Text

Rev 4 to, Process Control Program Oconee Nuclear Station
	ML20012A373
Person / Time
Site:	Oconee, McGuire, 05000000
Issue date:	11/15/1989
From:	Jennifer Davis, Entrekin M, Tuckman M; DUKE POWER CO.
To:	;
Shared Package
ML15217A104	List: ML15217A103; ML20012A368; ML20012A369; ML20012A372; ML20012A373; ML20012A375; ML20012A377; ML20012A379; ML20012A380;
References
	PROC-891115, NUDOCS 9003090340
	Download: ML20012A373 (114)
	v • d • e

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.y j,f: g i. DUKE' POWER COMPANY. CORPORATE PROCESS CONTROL: PROGRAM TABLE OF-CONTENTS o p i -- 1.O PURPOSE ^ i 2.0;-SOLIDIFICATION '2.1 - Vendor Requirements- .2.2, Program Requirements 3.0 -DEWATERING 3. 11 Vendor Requirements: i 3. 2-Program Requirements- '4. 0 WASTE OIL 15. 0 INTERIM STORAGE 6.0- 10 CFR PART 61 COMPLIANCE '6.1 -Vendor Requirements 6.2. Program'-Requirements 7.O TRANSPORTATIONE 7_.1 : Program Requirements

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.~ -. 9. 0. AUDITS i 1 G-1 Rev. 4

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PROCESS CONTROL PROGRAM 1.0 PURPOSE 1.1 The purpose of the Duke Power Company Corporate Process Control Program is to establish a set of' requirements that shall_ be met at all nuclear stations to insureJthat all solidification and dewatering activities are conducted in a manner and produce a final product that complies with all applicable Federal and State regulations and licensed burial site criteria. 1.2 The Duke Power Company Process Control Program shall be used to control and direct all solidification and dewatering activities for liquids (e.g., evaporator concentrates) and " wet solids" (e.g., resin slurries, filter backwash slurries, cartridge filters) at the Oconee-Nuclear Station, Units 1, 2 and 3, the McGuire Nuclear Station, Units 1 and 2, and the Catawba Nuclear Station, Units 1 and 2. 1.3 Station - specific procedures shall be developed to implement the requirements of this corporate PCP. hk 1.4. Station Process Control Programs shall contain Process Control Program-related sections on definitions, limiting conditions for operation, bases and surveillance requirements transferred from Station Technical Specifications (TS). j

1. 5 - This Process Control Program and implementing procedures shall assure'that all solidification and= dewatering activities are in compliance with 10CFR20, 50, 61, 71, and 49 CFR and licensed burial site criteria.

i 1.6 If this Process Control Program is not followed, each vessel of: processed (i.e., solidified or dewatered) waste shall be physically tested to verify the absence of free standing liquids and all other applicable waste form requirements. 2.0 SOLIDIFICATION 2.1 Vendor Requirements O G-2 Rev. 4

a i n 2. 1. 11 Any vendor' utilized for solidification services by Duke (]). Power Company shalllhave a Topical Report that is either under NRC review or has NRC approval, or shall. supply to Duke Power sufficient documentation of the process and results for review to demonstrate an acceptable product will be produced using the described solidification process. .) 2.1.2 Any vendor solidification services utilized by. Duke Power Company shall be approved by the Corporate Technical System Manager, Nuclear Chemistry and 'i station (s) Technical Services Superintendent prior to operation. 2.1.2.1 Technical review shall be performed by corporate and station radwaste staffs of all vendor documents and procedures to insure they meet-the requirements of the Duke Power Company PCP outlined below, i 2.1.3 Cham-Nuclear Systems, Inc. has been reviewed and I approved to provide solidification services to the Oconee, McGuire, and Catawba Nuclear Stations as described int Mobile Cement Solidification System, Topical Report CNSI-2 (4313-01354-0IP-A). Approved waste streams for solidi-fication are: boric acid evaporator concentrates,.spant bead resin, spent powdered resin, filters, filter backwash slurry, and resin regenerative chemical wastes. H I)-2.1.4 Babcock and Wilcox has been reviewed _and approved to provide solidification services to McGuire, Oconee and Catawba Nuclear Stations for Class A unstable waste as described in B & W's supporting documents. However,-each drum of solidified product shall be puntured and fully inspected prior to shipment!for disposal.- Approved waste streams for solidification are: oil, oil and water mixtures, organics, EDTA-based steam generator-cleaning solution concentrate, and sludges. The approved binders are Aquaset, Aquaset II, Petroset and Petroset II. 2.2 Program Requirements 2.2.1- .The vendor topical report or documentation supplied to .the company shall include a detailed system description giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing all solidification system interfaces with plant radwaste systems and equipment. 2.2.2 The vendor topical report or documentation supplied to the Company shall include a statement that the design, construction, operation and quality assurance provisions are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. i l l G-3 Rev. 4

,7 f( U22 ' Duke power Company permanent or portable solidification- .2.3 systems: shall have a: detailed system description' giving all-solidification equipment interfaces with other company equipment.-> Drawings or diagrams shall be -includedxdetailing all solidification system intel-faces' with other plant radwaste equipment and systems. NOTZ: This information may be included as part of a TopicaliReport furnished by the equipment manufacturer or supplier or_as part of the plant specific Final Safety Analysis Report. 2.2.4 Duke Power. Company permanent or portable solidification systems shall be designed, constructed, operated per and_ meet all quality assurance provisions of NRC ETSB Branch Technical Positien 11-3 and Regulatory Guide 1.143. 2.2.5 StationLprocedures shall be established to assure the following requirements are met: 2.2.5.1 A representative sample shall be taken from at least every tenth batch of each waste type to verify solidification. 2.2.5.2 If the; initial sample fails to verify solidification, a representative sample shall be taken from each - consecutive batch of the same type waste until three consecutive samples demonstrate solidification. 2.2.5.3 A representative sample shall meet all the following conditions: (a) The contents-of the container to be sampled shall be recirculated a. minimum of three' volume turnovers or adequately mixed to achieve a homogeneous mixture. NOTE: Adequately mixed shall be defined as: mixing via agitative or recirculative flow which exceeds a specified minimum rate which has been. documented to provide a representative sample for the vessel. -(b) For final samples prior to initiating solidification, no additional waste shall be introduced into the container ~ after recirculation or mixing has begun. vessel level readings or input isolation shall be documented at the time of mixing initiation, sampling, and process initiation. -(c) Recirculation or mixing time and/or volume must be ' uninterrupted from initiation until completion of sample collection. ll[2.2.5.4. During the recirculation and sampling period, the vessel shall not be placed in a transfer mode. I G-4 Rev. 4

g.. g.. s 4 r 2.'i. 5. 5 sample analysis shall be performed as outlined in (') - site-specific procedures for each waste form and U so3tdification media. These should include such analysis as: t, (a) Haste pH. .(b) Waste density.- (c) Waste boron concentration. o (d)- Waste oil content. 2.2.5.6 Test solidification shall be performed to establish bottndary conditions for all process parameters. r. NOTE: " Process-parameters' shall be defined as, "those conditions critical to insure complete solidification". NOTE: " Boundary conditions" shall be defined as, " acceptable numerical values for process parameters as established by a test solidification". 2.2.5.7 Process parameters should include.any of the following which are required to assure solidification: (a). Waste form. (b) Waste cd solidification agent ratio. (c) Amount of each-solidification additive. (d) Waste pH. (e) Waste boron concentration. (f) Waste. density. c(g') Waste oil content, t th) . Mixer speed. (1)" -Mixing time. y L(j) Curing time. (k) specific activity, ~ s

2.2.5.8 Vender shall submit sample analysis, test solidification results and prescribed-boundary condi-

.tions~to Station Chemistry supervision. 1({)2.2.5.9 Station Chemistry. supervision shall review the data outlined in Step 2.2.5.8 and shall authorize solidi-fication prior to initiation. G-5 Rev. 4 3 i e _ _ ~

t t (_)) f (a) Difficulties and/or disagreements between vendor and I station personnel should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot f be reached at the station level, i 2.2.5.10 Solidification for disposal shall not be performed { unless the test solidification is acceptable. i i 2.2.5.11 All system operation shall be controlled by station procedures to assure that the solidification system is operated within the boundary ccnditions established in i Step 2.2.5.7. (a) Vendor procedures shall be incorporated as attachments to i station procedures. Vendor format may be retained as a DPC enclosure if desired or the procedure may be rewritten into DPC format. 2.2.5.12 The absence of free standing liquids (FSL) shall be verified for each vessel of solidified waste prior to disposal. Verification shall be performed by either confirmation that the Process Control Program was followed or by physical testing. ./ (a) Physical testing shall be required for each vessel if the T Process Control Program was not followed or if any off-normal condition existed during processing. (a.1) Physical testing shall consist of visual. inspection and probe-penetrate tests. f (b) A vessel shall have less than 0.5% free standing liquid by waste volume. (c) If a High Integrity Container is utilized, the vessel shall have less than 1% free standing liquid. 2.2.5.13 Any solidification vessel that does not pass the tests specified in Step 2.2.5.12 shall not be shipped to a burial sits until reproesssing or repackaging has resulted in an acceptable product. i 2.2.5.14 Records shall be maintained by Duke Power Company on each vessel of solidified wastes. These records shall be maintained for six (6) years (per the Administrative Policy Manual). (a) These records shall includes O (a.1) Representative sampling documentation (per Step 2.2.5.3>. j. l G-6 Rev. 4 4

()(a.2) Sample analysis results (per Step 2.2.5.5). (a.3) ' Reference test solidification results and boundary conditions (per Steps 2.2.5.6 and 2.2.5.7). (a.4) Station Radwaste Supervision authorization for solidification per (Step 2.2.5.9). i (a.5) System operation data to insure all boundary conditions were met (per Step 2.2.5.11). '(a.6) FSL Verification (per Step 2.2.5.12). R 3.0 DEWATERING ) 3.1 Vender Requirements I 1 3.1.1 Any vender utilized by Duke Power Company to provide dewatering services shall have a Topical Report that is either under NRC review or has NRC approval,for shall supply to Duke Power sufficient documentation of process i and results for review to demonstrate adequate dewatering is accomplished using the described process. i 3.1.2 Any vender dewatering servicer utilized by Duke Power Company shall ba. approved by the Corporate Technical System Manager, Nuclear Chemistry anc statien(s) Technical Services Superintendent prior to operation. 1 3.1.2.1 Technical review shall be performed by corporate and station radwaste staffs of all vendor documants and procedures to insure they meet all requirements of the Duke Power Company PCP outlined below. l 3.1.3 Chem-Nuclear Systems, Inc. has been reviewed and approved to provide dewatering services to Oconee, McGuire, and Catawba Nuclear Stations as described in i Topical Report CNSI-DW-11118-01. 3.2 Program Requirements i 3.2.1 The vendor topical report or documentation supplied to l the company shall include a detailed system description giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing all dewatering system interfaces with plant radwaste systems and equipment. 3.2.2 The vendor topical report or documentation supplied to the Company shall include a statement that the design, construction, operation and quality assurance provisions (]) are in accordance with Regulatory Guide 1.143. G-7 Rev. 4

{ -([3.2.3 'All vendor supplied portable domineralizers shall meet all' requirements of Steps 3.2.1 and 3.2.2. 13.2.4 Duke Power Company permanent or portable dewatering systems shall have a detailed system description giving i i all dewatering equipment interfaces with other company equipment. Drawings or diagrams shall be included detailing all dewatering system interfaces with other plant radwaste equipment and systems. i NOTE: This information may be included as part of a Topical Report furnished by the equipment manufacturer or I supplier or as part of the plant specific Final Safety Analysis Report. 3.2.5 Duke Power-Company permanent or portable dewatering J systems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC Branch i Technical Position 11-3 and Regulatory Guide 1.143. i 3.2.6 Station procedures shall be established to assure the following requirements are met: 3.2.6.1 Boundary conditions shall be established for all process parameters. NOTE 'O Process parameters shall be defined as, "those conditions critical to insure complete dewatering". NOTE: " Boundary conditions" shall be defined as, unacceptable numerical values for process parameters". 3.2.6.2 Process parameters shall be identified in site-specific procedures. Typical parameters are: (a) Waste form. t (b) Settling time. (c) Drain (or pump) time. (d) Drying time. 3.2.6.3 Sample analysis and boundary conditions shall be submitted to the Station Radwaste Supervisor. (a) For filter dewatering, data shall be submitted to the Station Health Physics Supervisor. 3.2.6.4-Station Supervisor shall review the data outlined in Step 3.2.6.3 and shall authorize dewatering prior to initiation. G-8 Rev. 4

s i i .{}(a) Difficulties and/or disagreements between vendor and station personnel should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot be reached at l the station level. 3.2.6.5 All operations shall be controlled by station procedures to assure that all boundary conditions established in Step 3.2.6.1 are met. (a) Vendor procedures shall be incorporated as attachments to I station procedures. Vendor format may be retained as a DPC enclosure if desired or the procedure may be rewritten into DPC format. 1 3.2.6.6 The absence of free standing liquids (FSL) shall be verified for each vessel of dowatered waste prior to disposal. Verification shall be performed by either i confirmation that the Process Control Program was followed or by physical testing. (a) Physical testing shall be required for each vessel if the Process Control Program was not followed or if any off-normal condition existed during processing. (b).A vessel shall have less than 0.5% free liquids by waste volume. (c) A High Integrity container shall have less than 1% free liquids by waste volume. f 3.2.6.7 Any dewatered vessel containing excess free liquids, as defined in Step 3.2.6.6, shall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product. 3.2.6.8 Records shall be maintained by Duke Power Company on each vessel of dewatered wastes. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall includes (a) Sample analysis and boundary conditions (per Step 3.2.6.3). (b) Station supervisor authorization for dewatering (per Step 3.2.6.4). (c) Equipment operation data to insure all boundary conditions-were met (per Step 3.2.6.5). .(d) FSL Verification (per Step 3.2.6.6). O .0 4 WASTE OIL 4.1 Incidental levels of waste oil may be solidified using the system described in Section 2.2. G-9 Rev. 4

_ _ _~_ " Incidental" shall-be defined as.less than 1% oil, .( ) 4.1.1 i 4.2 If larger volumes of waste oil are to be solidified a special procedure shall be used. 4 ) 4.2.1 The oil-specific procedure shall include all' e requirements in Section 2.0. l 4.3 Solidified waste oil shall not be shipped to the licensed burial site at Barnwell, S.C., for disposal, except as defined in Step 4.1. 5.0 INTERIM STORAGE i 5.1 Program Requirements 5.1.1 Station procedures shall be established to assure the -following requirements are met 5.1.1.1 Any processed (i.e., solidified or dewatered) waste that is stored for an interim period in a disposal container shall be packaged such that there is no interaction between the waste and its container. 5.1.1.2 If applicable, certificates of Compliance shall be maintained at each station for all waste disposal containers used for interim storage. 5.1.1.3 Vendor supplied handling and storage procedures shall be maintained at each station. 5.1.1.4 Each< container and waste shall be checked against information given in Steps 5.1.1.2 and 5.1.1.3 to insure all chemical compatibility requirements are met. 5.1.1.5 Station Chemistry or Health Physics supervision shall review the information in Step 5.1.1.4 and shall certify chemical compatibility and authorize storage. 5.1.1.6 Records shall be maintained by Duke Pcwer. Company for each container. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include ~ '(a) Chemical compatibility certification (per step 5.1.1.5). (b) Station supervision authorization to store waste (per Step 5.1.1.5). 6.0 10CFR61 COMPLIANCE 6.1 Vendor Requirements e l. G-10 Rev. 4

f I r. ) q h 6.1.1 The vendor (s) described in Section 2.1 for solidification shall have a NRC approved report documenting compliance with waste form requirements in the final i solidified product, or shall supply Duke Power sufficient ] i documentation to demonstrate waste fem compliance. 6.1.2 The vendor (s) described in Section 2.1 for dewatering small have a NRC approved report documenting compliance with waste form requirements in the final dewatered i product, or shall supply Duke Power sufficient documentation to demonstrate waste form compliance. i 6.1.3 Any vendor-providing High Integrity Containers to Duke I Power Company shall have a NRC approved report documenting compliance with waste form requirements, or shall supply Duke Power sufficient documetntation to demonstrate waste form compliance. t 6.1.4 All vender reports (per Steps 6.1.1, 6.1.2, and 6.1.3) shall contain a statement that the final product conforms to the appropriate waste form for either Class A, B, or C waste. 6.2 Program Requirements 6.2.1 Stati n procedures shall be established to assure the following requirements are met 6.2.1.1 Each container of processed (i.e., solidified or dowatered) waste shall be classified as either class A, B, or C waste using the Duke Power Company "10 CFR Part 61 Waste Classification and Waste Form Implementation Program". ,6.2.1.2 Each container of processed waste shall be certified to the appropriate waste fem for either Class A, B or C - waste. (a) Waste form certification shall be contingent upon the documents referenced in Section 6.1. 6.2.1.3 Records shall be maintained for each container of processed waste to assure compliance with the requirements of Steps 6.2.1.1 and 6.2.1.2. These records shall be maintained for six (6) years (per the Administrative Policy Manual). 7.0_ TRANSPORTATION 7.1 Program Requirements O G-11 Rev. 4

i l h 7.1.1 All shipping casks used to transport processed waste for burial shall have a NRC issued Certificate of Compliance. -7.1.2 Station procedures shall be established to insure all requirements of the Certificate of Compliance are met. 7.1.2.1 Vendo procedures shall be incorporated into station procedures prior to use. Vendor format may be retained, if desired, or the procedure may be rewritten into DPC format. 7.1.3. Station procedures shall be established to insure all . applicable Federal and State regulations and burial site criteria are met for each container of processed waste. 7.1.4 Records shall be maintained for each container and shipment of processed waste. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include: 7.1.'4.1 Documentation of a' valid certificate of compliance for each cask (per Step 7.1.1). Maintained for six (6) years. 7.1.4.2 Documentation that all requirements of the Certificate of Compliance were met (per Step 7.1.2). Maintained for six (6)-years. l 7.1.4.3 Documentation that all shipping regulations were met (per Step 7.1.3). Maintained for life of plant. 8.0 REVIEWS 8.1 Program Requirements 8.1.1 Changes to the Corporate Process control Program shall-be reviewed by the Corporate Nuclear Chemistry staff and each station's Radwaste and Health Physics staffs prior to implementation. Proposed revisions shall be l reviewed against Technical Specifications and all applicable NRC guidance to assure all requirements of a Process Control Program have been addressed. Review-documents shall include: 8.1.1.1 NUREG-0133. 8.1.1.2 NUREG-0472. 8.1.1.3 NUREG-0800. O 8.1.1.4 era =ch rech=ica1 rosition - ETes 11-3. G-12 Rev. 4 1 .~

