ML20056G009

Rev 2 to Pcp

ML20056G009
Person / Time
Site:	Comanche Peak
Issue date:	03/31/1993
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20056G003	List: ML20056G002 ML20056G005 ML20056G007 ML20056G009
References
PROC-930331, NUDOCS 9309010149
Download: ML20056G009 (44)

Text

CPSES/PCP PROCESS CONTROL PROGRAM -

TU ELECTRIC COMANCHE PEAK STEAM ELECTRIC STATION 1

Revision 2 March 1993

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CPSES/PCP l

TABLE OF CONTENTS  :

i Title Pigg  ;

DEFINITIONS iv  :

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1.0 INTRODUCTION

1-1  ;

1.1 PURPOSE 1-1 1.2 SCOPE 1-1 1.3 PRECAUTIONS / LIMITATIONS 1-2 l

1.4 RESPONSIBILITIES 1-4 1.4.1 Vice President, Nuclear 1-4 l Operations 1.4.2 Station Operations Review 1-4 Committee 1.4.3 Radiation Protection Manager 1-5 1.4.4 Manager, Operations 1-5 l

l 2.0 RADI0 ACTIVE WASTE PROCESSING REQUIREMENTS 2-1 l 2.1 SOLID RADI0 ACTIVE WASTES 2-1 2.1.1 Operability Criteria 2-1 2.1.2 Tests / Inspections 2-2 2.1.3 Basis 2-3 2.2 MAJOR CHANGES TO LIQUID, GASEOUS, & 2-3 )

SOLID RADWASTE TREATMENT SYSTEMS i

3.0 PROGRAM DESCRIPTION 3-1 l 3.1 PROCESSING OF WET RADI0 ACTIVE WASTE 3-1 3.1.1 Processing Methods 3-1 3.1.2 Processing System Description 3-2 l 3.1.3 Prequalification Testing 3-2  !

3.1.4 System Qualification Tests 3-2 3.1.5 Equipment / System Operability 3-3 Requirements I

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l 3.0 PROGRAM DESCRIPTION (continued) 3.1.6 Batch Preprocessing Sampling 3-3 3.1.7 Testing / Inspections 3-4 3.1.8 Acceptance Criteria 3-6 3.1.9 Corrective Actions 3-7 l 3.2 PROCESSING OF DRY ACTIVE WASTE 3-8 i 3.3 MIXED WASTE 3-9 l l l l 4.0 WASTE CLASSIFICATION AND CHARACTERIZATION 4-1 4.1 WASTE CLASSIFICATION 4-1 4.2 WASTE CHARACTERISTICS 4-2 5.0 SPECIFIC WASTE STREAM PROCESSING DESCRIPTIONS 5-1

! 5.1 WET RADIDACTIVE WASTE STREAMS 5-1 5.1.1 Resins 5-1 5.1.2 Cartridge Filters 5-3 5.1.3 Evaporator Concentrates 5-4 5.1.4 Sludge 5-5 5.1.5 Miscellaneous Liquids 5-5 5.2 DRY ACTIVE WASTE 5-6 6.0 ADMINISTRATIVE CONTROLS 6-1 '

6.1 PROCEDURES 6-1 6.2 QUALITY ASSURANCE 6-1 6.3 CHANGES TO THE PROCESS CONTROL PROGRAM 6-2 6.4 DOCUMENTATION 6-2 6.5 TRAINING 6-3

7.0 REFERENCES

7-1 ii M9

CPSES/PCP l

LIST OF FIGURES l

Fioure No. Title Pace 1-1 CPSES Radioactive 1-6 l Management Organizational  !

Responsibilities 5-1 Dewatering Process Flow Chart 5-8 ,

I 5-2 Solidification Process Flow 5-9 i Chart i

5-3 DAW Process Flow Chart 5-10 l

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i CPSES/PCP l DEFINITIONS l l

l Terms in this manual which have a specific definition or meaning are l capitalized (e.g., "0PERABILITY"). Definitions for such capitalized 1 i terms are found in Section 1.0 of the CPSES Technical Specifications, j with the exception of those terms defined below- I I

i PROCESSING  !

i l PRO:ESSING shall be the conversion of radioactive waste into a form 1 l that meets shipping and burial ground requirements. i l

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CPSES/PCP SECTION 1.0 INTR _iDUCTION l

1.1 PURPOSE The purpose of the CPSES Process Control Program (PCP) is to 1 establish a program which provides reasonable assurance that all radioactive wastes PROCESSED at CPSES for disposal at a l

land disposal facility are PROCESSED and packaged such that l applicable Federal regulations, State rules and regulations, I

and disposal site criteria are satisfied. The PCP contains a general description of the methods for controlling the PROCESSING and packaging of radioactive wastes, specific parameters for each method, and the administrative controls and quality assurance required to ensure compliance with I applicable regulations and requirements. This PCP is not I applicable to radioactive wastes transported to an offsite l vendor for PROCESSING.

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1.2 SCOPE I This program defines criteria for the PROCESSING of the following waste streams for disposal at a land disposal facility:

(1) Wet Wastes (a) Resins (bead ar.1 powdered)

(b) Cartridge Filters (c) Evaporator Concentrates (d) Sludge (e) Miscellaneous liquids (f) Activated Carbon, Powdered Carbon, Diatomaceous 2 Earth and other granular or fibrous filter media.

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CPSES/PCP l (2) Dry Act tve Wastes (DAW)

(a) Compactible l (b) Noncompactible l 1

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1.3 PRECAUTIONS / LIMITATIONS 1

Except as specifically described in this document, the following general precautions and limitations apply to the PROCESSING and packaging of all radioactive wastes generated at CPSES for disposal at a land disposal facility. These ,

precautions and limitations shall be included in appropriate f i

station or vendor implementing procedures.

(1) Liquid wastes or wastes containing liquids shall contain 1 as little free standing and non-corrosive liquid as is reasonably achievable.

