ML20056G916

Semiannual Radioactive Effluent Release Rept Jan-June 1993

ML20056G916
Person / Time
Site:	Callaway
Issue date:	06/30/1993
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-2844, NUDOCS 9309070315
Download: ML20056G916 (52)

Text

i 1901 Chautuu Avenue Past O!! ice Bc3 149 '

St iDurs, Mesoun G31(S

• 31 554-2650 , i n Donald F. SchneII h ul Senior Mce hesident !

ELECTRIC nuees -

• &3 August 31, 1993 4

U.S. Nuclear Regulatory Commission Attn: Document Control Desk >

i Mail Stop P1-137 ,

I Washington, D.C. 20555 i i

Gentlemen: ULNRC-2844 l

DOCKET NUMBER 50-483 CALLAWAY-PLANT l

, SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT  :

The enclosed semiannual radioactive' effluent i j release report for the first half of 1993 is submitted l pursuant to section 6.9.1.7 of the Callaway Plant- ,

l Technical Specifications.

l If there are any questions relating to this information, please contact.us.

I Ve truly you.s, t \

i

, Donald F. Schnell I BFH/plh-1

( Enclosure..

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i 9309070315 DR 930630 Y

ADOCK 05000483 I PDR j$

DOCKET NO. 50-483 Umon .

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l1 CALLAWAY PLANT SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY JUNE 1993

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k SEMIANNUAL RADIOACTIVE EFFLUENT ,

RELEASE REPORT '

b CALLAWAY NUCLEAR PLANT 1 UNION ELECTRIC COMPANY )

LICENSE NPF - 30 ,

i JANUARY - JUNE,1993 a

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TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 SUPPLEMENTAL INFORMATION 2.1 Regulatory Limits 2.2 Maximum Permissible Concentrations 2.3 Average Energy f

2.4 Measurements and Approximations of Total Radioactivity 2.5 Batch Releases 2.6 Abnonnal Releases 3.0

SUMMARY

OF GASEOUS RADIOACTIVE EFFLUENTS 4.0

SUMMARY

OF LIQUID RADIOACTIVE EFFLUENTS 5.0 SOLID WASTE SHIPMENTS 6.0 RELATED INFORMATION 6.1 Unplanned Releases 6.2 Changes to the Process Control Program 6.3 Changes to the Offsite Dose Calculation Manual 6.4 Major Changes to Radwaste Treatment Systems 6.5 12nd Use Census Changes 6.6 Inoperability of Ef0uent Monitoring Instrumentation 6.7 Instances of Liquid Holdup Tanks or Waste Gas Decay Tanks Exceeding Technical Specincation Limits 6.8 Composite Sample Analysis Problems I

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l TABLE OF CONTENTS (continued)  ;

i: l j Table 1 A Semiannual Summation of Gaseous Releases Table IB Semiannual Airbome Continuous and Batch Releases a

j Table 2A Semiannual Summation of Liquid Releases  ;

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,! Table 2B Semiannual Liquid Continuous and Batch Releases  !

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. Table 3 Solid Waste and Irradiated Fuel Shipments

Attachment 1 APA-ZZ-010ll, Process Control Program Manual, Revision 3

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1.0 INTRODUCTION

This Semiannual Radioactive EfDuent Release Repon is submitted in accordance with Section 6.9.1.7 of the Callaway Plant Technical Specifications.

The repon presents a summary of radioactivity mleased in liquid and gaseous effluents, and solid waste shipped from the Callaway Plant during the period from January 1,1993 to June 30, 1993. The infonnation is presented in the format outlined in Appendix B of Regulatory Guide 1.21, Revision 1, June 1974.

All liquid and gaseous effluents discharged during this reponing period were in compliance with federal regulations and the limits of Union Electric Administrative Procedure APA-ZZ-01003, "Offsite Dose Calculation Manual".

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2.0 SUPPLEMENTAL INFORMATION 2.1 Reculatory Limits SpeciDed as follows are the radioactive efDuent control limits applicable to the release of radioactive material in liquid and gaseous ef0uents.

2.1.1 Fission and Activation Gases (Noble Gases)

The dose rate due to radioactive noble gases released in gaseous efDuents from the site to areas at and beyond the site boundary shall be limited to less than or equal to 500 mrem /yr to the total body and less than or equal to 3000 mrem /yr to the skin.

The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the site boundary shall be limited to the following:

a. During any calendar quaner: Less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation and,

b. During any calendar year: Less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

2.1.2 Radiciodine, Tritium, and Paniculates The dose rate due to lodine 131 and 133, Tritium and all radionuclides in paniculate form with half lives greater than eight (8) days released in gaseous

efnuents from the site to areas at and beyond the site boundary shall be limited to j less than or equal to 1500 mrem /yr to any organ.

l The dose to a member of the public from lodine 131 and 133, Tritium, and all J radionuclides in paniculate form with half-lives greater than eight (8) days in gaseous efDuents released to areas at and beyond the site boundary shall be limited to the following:

a. During any calendar quaner: Less than or equal to 7.5 mrem to any organ and,

b. During any calendar year: less than or equal to 15 mrem to any organ.

2.1.3 Liquid Effluents The concentration of radioactive material released in liquid effluents to unrestricted areas shall be limited to the concentrations specified in 10 CFR Pan 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentation shall be limited to 2.0E-04 microcuries/ml total activity.

The dose or dose com nitment to an Individual from radioactive materials in liquid effluents released to tmrestricted areas shall be limited:

a. During any calendar quaner to less than or equal to 1.5 mrem to the total body and less than or equal to 5 mrem to any organ, and

b. During any calendar year to less than or equal to 3 mrem to the whole body and to less than or equal to 10 mrem to any organ.

2.1.4 Uranium Fuel Cycle Sources The annual (calendar year) dose or dose commitment to any member of the public j due to releases of mdioactivity and to radiation from uranium fuel cycle sources I shall be limited to less than or equal to 25 mrem to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem.

2.2 Maximum Permissible Concentrations 2.2.1 The maximum permissible concentations specified in 10 CFR Pan 20, Appendix B, Table II, Column 2 are used to calculate release rates and permissible concentrations ofliquid radioactive ef0uents at the unrestricted area boundary. A value of 2.0E-4 microcuries/ml is used as the MPC for dissolved and entrained noble gases in liquid effluents.

2.2.2 For gaseous effluents, maximum permissible concentrations are not directly used in release rate calculations since applicable limits are stated in terms of dose rate at the unrestricted area boundary.

2.3 Average Energy This is not applicable to the Callaway Plant's ndiological effluent control limits.

2.4 Measurements and Arproximations of Total Radioactivity The quantity of mdioactivity released in liquid and gaseous effluents was detennined by sampling and radiological analysis of effluents in accordance with the requirements of Table 9.3-A and Table 9.6-A of APA-ZZ-01003, Offsite Dose Calculation Manual.

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Gamma spectroscopy was the primary analysis technique used to determine the adionuclide composition and concentration of liquid and gaseous effluents. Composite l samples were analyzed for Sr-89, Sr-90, and Fe-55 by an independent laboratory.

Tritium and Gross Alpha were measured for both liquid and gaseous effluents using .

liquid scintillation countmg and gas flow proportional counting techmques, respectively.  ;

1 The total radioactivity in effluent releases was determined from the measured I

concentration of each radionuclide present and the total effluent volume discharged.

