ML16126A417

RW-AA-100, Rev. 11, Process Control Program for Radioactive Wastes

ML16126A417
Person / Time
Site:	Crane
Issue date:	04/29/2016
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML16126A414	List: ML16126A417 TMI-16-016, Combined 2015 Annual Radioactive Effluent Release Report
References
RW-AA-100, Rev 11
Download: ML16126A417 (14)

Text

'.

Exelon Confidential/Proprietary Generationw RW-AA-100 Revision 11 Page 1 of 13 Level.3 - lnfor'11ation Use PROCESS CONTROL PROGRAM FOR RADIOACTIVE WASTES

1.

PURPOSE 1.1.

• The purpose of the' Process* Control Program (PCP) is to:

1.1.1.

Establish the process and boundary conditions for the preparation of specific procedures for processing, sampling, analysis, packaging, storage, and shipment of solid radwaste in accordance with local, state, and federal requirements. (CM-1) 1.1.2.

Establish parameters which* will provide reasonable assurance that all Low Level Radioactive Wastes (LLRW), processed by the in-plant waste process systems on-site OR by on-site vendor supplied waste processing systems, meet the

• acceptance criteria to a Licensed Burial Facility, as required by 10CFR Part 20, 1 OCFR Part 61, 1 OCFR Part 71, 49CFR Parts 171-172, "Technical Position on Waste Form (Revision 1)" [1/91], "Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification" [5/83], and the Station Technical Specifications, as applicable.

1.1.3.

Provide reasonable assurance that waste placed in "on-'site storage" meets the requirements as addressed within the Safety Analysis Reports for the low level radwaste storage facilities for dry and/or processed wet waste.

2.

TERMS AND DEFINITIONS

2.1. Blending

The mixing of LLRW with different concentrations of radionu'clides, typically in an effort to create a relatively homogeneous mixtur~ for disposal.

2.2.

Classification Controlling Nuclides: One or more nuclides, listed in Table 1 or

.Table 2of10CFR61.55, whose concentration is the specific basis for the.

classification of the waste container. This could be *a single nuclide or multiple nuclides that make up >50% of the sum of the fractions.,

2.3. Compaction

When dry wastes such as paper, wood, plastic, cardboard,.

incinerator ash, and etc. are volume reduced through the use of a.compactor.

2.4.

Concentration Averaging: The averaging of the radionuclide concentrations for specific wastes or mixture of waste over the volume or weight of the waste.

2.5. Dewatering

The process of removing fluids from liquid waste streams to produce a waste form that meets the requirements of 1 OCFR Part 61 and applicable burial site criteria, s0.5% by volume when the waste is packaged to 'an "unstable" state, or s1 % by volume when the waste is packaged to a "stable" form.

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 2of13

2.6. Encapsulation

Encapsulation is the surrounding of a radioactive source or component with a nonradioactive material. Encapsulation involves a radioactive core surrounded by a non-radioactive matrix..

2.7.

High Integrity Container CHIC): A disposable container that is approved to the Requirements of 1 OCFR61. The use of HIC's is an alternative to solidification or encapsulation in a steel container to meet burial stability. HIC's are used to package dewatered liquid wastes, (e.g. filter cartridges, filter media, resin, sludges, etc), or dry active waste.

2.8.

Homogeneous Waste: Waste in which concentrations of radionuclides of concern are likely to approach uniformity in the c'ontext of reasonable fore*seeable intruder scenarios (This is because hot spots are a concern with respect to protection of an individual who may inadvertently intrude into the burial site).

2.9.

Incineration. RVR. and/or Glass Vitrification of Liquid or Solid: Dry or wet waste processed via incineration and/or thermal processing where the volume is reduced by thermal means meets 1 OCFR61 requirements.

2.10.

Liquid Waste Processing Systems: In-plant or vendor supplied processing systems consisting of equipment utilized for evaporation, filtration, demineralization, dewatering, compression dewatering, solidification, or reverse osmosis (RO) for the treatment of liquid wastes (such as Floor Drains, Chemical Drains and Equipment

• Drain inputs).

2.11.

Mixable Waste: Waste that is amenable to physical mixing to create relatively uniform radionuclide concentrations.

2.12.

Nuclides of Concern: A nuclide in the waste in concentrations greater than 1 % of

• the concentration of that nuclide listed in Table 1 of 1 OCFR61.. 55 or 1 % of the applicable class-dependent concentration of that nuclide in Table 2 of 1 OCFR61.55, Column 2 or 3.

2.13.

Process Control Program (PCP): The program which contains the current formulas, sampling, analysis, tests, and determinations to be made to ensure that processing and packaging *of solid radioactive waste based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure the waste meets the stabilization criteria specified in 1 OCFR Parts 20, 61 and 71, state regulations, and burial site requirements.

2.14.

Solidification: Liquid waste processed to either an unstable or stable form per 1 OCFR61 requirements. Waste solidified does not have to meet the 300-year free standing monolith criteria. Approved formulas, samples and tests do not have to meet NRC approval for wastes solidified* in a container meeting stability criteria (e.g.

High Integrity Container).

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 3of13 2.15.

Solidification Media: An approved media (e.g. Barnwell - vinyl ester styrene, cement, bitumen) when waste containing nuclides with greater than 5-year half lives is solidified in a container with activity greater than 1 micro curie/cc. Waste solidified in a HIC is approved by the commission meeting the 1 OCFR61 stabilization criteria, including 1 % free standing liquids by volume when the waste is packaged to a

• "stable" form and :s 0.5% when waste is packaged to an "unstable" form. The formulas, sampling, analysis, and test do not require NRC approval, because the HIC meets the stability criteria.

2.15.1.

Solidification to an unstable or stable state is performed by vendors, when applicable. Liquid waste solidified to meet stabilization criteria (1 OCFR61 and 01-91 Branch Technical Requirements) shall have documentation available that*

demonstrates that the process is approved by the NRC or disposal facility.

2.16.

Stabilization: Liquid waste processed to a "stable state" per 1 OCFR61

.Requirements. Established formulas, samples, and tests shall be approved by the NRC in order to meet solidification "stabilization" criteria. This processing method is currently not available, because the NRC recognizes that waste packed in a High Integrity Container meets the 300-year stabilization criteria. In the event that this processing method becomes an acceptable method, then the NRC shall approve the stabilization formulas, samples, tests, etc.

2.17.

