ML20043B111

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Rev 0 to Station Administrative Procedure VPAP-2104, Radwaste Process Control Program
ML20043B111
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 04/27/1990
From: Joshua Wilson
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20043B104 List:
References
VPAP-2104, NUDOCS 9005240202
Download: ML20043B111 (18)
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Station Administrative.

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i Ihle: Radioactive Waste Process Control Program (PCP) 9 Lend Denartment:.- Radiological Protection l

Procedure Number:.

Revision-Number:

Effective Date:.

VP AP-2104 -

0 05/31/90' i

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Surry, Power Station North Anna Power Station Approved by:

Approved by:

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Approved by Approved by:

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- VIRGINIA ~

VPAP 2104 POWER REVISION 0 ;

es PAGE 2 OF 16 JJ TABLE:OF CONTENTS Section

- Pane :

1.0 PURPOSE 3

3-2.0 SCOPE.

3.0 REFERENCE / COMMITMENT DOCUMENTS

3-4.0 DEFINITIONS 4

5.0 RESPONSIBILITIES 6

6.0 INSTRUCTIONS

.7 6.1 General Descriptions and Requirements 7

6.1.1 Types of Wet Radioactive Waste 7

6.1.2 Waste Sources 7 '-

6.1.3 Requirements for Processing. Wet Radioactive Waste 8'

6.1.4 Process Control Program Implementing Procedures ~

8 6.1.5 Requirements For Use of Contractor Services 9

6.2 Solidification of Wet Waste ~

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L 6.2.1 Solidification Parameters 10 6.2.2 Adverse Chemical Reactions During Solidification 10 6.2.3 Sampling, Analysis, and Process Surveillance -

11 6.2.4 Processing Acceptance Criteria 12 1

6.3 Dewatering and Encapsulation 'of Filter Elements 12 6.3.1 GeneralRequirements 12

.6.3.2 Filter Elements to be Disposed of as Class A Waste 13 6.3.3 Filter Elements to be Disposed of as Class B or C Waste 13 6.4 Reporting Requirements

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6.4.1 Major Changes to Radioactive Solid Waste Treatment Systems 14 6.4.2 Changes to the Process Control Program (PCP) 15 7.0 RECORDS 16

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u VIRGINIA VPAP 2104:

POWER '

REVISION 0 PAGE 3 OF 16-1,0-PURPOSE This procedure establishes Virginia Power's PROCESS CONTROL' PROGRAM (PCP) '

including associated requirements and n:sponsibilities.' The PCP provides instructions for -

i processing and packaging of wet radioactive wastes to assure compliance with applicable Federal and State regulations for disposal of solid radioactive waste.

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2.0 SCOPE This pmcedure is applicable to the processing and packaging of wet radioactive waste performed at or by the Station. Systems and procedures used for implementing the PCP, including vendor supplied systems and procedures, shall be considered a part of the PCP.-

3.0 REFERENCES

/ COMMITMENT DOCUMENTS t

I 3.1 References 3.1.1 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Production and Utilization Facilities ~

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3 3.1.3 10 CFR 61, Licensing Requirements for Land Disposal of Radioactive Waste j

3.1.4 - 10 CFR 71, Packaging and Transportation of Radioactive Material 3.1.5 -49 CFR Pans 170 to _189, Department of Transportation Regulations for Transportation of Hazardous Materials 3.1.6 USNRC low Level Waste Licensing, Branch Technical Position ~on Radioactive -

Waste Classification and Technical Position on Waste Form, May 1983, Rev 0 3.1.7 INPO 88 010, Guidelines for Radiological Protection at Nuclear Power Stations t

3.1.8 NUREG 0800, USNRC, Standard Review Plan ~11.4, Solid Waste Management 1

. Systems, Rev 2, July 1981 l

3.1.9 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RSTS) in the Administrative Controls -

ii Section of the Technical Specifications and the Relocation of Procedural Details of t

