor solidification and dewatering services are now indicated.( Ref: PIP G-00-0401)
PCP APP H Page 2 of 10 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 0
SUMMARY
OF MARCH 2003 MANUAL REWRITE OVERVIEW The Chemistry procedure CP/3/B/5200/08A Unit 3 High Activity Spent Resin Storage Tank (HASRST) Resin Transfer to Disposable Liner was removed from the implementing procedures list because the PCP activities associated with this procedure have been eliminated.
APPENDIX B McGUIRE NUCLEAR STATION PCP Rev 16 This revision of the McGuire PCP incorporates the new manual formatting and the removal of the exception related to vendor approvals. Previously each site PCP contained an exception to the Corporate PCP requirement that the Station Manager or his designee had to approve solidification or dewatering services. This exception was incorporated into the Corporate PCP such that only corporate review and approval of vendor solidification and dewatering services are now indicated.( Ref: PIP G-00-0401)
The procedure OP/0/B/6200/065, Transfer of Powdex to a Disposable Liner has been removed from the McGuire PCP implementing procedure list. The PCP activities in this procedure have been incorporated into two other procedures already on the list, OP/1/B/6200/102, Unit 1 CM Backwash Tank Operation and OP/2/B/6200/102, Unit 2 CM Backwash Tank Operation.
The procedure HP/0/B/1004/032, Procedure for Packaging Radioactive Filters, used for filter dewatering and packaging was added to the implementing procedure list.
APPENDIX C CATAWBA NUCLEAR STATION PCP Rev 10 This revision of the Catawba PCP incorporates the new manual formatting and the removal of the exception related to vendor approvals. Previously each site PCP contained an exception to the Corporate PCP requirement that the Station Manager or his designee had to approve solidification or dewatering services. This exception was incorporated into the Corporate PCP such that only corporate review and approval of vendor solidification and dewatering services are now indicated.( Ref: PIP G-00-0401)
The CNS PCP procedure list was revised as follows:
- Corrected the entry for Chemistry procedure OP/1(2)/A/6250/016 "Operating Procedure for the, Condensate Polishing Demineralizer Backwash Tank Subsystem to reflect that it is a "B" procedure and is unit specific. The entries are now OP/1/B/6250/016 Condensate Polishing Demineralizer Backwash Tank Subsystem PCP APP H Page 3 of 10 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 0
SUMMARY
OF MARCH 2003 MANUAL REWRITE OVERVIEW
- Unit 1" and OP/2/B/6250/016 Condensate Polishing Demineralizer Backwash Tank Subsystem - Unit 2".
- Revised entry for OP/1(2)/B/6500/053 to reflect current Unit specific titles OP/1/B/6500/053 Transfer and Dewatering of Contaminated Secondary Resin Unit 1" and OP/2/B/6500/053 Transfer and Dewatering of Contaminated Secondary Resin Unit 2".
- Removed Chemistry procedure OP/0/B/6500/072 "Operating Procedure for Filter HIC Operations" because it was deleted and is no longer needed.
APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES Rev 0 This appendix lists the approved vendors and their services and provides additional detail of requirements contained in other documents. (e.g., vendor contract, purchase order, etc.) Removal of this detail from the Corporate PCP minimizes the number of revisions to the technical portion of the manual due to the unpredictable nature of vendor ownership and commercial changes. The Corporate PCP still describes the approval process and requires PCP service vendors to be incorporated into the QA supplier program. This program utilizes industry QA audits to monitor and verify vendor performance against customer program requirements. A note has been added to the computerized Approved Supplier List to ensure PCP vendors are maintained in the program unless NGO Chemistry requests or approves their removal.
APPENDIX E PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS This section summarizes in a tabular format the required reviews and approvals for revisions to the PCP Manual. This was previously discussed in the body of the Corporate PCP. The approval process is described in APPENDIX F. Additional approval requirements were added for the new appendices based on their significance to the regulated portion of the manual. Additional reviews by RP will be documented for those parts of the manual affecting their programs. The previous PCP included only Chemistry and station manager reviews and approvals. The formal RP review is intended to broaden awareness of and input to PCP requirements and improve integration of the PCP with other related programs and activities.
APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS This appendix describes the administrative processes used to manage and publish the PCP Manual and the supporting documents required to maintain it. This information PCP APP H Page 4 of 10 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 0
SUMMARY
OF MARCH 2003 MANUAL REWRITE OVERVIEW was not contained in any detail in the prior versions of the PCP manual and has been added to address many of the document control issues identified in historical audits and recent PIPs. The process used to publish the manual electronically is described in detail to address SDQA requirements.