(2) No package shall be loaded for shipment if it has any indication of a hole or failure. These packages shall either be repacked, or placed in an overpack.  ;

(3) Radioactive waste shall not be packaged for disposal in i cardboard or fiberboard boxes.

(4) Void spaces within the waste and between the waste and 1 its package shall be reduced to the extent practicable.

(5) Only High Integrity Containers (HICs) approved for burial at a land disposal facility shall be utilized for packaging dewatered wastes when waste form stability is required per 10 CFR 61.

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CPSES/PCP }

(6) No objects or materials shall be placed into HICs that '

may cause chemical or physical damage to the container I per the vendor's 10 CFR 61 Topical Report or other '

Federal, State or Burial Facility requirements.  !

(7) Any HIC shall not be stored in such a manner as to cause 2 l

exposure to ultraviolet radiation (sunlight) to exceed ,

the HIC's Certificate of Compliance limitations. f (8) Radioactive waste shall not be packaged for disposal if  !

it is pyrophoric. Pyrophoric materials contained in  !

radioactive waste shall be treated, prepared, and packaged to be nonflammable prior to disposal.  !

(9) Radioactive waste in gaseous form shall not be packaged for disposal.

(10) Radioactive waste containing hazardous material shall be treated to reduce to the maximum extent practicable the potential hazard from the nonradiological materials.

Biological, pathogenic or infectious material is not expected to be produced and will be handled on a case-by-case basis.

(11) Radioactive waste shall not be packaged for disposal if it is readily capable of detonation or of explosive decomposition or reaction at normal pressures and temperatures, or of explosive reaction with water.

(12) Radioactive waste shall not be packaged for disposal if it contains, or is capable of generating quantities of toxic gases, vapors, or fumes harmful to persons transporting, handling or disposing of the waste.

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{ (13) Samples shall be handled and collected in accordance with applicable CPSES procedures and in keeping with ALARA principles.

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(14) PROCESSING evolutions should be periodically monitored for adverse chemical reactions and temperature changes.

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l 1.4 RESPONSIBILITIES i

1.4.1 Vice President of Nuclear Ocerations 2 i

! It is the responsibility of the Vice President of 2 Nuclear Operations, to ensure that the requirements l contained in this manual are achieved during the  ;

PROCESSING of radioactive waste by developing appro;-iate administrative and implementing procedures.

An organizd ional chart showing specific station 2 responsibilities for radioactive waste PROCESSING assigned by the Vice President of Nuclear Operations, is shown on Figure 1-1. The Vice President of Nuclear 2 Operations, is responsible for approving changes to this PROCESS CONTROL PROGRAM, as required by Technical Specification 6.13. l 1.4.2 Station Operations Review Committee l The Station Operations Review Committee (SORC) shall j review the Topical Reports and PROCESS Control Programs of vendors selected to provide waste PROCESSING services or products prior to their initial use at the station. Any subsequent revision to these documents shall also be reviewed by 50RC prior to the initial use of the revision. These reviews shall ensure compatibility with station equipment and operation.

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CPSES/PCP Additionally, 50RC is responsible for reviewing changes to this PCP prior to implementation. 50RC also reviews 2 station administrative procedures for radioactive waste

! PROCESSING activities.

1.4.3 Radiation Protection Manacer

! The Radiation Protection Manager has overall 2 responsibility for the supervision and control of the site-wide Radioactive Waste Program. Included is the direct supervisor of DAW PROCESSING, and Radioactive l Waste Classification Transportation, Storage and Burial.

1.4.4 Manaaer. Operations 2 The Manager, Operations is responsible for coordinating 2 l the review of, and for approving vendor procedures for i onsite wet waste PROCESSING prior to the initial use of j

the documents at the station. He shall also approve I any revisions to these documents prior to their initial use. Review of vendor procedures for waste PROCESSING 2

, shall include technical review by the Radiation l Protection, Chemistry, and Quality Assurance departments. j 1

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4 j Vice Preeldert 1 of Nucleet Operations

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, War *0er Operstlene 4

Radletion Protection i

j Wana0er

, ResponeMe for:

o DAW Conectiorprocessing i

o IDCFRet Weste Desamesson o Storage o Trenaportation

. Shm Operations *W 4 N o Radletion Protection support N

o Wat Weste Processing Except Dewatering of Resan type Wedle Responalbie lor: ResponeMe W, i o FRor/Darnineretteroperetton i

o N and Nonsweaaagical 1

f o Emporator Operation o ResinTransfers

o Wet Weste p% of Rose and Realn tpa Pher Ween j (IE Spaceslen behange heeH 1

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4 Pipise11 CP9EB Redoacahe Weste Mana0emert Rev.2 03/B3 14

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SECTION 2.0 '

RADI0 ACTIVE WASTE PROCESSING REQUIREMENTS 2.1 SOLID RADICACTIVE WASTES 2.1.1 Operability Criteria Radioactive wastes shall be PROCESSED in accordance with this PROCESS CONTROL PROGRAM to meet shipping and j transportation requirements during transit, and disposal site requirements when received at the disposal site.

1 APPLICABILITY: At all times.

COMPENSATORY MEASURES:

(1) With PROCESSING not meeting disposal site and shipping and transportation requirements, suspend shipment of the inadequately PROCESSED wastes and

correct this PROCESS CONTROL PROGRAM, the

$ procedures, and/or the Waste PROCESSING System as necessary to prevent recurrence.

(2) With PROCESSING not performed in accordance with this PROCESS CONTROL PROGRAM, test the improperly PROCESSED waste in each container to ensure that it meets burial ground and shipping requirements and take appropriate administrative action to prevent recurrence.

(3) The provisions of Technical Specifications 3.0.3 and 3.0.4 are not applicable.