Waste Streams: Consist of but are not limited to Filter media (powdered, bead resin and fibe_r),

Filter cartridges, Pre-coat body feed material, Contaminated charcoal, Fuel pool activated hardware, Oil Dry absorbent material added to a container to absorb liquids Fuel Pool Crud Sump and tank sludges, High activity filter cartridges, Concentrated liquids, Contaminated waste oil,

. Dried sewage or wastewater plant waste, Dry Active Waste (DAW): Waste such as filters, air filters, low activity cartridge filters, paper, wood, glass, plastic, cardboard, hoses, cloth, and metals, etc, which have become contaminated as a consequence of normal operating, housekeeping and maintenance activities.

Other radioactive waste generated from cleanup of inadverte-nt contamination.

3.

RESPONSIBILITIES 3.1.

Implementation of this Process Control Program (PCP) is described in procedures at each station and is the responsibility of the each site to implement.

Exelon Confidential/Proprietary

4.

MAIN BODY 4.1.

Process Control Program Requirements RW-AA-100 Revision 11 Page 4of13 4.1.1.

A change to this PCP (Radioactive Waste Treatment Systems) may be made provided that the change is reported as part of the annual radioactive effluent release report, Regulatory Guide 1.21, and is approved by the Plant Operations Review Committee (PORC).

4.1.2.

Changes become effective upon acceptance per station requirements.

4.1.3.

A solidification media, approved by the burial site, may be REQUIRED when liquid radwaste is solidified to a stable/unstable state.

4.1.4.

When processing liquid radwaste to meet solidification stability using a vendor supplied solidifica!ion system:

1.

If the vendor has its o'wn Quality Assurance (QA) Program, then the vendor shall ADHERE to its own QA Program and shall have SUBMITTED its process syste*m topical report to the NRC or agreement state.

2.

If the vendor does not HAVE its own Quality Assurance Program, then the vendor shall ADHERE to an approved Quality Assurance Topical Report standard belonging to the Station or to another approved vendor.

4.1.5.

The vendor processing system(s) is/are controlled per the following:

1.

A commercial vendor supplied processing system(s) may be USED for the processing of LLRW streams.

2.

Vendors that process liquid LLRW at the sites shall MEET applicable Quality Assurance Topical Report and Augmented Quality Requirements.

4.1.6.

Vendor processing system(s) operated at the site shall be OPERATED and CONTROLLED in accordance with vendor approved procedures or station procedures based upon vendor approved documents.

4.1.7.

All waste streams processed for burial or long term on-site storage shall MEET the waste classification and characteristics spetified in 1 OCFR Part 61.55, Part 61.56,

• the 5-83 Branch Technical Position for waste classification, and the applicable burial site acceptance criteria (for any burial site operating at the time the waste was processed).

4.1.8.

An Exelon Nuclear plant may store waste at another Exelon Nuclear plant, provided formal NRC approval has been RECEIVED for the transfer of waste.

Exelon Confidential/Proprietary

• 4.2.

• General Waste Processing Requirements RW-AA-100 Revision 11 Page 5of13 NOTE:.

On-site resin* processing involves tank mrxmg and settling, transferring 'to the station. or vendor processing system via resin water slurry or vacuuming into approved waste containers, and, when applicable, dewatering for burial.

• 4.2.1.

Ve~c!or resin beds may be USED for decontamination of plant systems, such as, SFP (Spent Fuel Pool), RWCU (reactor water cleanup), and SOC (Shut Down Cooling). These resins are then PROCESSED via the station or vendor processing system.

4.2.2.

Various drains and sump discharges will be COLLECTED in tanks or suitable containers for processing treatment. Water from these tanks may be SENT through a filter, demineralizer, concentrator or vendor supplied processing systems.

4.2.3.

Process waste (e.g. filter media, sludges, resin, etc) will be periodically DISCHARGED to the station or vendor processing system for onsite waste treatment or PACKAGED in containers for shipment to offsite vendor for volume reduction processing.

4.2.4.

Process water (e.g. chemical, floor. drain, equipment drain, etc.) may be SENT to

- either the site waste processing systems or vendor waste processing systems for further filtration, demineralization for plant re-use, or discharge.

4.2.5.

All dewatering and solidification/stabilization will be PERFORMED by either utility site personnel or by on-site vendors or will be PACKAGED and SHIPPED to an off-site vendor low-level radwaste processing facility.

4.2.6.

Dry Active Waste (DAW) will be HANDLED and PROCESSED per the following:

1.

DAW will be COLLECTED and SURVEYED and may be SORTED.for compactable and no~-compaptable wastes.

• 2.

DAW may'be packaged in containers to facilitate on-site pre-compadion and/or off-site vendor contract requirements.

3.

• DAW items may be S.URVEYED for release onsite or offsite when applicable.

4.

Contaminated filter cartridges will be PLACED into a HIC or will be ENCAPSULATED in an in-situ liner for disposal or SHIPPED to an offsite waste processor in drums, boxes or steel liners per the vendor site criteria for processing and disposal.

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 6of13 4.2.7.

Filtering devices using pre-coat media may be USEQ for the removal of suspended solids from liquid waste streams. The pre-coat material or cartridges from these devices may be routinely REMOVED from the filter vessel and discharged to a Filter Sludge Tank or Liner/HIC. Periodically, the filter sludge may be DISCHARGED to the vendor processing system for waste treatment onsite or PACKAGED in containers for shipment to offsite vendor for volume reduction processing.

4.2.8.

Activated hardware stored in the Spent Fuel Pools will be PROCESSED periodically

• using remote handling equipment and may then be PUT into a container for shipment or storage in the pool or loading the processed activated hardware into the Dry Cask storage system.

4.2.9.

High Integrity Containers (HIC):

1.

For disposal at Barnwell, vendors supplying HIC's to the station shall PROVIDE a copy of the HIC Certificate of Compliance, which details specific limitations on use of the HIC.

2.

For disposal at Clive or WCS, vendors supplying HIC's to the station shall P.ROVIDE a copy of the HIC Certificate of Conformance, which details specific limitations on use of the HIC.

3.

Vendors supplying HIC's to the station shall PROVIDE a handling procedure which establishes guidelines for the utilization of the HIC. These guidelines

• serve to protect the integrity of the HIC and ensure the HIC is h~ndled in accordance with the requirements of the Certificate of Compliance or

• Certificate of Conformance.

4.2.10.

Lubricants and oils contaminated as a consequence of normal operating and maintenance activities may be PROCESSED on-site (by incineration, for oils meeting 1 OCFR20.2004 andapplicable state requirements, or by an approved vendor process) or SHIPPED offsite (for incineration or other acceptable processing method).

4.2.11.