y i i -O 8115 ^99aat= 4-^ "o i = outa =ce <== re =r rv Storage...". 8.1.1.6 NRC Review Criteria for Solid Waste Management Systems. 8.1.1.7 Site-specific Technical Specifications. 8.1.2 Changes to the Corporate Process Control Program shall { be approved by the Technical System Manager, Nuclear i Chemistry and each station's Technical Services Super- ) intendent prior to implementation. j 8.1.3 Each Station Manager shall document that any changes to the Corporate Process Control Program have been reviewed and approved (per Steps 8.1.1 and 8.1.2). 8.1.4 The Nuclear Safety Review Board shall review the activities of the Station Manager detailed in Step B.1.3. 8.1.5 A record of the review (per Step 8.1.4) shall be sent to the Vice President, Nuclear Production and the Executive Vice President, Power Operations within fourteen (14) days following completion of the review. 8.1.6 All changes to the Corporate PCP shall be sent to the NRC in each station's Semi-annual Radioactive Effluent Report for the period in which the changes were implemented. 8.1.7 Changes to all implementing procedures shall be reviewed by station radwaste or health physics staff and approved by the station's Technical Services, operating, QB Maintenance Superintendent, or Station Managar, prior to implementation. 8.1.7.1 Changes to bnplementing procedures shall be reviewed by the Technical Services, operating, QR Maintenance Superintendent, or Station Manager, to assure they do not conflict with the Corporate Process Control Program. 8.1.8 Records shall be maintained documenting the approvals required by Section 8.1. Records shall be maintained for six (6) years (per the Administrative Policy Manual). 9.0 AUDITS 9.1 Program Requirements L O (: G-13 Rev. 4

e, l- -C ;1.1 The Corporate Process Control Program and station 9 c impitamenting procedures shall be audited at least once per twenty-four months at each station. 9.1.2 This audit shall be performed under the cognizance of the NSRB. 9.1.3 Audit reports shall be forwarded to the Vice President, Nuclear Production; Executive Vice President, Power Operatiens; and Station Manager within thirty (30) days i of completion of the audit. i 3 O I l l-O- G-14 Rev. 4 l-

l { DUKE POWER COMPANY O t STATION PROCESS CONTROL PROGRAM l 1.0 PURPOSE The purpose of the Duke Power Company Station Process Control Program shall be to insure all requirements of the DPC Corporate Process Control Program have been met for each container of solidified or dewatered radioactive waste shipped for burial at a licensed burial facility. 2.0 COMPOSITION l 2.1 The Duke Power Company Station Process Control Program shall consist of: 2.1.1 The Duke Power Company Process Control Manual Introduction (Section I). 2.1.2 The Duke Power Company Corporate Process Control Program. 2.1.3 A list of all station-specific procedures that \\ implement the requirements of the Corporate Process Control Program. 2.1.4 Diagrams or. drawings or drawing numbers showing all l connections between plant radwaste systems and solidi-fication and dewatering equipment. 2.1.5 Documentation of NRC approval of the initial Station ) Process Control Program. 2.1.6 Documentation of System Technical System Manager, Nuclear Chemistry station, Technical Services Superintendent, and Station Manager approval of all changes to the Corporate Process Control Program. 2.1.7 Documentation that all changes to the Corporate and/or Station Process Control Program were sent to the NRC in the Semi-Annual Radioactive Effluent Report. 2.1.8 Relevant Sections and Subsections of Process Control Program-related definition transferred from Section 1 of Nuclear Station Technical Specifications. 2.1.9 Relevant sections and subsections of Process Control Program-related limiting conditions for operation, bases 3(])- and surevillance requirements transferred from sections ~3/4 of Nuclear Station Technical Specifications. 1 l G-15 Rev. 4

.i, ... : ;o t. . q.., f 3.0 EXCEPTICDIS .3.1.Each Station's exceptions to the Corporate PCP shall be documented in the Station's PCP. .i 4 f r P b t 1 O; ? 1 s i ? i 0: a G-16 Rev. 4

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4 ,e -'a i t. -- i DUKE POWER COMPANY PCP REVISION APPROVAL Revised PCP Sections ,p Ch!WI.: rf Corporate PCP, Rev. 4 h [ ONS PCP, Rev. p MNS PCP, Rev. g1 o CNS PCP, Rev. W mt ThisrevisionhasbeenreviewedagainstTechnihalSpecifications and applicable NRC guidance documents and found to be acceptable. Prepared By: M. B. Entrekin

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m ' fp v "c-i DUKE POWER COMPANY CORPORATE PROCESS CC,NTROL PROGRAM l 1 TABLE OF CONTENTS .l i 1.0: PURPOSE { ^ 2.0 SOLIDIFICATION { 2.1 Vendor-Requirements 2.2 Program Requirements-3.0' DEWATERING '3.1 Vendor Requirements

3. 2: Program Requirements I

{ 4.0 WASTE OIL ~ T '5.O INTERIM-STORAGE / L/ = 6.0 10 CFR PART 61 COMPLIANCE I 6.1 Vendor Requirements 6.2 Program Requirements 7.O TRANSPORTATION-7.1-Program' Requirements 8.0 REVIEWS 9.0. AUDITS ..30 G-1 Rev. 4

4 V ) L i w DUKE POWER COMPANY (_) I CORPORATE I PROCESS CONTROL PROGRAM 1 4 1.0 PURPOSE 1 1.1 The purpose of the Duke Power Company Corporate Process { control Program is to-establish a set of requirements that shall be met at all nuclear stations to insure that all solidification and dewatering activities are conducted in a manner and produce a j final product that complies with all applicable Federal and State regulations and licensed burial site criteria. 1.2 The Duke Power Company Process Control Program shall be used to control and direct all solidification and dewatering activities for liquids (e.g., evaporator concentrates) and " wet solids" (e.g., resin slurries, filter. backwash slurries, cartridge filters) at the Oconee Nuclear Station, Units 1, 2 i and 3, the McGuire Nuclear Station, Units 1 and 2, and the Catawba Nuclear Station, Units 1 and 2. 1.3 Station - specific procedures shall be developed to implement the requirements of this corporate PCP. ~ ( 1.4 Station Process Control Programs shall contain Process Control Program-related sections on definitions, limiting conditions for operation, bases and surveillance requirements transferred from Station Technical Specifications (TS). 1.5 This Process Control Program and implementing procedures shall assure that all solidification and dewatering activities are in compliance with 10CFR20, 50, 61, 71, and 49 CFR and licensed burial site criteria. 1.6 If.this Process Control Program is not followed, each vessel of processed (i.e., solidified or dewatered) waste shall be physically tested to verify the absence of free standing liquids and all other applicable waste form requirements. 2.0 SOLIDIFICATION 2.1 Vendor Requirements ] G-2 Rev. 4

\\ -(])2.1.1 Any vendor utilized for solidification services by Duke { Power Company shall have a Topical Report that is either i under NRC review or has NRC approval, or shall supply to Duke Power sufficient documentation of the process and i results for review to demonstrate an acceptable product will be produced using the described solidification process. 2.1.2 Any vendor solidification services utilized by Duke Power Company shall be approved by the Corporate Technical System Manager, Nuclear Chemistry and station (s) Technical Services Superintendent prior to i operation. t ' 2.1.2.1 Technical review shall be performed by corporate and k station radwaste staffs of all vendor documents and l procedures to insure they meet the requirements of the Duke Power Company PCP outlined below. 2.1.3 Chem-Huclear Systems, Inc. has been reviewed and approved to provide solidification services to the oconee, .McGuire, and Catawba Nuclear Stations as described int Mobile Cament solidification System, Topical Report CNSI-2 (4313-01354-0IP-A). Approved waste streams for solidi-1 fication are: boric acid evaporator concentrates, spent bead resin, spent powdered resin, filters, filter backwash slurry, and resin regenerative chemical wastes. l ( ) 2.1.4 Babcock and Wilco:t has been reviewed and approved to provide solidification services to McGuire, Oconee and Catawba Nuclear Stations for Class a unstable wasta as described in B & W's supporting documents. However, each . drum of solidified product shall be puntured and fully inspected prior to shipment for disposal. Approved waste streams for solidification aret oil, oil and water mixtures, organics, EDTA-based steam generator cleaning solution concentrate, and sludges. The approved binders are Aquaset, Aquaset II, Petroset and Petroset II. 2.2 Program Requirements 2.2.1 The vendor topical report or documentation supplied to the company shall include a detailed system description giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing all solidification system interfaces with plant radwaste systems and equipment. 2.2.2 The vendor topical report or documentation supplied to the company shall include a statement that the design, construction, operation and quality assurance provisions are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. G-3 Rev. 4 ~ - - -- ~ ~--

't - 2.2.3 Duke Power Company permanent or portable solidification. l,). systems shall have a detailed system description giving g all solidification equipment interfaces with other i company equipment. Drawings or diagrams shall be included detailing all solidification system interfaces with other plant radwaste equipment and systems. NOTE: This information may be included as part of a Topical Report furnished by the equipment manufacturer or supplier or as part of the plant specific Final Safety Analysis Report. 2.2.4 Duke Power Company permanent or portable solidification systems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. 2.2.5 Station procedures shall be established to assure the following requirements are met: 2.2.5.1 A representative sample shall be taken from at least [ every tenth batch of each waste type-to verify solidification. 2.2.5.2 If the initial sample fails to verify solidification, a representative sample shall be taken from each \\r s - consecutive batch of the same type waste until three consecutive samples demonstrate solidification. 2.2.5.3 A representative sample shall meet all the following ~ conditions: (a) The contents of the container to be sampled shall be recirculated.a minimum of three volume turnovers or adequately mixed to achieve a homogeneous mixture. NOTE: Adequately mixed shall be defined as:. mixing via agitative or recirculative flow which exceeds a specified minimum rate which has been documented to provide a representative sample for the vessel. (b) For final samples prior to initiating solidification, no additional waste shall be introduced into the container after recirculation or mixing has begun. Vessel level readings or input isolation shall be documented at the time of mixing initiation, sampling, and process initiation. (c) Recirculation or mixing time and/or volume must be uninterrupted from initiation until completion of sample collection. (])

2. 2. 5. 4 During the recirculation and sampling period, the vessel shall not be placed in a transfer mode.

G-4 Rev. 4

D '(_)2.'2.5.5 Sample analysis shall be performed as outlined in us site-specific procedures for each waste form and l solidification media. These should include such analysis as (a) Waste pH. (b) Waste density. (c) Waste boron concentration. (d) Waste oil content. 2.2.5.6 Test solidification shall be performed to establish boundary conditions for all process parameters. NOTE: " Process parameters' shall be defined as, "those conditions critical to insure complete solidification". NOTE: " Boundary conditions" shall be defined as, " acceptable numerical values for process parameters as established ~by a test solidification". 2.2.5.7 ' Process parameters should include any of the following which are required to assure solidification: (a). Waste form. (b) Waste to solidification agent ratio. (c). Amount of each solidification additive. (d) Waste pH. (e) Waste boron concentration. (f) Waste density. (g) Waste oil content. (h) Mixer speed.. (i) Mixing time. (j)_ Curing time. (k) Specific activity. 2.2.5.8 Vendor shall submit sample analysis, test solidification results and prescribed boundary condi-tions to Station Chemistry supervision. (]) ' 2. 2. 5. 9 Station Chemistry supervision shall review the data outlined in Step 2.2.5.8 and shall authorize solidi-fication prior to initiation. G-5 Rev. 4

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(a) Difficulties and/or disagreements between vender and station personnel should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot be reached at the station level. 2.2.5.10- Solidification for disposal shall not be performed unless the test solidification is acceptable. 2.2.5.11 All system operation shall be controlled by station procedures to assure that the solidification system is operated within the boundary conditions established in Step 2.2.5.7. (a) Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC enclosure if desired or the procedure may be rewritten into DPC format. 2.2.5.12 The absence of free standing liquids (FSL) shall be verified for each vessel of solidified waste prior to disposal. Verification shall be performed by either confirmation that the Process Control Program was followed or by physical testing. (a)- Physical testing shall be required for each vessel if the Process Control Program was not followed or if any off-normal condition existed during processing. (a.1). Physical testing shall consist of visual inspection and probe penetrate tests. .(b) A vessel shall have less than 0.5% free standing liquid by waste volume. (c) If a High Integrity Container is utilized, the vessel shall have less than 1% free standing liquid. 2.2.5.13 Any solidification vessel that does not pass the tests specified in Step 2.2.5.12 shall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product. 2.2.5.14 Records shall be maintait. d by Duke Power Company on each vessel of solidified wastes. These records shall be maintained for six (6) years (per the Administrative Policy Manual). (a) These records shall include: (a.1) Representative sampling documentation (per Step 2.2.5.3). G-6 Rev. 4

F,~ a !L L ;, L j h-(a.2) Sample analysis results (per Step 2.2.5.5). (a.3) Reference test solidification results and boundary conditions (per Steps 2.2.5.6 and 2.2.5.7). J t (a.4)- Station Radwaste Supervision authorization for I solidification per (Step 2.2.5.9). (a.5) System operation data to insure all boundary conditions were met (per Step 2.2.5.11). (a.6) FSL Verification (per Step 2.2.5.12). 3.0 DEWATERING 3.1 Vendor Requirements 3.1.1 Any vender utilized by Duke Power Company to provida dewatering services shall have a Topical Report that is j either under NRC review or has NRC approval, or shall supply to Duke Power sufficient documentation of process. and results for review to demonstrate adequate dewatering is accomplished using the described process. 3.1.2 Any vender cewatering servicer utilized by Duke Power Company shall ha approved by the Corporate Technical n System Manager, Nuclear Chemistr/ and statien(s) ) Technical cervices Superintendent prior to operation. 3.1.2.1 Technical review shall be performed by corporate and l station radwaste staffs of all vendor documents and procedures to insure they meet all requirements of the Duke Power Company PCP outlined below. 3.1.3 Chem-Nuclear Systems, Inc. has been reviewed and approved to provide dewatering services to Oconee, McGuire, and Catawba Nuclear Stations as described in { Topical Report CNSI-DW-11118-01. 3.2 Program Requirements 3.2.1 The vendor topical report or documentation supplied to i the Company shall include a detailed system description giving all vendor interfaces with company equipment. j Drawings or diagrams shall be included detailing all dewatering system interfaces with plant radwaste systems and equipment. ~ ' 3.2.2 The vendor topical report or documentation supplied to the Company shall include a statement that the design, construction, operation and quality assurance provisions h are in accordance with Regulatory Guide 1.143. G-7 Rev. 4 +

l 1 j ( ) 3.2.3 All vendor supplied portable domineralizers shall meet all requirements of Steps 3.2.1 and 3.2.2. 3.2.4 Duke Power Company permanent or portable dewatering systems shall have a detailed system description giving all dewatering equipment interfaces with other company [ equipment. Drawings or diagrams shall be included detailing all dewatering system interfaces with other i plant radwaste equipment and systems. l NOTES. This information may be included as part cf a Topical Report furnished by the equipment manufacturer or supplier or as part of the plant specific Final Safety Analysis Report. 3.2.5 Duke Power Company permanent or portable dewatering systems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC Branch i Technical Position 11-3 and Regulatory Guide 1.143. 3.2.6 Station procedures shall be established to assure the following requirements are met: 3.2.6.1 Boundary conditions shall be established for all process parameters. m NOTE: Process parameters shall be defined as, "those U_ conditions critical to insure complete dewatering". NOTE: " Boundary conditions" shall be defined as, j unacceptable numerical values for process parameters". 3.2.6.2. Process parameters shall be identified in site-specific procedures. Typical parameters are: (a) Waste form, l' (b) Settling time. l (c) Drain (or pump) time. (d) Drying time. L p 3.2.6.3 Sample analysis and boundary conditions shall be submitted to the Station Radwaste Supervisor. (a) For filter dewatering, data shall be submitted to the Station Health Physics Supervisor. 3.2.6.4 Station Supervisor shall review the data outlined in Step 3.2.6.3 and shall authorize dewatering prior to initiation. G-8 Rev. 4

l l f .( )-[(a) Difficulties and/or disagreements between vendor and station i personnel should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry j staff should be contacted if resolution cannot be reached at t the station level. 3.2.6.5 All operations shall be controlled by station procedures to assure that all boundary conditions established in Step 3.2.6.1 are met. (a) Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC enclosure if desired or the procedure may be rewritten into DPC format. 3.2.6.6 The absence of free standing liquids (FSL) shall be verified for each vessel of dewatered waste prior to disposal. Verification shall be performed by either confirmation that the Process Control Program was followed or by physical testing. (a) Physical testing shall be required for each vessel if the Process Control Program was not followed or if any off-normal condition existed during processing. (b) A vessel shall have less than 0.5% free liquids by waste . volume. (c) A High Integrity Container shall have less than 1% free liquids by waste volume. 3.2.6.7 Any dewatered vessel containing excess free liquids, as defined in Step 3.2.6.6, shall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product. 3.2.6.8 Records shall be maintained by Duke Power Company on each vessel of dewatered wastes. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include: + (a) Sample analysis and boundary conditions (per Step 3.2.6.3). (b) Station supervisor authorization for dewatering (per Step 3.2.6.4). (c) Equipment operation data to insure all boundary conditions were met (per Step 3.2.6.5). (d) FSL Verification (per Step 3.2.6.6). O .0 4 WASTE OIL 4.1 Incidental levels of waste oil may be solidified using the system described in Section 2.2. G-9 Rev. 4

t I' ic'. n O .1.1. " Incidental" shall be defined as less than 1% oil. 4 4.2 If larger volumes of waste oil are to be solidified a l special procedure shall be used. 4.2.1 The oil-specific procedure shall include all requirements in Section 2.0. i 4.3 Solidified waste oil shall not be shipped to the licensed burial site at Barnwell, S.C.,-for disposal, except as defined in Step 4.1. 5.0 INTERIM SMRAGE 5.1 Program Requirements 5.1.1 Station procedures shall be established to assure the i following requirements are met 5.1.1.1 Any processed (i.e., solidified or destatered) waste that is stored for an interim period in a disposal container shall be packaged such that there is no interaction between the waste and its container. t 5.1.1.2 If applicable, certificates of compliance shall be maintained at each station for all waste disposal l containers used for interim storage. l 5.1.1.3 Vendor supplied handling and storage procedures shall be maintained at each station. t 5.1.1.4 Each container and waste shall be checked against information given in Steps 5.1.1.2 and 5.1.1.3 to insure all chemical compatibility requirements are met. 5.1.1.5 Station Chemistry or Health Physics supervision shall review the information in step 5.1.1.4 and shall certify chemical compatibility and authorize storage. H5.1.1.6 Records shall be : maintained by Duke Power Company for s each container. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include: (a) Chemical compatibility certification (per Step 5.1.1.5). (b) Station supervision authorization to store waste (per Step 5.1.1.5). 6.0 10CFR61 COMPLIANCE 6.1 Vendor Requirements F G-10 Rev. 4