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CPSES/PCP l

l 2.1.2 Tests /Inscections Satisfactory PROCESSING of wet radioactive wastes (e.g., filter sludges, spent resins, evaporator bottoms, boric acid solutions, and sodium sulfate solutions) shall be verified in accordance with this PROCESS CONTROL PROGRAM:

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(1) If any test specimen fails to verify satisfactory PROCESSING, the PROCESSING of the batch under test shall be suspended until such time as additional testing can be performed, alternative PROCESSING parameters.can be determined in accordance with this PROCESS CONTROL PROGRAM, and subsequent testing verifies satisfactory-PROCESSING. l PROCESSING of the batch may then be resumed using j the alternative PROCESSING parameters determined by l this PROCESS CONTROL PROGRAM; This PROCESS CONTROL PROGRAM shall be modified as required, as provided in Technical Specification 6.13, to assure satisfactory PROCESSING of subsequent batches of waste; and (2) With the installed equipment incapable of meeting Operability Criterion 2.1.1, above, or declared inoperable, restore the equipment to OPERABLE status or provide for contract capability to PROCESS wastes as necessary to satisfy all applicable transportation and disposal requirements.

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CPSES/PCP 2.1.3 Basis This requirement implements the requirements of 10 CFR t 50.36a and General Design Criterion 60 of Appendix A to l 10 CFR Part 50. The PROCESS parameters included in estcblishing this PROCESS CONTROL PROGRAM may include, but are not limited to, waste type, waste pH, i waste / liquid / solidification agent / catalyst ratios, l waste oil content, principal chemical constituents of l the waste, mixing and curing times, and dewatering l parameters.

! i 2.2 MAJOR CHANGES TO LIOUID. GASEOUS. AND SOLID RADWASTE I TREATMENT SYSTEMS l

t Licensee-initiated major changes to the Radwaste Treatment l Systems (liquid, gaseous, and solid): i 1 m

, (1) Shall be reported to the Commission in the Semiannual 1  ;

Radioactive Effluent Release Report for the period in  ;

which the changes were reviewed by the 50RC. The  !

discussion of each change shall contain:

(a) A Summary of the evaluation that led to the l

determination that the change could be made in l accordance with 10 CFR 50.59; (b) Sufficient detailed information to support the 1 reason for the change without benefit of additional or supplemental information; (c) A detailed description of the equipment, components, and PROCESSES involved and the interfaces with other plant systems; l 1 1

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CPSES/PCP (d) An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or the quantity of solid waste that differ from those previously predicted in the License application and amendments thereto; (e) An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the License application and amendments thereto; (f) A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the change is to be made; (g) An estimate of the exposure to plant operating personnel as a result of the change; and (h) Documentation of the fact that the change was reviewed and found acceptable by the 50RC.

(2) Shall become effective upon review and acceptance by the SORC.

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CPSES/PCP I

SECTION 3.0 .

PROGRAM DESCRIPTION  ;

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3.1 PROCESSING OF WET RADI0 ACTIVE WASTE  :

3.1.1 PROCESSING Methods f

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Wet radicactive waste PROCESSED at CPSES shall be 1 j PROCESSED into a form acceptable for disposal at a licensed facility. PROCESSING shall be performeJ  !

utilizing vendor supplied services and equipment  :

operating in accordance with the vendor's PROCESS Control Program (PCP) and procedures. Solidification 2 shall not be used to achieve structural stability if l

l required per 10 CFR 61 or burial site criteria. i Solidification may be used for Class A unstable waste  !

as a method to meet freestanding water requirements j for waste placed in an HIC. Any vendor selected to provide services or products used for compliance with 10 CFR 61 stability requirements shall have a topical report addressing 10 CFR 61 requirements under review or approved by the NRC, or appropriate burial site licensing agency (e.g., agreement state). The Topical Reports and PCPs of other vendors may be referenced in this PCP even if all vendors are not  ;

actively providing services or products at CPSES.

However, if any other vendor is selected whose documents are not referenced, this document shall be revised to reference them.

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CPSES/PCP 3.1.2 Processino System Descriotion Detailed descriptions of the vendor's PROCESSING ,

system shall be included in the vendor's Topical Report.

3.1.3 Precualification Testino l Prequalification tests shall be performed on each type of wet radioactive waste stream to demonstrate the ability of the PROCESS to produce an acceptable waste form per the requirements of 10 CFR 61. This prequalification testing is performed by the vendor and documented in the vendor's Topical Report, f

3.1.4 System Oualification Tests Prior to the initial solidification of a given waste I stream type using a specified PRGCESS, a test shall be conducted to demonstrate the ability of the PROCESS system to produce an acceptable waste form over the range of critical parameters identified during the prequalification testing. Counds for critical parameters and specific operating limits shall be )

i specified in the vendor's PCP. j These tests shall be performed on laboratory scale or l full scale specimens and shall ensure that the  !

l acceptance criteria specified in Section 3.1.8 are )

achieved.

The dewatering PROCESS shall specify an endpoint for 1 each dewatering evolution so as to assure that the I acceptance criteria specified in Section 3.1.8 are achieved.

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l CPSES/PCP 3.1.5 Ecuipment/ System Ooerability Reauirements Prior to each PROCESSING evolution, the vendor shall demonstrate operability of the PROCESSING equipment which shall include, but not be limited to, the following:

(1) Control Panel l

(2) Instrumentation an'd Controls (3) Mechanical Equipment (4) Electrical Equipment The operability test shall be performed in accordance with station procedures and the vendor's PCP and procedures, j i

3.1.6 Batch Precrocessina Samplina Each batch of waste offered for PROCESSING shall be sampled and analyzed, as appropriate, in accordance with station procedures, the vendor's PCP and the l l '

Topical Report that addresses the 10 CFR 61 stability I requirements. This sampling shall:

(1) Provide necessary data to estimate curie content and to perform the waste classification analysis.

(2) When solidification is involved, sampling 1 shall provide the data necessary to:

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i CPSES/PCP (a) Ensure that waste stream parameters l are witnin the bounds for critical j parameters established in the vendor's $

PCP and 10 CFR 61 Topical Report.  !