Former in-plant systems GE or Stock Drum Transfer Cart and Drum Storage Areas may be USED for higher dose DAW storage at Clinton, Dresden, Quad Cities, Braidwood and Byron.

4.2.12.

Certain waste, including flowable solids from holding pond, oily waste separator, cooling tower basin and emergency spray pond, may be disposed of onsite under the provisions of a 1 OCFR20.2002 permit. Specific r~quirements associated with the disposal shall be incorporated.into station implementing procedures. {CM-2)

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 7of13 4.2.13.

Cor:icentration averaging may be PERFORMED to combine LLRW having different concentrations of radionuclides to form a homogeneous mixture in accordance with the guidance in the NRC's Branch Technical Position on Concentration Averaging and Encapsulation-1995,. NRC-2011-0022:

For homogeneous waste types such as resins and filter media, the concentration of the mixture for classification purposes may be based on either the highest radionuclide *concentration in any of the individual, waste types contributing to the mixture or the volumetric or weight-averaged nuclide concentrations in the mixture provided that the concentrations of the individual waste type contributors to the mixture are within a factor of 10 of the average concentration of ttie resulting mixture. (NOTE: a designed collection of homogeneous waste types (from different sources within a facility) is not considered 'mixing' and the concentration for classification purposes may be the average concentration of the combination).

For non-homogeneous waste types such as activated metals, cartridge filters or components incorporating radioactivity in their design, the concentration should be determined from the total weight or displaced volume (excluding.

major void spaces) of the component. Mixtures of components in a disposal container is permissible. Concentration averaging of a mixture of components of similar types can be performed in accordance with the NRC's Branch Technical Position on Concentration Averaging and Encapsulation and any State or Disposal Site specific requirements.

4.2.14.

Blending may be PERFORMED for routine LLRW such as resins and filter. media in accordance with the* guidance in the NRC's Branch Technical Position on Concentration Averaging and Encapsulation as further clarified in SECY 2010-0043.

The concentration of the mixture may be determined bas.ed on the total activity of all components in the mixture divided by the total volume or mass of the mixture.

Reasonable effort should be made to mix blended LLRW so that activity is;evenly distrib.uted.

4.2.15.

Encapsulation may be PERFORMED for routine wastes such as filters, filter cartridges, or sealed sources centered in ~n encapsulated mass, in accorqance with the guidance in the NRC's Branch Technical Position on.Concentration Averaging and Encapsulation. Classification may be based on the overall volume of the final solidified mass provided that; The minimum solidified volume or mass sh9uld be reasonably difficult to move by hand.

The maximum solidified volume or mass used for determining 1

concentration for any single discrete source should be no more than 0.2 m3 or 500Kg (typically 55-gallon drum).

The maximum amount of gamma-emitting radioactivity or radioactive material is <0.02 mrem/hr on the surface of the encapsulation over a 500-year decay period.

The maximum amount of any radionuclide in a single encapsulation, when averaged over the waste and *encapsulating media, does not exceed the

Exelon Confidential/Proprietary maximum concentration limits for Class C waste.

RW-AA-100 Revision 11 Page 8of13 Written procedures should be established to ensure that the radiation source(s) is reasonably centered (or distributed} within the encapsulating media.

All other disposal facility requirements for encapsulated material are met.

4.3.

Burial Site Requirements 4.3.1.

Waste sent directly to burial shall COMPLY with the applicable parts of 49CFR171-172, 1 OCFR61, 1 OCFR71, and the acceptance criteria for the applicable burial site.

4.4.

Shipping and Inspection Requirements 4.4.1.

All shipping/storage containers shall be INSPECTED, as required by station procedures, for compliance with applicable requirements (Department of Transportation (DOT), Nuclear Regulatory Commission (NRG), station, on-site storage, and/or burial site requirements) prior to use.

4.4.2.

Containers of solidified liquid waste shall be INSPECTED for solidification quality and/or dewatering requirements per the burial site, offsite vendor acceptance, or station acceptance criteria, as applicable.

4.4.3.

Shipments sent to an off site processor shall be INSPECTED to ensure that the applicable processor's waste acceptance criteria are being met.

4.4.4.

Shipments sent for off site storag~ shall MEET the storage site's waste acceptance criteria.

4.5.

Inspection and Corrective Action

• 4.5.1.

Inspection results that indicate non-compliance with applicable NRC, State, vendor, or site requirements shall be IDENTIFIED and TRACKED through the Corrective Action Program.

4.5.2.

Administrative controls for preventing unsatisfactory waste forms from being released for shipment are described in applicable station procedures. If the provisions of the Process Control Program are not satisfied, then SUSPEND shipments of defectively packaged radioactive waste from the site. (CM-1) 4.5.3.

If freestanding water or solidification not meeting program requirements is observed, then samples of the particular series of batches shall be TAKEN to determine the cause. Additional samples shall be TAKEN, as warranted, to ensure that no freestanding water is present and solidification require.ments are maintained.

Exelon Confidential/Proprietary 4.6.

Procedure and Process Reviews RW-AA-100 R.evision 11 Page 9of13 4.6.1.

The Exelon Nuclear Process Control Program and subsequent changes (other than editorial/minor changes) shall be REVIEWED and APPROVED in accordance with the station procedures, plant-specific Technical Specifications (Tech Spec),

Technical Requirements Manual (T&RM), Operation Requirements Manual (ORM),

as applicable, for the respective station and LS-AA-106. Changes to the Licensees Controlled Documents, UFSAR, ORM, or TRM are controlled by the provisions of 1 OCFR 50.59.

4.6.2.

Any changes to the PCP shall. be reviewed to determine if reportability is required in the Annual Radiological Effluent Release Report (ARERR). The Radwaste Specialist shall ensure* correct information is SUBMITTED to the ODCM program owner prior to submittal of the ARERR.

4.6.3.

Procedures shall be IMPLEMENTED as follows:

Station processes or other vendor waste processing/operating procedures shall be technically reviewed and approved per Rl\\,ll-AA-102-1006.

Procedures related to waste manifests, shipment inspections, and container activity determinations are CONTROLLED by Radiation Protection Standard Procedures (RP-AA-600 Series).

Site waste processing IS CONTROLLED by site operc;itiilg procedures.

Liquid processed by vendor equipment shall.be PERFORMED in accordance with vendor procedures.*

The dewatering procedures implemented by Vendor for the purpose of compliance to the Process Control Program SHALL BE REVIEWED and APPROVED in accordance with the plant specific TRM or ORM (either Current Technical Specifications (CTS) or Improved Technical SpeGifications (ITS), as applicable for the respective stations).