()6.1.1 The vendor (s) described in Section 2.1 for solidification shall have a NRC approved report documenting compliance with waste form requirements in the final solidified product, or shall supply Duke Power sufficient documentation to demonstrate waste form compliance. 6.1.2 The vender (s) described in Section 3.1 for dowatering shall have a NRC approved report documenting compliance with waste form requirements in the final dowatered product, or shall supply Duke Power sufficient documentation to demonstrate waste form compliance. 6.1.3 Any vendor providing High Integrity Containers to Duke Power Company shall hhve a NRC approved report documenting compliance with waste form requirements, or shall supply Duke Power sufficient documentation to demonstrate waste form compliance. 6.1.4 All vendor reports (per Steps 6.1.1, 6.1.2, and 6.1.3) shall contain a statement that the final product conforms to the appropriate waste form for either class A, B, or C waste. 6.2 Program Requirements . O 6.2.1 Stati:n procedures shall be established to assure the following requirements are met: 6.2.1.1 Each container of processed (i.e.,. solidified or dewatered). waste shall be classified as either class A, B, or C waste using the Duke Power Company "10 CFR Part 61 Waste Classification and Waste Form Implementation Program". 6.2.1.2 Each container of processed waste shall be certified to the appropriate waste form for either Class A, B or C waste. (a) Waste form certification shall be contingent upon the documents referenced in Section 6.1. 6.2.1.3 Records shall be maintaited for each container of j processed waste to assure compliance with the requirements of Steps 6.2.1.1 and 6.2.1.2. These records shall be maintained for six (6) years (per the Administrative Policy Manual). 7.0 TRANSPORTATION 7.1 Program Requirements () G-11 Rev. 4

I O v.1.1 x11 sai>>ino casxs used to trans ort vrocessed waste for burial shall have a NRC issued Certificate of Compliance. t 7.1.2 Station procedures shall be established to insure all requirements of the certificate of Compliance are met. 7.1.2.1 Vendor procedures shall be incorporated into station procedures prior to use. Vendor format may be retained, if desired, or the procedure may be rewritten into DPC format. 7.1.3 Station procedures shall be established to insure all applicable Federal and State regulations and burial site criteria are met for each container of processed waste. 7.1.4 Records shall be maintained for each container and shipment of processed waste. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include 7.1.4.1 Documentation of a valid certificate of compliance for each cask (per Step 7.1.1). Maintained for six (6) years. 'O 7.1. 4. 2 Documentation that all requirements of the certificate of compliance were met (per Step 7.1.2). Maintained for six (6) years, t 7.1.4.3 Documentation that all shipping regulations were met (per Step 7.1.3). Maintained for life of plant. 8.0 REVIEWS 8.1 Program Requirements 8.1.1 Changes to the Corporate Process Control Program shall be revie'>ed by the Corporate Nuclear Chemistry staff and each station's Radwaste and Health Physics staffs prior to implementation. Proposed revisions shall be reviewed against Technical Specifications and all applicable NRC guidance to assure all requirements of a Process Control Program have been addressed. Review documents shall include: 8.1.1.1 NUREG-0133. i 8.1.1.2 NUREG-0472. 8.1.1.3 NUREG-0800. O 8.1.1.4 ar ach 2 canica1 rosition - eras 11-3. G-12 Rev. 4

1 1 1 k h 8.1.1.5 Appendix aa.4-A, " Design Guidance for Temporary Storage...". 8.1.1.6 NRC Review Criteria for Solid Waste Management Systens. 8.1.1.7 Site-specific Technical Specifications. 8.1.2 Changes to the Corporate Process Control Program shall be approved by the Technical System Manager, Nuclear Chemistry and each station's Technical Services Super-intendent prior to bnplementation. 8.1.3 Each Station Manager shall document that any changes to I the. Corporate Process Control Program have been d reviewed and approved (per Steps 8.1.1 and 8.1.2). 8.1.4 The Nuclear Safety Review Board shall review the activities of the Station Manager detailed in Step 8.1.3. 8.1.5 A record of the review (per Step 8.1.4) shall be sent to the Vice President, Nuclear Production and the Executive Vice President, Power Operations within fourteen (14) days following completion of the review. 8.1.6 All changes to the Corporate PCP shall be sent to the NRC in each station's Semi-annual Radioactive Effluent Report for the period in which the changes were implemented. 8.1.7 Changes to all implementing procedures shall be reviewed by station radwaste or health physics staff and approved by the station's Technical Services, Operating, OR Maintenance Superintendent, or Station Managar, prTor to implementation. 8.1.7.1 Changes to implementing procedures shall be reviewed by the Technical Services, operating, OR Maintenance Superintendent, or Station Manager, to assure they do not conflict with the Corporate Process Control Program. 8.1.8 Records shall be maintained documenting the approvals required by Section 8.1. Records shall be maintained for six'(6) years (per the Administrative Policy Manual). 9.0 AUDITS 9.1 Program Requirements LO? G-13 Rev. 4

.g,, _ *(: ce '1 ( ,y 4 l- .. ;x ~ L!j;.9.1.1 The. Corporate Process Control Program and station implementing procedures shsll'bs audited at least once e [ - 'per twenty-four months ~at each station.- l 2: 9.1. 2 '- This audit shall be' performed under'the cognizance of the NSRB. t 9.1.3 ' Audit reports shall be forwarded to the Vice President, Nuclear. Production; Executive.Vice President, Power operations;.and Station Manager within-thirty (30) days i ofLcompletion of the audit. ls 1 1 2 i ) _.5 G-14 Rev. 4 -= 1,

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~ i L*. ( i DUKE.-POWER COMPANY STATION PROCESS CONTROL PROGRAM 1.0 PURPOSE The purpose of the Duke Power Company Station Process Control Program:shall be to insure all requirements of the DPC Corporate Process Control Program have been met for each container of solidified or dewatered radioactive waste shipped for burial- -i at_a licensed burial facility. 2.0 COMPOSITION 2.1 The Duke Power Company Station Process Control Program shall consist of: 2.1.1 The Duke Power Company Process Control Manual Introduction (Section I). 2.1.2 The Duke' Power Company Corporate Process Control Program. g-( 2.1.3 A list of all station-specific procedures that i/ implement the requirements of the Corporate' Process s Control Program. 2.1.4 Diagrams or drawings or drawing numbers showing all connections between plant.radwaste systems and solidi-fication and dewatering. equipment. '2.1.5 Documentation of NRC approval of the initial Station Process Control Program. 2.1.6 Documentation of System Technical System Manager, Nuclear Chemistry station, Technical Services Superintendent, and Station Manager approval of all changes to the Corporate Process Control Program. 2.1.7 Documentation that-all changes to-the Corporate and/or ~ Station Process Control Program were sent to the NRC in the Semi-Annual. Radioactive Effluent Report. i~ ,2.1.8 Relevant Sections and Subsections of Process Control Program-related definition transferred from Section 1 of Nuclear Station Technical Specifications. l 2.1.9 Relevant sections and subsections of Process Control Program-related limiting conditions for operation, bases '({): and surevillance requirements transferred from sections 3/4 of Nuclear Station Technical Specifications. p t G-15 Rev. 4 1:

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2. 2! Program Requirements o 3 '. 0 : -DEWATERING 1

~3.1'. Vendor Requirements; j 3.2 Program Requirements l ' 4.0. WASTE OIL a-t 5.0'fINTERIM STORAGE 6.0!'10 CFR PART 61' COMPLIANCE-- ( V.. 6'.1 1 endor Requirements .6.2: Program? Requirements 1 7.0 TRANSPORTATION-7.1 Program Requirements. '8[0- REVIEWS-l9.0: -AUDITS' 4

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a t I 1 l;- ) DUKE POWER COMPANY CORPORATE -PROCESS CONTROL PROGRAM L 1.0 PURPOSE . 1.1. The purpose of.the Duke Power Company Corporate Process Control Program is to establish a set of requirements.that shall-be met at all. nuclear stations to-insure that all solidification and. dewatering activities are conducted in:a manner and. produce a final-product.that complies with-all applicable Federal and State i regulations and licensed burial site criteria. l'.~2 ' The Duke Power Company Process Control Program shall be used to control ~and direct all solidification and dewatering activities for. liquids (e.g., evaporator concentrates) and " wet' solids" (e.g., resin slurries, filter backwash slurries, cartridge filters) at the Oconee Nuclear Station, Units 1, 2 .and.3,-the McGuire Nuclear Station, Units 1 and 2, and the Catawba ~ Nuclear Station, Units 1 and'2. 1.3 Station specific procedures shall be developed to implement.the requirements of this corporate PCP. .G. (J' '1.4 ' Station Process Control Programs shall contain Process Control Program-related sections on definitions, limiting conditions-for operation, bases and surveillance requirements transferred,from Station Technical Specifications (TS). 1.5.This. Process Control Program and implementing procedures shall assure that all solidification and dewatering activitiesiare in compliance with 10CFR20, 50, 61, 71, and 49 CFR and licensed burial site criteria. 1.6 If this Process Control Program is not followed, each vessel of processed (i.e., solidified or dewatered) waste shall.be-physically tested to verify the absence of free star. ding liquids and all other applicable waste form requirements. 2.0 SOLIDIFICATION 2.1 Vendor Requirements O ~ G-2 Rev. 4

l 4 Wi l 211.1 h(])1 Any vender; utilized'for solidification services by Duke Power' Company shall have a~ Topical Report'that is either. under NRC review or has NRC approval, Lor shall supply to j Duke Power 2 sufficient documentation of'the' process and results-for-review to demonstrate an acceptable product will be produced using the described solidification process. 12.1.2 Any. vender solidification services utilized by Duke Power' Company shall be approved by the Corporate ' Technical System Manager, Nuclear-Chemistry and station (s) Technical Services Superintendent 1 prior to. operation. 2.1.2.1 . Technical review shall be performed _by corporate and station radwaste staffs of-all vendor documents and procedures-to insure they meet the requirements of the Duke Power Company PCP outlined below. 2.1.3' -Chem-Nuclear Systems, Inc. has been reviewed and approved to-provide solidification services to the oconee, McGuire,-and Catawba Nuclear Stations as described in: Mobile Cement 1 Solidification System, Topical Report CNSI-2 -(4313-01354-0IP-A). Approved waste streams for. solidi-fication are: boric acid evaporator concentrates, spent bead. resin, spent powdered resin, filters, filter backwash slurry, and resin regenerative chemical wastes. L 2.1.4 Babcock.and Wilcox has been reviewed and approved to provide solidification services to McGuire, Oconee and Catawba Nuclear Stations for Class A unstable waste as- -described in B & W's supporting documents.- However, each drum of solidified product shall be puntured and fully inspected prior to shipment for disposal. Approved waste streams for solidification are: oil, oil and water _ mixtures, organics, EDTA-based steam generator cleaning _ solution' concentrate, and sludges. The approved bir.ders 02 are Aquaset, Aquaset II, Petroset and Petroset II.- i .2.2 Program Requirements 2.2.1 The vendor topical report or documentation supplied to the Company.shall include a detailed system description giving all vendor interfaces with campany.. equipment. Drawings or diagrams shall be included detailing all solidification system interfaces with plant radwaste systems and equipment. 2.2.2 The vendor topical report or documentation supplied to the Company shall include a statement that the design, construction, operation and quality assurance provisions are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. G-3 Rev. 4 =. t ~

.c j ~ s e ? j )h'2.2.3 . Duke. Power. Company permanent or portable solidification I systemanshall have a detailed system description giving allisolidification equipment interfaces with1other company equipment. Drawings or diagrams shall be included 1 detailing all solidification. system interfaces with other plant:radwaste equipment and systems. NOTE: This information may be included as part of a Topical Report furnished by the equipment manufacturer or. supplier or ao part of the plant specific Final m y1 ' Safety Analysis Report. 2.2.4 Duke Power Company permanent or portable solidification systems shall be designed, constructed, operated per 't and meet all quality assurance provisions of NRC ETSB Branch Technical Position 11-3 and Regulatory Guide l.143. 2.2.5 Station procedures shall be established to assure the following requirements are met: 2.2.5.1 'A representative sample shall be taken from at least every tenth batch of each waste type to verify solidification. 4 ~ a 2.2.5.2 If the initial sample fails to verify solidification, a representative sample shall be taken from each ( consecutive batch of the same type waste until three consecutive samples demonstrate solidification. 2.2.5.'3 A representative' sample'shall meet all the following i L conditions: (a)- The contents of the container to be sampled shall be recirculatedca minimum of three volume turnovers or adequately. mixed to achieve a homogeneous mixture. I NOTE: Adequately' mixed shall be defined as: mixing via agitative'or recirculative flow which exceeds a specified ~ minimum rate which has been documented to provide a t. representative: sample for the vessel. y (b) For. final samples prior to initiating solidification, no -additional waste shall be introduced into the container l after recirculation or mixing has begun. Vessel level readings or input isolation shall be documented at the time o l~ of mixing initiation, sampling, and process initiation. l - ( c )' Recirculation or mixing time and/or volume must be uninterrupted from initiation until completion of sample collection. (]['2.2.5.4 During the recirculation and sampling period, the vessel shall not be placed in a transfer mode. G-4 Rev. 4 l

g1 _ _, ,,;ya 6 *.. i f 1 h 'l t v. 1 . [h ,15.5j ild 252 sample'. analysis shall"be performed as outlined <in? ? site-specific. procedures?for'each waste form and' 2 solidification media. -These should include such analysistas s f( a )'. ' Waste pH. l c(b)J; Waste density.- . '( e ) ' Waste boron; concentration .I l t(d)9. Waste oil content. J .2.2.5.6 . Test solidification.shall be performed to-establish ') boundary conditions for all process' parameters. 3 s NOTE:~.. Process parameters' shall be defined as, "those-conditions critical to insure complete solidification". 1 p NOTE: " Boundary conditions" shall be defined as,- " acceptable numerical. values for' process parameters.as-established-by-a test solidification".. L 12 2.5.75 Process parameters should include any of the following } .which are required to assure solidification: 4 h> (a)- Waste form.-- + L ~ .(b) ' Waste.to solidification' agent ratio. ~ j i I L

(c):

Amount of each solidification ~ additive. ' 1( d). Waste pH. L . ('e ) Waste-boron. concentration. (f) Waste ^ density. (g) -Waste oil content. lc (h)- Mixer speed.. -(i): Mixing time. [(j): ~ Curing time. 1. '(k) _ specific activity. 2;2.5.8-. Vendor-shall submit sample analysis, test solidification results and prescribed boundary condi-tions to station Chemistry supervision. 2.2.5.9-Station Chemistry supervision shall review the data outlined in'~ step 2.2.5.8 and shall authorize solidi-fication prior to initiation. G-5 Rev. 4 9 4 v.

9 e 1 l f '(a)' i Difficulties and/or disagreements between vendor and' station personnel-should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot be reached at the station level.. 2.2.5.10 SolidificationEfor disposal shall not be performed s unless:the test solidification-is acceptable. 12.2.5.11 All system operation shall be controlled by station procedures to assure that the solidification system is operated within the boundary conditions established in Step 2,2.5.7. (a) Vendor-procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC enclosure if' desired or-the procedure may be rewritten into DPC format. 2.2.5.12 The absence of free standiny liquids (FSL) shall be verified for each vessel of solidified waste prior to disposal. Verification shall be performed by either ' confirmation that the Process-Control Program was followed or.by physical testing. 1 (a). Physical testing shall be required for each vessel if the Process Control _ Program was not followed or if any off-normal condition existed during processing. f (a.1) Physical testing shall' consist of visual inspection and probe penetrate tests. I ~ b) A vessel shall.have less than 0.5% free standing liquid by ( waste. volume. (c) If a High-Integrity Container is utilized, the vessel shall have less-than 1% free standing liquid. L 2.2.5.13 Any solidification vessel that does not pass the tests specified in Step.2.2.5.12 shall not be shipped to a burial site until reprocessing or repackaging has p resulted in an acceptable product. 2.2.5.14 Records shall be maintained by Duke Power Company on U each vessel of solidified wastes. These records shall be maintained for six (6) years (per the Administrative ? Policy Manual). (a) These records shall include: l -(a.1) Representative sampling documentation (per Step f-(,j 2.2.5.3). G-6 Rev. 4 l

,a ' F t. ia.2)? Sample' analysis _results (per! Step 2.2.5.5).

(a.3)1 fReferenceitest solidification results and boundary conditions,(per Steps 2.2.5.6 and 2.2.5.7).