RETS to the Offsite Dose Calculation Manual or to the PROCESS CONTROL 1

PROGRAM i

3.1.10 Surry and North Anna Technical Specifications 3.1.11 NODS-HP-01, Radiation Protection Plan

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3.1.12 VPAP-0102, Station Nuclear Safety and Operating Committee u

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VIRGINIA VPAP 2104 POWER REVISION O PAGE 4 OF 16

/G 3.1.13 VPAP 2101, Radiation Protection Plan 3.1.14 VPAP 2103, Offsite Dose Calculation Mannl(ODCM) l 3.1.15 VPAP 3001, Safety Evaluations (when hsueA I

3.1.16 Chem Nuclear Systems,Inc. Letter (conceming limitation of package void space),

October 6,1989, GAR 196 89, (460$g) l 3.2 Commitment Documents None i

4.0 DEFINITIONS 1

l NOTE: Terms which are defined in Surry and North Anna Technical Specifications appear as all capitallred letters in the text of this pmcedure for identification.

4.1 Batch A quantity of waste that is or may be mixed to produce a homogeaccus mixture for the purposes of sampling, testing, and processing. Different samp3es of a homogeneous mixture are expected to exhibit similar chemical and physical properties.

4.2 Composite A mixture of samples, proportional by volume to the individual transfers making up a batch, that creates a test specimen representative of the batch.

4.3 Free Liquid Free liquid is the liquid still visible after solidification or dewatering is complete, or is drainable

' om the low point of a punctured container (NRC SRP 11.4, ETSB 11 3).

4./

dish Integrity Container A container designed to provide long term structural stability to contained waste during the l

required disposal period. May be used as an attemative to waste solidification. See section C.4 of NRC BTP (Waste Form) for more details. High integrity containers must be approved L

by the appropriate agency.

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VIRGINIA VPAP 2104 IOWTR REVISION 0 PAGE 4A OF 16 SUPPLEMENTAL REFERENCE PAGE This Supplemental Reference Page is provided to aid the pmcedure user in determining the appropric.te procedures to use until such time that proceduits referenced in the References Section, which reflect "When issued", are approved and issued.

a. Upgraded Procedure Reference VPAP 3001, Safety Evaluations (When issued)

The following existing procedures shall be used with respect to Safety Evaluations until such time that the new referenced procedure is approved and issued:

a. Surry
1. SUADM LR 12, Safety Analysis /10CFR$0.59/10CFR72.48 Safety Evaluations and Justifications for Continued Operations
b. North Anna
1. ADM 3.9,10CFR 50.59 Safety Evaluation and JCOs (North Anna)
2. ADM 3.15 Tracking of Justifications for Continued Operation (JCO)

NOTE: This Supplemental Reference Page shall be removed and pmcesv.d as directed upon notification from Records Management.

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i VIRGINIA VPAP 2104 i

POWER REVISION 0 PAGE 5 OF 16

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4.5 Non Corrosive Liquid i

In lieu of specific tests, a liquid may be considered non corrosive if it has a pH between i

4 and 11 (based on section C.2.h of NRC BTP (Waste Form)).

s 4.6-Process Control Program The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas, sampling, analyses, tests and determinations to ensure that pmcessing and packaging of solid radioactive wastes, based on demonstrated processing of actual or simulated wet solid wastes, will be accomplished in a way that assures compliance with 10 CFR Parts 20,61 and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste, i

4.7 Site Boundary l

The SITE BOUNDARY is that line beyond wb!ch the land is not owned, leased, or otherwise controlled by Virginia Power.

4.8 Solidification Solidification is the conversion of wet waste into a form that meets shipping and burial ground requirements.

4.9 Spent Ion Exchange Material Organic resins and other ion exchange material are considered spent when decontamination factors decrease significantly or when activity levels reach a pre-determined level.