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 10of13 4.7.

Waste Types. Point of Generation. and Processing Method Methods of processing and individual vendors may CHAN.GE due to changing financial and regulatory options. The table below is a representative sample. It is not intended be all encompassing.

WASTE POINTS OF GENERATION AVAILABLE WASTE STREAM PROCESSING METHODS Bead Systems - Fuel Pool, Condensate, Dewatering,* solidification to an Resin Reactor Water Cleanup, Slowdown, unstable/stable state Equipment Drain, Chemical and Thermal Processing Volume Control Systems, Floor Drain, Maximum Recycle, Slowdown, Boric Free Release.to a Land Fill Acid Recycling System, Vendor Supplied Processing Systems, and Portable Demin System Powdered Systems!.. (Condensate System, Floor Dewatering, solidification to an Resin Drain/Equipment Drain filtration, Fuel unstable/stable state Pool)

Thermal ProcessinQ

• Concentra Waste generated from Site Solidification to an unstable/stable ted Waste Evaporators resulting typically from the state Floor Drain and Equipment Drain Thermal Processing Systems Sludge Sedimentation resulting from various Dewatering, solidification to an sumps, condensers, tanks, cooling unstable/stable state tower, emergency spray pond, holding Thermal Processing pond, and oily waste separators Evaporation on-site or at an offsite processor On-site disposal per 1 OCFR20.2002 permit Filter Systems - Floor/Equipment Drains, Dewatering, solidification to an cartridges Fuel Pool; cartridge filters are typically unstable/stable state generated from clean up activities Processed by a vendor for volume within the fuel pool, torus, etc reduction Dry Active Paper, wood, plastic, rubber, glass, Decon/Sorting for Free Release Waste metal, and etc. resulting from daily Compaction/Super-compaction plant activities Thermal Processing by Incineration or glass vitrification Sorting for Free Release Metal melting to an ingot Contamin Oil contaminated with radioactive Solidification unstable state ated Oil materials from any in-plant system.

Thermal Processing by Incineration Free Release for recvclinQ

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 11 of 13 WASTE POINTS OF GENERATION AVAILABLE WASTE STREAM PROCESSING METHODS Drying Sewage Treatment and Waste Water Free release to a landfill or burial Bed Treatment Facilities Sludqe Metals See DAW*

See DAW Irradiated Fuel Pool, Reactor Components Volume Reduction for packaging Hardware efficiencies -

5.

DOCUMENTATION 5.1.

Records of reviews performed shall be retained for the duration of the unit operating license. This documentation shall contain:

1.

Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change, and

2.

A determination which documents that the change will maintain the overall conformance of waste products to Federal (1 OCFR61 and the Branch Technical Position), State, or other applicable requirements, including applicable burial site criteria.

6.

REFERENCES 6.1.

Station Commitments:

6.1.1.

Peach Bottom CM-1, T03819, Letter from G.A. Hunger, Jr., dated Sept. 29 1994, transmitting TSCR 93-16 (Improved Technical Specifications). (Step 1.1.1, 4.5.2) 6.1.2.

Limerick CM-2, T03896, 1 OCFR20.2002 permit granted to Limerick via letter dated July 10, 1996. (Step 4.2.12) 6.2.

• Technical Specifications:

6.2.1.

The details contained in Current Tech Specs (CTS) or Improved Technical, Specifications (ITS), as applicable, in regard to the Proc~ss Control Program (PCP),

are to b~ relocated to the Licensee Controlled Documen_ts. Some facilities have elected to relocate these details into the Operational Requirements Manual (ORM).

Relocation of the description of the PCP from the CTS or ITS does not affect the safe operation of the facility. Therefore, the relocation details are not required to be in the CTS or th.e ITS to provide adequate protection of the public health and safety.

6.3.

UFSAR 6.3.1.

Braidwood UFSAR, Section 11.4, Solid Waste Management System

Exelon Confidential/Proprietary 6.3.2.

Byron UFSAR Section 11.4, Solid Waste Management System 6*.3.3.

Calvert Cliffs UFSAR Section 11.1.2.3 Solid Waste Processing System 6.3.4.

Clinton USAR Table 11.4, Solid Waste Management System 6.3.5.

Dresden UFSAR Section 11.4, Waste Management System 6.3.6.

Ft. Calhoun USAR Section 11-03, Radiological Effluent Requirements 6.3.7.

Ginna UFSAR Section 11.4, Solid Waste Management System

. RW-AA-100 Revision 11 Page 12of13 6.3.8.

LaSalle UFSAR Section 11.4.2.7 Storage areas, Table 12.3.6-IRSF Storage Area 6.3.9.

Limerick UFSAR Section11.4, Solid Waste Management 6.3.10.

Nine Mile Point Unit 1 UFSAR Section 2.3 Solid Waste System*

6.3.11.

Nine Mile Point Unit 2 UFSAR Section 11.4, Solid Waste Management System 6.3.12.

Oyster Creek UFSAR Section 11.4, Solid Waste Management System 6.3.13.

Peach Bottom UFSAR Section 9.0, Radioactive Waste Systems 6.3.14.

Quad Cities UFSAR Section 11.4.4.5, Interim Radwaste Storage Facility 6.3.15.

Three Mile Island UFSAR Section 11.2, Radioactive Waste Disposal Systems Summary 6.4.

Writers'

References:

Amendment No. 202 to Facility Operating License No. NPF-11 and Amendment No. 189 to Facility Operating License (FOL) No. NPF-18 for the LaSalle County Station (LSCS), Units 1 and 2 Code of Federal Regulations: 10 CFR Part 20, Part 61, Part 71, 49 CFR Parts 171-172 I.E. Circular 80.18, 10CFR 50.59 Safety Evaluation for Chang~s to Radioactive Waste Treatment Systems Low Level Waste Licensing Branch Technical Position on Radioactive Waste Classification, May 1983 NRC Branch Technical Position on Blending of Low-Level Radioactive Waste, SECY-10-0043 NRC Conce.ntration Averaging and Encapsulation Branch Technical Position, NRC-2011-0022 Regulatory Guide 1.21, Measuring Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants Technical Position on Waste Form (Revision 1 ), January 1991

Exelon Confidential/Proprietary 6.5.

Users'

References:

CY-AA-170-2000, Annual Radioactive Effluent Release Report LS-AA-106.* Plant Operations Review Committee Quality Assurance Program (QATR)

RM-AA-101, Records Management Program RM-AA-102-1006, Processing Vendor Documents RP-AA-600 Series, Radioactive Material/Waste Shipments

7.