(a.4). Station Radwaste" Supervision authorization for solidification-per-(Step 2.2.5.9). -(a.5)- System operation data to insure all boundary conditions were met--(per Step 2.2.5.11). .FSL Verification (per Step 2.2.5.12).- (a.6). ?3.01 1 DEWATERING" -r 3.1 Vendor Requirements 3.1.1' Any vendor utilized by Duke Power Company to provide dewatering services-shall have a Topical Report that.is either under NRC review or has NRC approval, or shall E -supplysto Duke' Power sufficient documentation of process.

and results for review to demonstrate adequate dewatering is> accomplished using the described process.

f ? .3.1.2'- Any vender dewatering servicer utilized by~ Duke Power Company shall ha approved.by the Corporate Technical "( System' Manager,. Nuclear Chemistry and station (s) Technical: Services Superintendent prior to operation. 3.1.2.l' Technical review shall be performed by corporate and i' station radwaste staffs'of all vendor documents and procedures to insure they meet all: requirements of the p Duke Power Company PCP outlined below. 3.1.3 Cham-Nuclear Systems, Inc. has been reviewed and approved to provide dewatering services to oconee, McGuire, and Catawba Nuclear Stations as described in Topical Report CNSI-DW-11118-01. 3.2 Program Requirements i 3.2.1 The vendor topical report or documentation supplied to the company shall include a detailed system description i .giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing all dewatering system interfaces with plant radwaste systems and equipment. p 3.2.2 The vendor topical report or documentation supplied to the Company shall include a statement that the design, construction, operation and quality assurance provisions (]) are in accordance with Regulatory Guide 1.143. G-7 Rev. 4

m. T l c, s. E l( ):.. 3. 213 - -All" vendor supplie'd portable demineralizers shall meet 'l } all' requirements of Steps 3.2.1tand 3.2.2. i r 3.2.4' Duke Power Company permanent or portable dewatering-systems _shall have a detailed system description giving-all dewatering equipment interfaces with otherJcompany t -equipment.- -Drawings or diagrams shall be included detailing:all dewatering system interfaces with other plant radwaste equipment and systems. NOTE: This information.may be included as part.of a Topical Report furnished by the equipment manufacturer or - t supplier or as'part of-the: plant specific-Final Safety Analysis. Report. I 3.2.5 Duke Power Company permanent or' portable dewatering . systems shall.be designed, constructed, operated per and-a meet all quality assurance provisions of NRC Branch Technical Position 11-3 and Regulatory Guide 1.143. 3.2.6 Station procedures shall be established to assure the following requirements are met + 3.2.6.1 Boundary conditions shall be established for all i process parameters. ~ NOTE:. Process parameters shall be defined as, "those \\ conditions critical to insure complete dewatering". NOTE: " Boundary conditions" shall be defined as, unacceptable numerical values for process parameters". 3.2.6.2 Process parameters shall be identified in site-specific ' procedures. Typical parameters are: - t ~(a-)' -Waste form. (b) ' Settling time. (c) Drain (or pump) time. (d)- Drying time. 3.2.6.3 Sample analysis and boundary conditions shall be submitted to the Station Radwaste Supervisor. .(a) For filter dewatering, data shall be submitted to the Station Health Physics Supervisor. 3.2.6.4 Station Supervisor shall review the data outlined in Step 3.2.6.3 and shall authorize dewatering prior to initiation. G. V G-8 Rev. 4 1 e-w

i .. ~. y J(a) (])- ' Difficulties and/or disagreements between vender and station personnel should be resolved through direct interaction between vendor and station.- Corporate Nuclear Chemistry staff should be. contacted if resolution cannot be reached at the station level. .3.2.6.5 All operations ~shall be controlled by station procedures to assure that'all boundary conditions established in Step 3.2.6.1 are met. _(a) _ Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC , enclosure if desired or the procedure may be rewritten into DPC format. 13.2.6.6 The absence of free standing liquids (FSL) shall be verified for each vessel of dewatered waste prior to disposal. Verification shall be performed by either confirmation that the Process Control Program was followed or by physical testing. (a) Physical testing shall-be required for each vessel if the Process Control Program was not followed or if any off-normal condition existed during processing. ~ (b).A vessel shall have less than 0.5% free liquids by waste i volume. O (c): A High Integrity Container shall have les' than 1% free s liquids by waste volume. 3.2.6.7 Any dewatered vessel containing excess free liquids, as defined in Step 3.2.6.6, shall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product. 3.2.6.8 Records shall~be maintained by Duke Power Company on each vessel of dewatered wastes. - These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include: (a) Sample analysis and boundary conditions (per Step 3.2.6.3). (b) Station supervisor authorization for dewatering (per Step 3.2.6.4). q (c) Equipment. operation data to insure all boundary conditions-were met (per Step 3.2.6.5). (d) FSL Verification (per Step 3.2.6.6). G.4.0 WASTE OIL - 4.1 Incidental levels of waste oil may be solidified using the system described in Section 2.2. G-9 Rev. 4

r ,g - g.. g 4;1.1 " Incidental"'shall be defined as less than 1% oil. } v l4.2' If larger-volumes of waste oil are to be solidifiec. a special procedure;shall-be used. 4.2.1 The' oil-specific procedure.shall include'all ' requirements in Section 2.0.

4. 3 ' solidified waste oil shall not be shipped to the licensed i

burial-site at Barnwell, S.C., for. disposal, except as defined in Step 4.1. l5.0 INTERIM STORAGE h ? .5.1 Program Requirements f 5.1.1 Station. procedures shall be established to assure the following requirements are met: L 5.1.1.1 Any processed-(i.e., solidified or dewatered) waste l. that is stored for an interim period in a disposal L' container shall be packaged such that there is no interaction between the waste and its container. l 5.1.1.2 If applicable,' Certificates of Compliance shall be maintained at each station for all waste disposal containers used for interim storage. 5.1.1.3 Vendor. supplied handling and storage procedures shall be1 maintained at each station. 5.'l.1.4 Each container and waste.shall be checked against information given in Steps 5.1.1.2 and 5.1.1.'3 to insure all chemical compatibility requirements are met. 5.1.1.S Station Chemistry or Health Physics supervision shall review the information in Step 5.1.1.4.and shall certify. chemical compatibility and authorize storage. 5.1.1.6 Records shall be maintained by Duke Power Company for each container. -These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shcIl include: (a) Chemical compatibility certification (per Step 5.1.1.5). (b) Station supervision authorization to store waste (per Step 5.1.1.5). .6. 0 10CFR61 COMPLIANCE 6.1. Vendor Requirements I G-10 Rev. 4 q

pg a

o,.a u

m IJ = L(])c6.1.1 The' vendor (s) described in Section 2.1 for solidification shall have a NRC approved report documenting-M compliance with waste form requirements in the final solidified product, or shall supply Duke Power sufficient a documentation to demonstrate waste form compliance. 6.1.2 The vendor (s) dercribed in Section 3.1 for dewatering-shall.have a-NRC approved report documenting compliance p with waste form requirements in the final dewatered product, or-shall supply Duke Power sufficient l documentation to demonstrate waste form compliance. L 6.1.3 Any vendor providing High Integrity containers to Duke Power Company shall have a NRC approved report o documenting compliance with waste form requirements, or shall supply Duke Power sufficient documentation to demonstrate waste form compliance. L 6.1.4 All vendor reports (per-Steps 6.1.1, 6.1.2, and 6.1.3) shall contain a statementcthat.the final product L conforms to the appropriate waste form for either Class A, B, or C waste. 6.2' Program' Requirements f-6.2.1 Station procedures shall be established to assure the 3 following requirements are met: 6.2.1.1 Each container of_ processed (i.e., solidified or dewatered) waste shall be classified as either Class A, B, or C waste using the Duke Power Company "10 CFR Part 61 Waste classification and Waste Form Implementation Program". 6.2.1.2 Each container of processed waste shall be certified to the appropriate waste form for either Class A,.B or C waste. 1 (a) Waste. form certification shall be contingent upon the documents referenced in Section 6.1. 6.2.1.3 Records shall be maintained for each container of processed waste to assure compliance with the. requirements of Steps 6.2.1.1 and 6.2.1.2. These records shall be maintained for six (6) years (per the Administrative Policy Manual). 7.0 TRANSPORTATION 7.1. Program Requirements

O G-11 Rev. 4

.,2 L. (f7.1.1~ All~ shipping casks.used to transport processed waste for burial shall have a NRC issued Certificate ofL Compliance.

7.1.2 Station

procedures shall be established to insure all requirements of the certificate of Compliance are met. u -7.1.2.1 Vendor procedures shall be incorporated into station procedures prior to use. Vendor format may be retained, if.decired, or the procedure may be rewritten l into DPC format. 1 7.1.3 -Station procedures shall be established to insure all applicable Federal and State regulations and burial site criteria are met for each container of processed waste. 7.1.4 Records shall be maintained for each container and shipment of processed waste. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include: i 7.1.4.1 Documentation'of a valid certificate of Compliance for each cask (per Step 7.1.1). Maintained for six (6) years.- ' O ' 7.1. 4. 2 Documentation that all requirements of the certificate of Compliance were met (per Step 7.1.2). Maintained for six (6) years. 7.1.4.3 Documentation that all shipping regulations were met (per-Step 7.1.3). Maintained for life of plant. 8.0 REVIEWS 8.1 Program Requirements 1 8.1.1 Changes to the Corporate Process Control Program shall be reviewed by the Corporate Nuclear Chemistry staff and each station's Radwaste and Health Physics staffs prior to implementation. Proposed revisions shall be reviewed against Technical Specifications-and all applicable NRC' guidance to assure all requirements of a Process Control Program have been addressed. Review documents shall include: 8.1.1.1 NUREG-0133. 8.1.1.2 NUREG-0472. 8.1.1.3' NUREG-0800. ( ) 8.1.1.4 Branch Technical Position - ETBS 11-3. G-12 Rev. 4

'l ([ h 8;1.1J5 Appendix aa.4-A, " Design' Guidance for Temporary (' Storage...". o, H 8.1.1.6 NRC Review Criteria for Solid Waste Management Systems. E 8.1.1.7 Site-specific Technical Specifications. 8.1. 2 - ' Changes to the Corporate Process Control Program shall be' approved by the Technical System Manager, Nuclear Chemistry and each station's Technical Services Super-intendent-prior to implementation. 8.1.3 Each Station Manager.shall document that any changes to the Corporate Process Control Program have been reviewed and approved-(per Steps 8.1.1 and 8.1.2). 8.1.4 -The Nuclear Safety Review Board shall review the activities of the Station Manager detailed in Step 8.1.3.

B.1.5 A record of the review (per Step 8.1.4) shall be sent to the Vice President, Nuclear Production and the Executive Vice President, Power Operations within fourteen'(14) days following completion of the review.

" ) 8'.1.6 NRC in each station's Semi-annual Radioactive Effluent ( All changes to the Corporate PCP shall be sent to the ~ Report for the period in which the changes were implemented. 'I -8'1.7 Changes to all implementing procedures shall be reviewed by station radwaste or health physics staff and approved:by the station's Technical Services, Operating, OR Maintenance Superintendent, or Station Managar, prior to implementation. 8.1.7.1 Changes to implementing-procedures shall be reviewed by the Technical Services, Operating, OR Maintenance ' Superintendent, or Station Manager, to assure they do not conflict with the Corporate Process Control Program. 18.1.8-Records shall be maintained documenting the approvals , required by~Section 8.1. Records shall be maintained for six (6) years (per the Administrative Policy Manual). 9.0 AUDITS-9.1 Program Requirements O G-13 Rev. 4 M

f I '[ .~ . ' ()- 9.1.1 -The Corporate Process Control Program.and station: implementing procedures shall be audited at least once w per. twenty-four months at each station. . 9.1.2-This audit shall be performed under the cognizance of

the NSRB.

9.l.3 Audit ~' reports shall be forwarded to the Vice President-Nuclear Production; Executive Vice President, Power' operations; and Station Manager within thirty (30) days 'of completion of the audit.. i I t 1 L n 'U L l i O 1 G-14 Rev. 4

j. ..f ' J; a D' DUKE POWER COMPANY ) STATION 1 PROCESS CONTROL PROGRAM 1.0 PURPOSE The purpose of the Duke Power Company Station Process Control = Program shall be to insure all requirements of the DPC Corporate i -Process Control Program have been met for each container of solidified or dewatered radioactive waste shipped for burial -at a licensed burial facility, j 2.0 = COMPOSITION 2.1 The Duke Power Company Station Process Control Program shall consist of: i 2.1.1 The Duke Power Company Process Control Manual Introduction (Section I). 2.1.2 The Duke Power Company Corporate Process Control Program. O.12.1.3 A list of all station-specific procedures that implement the requirements of the Corporate Process . Control Program. 2.1.4 Diagrams or drawings or drawing numbers showing all connections between plant radwaste systems and solidi-fication and dewatering equipment. 12.1.5 Documentation of-NRC approval of the initial Station Process Control Program. 2.1.6 Documentation of. System Technical System Manager, Nuclear Chemistry station, Technical Services Superintendent, and Station Manager approval of all changes to the Corporate Process Control Program. 2.1.7 Documentation'that all changes to'the Corporate and/or-Station-Process Control Program were sent to the NRC in the Semi-Annual Radioactive Effluent Report. 2.1.8-Relevant Sections and Subsections of Process Control Program-related definition transferred from Section 1 of Nuclear Station Technical Specifications. 2.1.9 Relevant sections and subsections of Process Control Program-related limiting conditions for operation, bases

(])

and surevillance requirements transferred from sections 3/4 of Nuclear Station Technical Specifications. G-15 Rev. 4

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q l' h ol EXCEPTIQliS W

c 3.1; Each Station's exceptions-to the Corporate PCP shall be documented in the Station's PCP. ?

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(.' \\ l n l t i ( ) 2 .~ ? t -\\ i -G-16 Rev. 4 y

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} N,;-%. ^ pt A.. DUKE POWER. COMPANY %.s'% i 'PCP REVISION APPROVAL Yr)., 8 Rev'ised,PCP Section: i x. 2 g Corporate-PCP, Rev. J -4 ONS-PCP,.Rev ' MNS PCP, Rev. .CNS.PCP,:Rev.

~

This revision:has been reviewed against Technical Specifications. and applicable NRC guidance' documents and found to be acceptable, j Prepared By: M. B. Entrekin )

Title:

-Nuclear Production Engineer Date: ' ll fff1 General Office Review ' Station Rev3 e'? [hL - t2uf$ b[rk By: By:

Title:

'IU /mvboduc$th b 7.

Title:

uM g ll!&!Y7 Date: // / t d / " F Date:- ,c

This revision is approved-for use at. D Cone o- -

Nuclear H Station.- t i- ??) Gevs5 fedhnical System Manager g-Technical Services Superintendent ff ~ Date: ////W 89 - Date: /. -l >A. 3. C6% t Station Manager \\\\\\\\Nb Dato: \\revapprl.068

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s, i 4. -b p. DUKE POWER COMPANY f, PCP REVISION = APPROVAL l Revised PCPLSection: l 'CorporateiPCP, Rev. 4 [

ONS:PCP', Rev.

MNS PCP, Rev.- CNS PCP,JRev. _ ThisL' revision has been reviewed against Technical Specifications j and applicable NRC guidance documents and found to be acceptable. Prepared 1By: O. E. Ekechukwu

Title:

Nuclear Production Engineer Date: b 4 M I / i General Office' Review Station Review th(Ld N / By: S -- I I--M "- f By: .Y1 rlsn u lh-lurbm 6lut.uf

Title:

Wam /kaw iGc, ave:rg.

Title:

Date: S:24 89 Dates 67-MM i i I McGuire Nuclear This revision is. approved for use=at Station. j g. // b J' Al s'& + j = L Tebhnic'h1 5'ystfein Manager Metiu' ire - Tbchnical Services Superintendent

Date:

Date: M/887 [; ( l I l hts.,7. />A,1 [Y 6$tation Manager Date: 7/4V/P 4 n; L. v \\revapprl'.068 l l

f4 } -DUKE POWER COMPANY PCP' REVISION APPROVAL Revised PCP Section: Corporat'e PCP, Rev. 4 ONS PCP, Rev. -e j MNS PCP, Rev.