2.5 Batch Releases j l 2.5.1 Liquid ,

i Number of batch releases: 123

, Total time period for batch releases: 78,247 minutes t l Maximum time period for a batch release: 3209 minutes j Average time period for batch releases: 636 minutes l Minimum time period for a batch release: 89 minutes  ;

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Average stream flow during periods of effluent release into a flowing stream: 146,921 cfs* l l "Ref: Letter, United States Depanment of the Interior-Geological  ;

Survey-Missouri, dated July 2,1993.  !

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Number of batch releases: 7 Total time period for batch releases: 6580 minutes l

Maximum time period for a batch release: 703 minutes Average time penod for batch releases: 140 minutes  ;

l Mimmum time peno,1 for a batch release: 41 mimites 2.6 Abnormal Releases l

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Number of releases: 0 l Total Activity released: 0 2.6.2 Gaseous  ;

! 4 2.6.2.1 Number of releases: 2 i

2.6.2.2 Total Activity released: 1.4E-03 Ci ,

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SUMMARY

OF GASEOUS RADIOACTIVE EFFLUENTS j l 3.1 The quantity of radioactive material released in gaseous effluents is summarized in Table i l 1 A and IB. For this reponing period no gaseous effluents were considered elevated }

releases.

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SUMMARY

OF LIOUID RADIOACTIVE EFFLUENTS i

l 4.1 The quantity of radioactive material released in liquid effluents is summarized in Table  :

2A and 2B.  ;

l 5.0 SOLID WASTES 5.1 The quantity of radioactive material released in shipments of solid waste and irradiated fuel during the reponing period is summarized in Table 3. The activity and fractional j abundance of each nuclide was detennined for each waste type by an independent l laboratory based upon radiochemical analysis. De activity of each nuclide listed in ,

Table 3 was determined as the product of the fractional abundance and the total activity shipped. Those nuclides which comprise at least 1 % of the total activity for a particular j waste type are presented in Table 3. l 6.0 RELATED INFORMATION l' l

l 6.1 Unnlanned Releases I

l Unplanned releases are inadvertent or accidental releases of radioactive material, or .{

releases of radioactive material via normal pathways without a release permit or proper l authorization, or without proper sampling and analysis, or releases which are conducted  ;

in such a manner as to result in significant deviation from the requirements of the release l permit. l l

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i There were two events during this reponing period, involving the release of radioactive material to the turbine building from an abnomial release path during routine maintenance of the condenser air removal system. These releases resulted in an  ;

insigni5 cant offsite dose; the health and safety of the public was not compromised, i

The releases occurred February 17,1993, and April 29,1993, during routine maintenance on the condenser air removal system. The filtration dampers were open for >

630 minutes and 529 minutes respectfully. This resulted in a radioactive release ofless than 100 CFM from the condenser air mmoval system to the turbine building atmosphere. The condenser air removal system was sampled, and dose and dose rate calculations were performed to determine offsite impacts before maintenance activities were staned. During the maintenance activities additional air samples were taken at the point where the condenser air removal system discharged to the turbine building 3 atmosphere. After the maintenance activities wem completed the data from the air samples we:e evaluated and the Effluents Management System (EMS) data bases wM ,

updated with the activity released. l The activity released and the offsite doses at the site boundary from each occurrence were:

Febmarv 17.1993 Antil 29.1993 ACTIVITY (Cil H-3 1.21E-05 I-131 - 3.23E-09 7.16E-08 I I-133 2.51E-09 2.82E-08  !

Xe-135 5.66E-05 1.18E-04 Xe-133 1.70E-04 2.58E-04 Kr-85m 2.44E-04 2.15E-05 POSE AT SITE BOUNDARY Gamma Air Dose (mrad) 9.51E-08 1.08E-08 ,

Beta Air Dose (mmd) 1.76E-07 1.90E-08 Total Body Dose Rate (mmm/yr) 4.51E-06 9.83E-06 Skin Dose Rate (mrem /yr) 1.02E-05 2.21E-05 )

Maximum Organ Dose 1.39E-06 5.41E-07 These values are a small fraction of the Technical Specification Limits.

The activity released is reported in Table 1 A and IB for this mporting period and will be l included in the annual dose calculations. i 6

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6.2 Chances to the Process Control Pmeram Revision 3 to APA-ZZ-01011, PROCESS CONTROL PROGRAM MANUAL (PCP),

was reviewed and approved by the Onsite Review Committee. Approval by the Manager, Callaway Plant was obtained on April 22,1993.

This revision incorporated the changes in procedure reference to 10CFR Part 20 to relate to the new 10CFR Pan 20 that was implemented at the Callaway Plant January 1,1993.

Changes made in this revision do not alter or otherwise reduce the overall conformance

( of packaged and/or solidified was*e products to existing requirements of federal, state, or other applicable regulations.

A copy of Revision 3 of Administrative Procedure APA-ZZ-010ll is included as Attachment 1.

6.3 Chances To The Offsite Dose Calculation Manual There were no changes made to Administrative Procedure APA-ZZ-01003, "Offsite Dose Calculation Ma lual", during the reponing period.

6.4 Maior Chances to Radwaste Treatment Systems Dudng the reponing period, ther were no changes which could be considered a major change to a Liquid, Gaseous, or Solid Radwaste Treatment System.

6.5 Land Use Census Chances Them were no changes in critical receptor locations for dose calculations during the reponing period.

6.6 Inocerability of Ef0uent Monitorine Instmmentation All ef0uent monitoring instrumentation was OPERABLE within the limits specined by APA-ZZ-01003 Sections 9.1.1 and 9.2.1 during the reponing period.

6.7 Instances of Liauid Holduo Tanks or Waste Gas Decay Tanks Exceedine TechnicM Specification Limits All liquid tanks and waste gas decay tanks were within the limits of SpeciGcations 3.11.1.4 and 3.11.2.6 during the reponing period.

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l 6.8 Comnosite Sample Analysis Problems During this reponing period it was determined the monthly and quanerly liquid effluent composite sample results had not been corrected for the preservative being added to the sample.

The monthly gross alpha analytical results reponed were calculated to be in error by 1.5 %. A review of the gross alpha release data from January 1990 to April 1993 showed that if the 1.5 % error was included, the alpha curies discharged would not have exceeded any regulatory limits. This error is also bounded by the estimated total error reponed in the semiannual radioactive effluent release repons.

The vendor laboratory calculated that the Strontium 89/90 results were under estimated by 16 to 18 percent due to not including the preservative in the analysis calculations. In review of the composite samples results for the past three years only one occurrence was noted where a positive Strontium 89/90 activity was reponed. The vendor laboratory reponed a Strontium 89 activity of 4.0E-10 pCi/ml with an error of 1.79E-10 pCi/ml and Strontium 90 activity of 4.21E-10 pCi/ml with an error of 1.57E-10 pCi/ml, for the fourth quaner 1990. If the 18% error was applied to the sample results, the results would be just outside of the reponed sample error. This increased activity would have resulted in an increase ofless than 1 percent in the maximum offsite dose reponed in the 1990 semiannual radioactive effluent release repon.

For the Strontium 89/90 sample results that were reponed less than LLD, it has been determined that if the 18% error was included in the LLD calculation the resultant LLD would not have met the required LLD listed in APA-ZZ-001003, Callaway Plant Offsite Dose Calculation Manual.

The vendor laboratory did determine that Iron 55 activities reponed were properly corrected for the preservative added to the sample.

Corrective actions taken to prevent recurrence of this problem were: 1) plant procedures were revised to take into account the addition of preservative to the liquid composite samples, 2) a new specification was written which requires the vendor to determine the amount of Strontium and Iron carriers that are present in the sample before analysis and -

j to correct the sample for dilution, and 3) the vendor laboratory was added to the Quality J Suppliers List (QSL) and is audited on a periodical basis to insure compliance with regulatory and specification requirements.