ATTACHMENTS - None RW-AA-100 Revision 11 Page 13of13

Exelon Confidential/Proprietary Generationw RW-AA-100 Revision 11 Page 1 of 13 Level.3 - lnfor'11ation Use PROCESS CONTROL PROGRAM FOR RADIOACTIVE WASTES

1.

PURPOSE 1.1.

• The purpose of the' Process* Control Program (PCP) is to:

1.1.1.

Establish the process and boundary conditions for the preparation of specific procedures for processing, sampling, analysis, packaging, storage, and shipment of solid radwaste in accordance with local, state, and federal requirements. (CM-1) 1.1.2.

Establish parameters which* will provide reasonable assurance that all Low Level Radioactive Wastes (LLRW), processed by the in-plant waste process systems on-site OR by on-site vendor supplied waste processing systems, meet the

• acceptance criteria to a Licensed Burial Facility, as required by 10CFR Part 20, 1 OCFR Part 61, 1 OCFR Part 71, 49CFR Parts 171-172, "Technical Position on Waste Form (Revision 1)" [1/91], "Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification" [5/83], and the Station Technical Specifications, as applicable.

1.1.3.

Provide reasonable assurance that waste placed in "on-'site storage" meets the requirements as addressed within the Safety Analysis Reports for the low level radwaste storage facilities for dry and/or processed wet waste.

2.

TERMS AND DEFINITIONS

2.1. Blending

The mixing of LLRW with different concentrations of radionu'clides, typically in an effort to create a relatively homogeneous mixtur~ for disposal.

2.2.

Classification Controlling Nuclides: One or more nuclides, listed in Table 1 or

.Table 2of10CFR61.55, whose concentration is the specific basis for the.

classification of the waste container. This could be *a single nuclide or multiple nuclides that make up >50% of the sum of the fractions.,

2.3. Compaction

When dry wastes such as paper, wood, plastic, cardboard,.

incinerator ash, and etc. are volume reduced through the use of a.compactor.

2.4.

Concentration Averaging: The averaging of the radionuclide concentrations for specific wastes or mixture of waste over the volume or weight of the waste.

2.5. Dewatering

The process of removing fluids from liquid waste streams to produce a waste form that meets the requirements of 1 OCFR Part 61 and applicable burial site criteria, s0.5% by volume when the waste is packaged to 'an "unstable" state, or s1 % by volume when the waste is packaged to a "stable" form.

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 2of13

2.6. Encapsulation

Encapsulation is the surrounding of a radioactive source or component with a nonradioactive material. Encapsulation involves a radioactive core surrounded by a non-radioactive matrix..

2.7.

High Integrity Container CHIC): A disposable container that is approved to the Requirements of 1 OCFR61. The use of HIC's is an alternative to solidification or encapsulation in a steel container to meet burial stability. HIC's are used to package dewatered liquid wastes, (e.g. filter cartridges, filter media, resin, sludges, etc), or dry active waste.

2.8.

Homogeneous Waste: Waste in which concentrations of radionuclides of concern are likely to approach uniformity in the c'ontext of reasonable fore*seeable intruder scenarios (This is because hot spots are a concern with respect to protection of an individual who may inadvertently intrude into the burial site).

2.9.

Incineration. RVR. and/or Glass Vitrification of Liquid or Solid: Dry or wet waste processed via incineration and/or thermal processing where the volume is reduced by thermal means meets 1 OCFR61 requirements.

2.10.

Liquid Waste Processing Systems: In-plant or vendor supplied processing systems consisting of equipment utilized for evaporation, filtration, demineralization, dewatering, compression dewatering, solidification, or reverse osmosis (RO) for the treatment of liquid wastes (such as Floor Drains, Chemical Drains and Equipment

• Drain inputs).

2.11.

Mixable Waste: Waste that is amenable to physical mixing to create relatively uniform radionuclide concentrations.

2.12.

Nuclides of Concern: A nuclide in the waste in concentrations greater than 1 % of

• the concentration of that nuclide listed in Table 1 of 1 OCFR61.. 55 or 1 % of the applicable class-dependent concentration of that nuclide in Table 2 of 1 OCFR61.55, Column 2 or 3.

2.13.

Process Control Program (PCP): The program which contains the current formulas, sampling, analysis, tests, and determinations to be made to ensure that processing and packaging *of solid radioactive waste based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure the waste meets the stabilization criteria specified in 1 OCFR Parts 20, 61 and 71, state regulations, and burial site requirements.

2.14.

Solidification: Liquid waste processed to either an unstable or stable form per 1 OCFR61 requirements. Waste solidified does not have to meet the 300-year free standing monolith criteria. Approved formulas, samples and tests do not have to meet NRC approval for wastes solidified* in a container meeting stability criteria (e.g.

High Integrity Container).

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 3of13 2.15.

Solidification Media: An approved media (e.g. Barnwell - vinyl ester styrene, cement, bitumen) when waste containing nuclides with greater than 5-year half lives is solidified in a container with activity greater than 1 micro curie/cc. Waste solidified in a HIC is approved by the commission meeting the 1 OCFR61 stabilization criteria, including 1 % free standing liquids by volume when the waste is packaged to a

• "stable" form and :s 0.5% when waste is packaged to an "unstable" form. The formulas, sampling, analysis, and test do not require NRC approval, because the HIC meets the stability criteria.

2.15.1.

Solidification to an unstable or stable state is performed by vendors, when applicable. Liquid waste solidified to meet stabilization criteria (1 OCFR61 and 01-91 Branch Technical Requirements) shall have documentation available that*

demonstrates that the process is approved by the NRC or disposal facility.

2.16.

Stabilization: Liquid waste processed to a "stable state" per 1 OCFR61

.Requirements. Established formulas, samples, and tests shall be approved by the NRC in order to meet solidification "stabilization" criteria. This processing method is currently not available, because the NRC recognizes that waste packed in a High Integrity Container meets the 300-year stabilization criteria. In the event that this processing method becomes an acceptable method, then the NRC shall approve the stabilization formulas, samples, tests, etc.

2.17.

Waste Streams: Consist of but are not limited to Filter media (powdered, bead resin and fibe_r),

Filter cartridges, Pre-coat body feed material, Contaminated charcoal, Fuel pool activated hardware, Oil Dry absorbent material added to a container to absorb liquids Fuel Pool Crud Sump and tank sludges, High activity filter cartridges, Concentrated liquids, Contaminated waste oil,

. Dried sewage or wastewater plant waste, Dry Active Waste (DAW): Waste such as filters, air filters, low activity cartridge filters, paper, wood, glass, plastic, cardboard, hoses, cloth, and metals, etc, which have become contaminated as a consequence of normal operating, housekeeping and maintenance activities.

