ML20040G787

Responds to Questions Re Process Control Program for Radwaste Solidification Sys

ML20040G787
Person / Time
Site:	LaSalle
Issue date:	02/11/1982
From:	Sargent C COMMONWEALTH EDISON CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8202160466
Download: ML20040G787 (4)

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Y /^N Commonwealth Edison one First National Ptzt, Chic go, lihno s

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\v'/ Address Reply Chicago tilinoisto: Post Offs Box 767 60690 Feb rua ry 11, 1982

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Mr. - A. Schwence r, Chie f NED ,

Licensing Branch #2 -

Division o f Licensing -

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4 U. S. Nuclear Regulatory Commission Washington, DC 20555 g"Qatam m rze 4

Subject:

LaSalle County Station Units 1 and 2 Response to Questions Concerning Process Control Program NRC Docket Nos. 50-373 and 50-374

Dear Mr. Schwencer:

The purpose of this letter is to provide our response to questions forwarded to Commonwealth Edison Company by Mr. A. Bournia concerning the LaSalle County Station Process Control Program.

Enclosure 1, attached, provides our response as well as a listing of the questions.

If there are any further questions in this regard, please contact this office.

Very truly yours, s

C. E. Sargent Nuclear Licensing Administrator im Enclosure cc: NRC Resident Inspector - LSCS

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3448N- $13)

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8202160466 920211 ~

PDR ADOCK 05000373 A PDR

O ENCLOSURE 1

1. Expended Cartridge - type filter elements will be dried as necessary and shipped as Dry Active Waste (DAW).

2. The following administrative controls (described in Section V of the LSCS PCP) provide reasonable assurance that the correct solidification formula is used for each waste stream.

a. Operating procedures address solidification of each type of waste separate formulas are included.

b. Each waste container Is assigned a unique identification number. The type of feed, quantitles of waste and cement, and final drum weight are recorded.

c. The container records are reviewed to verlfy that the correct drumming formula was used.

3 As discussed in Section VI of the PCP, the Concentrator Waste Tanks are sampled and analyzed for total solids content and pH before feeding to the LSCS solidifi-cation system. The total solids content of the feed is used to select the amount of cement and waste added to the container. If the waste pH is too high (> 10) It may be adjusted by addition of sulfuric acid. Before sampling, the tanks are recircu-lated for sufficient time (4 hrs.) to provide for 2 nominal tank volumes of total recirculation flow and adequate mixing.

4. As discussed in Section V.C. of the PCP, the free-standing water Ilmit is any visible water. This will be performed visually using remote viewing techniques such as mirrors, TV cameras, etc.

5 LOS-WX-01 outlines the following solidification tests and inspections:

a. Weekly, the process control parameters are reviewed for each drum solidified during the week. The review verifles that the correct drumming formulas were used, and that cement (waste quantities and drum final weights were within drumming formula tolerances) .

b. At the frequencies required by sections V.C. and V.D. of the PCP, drums are removed from storage, opened and inspected at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> aft er mixing.

Routine solidification tests and inspections will be performed on a full-scale basis; i.e., on the 55 gallon containers of solidified waste. Laboratory scale solidification tests are not used in the LSCS PCP.

Before shipment, excess water will be eliminated from drums which fall the solidification test. Drums will be inspected for solidification at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter mixing and prior to shipping.

6. At LSCS, cement for radwaste solidification is purchased by truckload and stored Indoors in an enclosed stgel silo. The storage area temperature is maintained by plant ventilation to a 60 - 100 F range. Indoor storage provides reasonable assurance that cement quality will be maintained. Plant inspection of a cement shipment verifies that the cement is properly certified to meet ASTM C150-1980 req ui remen ts .

7 Each resin source (tank) is sampled and isotopically analyzed for gamma emitters.

Based upon this analysis, the activity (uCi/ gram) and % abundance of each isotope in the resin are determined.

The Curie content of each processed barrel will be determined using conservative calculations which relate the average barrel surface dose rate to the total activity.

Station procedures prov,ide detailed formulas and tables to be utilized in estimating Curie content.

j, 8' . The 4-inch ring is s:curely attached to the drum head by swaging. During the pre-operational testing at LSCS at least 50 drums have been mixed without a single failure of the *Ing-to-drum-head Joint.

9 New solidification drum shipments are inspected to verify that certifications to DOT 17C specifications are included with the shipments. The Inspection may include verification that drum wall thicknesses are within tolerance and that seams are tight. Prior to loading with cement and waste, each drum is inspected to verify the absence of dents and holes and the presence of the required " Radioactive LSA" markings. The inspection also verifies that a 4-inch cap and gasket are installed hence open head drums would be eliminated. The drumming station capping interlocks (described in section Ill.E of topical report SRS-001-NP) would shut down the drumming operation when no drum cap was detected. New drum wall thicknesses will be 16 gauge.

10. Prior to shipping, drums are inspected for removable contamination and general condition. Drums which are damaged during handling will be identified during this inspection. Damaged drums will be placed in 70 gallon drums for shipment.

11. Although Laundry R0 wastes are not referenced in the Topical Report, Stock Equipnent Company has performed solidification tests on detergent solutions. The results indicate that non-foaming de'ergent solutions can successfully be solidified on the basis of solution solids content. As described in the LSCS PCP, Laundry RO wastes are combined with other concentrator wastes and solidified on the basis of solids content. AJditionally, since the Topical Report was issued a Laundry Dry Cleaning Facility has been installed which will substantially reduce the volume of laundry waste.

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Questions from ETSB on the Process Control Program for the Radioactiva Waste Solidification System at LaSalle' Station l PCP (Rev 0) July 29, 1981

1. How will the wet filter cartridges be packaged for' waste disposal?- 1

2. 'What controls will be used to prevent using the wrong solidification formula for

the five different types of waste feed?

l 3 What chemical and physical characteristics will be measured by the analysis of the-

sampled feed? What steps will be taken to adjust the feed to the parameters for which the formulas were developed? How are these samples taken to assure they are representative?

4. What limits are used to define free standing water versus no free-standing water?

How is this determined through a 4-inch diameter drum plug hole?

5 Provide a summary of procedure LOS-WX-101. Define the laboratory scale tests for free standing water and solidification and discuss the laboratory scale equipment.

What will be done with drums that fall solidification or free standing water 1 inspection. Clarify that drum inspection is made af ter 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and prior to

shipment.

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6. How will storage conditions assure that the quality of the cement is maintained?

Define the plant inspection for the cement.

7 How will the Curie content in each drum be determined for shipment?

8. Explain how the 4-inch ring (Part C9182) is attached to the drum lid so that it j does not rotate or fall during remote capping.

9 Describe the plant inspection steps for new drum. What steps will be taken to assure that open head drums are not used in the solidification system? What wall thickness is to be specified for new drums?

10. Should a packaged drum be damaged in handling, what pre-shipment inspection controls

and followup action will be taken?

11. Laundry RO wastes are not referenced in the Topical Report. Provide the ini tial test results to verify that this type of waste can be solidified.

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