This event had no adverse radiological consequences and the health and safety of the public was not compromised.

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TABLE 1 A SEMIANNUAL SUMMATION OF GASEOUS RELEASES ,

ALL AIRBORNE EFFLUENTS i l

QUARTERS 1 AND 2,1993 l l

l FIRST SECOND EST TOTAL' l TYPE OF EFFLUENT UNITS OUARTER QUARTER ERROR %  !

A. FISSION AND ACTIVATION GASES l 20

, 1. TOTAL RELEASE CURIES 8.83E+ 01 1.79E+ 02 l

2. AVERAGE RELEASE RATE FOR PERIOD pCl/SEC 1.14E+ 01 2.28E+01

3. PERCENT OF TECH SPEC LIMIT  % N/A N/A l

B. RADIOIODINES

1. TOTAL IODINE-131 CURIES 5.80E-06 1.08E-04 23

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2. AVERAGE RELEASE RATE FOR PERIOD pCi/SEC 7.45E-07 1.3BE-05 l

3. PERCENT OF TECH SPEC LIMIT  % N/A N/A l

C. PARTICULATES

1. PARTICULATE (HALF-LIVES > 8 DAYS) CURIES 1.95E-04 8.58E-04 30

2. AVERAGE RELEASE RATE FOR PERIOD vCi/SEC 2.51 E-05 1.09E-04 1

3. PERCENT OF TECH SPEC LIMIT  % N/A N!A

4. GROSS ALPHA RADIOACTIVITY CURIES 1.04E-06 1.50E-06 i

i D. TRITIUM

1. TOTAL RELEASE CURIES 1.95E+01 1.71E+ 01 14

2. AVERAGE RELEASE RATE FOR PERIOD vCi/SEC 2.51E+00 2.18E+00 1

3. PERCENT OF TECH SPEC LIMIT  % N/A N/A 1 Callaway Plant Safety Analysis Calculation 87-063-00 l

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TABLE 1B SEMIANNUAL AIRBORNE CONTINUOUS AND BATCH RELEASES GROUND LEVEL RELEASES FISSION GASES, IODINES, AND PARTICULATES QUARTERS 1 AND 2,1993 CONTINUOUS RELEASES BATCH RELEASES FIRST ISECOND FIRST SECOND NUCLIDE UNIT OUARTER l QUARTER QUARTER QUARTER

1. FISSION G ASES KR-85M CURIES 4.35E-01 1.85E+00 0.00E+00 2.15E-05 KR-85 CURIES 0.00E+00 0.00E+00 1.07E+00 B.63E-02 KR-88 CURIES 0.00E+00 1.51E+00 0.00E+00 0.00E+00 XE-131M CURIES 1.62E-01 1.42E-01 8.32E-02 2.01E-01 XE-133 CURIES 6.87E+01 1.37E+02 3.60E+00 9.80E+00 XE-133M CURIES 2.6BE-02 4.58E-01 2.04E-02 5.87E-02 XE-135 CURIES 1.40E+ 01 2.78E+01 6.95E-03 2.90E-02 AR-41 CURIES 1.31E-01 3.98E-02 9.31E-02 6.11 E-02 TOTAL FOR PERIOD CURIES 8.35E+01 1.69E+02 4.87E+00 1.02E+01

2. IODINES l-131 CURIES 5.79E-06 1.08E-04 6.33E-09 1.43E-07 l-132 CURIES 0.00E+00 0.00E+00 0.00E+00 2.74E-08 l-133 CURIES 1.81E-06 1.01E-04 2.51 E-09 1.02E-f"'

l-135 CURIES 0.00E+00 0.00E+00 0.00E+ 00 1.76E-08 TOTAL FOR PERIOD CURIES 7.60E-06 2.09E-04 8.84E-09 2.90E-07

3. PARTICULATES RB-88 CURIES 1.95E-04 6.43E-04 5.0SE-08 4.05E-07 SR-89 CURIES 0.00E+00 8.44E-07 0.00E+00 1.06E-08 CS-138 CURIES 0.00E+00 2.14E-04 0.00E+00 0.00E+00 BR-82 CURIES 2.27E-08 0.00E+00 0.00E+00 0.00E+00 G ALPHA CURIES 1.04E-06 1.50E-06 0.00E+00 2.66E-09 TOTAL FOR PERIOD CURIES 1.96E-04 8.59E-04 5.08E-08 4.18E-07

4. TRITIUM H-3 CUR!ES 1.92E+01 1.67E+ 01 3.21 E-01 4.18E-01 l PAGE 1 OF 1

l TABLE 2A

SEM1 ANNUAL SUMMATION OF LIQUID RELEASES ALL UQUID EFFLUENTS OUARTERS 1 AND 2,1993 l

l FIRST SECOND EST TOTAL' TYPE OF EFFLUENT UNITS OUARTER QUARTER ERROR %

l A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM GASES ALPHA) CURIES 5.32E-03 1.39E-02 20

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD vCl/ML 6.51E-09 1.97E-08 i

j 3. PERCENT OF APPLICABLE LIMIT  % N/A N/A B. TRITIUM

1. TOTAL RELEASE CURIES 3.45E+02 5.33E+02 14

2. AVERAGE DILUTED CONCENTRATION J DURING PERIOD pCi/ML 4.22E-04 7.55E-04 l

3. PERCENT OF APPLICABLE LIMIT  % N/A N/A C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE CURIES 7.06E-03 1.62E-01 27 l

2. AVERAGE DlLUTED CONCENTRATION DURING PERIOD vCi/ML 8.64E-09 2.30E-07 ,

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D. GROSS ALPHA RADIOACTIVITY  !

1. TOTAL RELEASE CURIES 2.32E-04 2.58E-04 29 l

E. WASTE VOL RELEASED (PRE-DILUTION) GAL 5.88E+ 06 5.58E+06 10 F. VOLUME OF DILUTION WATER USED GAL 2.10E+08 1.81 E+D8 10

$ Callaway Plant Safety Analysis Calculation 87-063-00 PAGE 1 OF 1 l

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TABLE 2B SEMIANNUAL LIQUID CONTINUOUS AND BATCH RELEASES TOTALS FOR EACH NUCLIDE RELEASED OUARTERS 1 AND 2,1993 CONTINUOUS RELEASES BATCH RELEASES FIRST SECOND FIRST SECOND NUCLIDE UNITS OUARTER QUARTER QUARTER QUARTER

