ML16132A506

2 to EN-RW-104, Scaling Factors

ML16132A506
Person / Time
Site:	Waterford
Issue date:	04/02/2015
From:	Miller R Entergy Operations
To:	Office of Nuclear Reactor Regulation
Shared Package
ML16132A496	List: ML16132A494 ML16132A506 ML16132A507 ML16132A508 ML16132A509 ML16132A510 W3F1-2016-0038, UNT-005-014, Rev. 306, Offsite Dose Calculation Manual
References
W3F1-2016-0038 EN-RW-104, Rev 12
Download: ML16132A506 (18)

Text

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 1 of 18 Scaling Factors Procedure Contains NMM ECH eB REFLIB Forms: YES NO Procedure Revision Type: New NON-Editorial Editorial TC Cancellation HQN Effective Date Procedure Owner:

Title:

Site:

Roy Miller Manager, RP GGNS Governance Owner:

Title:

Site:

David Moore Manager, Fleet RP HQN 4/2/15 Site Site Procedure Champion Title ANO Donnie Marvel Manager, RP BRP N/A N/A CNS Bob Beilke Manager, RP GGNS Roy Miller Manager, RP IPEC Frank Mitchell Manager, RP JAF Robert Heath Manager, RP PLP Doug Watkins Manager, RP PNPS Alan Zelie Manager, RP RBS Brad Cole Manager, RP W3 Daniel Frey Manager, RP HQN David Moore Manager, Fleet RP For site implementation dates see ECH eB REFLIB using site tree view (Navigation panel).

Site and NMM Procedures Canceled or Superseded By This Revision None Process Applicability Exclusion:

All Sites:

Specific Sites: ANO BRP CNS GGNS IPEC JAF PLP PNPS RBS W3 Change Statement Editorial revision to remove reference to specific version of RADMAN software per CR-HQN-2015-00069 Removed VY from coversheet Changed title of section 5.6 as recommended by CR-HQN-2015-00069 Reworded steps 5.3[2](b) and 5.4[3](b) to align with change being made to title of section 5.6 Associated PRHQN #: 2015-00080 Procedure Writer: Ron Schwartz Contains Proprietary Information: YES NO

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 2 of 18 Scaling Factors TABLE OF CONTENTS Section Title Page 1.0 PURPOSE 3

2.0 REFERENCES

.................................................................................. 3 3.0 DEFINITIONS.................................................................................... 3 4.0 RESPONSIBILITIES.......................................................................... 4 5.0 DETAILS 4 5.1 PRECAUTIONS AND LIMITATIONS................................................. 4 5.2 GENERAL REQUIREMENTS............................................................ 5 5.3 INDEPENDENT LABORATORY ANALYSIS..................................... 7 5.4 WASTE STREAM SAMPLE DATA SCREENING............................... 8 5.5 WASTE STREAM SAMPLE DATA EVALUATION USING RADMAN VERSION 8.2..................................................................................... 8 5.6 WASTE STREAM SAMPLE DATA EVALUATION USING CURRENT VERSION OF RADMAN.................................................................. 10 6.0 INTERFACES.................................................................................. 12 7.0 RECORDS 12 8.0 SITE SPECIFIC COMMITMENTS.................................................... 12 9.0 ATTACHMENTS............................................................................. 12 ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION..................................................................................... 13 ATTACHMENT 9.2 QUARTERLY TRENDING DOCUMENTATION........................... 18

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 3 of 18 Scaling Factors 1.0 PURPOSE This procedure provides instruction for developing scaling factors for difficult to measure radionuclides, including waste stream identification, waste stream sampling frequency, independent laboratory waste stream sample screening and evaluation, and independent laboratory waste stream sample disposition.

2.0 REFERENCES

[1]

Title 10 of the Code of Federal Regulations, Part 61

[2]

Title 10 of the Code of Federal Regulations, Part 20 Appendix G

[3]

Title 49 of the Code of Federal Regulations, Parts 107, 171-177

[4]

Branch Technical Position on Radioactive Waste Classification, 11 May 1983

[5]

Final Branch Technical Position on Concentration Averaging and Encapsulation, Revision in Part to Waste Classification Technical Position, issued 17 Jan. 1995

[6]

RADMAN-A Computer Code to Classify and Document Package LLW in accordance with 10CFR Part 61, Main Topical Report, May 1983

[7]

RADMAN Operating Procedure, WMG-P-065 (version 8.2)

[8]

RC-101 Introduction to RADMAN and Regulatory Compliance

[9]

RADMAN Operating Procedure, WMG-P-103 (version 9.0) 3.0 DEFINITIONS

[1]

Annual - Once per calendar year (based on sample date)

[2]

Biennial - Once every second calendar year (based on sample date)

[3]

Difficult to Measure Radionuclide - Isotopes such as alpha and low energy beta emitters, which are beyond the capability of routine plant analysis

[4]

Plant or Process Change - Changes to the plant or waste stream process that may alter the waste stream characteristics. This can include, but is not limited to changes to filter media or process equipment

[5]

Radioactive Liquid Waste - Radioactive waste that exists primarily in a liquid form and includes, but is not limited to, such items as water, oils, EHC fluids, etc.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 4 of 18 Scaling Factors 3.0 continued

[6]

Radioactive Solid Waste - Radioactive waste that exists primarily in a non-liquid form and includes, but is not limited to, such items as dry materials, metals, resins, filter media, and sludge

[7]

Scaling Factors - Known ratios of radionuclides in waste streams which are used to calculate the quantity of difficult to measure radionuclides

[8]

Surrogate Waste Stream - A substitute waste stream that has essentially the same radionuclide concentration or distribution as an existing waste stream.

[9]

Primary Waste Stream - For PWRs this is defined as Primary System resin and/or filters and for BWRs this is defined as the Reactor Water Clean Up System resin and/or filters

[10]

LLD - Lower limit of detection. For the purposes of this procedure, LLD is the a priori value representing the lowest value a counting system can detect based on instrument setup, calibration, background, decay time and sample volume.