N_QH: Results of waste stream chemical 2

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analyses shall be reviewed to ensure l

chemical constituents do not exist which could cause adverse chemical  :

reactions during the solidification PROCESS or react adversely with the solidification container.

l (b) Verify the applicability of pre- 1 established mix ratios.

3.1.7 Testino/ Inspections l

To satisfy the Test / Inspection requirements of Section 1 2.1.2 of this Program, a test or inspection shall be performed for each PROCESSING method to ensure that the applicable acceptance criteria of Section 3.1.8 are achieved. For dewatering this is accomplished by verifying that a specified end point is achieved for I

each dewatering evolution of the actual waste stream.  ;

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For solidification this is accomplished by performing 1 ,

l a solidification of at least one representative test specimen from at least every tenth batch of each type of wet radioactive waste offered for solidification.

The test specimen shall be verified in accordance with the vendor's PCP. The purpose of this testing is to provide assurance that an acceptable waste form is produced using the pre-established formulations provided in the vendor's PCP.

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j CPSES/PCP This test shall be performed on either a laboratory 1 l scale or full scale test specimen which is similar both chemically and physically to the unadjusted waste l stream to be PROCESSED. After the sample is {

collected, it should be conditioned in accordance with j the vendor's PCP. The sample should then be mixed l

l with the binder and additives in ratios determined using the vendor's pre-established formulations. The

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I specimen should be observed to ensure that the applicable acceptance criteria specified in Section 3.1.8 are achieved.

I I If the test results fail to meet the acceptance criteria, the following steps, as per the Compensatory Measures of Section 2.1.1, shall be followed:

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(1) PROCESSING of the batch under test shall be suspended until such time as additional testing can be performed, alternative PROCESSING parameters can be determined, and j subsequent testing verifies satisfactory PROCESSING of the waste. PROCESSING of the batch may then be resumed using the alternative PROCESSING parameters if the alternative parameters will produce a product that falls within the vendor's qualification envelope.

l The vendor's PCP shall provide the method for determining the alternative PROCESSING parameters. Alternative PROCESSING parameters I which fall within the vendor's qualification testing envelope shall be approved by the RP Supervisor, Radioactive Materials Control or his designee and shall be documented in accordance with the vendor's PCP. The vendor's PCP shall be modified as 3-5 Rev. 1 l 12/90

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required to assure adequate PROCESSING of

, subsequent batches of waste. Any changes should be consistent with the conditions,

! limitations, and restrictions addressed in'the a

vendor's 10 CFR 51 Topical Report.

1 (2) If the test results failure is due to a malfunction of the, PROCESSING equipment or the j i PROCESSING equipment is inoperable, the l i equipment shall be returned to an OPERABLE l l

condition or an alternate vendor shall be f obtained to PROCESS waste, as necessary, to l satisfy applicable transportation and disposal j requirements. l j l l

3.1.8 Acceotance Criteria  !

5 (1) Minimum Requirements 1 l

All classes of waste shall satisfy the 1 following acceptance criteria: j (a) Liquid wastes shall be solidified. 1 (b) Solid waste containing liquids shall 1 not contain freestanding liquid in excess of 1% of the internal volume of the container.

(2) Stability Requirements 1 T

i For wastes which require structural stability, I the acceptance criteria are as follows:

(a) The waste shall have structural I stability.

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__t CPSES/PCP (b) Notwithstanding the provisions of 1 Section 3.1.8 (1)(a) and (b), liquid wastes or wastes containing liquid shall be converted into a form in which the freestanding liquid shall not exceed 1% of the internal volume of the container when contained within a HIC, or 0.5% of the volume of the waste for waste PROCESSED to a stable form.

3.1.9 Corrective Actions With PROCESSING not meeting the above acceptance 1 criteria or otherwise not meeting disposal site and shipping and transportation requirements, suspend shipment of the inadequately PROCESSED waste and correct the PROCESS Control Program, the procedures, and/or the waste PROCESSING equipment as necessary to prevent a recurrence. Additionally, an evaluation of similar wastes PROCESSED since the last successful surveillance test shall be conducted to determine the extent of the inadequately PROCESSED waste. If such wastes have been shipped for disposal, the disposal site operator shall be contacted and the problem addressed.

If PROCESSING is not performed in accordance with this 1 PCP, the improperly PROCESSED waste shall be tested to ensure that it meets burial ground and shipping requirements. Appropriate corrective actions shall be taken to prevent recurrence.

Disposition of inadequately PROCESSED wastes will be handled on a case-by-case basis.

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, 3.2 PROCESSING OF DRY ACTIVE WASTE i  !

l Dry Active Waste (DAW) generated at CPSES shall be PROCESSED ,

j by segregation, sorting, and/or compaction. PROCESSING of DAW 4

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is performed to accomplish the following functions:  ;

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{ (1) Package DAW in a fashion acceptable for disposal at a l l licensed disposal facility. l

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(2) Remove constituents not acceptable for disposal as f l

DAW.  ;

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) (3) Minimize volumes of DAW shipped for disposal by: l l (a) removing reuseable and uncontaminated items; 2

' and i (b) reducing shipped volumes by compaction.

4 j Onsite PROCESSING of DAW at CPSES shall be performed in 1

! accordance with approved station procedures or vendor i procedures that have been reviewed by the Radiation Protection Manager. Vendor equipment, personnel and procedures may be l

i used for DAW PROCESSING and packaging.

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! The segregation of uncontaminated waste from DAW is performed i to minimize the volume of DAW shipped for disposal. In order l to provide reasonable assurance that radioactive materials are i- not released as clean waste, the following requirements shall l be included in the segregation program, as discussed in l

Reference 7.5.3

i j (1) Surveys, using equipment and techniques for detecting low levels of radioactivity, shall be_ made of items

! that may be contaminated and are to be disposed of as j clean waste.