Other radioactive waste generated from cleanup of inadverte-nt contamination.

3.

RESPONSIBILITIES 3.1.

Implementation of this Process Control Program (PCP) is described in procedures at each station and is the responsibility of the each site to implement.

Exelon Confidential/Proprietary

4.

MAIN BODY 4.1.

Process Control Program Requirements RW-AA-100 Revision 11 Page 4of13 4.1.1.

A change to this PCP (Radioactive Waste Treatment Systems) may be made provided that the change is reported as part of the annual radioactive effluent release report, Regulatory Guide 1.21, and is approved by the Plant Operations Review Committee (PORC).

4.1.2.

Changes become effective upon acceptance per station requirements.

4.1.3.

A solidification media, approved by the burial site, may be REQUIRED when liquid radwaste is solidified to a stable/unstable state.

4.1.4.

When processing liquid radwaste to meet solidification stability using a vendor supplied solidifica!ion system:

1.

If the vendor has its o'wn Quality Assurance (QA) Program, then the vendor shall ADHERE to its own QA Program and shall have SUBMITTED its process syste*m topical report to the NRC or agreement state.

2.

If the vendor does not HAVE its own Quality Assurance Program, then the vendor shall ADHERE to an approved Quality Assurance Topical Report standard belonging to the Station or to another approved vendor.

4.1.5.

The vendor processing system(s) is/are controlled per the following:

1.

A commercial vendor supplied processing system(s) may be USED for the processing of LLRW streams.

2.

Vendors that process liquid LLRW at the sites shall MEET applicable Quality Assurance Topical Report and Augmented Quality Requirements.

4.1.6.

Vendor processing system(s) operated at the site shall be OPERATED and CONTROLLED in accordance with vendor approved procedures or station procedures based upon vendor approved documents.

4.1.7.

All waste streams processed for burial or long term on-site storage shall MEET the waste classification and characteristics spetified in 1 OCFR Part 61.55, Part 61.56,

• the 5-83 Branch Technical Position for waste classification, and the applicable burial site acceptance criteria (for any burial site operating at the time the waste was processed).

4.1.8.

An Exelon Nuclear plant may store waste at another Exelon Nuclear plant, provided formal NRC approval has been RECEIVED for the transfer of waste.

Exelon Confidential/Proprietary

• 4.2.

• General Waste Processing Requirements RW-AA-100 Revision 11 Page 5of13 NOTE:.

On-site resin* processing involves tank mrxmg and settling, transferring 'to the station. or vendor processing system via resin water slurry or vacuuming into approved waste containers, and, when applicable, dewatering for burial.

• 4.2.1.

Ve~c!or resin beds may be USED for decontamination of plant systems, such as, SFP (Spent Fuel Pool), RWCU (reactor water cleanup), and SOC (Shut Down Cooling). These resins are then PROCESSED via the station or vendor processing system.

4.2.2.

Various drains and sump discharges will be COLLECTED in tanks or suitable containers for processing treatment. Water from these tanks may be SENT through a filter, demineralizer, concentrator or vendor supplied processing systems.

4.2.3.

Process waste (e.g. filter media, sludges, resin, etc) will be periodically DISCHARGED to the station or vendor processing system for onsite waste treatment or PACKAGED in containers for shipment to offsite vendor for volume reduction processing.

4.2.4.

Process water (e.g. chemical, floor. drain, equipment drain, etc.) may be SENT to

- either the site waste processing systems or vendor waste processing systems for further filtration, demineralization for plant re-use, or discharge.

4.2.5.

All dewatering and solidification/stabilization will be PERFORMED by either utility site personnel or by on-site vendors or will be PACKAGED and SHIPPED to an off-site vendor low-level radwaste processing facility.

4.2.6.

Dry Active Waste (DAW) will be HANDLED and PROCESSED per the following:

1.

DAW will be COLLECTED and SURVEYED and may be SORTED.for compactable and no~-compaptable wastes.

• 2.

DAW may'be packaged in containers to facilitate on-site pre-compadion and/or off-site vendor contract requirements.

3.

• DAW items may be S.URVEYED for release onsite or offsite when applicable.

4.

Contaminated filter cartridges will be PLACED into a HIC or will be ENCAPSULATED in an in-situ liner for disposal or SHIPPED to an offsite waste processor in drums, boxes or steel liners per the vendor site criteria for processing and disposal.

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 6of13 4.2.7.

Filtering devices using pre-coat media may be USEQ for the removal of suspended solids from liquid waste streams. The pre-coat material or cartridges from these devices may be routinely REMOVED from the filter vessel and discharged to a Filter Sludge Tank or Liner/HIC. Periodically, the filter sludge may be DISCHARGED to the vendor processing system for waste treatment onsite or PACKAGED in containers for shipment to offsite vendor for volume reduction processing.

4.2.8.

Activated hardware stored in the Spent Fuel Pools will be PROCESSED periodically

• using remote handling equipment and may then be PUT into a container for shipment or storage in the pool or loading the processed activated hardware into the Dry Cask storage system.

4.2.9.

High Integrity Containers (HIC):

1.

For disposal at Barnwell, vendors supplying HIC's to the station shall PROVIDE a copy of the HIC Certificate of Compliance, which details specific limitations on use of the HIC.

2.

For disposal at Clive or WCS, vendors supplying HIC's to the station shall P.ROVIDE a copy of the HIC Certificate of Conformance, which details specific limitations on use of the HIC.

3.

Vendors supplying HIC's to the station shall PROVIDE a handling procedure which establishes guidelines for the utilization of the HIC. These guidelines

• serve to protect the integrity of the HIC and ensure the HIC is h~ndled in accordance with the requirements of the Certificate of Compliance or

• Certificate of Conformance.

4.2.10.

Lubricants and oils contaminated as a consequence of normal operating and maintenance activities may be PROCESSED on-site (by incineration, for oils meeting 1 OCFR20.2004 andapplicable state requirements, or by an approved vendor process) or SHIPPED offsite (for incineration or other acceptable processing method).

4.2.11.

Former in-plant systems GE or Stock Drum Transfer Cart and Drum Storage Areas may be USED for higher dose DAW storage at Clinton, Dresden, Quad Cities, Braidwood and Byron.

4.2.12.