[11]

Real - Isotope was determined to be above the LLD and is present in the waste

[12]

Not present - isotope was not seen above the LLD 4.0 RESPONSIBILITIES

[1]

Vice President, Operations Support (VPOS) is responsible for the maintenance and interpretation of this procedure, and must approve any deviations from the provisions of this procedure.

[2]

Each Site Senior Nuclear Executive (SNE) is responsible for ensuring that necessary site documents are established and implemented to comply with regulatory requirements and the intent of this procedure.

[3]

Radwaste Focus Group is responsible for periodic reviews and revisions of this procedure.

[4]

Each Sites Radwaste Group (Radiation Protection) is responsible for implementing the site-specific requirements of this procedure.

5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS None

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 5 of 18 Scaling Factors 5.2 GENERAL REQUIREMENTS NOTE An equivalent form may be used in place of Attachment 9.1, 10CFR Part 61 Waste Stream Sample Screening and Evaluation & Attachment 9.2 Quarterly Trending Documentation, however the form must contain as a minimum the information contained in the attachment

[1]

The following are examples of the various waste streams used in the determination of waste stream scaling factors. This list is not exhaustive and surrogate waste streams may be used.

Resins Radioactive Liquids Dry Active Waste (DAW)

Mechanical Filters

[2]

Frequency for sampling of existing waste streams:

(a)

Noted exceptions to Class A, B & C waste sample frequencies Resin media - if there is not sufficient volume in the tank or there is no intended shipment to be made, then no sample is required. The resin media (tank containing the waste stream) will be sampled prior to the next shipment after a sufficient volume (tank level) is attained or shipment is scheduled. The results of the sample taken will be used to characterize all waste (in the tank) generated since the previously documented 10CFR61 results.

Filters - IF there is not sufficient volume in the container OR there is no intended shipment to be made, THEN no sample is required. Sampling of filters will occur within the periodicity noted unless it is discovered that the waste stream information does not match the plant conditions. IF this situation occurs, THEN additional methods for sampling will be employed (filter smears, clippings OR running flow of the waste stream through a Millipore filter of similar micron size as the filter in service) to obtain an official sample. The 10CFR61 waste stream analysis results will be used to characterize all filters generated since the previously documented waste stream results.

(b)

Class A Waste - at least biennially (within two years from the date the last official 10CFR61 sample was taken).

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 6 of 18 Scaling Factors 5.2[2] continued (c)

Class B & C Waste - at least annually (within one year from the date the last official 10CFR61 sample was taken).

NOTE Specific examples of significant equipment or process changes include: changes in oxidation reduction methods such as zinc injection, hydrogen water chemistry, media specialization, media distribution ion/cation ratios, fuel leaks and other changes in reactor coolant chemistry, sustained, unexplained changes in the routinely monitored Beta/Alpha ratios as determined by Radiation Protection, extended Reactor shutdown (>90 days), changes to liquid waste processing such as bypassing filters, utilizing filters or a change in ion exchange media, or when there are changes to waste stream that could change biogas generation rate.

(d)

IF there is a reason to believe that an equipment or process change has significantly altered the previously determined scaling factors by a factor of 10, THEN samples should be taken in addition to the annual/biennial sampling frequency. The waste stream sample should be analyzed, re-evaluated AND if necessary, shipped to a vendor laboratory for additional analysis.

[3]

Trending (a)

Once per quarter, each site shall compare one of the following listed ratios to the previous four quarter average of that same ratio for the primary waste stream. The ratios are taken from the Chemistry reactor water sample for the station for one of the desired combinations.

Cs-137 to Co-60 I-134 to Co-60 Dose equivalent Iodine (DEI) to Co-60 I-133 to I-131 Cs-134 to Cs-137 (b)

Calculate an average of the ratios for the last four quarters AND compare the average to the current quarter.

(c)

IF the comparison is less than a factor of ten, THEN no action is required.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 7 of 18 Scaling Factors 5.2[3] continued (d)

IF the comparison is more than or equal to a factor of ten higher, THEN the primary waste stream is to be sampled, analyzed, evaluated for change (increase) in waste class prior to the next shipment.

(e)

IF the change is more than or equal to a factor of ten lower, THEN the primary waste stream should be evaluated for a change (reduction) in waste class prior to the next shipment. Once it has been determined that the primary waste stream needs to be resampled prior to the next shipment, no further quarterly trending is necessary until the new data is obtained and accepted for update of the waste stream.

(f)

Document quarterly trending on Attachment 9.2.

[4]

For non-routine waste streams, generate scaling factors on a case by case basis 5.3 INDEPENDENT LABORATORY ANALYSIS

[1]

Obtain a sample from the appropriate waste stream and perform an in-house gamma spectral analysis of the waste stream sample.

[2]

Enter the in-house gamma spectral analysis results into the RADMAN Samples module.

(a)

IF using RADMAN version 8.2, THEN reference RADMAN Operating Procedure, WMG-P-065.

(b)

IF using the current version of RADMAN, THEN reference RADMAN Operating Procedure WMG-P-103

[3]

Ship the waste stream sample to the independent laboratory for 10 CFR 61 sample analysis per the vendors instructions and in accordance with, EN-RW-102, Radioactive Shipping Procedure.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 8 of 18 Scaling Factors 5.4 WASTE STREAM SAMPLE DATA SCREENING

[1]

Using Attachment 9.1, 10 CFR Part 61 Waste Stream Sample Screening and Evaluation, perform the waste stream sample data screening.

(a)

IF the waste stream sample data activities are reported in uCi/g, THEN they must be converted to uCi/cc and nCi/g to perform the lower limit of detection (LLD) comparison.

(b)

IF the activities are reported in uCi/sample, THEN the LLD comparisons cannot be performed.

[2]

WHEN performing the nuclide elimination, THEN document the nuclides eliminated on.1 or on the independent laboratory waste stream sample analysis.