1. ALL NUCLIDES H-3 CURIES 0.00E+00 0.00E+ 00 3.45E+02 5.33E+02 MN-54 CURIES 0.00E+00 0.00E+ 00 3.61 E-05 2.55E-05 FE-55 CURIES 0.00E+00 0.00E+00 4.38E-03 3.59E-03 CO-58 CURIES 0.00E+00 0.00E+00 6.47E-05 1.99E-05 CO-60 CURIES 0.00E+00 0.00E+00 6.19E-04 4.82E-04 SR-89 CURIES 0.00E+00 0.00E+00 0.00E+00 8.74E-03 SR-90 CURIES 0.00E+00 0.00E+ 00 0.00E+00 5.66E-04 SB-124 CURIES 0.00E-00 0.00E+00 0.00E+00 6.93E-06 SB-12d CURIES 0.00E+00 0.00E+ 00 1.21 E-05 7.52E-06 CS-134 CURIES 0.00E+00 0.00E+00 3.26E-05 1.65E-04 CS-137 CURIES 0.00E+00 0.00E+ 00 1.37E-04 2.75E-04 CE-141 CURIES 0.00E+00 0.00E+00 4.47E-06 0.00E+00 CE-144 CURIES 0.00E+00 0.00Ei00 2.98E-05 0.00E+00 1-131 CURIES 0.00E+00 0.00E+ 00 0.00E+ 00 3.83E-06 XE-131M CURIES 0.00E+00 0.00E+ 00 0.00E+00 9.10E-04 XE-133 CURIES 0.00E+00 0.00E+00 7.03E-03 1.60E-01 XE-133M CURlES 0.00E+00 0.00E+00 2.01E-05 1.25E-03 l, XE-135 CURIES 0.00E+00 0.00E+00 1.30E-05 3.54E-04 W G ALPHA CURIES 0.00E+00 0.00E+00 2.32E-04 2.5BE-04 TOTALS FOR PERIOD CURIES 0.00E+00 0.00E+ 00 3.45E+ 02 5.33E+02 PAGE 1 OF 1

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SOLID WASTE & IRRADIATED FUEL SHIPMEbrTS f OUARTERS 1 & 2. 1992 A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (DOES NOT INCLUDE IRRADIATED FUEL)

TYPE OF WASTE 6-MONTH EST. TOTAL PERIOD. ERROR ("A

a. Spent resins, filter sludges 0.00 m2 evaporator bottoms, etc. 0.00E+0 Ci i 25 %

b. Dry compressible waste, 3.68 m3 contaminated equipment, etc. 1.38E-2 Ci 1 25 %

Percent Abundance Curies

, Co-50 55.23 % 7.62E-3 Ni-63 26.52 % 3.66E-3 Mn-54 12.37 % 1.71E-3 Fe-55 2.26 % 3.14E-4 Sb-125 2.09 % 2.88E-4

[ Co-58 1.48 % 2.04E-4

c. Irradiated components, control 0 m5 rods, etc. O Ci

d. Other 0 m'

{ 0 Ci S_olid Waste Disposition Number of Mode of Class of Solid Type of

( Shinments Transportation Destination Waste Shinned Container 1 Truck Oak Ridge, TN A LSA (SEG)

Solidification Agent N/A

( B. IRRADIATED FUEL SHIPMENTS (DISPOSITION)

Number of Shinments Mode of Transportation Destination 0 NA NA

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APA-ZZ-01011 Revision 3 April 3, 1993 NUCLEAR FUNCTION ADMINISTRATIVE PROCEDURE APA-ZZ-01011 PROCESS CONTROL PROGRAM MANUAL" (PCP)

RESPONSIBLE DEPARTMENT h_b1s4 e.w w M c.kuao. tb I

PREPARED BY u o u-A e s DATE b 93 APPROVED BY [ cid DATE l/ ,22-73 i / -

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. eT oo, I ISSUED o Ch f DATE ISSUED 4 -% -93 APR 2 61993 AGCOUNTABLE HOLDER la l This procedure contains the following:

Pages 1 through 25 Attachments 1 through 2 Tables through Figures through Appendices through Checkoff Lists through J

f APA-ZZ-01011 Rev. 3 TABLE OF CONTENTS Section Pace Number

1.0 Purpose and Scope

1 2.0 Definitions 1 3.0 Administrative Controls .

2 3.1 Major Changes to Solid Radwaste Treatment Systems 2 3.2 Changes to the Process Control Program 3 3.3 Report of Solid Waste Released from the Plant 4 3.4 Reporting of Mishaps Involving Waste Stabilization and High Integrity containers 5 4.0 10CFR61 Compliance Methodology 7 5.0 Process Controls 8 5.1 Administrative Requirements 8 5.2 Collection and Analysis of Samples 9

( 5.2.1 5.2.2 General Requirements PCP Archive (Radioactive) Samples 9

10 5.2.3 Collection of Samples 11 5.2.4 Chemical Analysis of Waste Samples 13 5.2.5 Radiochemical Analysis of Waste Samples 13 5.3 Test Solidification and Acceptance Criteria 14

( 5.3.1 Waste Conditioning 14

[ 5.3.2 Test Solidification 14 5.3.3 Test Solidification Acceptability 15 6.0 Radioactive Waste Processing Using Installed 16 Liquid Volume Reduction System 6.1 General Requirements 16 6.2 Waste Sampling 17 6.3 Process Controls 17 7.0 Radioactive Waste Processing Using 18

( Bulk Disposal Methods 7.1 Radioactive Waste Processing Using 18 Contracted Vendor Services 7.1.1 General Requirements 18

[ 7.1.2 Control of Vendor Procedures and Documentation 20 7.2 Radioactive Waste Processing Using 21

[ In-House Bulk Disposal Options

[ 7.2.1 General Requirements 21 7.2.2 Waste Sampling 22 7.2.3 Packaging of Spent Filter Cartridges 23

( 7.2.4 Packaging of Spent Ion Exchange Bead Resin 24 8.0 References 25 f

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APA-ZZ-01011 Rev. 3 i TABLE OF CONTENTS Section Page Number Attachment 1 - Topical Reports Applicable to Callaway 1 page Process Control Program (PCP)

Attachment 2 - High Integrity Containers (HICS) 1 page I Authorized for Use at Callaway I

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APA-ZZ-01011 Rev. 3 RECORU OF REVISIONS Revision Number Revision Date Reason for Revision Process Control Procram (PCP)

Rev. O October 1983 Initial issue.

Rev. 1 February 1984 Incorporation of NRC review comments.

Rev. 2 December 1984 Revised to generic, non-procedural format; updating of formulations for solidification of wastes.

Rev. 3 March 1985 Added solidification 4

nomogram for concentrated borated wastes and renumbered l attachments; clarified sample I analysis documentation requirements. -

Rev. 4 August 1985 Incorporated Class A " unstable" resin solidification formulation (based upon in-plant testing).

Rev. 5 March 1986 Update solidification formulation nomograms; revised coversheet and

" preface" portion of document; removed section dealing with' solidification agents from document; made formulations proprietary documents.

Rev. 6 April 1986 Incorporated section dealing with control of vendor services for packaging of solid radioactive wastes; revised purpose to agree more closely with wording shown in Technical Specification definition for

" Process Control Program" Rev. 7 June 1987 Revised section dealing with contracted vendor services to clarify type of services involved.

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f 'APA-ZZ-01011 Rev. 3 Rev. 8 September 1987 Revised recorded boundary conditions / ratios for batch solidification; revised acceptance criteria for structural stability incor-

. porated wording regarding full scale test solidi-fication; minor text wording changes, j Rev. 9 December 1988 Revised format to reflect i actual use of document (program vice procedure);

incorporated new section(s) dealing with bulk disposal of wet radioactive vaste; revised solidification .

formula (s) in-stalled system solidification based upon vendor recommendation.

f APA-ZZ-01011 Rev. O July 1989 Incorporation of Tech. <

Spec. Amendment OL #1087.

l Formal controls on PCP placed under Administrative Procedure.

Added Commitment Tracking System Numbers (CTSNs).

Rev. 1 August 1991 Removal of installed

, solidification system (STOCK Solidification System) from text.

(System being retired under CMP-1045 and no longer used).

Incorporated new section detailing Administrative Corstrols regarding reporting of major changes to solid radwaste systems and changes to the Process Control Program (PCP) Manual. Added new attachment detailing which vendor topical report / systems approved for use and new attachment listing High Integrity Containers (HICs) authorized for use at Callaway.