Certain waste, including flowable solids from holding pond, oily waste separator, cooling tower basin and emergency spray pond, may be disposed of onsite under the provisions of a 1 OCFR20.2002 permit. Specific r~quirements associated with the disposal shall be incorporated.into station implementing procedures. {CM-2)

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 7of13 4.2.13.

Cor:icentration averaging may be PERFORMED to combine LLRW having different concentrations of radionuclides to form a homogeneous mixture in accordance with the guidance in the NRC's Branch Technical Position on Concentration Averaging and Encapsulation-1995,. NRC-2011-0022:

For homogeneous waste types such as resins and filter media, the concentration of the mixture for classification purposes may be based on either the highest radionuclide *concentration in any of the individual, waste types contributing to the mixture or the volumetric or weight-averaged nuclide concentrations in the mixture provided that the concentrations of the individual waste type contributors to the mixture are within a factor of 10 of the average concentration of ttie resulting mixture. (NOTE: a designed collection of homogeneous waste types (from different sources within a facility) is not considered 'mixing' and the concentration for classification purposes may be the average concentration of the combination).

For non-homogeneous waste types such as activated metals, cartridge filters or components incorporating radioactivity in their design, the concentration should be determined from the total weight or displaced volume (excluding.

major void spaces) of the component. Mixtures of components in a disposal container is permissible. Concentration averaging of a mixture of components of similar types can be performed in accordance with the NRC's Branch Technical Position on Concentration Averaging and Encapsulation and any State or Disposal Site specific requirements.

4.2.14.

Blending may be PERFORMED for routine LLRW such as resins and filter. media in accordance with the* guidance in the NRC's Branch Technical Position on Concentration Averaging and Encapsulation as further clarified in SECY 2010-0043.

The concentration of the mixture may be determined bas.ed on the total activity of all components in the mixture divided by the total volume or mass of the mixture.

Reasonable effort should be made to mix blended LLRW so that activity is;evenly distrib.uted.

4.2.15.

Encapsulation may be PERFORMED for routine wastes such as filters, filter cartridges, or sealed sources centered in ~n encapsulated mass, in accorqance with the guidance in the NRC's Branch Technical Position on.Concentration Averaging and Encapsulation. Classification may be based on the overall volume of the final solidified mass provided that; The minimum solidified volume or mass sh9uld be reasonably difficult to move by hand.

The maximum solidified volume or mass used for determining 1

concentration for any single discrete source should be no more than 0.2 m3 or 500Kg (typically 55-gallon drum).

The maximum amount of gamma-emitting radioactivity or radioactive material is <0.02 mrem/hr on the surface of the encapsulation over a 500-year decay period.

The maximum amount of any radionuclide in a single encapsulation, when averaged over the waste and *encapsulating media, does not exceed the

Exelon Confidential/Proprietary maximum concentration limits for Class C waste.

RW-AA-100 Revision 11 Page 8of13 Written procedures should be established to ensure that the radiation source(s) is reasonably centered (or distributed} within the encapsulating media.

All other disposal facility requirements for encapsulated material are met.

4.3.

Burial Site Requirements 4.3.1.

Waste sent directly to burial shall COMPLY with the applicable parts of 49CFR171-172, 1 OCFR61, 1 OCFR71, and the acceptance criteria for the applicable burial site.

4.4.

Shipping and Inspection Requirements 4.4.1.

All shipping/storage containers shall be INSPECTED, as required by station procedures, for compliance with applicable requirements (Department of Transportation (DOT), Nuclear Regulatory Commission (NRG), station, on-site storage, and/or burial site requirements) prior to use.

4.4.2.

Containers of solidified liquid waste shall be INSPECTED for solidification quality and/or dewatering requirements per the burial site, offsite vendor acceptance, or station acceptance criteria, as applicable.

4.4.3.

Shipments sent to an off site processor shall be INSPECTED to ensure that the applicable processor's waste acceptance criteria are being met.

4.4.4.

Shipments sent for off site storag~ shall MEET the storage site's waste acceptance criteria.

4.5.

Inspection and Corrective Action

• 4.5.1.

Inspection results that indicate non-compliance with applicable NRC, State, vendor, or site requirements shall be IDENTIFIED and TRACKED through the Corrective Action Program.

4.5.2.

Administrative controls for preventing unsatisfactory waste forms from being released for shipment are described in applicable station procedures. If the provisions of the Process Control Program are not satisfied, then SUSPEND shipments of defectively packaged radioactive waste from the site. (CM-1) 4.5.3.

If freestanding water or solidification not meeting program requirements is observed, then samples of the particular series of batches shall be TAKEN to determine the cause. Additional samples shall be TAKEN, as warranted, to ensure that no freestanding water is present and solidification require.ments are maintained.

Exelon Confidential/Proprietary 4.6.

Procedure and Process Reviews RW-AA-100 R.evision 11 Page 9of13 4.6.1.

The Exelon Nuclear Process Control Program and subsequent changes (other than editorial/minor changes) shall be REVIEWED and APPROVED in accordance with the station procedures, plant-specific Technical Specifications (Tech Spec),

Technical Requirements Manual (T&RM), Operation Requirements Manual (ORM),

as applicable, for the respective station and LS-AA-106. Changes to the Licensees Controlled Documents, UFSAR, ORM, or TRM are controlled by the provisions of 1 OCFR 50.59.

4.6.2.

Any changes to the PCP shall. be reviewed to determine if reportability is required in the Annual Radiological Effluent Release Report (ARERR). The Radwaste Specialist shall ensure* correct information is SUBMITTED to the ODCM program owner prior to submittal of the ARERR.

4.6.3.

Procedures shall be IMPLEMENTED as follows:

Station processes or other vendor waste processing/operating procedures shall be technically reviewed and approved per Rl\\,ll-AA-102-1006.

Procedures related to waste manifests, shipment inspections, and container activity determinations are CONTROLLED by Radiation Protection Standard Procedures (RP-AA-600 Series).

Site waste processing IS CONTROLLED by site operc;itiilg procedures.

Liquid processed by vendor equipment shall.be PERFORMED in accordance with vendor procedures.*

The dewatering procedures implemented by Vendor for the purpose of compliance to the Process Control Program SHALL BE REVIEWED and APPROVED in accordance with the plant specific TRM or ORM (either Current Technical Specifications (CTS) or Improved Technical SpeGifications (ITS), as applicable for the respective stations).

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 10of13 4.7.

Waste Types. Point of Generation. and Processing Method Methods of processing and individual vendors may CHAN.GE due to changing financial and regulatory options. The table below is a representative sample. It is not intended be all encompassing.