[3]

Upon completion of the waste stream sample screening process, enter the new waste stream data into the RADMAN Samples module (a)

IF using RADMAN version 8.2, THEN enter data according to RADMAN Operating Procedure, WMG-P-065.

(b)

IF using the current version of RADMAN, THEN enter data according to RADMAN Operating Procedure, WMG-P-103.

[4]

Complete the entered by AND verified by on Attachment 9.1.

5.5 WASTE STREAM SAMPLE DATA EVALUATION USING RADMAN VERSION 8.2

[1]

Use Attachment 9.1 in conjunction with these instructions to perform the waste stream sample data evaluation.

[2]

Compare the independent laboratory results to the in-house gamma results for the same sample using the Validate program in the RADMAN Samples module per RADMAN Operating Procedure, WMG-P-065. The comparisons performed are specific activity (for samples results reported in uCi/g or uCi/cc) and fractional abundance.

[3]

IF the specific activity OR fractional abundance comparison exceeds the recommended variance, THEN:

(a)

Investigate to determine the reason for the variance OR re-sample AND re-analyze the waste stream.

(b)

Document the results of the investigation OR the reason for re-sampling and re-analyzing the waste stream on Attachment 9.1.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 9 of 18 Scaling Factors 5.5[3] continued (c)

IF the new waste stream sample data is determined acceptable with variances greater than what is recommended, THEN document the explanation for the variance and disposition on Attachment 9.1.

(d)

IF the new waste stream sample data is determined to be unacceptable due to variances greater than what is recommended OR the waste stream is resampled and analyzed, THEN initiate a Condition Report.

NOTE Exercising the Simulate Database Update function does not affect the existing waste stream 10 CFR Part 61 database. This program is a useful tool for determining the appropriate option (Retain old data and re-sample, Replace old data with new, or Combine old data with new) for updating the 10 CFR Part 61 database.

The NRC approved Topical Report for RADMAN contains flowcharts that can be used to help explain variances.

For new waste streams being developed there will not be a sample in the database to update. In this case the parts of Attachment 9.1 concerning comparison to the database may be marked as not applicable (N/A).

[4]

Using the RADMAN Simulate Database Update function according to RADMAN Operating Procedure WMG-P-065, compare the specific activity, fractional abundance and scaling factors from the existing waste stream sample data to the new independent laboratory sample data set.

[5]

IF the specific activity, fractional abundance OR scaling factor comparison exceeds the recommended variance, THEN:

(a)

Perform an investigation to determine a reason for the variance OR resample and reanalyze the waste stream.

(b)

Document the results of the investigation OR the reason for resampling and reanalyzing the waste stream on Attachment 9.1.

(c)

IF the new waste stream sample data is determined acceptable with variances greater than what is recommended, THEN document the explanation for the variance AND disposition on Attachment 9.1.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 10 of 18 Scaling Factors 5.5[5] continued (d)

IF existing sample data is to be retained AND not replaced OR combined due to unacceptable new waste stream sample data, THEN document the reason(s) on Attachment 9.1 AND initiate a Condition Report.

[6]

WHEN the independent laboratory waste stream sample data (scaling factors) has been accepted, THEN replace the existing waste stream sample data with the new sample data OR combine the existing waste stream sample data with new sample data.

[7]

Record the waste stream update verification on Attachment 9.1.

[8]

Transmit a copy of the independent DAW Laboratory Analysis to the appropriate RP department personnel (e.g., Dosimetry, Instrumentation etc.)

[9]

Transmit a copy of all new waste stream data to the Chemistry/Environmental personnel responsible for site effluent data.

5.6 WASTE STREAM SAMPLE DATA EVALUATION USING CURRENT VERSION OF RADMAN

[1]

From the RADMAN home page, select the Distribution tab.

[2]

Select Nuclide Distribution Listing.

[3]

Select the distribution to be updated.

[4]

From the Commands window, select Update Distribution.

[5]

Select the sample to be used for the update.

[6]

From the Commands window select Replace Report, THEN print the following reports:

Scaling Factors Fractional (%) Abundance Data Values

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 11 of 18 Scaling Factors 5.6 continued NOTE The Combine Report shows what the result will be if the Combine Existing Data action is executed. This shows what the effect of combining the old sample data with the new sample will be (in effect, a rolling average of past data).

[7]

From the Commands window select Combine Report, THEN print the following reports:

Scaling Factors Fractional (%) Abundance Data Values

[8]

Compare the results of Replace Report to the results of Combine Report.

[9]

IF the specific activity, fractional abundance OR scaling factor comparison exceeds the recommended variance, THEN:

(a)

Perform an investigation to determine a reason for the variance OR resample and reanalyze the waste stream.

(b)

Document the results of the investigation OR the reason for resampling and reanalyzing the waste stream on Attachment 9.1.

(c)

IF the new waste stream sample data is determined acceptable with variances greater than what is recommended, THEN document the explanation for the variance AND disposition on Attachment 9.1.

(d)

IF existing sample data will be retained and not replaced or combined due to unacceptable new waste stream sample data, THEN document the reason(s) on Attachment 9.1 AND initiate a Condition Report.

[10]

WHEN the independent laboratory waste stream sample data (scaling factors) has been accepted, THEN replace the existing waste stream sample data with the new sample data OR combine the existing waste stream sample data with new sample data.

[11]

Record the waste stream update verification on Attachment 9.1.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 12 of 18 Scaling Factors 5.6 continued

[12]

Transmit a copy of the independent DAW Laboratory Analysis to the appropriate RP department personnel (e.g., Dosimetry, Instrumentation etc.)

[13]

Transmit a copy of all new waste stream data to the Chemistry/Environmental personnel responsible for site effluent data.