APPENDIX G WASTE PROCESSOR CHECKLIST This document is a template used by NGO RP and Duke Energy Environmental Health Services to evaluate waste services. The document was revised and added to the PCP to ensure that vendors who provide PCP services are evaluated against the Duke Energy PCP and approved by the NGO Chemistry organization.
APPENDIX H REVISION
SUMMARY
- LICENSEE INITIATED CHANGES This appendix incorporates revision summary information that in the past was contained in a transmittal letter. Incorporation of the revision discussion is consistent with the ODCM and other program documents where it is desirable to maintain a retrievable revision history.
1.3 Publication Changes The manual reorganization facilitates the use of current administrative processes and electronic publication. Electronic publication is more user-friendly and addresses the PCPs problematic history related to the obscurity of the hard copy PCP manual. It also enhances administrative controls needed to ensure the most current revisions are used.
(Ref: PIPs G-99-00349, G-00-0401)
The new PCP Manual is being published in the NEDL Portal under Electronic Licensing Library (ELL). Electronic publication enhances reference capability as described in NSD 228 APPENDIX B. In order to enhance the quality of NSD 228 applicability reviews, NSD 228 recommends that documents considered part of the licensing basis elements should be published electronically for easy and consistent utilization. The PCP and ODCM are licensing basis elements and historically have been grouped together in many Tech Spec and regulatory references. This revision aligns the PCP with the ODCM in its publication format, online accessibility, user interface, and administrative processes.
PCP APP H Page 5 of 10 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
Revision Summary - Licensee Initiated Changes PREVIOUS REVISION APPENDIX H REV 0
SUMMARY
OF MARCH 2003 MANUAL REWRITE OVERVIEW 1.4 Formatting Changes The new PCP has been reformatted using Nuclear Generation document font and formatting standards as described in the Procedure Writers' Guide and NSD 100. The Word template used is procopta.dot, modified to resemble the headings and hierarchy in the ODCM.
- 2. CORPORATE PCP CHANGES 2.1 Clarification of Programmatic linkage between Tech Specs, SLC and the PCP (Ref: PIPs C-99-05094, G-00-0401)
The references below contain specific PCP requirements. A list of these and other Duke Energy program documents that impact the PCP Manual was added to the Corporate PCP to ensure that future PCP Manual revisions and revisions to implementing procedures would include these documents in the review process.
2.1.1 The requirement to include revisions to the PCP in the Annual Radiological Effluents Report to the NRC is found in the following:
- Catawba SLC 16.11-16 Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report
- McGuire SLC 16.11.17 Radioactive Effluent Release Report 2.1.2 The Commitment to have a Process Control Program, description of its applicability, specific Remedial Actions and Surveillance Requirement are in the following SLCs:
- Catawba SLC 16.11-11 Solid Radioactive Waste
- McGuire SLC 16.11.11 Solid Radioactive Waste
- Oconee SLC 16.11.5 Solid Radioactive Waste The Solid Radioactive Waste SLCs listed above were submitted for revision during 2001-2002 to address inte-rsite program consistency issues, inaccurate references to the Process Control Program (PCP) applicability and content.
The wording in this PCP Manual rewrite incorporates the language in the SLC revision.
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OF MARCH 2003 MANUAL REWRITE OVERVIEW The SLC requirements were added to the Corporate PCP introduction to clarify SLC compliance. Those PCP requirements that specifically address SLC Remedial Actions and Surveillance Requirements in sections 10 and 11 are identified.
2.1.3 The following SLCs contain the commitment to have a Technical Review and Control Program covering the preparation, review, and approval of documents important to station operation, including review of PCP revisions by the NSRB:
- Catawba SLC 16.13.2 Technical Review and Control
- McGuire SLC 16.13.2 Technical Review and Control
- Oconee SLC 16.13.2 Technical Review and Control 2.2 New Sections in the Corporate PCP The following new sections were added to the Corporate PCP to consolidate and emphasize requirements under major headings that more closely align with the organization of other Duke Energy program guidance documents:
- Applicability
- Duke Energy Programmatic References
- Definitions This section lists definitions needed to interpret the PCP and consolidates them into one section.
- Responsibilities Specific responsibilities were clarified and the need for all site programs that impact the generation and management of liquid & wet radioactive wastes to support compliance with the PCP was emphasized.
- Administration of the PCP and Support Documents Consolidates all of the administrative requirements into one section and refers to the details contained in APPENDIX F.