4.10 Stabilization or Stability A structurally stable waste form will generally maintain its physical dimensions and its form l

under the expected disposal conditions. Structural stability can be provided by the waste form itself, processing the waste to a stable form (e.g, solidify), or placing the waste in a disposal l

container or structure that pmvides stability after disposal (10 CFR 61.56(b)).

R 4.11 Test Specimen A sample obtained fmm a batch of waste to be processed (solidified or absorbed), or a l

simulated sample of similar chemical and physical characteristics, on which a test can be performed to verify the intended process will perform satisfactory.

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VIRGINIA VPAP 2104 POWER REVISION 0 PAGE 6 0F 16 i

i 4,12 Unrestricted Ares l

UNRESTRICTED AREA is defined as any area at or beyond the SITE BOUNDARY where 1

accese,tw, wtrolled by Virginia Power for purpows of protection of individuals from 1

expr me to r.atior. and radioactive materials or any area within the SITE BOUNDARY used forrtJis 41 quarters or for industrial, commercial, institutional or recreational purposes.

4,13 Wet verstis Dry Wastes (from NRC SRP 11.4, BTP ETSB 113)

Radioactive waste is generated in the forms of" wet" and " dry" wastes. Wet wastes, including l

spent ion exchange material, filter sludge, evaporator concentrates, and spent cartridge filter elements, normally are byproducts from liquid processing systems. Dry wastes, including activated charcoal, HEPA filters, rags, paper, and clothing, normally are byproducts from ventilation air and gaseous waste pmcessing systems, and maintenance and refueling operations.

t 5.0 RESPONSIBILITIES 5.1 Health Physics Health Physics GIP) is responsible for:

m 5.1.1 Implementing the PROCESS CONTROL PROGRAM as a pan of the Radiation Protection Program.

5.1.2 Ensuring that vendors bmught on site by Health Physics to perform waste processing are cognizant of responsibilities in accordance with this procedure.

5.1.3 Maintaining procedures necessary for implementing the PCP.

5.2 Operations Department

'Ihe Operations Department is responsible for:

5.2.1 Implementing the PROCESS CONTROL PROGRAM as part of normal Station operations.

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5.2.2 Ensuring that vendors brought on site by Operations to perform waste processing are cognizant of responsibilities in accordance with this procedure.

5.2.3 Maintaining procedures necessary for implementing the PCP.

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l VIRGIN!A VPAP 2104 l

POWER REVISION 0 i

PAGE 7 OF 16 O

i 6.0 INSTRUCTIONS 6.1 General Descriptions and Requirements 6.1.1 Types of Wet Radioactive Waste Wet radioactive wastes produced at the Station which must be processed for disposal f

include:

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+ Resin

  • Filterelements
  • Waste oil

+ Liquid waste t

6.1.2 Waste Sources

a. Station systems which normally process radioactive liquids with the subsequent generation of spent radioactive ion exchange bead resin and/or filter elements which must be processed for disposal are:

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+ Primary Coolant System

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  • Spent Fuel Pit Purification System

+ Vent and Drain System

+ Liquid Waste Processing System

b. If primary to secondary leakage occurs while the Condensate Polishing System is processing secondary condensate, resin and filter elements used in the system may become radioactive, if so, they shall be pmcessed for disposal,
c. If lubricating / cooling oil becomes contaminated with radioactive material, and if the oil is to be disposed of as radioactive waste in a licensed land disposal facility, the oil shall be considered and processed as wet radioactive waste.
d. Ifliquid wet waste is produced which must be disposed of(e.g., evaporator

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bottoms or decontamination solutions)it shall be treated as wet radioactive waste.

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VIRGINIA VPAP.2104 POWER REVISION O PAGE 8 OF 16 O

6.1.3 Requirements for Processing Wet Radioactive Waste

a. Liquids which are to be processed as radioactive waste shall be processed by solidification.
b. Resins shall be processed by dewatering and/or solidification.
c. Filter elements shall be processed by dewatedng or encapsulation in a solidification binder.
d. Waste oil shall be processed by solidification or transferred to a licensed waste processor for disposal.
c. Class B and Class C waste shall be stabilized prior tc disposal (10 CFR 61),
f. Certain categories of Class A waste shall be stabilized prior to disposal as required by the disposal site and/or the disposal site license conditions.