6.0 INTERFACES

[1]

EN-RW-102, Radioactive Shipping Procedure

[2]

EN-AD-103, Document Control and Records Management Programs

[3]

RADMAN Operating Procedure WMG-P-065

[4]

RADMAN Operating Procedure WMG-P-103 7.0 RECORDS

[1].1, 10CFR Part 61 Waste Stream Sample Screening and Evaluation

[2].2, Quarterly Trending Documentation

[3]

RADMAN software output

[4]

Independent laboratory waste stream sample analysis results 8.0 SITE SPECIFIC COMMITMENTS None 9.0 ATTACHMENTS 9.1 10CFR Part 61 Waste Stream Sample Screening and Evaluation 9.2 Quarterly Trending Documentation

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 13 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 1 of 5 Date: _________________

In-House Sample Identification Number:

Independent Lab Sample Identification Number Waste Stream

Description:

Waste Stream Sample Data Screening The screening process performs the following:

Eliminate nuclides based on specific criteria, Record the status of 10 CFR 20 Appendix G radionuclides as LLD, Real or Not Present.

Record the status of RADMAN base nuclides as LLD or Real.

Determine that the values reported as an LLD for named 10 CFR Part 61 nuclides meet the limits established by the NRC.

The nuclides selected from the screening process will be evaluated for the purpose of updating the applicable RADMAN waste stream sample database.

Nuclide Elimination Eliminate the following nuclides based on the criteria listed below:

List the nuclide(s) eliminated and comments if applicable.

Nuclide is naturally occurring (i.e.

Pb, Rn, K, Po, etc)

Nuclide is a noble gas (i.e. Xe, Kr, etc.)

Nuclide has a half life <8 days with exception of I-131 which has an extremely low RQ value Nuclide is lower than the detectable limit and is not a base nuclide or 10 CFR 20 Appendix G nuclide Comments: _________________________________________________________________________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 14 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 2 of 5 10 CFR 20 Appendix G Nuclides Status Nuclide Value Real LLD LLD Limit 1% of Table 1 Class C Limits for C-14, I-129, Tc-99 and 1% of Table 2 Class A Limits for H-3 Not Present C-14

<8E-2 uCi/cc H-3

<4E-1 uCi/cc I-129

<8E-4 uCi/cc Tc-99

<3E-2 uCi/cc Comments: ________________________________________________________________

RADMAN Base Nuclides Status Nuclide Value Real LLD LLD Limit 1% of Table 2 Class A Limits Not Present Co-60

< 7 uci/cc Cs-137

< 1E-2 uCi/cc Ce-144

< 7 uci/cc Comments: ________________________________________________________________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 15 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 3 of 5 10 CFR 61.55 Listed Nuclides Status Table 1 Nuclides Nuclide Value Real LLD LLD Limit 1% of Table 1 Class C limits Not Present C-14

<8E-2 uCi/cc C-14 in activated metal

<8E-1 uCi/cc Ni-59 in activated metal

<2.2 uCi/cc Nb-94 in activated metal

<2E-3 uCi/cc Tc-99

<3E-2 uCi/cc I-129

<8E-4 uCi/cc Pu-241

<35 nCi/gm Cm-242

<200nCi/gm TRUs > 5 year T 1/2

< 1 nCi/gm Comments: ________________________________________________________________

Table 2 Nuclides Nuclide Value Real LLD LLD Limit 1% of Table 2 Class A limits Not Present H-3

<4E-1 uCi/cc Co-60

<7 uCi/cc Ni-63

<3.5E-2 uCi/cc Ni-63 in activated metal

<3.5E-1 uCi/cc Sr-90

<4E-4 uCi/cc Cs-137

<1E-2 uCi/cc Comments: ________________________________________________________________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 16 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 4 of 5 RADMAN Waste Stream Sample Data Set Entry With the exception of the nuclides eliminated during the screening, enter the following nuclides into RADMAN as a sample data set and attach a hard copy of sample data entered.

10 CFR 20 Appendix G nuclides (indicate real, LLD, or not present)

RADMAN Base nuclides (indicate real or LLD) 10 CFR 61.55 nuclides that have a real value Sample data entered by: ________________________________Date__________________

Sample data entry verified by: ______________________________Date________________

Sample Evaluation Using RADMAN perform the Validate program in the Samples module and attach the hard copy. This program compares the independent laboratory results to the in-house gamma results for the same sample. Two comparisons are performed specific (for samples reported in uCi/cc or uCi/g) and total activity, and fractional abundance.

Document the variances identified by the Validate program and disposition.

Using RADMAN, compare existing waste stream data to a new independent laboratory sample data set attaching the software output hard copy. Comparisons are made for specific activity, fractional abundance and scaling factors. Based on the comparisons from the simulation, determine which option should be used to update the RADMAN waste stream Part 61 database:

Retain old data and resample Replace old data with new sample Combine old data with new data

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 17 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 5 of 5 Document the variances identified by the software AND the action taken to address each variance:

Specific Activity Variances:

Fractional Abundance Variances: (2 for base nuclides Co-60, Cs-137, and 5 for Ce-144)

Scaling Factor Variances:

Based on the above variances, the waste stream sample is dispositioned as:

______ Retain old data and resample

______ Replace old data with new sample

______ Combine old data with new data Reason for the above disposition:

Waste Stream Evaluation Performed by: _______________________Date______________

Waste Stream Evaluation Reviewed by: _______________________Date______________

Waste Stream Update Verified by: ____________________________Date______________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 18 of 18 Scaling Factors ATTACHMENT 9.2 QUARTERLY TRENDING DOCUMENTATION Sheet 1 of 1 Document the radionuclide ratio utilized per 5.2[3]:

Current quarter average:

Four quarter average:

A - Current quarter average value B - Previous four quarters average value (not including current quarter average, e.g. whole year prior to current quarter)

A & B - same selected nuclide ratios utilized B / A = Variance ( C ) as well as 1 / C if value of C is < 1.0 Variance ( C )

Based on the above variance, the waste stream sample is dispositioned as:

< a factor of 10 - no action taken - current quarter

> a factor of 10 - schedule re-sample of primary waste stream - prior to next shipment Comments:

Performed by: _______________________Date________________

Reviewed by: _______________________Date________________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 1 of 18 Scaling Factors Procedure Contains NMM ECH eB REFLIB Forms: YES NO Procedure Revision Type: New NON-Editorial Editorial TC Cancellation HQN Effective Date Procedure Owner:

Title:

Site:

Roy Miller Manager, RP GGNS Governance Owner:

Title:

Site:

David Moore Manager, Fleet RP HQN 4/2/15 Site Site Procedure Champion Title ANO Donnie Marvel Manager, RP BRP N/A N/A CNS Bob Beilke Manager, RP GGNS Roy Miller Manager, RP IPEC Frank Mitchell Manager, RP JAF Robert Heath Manager, RP PLP Doug Watkins Manager, RP PNPS Alan Zelie Manager, RP RBS Brad Cole Manager, RP W3 Daniel Frey Manager, RP HQN David Moore Manager, Fleet RP For site implementation dates see ECH eB REFLIB using site tree view (Navigation panel).

Site and NMM Procedures Canceled or Superseded By This Revision None Process Applicability Exclusion:

All Sites:

Specific Sites: ANO BRP CNS GGNS IPEC JAF PLP PNPS RBS W3 Change Statement Editorial revision to remove reference to specific version of RADMAN software per CR-HQN-2015-00069 Removed VY from coversheet Changed title of section 5.6 as recommended by CR-HQN-2015-00069 Reworded steps 5.3[2](b) and 5.4[3](b) to align with change being made to title of section 5.6 Associated PRHQN #: 2015-00080 Procedure Writer: Ron Schwartz Contains Proprietary Information: YES NO

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 2 of 18 Scaling Factors TABLE OF CONTENTS Section Title Page 1.0 PURPOSE 3

2.0 REFERENCES

.................................................................................. 3 3.0 DEFINITIONS.................................................................................... 3 4.0 RESPONSIBILITIES.......................................................................... 4 5.0 DETAILS 4 5.1 PRECAUTIONS AND LIMITATIONS................................................. 4 5.2 GENERAL REQUIREMENTS............................................................ 5 5.3 INDEPENDENT LABORATORY ANALYSIS..................................... 7 5.4 WASTE STREAM SAMPLE DATA SCREENING............................... 8 5.5 WASTE STREAM SAMPLE DATA EVALUATION USING RADMAN VERSION 8.2..................................................................................... 8 5.6 WASTE STREAM SAMPLE DATA EVALUATION USING CURRENT VERSION OF RADMAN.................................................................. 10 6.0 INTERFACES.................................................................................. 12 7.0 RECORDS 12 8.0 SITE SPECIFIC COMMITMENTS.................................................... 12 9.0 ATTACHMENTS............................................................................. 12 ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION..................................................................................... 13 ATTACHMENT 9.2 QUARTERLY TRENDING DOCUMENTATION........................... 18

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 3 of 18 Scaling Factors 1.0 PURPOSE This procedure provides instruction for developing scaling factors for difficult to measure radionuclides, including waste stream identification, waste stream sampling frequency, independent laboratory waste stream sample screening and evaluation, and independent laboratory waste stream sample disposition.

2.0 REFERENCES

[1]

Title 10 of the Code of Federal Regulations, Part 61

[2]

Title 10 of the Code of Federal Regulations, Part 20 Appendix G

[3]

Title 49 of the Code of Federal Regulations, Parts 107, 171-177

[4]

Branch Technical Position on Radioactive Waste Classification, 11 May 1983

[5]

Final Branch Technical Position on Concentration Averaging and Encapsulation, Revision in Part to Waste Classification Technical Position, issued 17 Jan. 1995

[6]

RADMAN-A Computer Code to Classify and Document Package LLW in accordance with 10CFR Part 61, Main Topical Report, May 1983

[7]

RADMAN Operating Procedure, WMG-P-065 (version 8.2)

[8]

RC-101 Introduction to RADMAN and Regulatory Compliance

[9]

RADMAN Operating Procedure, WMG-P-103 (version 9.0) 3.0 DEFINITIONS

[1]

Annual - Once per calendar year (based on sample date)

[2]

Biennial - Once every second calendar year (based on sample date)

[3]

Difficult to Measure Radionuclide - Isotopes such as alpha and low energy beta emitters, which are beyond the capability of routine plant analysis

[4]

Plant or Process Change - Changes to the plant or waste stream process that may alter the waste stream characteristics. This can include, but is not limited to changes to filter media or process equipment

[5]

Radioactive Liquid Waste - Radioactive waste that exists primarily in a liquid form and includes, but is not limited to, such items as water, oils, EHC fluids, etc.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 4 of 18 Scaling Factors 3.0 continued

[6]

Radioactive Solid Waste - Radioactive waste that exists primarily in a non-liquid form and includes, but is not limited to, such items as dry materials, metals, resins, filter media, and sludge

[7]

Scaling Factors - Known ratios of radionuclides in waste streams which are used to calculate the quantity of difficult to measure radionuclides

[8]

Surrogate Waste Stream - A substitute waste stream that has essentially the same radionuclide concentration or distribution as an existing waste stream.

[9]

Primary Waste Stream - For PWRs this is defined as Primary System resin and/or filters and for BWRs this is defined as the Reactor Water Clean Up System resin and/or filters

[10]

LLD - Lower limit of detection. For the purposes of this procedure, LLD is the a priori value representing the lowest value a counting system can detect based on instrument setup, calibration, background, decay time and sample volume.

[11]

Real - Isotope was determined to be above the LLD and is present in the waste

[12]

Not present - isotope was not seen above the LLD 4.0 RESPONSIBILITIES

[1]

Vice President, Operations Support (VPOS) is responsible for the maintenance and interpretation of this procedure, and must approve any deviations from the provisions of this procedure.