_cr, CNS PCP, Rev.

a This revision has been reviewed against Technical Specifications and applicable NRC guidance documents and found to be acceptable. Prepared By: M. B. Entrekin

Title:

Nuclear Production Engineer Date: II T 'i Cl General Office' Review Station Review By: dit( ti,! By: O. O h.hd t

Title:

ttt bcw 'tb'c Ibf -

Title:

M t h-Date: / / TiY1 Date: il /13 I89 This revision is approved for use at CxrAvJ8A Nuclear Station. I Technical System Manager Technical Services Superigtendent [!h/ O Dfb Date: Date: j. p k %M Station Manager Date: Ilk 2M% ' O r r - Q e \\revapprl.068-

.A r .;.- ; g ly ): ). DUKE POWER COMPANY.- . CORPORATE- ~ ' PROCESS CONTROL PROGRAM .g i TABLE'OF CONTENTS 1.0 PURPOSE 2.' O. SOLIDIFICATION 2.1 -Vendor Requirements 2.2 Program Requirements-3.0 DEWATERING 3.1 Vendor Recuirements 3.2 Program Requirements i 4.O WASTE OIL -.5.0 INTERIM-STORAGE -l l 6.0 10-CFR PART 61 COMPLIANCE 6.1 Vendor Requirements .6.2 Program Requirements. I 7.0. TRANSPORTATION i . 7.1 Program Requirements' { 8.0 REVIEWS 9. 0.- AUDITS I i .iU c G-1 Rev. 4 i

9 1 ./~j S DUKE POWER COMPANY q CORPORATE J PROCESS CONTROL PROGRAM i 1.0 PURPOSE -1.1 The purpose of the Duke Power Company Corporate Process i Control Program.is to establish a set of requirements that shall be met at all nuclear stations to insure'that all solidification 4 and dewatering activities are conducted in a manner and produce.a 5 final' product that complies with all applicable Federal and-State regulations and licensed burial site criteria. 1.2 The: Duke Power Company Process Control Program shall be used-to control and direct all solidification and dewatering activities for liquids (e.g., evaporator concentrates) and " wet solids" (e.g., resin slurries, filter backwash slurries, cartridge' filters) at the Oconee Nuclear Station, Units 1, 2 and 3, the-McGuire Nuclear-Station, Units 1 and 2, and the Catawba Nuclear Station, Units 1 and 2. 1.3 Station - specific procedures shall be developed to implement the requirements of this corporate PCP. q(/ ~ Station Process Control Programs shall contain Process 1.4-Control Program-related sections on definitions, limiting i conditions for' operation, bases and surveillance requirements transferred from Station Technical Specifications (TS). 1:.5 This~ Process-Control Program and implementing procedures shall. assure that all solidification and dewatering activities are in compliance with 10CFR20, 50, 61, 71, and 49 CFR and licensed burial site criteria. 1.6 If-this Process Control Program is not followed, each vessel of. processed (i.e., solidified or dewatered) waste shall be physically tested to verify the absence of free standing liquids i and all other applicable waste form requirements. 2.0 SOLIDIFICATION

2.1 Vendor

Requirements O G-2 Rev. 4

+-a, -4.. e- _v.,ia... ~..: mdia .,4q.m.,M-4 e- .h as a w 4 ga cp x' I j 1h':=2.1.1J Any; vendor utilized for solidification services by Duke i 7, - ' Power Company shall.have a Topical Report that is either-4 u1 under NRC review or:has NRC approval, or shall supply to Duke. Power sufficient documentation of the process and .results for review to demonstrate an acceptable product will be produced using the described solidification process. r 2.2.2 Any vendor solidification services utilized by Duke ' Power Company shall be approved by the Corporate Technical System Manager, Nuclear Chemistry and . station (s)-Technical Services Superintendent prior to operation.- '2.1.2.1 Technical' review shall-be performed by corporate and ( station radwaste; staffs of all vendor documents and procedures'to: insure they meet the requirements of the Duke Power Company PCP outlined below. 2.1.3 Chem-Nuclear Systems, Inc. has been reviewed and approved to provide solidification services to the Oconee, 4 McGuire, and Catawba Nuclear Stations as described in: Mobile Cement Solidification System, Topical Report CNSI-2 (4313-01354-0IP-A).1 Approved waste streams for solidi-7 fication are: boric acid evaporator concentrates, spent bead resin, spent powdered resin, filters, filter backwash slurry, and resin regenerative chemical wastes. O 2.1.4 sabcock and wi1cox has been reviewed and approved to provide: solidification services to McGuire, Oconee and Catawbr " : lear Stations.for Class A unstable waste as descr' .n B & W's supporting documents. However,-each drum e sz idified' product-shall be puntured and fully inspec'.< rior to shipment-for disposal. Approved waste-streams for solidification are: oil, oil and water mixtures, organics, EDTA-based steam generator cleaning solution concentrate, and sludges. - The-approved binders are Aquaset, Aquaset II, Petroset and Petroset II. 2.2 Program Requirements L 2.2.1

The. vendor topical report or documentation supplied to 4

the company shall include a detailed system description giving all vender interfaces with company equipment. Drawings or diagrams shall be included detailing all n I solidification system interfaces with plant radwaste systems and equipment. ~ 2.2.2 The vendor topical report or documentation supplied to l the Company shall include a statement that the design, construction, operation and quality assurance provisions-are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. l G-3 Rev. 4 L

l l l I (_) 2. 2. 3 Duke Power Company permanent or portable solid,1fication m systems shall have a detailed system description giving l all solidificaticn equipment interfaces with other company equipment. Drawings or diagrams shall be included detailing all solidification system interfaces with other plant radwaste equipment and systems. NOTE: This information may be included as part of a Topical Report furnished by the equipment manufacturer or supplier or'as part of the plant specific Final Safety Analysis Report. i 2.2.4 Duke Power Company permanent or portanle solidification I rystems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. 2.2.5 Station procedurcs shall be established to assure the following requirements are met: 2.2.5.1 A representative sample shall be taken from at least every tenth batch of each waste type to verify solidification. If the initial sample fails to verify solidification, a 2.2.5.2 representative sample shall be taken from each t

\\

consecutive batch of the same type waste until three consecutive samples demonstrate solidification. .2.2.5.3 A representative semple shall meet all the following conditions: (a) The contents of the container to be sampled shall be L recirculated a minimum of three volume turnovers or L adequately mixed to achieve a homogeneous mixture. l l NOTE: Adequately mixed shall be defined as: mixing via L agitative or recirculative flow which exceeds a specified minimum rate which has been documented to provide a p representative sample for the vessel. -(b) For final samples prior to initiating solidification, no additional waste shall be introduced into the container after recirculation or mixing has begun. Vessel level L readings or input isolation shall be documented at the time of mixing initiation, sampling, and process initiation. L (c) Recirculation or mixing time and/or volume must be uninterrupted from initiation until completion of sample collection. ({)2.2.5.4 During the recirculation and sampling period, the vessel shall not be placed in a transfer mode. .e l, G-4 Rev. 4

/' I 2.2.5.5 Sample analysis shall be performed as outlined in (o"') site-specific procedures for each waste form and ) solidification mesi.a. These should include such analysis ast \\ (a) Waste pH. (b) Waste density. (c) Waste boron concentration. l (d) Waste oil content. 2.2.5.6 Test solidification shall be performed to establish boundary conditions for all process parameters. NOTE: " Process parameters' shall be defined as, "those conditions critical to insure complete solidification". NOTE: " Boundary conditions" shall be defined as, { " acceptable numerical values for process parameters as established by a test solidification". i 2.2.5.7 Process parameters should include any of the following which are required to assure solidification: i (a) Waste form. (b) Vaste to solidification agent ratio. (c) Amount of each sr#21tification additive. (d) Waste pH. (e) Waste boron concentration. (f) Waste density. (g) Waste oil content. -(hi Mixer speed. (1) Mixing time. ( j )- curing time. (k) Specific activity. =2.2.5.8 Vendor shall submit sample analysis, test solidification results and prescribed boundary condi-tions to Station Chemistry supervision. i O 2.2.5.5 Station chemistry supervision sha11 review the data outlined in Step 2.2.5.8 and shall authorize solidi-p fication prior to initiation. G-5 Rev. 4 I f

i I l I '() (a) Difficulties and/or disagreements between vendor and station personnel should be resolved through direct interaction between vender and station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot be reached at the station level. 2.2.5.10 Solidification for disposal = hall not be performed unless the test solidification is acceptable. l 2.2.5.11 All system operation shall be controlled by station procedures to assure that the solidification system is operated within the boundary conditions established in t Step 2.2.5.7. (a) Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC enclosure if desired or the procedure may be rewritten into DPC format. 1 2.2.5.12 The absence of free standing liquids (FSL) shall be verified for each vessel of solidified waste prior to disposal. Verification shall be performed by either confirmation that the Process control Program was followed or by physical testing. P r' (a) Physical testing shall be required for each vessel if the \\ Process Control Program was not followed.or if any off-normal condition existed during processing. (a.1) Physical testing shall consist of visual inspection and probe penetrate tests. (b) A. vessel shall have less than 0.5% free standing liquid by waste volume. (c) If a High Integrity container is utilized, the vessel shall have less than 1% free standing liquid. 2.2.5.13 Any solidification vessel that does not pass the tests specified in Step 2.2.5.12 shall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product. 2.2.5.14 Records shall be maintained by Duke Power Company on each vessel of solidified wastes. These records shall be maintained for six (6) years (per the Administrative t Policy Manual). (a) These records shall include: (a.1) Representative sampling documentation (per Step () 4 2.2.5.3). G-6 Rev. 4

( ) (a.2) Sample analysis results (per Step 2.2.5.5). (a.3) Reference test solidification results and boundary conditions (per Steps 2.2.5.6 and 2.2.5.7). (a.4) Station Radwaste Supervision authorization for solidification per (Step 2.2.5.9). (a.5) System operation data to insure all bcktndary conditions were met (per Step 2.2.5.11). (a.6) FSL Verification (per Step 2.2.5.12). 3.0 DEWATERING 3.1 Vendor Requirements 3.1.1 Any vender utilized by Duke Power Comrany to providet dewatering services shall have a Topical Report that is either under NRC review or has NRC approval, or shall supply to Duke Power sufficient documentation of process and results for review tu demonstrate adequate finwntering is accomplished using the described procesa. 3.1.2 Any vender dewatering services utilized by Duke Power Company shall ha approved by the Corporate Technical \\ System Manager, Nuclear Chemistry and Jtaticn(S) Technical Services Superintendent prior to operation. 3.1'2.1 Technical review shall be performed by cerporate and station radwasta staffs of all vendor documents and procedures to insure they meet all requirements of the Duke Power Company PCP outlined below. 3.1.3 Chem-Nuclear Systems, Inc. has been reviewed and approved to provide dewatering services to oconne, .McGuire, and Catawba Nuclear Stations as described in Topical Report CNSI-DW-11118-01. 3.2 Program Requirements 3.2.1 The vendor topical report or documentation supplied to i the Company shall include a detailed system description giving all-vendor interfaces with company equipment. Drawings or diagrams shall be inc3uded detailing all dewatering system interfaces with plant radwaste systems and equipment. 3.2.2 The vendor topical report or documentation supplied to l the company shall include a statement tnat the design, construction, operation and quality assurance provisions 7([) are in accordance with Regulatory Guide 1.143. G-7 Rev. 4 h

3.2.3 All vendor supplied portable domineralizers shall meet L all requirements of Steps 3.2.1 and 3.2.2. 3.2.4 Duke Power Company permanent or portable dewatering systems shall have a detailed system description giving all dewatering equipment interfaces with other company equipment. Drawings or diagrams shall be included detailing.all dewatering system interfaces with other plant radwaste equipment and systems. NOTE: This information may be included as part of a Topical Report furnished by the equipment manufacturer or supplier or as part of the plant specific Final Safety Analysis Report. 3.2.5 Duke Power Company permanent or portable dewatering systems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC Branch Technical Position 11-3 and Regulatory Guide 1.143. 3.2.6 Station procedures shall be established to assure the following requirements are met: 3.2.6.1 Boundary conditions shall be established for all process paramsters. -NOTE: Process parameters shall be defined as, "those conditions critical to insure complete dewatering". NOTE: " Boundary conditions" shall be defined as, unacceptable numerical values for process parameters". 3.2.6.2 Process parameters shall be identified in site-specific procedures. Typical parameters ares (a) Waste form. (b) Settling time. (c) Drain (or pump) time. -(d) Drying tkme. 3.2.6.3 Sample analysis and boundary conditions shall be submitted to the Station Radwaste Supervisor. ( a )- For filter dewatering, data shall be submitted to the Station Health Physics Supervisor. 3.2.6.4 Station Supervisor shall review the data outlined in Step 3.2.6.3 and shall authorize dewatering prior to initiation. G-8 Rev. 4

I (_) ( a ) Difficulties and/or disagreements between vender and station 7s personnel should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot be reached at the station level. 3.2.6.5 All operations shall be controlled by station l-procedures to assure that all boundary conditions established in Step 3.2.6.1 are met. (a) Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC s enclosure if desired or the procedure may be rewritten into i DPC format. 3.2.6.6 The absence of free standing liquids (FSL) shall be verified for each vessel of dewatered waste prior to disposal. Verification shall be performed by either confirmation that the Process Control Program was followed or by physical testing. l (a) Physical testing shall be required for each vessel if the Process Control Frogram was not followed or if any off-normal condition existed during processing. (b) A vessel shall have less than 0.5% free.'.iquids by waste ) volume. ) (c) A High Integrity Container shall have less than 1% free liquids by waste volume. 3.2.6.7 Any dewatered vessel containing excess free liquids, as defined in Step 3.2.6.6, shall not be shipped to a burial 3 site until reprocessing or repackaging has resulted in an acceptable product. 3.2.6.8 Records shall be maintained by Duke Power Company on each vessel of dewatered wastes. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall includes (a) Sample analysis and boundary conditions (per Step 3.2.6.3). (b) Station supervisor authorization for dewatering (per Step 3.2.6.4). (c) Equipment operation data to insure all boundary conditions' were met (per Step 3.2.6.5). j (d) FSL Verification (per Step 3.2.6.6), i 4.0 WASTE OIL 4 '.1 Incidental levels of waste oil may be solidified using the system described in Section 2.2. i G-9 Rev. 4

I J I)4.1.1 " Incidental" shall be defined as less than 1% oil. J 4.2 If larger volumes of waste oil are to be solidified a j special procedure shall be used. ] 4.2.1 The oil-specific procedure shall include all { requirements in Section 2.0. 4.3 Solidified waste oil shall not be shipped to the licensed burial site at Barnwell, S.C., for disposal, except as defined in~ Step 4.1. 5.0 INTERIM STORAGE ) 5.1 Program Requirements 5.1.1 Station procedures shall be established to assure the following requirmnents are met: 1 5.1.1.1 Any processed (i.e., solidified or dewatered) waste that is stored for an interim period in a disposal container shall be packaged such that there is no interaction between the waste and its container. 5.1.1.2 If applicable, certificates of compliance shall be maintained at each station for all waste disposal containers used for interim storage. 5.1.1.3 Vendor supplied handling and storage procedures shall ] be maintained at each station, l 5.1.1.4 Each container and waste shall be checked against { information given in Steps 5.1.1.2 and 5.1.1.3 to i insure all chemical compatibility requirements are met. 5.1.1.5 Station Chemistry or Health Physics supervision shall review the information-in Step 5.1.1.4 and shall certify chemical compatibility and authorize storage. 5.1.1.6 Records shall be maintained by Duke Power Company for each container. These records shall be maintained for six (6) years (per the Administrative-Policy Manual). These records shall include: (a) chemical compatibility certification (per Step 5.1.1.5). (b) Station supervision authorization to store waste (per Step 4 5.1.1.5). L 6.0 10CFR61 COMPLIANCE l Vendor Requirements f ) 6.1 j ( L l l G-10 Rev. 4 L l

.7 l l '3-1 l h' 6.1.1 The vendor (s) described in Section 2.1 for solidification shall have a NRC approved report documenting i compliance with waste fem requirements in the final solidified product, or shall supply Duke Power sufficient documentation to demonstrate waste fem compliance. i 6.1.2 The vendor (s) described in section 3.1 for dewatering shall have a NRC approved report documenting compliance i with waste form requirements in the final dewatered 1 product, or shall supply Duke Power sufficient documentation to demonstrate waste form compliance. 6.1.3 Any vendor providing High Integrity Containers to Duke Power Company shall have a NRC approved report i documenting compliance with waste form requirements, or shall supply Duke Power sufficient documentation to l demonstrate waste form compliance. j 6.1.4 All vendor reports (per Steps 6.1.1, 6.1.2, and 6.1.3) shall contain a statement that the final product i conforms to the appropriate waste form for either class A, B, or C waste. 6.2 Program Requirements - 6.2.1 Stati n procedures shall be established to assure the i following requirements are met: 6.2.1.1 Each container of processed (i.e., solidified or dowatered) waste shall be classified as either class A, B, or C waste using the Duke Power Company "10 CFR Part 61 Waste Classification and Waste Form Implementation Program". 6.2.1.2 Each container of processed waste shall be certified to the appropriate waste form for either Class A, B or C waste. j i (a) Waste form certification shall be contingent upon the documents referenced in Section 6.1. 6.2.1.3 Records shall be maintained for each container of processed waste to assure compliance with the requirements of Steps 6.2.1.1 and 6.2.1.2. These records shall be maintained for six (6) years (per the Administrative Policy Manual). 7.0 TRANSPORTATION 7.1 Program Requirements O G-11 Rev. 4

i O 7.1.1 A11 shi in casxs used to transport vrocessed waste for burial shall have a NRC issued Certificate of t Compliance. ) 7.1.2 Station procedures shall be established to insure all requirements of the certificate of Compliance are met. 7.1.2.1 Vendor procedures shall be incorporated into station procedures prior to use. Vendor format may be i retained, if desired, or the procedure may be rewritten into DPC format. i 7.1.3 Station procedures shall be established to insure all applicable Federal and State regulations and burial site criteria are met for each container of processed waste. 7.1.4 Records shall be maintained for each container and \\ shipment of processed waste. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include 7.1.4.1 Documentation of a valid Certificate of Compliance for each cask (per Step 7.1.1). Maintained for six (6) years. O;. 7. 1. 4.2 Documentation that all requirements of the certificate of Compliance were met (per Step 7.1.2). Maintained for six (6) years. 7.1.4.3 Documentation that all shipping regulations were met (per Step 7.1.3). Maintair.sd f tr life of plant. 8.0 REVIEWS 8.1 Program Requirements 8.1.1 Changes to the Corporate Process Control Program shall be reviewed by the Corporate Nuclear Chemistry staff and each station's Radwaste and Health Physics staffs prior to implementation. Proposed revisions staall be reviewed against Technical Specifications and all applicable NRC guidance to assure all requirements of a Process Control Program have been addressard. Review documents shall include: 8.1.1.1 NUREG-0133. 8.1.1.2 NUREG-0472. 8.1.1.3 NUREG-0800. O 8.1.1.4 Branch Technical Position - ETBS 11-3. t y G-12 Rev. 4

i ~()8.1.1.5 Appendix aa.4-A, " Design Guidance for Temporary Storage...". 8.1.1.6 NRC Review Criteria for Solid Waste Management Systems. I 8.1.1.7 Site-specific Technical Specifications. 8.1.2 Changes to the Corporate Process Control Program shall be approved by the Technical System Manager, Nuclear Chemistry _and each station's Technical Services Super-intendent prior to implementation. 8.1.3 Each Station Manager shall document that any changes to the Corporate Process Control Program have been reviewed and approved (per Steps 8.1.1 and 8.1.2). 8.1.4 The Nuclear Safety Review Board-shall review the 'i activities of the Station Manager detailed in Step 8.1.3. 1 8.1.5 A record of the review (per Step 8.1.4) shall be sent ] to the Vice President, Nuclear Production and the Executive Vice President, Power Operations within fourteen (14) days following completion of the review. 8.1.6 All changes to the Corporate PCP shall be sent to the NRC in each station's Semi-annual Radioactive Effluent Report for the period in which the changes were i implemented. 8.1.7 Changes to all implementing procedures shall be reviewed by station radwaste or health physics staff J and approved by the station's Technical Services, Operating, OR Maintenance Superintendent, or Station Managst, prior to implementation. 8.1.7.1 Changes to implementing procedures shall be reviewed by the Technical Services, Operating, OR Maintenance Superintendent, or Station Manager, to assure they do not conflict with the Corporate Process Control Program. 8.1.8 Records'shall be maintained documenting the approvals required by Section 8.1. Records shall be maintained for six (6) years (per the Administrative Policy Manual). 9.0 AUDITS 9.1 Program Requirements O G-13 Rev. 4

i r V(N 9.1.1 The Corporate Process Control Program and station l implementing procedures shall be audited at least once per twenty-four months at each station. I 9.1.2 This audit.shall be performed under the cognizance of the NSRB. 9.1.3 Audit reports shall be forwarded to the Vice President, Nuclear Production: Executive Vice President, Power i operations; and Station Manager within thirty (30) days of completion of the audit. i l B l 1 i L l O t G-14 Rev. 4

l DUKE POWER COMPANY ) STATION PROCESS CONTROL PROGRAM 1.0 PURPOSE The purpose of the Duke Power Company Station Process Control Program shall be to insure all requirements of the DPC Corporate Process Control Program have been met for each container of solidified or dewatered radioactive waste shipped for burial at a~ licensed burial facility. 2.0 COMPOSITION 2.1 The Duke Power Company Station Process Control Program 1 shall consist of 4 2.1.1 The Duke Power Company Process Control Manual Introduction (Section I). 2.1.2 The Duke Power Company Corporate Process Control Program. 2.1.3 A list of all station-specific procedures that implement the requirements of the Corporate Process l Control Program. 2.1.4 Diagrams or drawings or drawing numbers showing all connections between plant radwaste systems and solidi-fication and dewatering equipment. 2.1.5 Documentation of NRC approval of the initial Station Process Control Program. 2.1.6 Documentation of System Technical System Manager, Nuclear Chemistry station, Technical Services Superintendent, and Station Manager approval of all changes to the Corporate Process Control Program. 2.1.7 Documentation that all changes to the Corporate and/or Station Process Control Program were sent to the NRC in the Semi-Annual Radioactive Effluent Report. 2.1.8 Relevant Sections and Subsections of Process Control Program-related definition transferred from Section 1 of Nuclear Station Technical Specifications. 2.1.9 Relevant sections and subsections of Process Control Program-related limiting conditions for operation, bases f(]) and surevillance requirements transferred from sections 3/4 of Nuclear Station Technical Specifications. G-15 Rev. 4

r j .:e 1 c.. l ..O: 2.o excarrzoi<. 3.1-Each Station's exceptions to the Corporate PCP shall be documented in the Station's PCP. 1 I / ) l I t i!: t i I h O i s L ,O. G-16 Rev. 4 i

w. ~~ ' 1 Ni a c j t I A,. .i 's DUKE POWER COMPANY

e.,'

PCP REVISION APPROVAL i ' m., N8 Revised PCP. Sections i Corporate PCP, Rev. 4 f ONS PCP, Rev. MNS PCP, Rev. CNS PCP, Rev.

l This revision.has been reviewed against Technical Specifications and applicable NRC guidance documents and found to be acceptable.

l I Prepared By: M. B. Entrekin l

Title:

Nuclear Production Engineer Date ll l on l General Office Review Station Revje'd Byt ~ [dt# d b dt k By: I bL.--

Title:

'Mu trayhtdtt<h(h by.