6.1.4 Process Control Program implementing Procedures

a. Health Physics shall maintain procedures necessary to implement the PCP.

Procedures shall include acceptable methods for:

1. Radioactive waste sampling, analysis and waste classification. Waste classification shall be performed per 10 CFR 61.55, Waste Classification, and methods set forth in NRC BTP on Radioactive Waste Classification, i

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2. Radioactive waste processing including waste solidification and stabilization.

Acceptance criteria shall meet criteria set forth in:

+ 10 CFR 61.56, Waste Characteristics

+ NRC BTP on Waste Form

+ Disposalsitecdteria

3. Radioactive waste packaging ar.d shipping. Acceptance criteria shall meet requirements set forth in:

+ 10 CFR 20.311, Transfer for Disposal and Manifests

+ 10 CFR 71, Packaging and Transporting of Radioactive Material

+ 49 CFR 170 - 189, Transportation of Hazardous Materials O

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VIRGINIA VPAP 2104 POWER REVISION 0 PAGE 9 OF 16

b. Operations Department shall maintain procedures necessary to implement the PCP.

Pmcodures shallinclude acceptable methods for dewatering ion exchange resin.

6.1.5 Requirements For Use of Contractor Services i

The following actions shall be taken before a contractor supplied waste processing

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l system is used on site:

a Obtain the following, as a minimum, for review and evaluation:

  • A detailed system description, which may be included in a topical report or f

equivalent documentation i

+ System operating procedures, which include process control parameters

  • A list of required physical interfaces and Station materials /senices
  • A list of chemicals to be brought on site, quantity to be used and material safety I

data sheets for each chemical l

  • A list of expected utility / contractor responsibilities including disposal of unused l

and contaminated chemicals l

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+ Vendor's document control procedures / manual to ensure controls are in place which prohibits use of procedures not approved by Station Nuclear Safety Operating Committee (SNSOC)

b. Compare the system description and operating procedures to the requirements provided in Subsection 6.2, Solidification of Wet Waste. Ensure that the system can be operated within requiremer;ts.

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c. Submit system operating procedures to SNSOC for review and approval in I

accordance with VPAP-0102, Station Nuclear Safety and Operating Committee.

Pmeessing of radwaste shall not be performed without approved operating l

procedures.

d. Ensure the contractor provides a system as proposed, described, and approved for j

use at the Station.

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VIRGIN %

VPAP 2104 POWER REVISION O

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PAGE 10 OF 16 6.2 Solidification of Wet Waste P:tcedures used for wet waste solidification shall incorporate the following requirements:

6.2.1 Solidification Parameters

s. As appropriate, parameters used when performing solidification may include, but i

are notlimited to:

+ Waste type

  • Waste pH

+ Ratios of waste / liquid to solidification agent / catalyst

+ Waste oil content

+ Waste principal chemical constituents i

+ Mixing and curing times i

b. Once established, solidification parameters shall provide boundary conditions to ensure that:

O Solidification is complete Requirements for waste form stability are met

  • There are no detectable free standing liquids 6.2.2 Adverse Chemical Reactions During Solid!fication Adverse chemical reactions between waste contaminants and solidification agents may not be noticeable during specimen tests perfomwd to develop solidification parameters, i

To preclude such adverse chemical reactions, the following shall be performed prior to initial solidification of wet radioactive waste :

i NOTEt Performance of this subsection is not required if solidification is to be performed by a vendor and results of such testing performed by the vendor was included in a technical' repon describing the proposed solidification methodology.

a. Prepare large volume (e.g.,1 or 2 gallons) non radioactive mixtures of the waste -

j stream chemicals potentially present (e.g., resin beads, boric acid, acids, bases, i

detergents, decontamination solutions).