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i (2) Surveys may be conducted on individual items using portable survey instruments, such as pancake GM l probes. However, in all cases, final measurements of l j each package (e.g., bag or box) of aggregated waste to }

l be released as clean waste shall be performed to  ;

! ensure that there has not been an accumulation of l

i radioactive material due to the buildup of multiple i

quantities of contamination which were not detectable  :

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i with portable instrumentation. Final measurements l l shall be performed using sensitive detectors, such as scintillation detectors, in a low background area.  ;

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i i 1 5 l 3.3 MIXED WASTE i  !

! Mixed Waste is defined as waste that contains constituents- l

] that satisy the definition of radioactive waste, subject to

.' the Atomic Energy Act, and contains hazardous waste that

) either (1) is listed as hazardous waste in 40 CFR 261, Subpart i D, or (2) causes the waste to exhibit any of the hazardous  ;

l waste characteristics identified in'40 CFR 261, Subpart C. l

} Under current federal law, this waste is subject to dual l regulation by the NRC and EPA, where both agencies have  !

l control over the same waste. Due to the complex regulatory >

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issues that must be resolved pertaining to mixed waste, there I currently are no authorized disposal sites in the United States which are licensed to receive and dispose of mixed

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j hazardous and radioactive waste. .

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i Since there currently is no avenue for disposal of mixed waste, efforts shall be made to reduce the generation of such j waste at CPSES. To accomplish this, station procedures for j chemical control and radioactive waste PROCESSING shall include the following requirements:

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(1) The station chemical control program shall include a I method to identify hazardous constituents of chemicals / chemical products and to evaluate and authorize any usage of these products in areas whrre e mixed waste generation is likely to occur. This ,

evaluation shall consider the substitution of products which are evaluated as non-hazardous per 40 CFR 261. l (2) Radioactive waste PROCESSING procedures shall include l provisions for segregation and removal of non-radioactive hazardous constituents. Upon removal, such constituents would be handled as hazardous waste, as required by the EPA.

(3) Mixed low-level radioactive waste generated at CPSES 1 l

! shall not be shipped for disposal to a low-level .

radioactive waste disposal facility unless specific  :

approval for such disposal is granted by the l appropriate regulatory agencies. Such wastes shall .

be stored until regulatory changes allow for disposal, l or they-are otherwise approved for disposal by appropriate regulatory agencies.

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CPSES/PCP SECTION 4.0 WASTE CLASSIFICATION AND CHARACTERIZATION 4.1 WASTE CLASSIFICATION Radioactive waste generated at CPSES shall be classified as Class A, B, or C in accordance with the requirements of 10 CFR l 61.55, using one or more of the classification methods given in the USNRC's " Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification (May 1983)".

Waste classification shall be performed in accordance with approved station procedures.

The following specific requirements shall be incorporated in the program for sampling and analysis'for waste classification:

(1) Annual analyses shall be performed on representative samples of each waste stream or, alternatively, a PROCESS stream associated with the generation of the waste, for the nuclides listed in Table 1 and Table 2 of 10 CFR 61.55. (Note: Isotopic data from other 1 PWRs may be utilized until annual analyses are performed.)

(2) The results of these annual analyses shall be used to develop isotopic abundances and scaling facators for difficult to measure nuclides (i.e., beta emitters and transuranics) based on correlations between those nuclides and more easily measured gamma emitters.

(3) Gamma spectroscopy or gross radioactivity measurements shall be made for each container of waste PROCESSED for disposal. Calculational methods for determining 4-1 Rev. I 12/90

l CPSES/PCP the total activity in each container shall be developed which use the results of the gamma j spectroscopy or gross activity measurements, and the I percent isotopic abundances and scaling factors from l

the annual analyses. l l l l (4) The classification program shall establish criteria  !

f and include provisions for an increased frequency for  !

the sampling and analysis required by paragraph (1), f l _

above, if the failed fuel fraction changes by a factor  !

of 10. [

(5) Each package of waste shall be clearly labeled as l' Class A, Class B, or Class C.

4.2 WASTE CHARACTERISTICS i i

i Waste PROCESSED for disposal at CPSES shall meet the i applicable characteristics specified in 10 CFR 61.56. Waste  !

classified as Class B, Class C, or Class A waste that will not j l be segregated from Class B and C wastes at the burial l facility, shall be PROCESSED into a stable waste form. This 1 l

shall be accomplished by placement into a HIC, or by j i

solidification using a PROCESS that produces a product which meets the stability requirements of 10 CFR 61.56, per Section 3.1 of this manual. The vendor's topical report shall include documer.'ation or testing which verifies that the HIC or solidified product meets these stability requirements.

Additionally, TU Electric shall comply with Federal or State requirements imposed specifically on an approved HIC or solidification product which limit the type and/or radioactive concentration of the waste to be placed in the approved HIC or solidified product. j 1

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CPSES/PCP SECTION 5.0 SPECIFIC WASTE STREAM PROCESSING DESCRIPTIONS l

5.1 WET RADIOACTIVE WASTE STPEAMS 5.1.1 Resins Radioactive resins may be accumulated from one or more 1 of the following systems:

(1) Chemical and Volume Control System (CVCS)

(2) Spent Fuel Pool Cooling and Purification System (3) Liquid Waste Processing System (including the filter / demineralization system)

(4) Boron Recycle System 1

(5) Boron Thermal Regeneration System I

(6) Steam Generator Blowdown System (SGBS)

(7) Condensate Polishing Demineralizer System (8) Other miscellaneous ion exchange media as generated These resins may be transferred to the vendor's 2 PROCESSING skid or to the Spent Resin Storage Tanks

(SRSTs), if it is necessary to PROCESS secondary condensate polishing powdex resins, they are 1 transferred to the vendor's PROCESSING skid.

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l 5-1 Rev. 2 3/93

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CPSES/PCP j l

Spent resins are PROCESSED for disposal by 2 -

dewatering. The resin is transferred to the liner  !

or HIC where it is PROCESSED utilizing vendor supplied 1 j services, per Section 3.1 of this manual. A representative sample of the resin is collected during ,

transfer for calculations of curie content and waste l l

l classification. Containers are sealed, surveyed, and i l labeled, as appropriate, and stored in a designated '

storage area until they are shipped for disposal.

l 2 A flow chart of a typical dewatering PROCESSING path 2 l is snown on Figure 5-1. I I

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5-2 Rev. 2 M

p_ . _ _ _ . . . _ _ . . . . _ .