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APA-ZZ-01011 Rev. 3 Rev 2 January 1992 Incorporation of new process controls text detailing process controls applicable to use of new installed liquid volume reduction system (RVR) for processing liquid wastes; added new Administrative Controls Sections detailing " Reporting of Mishaps" and "PCP Archive Sample Requirements" per requirements found in NRC BTP on Waste Form; added several new commitments to PCP; Minor text wording changes.

Rev 3 April 1993 Changed reference to 10CFR20.

Added commitment 4160.

Removed commitment 2731.

I Minor text wording changes.

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APA-ZZ-01011 Rev. 3 I PROCESS CONTROL PROGRAM MANUAL (PCP)

I 1.0 PURPOSE AND SCOPE 4166 1.1 The purpose of the Process control I 4700 Program (PCP) is to provido reasonable 41638 assurance and documentation that the 4160 processing and packaging of solid ra-dioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance I with 10CFR Parts 20, 61 and 71, State regulations, burial ground require-g ments, and other requirements govern-l .

ing the disposal of the radioactive wastes.

2791 1.2 The PCP contains the sampling, tests, I analyses, determinations and formula-tions by which waste classification, solidification and/or dewatering of I radioactive wastes from liquid systems is assured. The PCP is implemented by Radwaste operating procedures.

I 2.0 DEFINITIONS 2.1 Solidification - The conversion.of wet I- wastes inte a form that meets shipping and burial ground requirements.

2.2 Waste Classification - The determina-tion of waste class as outlined in 10CFR61 by radionuclide isotopic anal-ysis and/or correlation with measured 1 nuclides.

2.3 Dewaterina - The process of removing I water from a bed of wet solid waste.

Dewatering processes may be utilized to prepare wet solid waste for ship-I ment without solidification using ce-ment or other chemical agents. Dewa-tered wastes must meet NRC and burial site conditions on maximum drainable I liquid content.

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[ APA-ZZ-01011 Rev. 3

[ 1.4 Batch - A specified quantity of liquid i vastes/ sludges requiring solidifica-tion or dewatering (ie., the amount of waste content within a tank, or, the

( amount of waste content within two or more tanks if the contents of the tanks are to be solidified or dewa-tered together within a common con-tainer) any portion of which would have the same physical and chemical characteristics as the'whole. If new material is added to a tank's contents which is currently being processed, a new batch is created and further sam-pling must be performed prior to so-lidification or dewatering.

3.0 ADMINISTRATIVE CONTROLS 3.1 MAJOR CHANGES TO SOLID RADWASTE TREAT-MENT SYSTEMS NOTE Union Electric Co. may choose to submit the in-formation called for in this section as part of the annual FSAR update.

3.1.1 Licensee-initiated major changes to the Solid Radwaste Treatment System:

3.1.1.1

( Shall be reported to the commission in the Semiannual Radioactive Effluent Release Report for the period in which

[ the evaluation was reviewed by the L

On-Site Review Committee (ORC) . The discussion of each change shall con-tain:

[

3.1.1.1.1 A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59.

[ 3.1.1.1.2 Sufficient detailed information to to-t tally support the reason for the.

change without benefit of additional or supplemental information;

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l APA-ZZ-01011 Rev. 3 3.1.1.1.3 A detailc6 description of the equip-ment, components and processes in-volved and the interfaces with other plant systems; 3.1.1.1.4 An evaluation of the change, which shows the predicted releases of ra-dioactive materials in and/or quantity of solid waste that differ from those previously predicted in the License application and amendments thereto; 3.1.1.1.5 An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC in the UN-RESTRICTED AREA and to the general population that differ from those pre-viously estimated in the License app-lication and amendments thereto; 3.1.1.1.6 A comparison of the predicted releases of racioactive materials in solid waste, to the actual releases for the period prior to when the changes are to be made; 3.1.1.1.7 An estimate of the exposure to plant operating personnel as a result of the change; and 3.1.1.1.8 Documentation of the fact that the change was reviewed and found accepta-ble by the ORC.

2781 3.1.1.2 Shall become effective upon review and approval by the ORC in accordance with Technical Specification 6.5.3.1.

2814 3.2 CHANGES TO THE PROCESS CONTROL PROGRAM 20174 (PCP) 3.2.1 All changes to the PCP shall be com-pleted pursuant to Technical Specifi-cation 6.13 and approved as per APA-ZZ-00101, Preparation, Review, Appro-val and Control of Procedures.

3.2.2 Documentation'of the change (s) shall include:

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APA-ZZ-01011 Rev. 3 3.2.2.1 Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change (s); and 3.2.2.2 A determination that the change will maintain the overall conformance of the solidified waste product to exist-ing requirements of federal, state, or other applicable regulations.

3.2.3 Cross Disciplinary Review for each re-vision of the PCP nust include as a minimum Radwaste and Quality Assu-rance.

3.2.4 All changes shall be reviewed and app-roved by the ORC and approved by the Manager, Callaway Plant PRIOR to in-plementation.

3.3 REPORT OF SOLID UASTE RELEASED FROM THE PLANT 2805 3.3.1 The Semiannual Radioactive Effluent Release Report covering the operation of Callaway Plant during the previous 6 months of operation shall include a summary of the quantities of solid ra-dioactive waste released from the

. plant as outlined in Regulatory Guide 1.21, Measuring, Evaluating, and Re-porting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, " Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

3.3.1.1 For solid wastes, the format for Table 3 in Appendix B shall be supplemented with three additional categories; class of solid waste (as defined by 10 CFR Part 60), type of container (e.g.,

LSA, Type A, Type B,Large Quantity),

and SOLIDIFICATION agent or absorbent (e.g., cement, urea formaldehyde).

APA-ZZ-01011 Rev. 3 42377 3.4 REPORTING OF MISHAPS I?TVOLVING WASTE STABILIZATION AND HIGH INTEGRITY CON-TAINERS 3.4.1 As per the requirements of the NRC Branch Technical Position paper on Waste Form, dated 1/24/91, information on misuse or failure of waste forms or containers used to meet the stability requirements of 10CFR61 shall be pro-vided to the Commission. Such mishaps include, but are not necessarily lim-ited to, the following:

3.4.1.1 The failure of high integrity contain-ers used to ensure structural stabil-ity. Such failure may be evidenced by changed container dimensions, cracking or injury from mishandling (e.g.,

dropping or impacting against another object).

3.4.1.2 The misuse of high integrity contain-ers, as evidenced by quantity of free liquid greater than one percent of container volume, or an excessive void space within the container; (such use is in violation of 10CFR61.56(a)).

APA-ZZ-01011 Rev. 3 3.4.1.3 The production of a solidified Class B or C waste form that has any of the following characteristics:

1. greater than 0.5 percent volume of free liquid.

2. concentrations of radionuclides greater than the concentrations demonstrated to be stable in the waste form in qualification test-ing accepted by the regulatory agency.

3. greater.or lessor amounts of so-lidification media than were used

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in qualification testing accepted by the regulatory agency.

4. contains chemical ingredients not present or accounted.in qualifica-tion testing accepted by the regu-latory agency.

5. shows instability evidenced by' crumbling, cracking, spalling, voids, softening, disintegration, nonhomogeneity, or change in di-mensions.

6. evidences processing phenomena that exceed the limiting process-ing conditions identified in app-licable topical reports or-process control programs, such as-foaming, excessive temperature, premature or slow hardening, production of volatile material, etc.