[2]

Each Site Senior Nuclear Executive (SNE) is responsible for ensuring that necessary site documents are established and implemented to comply with regulatory requirements and the intent of this procedure.

[3]

Radwaste Focus Group is responsible for periodic reviews and revisions of this procedure.

[4]

Each Sites Radwaste Group (Radiation Protection) is responsible for implementing the site-specific requirements of this procedure.

5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS None

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 5 of 18 Scaling Factors 5.2 GENERAL REQUIREMENTS NOTE An equivalent form may be used in place of Attachment 9.1, 10CFR Part 61 Waste Stream Sample Screening and Evaluation & Attachment 9.2 Quarterly Trending Documentation, however the form must contain as a minimum the information contained in the attachment

[1]

The following are examples of the various waste streams used in the determination of waste stream scaling factors. This list is not exhaustive and surrogate waste streams may be used.

Resins Radioactive Liquids Dry Active Waste (DAW)

Mechanical Filters

[2]

Frequency for sampling of existing waste streams:

(a)

Noted exceptions to Class A, B & C waste sample frequencies Resin media - if there is not sufficient volume in the tank or there is no intended shipment to be made, then no sample is required. The resin media (tank containing the waste stream) will be sampled prior to the next shipment after a sufficient volume (tank level) is attained or shipment is scheduled. The results of the sample taken will be used to characterize all waste (in the tank) generated since the previously documented 10CFR61 results.

Filters - IF there is not sufficient volume in the container OR there is no intended shipment to be made, THEN no sample is required. Sampling of filters will occur within the periodicity noted unless it is discovered that the waste stream information does not match the plant conditions. IF this situation occurs, THEN additional methods for sampling will be employed (filter smears, clippings OR running flow of the waste stream through a Millipore filter of similar micron size as the filter in service) to obtain an official sample. The 10CFR61 waste stream analysis results will be used to characterize all filters generated since the previously documented waste stream results.

(b)

Class A Waste - at least biennially (within two years from the date the last official 10CFR61 sample was taken).

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 6 of 18 Scaling Factors 5.2[2] continued (c)

Class B & C Waste - at least annually (within one year from the date the last official 10CFR61 sample was taken).

NOTE Specific examples of significant equipment or process changes include: changes in oxidation reduction methods such as zinc injection, hydrogen water chemistry, media specialization, media distribution ion/cation ratios, fuel leaks and other changes in reactor coolant chemistry, sustained, unexplained changes in the routinely monitored Beta/Alpha ratios as determined by Radiation Protection, extended Reactor shutdown (>90 days), changes to liquid waste processing such as bypassing filters, utilizing filters or a change in ion exchange media, or when there are changes to waste stream that could change biogas generation rate.

(d)

IF there is a reason to believe that an equipment or process change has significantly altered the previously determined scaling factors by a factor of 10, THEN samples should be taken in addition to the annual/biennial sampling frequency. The waste stream sample should be analyzed, re-evaluated AND if necessary, shipped to a vendor laboratory for additional analysis.

[3]

Trending (a)

Once per quarter, each site shall compare one of the following listed ratios to the previous four quarter average of that same ratio for the primary waste stream. The ratios are taken from the Chemistry reactor water sample for the station for one of the desired combinations.

Cs-137 to Co-60 I-134 to Co-60 Dose equivalent Iodine (DEI) to Co-60 I-133 to I-131 Cs-134 to Cs-137 (b)

Calculate an average of the ratios for the last four quarters AND compare the average to the current quarter.

(c)

IF the comparison is less than a factor of ten, THEN no action is required.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 7 of 18 Scaling Factors 5.2[3] continued (d)

IF the comparison is more than or equal to a factor of ten higher, THEN the primary waste stream is to be sampled, analyzed, evaluated for change (increase) in waste class prior to the next shipment.

(e)

IF the change is more than or equal to a factor of ten lower, THEN the primary waste stream should be evaluated for a change (reduction) in waste class prior to the next shipment. Once it has been determined that the primary waste stream needs to be resampled prior to the next shipment, no further quarterly trending is necessary until the new data is obtained and accepted for update of the waste stream.

(f)

Document quarterly trending on Attachment 9.2.

[4]

For non-routine waste streams, generate scaling factors on a case by case basis 5.3 INDEPENDENT LABORATORY ANALYSIS

[1]

Obtain a sample from the appropriate waste stream and perform an in-house gamma spectral analysis of the waste stream sample.

[2]

Enter the in-house gamma spectral analysis results into the RADMAN Samples module.

(a)

IF using RADMAN version 8.2, THEN reference RADMAN Operating Procedure, WMG-P-065.

(b)

IF using the current version of RADMAN, THEN reference RADMAN Operating Procedure WMG-P-103

[3]

Ship the waste stream sample to the independent laboratory for 10 CFR 61 sample analysis per the vendors instructions and in accordance with, EN-RW-102, Radioactive Shipping Procedure.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 8 of 18 Scaling Factors 5.4 WASTE STREAM SAMPLE DATA SCREENING

[1]

Using Attachment 9.1, 10 CFR Part 61 Waste Stream Sample Screening and Evaluation, perform the waste stream sample data screening.

(a)

IF the waste stream sample data activities are reported in uCi/g, THEN they must be converted to uCi/cc and nCi/g to perform the lower limit of detection (LLD) comparison.

(b)

IF the activities are reported in uCi/sample, THEN the LLD comparisons cannot be performed.

[2]

WHEN performing the nuclide elimination, THEN document the nuclides eliminated on.1 or on the independent laboratory waste stream sample analysis.

[3]

Upon completion of the waste stream sample screening process, enter the new waste stream data into the RADMAN Samples module (a)

IF using RADMAN version 8.2, THEN enter data according to RADMAN Operating Procedure, WMG-P-065.

(b)

IF using the current version of RADMAN, THEN enter data according to RADMAN Operating Procedure, WMG-P-103.