CPSES/PCP

.l 5.1.2 Cartridae Filters 2

i

! Cartridge filters will be accumulated from one or more

! of the following systems:

j (1) Chemical and Volume Control System

! (2) Spent Fuel Pool Cooling and Purification i System l (3) Liquid Waste Processing System (including i filter / demineralization system) t j (4) Boron Recycle System  ;

! (5) Boron Recovery System j (6) Steam Generator Slowdown System Miscellaneous  ;

(7) e j Spent filter cartridges are surveyed for dose rate j upon removal from the system. The measured dose rate j i is used to calculate isotopic content using a dose-to-S on f h anu Bs on a culated >

j isotopic content, the waste classification and the j appropriate PROCESS and container to be used for j disposal are determined. Normally, filters are placed 1

! in a liner or HIC and dewatered; however, filters may l

be dried and handled as DAW if conditions allow, or i may be encapsulated. Upon completion of PROCESSING, the containers are sealed, surveyed, and labeled, as f

j appropriate, and stored in a designated storage area j until they are shipped for disposal.

1 1

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I 5-3 Rev. I 12/90. - - - . -

CPSES/PCP l i For purposes of waste classification, isotopic

)

l concentrations of filters dewatered in a liner or HIC

! should be determined as calculated over the volume of l' r

l the cartridge filter itself, rather than averaged over 1 '

i the gross volume of the container. When filters are 1 j encapsulated by solidification in a container, t

i isotopic concentrations may be determined by averaging

! over the volume of the solidified mass. ,

1 i j

1 5.1.3 Evaporator Concentrates i

j Evaporator concentrates result from operation of j evaporators for PROCESSING of liquid wastes (e.g.,

j floor drains) and boron rec ~ ;ery. Normally, liquid i waste streams are PROCESSED through the

! filter /demineralizer system for release to the I

! environment. The liquid waste evaporator is available i

j as an alternate PROCESSING method. The boron recovery l evaporator is used to remove boron from reactor grade l water and the boric acid concentrates are normally recycled. Therefore, volumes of evaporator 1 l

! concentrates from liquid waste PROCESSING and boron l recovery, that must be solidified, are expected to be relatively small. If solidification of evaporator I concentrates is required, they would be transferred i

l from the evapcrators to the Waste Conditionng Tank j where batches are isolated and sampled for isotopic i content and PCP parameters as defined in the vendor's PCP. If necessary, the concentrates are chemically f

j conditioned. The isotopic analysis results are used i

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. 5-4 Rev. I f 12/90

CPSES/PCP to estimate the waste classification, determine the 1 i

proper waste form stability requirements and select the proper container for transportation and disposal.

1 The concentrates then are transferred to tN vendor's PROCESSING skid where they are solidified per Section 3.1 of this manual. Containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal.

A flow chart of a typical solidification PROCESSING 2

.f. path is shown on Figure 5-2.

5.1.4 Sludce 4

Radioactive sludge is accumulated and handled on a case-by-case basis by periodically removing the sludge  !

1 frnm various tanks and sumps located throughout the plant. Each batch of sludge is sampled for isotopic l content and PCP parameters, chemically conditioned, if necessary, and PROCESSED per Section 3.1 of this manual. Containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal.

5.1.5 Hiscellaneous Licuids 1

Miscellaneous liquids generated in the station will be collected and PROCESSED on a case-by-case basis. Such wastes may include decontamination wastes and chemical wastes collected from the Chemistry Labs. Batches of such waste are isolated, sampled for isotopic content 5-5 Rev. 2 3/93

4 CPSES/PCP

~

and PCP parameters, chemically conditioned, if necessary, and transferred to the vendor's PROCESSING 4

skid where they are PROCESSED per Section 3.1 of this manual. Containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal.

5.2 DRY ACTIVE WASTE ,

l Dry Active Waste (DAW) consists of radioactively contaminated 1 or activated waste which contains minimal amounts of liquids.

DAW may be compactible, such as paper, plastic and protective clothing, or non-compactible, such as tools or plant equipment. This waste is segregated by station workers at the point of generation into receptacles designated for i

" clean" or " contaminated" trash. " Clean" receptacles are used to collect trash that potentially is not contaminated.

" Contaminated" containers are used to collect waste that is

~

known or suspected to be contaminated. HoweIr,forpurposes of DAW PROCESSING, all waste collected in Radiation Controlled Areas (i.e., that collected in both the " clean" and

" contaminated" receptacles) is assumed to be contaminated until it is surveyed and proven clean. Bags are collected from the receptacles, surveyed for external dose rate, and 4

taken to a designated sorting area for PROCESSING. Bags below i

a specified dose rate level, per station procedures, may be

opened and the contents surveyed individually for radioactivity. Items found to be not contaminated per station procedures, reusable items, and items not acceptable for disposal as DAW are removed. In general, the contents of bags

~

that are above the specified dose rate level are not surveyed for contamination, but are examined for reusable items and items not acceptable for disposal as DAW. Contaminated items are then disposed of as DAW. Compactible items are collected 1 and may be compressed into approved strong, tight containers.

5-6 Rev. I 12/90

CPSES/PCP l Noncompactible items are placed directly into approved strong, tight containers. Containers are sealed, surveyed, and I labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal or offsite PROCESSING.

i A flow chart of the DAW PROCESSING path is shown on Figure 1

, 5-3.