3.4.2 Waste form mishaps should be reported to the NRC's Director of the Division of Low-Level Waste Management and De-commissioning and the designated State disposal site regulatory authority within 30 days of knowledge of the in-cident.

APA-ZZ-01011 Rev. 3 3.4.3 For any such waste form mishap occur-rence, the affected vaste form should not be shipped off-site until approval is obtained from tha disposal site regulatory authority.

3.4.3.1 Either adequate mitigation of the po-tential effects on the waste form or an acceptable justification concerning the lack of any potential significant effects of the affected waste form on the overall performance of the dispo-sal facility must be provided to the disposal site authority and other reg-ulatory agencies, c; appropriate, prior to the waste form being shipped to a disposal facility.

l NOTE The reason for this is l that the low-level waste I generators and proces-l sors are required by l 10CFR 20.2006(c) to cer-l tify that their waste i forms meet all applica-l ble requirements of j 10CFR Part 61, and waste 1 forms that are subject I to the types of michaps l mentioned above may net .

l possess the required

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long-term structural stability.

4.0 10CFR61 COMPLIANCE METHODOLOGY 2713 4.1 All packaged radioactive wastes 2720 generated at the Callaway Plant shall 42371 meet the requirements of Title 10 Code 42372 of Federal Regulations Part 61 (10CFR61). As a minimum, all radioac-tive waste stream sources must be sampled and analyzed on an annual ba-sis for development of applicable ra-dionuclide correlations for determin-ing waste classification and packaging requirements.

APA-ZZ-01011 Rev. 3 2715 4.2 Waste Classification (10CFR61.55) 2728 requirements shall be met by the me-thodology established in plant operat-ing procedure (s) governing Waste Clas-sification. Waste Characterization (10CFR61.56) requirements shall be met by a combination of the methodology stated in the Process Control Program and related Callaway Plant Operating Procedures. Stability requirements stated in 10CFR61.56 (b) and by burial site shall be met and ensured prior to shipping packaged radioactive waste offsite for burial.

4.3 Additionally, the use of NRC-approved topical reports may be utilized in

) meeting specific requirements of 10CFR61. (See Attachment 1, Topical Reports Applicable to Callaway Plant PCP).

5.0 PROCESS CONTROLS 5.1 ADMINISTRATIVE REOUIREMENTS 5.1.1 All samples must be handled in accor-dance with applicable Callaway Plant procedures and in keeping with ALARA principles. Test samples containing radioactive waste and contaminated disposable labware utilized in the performance of the methods described in the PCP should be disposed of as radioactive' waste.

.5.1.2 Administrative controls governing the use and disposal of oils, greases and chelating agents should be utilized as a means to control and/or limit thd production of wastes containing these substances. In the event that chemical analysis of process wastes for these substances is impractical due to phys-ical restrictions or analytical con-straints, determination of their pres-ence (or absence) may be made utiliz-ing appropriate evaluation techniques.

l APA-ZZ-01011 Rev. 3 41885 5.1.3 With solidification or dewatering not 1911 meeting disposal site and shipping and transportation requirements, shipment of the inadequately processed wastes shall be suspended. Additionally, the Process Control Program, its imple-menting procedures and/or the Solid Waste System shall be corrected, as necessary, to prevent recurrence.

41885 5.1.4 With solidification or dewatering not 1911 performed in accordance with the Pro-cess Control Program, tne improperly processed waste in each container, as applicable, shall be tested to ensure that it meets burial ground and ship-ping requirements. Appropriate admi-nistrative actions shall be taken to prevent recurrence.

4166 5.1.5 Prior to batch solidification of wastes to be solidified, waste classi-fication and acceptability for near-surface disposal shall be determined.

This will involve calculating the ac-tivity within the projected waste con-tainer using the isotopic analysis of the batch and the actual solidifica-tion formulas to be used.

5.1.6 Prior to packaging of wastes using other processes (e.g., immobilization or dewatering, etc.), waste classifi-cation and acceptability of process method chosen for near-surface dispo-sal must be determined. This will in-volve calculating the activity within the projected waste container using the isotopic analysis of the waste to be processed and packaged.

t 5.2 COLLECTION AND ANALYSIS OF SAMPLES 5.2.1 General Requirements (applicable to cement solidified wastes only) 41886 5.2.1.1 The PCP shall be used to verify the i solidification of at least one repre-sentative test sample from at least every tenth batch of each type of wet radioactive waste solidified.

APA-ZZ-01011 Rev. 3 41886 5.2.1.2 If any test sample fails to solidify, )

solidification of the batch under test I shall be suspended until such time as additional test samples can be ob-tained, alternative solidification pa-rameters can be determined in accor- .

dance with the Process Control Pro-gram, and a subsequent test verifies solidification. Solidification of the batch may then be recumed using the alternative solidification parameters determined.

41886 5.2.1.3 If the initial test sample from a batch of waste fails to verify solidi-fication, then representative test samples shall be collected from each consecutive batch of the same type of waste until three (3) consecutive in-itial test specimens demonstrate'so-lidification.

5.2.1.4 For high activity wastes, where han-dling samples could result in person-nel radiation exposures which are in-consistent with ALARA principles, re-presentative non-radioactive samples may be test solidified. These samples must be as close to the actual waste and chemical properties as possible.

Typical unexpended nixed bead resin may be used to simulate the spent bead resin.

5.2.1.5 Where practical, all chemicals used to condition or solidify waste (or simu-lated waste) in solidification tests must be identical to the actual chemi-cals to be used in full scale solidi-fication.

5.2.2 PCP ARCHIVE SAMPLE REQUIREMENTS 5.2.2.1 As per the Appendix to the NRC Branch Technical Position paper on Waste Form, dated 1/24/91, archiving of PCP test sample specimen must be performed for all Class B and C wastes that are stabilized using cement.

APA-ZZ-01011 Rev. 3 5.2.2.2 These specimens are to be tested and evaluated at 6 and 12 month intervals after the actual stabilization.

5.2.2.2.1 Testing must encompass a verification of compressive strength > 60 lbs after immersion in water for at least 14 days.

42377 5.2.2.3 If a tested specimen does not meet the acceptance test above, it shall be presumed that all containers of waste packaged per that PCP formulation do not meet 10CFR61 stabilization requir-ements.

5.2.2.3.1 Reporting of failure of tested speci-men to meet acceptance criteria shall be made to the Commission as well as to the burial facility where the pack-aged waste had been disposed.

5.2.2.3.2 Any containers of material packaged with this formulation on site will need to be retested or otherwise re-packaged to ensure 10CFR61 stability requirements are adhered to.

5.2.3 Collection Of Samples 5.2.3.1 Sample Analysis Documentation 5.2.3.1.1 For wastes that are to be solidified, pertinent information on the charac-teristics of test sample solidifica-tion must be recorded in order to ver-ify solidification of subsequent ,

batches of similar waste without re-testing. If waste pretreatment is ne-cessary prior to actual batch solidi-fication, the agent used and amount added must be recorded.

APA-ZZ-01011 Rev. 3 5.2.3.1.2 The test sample data for waste must include, but is not limited to: the type of wastes solidified; percent to-tal solids; pH; amount of oil in the sample. Additionally, recorded infor-nation should include the batch number, waste type, waste classifica-tion, total wastes received, total binding agent (s) added and the date solidified.

5.2.3.2 Takinc Samples 5.2.3.2.1 A sample (s) of the waste tank's con-tents to be processed / packaged must be taken in order to determine the actual

{ process formulation for solidifica-

) tion, any pretreatmeht of the waste needed prior to solidification or oth-er process and packaging method, and the waste classification of the final packaged waste product.