[4]

Complete the entered by AND verified by on Attachment 9.1.

5.5 WASTE STREAM SAMPLE DATA EVALUATION USING RADMAN VERSION 8.2

[1]

Use Attachment 9.1 in conjunction with these instructions to perform the waste stream sample data evaluation.

[2]

Compare the independent laboratory results to the in-house gamma results for the same sample using the Validate program in the RADMAN Samples module per RADMAN Operating Procedure, WMG-P-065. The comparisons performed are specific activity (for samples results reported in uCi/g or uCi/cc) and fractional abundance.

[3]

IF the specific activity OR fractional abundance comparison exceeds the recommended variance, THEN:

(a)

Investigate to determine the reason for the variance OR re-sample AND re-analyze the waste stream.

(b)

Document the results of the investigation OR the reason for re-sampling and re-analyzing the waste stream on Attachment 9.1.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 9 of 18 Scaling Factors 5.5[3] continued (c)

IF the new waste stream sample data is determined acceptable with variances greater than what is recommended, THEN document the explanation for the variance and disposition on Attachment 9.1.

(d)

IF the new waste stream sample data is determined to be unacceptable due to variances greater than what is recommended OR the waste stream is resampled and analyzed, THEN initiate a Condition Report.

NOTE Exercising the Simulate Database Update function does not affect the existing waste stream 10 CFR Part 61 database. This program is a useful tool for determining the appropriate option (Retain old data and re-sample, Replace old data with new, or Combine old data with new) for updating the 10 CFR Part 61 database.

The NRC approved Topical Report for RADMAN contains flowcharts that can be used to help explain variances.

For new waste streams being developed there will not be a sample in the database to update. In this case the parts of Attachment 9.1 concerning comparison to the database may be marked as not applicable (N/A).

[4]

Using the RADMAN Simulate Database Update function according to RADMAN Operating Procedure WMG-P-065, compare the specific activity, fractional abundance and scaling factors from the existing waste stream sample data to the new independent laboratory sample data set.

[5]

IF the specific activity, fractional abundance OR scaling factor comparison exceeds the recommended variance, THEN:

(a)

Perform an investigation to determine a reason for the variance OR resample and reanalyze the waste stream.

(b)

Document the results of the investigation OR the reason for resampling and reanalyzing the waste stream on Attachment 9.1.

(c)

IF the new waste stream sample data is determined acceptable with variances greater than what is recommended, THEN document the explanation for the variance AND disposition on Attachment 9.1.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 10 of 18 Scaling Factors 5.5[5] continued (d)

IF existing sample data is to be retained AND not replaced OR combined due to unacceptable new waste stream sample data, THEN document the reason(s) on Attachment 9.1 AND initiate a Condition Report.

[6]

WHEN the independent laboratory waste stream sample data (scaling factors) has been accepted, THEN replace the existing waste stream sample data with the new sample data OR combine the existing waste stream sample data with new sample data.

[7]

Record the waste stream update verification on Attachment 9.1.

[8]

Transmit a copy of the independent DAW Laboratory Analysis to the appropriate RP department personnel (e.g., Dosimetry, Instrumentation etc.)

[9]

Transmit a copy of all new waste stream data to the Chemistry/Environmental personnel responsible for site effluent data.

5.6 WASTE STREAM SAMPLE DATA EVALUATION USING CURRENT VERSION OF RADMAN

[1]

From the RADMAN home page, select the Distribution tab.

[2]

Select Nuclide Distribution Listing.

[3]

Select the distribution to be updated.

[4]

From the Commands window, select Update Distribution.

[5]

Select the sample to be used for the update.

[6]

From the Commands window select Replace Report, THEN print the following reports:

Scaling Factors Fractional (%) Abundance Data Values

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 11 of 18 Scaling Factors 5.6 continued NOTE The Combine Report shows what the result will be if the Combine Existing Data action is executed. This shows what the effect of combining the old sample data with the new sample will be (in effect, a rolling average of past data).

[7]

From the Commands window select Combine Report, THEN print the following reports:

Scaling Factors Fractional (%) Abundance Data Values

[8]

Compare the results of Replace Report to the results of Combine Report.

[9]

IF the specific activity, fractional abundance OR scaling factor comparison exceeds the recommended variance, THEN:

(a)

Perform an investigation to determine a reason for the variance OR resample and reanalyze the waste stream.

(b)

Document the results of the investigation OR the reason for resampling and reanalyzing the waste stream on Attachment 9.1.

(c)

IF the new waste stream sample data is determined acceptable with variances greater than what is recommended, THEN document the explanation for the variance AND disposition on Attachment 9.1.

(d)

IF existing sample data will be retained and not replaced or combined due to unacceptable new waste stream sample data, THEN document the reason(s) on Attachment 9.1 AND initiate a Condition Report.

[10]

WHEN the independent laboratory waste stream sample data (scaling factors) has been accepted, THEN replace the existing waste stream sample data with the new sample data OR combine the existing waste stream sample data with new sample data.

[11]

Record the waste stream update verification on Attachment 9.1.

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 12 of 18 Scaling Factors 5.6 continued

[12]

Transmit a copy of the independent DAW Laboratory Analysis to the appropriate RP department personnel (e.g., Dosimetry, Instrumentation etc.)

[13]

Transmit a copy of all new waste stream data to the Chemistry/Environmental personnel responsible for site effluent data.

6.0 INTERFACES

[1]

EN-RW-102, Radioactive Shipping Procedure

[2]

EN-AD-103, Document Control and Records Management Programs

[3]

RADMAN Operating Procedure WMG-P-065

[4]

RADMAN Operating Procedure WMG-P-103 7.0 RECORDS

[1].1, 10CFR Part 61 Waste Stream Sample Screening and Evaluation

[2].2, Quarterly Trending Documentation

[3]

RADMAN software output

[4]

Independent laboratory waste stream sample analysis results 8.0 SITE SPECIFIC COMMITMENTS None 9.0 ATTACHMENTS 9.1 10CFR Part 61 Waste Stream Sample Screening and Evaluation 9.2 Quarterly Trending Documentation

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 13 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 1 of 5 Date: _________________

In-House Sample Identification Number:

Independent Lab Sample Identification Number Waste Stream

Description:

Waste Stream Sample Data Screening The screening process performs the following:

Eliminate nuclides based on specific criteria, Record the status of 10 CFR 20 Appendix G radionuclides as LLD, Real or Not Present.