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i VIRGINIA VPAP 2104 POWER REVISION 0 i

PAGE 11 OF 16

b. Solidify the mixture.
1. The mixture shall be solidified using solidification pmcedure and parameters prepared for specified waste stream.
2. The solidification shall be performed within an insulated container to simulate -

the restricted heat removable capability of larger containers.

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c. Ensure the mixture solidifies without generating excessive temperatures or gases, f

6.2.3 Sampling, Analysis, and Process Surveillance l

Wet radioactive waste shall be processed strictly in accordence with the approved solidification procedure for the specific waste stream substances to be solidified.

Waste shall be sampled, analyzed, and compared to solidification parameters.

a. Results of sample analysis shall be recorded on waste processing data sheets.

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b. A representative test specimen from at least every tenth batch of each type of waste to be solidified shall be used to verify solidification, if any test specimen fails to solidify:
1. Solidification of the batch under test shall be suspended until such time as:

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  • Additional samples can be obtained
  • Altemative solidification parameters can be determined
  • Subsequent tests verify solidification
2. Solidification of the batch may then be resumed using the altemative solidification parameters determined.
3. A representative test specimen shall be obtained from each subsequent batch of l

the same type of waste and test solidification performed.

4. Collection and testing of representative test specimens from each consecutive batch shall continue until three consecutive initial test specimens demonstrate l

solidification.

c. If necessary, procedures shall be revised to ensure solidification of subsequent l

batches of waste.

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VIRGINIA VPAP 2104 POWER REVISION O PAGE 12 OF 16 O

d. If provisions of the PROCESS CONTROL PROGRAM cannot be satis 6ed, f

suspend shipments of defectively pmcessed or defectively packaged solid radioactive wastes from the site, 6.2.4 Solidification Acceptance Criteria NOTEt The following are general considerations. Specine site disposal criteria must be addressed based on the site to be used.

Procedures for wet radioactive waste solidification shallincorporate the following requirements:

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a. Containers for processed waste shall be filled to at least 85% of capacity. If a container is processed to less than 85% of capacity, it shall not be shipped for disposal prior to approval from the disposal site.

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b. Solid waste that contains liquid shall have as little free standing liquid as is reasonably achievable, but in no case shall the liquid exceed 1% of the volume.

The liquid shall be noncorrosive.

1. If a high integrity container is not used, the maximum free liquid is 0.5% of the.

waste volume.

2. If a high integrity container is used, the maximum free liquid is 1.0% of the waste volume.

6,3 Dewatering and Encapsulation of Filter Elements NOTE: Filter elements are normally mechanical filters with wound fiber cartridges used for removing particulates from liquid systems. "Ihis procedure is only applicable to filter elements which are of the cartridge type.

6.3.1 General Requirements j

a. Spent filter elements removed from systems shall be placed in appropriate storage to await processing and shipment.

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b. Processing of spent filter elements shall be based on waste classification of 61ter.

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VIRGINIA VPAP 2104 POWER REVISION 0 i

PAGE 13 OF 16 NOTE: "Ihe following are general considerations. Specific site disposal criteria must be addressed based on the site to be used.

1. If filter media ls classified as Class A waste and does not contain nuclides with half lives greater than 5 years which have a total specific activity of I pCi/cc or greater,it may be disposed of a: Class A waste.
2. If filter media is classified as Class B or Class C waste (per 10 CFR 61.55), it shall be encapsulated in a solidification media prior to disposal or disposed of in a high integrity container (NRC BTP, C.5 (Waste Form)).

6.3.2 Filter Elements to be Disposed of as Class A Waste

a. Filters should be allowed to drain dry in such a manner that any liquid trapped in i

voids is allowed to drain,

b. Filters shall not be compacted unless they are first allowed to dry essentially free of i

moisture.