5.2.3.2.2 Sample sizes, as determined by the Radwaste Department, should be compat-ible with the standard size samples

} used for radioactivity and chemical j analysis. If the radioactivity levels are too high to permit full size sam-ples to be taken, then smaller samples should be taken with the results cor-rected accordingly.

5.2.3.2.3 Sufficient sampling lead time should be allotted prior to planned waste so-lidification of a batch to allow ade-quate time to complete the required testing and verification of solidifi-cation, as applicable. The contents of the waste tanks that are to be pro-cessed / packaged must be recirculated (mixed) prior to sampling to ensure that a representative sample is ob-tained.

APA-ZZ-01011 Rev. 3 5.2.3.2.4 If the contents of more than one tank or container are to be packaged in the same container, then representative samples of each tank (container) should be drawn. These samples should be of a sufficient composition that if "X" percent of the total waste to be packaged is to be taken from one of the tanks, then the sample taken from

- that tank should be the same percen-tage in the composite sample. The sam-ples taken of each should be mixed in the proper proportions to yield a standard size sample.

5.2.4 Chemical Analysis Of Waste Samples 5.2.4.1 Evaporator bottoms and chemical wastes must be analyzed for total solids, oil content, boric acid concentration and pH. Spent resin beads and charcoal to be solidified must be characterized by analyzing the water surrounding the beads and charcoal for oil content and pH. (Chemical analysis of resins / char-coal is not required for packaging via-dewatering).

5.2.4.2 Results of chemical analysis must be documented.

5.2.5 Radiochemical _ Analysis Of Waste San-ples 5.2.5.1 A gamma isotopic analysis must be per-formed on each batch of waste to be

, packaged. This analysis is used in determining an acceptable packaging method as well as waste classification of the pt*kaged waste.

5.2.5.2 Samples are drawn from the evaporator bottoms tank (s) for performing this batch analysis.

J 5.2.5.3 Sampling of individual demineraliz-ers/ charcoal adsorbers is performed during vessel changeouts. These sam-ples are composited to determine the batch sample for gamma isotopic analy-sis.

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APA-ZZ-01011 Rev. 3 5.2.5.4 The results of the gamma isotopic analysis must be recorded on/ attached to the documentation package.

i 5 ! TEST SOLIDIFICATION AND ACCEPTANCE CRITERIA 5.3.1 Waste Conditionina 5.3.1.1 Prior to test sample solidification, ,

the pH of the tank must be adjusted to i a range of 5 to 9 pH. Should adjust-ment be necessary, the agent and quan-tity used must be recorded. ,

5.3.1.2 If oil is present in quantities great-

, er than 1% by volume, dilution of the l

batch to belew 1% is required prior to solidificatic .

l 5.3.2 Test Solid!!ication 5.3.2.1 Whenever pretreatment of a batch is necessary, the tank contents must have the required pretreatment accomplished prior to pulling the sample for test ,

solidification analysis. l 5.3.2.2 A test solidification container should  ;

be prepared with a mixing device.  !

5.3.2.3 The appropriate proportional amount of partland cement and sodium metasili- l i

cate and/or other solidification media per the applicable test solidification procedure must be added. A known re- 1 I presentative volume of the waste must l be transferred to the test solidifica-tion container.

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i APA-ZZ-01011 Rev. 3  !

5.3.2.4 Mixir.g of the waste, portland cement  !

and/or other solidification media is  !

j then initiated. After appropriate mix-l ing or when a homogenous mixture is  :

obtained, the cement / waste mixture i must be allowed to stand for a spec- l ified time period. Any free liquid ob- l served on the top of the test solidi- i fication must be decanted into a clear

• I volumetric beaker (cylinder) . The amount of liquid decanted is used to calculate the percent free liquid. Re-sults of this analysis must be docu-mented.

5.3.3 Test Solidification Acceptability 2720 5.3.3.1 The test sample solidification shall be considered acceptable from a _ree

) liquid standpoint if the amount of

) free liquid is the lessor of either 1%

by volume or burial site limits.

l2713 5.3.3.2 The test sample solidification shall I be col.sidered accaptable from a solid j mass st.undpoint (i.e., structural sta-l l bility) if the surface of the sample

) I resists penetration when probed with a i sostula or comparable firm object.

5.3.3.3 If either or both of the above checks fail to mer

• the stated criteria, the waste samp slysis and/or the sam-ple solidif 9 ;._; m formula must be verified as ba.r.g correct. If this verification shows an error in waste

{ sample analysis or sample solidifica-

) tion formula,a corrected solidifica-tion formula must be obtained and sam-ple solidificaticn performed using this corrected formula.

5.3.3.4 In the event that the analysis and formula previously derived and used ~

are correct, a tternative solidifica-tion parameters must be determined be-fore solidification can proceed.

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i APA-ZZ-01011 l Rev. 3 41886 5.3.3.5 If the initial test solidification of a batch is unacceptable, then a repre- 1 sentative sample shall be test solid- )

ified on each subsequent batch of the ,

same type of waste until three consec-utive test samples demonstrate solidi-fication.

5.3.3.6 If a test sample fails to provide ac-ceptable solidification of waste, '

equal volumes of dry cement and sater 1 should be mixed to ensure that the problem is not due to a bad batch of l cement.

6.0 RADIOACTIVE WASTE PROCESSING USING IN-STALLED LIOUID VOLUME REDUCTION SYSTEM 6.1 General Reauirements 6.1.1 The installed radioactive waste liquid I volume reduction (RVR) System will be '

used to process most_ aqueous wastes (i.e., evaporator concentrates, floor j

, drain and sump sludges, etc.) from l plant radioactive systems. Liquid wastes from other than installed Power Block drain systems may be processed l in the RVR System but must be evaluat- I ed for compatibility with materials of construction used in fabrication of the RVR System.

i 6.1.2 A system description of the RVR System I is detailed in chapter 11.0 of the  !

Callawr.J Plant FSAR.- l 6.1.3 All containers used for packaging ,

wastes processed using the RVR System must be inspected prior to use to en-sure they are free from defects.

2713 6.1.4 The RVR System process produces a re-sulting waste product that will not meet 10CFR61 stability requirements.

l The RVR shall only be used for pro-

cessing / packaging wastes that will re-

' sult in a vaste classification of Class A.

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APA-ZZ-01011 l Rev. 3 1

6.2 Waste Sampling 6.2.1 Representative samples of liquid wastes to be processed by the RVR Sys-I tem must be obtained and analyzed for chemical and radiochemical content, as appropriate.

I 6.2.1.1 Chemical analyses required include as a minimum; total solids, oil content and pH.

6.2.1.2 A gamma isotopic analysis must be per-formed on each batch of waste to be I processed. An appropriate concentra-tion factor must be applied to the

. analysis results in order to derive I the waste classification of the re-sulting packaged waste.

6.2.1.2.1 Gamma isotopic analysis performed on I processed waste discharged from the RVR do not require application of a concentration correction factor.

I 6.2.2 Samples are drawn from the evaporator bottoms tank (s) or from individual containers of liquid waste sludges for I performing this batch analysis.

6.2.3 Results of chemical analyses and gamma I. isotopic analyses must be recorded on/ attached to the applicable batch documentation package.

6.3 Process Controls 6.3.1 Operation of the installed RVR System I must be performed and documented per approved plant operating procedures.

6.3.2 In order to ensure production of a .

waste product meeting desired " dry-ness" prior to final packaging, prc-cess parameters must be controlled and I monitored during all stages of system operation (i.e., filling, drying, mix-ing and final pumpout of waste pro-1 duct).