WASTE POINTS OF GENERATION AVAILABLE WASTE STREAM PROCESSING METHODS Bead Systems - Fuel Pool, Condensate, Dewatering,* solidification to an Resin Reactor Water Cleanup, Slowdown, unstable/stable state Equipment Drain, Chemical and Thermal Processing Volume Control Systems, Floor Drain, Maximum Recycle, Slowdown, Boric Free Release.to a Land Fill Acid Recycling System, Vendor Supplied Processing Systems, and Portable Demin System Powdered Systems!.. (Condensate System, Floor Dewatering, solidification to an Resin Drain/Equipment Drain filtration, Fuel unstable/stable state Pool)

Thermal ProcessinQ

• Concentra Waste generated from Site Solidification to an unstable/stable ted Waste Evaporators resulting typically from the state Floor Drain and Equipment Drain Thermal Processing Systems Sludge Sedimentation resulting from various Dewatering, solidification to an sumps, condensers, tanks, cooling unstable/stable state tower, emergency spray pond, holding Thermal Processing pond, and oily waste separators Evaporation on-site or at an offsite processor On-site disposal per 1 OCFR20.2002 permit Filter Systems - Floor/Equipment Drains, Dewatering, solidification to an cartridges Fuel Pool; cartridge filters are typically unstable/stable state generated from clean up activities Processed by a vendor for volume within the fuel pool, torus, etc reduction Dry Active Paper, wood, plastic, rubber, glass, Decon/Sorting for Free Release Waste metal, and etc. resulting from daily Compaction/Super-compaction plant activities Thermal Processing by Incineration or glass vitrification Sorting for Free Release Metal melting to an ingot Contamin Oil contaminated with radioactive Solidification unstable state ated Oil materials from any in-plant system.

Thermal Processing by Incineration Free Release for recvclinQ

Exelon Confidential/Proprietary RW-AA-100 Revision 11 Page 11 of 13 WASTE POINTS OF GENERATION AVAILABLE WASTE STREAM PROCESSING METHODS Drying Sewage Treatment and Waste Water Free release to a landfill or burial Bed Treatment Facilities Sludqe Metals See DAW*

See DAW Irradiated Fuel Pool, Reactor Components Volume Reduction for packaging Hardware efficiencies -

5.

DOCUMENTATION 5.1.

Records of reviews performed shall be retained for the duration of the unit operating license. This documentation shall contain:

1.

Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change, and

2.

A determination which documents that the change will maintain the overall conformance of waste products to Federal (1 OCFR61 and the Branch Technical Position), State, or other applicable requirements, including applicable burial site criteria.

6.

REFERENCES 6.1.

Station Commitments:

6.1.1.

Peach Bottom CM-1, T03819, Letter from G.A. Hunger, Jr., dated Sept. 29 1994, transmitting TSCR 93-16 (Improved Technical Specifications). (Step 1.1.1, 4.5.2) 6.1.2.

Limerick CM-2, T03896, 1 OCFR20.2002 permit granted to Limerick via letter dated July 10, 1996. (Step 4.2.12) 6.2.

• Technical Specifications:

6.2.1.

The details contained in Current Tech Specs (CTS) or Improved Technical, Specifications (ITS), as applicable, in regard to the Proc~ss Control Program (PCP),

are to b~ relocated to the Licensee Controlled Documen_ts. Some facilities have elected to relocate these details into the Operational Requirements Manual (ORM).

Relocation of the description of the PCP from the CTS or ITS does not affect the safe operation of the facility. Therefore, the relocation details are not required to be in the CTS or th.e ITS to provide adequate protection of the public health and safety.

6.3.

UFSAR 6.3.1.

Braidwood UFSAR, Section 11.4, Solid Waste Management System

Exelon Confidential/Proprietary 6.3.2.

Byron UFSAR Section 11.4, Solid Waste Management System 6*.3.3.

Calvert Cliffs UFSAR Section 11.1.2.3 Solid Waste Processing System 6.3.4.

Clinton USAR Table 11.4, Solid Waste Management System 6.3.5.

Dresden UFSAR Section 11.4, Waste Management System 6.3.6.

Ft. Calhoun USAR Section 11-03, Radiological Effluent Requirements 6.3.7.

Ginna UFSAR Section 11.4, Solid Waste Management System

. RW-AA-100 Revision 11 Page 12of13 6.3.8.

LaSalle UFSAR Section 11.4.2.7 Storage areas, Table 12.3.6-IRSF Storage Area 6.3.9.

Limerick UFSAR Section11.4, Solid Waste Management 6.3.10.

Nine Mile Point Unit 1 UFSAR Section 2.3 Solid Waste System*

6.3.11.

Nine Mile Point Unit 2 UFSAR Section 11.4, Solid Waste Management System 6.3.12.

Oyster Creek UFSAR Section 11.4, Solid Waste Management System 6.3.13.

Peach Bottom UFSAR Section 9.0, Radioactive Waste Systems 6.3.14.

Quad Cities UFSAR Section 11.4.4.5, Interim Radwaste Storage Facility 6.3.15.

Three Mile Island UFSAR Section 11.2, Radioactive Waste Disposal Systems Summary 6.4.

Writers'

References:

Amendment No. 202 to Facility Operating License No. NPF-11 and Amendment No. 189 to Facility Operating License (FOL) No. NPF-18 for the LaSalle County Station (LSCS), Units 1 and 2 Code of Federal Regulations: 10 CFR Part 20, Part 61, Part 71, 49 CFR Parts 171-172 I.E. Circular 80.18, 10CFR 50.59 Safety Evaluation for Chang~s to Radioactive Waste Treatment Systems Low Level Waste Licensing Branch Technical Position on Radioactive Waste Classification, May 1983 NRC Branch Technical Position on Blending of Low-Level Radioactive Waste, SECY-10-0043 NRC Conce.ntration Averaging and Encapsulation Branch Technical Position, NRC-2011-0022 Regulatory Guide 1.21, Measuring Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants Technical Position on Waste Form (Revision 1 ), January 1991

Exelon Confidential/Proprietary 6.5.

Users'

References:

CY-AA-170-2000, Annual Radioactive Effluent Release Report LS-AA-106.* Plant Operations Review Committee Quality Assurance Program (QATR)

RM-AA-101, Records Management Program RM-AA-102-1006, Processing Vendor Documents RP-AA-600 Series, Radioactive Material/Waste Shipments

7.

ATTACHMENTS - None RW-AA-100 Revision 11 Page 13of13