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c. If moist filters are to be packaged without compaction:
1. There shall be no indication of moisture on the filter in the form of drops or surface wetness.

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2. Place filters in a container or plastic bag to which absorbent material has been placed to absorb unintentional and incidental amounts ofliquids. The amount of absorbent material should be equal to at least one founh the volume of filter.
d. Ensure documentation indication package contents describes the presence of filters.

s 6.3.3 Fliter Elements to be Disposed of as Class B or C Waste

a. If filters are to be solidified by being encapsulated in a solidification media:
1. Place filters in a suitable container such that filters will be completely surrounded by the solidification media when added. A basket type l

arrangement of thin wire is recommended to hold filters in a fixed geometry.

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3 VIRGINIA VPAP 2104 POWER REVISION O PAGE 14 OF 16 NOTE: The solidification media, including absence of free liquid, must be tested and documented in a manner required for solidification described in subsection 6.2, Solidification of Wet Waste.

2. Fill container with solidification media until filters are completely covered and container is filled to at least 85% of capacity.
3. Place solidified filter container in container appropriate for shipping and disposal at specified disposal site. A high integrity container is recommended to ensure compliance with all requirements,
b. If an encapsulated filteris to be disposed ofin a high integrity container, properly place the container with the encapsulated filter in a high integrity container,
c. If an un encapsulated filter is to be disposed of in a high integrity container:
1. Place filters in container such that filters will be held in a fixed geometry and such that liquids will not be trapped within filters. A basket type arrangement of thin wire is recommended to hold filters provided container's C of C will not be violated.
2. If resin will be added, proceed with resin addition as appropriate.
3. Dewater the container, as applicable.

6.4 Reporting Requirements 6.4.1 - Major Changes to Radioactive Solid Waste Treatment Systems NOTE: Information required by this subsection to be reported to the NRC may be submitted as part of the annual FSAR update.

Major changes to the radioactive solid waste systems:

a. Shall become effective upon review and acceptance by SNSOC.
b. Shall be reponed to the NRC in the Semiannual Radioactive Effluent Release Report for the period in which the evaluation was reviewed by SNSOC. The discussion of each change shall contain:

VIRGINIA VPAP 2104 POWER REVISION 0 g

PAGE 15 OF 16 ig

1. A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR Part 50.59. Such evaluations shall be L

made in accordance with VPAP 3001, Safety Evaluations.

-2. Detailed information sufficient to totally support the tranon for the change without benefit of additional or supplemental information.

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3. A detailed description of equipment, components, and processes involved and interfaces with other plant systems.
4. An evaluation of the change, in quantity of solid waste differing from that previously predicted in the lleense application and amendments to the application.
5. An evaluation of the change, which shows the expected maximum exposures to individual in the UNRES'IRICTED AREA and to the general population that differ from those previously estimated in the license and amendments.
6. A comparison of the predicted releases of radioactive materials,in solid waste, to the actual releases for the period prior to the changes.

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7. An estimate of the exposure to plant openiting personnel as a result of the

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change.

8, Documentation of SNSOC review and approval.

6.4.2 Changes to the Process Control Program (PCP)

Changes to the PCP shall be:

1 a, Documented; reviews shall be retained as Station records. Documentation shall include:

1, Information to support the chanic together with the appropriate analyses or evaluations justifying the changes.

2. A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations.
b. Reviewed and approved by SNSOC and Plant Manager prior to implementation.

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VIRGINIA ypAp.2 30.g POWER REVISION O PAGE 16 OF 16 7.0 RECORDS The following individual / packaged documents and related correspondence completed as a result of the performance or implementation of this procedure are records. Records shall be transmitted to Records Management in accordance with VPAP 1701, Records Management.

PROCESS CONTROL PROGRAM records shall include, but are not limited to:

  • System description of any contractor's temporary processing system. Such a description may be provided in a topical report or other equivalent documentation
  • Appmved solidification system operating procedures
  • Data sheets used to record solidification data, including test specimen data

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