Title:

uh f3ru l ' Date: Il TY % Date: IllsJ 6 I ? This revision is approved for use at O cono a-. - Nuclear- -Station. -l 771 Wavsf fedhnical System Manager y Technical Services Superintendent ///h b Date: ////W 89' Date: s .j C t \\W W Station Manager \\b\\Mb Date: \\revapprl.068 l. y

_, ;g y.- E s; I I' i n. b-DUKE POWER COMPANY f PCP REVISION APPROVAL Revised PCP Sections i-Corporate PCP, Rev. 4 l t ONS PCP, Rev. L MNS PCP, Rev. [ CNS PCP, Rev. t This revision has been reviewed against Technical Specifications. cnd applicable NRC guidance documents and found to be acceptable. . Prepared By: O. E. Ekechukwu

Title:

Nuclear Production Engineer Datet b!S4 /S'4 f i / General Office Review Station Review 'Bys lYlitLLb. ?Y! l= -- - $ ! = & Bys = flYItrlrnfityseury Titlet k t ?

Title:

W cm thur.nw Csmerg eIr v $b29 lSf1 Dates 67-N M -Dates t This. revision is approved for use at McGuire Nuclear Station. // b k> l'26/i.^- Tebbnic'al systfein Manager Metu' ire Thchnical Services Superintendent

Date s:

1 Date: W/E/V$ ( c l J. A A.? C J c$tation Manager Dates 9lMlPI \\revapprl.068 x

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j ~ ~ 7-i ) DUKE POWER COMPANY '~ PCP REVISION APPROVAL Revised PCP Section: Corporate PCP, Rev. 4 ONS PCP, Rev. MNS PCP, Rev. -cq

CNS PCP, Rev.

-s This revision has been reviewed against Technical Specifications -and applicable NRC-guidance documents and found to be acceptable. Prepared By: M. B. Entrekin

Title:

Nuclear Production Engineer t Dates il T #9 f General Office' Review Station Review N liitt b r t By: O.O e 3 d ) By s. (4Llu iv b 7 bi b8h. Ibf -

Title:

bSE 4

Title:

t t I/!$fT9 Date: ll /13 IM i Date This revision is approved for use at CurAW8A Nuclear Station. Technical system Manager Technical Services Superistendent /! h O D Date: Dates j p Station Manager Ilk 2Ab. Date: m s s - O \\revapprl.068

i; e f,. v '. J: \\ j s.. (. - l@ '..!-1 i ?~N DUKE' POWER COMP.tNY LQ[ I-CORPORAT2: s ,w PROCESS CONTROL' PROGRAM ) y, l r. L TABLE OF CONTENTS i i e, '1.0 PURPOSE f, 2.0 SOLIDIFICATION l 2.1' Vendor Requirements i. 2.2 Program Requirements 3.O DEWATERING i '3.1 Vendor Requirements 3.2 Program Requirements 4.0 WASTE OIL I ' { 5.0-INTERIM STORAGE

6. 0 - 10 CFR PART 61 COMPLIANCE 6.1. Vendor Requirements 6.2 Program Requirements i

7.0 TRANSPORTATION '~ a '7.1. Program Requirements 8.0 REVIEWS

9.0 AUDITS l

-.). l-G-1 Rev. 4- .=

i .i I q DUKE POWER COMPANY V CORPORATE PROCESS CONTROL PROGRAM 1.0 PURPOSE 1.1 The purpose of the Duke Power Company Corporate Process Control Program is to establish a set of requirements that shall be met at all nuclear stations to insure that all solidification i and dewatering activities are conducted in a manner and produce a final product that complies with all applicable Federal and State regulations and licensed burial site criteria. 1.2 The Duke Power Company Process Control Program shall be used to control and direct all solidification and dewatering activities for liquids (e.g., evaporator concentrates) and " wet solids" (e.g., resin slurries, filter backwash slurries, cartridge filters) at the Oconee Nuclear Station, Units 1, 2 and 3, the McGuire Nuclear Station, Units 1 and 2, and the Catawba Nuclear Station, Units 1 and 2. 1.3 Station - specific procedures shall be developed to implement the requirements of this corporate PCP. } 1.4 Station Process Control Programs shall contain Process Control Program-related sections on definitions, limiting conditions for operation, bases and surveillance requirements I transferred from Station Technical Specifications (TS). 1 1.5 This Process Control Program and implementing procedures shall assure that all solidification and dewatering l activities are in compliance with 10CFR20, 50, 61, 71, and 49 CFR and licensed burial site criteria. 1.6 If this Process Control Program is not followed, each vessel of processed (i.e., solidified or dewatered) waste shall be l physically tested to verify the absence of free standing liquids l and all other applicable waste form requirements. 2.0 SOLIDIFICATION 2.1 Vendor Requirements I h G-2 Rev. 4

()2.1.1 Any vendor utilized for solidification services by Duke Power Company shall have a Topical Report that is either i under NRC review or has NRC approval, or shall supply to Duke Power sufficient documentation of the process and results for review to demonstrate an acceptable product i will be produced using the described solidification process. 2.1.2 Any vendor solidification services utilized by Duke Power Company shall be approved by the Corporate Technical System Manager, Nuclear Chemistry and station (s) Technical Services Superintendent prior to 4 operation. 1 t 2.1.2.1 Technical review shall be performed by corporate and station radwaste staffs of all vendor documents and procedures to insure they meet the requirements of the Duke Power Company PCP outlined below. 1 2.1.3 Chem-Nuclear Systems, Inc. has been reviewed and i approved to provide solidification services to the Oconee, McGuire, and Catawba Nuclear Stations as described int Mobile Cement solidification System, Topical Report CNSI-2 (4313-01354-0IP-A). Approved waste streams for solidi-fication are: boric acid evaporator concentrates, spent bead resin, spent powdered resin, filters, filter backwash slurry, 1 and resin regenerative chemical wastes. ()2.1.4 Babcock and Wilcox has been reviewed _.and approved to provide solidification services to McGuire, Oconee and Catawba Nuclear Stations for Class A unstable waste as j described in B & W's supporting documents. However, each

~

drum of solidified product shall be puntured and fully inspected prior to shipment for disposal. Approved waste streams for solidification are: oil, oil and water mixtures, organics, EDTA-based steam generator cleaning l solution concentrate, and sludges. The approved binders L are Aquaset, Aquaset II. Petroset and Petroset II. 2.2 Program Requirements 2.2.1 The vendor topical report or documentation supplied to the company shall include a detailed system description giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing all l l solidification system interfaces with plant radwaste systems and equipment. L 2.2.2 The vendor topical report or documentation supplied to the company shall include a statement that the design, construction, operation and quality assurance provisions are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. i 1 l. L G-3 Rev 4 L l.

~ ?()2.2.3 Duke Power l Company permanent or' portable solidification l systems shall have a detailed system description giving all solidification equipment interfaces with other company equipment. Drawings or diagrams shall be included detailing all solf.dification system interfaces l with other plant radwaste equipment and systems. NOTE: This information may be included as part of a Topical Report furnished by the equipment manufacturer or supplier or as part of the plant specific Final Safety Analysis Report. 2.2.4 Duke Power Company permanent or portable solidification systems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC ETSB ) Branch Technical Position 11-3 and Regulatory Guide 1.143. '2.2.5 Station procedures shall be established to assure the following requirements are met: 2.2.5.l' A representative sample shall be taken from at least every tenth batch of each waste type to verify solidification. 2.2.5.2 If the initial sample fails to verify solidification, a representative sample shall be taken from each i consecutive batch of the same type waste until three consecutive samples demonstrate solidification. 2.2.5.3 A representative sample shall meet all the following conditions: (a) The contents of the container to be sampled shall be recirculated a minimum of three volume turnovers or adequately mixed to achieve a homogeneous mixture. NOTE: Adequately mixed shall be defined as: mixing via agitative or recirculative flow which exceeds a specified minimum rate which has been documented to provide a representative sample for the vessel. (b) For final samples prior to initiating solidification, no additional waste shall be introduced into the container after recirculation or mixing has begun. Vessel level readings or input isolation shall be documented at the time of mixing initiation, sampling, and process initiation. L =(c) Recirculation or mixing time and/or volume must be uninterrupted from initiation until completion of sample collection. ! (][2.2.5.4' During the recirculation and sampling period, the vessel shall not be placed in a transfer mode. G-4 Rev. 4 i

,; ; s /)2.2.5.5 Sample analysis shall be performed as outlined in ( site-specific procedures for each waste form and solidification media. These should include such analysis as (a) Waste pH. -(b) Waste density. (c) Waste boron concentration. (d) Waste oil content. 2.2.5.6 Test solidification shall be performed to establish boundary conditions for all process parameters. NOTE: " Process parameters' shall be defined as, "those conditions critical to insure complete solidification". NOTE: " Boundary conditions" shall be defined as, " acceptable numerical-values for process parameters as i established by a test solidification". 2.2.5.7 Process parameters should include any of the following which are required to assure solidification: (a) Waste form. (b) ' Waste to solidification agent ratio. i (c) Amount of each solidification additive. (d) Waste pH. L (e) Waste boron concentration. -(f) Waste density. i (g)- Waste oil content. (h)' Mixer speed. -(i) Mixing time. (j) Curing time. (k) Specific activity. 2.2.5.8 Vendor shall submit sample analysis, test solidification results and prescribed boundary condi-tions to Station Chemistry supervision. ()2.2.5.9 Station Chemistry supervision shall review the data outlined in Step 2.2.5.8 and shall authorize solidi-fication prior to initiation. G-5 Rev. 4 / _r

i l 1 h ()(a) Difficulties and/or disagreements between vendor and station personnel should be resolved through direct l interaction between vendor and station. Corporate Nuclear i Chemistry staff should be contacted if resolution cannot be reached at the station level. 2.2.5.10 Solidification for disposal shall not be performed l unless the test solidification is acceptable. 2.2.5.11 All system operation shall be controlled by station procedures to assure that the solidification system is operated within the boundary conditions established in Step 2.2.5.7. (a) Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC enclosure if desired or the procedure may be rewritten into l DPC format. 2.2.5.12 The absence of free standing liquids (FSL) shall be verified for each vessel of solidified waste prior-to disposal. Verification shall be performed by either confirmation that the Process Control' Program was followed or by physical testing. ,r3 (a) Physical testing shall be required for each vessel if the \\J Process Control Program was not followed or if any off-normal condition existed during processing. (a.1) Physical testing shall consist of visual inspection and probe penetrate tests. (b) A vessel shall have less than 0.5% free standing liquid by waste volume. 1 (c) If a High Integrity Container is utilized, the vessel shall have less than 1% free standing liquid. 2.2.5.13 Any solidification vessel that does not pass the tests specified in Step 2.2.5.12 ahall not be shipped to a burial site until reprocessing or repackaging has resulted in an acceptable product. 2.2.5.14 Records shall be maintained by Duke Power Company on each vessel of solidified wastes. These records shall be maintained for six (6) years (per the Administrative Policy Manual). (a) These records shall include: O (a.1) Representative sampling documentation (per Step 2.2.5.3). G-6 Rev. 4

I,*.. ) () (a.lJ) Sample analysis results (per Step 2.2.5.5). (a.3) Reference test solidification results and boundary conditions (per Steps 2.2.5.6 and 2.2.5.7). i (a.4) Station Radwaste Supervision authorization for I solidification per (Step 2.2.5.9). (a.5) System operation data to insure all boundary conditions were met (per Step 2.2.5.11). (a.6) FSL Verification (per Step 2.2.5.12). 3.0 DEWATERING 3.1 Vendor Requirements 3.1.1 Any vendor utilized by Duke Power Company to provida dewatering services shall have a Topical Report that is either under NRC review or has NRC approval, or shall supply to Duke Power sufficient documentation of process and results for review to demonstrate adequate dewatering is accomplished using the described process. 3.1.2 Any vender dewatering services utilized by Duke Power "O Company shall ha approved by the Corporate Technical System Manager, Nuclear Chemistry and statients) Technicti Services Superintendent prior to operation. 3.1.2.1 Technical review shall be performed by corporate and station radwaste staffs of all vendor documents and procedures to insure they meet all requirements of the Duke Power Company PCP outlined below. 3.1.3 Chem-Nuclear Systems, Inc. has been reviewed and approved to provide dewatering services to Oconee. McGuire, and Catawba Nuclear Stations as described in Topical Report CNSI-DW-11118-01. 3.2 Program Requirements 3.2.1 The vendor topical report or documentation supplied to the Company shall include a detailed system description giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing all dewatering system interfaces with plant radwaste systems and equipment. 3.2.2 The vendor topical report or documentation supplied to the company shall include a statement that the design, construction, operation and quality assurance provisions (]) are in accordance with Regulatory Guide 1.143. G-7 Rev. 4

f l t 3.2.3 '()' All vendor supplied portable domineralizers shall meet all requirements of Steps 3.2.1 and 3.2.2. I i 3.2.4 Duke Power Company permanent or portable dewatering systems shall have a detailed system description giving all dewatering equipment interfaces with other company i equipment. Drawings or diagrams shall be included detailing all dewatering system interfaces with other plant radwaste equipment and systems. 1 NOTE: This~information may be included as part of a Topical-Report furnished by the equipment manufacturer or [ supplier or as part of the plant specific Final Safety Analysis Report. 3.2.5 Duke Power Company permanent or portable dewatering systems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC Branch Technical Position 11-3 and Regulatory Guide 1.143. 3.2.6 Station procedures shall be established to assure the I following requirementa are met: 3.2.6.1 Boundary conditions shall be established for all process parameters. i rm NOTEt_ Process parameters shall be defined as, "those (_)- conditions critical to insure complete dewatering". NOTE: " Boundary conditions" shall be defined as, unacceptable numerical values for process parameters". 3.2.6.2 Process parameters shall be identified in site-specific procedures. Typical parameters are: (a) Waste form. t (b) Settling time. (c) Drain (or pump) time. (d) Drying time. 3.2.6.3 Sample analysis and boundary conditions shall be submitted to the Station Radwaste Supervisor. (a) For filter dewatering, data shall be submitted to the Station Health Physics Supervisor. 3.2.6.4 Station Supervisor shall review the data outlined in Step 3.2.6.3 and shall authorize dewatering prior to initiation. G-8 Rev. 4

) 9 i (a) Difficulties and/or disagreements between vendor and station personnel should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot be reached at -the station level. 3.2.6.5 All operations shall be controlled by station procedures to assure that all boundary conditions established in Step 3.2.6.1 are met. (a) Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC enclosure if desired or the procedure may be rewritten into DPC format. l 3.2.6.6 The absence of free standing liquids (FSL) shall be verified for each vessel of dowatered waste prior to ) disposal. Verification shall be performed by either confirmation that the Process Control Program was followed or by physical testing. (a) Physical testing shall be required for each vessel if the Process Control Frogram was not followed or if any off-normal condition existed during processing. (b) A vessel shall have less than 0.5% free liquids by waste volume. ) (c) A High Integrity Container shall have less than 15 free liquids by waste volume. 3.2.6.7 Any dewatered vessel containing excess free liquids, as I defined in Step 3.2.6.6, shall not be shipped to a burial l site until reprocessing or repackaging has resulted in an acceptable product. 3.2.6.8 Records shall be maintained by Duke Power Company on each vessel of dewatered wastes. These records shall be l maintained for six (6) years (per the Administrative Policy l Manual). These records shall includes ( (a) Sample analysis and boundary conditions (per Step 3.2.6.3). (b) Station supervisor authorization for dewatering (per Step 3.2.6.4). (c) Equipment operation data to insure all boundary conditions were met (per Step 3.2.6.5). .(d). FSL Verification (per Step 3.2.6.6). l l O .0-4 WASTE OIL 4.1 Incidental levels of waste oil may be solidified using the system described in Section 2.2. G-9 Rev. 4