Record the status of RADMAN base nuclides as LLD or Real.

Determine that the values reported as an LLD for named 10 CFR Part 61 nuclides meet the limits established by the NRC.

The nuclides selected from the screening process will be evaluated for the purpose of updating the applicable RADMAN waste stream sample database.

Nuclide Elimination Eliminate the following nuclides based on the criteria listed below:

List the nuclide(s) eliminated and comments if applicable.

Nuclide is naturally occurring (i.e.

Pb, Rn, K, Po, etc)

Nuclide is a noble gas (i.e. Xe, Kr, etc.)

Nuclide has a half life <8 days with exception of I-131 which has an extremely low RQ value Nuclide is lower than the detectable limit and is not a base nuclide or 10 CFR 20 Appendix G nuclide Comments: _________________________________________________________________________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 14 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 2 of 5 10 CFR 20 Appendix G Nuclides Status Nuclide Value Real LLD LLD Limit 1% of Table 1 Class C Limits for C-14, I-129, Tc-99 and 1% of Table 2 Class A Limits for H-3 Not Present C-14

<8E-2 uCi/cc H-3

<4E-1 uCi/cc I-129

<8E-4 uCi/cc Tc-99

<3E-2 uCi/cc Comments: ________________________________________________________________

RADMAN Base Nuclides Status Nuclide Value Real LLD LLD Limit 1% of Table 2 Class A Limits Not Present Co-60

< 7 uci/cc Cs-137

< 1E-2 uCi/cc Ce-144

< 7 uci/cc Comments: ________________________________________________________________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 15 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 3 of 5 10 CFR 61.55 Listed Nuclides Status Table 1 Nuclides Nuclide Value Real LLD LLD Limit 1% of Table 1 Class C limits Not Present C-14

<8E-2 uCi/cc C-14 in activated metal

<8E-1 uCi/cc Ni-59 in activated metal

<2.2 uCi/cc Nb-94 in activated metal

<2E-3 uCi/cc Tc-99

<3E-2 uCi/cc I-129

<8E-4 uCi/cc Pu-241

<35 nCi/gm Cm-242

<200nCi/gm TRUs > 5 year T 1/2

< 1 nCi/gm Comments: ________________________________________________________________

Table 2 Nuclides Nuclide Value Real LLD LLD Limit 1% of Table 2 Class A limits Not Present H-3

<4E-1 uCi/cc Co-60

<7 uCi/cc Ni-63

<3.5E-2 uCi/cc Ni-63 in activated metal

<3.5E-1 uCi/cc Sr-90

<4E-4 uCi/cc Cs-137

<1E-2 uCi/cc Comments: ________________________________________________________________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 16 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 4 of 5 RADMAN Waste Stream Sample Data Set Entry With the exception of the nuclides eliminated during the screening, enter the following nuclides into RADMAN as a sample data set and attach a hard copy of sample data entered.

10 CFR 20 Appendix G nuclides (indicate real, LLD, or not present)

RADMAN Base nuclides (indicate real or LLD) 10 CFR 61.55 nuclides that have a real value Sample data entered by: ________________________________Date__________________

Sample data entry verified by: ______________________________Date________________

Sample Evaluation Using RADMAN perform the Validate program in the Samples module and attach the hard copy. This program compares the independent laboratory results to the in-house gamma results for the same sample. Two comparisons are performed specific (for samples reported in uCi/cc or uCi/g) and total activity, and fractional abundance.

Document the variances identified by the Validate program and disposition.

Using RADMAN, compare existing waste stream data to a new independent laboratory sample data set attaching the software output hard copy. Comparisons are made for specific activity, fractional abundance and scaling factors. Based on the comparisons from the simulation, determine which option should be used to update the RADMAN waste stream Part 61 database:

Retain old data and resample Replace old data with new sample Combine old data with new data

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 17 of 18 Scaling Factors ATTACHMENT 9.1 10CFR PART 61 WASTE STREAM SAMPLE SCREENING AND EVALUATION Sheet 5 of 5 Document the variances identified by the software AND the action taken to address each variance:

Specific Activity Variances:

Fractional Abundance Variances: (2 for base nuclides Co-60, Cs-137, and 5 for Ce-144)

Scaling Factor Variances:

Based on the above variances, the waste stream sample is dispositioned as:

______ Retain old data and resample

______ Replace old data with new sample

______ Combine old data with new data Reason for the above disposition:

Waste Stream Evaluation Performed by: _______________________Date______________

Waste Stream Evaluation Reviewed by: _______________________Date______________

Waste Stream Update Verified by: ____________________________Date______________

NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED EN-RW-104 REV. 12 INFORMATIONAL USE Page 18 of 18 Scaling Factors ATTACHMENT 9.2 QUARTERLY TRENDING DOCUMENTATION Sheet 1 of 1 Document the radionuclide ratio utilized per 5.2[3]:

Current quarter average:

Four quarter average:

A - Current quarter average value B - Previous four quarters average value (not including current quarter average, e.g. whole year prior to current quarter)

A & B - same selected nuclide ratios utilized B / A = Variance ( C ) as well as 1 / C if value of C is < 1.0 Variance ( C )

Based on the above variance, the waste stream sample is dispositioned as:

< a factor of 10 - no action taken - current quarter

> a factor of 10 - schedule re-sample of primary waste stream - prior to next shipment Comments:

Performed by: _______________________Date________________

Reviewed by: _______________________Date________________