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i 5-7 Rev. 1 12/90 1 1

l CPSES/PCP iS0uTE wisTE l BRICM

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l ESTIWTE CUISSIFICATICDI 0F sRSTE BRTCH SELECT

. TE FORM W 8FF3EPR! RTE ST818!LITY L!ER FOR RE2JIRED7 OISPOSfL YES o

SELECT T9mMSER smSTE RPMuse! RTE TO CONTRIER HIC FOR FW DISPOSfL PROCESSING 1

NO n

Osintw & is CU RTER smSTE SPECIFIED

%aFINRLIN SfteLE  : PER VE W R'S EW POINT CUIESIFICRTim PCP RCHIEVED7 YES j i

r PEEPfuPE PLRCE IN TRINER FOR lf STORRGE OR SMIP TRTION c DISPOSAL

( FOR OISPOSIL j:

TICURE 5-1 Dewatering Process Flow Chart 5-8 fWE@

l . _

CPSES/PCP l

)

TRfteFIR WETE TO TE sqTE -

IS3 8TE C Mix WRSTE BRTCH kN REPRESENTRTIVE CDPCITim!fG TRpet SfteLE VERIFY DETERMIE NO PROCESS USED YES TE FORM RLTERNRTE SURVEILLMdCE "

WILL PRODUCE -

STietLITY SOLIO!FICATION TEST 7 A STROLE REGJIRED7 PARftETERS l WRSTE FORM i

YES NO 1

I 1

1 NO COBOIT!fW COLLECT TEST SRPPLE TO PDFORM TEST ACCEPTRNCE SAMPLE MEET VD OCR SOLIOlFICATION CRITERIR PCP ACHIEYED7 PRRfDETERS YES l

COICITICM TMNSFER WRSTE TRSTE BRTCH WRSTE TO GEM PRSSES NO

- - . 70 CONTRIIER 800 -

ACCEPTftG  : CCRRECT!vE ACTION VENOC.EET PCP SOLIO!FY PER CRITERIR7 PAMDETERS VDOc S PCP j

PERFORM FINFL CLAS$1FICATICM CF WRSTE l

P PREPMRE PLACE IN CtMTRIIER FOR STORMBE OR SHIP TWesPORTRTION FOR O!SPOSfL j: fee O!SPOWL Figure 5-2 Solidification Process Flow Chart Rev. 1 5-9 12/90

a 4

CPSES/PCP 4 f4 i autif i

t l

1 4 T4 smSTE YES %8CE IN i

• .c;EApr mCE IN. actINT!mLLY -CatspleTCD*

CONT.? RECEPTRCLE j RECEPTRCLE 1

1 aLLECT gmGS C1 LECT ORGS.

s survtv Survtv Ex?teset

' eg. ley 4 &

EliERNAL aPC. f*170 SJtTING 4

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!S DEM0vt 15 nac. ITOst $10 ffC LEVEL 'E5 PEL1E88LE !?twS i e LEVEL >

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&t NETt > SPECIF!w & !*EwS @t 8CCEPT8EI M5 vmLd? ACCEPT 88LE 85 a

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m apetWIus 15 ans7t e ITDS FM C3rstTIGLE7 LOCR713 ApWityCT!v!TY 4

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! 6 WCT 88CPER I W IN Cawtalwa ram l Caf#t FOf e R7f YES rtur Tim misitcpt -

as O! fgg Q[ptgL pse clSPggt j

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1 _ g 4 ,i esenCT unsrE in Carntset staCE m it IN Catare i

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l astP=E e Carat e ran M vis ist FAILLM7 TRfeWP'J1RT10N 8ee DISPolfL 4

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a.aCr tw as stonnet as SNtP osyant CLsm nToe I i.oTirim j FOR Q1SPOSAL A

j i

Figure 5-3 DAW Process Flow Chart

1. 5-10 12/90

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.  % i l

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j CPSES/PCP j

! l t

l  :

j SECTION 6.0 i

ADMINISTRATIVE CONTROLS j i i

)

j 6.1 PROCEDURES l i

l Activities associated with the implementation of the requirements ..

! of this program shall be conducted in accordance with approved

station procedures or vendor documents and procedures that have

! been reviewed and approved per Sections 1.4 and 3.2 of this 4

manual.

1

6.2 OVAllTY ASSURANCE  !

iJ Quality Assurance related activities for radioactive waste PROCESSING are implemented as described in the TU Electric CPSES j

{ Quality Assurance Manual. Such activities include:

(1) Review of documents and procedures affecting the l PROCESSING, packaging, handling, and transportation of l radioactive waste.

l (2) Review of procurement documents or services. j (3) Perform inspections as designated in applicable PROCESSING, j 2

packaging, and shipping procedures. l

) (4) Review applicable vendor QA programs for compliance with i Regulatory and TU Electric requirements.

i (5) Perform audits of the radioactive waste management program

at least once per 24 months.

I j (Note: Technical Specification Administrative Control j 6.5.2.8.i requires that audits of the Process Control

Program and implementing procedures be performed under the

{ cognizance of the Operations Review Committee at least once

, per 24 months.)

6-1

12/90

CPSES/PCP (6) Documentation and retention of documentation of waste PROCESSING packaging and shipping activities.

These activities provide assurance that the final waste form, packaging, labeling, and transportation are in accordance with

! applicable regulations and requirements.

I l 6.3 CHANGES TO THE PROCESS CONTROL PROGRAM r .

Changes to this PCP shall be made in accordance with Technical Specification 6.13 which requires that changes to the PCP:

(1) Shall be documented and records of reviews performed shall be retained for the duration of the unit Operating License.

This documentation shall contain:

(a) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change (s), and (b) A determination that the change will maintain the overall conformance of the waste product to. existing requirements of Federal, State, or other applicable regulations.

l (2) Shall become effective after review and acceptance by SORC, 2 '

and the approval of the.Vice President of Nuclear l Operations.

l 6.4 nnrea4ENTATION Procedures for radioactive waste PROCESSING, packaging, and transportation shall include requirements for maintaining and retaining LLW PROCESSING, packaging, and transportation records.

Detailed records for each container of waste shall be maintained.