// '(_~ 4.1.1 " Incidental" shall be defined as less than 1% oil. ) 4.2 If larger volumes of waste oil are to be solidified a special procedure shall be used. 4.2.1 The oil-specific procedure shall include all requirements in Section 2.0. 4.3 Solidified waste oil shall not be shipped to the licensed burial site at Barnwell, S.C., for disposal, except as defined in Step 4.1. 5.0 INTERIM STORAGE 5.1 Program Requirements 5.1.1 Station procedures shall be established to assure the following requirements are mett 5.1.1.1 Any processed (i.e., solidified or dewatered) waste that is stored for an interim period in a disposal container shall be packaged such that there is no interaction between the waste and its container. 5.1.1.2 If applicable, certificates of Compliance shall be maintained at each station for all waste disposal ) containers used for interim storage. 5.1.1.3 Vendor supplied handling and storage procedures shall be maintained at each station. 5.1.1.4 Each container and waste shall be checked against information given in Steps 5.1.1.2 and 5.1.1.3 to insure all chemical compatibility requirements are met. 5.1.1.5 Station Chemistry or Health Physics supervision shall review the information in Step 5.1.1.4 and shall certify chemical compatibility and authorize storage. 5.1.1.6 Records shall be' maintained by Duke Power Company for each container. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include: (a) _ Chemical compatibility certification (per Step 5.1.1.5). (b) Station supervision authorizatien to store waste (per Step 5.1.1.5). 6.0 10CFR61 COMPLIANCE 6.1 Vendor Requirements G-10 Rev. 4

.c j i O 6.1.1 rae veadort > ae==ridea ia se= tion 2.1 for i solidification shall have a NRC approved report doctamenting compliance with waste form requirements.in the final solidified product, or shall supply Duke Power sufficient documentation to demonstrate waste fom compliance. 6.1.2 The vendor (s) described in Section 3.1 for dowatering shall have a NRC approved report documenting compliance with waste form requirements in the final dowatered product, or shall supply Duke Power sufficient i documentation to demonstrate waste form compliance. 6.1.3 Any vendor providing High Integrity Containers to Duke Power Company shall have a NRC approved report documenting compliance with waste form requirements, or shall supply Duke Power sufficient documentation to demonstrate waste fem compliance. 6.1.4 All vender reports (per Steps 6.1.1, 6.1.2, and 6.1.3) shall contain a statement that the final product i conforms to the appropriate waste form for either Class A, B, or C waste. 6.2 Program Requirements 6.2.1 Stati:n procedures shall be established to assure the following requirements are met: t 1 6.2.1.1 Each container of processed (i.e., solidified or dowatered) waste shall be classified as-either Class A, B, or C waste using the Duke Power Company "10 CFR Part 61 Waste classification and Waste Form Implementation Program". 6.2.1.2 Each container of processed waste shall be certified to the appropriate waste form for either Class A, B or C waste. (a) Waste form certification shall be contingent upon the documents referenced in Section 6.1. 6.2.1.3 Records shall be maintained for each container of processed waste to assure compliance with the requirements of Steps 6.2.1.1 and 6.2.1.2. These records shall be maintained for six (6) years (per the Administrative Policy Manual). 7.0 TRANSPORTATION 7.1 Program Requirements O G-11 Rev. 4 L

i I i ()7.1.1 All shipping casks used to transport proce:ssed waste for burial shall have a NRC issued Certificate of Compliance. -- 7.1. 2 - station procedures shall be established to insure all requirements of the certificate of Compliance are met. 7.1.2.1 Vendor procedures shall be incorporated into station procedures prior to use. Vendor format may be \\ retained, if desired, or the procedure may be rewritten into DPC format. 7.1.3 Station procedures shall be established to insure all applicable Federal and State regulations and burial site criteria are met for each container of processed waste. 7.1.4 Records shall be maintained for enca container and shipment-of processed wasta. These records shall be maintained for six (6) years (per the Administrative Policy Manual). These records shall include 7.1.4.1 Documentation of a valid certificate of Compliance for l each cask (per Step 7.1.1). Maintained for six (6) years. j O(d .7.1.4.2 Documentation that all requirements of the certificate of-Compliance were met (per Step 7.1.2). Maintained for six (6) years. 7.1.4.3 Documentation that all shipping regulations were met (per Step 7.1.3). Maintained for life of plant. 1 B.O REVIEWS p 8.1 Program Requirements 8.1.1 Changes to the Corporate Process Control Program shall i be reviewed by the Corporate Nuclear Chemistry staff and each station's Radwaste and Health Physics staffs prior to implementation. Proposed revisions shall be reviewed against Technical Specifications and all applicable NRC guidance to assure all requirements of a l Process Control Program have been addressed. Review documents shall include: 8.1.1.1 NUREG-0133. 8.1.1.2 NUREG-0472. L 8.1.1.3 NUREG-0800. () 8.1.1.4 Branch Technical Position - ETBS 11-3. o G-12 Rev. 4

ys ~._ _ __ ~ - _ _ 1 4 e s I hT 8.1.1.5 Appendix an.4-A, " Design Guidance for Temporary Storage...". l . 8.1.1. 6 L NRC Review: Criteria for Solid Waste Management. Systeras. 8.1.1.7' Site-specific Technical Specifications. 1 8.1.2 Changes to the Corporate Process Control Program shall be-approved by the Technical System Manager, Nuclear Chemistry and each station's Technical Services Super-intendent prior to implementation. -8.1.3 Each Station Manager'shall document that any changes to the Corporate Process Control Program have been reviewed and approved (per' Steps 8.1.1 and 8.1.2). 8.1.4 The Nuclear Safety Review Board shall review the L; activities of the Station Manager detailed in Step 8.1.3. L 8.1.5 A record of the review (per Step 8.1.4) shall be sent to the Vice President, Nuclear Production and the Executive Vice President, Power Operations'within. fourteen (14) days following completion of the review. j%) 8.1.6 All changes to the Corporate PCP shall be sent~to the NRC'in each station's Semi-annual Radioactive Effluent Report for the^ period in which-the changes were . implemented.. 8.1.7 Changes to all implementing procedures shall be , reviewed by station radwaste or health physics staff and approved-by the station's Technical Services, L Operating, QR Maintenance Superintendent, or Station Managsr, prior to implementation. o 8.1.7.1 Changes to implementing-procedures shall be reviewed by the Technical Services, Operating, OR Maintenance Superintendent, or Station Manager, to assure they do notl conflict with~the Corporate Process Control Program. f 8.1. 8 ' Records shall be maintained documenting the approvals required by Section 8.1. Records shall be maintained- -for six (6) years (per the Administrative Policy Manual). 9.0 AUDITS-9.1: Program Requirements c0 G-13 Rev. 4 o

.,p - J 'y y _, -l;: n u z7 e19;1.1 ~M( ~ The Corporate Process-Control Program and station implementing. procedures shall be audited at least once 'per twenty-four months at each station. 9.1,2 This audit shall be performed under the cognizance of the NSRB. 9.1. 3 ' -Audit reports shall be forwarded to the Vice President, Nuclear Production; Executive Vice President, Power opera **ons; and Station Manager within thirty (30) days-of cot.,.setion of the audit. R 10 4 i l,. i: p l-1. t 1 i ? 4 1 "O 1 G-14 Rev. 4 1

j 1..: L g DUKE POWER COMPANY- - h-g E STATION g PROCESS CONTROL PROGRAM L 1.0 PURPOSE

The purpose of the Duke Power Company Station Process Control Program shall be to insure;all requirements of the DPC Corporate Process Control Program have been met for each container.of' solidified or dewatered radioactive waste shipped for burial at a licensed burial facility.

.l 2.0- COMPOSITION r 2.1 The Duke Power Company Station Process Control Program shall consist of: f L 2'.1.1 The Duke' Power Company Process Control Manual Introduction (Section I). 2.1.2 The Duke Power Company Corporate Process Control l Program. t 34 .2.1.3-A list of all station-specific procedures that (_/ implement the requirements of the Corporate Process Control Program. 2.1. 4 ' Diagrams.or drawings;or drawing numbers showing all connections between plant radwaste systems-and solidi-fication and dewatering equipment. ~2.1.5 . Documentation of NRC approval of the initial Station . Process Control Program. 2.1.6 Documentation of System Technical System Manager, Nuclear Chemistry station, Technical Services Superintendent, and Station Manager approval of all changes to the Corporate Process Control Program. 2.1.7 Documentation that all changes to the Corporate and/or Station Process Control Program were sent to the NRC in the Semi-Annual Radioactive Effluent Report. ~2.1.8 Relevant Sections and Subsections of Process Control Program-related definition transferred from Section 1 of Nuclear Station Technical Specifications. 2.1.9 Relevant sections and subsections of Process Control Program-related limiting conditions for operation, bases (]) and surevillance requirements transferred from sections 3/4 of Nuclear Station Technical Specifications. G-15 Rev. 4

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'( )y 3'.0:. EXCEPTI0lts i h 3.11 Each station's exceptions to the Corporate PCP'shall be-Ldocumentedfin the Station's PCP. A -r^ i x , s I r + J 3 -r -; e H,., r l i k l n: 1. i b-4 i s. Y r p u. l ~ h 's .' l r 't I ,.i - f .\\ G-16 Rev. 4 { P + r -w.

w ;,gg-3, s.: y-k$j; + 1, v 1 ! 4.i i 4 DUKE POWER COMPhNY-4 4.,% g, PCP REVISION APPROVAL may N8 ' Revised PCP Section \\ k Corporate PCP, Rev. e.. ONS-PCP,:Rev.- -MNS PCP, Rev. CNS PCP, Rev. .This revision has-been reviewed against Technical Specifications- -and applicable NRC guidance documents and-found to be acceptable. Prepared By: M. B. Entrekin

Title:

Nuclear Production Encineer Date: II fTM n -v 1 General Office Review Station Rev3 e'? B'y :' dOf N Er k By:.- L-- Titile:NubetvNoda</nuYky,

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u,,3 Date: ' Il 1 Date: ll / ' 'J ' * ' This> revision is. approved for use at O cono u Nuclear Station. ??) W& 'fedhnical System Manager y Technica.:. Services Superintendent fi/ / Date: llllVl89 'Date: m s j Station Manager \\\\\\\\Nb T Date: O; .\\revapprl.068 7

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L if g n O . DUKE POWER COMPANY / PCP: REVISION APPROVAL ? RevisedePCP:Section: Corporate'PCP,.Rev. 4 i 'ONS PCP, Rev. .MNS PCP, Rev. CNS'PCP, Rev. i G This revision has been reviewed against' Technical Specifications ~ .and'. applicable NRC guidance documents and found to be acceptable. Prepared By: O. E. Ekechukwu

Title:

Nuclear Production Engineer h!df /M Date: / l. I i l l General Office' Review-Station-Review 4 - 'By: AltL2 By: d -- - $ eIsn iNlttibn l

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' W.usw Asurzw & cave:rg $!c2O /SC7 .Date: 67-N d7 Date:- / iThis' revision is approved for.'use at Mccuire Nuclear . Station. ) A/,: n AT441 1 + l lTebhnic'al systfein Manager Metu* ire Technical Services l Superintendent-i Date:. Date: I//8/f7 - ( 3 e i lh1J A1C J (Station Manager Date: 9lMlPI .\\revapprl'.068 V... 9

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~ DUKE POWER COMPANY' ^ PCP-REVISION APPROVAL T y Revised PCP Section: Corporate-PCP, Rev. 4 ONS<PCP, Rev. MNS.-PCP, Rev. qg' .CNS PCP~ Rev.- -This revision-has been reviewed against Technical Specifications m. .and applicable-NRC guidance documents and found to be acceptable. 1 Prepared By: M. B. Entrekin l Ls Nuclear Production Engineer

Title:

i l f g gcg .f ~Date: i J eneral'Ofrice Review: Station Review G te ( By: O.Oe 3d By:- ' f ditt

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tiLbek rt'7b'L by-Title-1 t h- /I!T f FT Date: I'/s s lti i -Date:- This revision.is approved for use at CATAvJSA Nuclear l -Station. .j L ,7 Technical System. Manager . Technical Services Superi tendent /!h/W O Db I ~ LDate: l 'Date: ~ Station Manager ilk 2.LI%. Date: r r .\\revapprl.068 4

e 3 ( 4., i >y4 j T?(. i 7 kW:j %. A-DUKE POWER COMPANY a CORPORATE a -PROCESS ~ CONTROL PROGRAM 1 -TABLE;OF CONTENTS l l'. 0 ' PURPOSE-w. . 2 '. O SOLIDIFICATION ~ 4 .2.1--Vendor-Requirements -: 2. 2. Program: Requirements -i

3.0-' DEWATERING-I3.1. Vendor' Requirements j

'3.2'jProgram Requirements s 4.0' WASTE OIL-N.g. 5. 0 - INTERIM' STORAGE t f6$0 10:CFR'PART 61 COMPLIANCE '6.1_; Vendor Requirements- .6.2 xProgram Requirements-= 7,0-TRANSPORTATION 17.1-Program Requirements-8.0 REVIEWS o 9.0. AUDITS l g i G, ,R ' 1)! t G-1 Rev. 4 i i-w

_y f t* DUKE POWER' COMPANY. -f2). ( CORPORATE 'l PROCESS CONTROL PROGRAM i - 1. 0 PURPOSE q ~ 1.1 The purpose of the. Duke Power Company Corporate Process Control Program is to establish a set of requirements that shall be met at all nuclear stations to insure that all solidification I and dewatering activities are-conducted in a manner and produce.a final product that complies with all applicable Federal and State. ) regulations and licensed burial site criteria. 1.2 The Duke Power Company Process Control Program shall be used to control and direct all solidification and dewatering activities for liquids (e.g., evaporator concentrates) and " wet solids"1(e.g., resin slurries, filter backwash slurries, cartridge filters) at the Oconee Nuclear Station, Units 1, 2 and 3, the McGuire Nuclear Station, Units 1 and 2, and the Catawba Nuclear Station, Units 1 and 2. 1.3 Station - specific procedures shall be developed to -implement the requirements of this corporate PCP. ) 1.4 Station Process Control Programs shall contain Process Control Program-related sections on definitions, limiting conditions for operation, bases and surveillance requirements . transferred from Station Technical Specifications.(TS). 1.5 This~ Process Control Program and implementing procedures shall assure that all solidification and dewatering activities:are in compliance ~with 10CFR20, 50, 61, 71, and 49 CFR and' licensed burial site criteria. 1.6 If this Process Control Program is not followed,.each vessel of processed (i.e., solidified or dewatered) waste shall be physically tested to verify the absence of free standing liquids and all other applicable waste form requirements. i. 2.0 SOLIDIFICATION 2.1 Vendor Requirements i L n O l L G-2 Rev. 4

e 4 -] ) - :. + a i sf-) 2.1.1. -Anyfvendor utilized'for solidification services by Duk? ( Power Company shall:have a. Topical Report that is e.L. a under NRC review or has NRC approval, or shall supply to Duke Power sufficient documentation of the process and results for review to demonstrate an acceptable product will be produced using the described solidification process. L 1 '2.1.2 Any vendor solidification services utilized by Duke Power Company shall be approved by the Corporate Technical System Manager, Nuclear Chemistry and d station (s) Technical Services Superintendent prior to f operation. 2.1.2.1-Technical review shall be performed by corporate and station radwaste staffs of all vendor documents and procedures'to insure they meet the requirements of the Duke-Power Company PCP outlined below. 2.1.3 Chem-Huclear Systems, Inc. has been reviewed and-approved to provide solidification services to the Oconee, McGuire, and Catawba Nuclear Stations as described in: Mobile Cement solidification System, Topical Report CNSI (4313-01354-0IP-A). Approved waste streams for solidi-fication are: boric acid evaporator concentrates, spent bead resin, spent powdered resin, filters, filter backwash slurry, and resin regenerative chemical wastes. )2.1.4 Babcock and Wilcox has been reviewed and approved to l provide' solidification services to McGuire, Oconee and Catawba Nuclear Stations for Class A unstable waste as described in B & W's supporting documents. However, each drum of solidified product-shall be puntured and fully inspected prior to shipment for disposal. Approved waste streams for solidification are: oil, oil and water mixtures, organics, EDTA-based steam generator cleaning solution concentrate, and sludges. The approved binders-are Aquaset, Aquaset II, Petroset and Petroset II. .2.2 Program Requirements 2.2.1 The vendor topical report or documentation supplied to the company shall include a detailed system description giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing all solidification system interfaces with plant radwaste systems and equipment. 2.2.2 The vendor topical report or documentation supplied to o the Company shall include a statement that-the design, construction, operation and quality assurance provisions are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. / G-3 Rev. 4 i

a 1( k. 2'. 3 Duke Power _ Company' permanent or portable ~ solidification 2 systems shall have a detailed system description giving i all1 solidification equipment interfaces.with other company equipment. Drawings or diagrams shall be. . included detailing all solidification system interfaces with:other-plant radwaste equipment and systems. o NOTE:- This information may be included as part of a Topical Report furnished by the equipment manufacturer l<

or supplier or as part of the plant specific Final Safety Analysis Report.