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OF MARCH 2003 MANUAL REWRITE OVERVIEW
- Approval Process for QA Approved Suppliers This section describes and clarifies the linkage between existing Supply Chain processes and PCP compliance involving vendors. The incorporation of vendor PCP PREVIOUS REVISION APPENDIX H Rev 0 services into the QA Approved Suppliers List and its associated NUPIC QA Audit process is a critical component of maintaining required oversight of PCP compliance.
- PCP Requirements for Vendor Processes and Services This section consolidates vendor program and process requirements into one section.
2.3 PCP Retention Requirements Changes The record retention requirements were revised in the Duke Energy Information Retention Policy to align with other records that have long term litigation significance.
The PCP rewrite incorporates these changes in APPENDIX F. Archive requirements were expanded to include vendor documents used to implement the PCP requirements.
2.4 Vendor Names and Service Information Update (Ref: PIPs G-99-00349, C-01-02522)
The original version of the Corporate PCP was written when the only vendor services available were onsite mobile units that were interfaced with plant equipment and the final waste form was accomplished prior to shipping the waste offsite. Most current vendor services are offsite processes performed at the vendor location. To accommodate this, the discussion of Radwaste vendors was expanded to include offsite processing. Details of the vendor approval process and documentation requirements were enhanced and the interface with Supply Chain processes emphasized.
2.5 Changes in the Solidification Section The guidance for solidification was rewritten to be more of a guideline of the minimum content required for implementing procedures.
The technical requirements for solidification of liquid or wet wastes to meet regulatory requirements have not changed. This section was reorganized to provide an outline of the major process steps that must be included in solidification procedures to adequately address the PCP requirements for a solidification process. Redundant presentation of information due to the organization of the prior version was removed. (e.g., the PCP APP H Page 8 of 10 APP H Rev. 10 NEDL SDQA C
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H (Past Revision History)
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OF MARCH 2003 MANUAL REWRITE OVERVIEW Introduction chapter contained solidification discussion that was repeated in the Solidification section of the Corporate PCP chapter) Notation identifying requirements derived from SLC was added for clarity in developing or reviewing implementing procedures. Guidance was updated to incorporate vendor support.
2.6 Expanded Guidance for Dewatering (Ref: PIPs O-01-01067, G-00-0401)
The dewatering section, 11, in the new Corporate PCP) contains all of the requirements from the previous version, but was revised to clarify the distinctive requirements for dewatering of mechanical filters and media. The discussion of mechanical filter dewatering was expanded to clarify the distinction between dewatering filters to meet PCP requirements and removal of FSL from the filter disposal container. Requirements derived from SLC are identified for clarity in developing or reviewing implementing procedures. Guidance was updated to incorporate vendor support and lessons learned.
- 3. ADMINISTRATIVE PROCESS CHANGES Most of the processes used to administer the PCP changed during the rewrite of the PCP Manual.
This level of detail was not documented in the DPCo PCP. It was added to address the many administrative issues described in the PIPs listed above. APPENDIX F describes the requirements for administering the Process Control Program and the documents required to implement the program. It details the administrative processes used to implement several of the requirements contained in the Corporate PCP. The following list summarizes the major processes that are detailed in APPENDIX F.
Enclosure 6.1 PCP Manual Revision Publication Process This enclosure describes in detail the revision process in the electronic environment. Significant changes from the old process are:
- Electronic routing of the manual for review and approval
- Electronic approval using email responses to communicate approval. The email will be printed out and included in the archive of the revision as documentation of required approvals.
- Publication process using Scribe for user viewing in the NEDL Portal
- Process for transmittal of the PCP revisions to the NRC only once per year in the Annual Radioactive Effluents Report. Historically the PCP sections were transmitted to the NRC at the time they were revised to allow for page by page insertions in the hard copy manuals maintained by the NRC. The new process is similar to the process used for the ODCM.
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OF MARCH 2003 MANUAL REWRITE OVERVIEW Enclosure 6.2 Chemistry Distribution of Radwaste Vendor Documents A detailed administrative process for electronic publication, archival and incorporation of documents from approved suppliers comprises this enclosure. Although portions of this process have been used for the past two years, it is now documented in the manual and adds the archival requirements and process.
Enclosure 6.3 NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry This enclosure describes the process for evaluating vendor documents for technical impact to the PCP and implementing procedures. The basis for this process is NSD 319 Vendor Technical Information Program. It requires technical review by NGO and station Chemistry using a list of criteria from NSD 319 to determine if the changes in the document require any PCP related document revisions and documentation of the conclusions of the review in PIP.
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