6-2 Rev. 2 3/93

1 . _ l

i

! CPSES/PCP 6.5 TRAINING TU Electric and vendor personnel responsible for waste PROCESSING, packaging and transportation activities shall be trained and qualified to ensure that waste PROCESSING is performed in accordance with applicable requirements. Training programs shall establish a schedule for periodic requalification of at least once every two years. TV Electric shall verify the l training of vendor personnel.

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d 6-3 12/90

1 a 1 i CPSES/PCP j i

I i l

! SECTION 7.0 I

i i REFERENCES i

i  !

3 l

i

! 7.1 Code of Federal Regulations: j i i 1

} 7.1.1 Title 10, Parts 20, 61, and 71 I 7.1.2 Title 49, Part 173 I 7.1.3 Title 40, Part 261 1

\ ,

j j 7.2 USNRC, Low-Level Waste Licensing Branch, Technical Position on  ;

j Radioactive Waste Classification, May 1983 1 ,

4 7.3 USNRC, Lcw-Level Waste Licensing Branch, Technical Position on  ;

! Waste Form, May 1983 i

t j 7.4 USNRC, Guidelines for Preparation and Implementation of a Solid Waste Process Con trol Program (Proposed), Draft Revision i l

,l 3, September 1986 i i

t 7.5 USNRC, Office of Inspection and Enforcement, IE Information l Notices:

! 7.5.1 IEN 79-09, " Spill of Radioactively Contaminated Resins" 4

7.5.2 IEN 83-14, "Dewatered Spent Ion Exchange Resin Susceptibility to Exothermic Chemical

{

Reaction" I 7.5.3 IEN 85-92, Surveys of Wastes Before Disposal from Nuclear Reactor Facilities" I 7.5.4 IEN 86-20, " Low-Level Radioactive Waste Scaling i Factors, 10 CFR Part 61" 7.5.5 IEN 87-03, " Segregation of Hazardous and Low-Level Radioactive Wastes" I

1 j 7-1 j 1

i 12/90

l

) CPSES/PCP i

! 7.5.6 IEN 87-07, " Quality Control of Onsite Dewatering / Solidification Operations l By Outside Contractors" ,

7.5.7 IEN 88-08, " Chemical Reactions With Radioactive Waste Solidification Agents"  ;

7.5.8 IEN 89-27, " Limitations on the Use of Waste Forms l

l and High Integrity Containers for the

Disposal of Low-Level Radioactive

! Waste"  !

7.6 CPSES Technical Specifications, Sections 6.5.2.8.i and 6.13  :

i

! i j 7.7 CPSES Station Administrative Procedure STA-709, " Radioactive 1 i l Waste Management Program" 1 i l 7.8 CPSES Radiation Protection Instructions:

i i

4 7.8.1 RPI-203, " Shipment of Radioactive Materials" .

J r j 7.8.2 RPI-204, " DAW Processing" i j 7.8.3 RPI-205, " Liquid Waste Processing" l 1

1 7.8.4 RPI-209, " Radioactive Waste Classification"  !

I i

j 7.8.5 RPI-216 " Waste Steam Sampling and Data Base 1  ;

p Maintenance"

]

k j 7.9 CPSES Chemistry Procedures:

j 7.9.1 CHM-517 " Chemistry Control of Liquid Waste l Systems" 7.10 CPSES Radioactive Waste Systems Operation Procedures: 2 i i j 7.10.1 RWS-302, "NSSS Spent Resin Handling" 2 l

l

} 7.10.2 RWS-304, "SGBD Spent Resin Handling" 2 i

1 1

i 7-2 Rev. 2 j 3/93

.aa ,,.i- - - ,T*-r- .+-, gmy- , w -- ,-.m3 ,3-r,e-+eg.--sy&:ag g---- xy--- ng ya,,

i CPSES/PCP f

1 7.11 Vendor Documents 1

]

l 7.11.1 CNSI-DW-11118-01-NP-A, " Dewatering Topical - Chem- 1 j 2

Nuclear Systems, Inc." 1 l 1 7.11.2 SD-0P-003, " Process Control Program for CNSI Cement 1 l

Solidification Units" l

j 7.11.3 CNSI-2 (4313-01354-01P-A) Rev. 2, " Topical Report I l i for Chem-Nuclear Systems, Inc., Mobile Cement Solidification Systems"

! 1 7.11.4 STD-PCP-03-003, " Westinghouse Hittman Mobile 2

Incontainer Dewatering and Solidification System j Process Control Program" 4

l 7.11.5 STD-R-05-011NP-A, Topical Report - Mobile Incontainer 2 l Dewatering and Solidification System (MDSS)"

4 7.12 TU Electric CPSES Quality Assurance Manual ,

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7-3 Rev. 2 j

wo

PROCESS CONTROL PROGRAM EFFECTIVE PAGE LISTING l

PAGE EFFECTIVE REVISION /DATE i March 1993 i ii December 1990 iii December 1990 <

j iv March 1993  !

i 1-1 Revision 2 1-2 Revision 1 1-3 Revision 2 1-4 Revision 2 1-5 Revision 2 1-6 (Figure 1-1) Revision 2 2-1 March 1993 l 2-2 March 1993 .

2-3 March 1993 1 2-4 March 1993 J 3-1 Revision 2 3-2 Revision 1 3-3 Revision 1 3-4 Revision 2 3-5 Revision 1 3-6 Revision 1  !

3-7 Revision 1 l 3-8 Revision 1 3-9 December 1990 3-10 Revision 1 I

l 4-1 Revision 1  ;

4-2 Revision 1 l l

5-1 Revision 2 5-2 Revisior. 2 j 5-3 Revision 1 l 5-4 Revision 1 5-5 Revision 2 5-6 Revision 1 5-7 Revision 1 5-8 (Figure 5-1) December 1990 5-9 (Figure 5-2) Revision 1 l 5-10 (Figure 5-3) December 1990 6-1 December 1990 6-2 Revision 2 6-3 December 1990 7-1 December 1990 7-2 Revision 2 7-3 Revision 2 EPL-1 March 1993 i