'2.'2.4 Duke l Power Company permanent or portable solidification systems shall be designed, constructed, operated per s and meet all quality assurance provisions of NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143. 7 1 2.2.5 station procedures shall be established to assure the following requirements are met: 2.2.5.1 A representative sample shall be taken from at least every tenth batch of each waste type to verify solidification. s 2'.2.5.2-If the initial sample fails to verify solidification, a representative sample'shall be taken from each consecutive batch of the same type waste.until three consecutive samples demonstrate solidification. 2.2.5.3 A representative sample shall meet all1the following conditions: (a)- The'contentz of_the container to be sampled shall be recirculated a minimum of three volume turnovers or L adequately mixed-to achieve a homogeneous mixture. t NOTE: Adequately mixed shall be defined as: mixing via L+ agitative or'recirculative flow which exceeds a specified i minimum rate which-has been documented to provide a L > representative sample for the vessel. '-(b) For final samples prior to initiating solidification, no additional waste shall be introduced into-the container after recirculation or mixing has~ begun. Vessel level readings or input isolation shall be documented at the time of mixing initiation, sampling, and process initiation. (c)- Recirculation or mixing time and/or volume must be -uninterrupted from initiation until completion of sample collection. h2.2.5.4' During the recirculation and sampling period, the n i vessel shall not be placed in a transfer mode. i l G-4 Rev. 4

2 JTbc j i Ef ( ' d )y 2 ; 2. 5. 5sample analysis.shall be1 performed as. outlined in-t L 1 site-specific procedures for each waste form and t L solidification media. These-should include such f analysis as-(a)- Waste pH. (b)- Waste density. (c)'. Waste boron. concentration. ~(d) Waste-oil content. -2.2.5.6' Test solidification shall be performed to establish' boundary conditions for all process parameters. NOTE: " Process parameters' shlall'bedefinedas,"those-conditions critical to insure complete solidification". NOTE: " Boundary: conditions" shall be defined as, " acceptable-numerical values'for-process-parameters as established by a test solidification". . 2.2.5.7 Process parameters should include any of the following 3which are required to assure solidification: 4 -e ('a). 3, ~, Waste. form. r . (b) , Waste to solidification agent ratio. (c)' Amount of each solidification additive. (d) Waste pH. 9 l(e)- . aste boron concentration. W (f) Waste density. ~(g)' Waste oil content.- (h)' .Mixerfspeed. (i)- Mixing time. (1) Curing time. (k) ' Specific activity. 2.2.5.8 vendor shall submit sample analysis, test solidification results and prescribed boundary condi-tions to Station Chemistry supervision. (])n2.2.5.9 Station Chemistry supervision shall review the data outlined in Step 2.2.5.8 and shall authorize solidi-fication prior to initiation. G-5 Rev. 4 4 f ~t L.-

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+ .- c ,3 i i 3 i)L ( a)=. Difficulties and/or disagreements betwaen vendor and-station personnel should be resolved through direct interaction between vendor and station. Corporate Nuclear Chemistry staff should be contacted if' resolution cannot be-reached'at the station level. 2.2.5.10 Solidification for disposal shall not be performed i unless the test solidification is acceptable. -2'.2.5.11 All system operation shall be controlled by station procedures to assure that the solidification system ic operated within the boundary conditions established in 1 Step 2.2.5.7. 4 (a) ' Vendor procedures shall be incorporated as attachments to station procedures. Vendor format may be retained as a DPC enclosure if' desired or the procedure may be rewritten into E DPC format. h 2'.2.5.12 The absence of free standing liquids (FSL) shall be verified for each vessel of solidified waste prior to disposal. Verification shall be performed by either confirmation that the Process Control Program was followed or by physical testing. '- )*T (a) Physical testing shall be required for each vessel if the (/ Process Control-Program was not followed or if any off-normal condition existed during processing. - ( a.1 ) - Physical testing shall consist of visual inspection and probe < penetrate tests. -(b) A-vessel shall have less than 0.5% free standing liquid by waste volume. (c) If a.High Integrity container is utilized, the vessel shall have less than 1%-free standing liquid. 2.2.5.13 Any solidification vessel'that does not pass the tests specified in' Step 2.2.5.12 shall not be shipped to a . burial site until reprocessing or repackaging has resulted in an acceptable product. 2.2.5.14 Records shall be maintained by Duke Power Company on each vessel of. solidified wastes. These records shall be maintained for six (6) years (per the Administrative Solicy Manual). (a) These records shall include: ,( ) (a.1), Representative sampling documentation (per Step 2.2.5.3). -G-6 Rev. 4

1 bN , J. i ss 3 )"(.a.2): Sample 1 analysis results (per' Step 2.2.5.5). 1 1 -(a.3) Reference test' solidification results and boundary conditions =(per' Steps 2.2.5.6 and 2.2.5.7). (a.4) Station Radwaste Supervision authorization for ~ solidification per (Step 2.2.5.9). a ( a'. 5 ) System operation data to insure all boundary conditions were met (per Step'2.2.5.ll). (a.6)- FSL Verification (per Step 2.2.5.12). 3.0L> DEWATERING 3.1 Vendor Requirements 3.1.1 Any. vendor ~ utilized by Duke Power Company to provide dewatering services shall have a Topical Report that is j either under NRC review or has NRC approval, or shall supply to Duke Power sufficient documentation of process j and results for review to demonstrate adequate dewatering is accomplished using the described process. V 1 3 ' 1. 2 ' Any vender dewatering services utilized by Duka Power Company shall ha approved by the Corporate Technical

( -

_ System Manager, Nuclear Chemistry and statients) J ~ ' Technical Services Superintendent prior to operation. 1'-$ 3.1'.2.1 Technical review shall be performed by corporate and gh '# station radwaste staffs of all vendor documents and ~~f procedures to insure they meet all requirements of'the Emke Power Company PCP outlined below. 'W .'3.1.3 . Chem-Nuclear Systems,-Inc. has been reviewed 1and approved to provide dewatering' services to Oconee, 0 .McGuire, and Catawba Nuclear Stations as described in Topical Report CNSI-DW-11118-01. L ,3.2 Program Requirements 3.2.1 The vendor topical report or documentation supplied.to the company shall' include a detailed system. description giving all vendor interfaces with company equipment. Drawings or diagrams shall be included detailing'all L dewatering system interfaces with plant radwaste systems and equipment. '3.2.2 The vendor topical report or documentation supplied to the Company shall include a statement that the design, construction, operation and quality assurance provisions (]). are in accordance with Regulatory Guide 1.143. a G-7 Rev. 4

l c.; r >h): 3$ 2. 3. All_. Vendor supplied portable-domineralizers shall meet all requirements of. Steps 3.2.1 and 3.2.2. 3.2.4 Duke Power Company. permanent or portable dewatering-systems shall have a detailed system description giving -all dewatering equipment interfaces with other company equipment. = Drawings or diagrams shall be included detailing all dewatering system interfaces with other plant radwaste equipment and systems. NOTE: This information may be included as part of a Topical Report furnished-by the equipment manufacturer or supplier or as part of the plant specific Final Safety Analysis Report. <3.2.5 Duke Power Company permanent or portable dewatering systems shall be designed, constructed, operated per and meet all quality assurance provisions of NRC Branch Technical' Position 11-3 and Regulatory Guide 1.143. 3.2.6 Station procedures shall be established to assure the following requirements are met: 6 -3.2.6.1 Boundary conditions shall be established for all precess parameters. ~ NOTE: Process-parameters shall be defined as, "those l conditions critical to insure complete dewatering". l . NOTE:, " Boundary conditions" shall be defined as, unacceptable numerical values for. process parameters".. i L 3.2.6'.2 Process parameters.shall be identified in site-specific procecures. Typical parameters are: ~ (a)- Waste form. r (b): Settling time. (c) Drain-(or pump) time. p (d) Drying' time. l 3.2.6.3-Sample analysis and boundary conditions shall be L submitted to the Station Radwaste Supervisor. L '(a) For filter. dewatering, data shall be submitted to the p Station Health Physics Supervisor. 3.2.6.4 Station Supervisor shall review the data outlined in Step-3.2.6.3 and shall authorize dewatering prior to initiation. p G-8 Rev. 4 bo !w

4 1 -O'-(a) Difficulties and/or disagreements between vendor and station personnel should be resolved through direct interaction between vendor and. station. Corporate Nuclear Chemistry staff should be contacted if resolution cannot be reached at the~ station level. l; I ! 3.2.6.5 All operations shall be controlled by station [ procedures to assure that all boundary conditions q established in Step 3.2.6.1 are met. t .(a) Vendor procedures shall be incorporated-as attachments to-station procedures. Vendor format may be retained as a DPC-- t enclosure if desired or the procedure may be rewritten into DPC format. 3.2.6.'6 The absence of free standing-liquids (FSL) shall be l' verified for each vessel of dewatered waste prior to disposal. Verification shall be performed by either confirmation that the Process Control Program was L followed or by physical testing. (a) Physical testing shall be required for each vessel if the Process Control Program was not followed or if any off-normal condition existed during processing. (b) A vessel shall have less than 0.5%. free liquids by waste .n volume. Q (c) A High Integrity Container shall have less than 1% free liquids by waste volume. 3.2.6.7 Any.dewatered vessel containing excess free liquids, as defined in Step 3.2.6.6, shall not be shipped to a burial site until reprecessing or repackaging has resulted in an acceptable product. 3.2.6.8 Records.shall be maintained by Duke Power Company on each vessel of dewatered wastes. These records shall'he maintained for six (6) years (per the Administrative Policy' Manual). These records shall include: (a) Sample analysis-and boundary conditions:(per Step 3.2.6.3). (b). Station supervisor authorization for dewatering (per Step 3.2.6.4).- (c) Equipment operation data to insure all boundary conditions-were met (per Step 3.2.6.5). (d) FSL Verification (per Step 3.2. 6. 6). O .0 4 WASTE OIL . 4.1 Incidental levels of waste oil may be solidified using the . system described in Section 2.2. G-9 Rev. 4 4 w-- - - * ,-e

e. - - - - -. -

7 ..- ~. - - - ~. v', p$ Q' I{ edE h.). s!4.1.1" " Incidental" shall be. defined as less than 1% oil. '4.2,)If larger-volumes.of waste oil-'are to be solidified a specialiprocedure shall-be'used. 74.2.1 . The vil-specific procedure shall-include all ^ requirements in Section 2.0. '4.3L Solidified-waste oil shall not be shipped to the licensed; s s burial site:at Barnwell, S.C., for disposal,-except as

defined-in Step 4.1.

i s ' 5.O; INTERIM STORAGE l .5.1 Program Requirements 5.1'.1 Station procedures shall be established to assure the q following requirements are met: 5.1.1.1 . Any processed (i.e., solidified or dewatered) waste that is stored for an interim period in a disposal container shall be packnged such that there is no -interaction between the waste and'its container. '5.1.1.2 If applicable, certificates of Compliance shall be . maintained at each station for all waste disposal containers used for interim storage. 5.1.1.3 Vendor supplied handling and storage procedures shall-be maintained at each station. 5.1.1 ~. 4 ' Each container and waste shall be checked against 4 information given in Steps 5.1.1.2 and 5.1.1.3 to . insure all chemical compatibility requirements are met. 5.1.1.5 Station Chemistry.or Health Physics supervision shall review the information in Step.5.1.1.4 and shall certify chemical-compatibility and authorize storage. - 5.1,1.6-~ l Records shall be maintained by Duke Power Company for each container. These records shall be maintained for six (6) years'(per the Administrative Policy Manual). These records shall include: . (a). Chemical' compatibility certification (per Step 5.1.1.5). (b) Station ~ supervision authorization to store waste (per Step 5.1.1.5), 6.0 -10CFR61-COMPLIANCE 6.1 Vendor Requirements V G-10 Rev. 4 4 y. g v-w y e- - +

t I 6 7,g 6.1.1-TheLvendor(s) described in Section 2.1 for . solidification shall have a NRC approved-report documenting compliance with waste form-requirements in the final ^ solidified product, or shal1~ supply Duke Power sufficient documentation to demonstrate waste form compliance. ~ 6.1. 2 - The vendor (s) described'in Section 3.1'for dewatering shall have a NRC approved report documenting compliance

with waste form requirements in the final dewatered

-product, or shall supply Duke Power aufficient -documentation to demonstrate waste' form compliance. 6.1.3 Any vendor providing High Integrity Containers to Duke Power Company shall have a NRC approved report-documenting compliance with waste form requirements, or shall supply Duke Power aufficient documentation to t demonstrate waste form compliance.. 6.'1.4 All vendor reports (per Steps 6.1.1, 6.1.2, and 6.1.3) 4 shall contain a statement that the final product conforms to the appropriate waste form for either Class A, B, or C waste, t V 6.2 Program-Requirements-L O'6.2.1 Station procedures shall be established to assure the fo nowing reeuir - nts - e met: 4 1: 6.2.1.1 Each container of processed (i.e., solidified or i dewatered) waste shall be classified-as either Class A, B, or C waste-using the Duke Power Company "10 CFR Part 61 Waste Classification and Waste Form Implementation Program". - 6.2.1.2 'Each container of processed waste shall be certified-to the appropriate waste form for either Class A,~B or C waste. (a) Waste form certification shall be contingent upon the documents referenced in Section 6.1. s 6.2.1.3 Records shall be maintained for each container of 1 processed waste to assure compliance with the requirements of Steps-6.2.1.1 and 6.2.1.2. These records shall be maintained for six (6) years (per the l Administrative Policy Manual). 7.0 TRANSPORTATION l 7.1 Program Requirements .O c %) G-11 Rev. 4

Lj, g: 9 f e 2017.1.1 x11 shi>>1n casxs used to trans, ort processed waste, for burial shall have a NRC issued Certificate of Compliance. t 7.1.2 Station procedures shall be established to insure all requirements of the certificate of Compliance are met. 7.1.2.1 Vendor procedures shall be incorporated into station procedures prior to use. Vendor format may be retained, if desired, or the procedure may be rewritten into:DPC format. 7.1.3 Station procedures shall be established to insure all-applicable Federal and State regulations and burial site criteria are met for each container of-processed waste. ~7.1.4 Records shall be maintained for each container and' shipment of processed waste. These records shall be maintained for six (6) years (per the Administrative Policy. Manual). These records shall include: - 7.1. 4.1- -Documentation of a-valid certificate of compliance for each cask (per Step 7.1.1). Maintained for six (6) years. p 7.1.4.2 Documentation that all requirements of the Certificate A of-Compliance were met (per Step 7.1.2). Maintained for six-(6): years. ~7.1.4.3 Documentation that all shipping regulations were met (per Step 7.1.3). Maintained for life of plant. 8.0 REVIEWS .8.1 F:cgram Requirements '8.1.1 Changes to the Corporate Process Control Program shall .be reviewed by the Corporate Nuclear Chemistry staff and each station's Radwaste and-Health Physics staffs prior to implementation. Proposed revisions shall be reviewed against Technical Specifications and all applicable-NRC guidance-to asbure all. requirements of a Process. Control-Program have been addressed. Review documents shall include: 0.1.1.1 - NUREG-0133. 8.1.1.2 NUREG-0472. 8.1.1.3 NUREG-0800. O 8.1.1.4 Branch Technical Position - ETBS 11-3. G-12 Rev. 4 a

71 l .I h?.1'.1.S 8 D 7 Appendix aa.4-A,-" Design Guidance for Temporary Storage...". 8.l.'1.6 'NRC Review' Criteria for-Solid Waste Management Systems. 8.1.i.7 Site-specific Technical Specifications. <8.1.2 Changes to-the Corporate Process-Control Program shall { l be approved by the Technical System Manager, Nuclear Chemistry and each station's Technical Services Super-intendent prior to implementation.- 8.1 '3 Each Station Manager shall document that any changes to the Corporate Process Control Program have been reviewed and approved (per Steps 8'.1.1 and 8.1.2). - 8.1. 4 ' The Nuclear Safety Review Board shall' review the d activities of the Station Manager detailed in Step i 8.1.3.

8.1.5-A record of the review (per Step 8.1.4) shall be sent to the Vice President, Nuclear Production and the Executive Vice-President, Power Operations within

. fourteen (14) days following completion of the review. 8.1.6 All changes to the Corporate PCP shall be sent to the i NRC in each station's Semi-annual Radioactive Effluent Report for the period in which the changes were t implemented. I: 8.1.7 Changes to all implementing procedures shall be reviewed by station radwaste or health physics. staff and approved by the station's. Technical Services, Operating, og Maintenance Superintendent, or Station Manager, prior to implementation. 8.1.7.1 Changes to implementing procedures shall be reviewed by the Technical Services, operating, OR Maintenance Superintendent, or Station Manager, to assure they do i not conflict with-the Corporate Process Control Program. 8.1.8 Records shall be maintained documenting the approvals required by Section 8.1. Records shall be maintained for six (6) years (per the Administrative Policy Manual). 9.0 AUDITS 9.1 Program Requirements O-G-13 Rev. 4 l.

p. 1 K l p: jh-J 9.1.1 - ' The Corporate Process Control Program and station ~ implementing procedures shall be audited at least once l per= twenty-four months at each station. 9.1.2 This audit ~shall be performed under.the cognizance of [ L the NSRB. ,t l - 9.1. 3 ' Audit reports shall be forwarded to the Vice President, Nuclear Production; Executive Vice President, Power' o L--, operations;:and Station Manager within thirty (30) days of completion of the audit. L ? I' 1 [: L O t x o.. G-14 Rev. 4 .\\ '.

~ + 't s DUKE POWER' COMPANY ~ STATION PROCESS CONTROL PROGRAM l' 0 - PURPOSE The purpose of the Duke Power Company Station Process Control Program shall be to insure all requirements of the DPC Corporate Process Control Program have been met for each container of' solidified or dewatered radioactive waste shipped for burial at a licensed burial facility. i 2.0. COMPOSITION 2.1 The Duke Power Company Station Process Control Program shall consist of: 2.1.1 The Duke Power. Company Process Control Manual Introduction (Section I). -2.1.2 The Duke Power Company Corporate Process Control l Program. O1 A list of all station-specific procedures'that 2.1.3 implement the requirements of the Corporate Process ~ Control Program. 2.1.4 Diagrams or drawings or drawing numbers showing all connections between plant radwaste systems and solidi-e" fication and dewatering equipment. 2.1.5 Documentation of NRC approval of the initial Station Process Control Program. L 2.1.6 Documentation of System Tecnnical System Manager, Nuclear Chemistry station, Technical Services Superintendent, and Station Manager approval of all i changes to the Corporate Process Control Program. 1 2.1.7. Documentation that all changes to the Corporate and/or Station Process Control Program were sent to the NRC in the Semi-Annual Radioactive Effluent Report. 2.1.8 Relevant Sections and Subsections of Process Control Program-related definition transferred from Section 1 of Nuclear Station Technical Specifications. 2.1.9 Relevant sections and subsections of Process Control Program-related limiting conditions for operation, bases /~k-) and surevillance requirements transferred from sections 3/4 of Nuclear Station Technical Specifications. G-15 Rev. 4

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e -.e r i s" s 7.,; i .f3;OfEXCEPTICIES L-r3.1 Each Station's~ exceptions.to the Corporate PCP shall-'be? ~ documented in the. Station's PCP.: 3 = I - t ?

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