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APA-ZZ-01011

( Rev. 3 6.3.3 Key operating parameters such-as oper-

[ ating temperatures and pressures with-

[ in the RVR System's blender / dryer must be monitored and recorded.

6.3.4 A final material dryness " endpoint" must be met prior to considering the material dry within the blender / dryer.

This " endpoint" is met through a se-quence of system manipulations where the RVR blender / dryer contents are cycled above saturation temperature several times to drive off remaining water from the contents. The sequence of steps to do this is detailed in system operating procedures.

6.3.5 Following the " endpoint", paraffin may be added to the blender / dryer for mix-ing with the dried processed waste powder to immobilize the powder'and keep it from readily dispersing in the air.

2713 6.3.6 Should packaged wastes be created that exceed a waste classification of Class A, the resulting packaged waste con-tainer shall be placed.into an over-pack container capable of meeting 10CFR61 stability requirements prior-to shipment offsite for disposal.

7.0 RADIOACTIVE WASTE PROCESSING USING BULK DISPOSAL METHODS 7.1 RADIOACTIVE WASTE PROCESSING USING CONTRACTED VENDOR SERVICES 7.1.1 Processing and Packacinq of Primary-and Radwaste System Wastes 7.1.1.1 General Recuirements 41886 7.1.1.1.1 Contracted vendor services shall be provided to process and package ra-dioactive vastes to the required waste form to satisfy the applicable trans-portation and disposal-requirements =

for those instances when the installed f solid radioactive waste system is in-capable of processing these wastes.

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APA-ZZ-01011 Rev. 3 41886 7.1.1.1.2 Contracted vendor services will be es-tablished for the packaging of wet ra-dioactive wastes by vendor solidifica-tion and/or dewatering. Contracted vendor services may be exercised when, in the opinion of plant management, any of the following conditions exist:

a. The installed system is declared out-of-service thereby reducing or ,

eliminating the capability of Cal-laway Plant to efficiently and le-gally package radioactive wastes in accordance with all applicable requirements governing the dispo-sal of the vastes; or,

b. The installed system is incapable I of packaging these wastes in ac-cordance with any of the applica-ble requirements (e.g., 10CFR61.)

governing the disposal of these l wastes; or,  ;

c. When processing and packaging eco-  ;

l nomics show an increased cost ef- l l

ficiency of vendor processing ver- '

sus installed system processing.

4618 7.1.1.1.3 Specific programmatic controls for i these services will be handled in ac-cordance with the vendor's Quality As-surance program. This program shall be  ;

l approved by Union Electric Quality As-surance prior to implementation of the I contracted services. I 7.1.1.2 Control Of Vendor Procedures And Docu-mentation 7.1.1.2.1 Vendor procedures covering equipment setup, operation, and removal must be reviewed and approved in accordance with plant administrative procedures prior to implementation.

APA-ZZ-01011  !

Rev. 3 7.1.1.2.2 Vendor procedures detailing the ven-dor's Process Control Program (PCP) in addition to the review and approval  ;

mentioned above must also be reviewed )

and approved by the Onsite Review Com- '

mittee prior to implementation. The  !

vendor PCP must provide for the sam- ,

pling, tests, analyses and formulation determination, as required by the Cal-laway Plant PCP.

4955 7.1.1.2.3 Res'11ts of all testing and analyses shall be documented, as necessary, to ensure compliance with the vendor PCP and all applicable transportation and burial ground requirements governing l the disposal of these wastes.

4955 7.1.1.2.4 Copies of all documentation attesting to compliance with the requirements of the vendor PCP as well as any plant operating procedures utilized in sup-port of the contracted vendor service shall be retained by the plant for in-clusion in plant files. Documentation containing proprietary information ,

should be appropriately handled and  :

controlled to ensure the required de-gree of confidentiality is met.

7.1.2 Processing and Packacine of Secondary l and Support System Wastes l l

7.1.2.1 General Recuirements 7.1.2.1.1 Contracted vendor services must be provided to process and package ra-dioactive wastes to the required waste form to satisfy the applicable trans-portation and disposal requirements for wastes which are generated outside 1 the RCA/ Power Block of the plant or where expertise in handling same is ,

! not available at Union Electric. l 1 1 i

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APA-ZZ-01011 Rev. 3 '

7.1.2.1.2 These contracted vendor services may be established and exercised for pro-I cessing and packaging of any of the following contaminated wastes:

a. Contaminated Sewage Treatment I Plant sludges and similar aque-ous-based colutions.

I b. Mixed wastes (i.e., waste exhibit-ing characteristic hazardous mate-rial which have become radioac-tively contaminated.)

4618 7.1.2.1.3 Specific programmatic controls for these services will normally be I handled in accordance with the ven-dor's Quality Assurance Program. This program shall be approved by Union I Electric Quality Assurance prior to implementation of the contracted ser-vices.

I 7.1.2.1.4 For those cases where the vendor ser-vice is not performed per an estab-lished, acceptable vendor Quality As-I surance Program, applicable require-ments of the Union Electric Quality Assurance Program are to be implement-ed.

I 7.1.2.1.5 Control of vendor procedures and/or documentation utilized or created in support of the contracted service must I ba handled per applicable guidance found in step 7.1.1.2 of this proced-ure.

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APA-ZZ-01011 Rev. 3 7.2 RADIOACTIVE WASTE PROCESSING USING IN-HOUSE BULK DISPOSAL OPTIONS 7.2.1 General Requirements 7.. 1.1 All containers used for solidification or dewatering must be inspected to en-sure they are free from defects. Steel containers used for dewatering must be inspected to ensure that their inter-nals are intact and undamaged. High Integrity Containers (HICs) must be

[ inspected to ensure that they are in compliance with their Certificate of Compliance as well as ensuring that their internals are intact and undam-aged.

2720 7.2.1.2 All wastes dewatered in steel contain-ers shall be dewatered in accordance with approved procedures for which testing has demonstrated that the one-half of one percent (0.5%) draina-ble liquid criteria can be met. All wastes to be dewatered in HICs shall be dewatered in accordance with app-roved procedures for which testing has demonstrated that the one percent (1%)

drainable liquid criteria can be met.

Test data to ensure compliance may be based upon container supplier testing.

7.2.2 Waste Sampline .

7.2.2.1 Representative samples of wastes to be processed by bulk disposal means must be obtained and analyzed for chemical and radiochemical content, as approp-riate. Based upon this analysis, the packaging process as well as the con-tainer to be utilized will be deter-mined.

7.2.2.2 Results of all analyses must be docu-mented, as necessary, to ensure com-

[- pliance with all applicable packaging, transportation and burial ground re-quirements governing the disposal of these wastes.

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I ApA-ZZ-01011 !

Rev. 3  !

7.2.3 Packacinc Of Spent Filter Cartridges 7.2.3.1 packaging of spent filter cartridges will be performed in either steel drums and Low Specific Activity (LSA) boxes or in High Integrity Containers (HICs), dependent upon waste classifi-cation of the spent filter car- ,

tridge(s) involved. I 7.2.3.2 Determination of waste classification will be performed based upon dose to l l

curie correlations of the spent filter cartridges. The acthodology involved l must be covered in approved plant  !

I operating procedures.  !

l l2720 7.2.3.3 Spent filter cartridges which meet the I requirements of Class A waste may be i packaged in common 17H drums with up ,

I to 12 filter cartridges per drum or l l packaged in LSA boxes. Absorbent media i i shall be utilized to absorb twice the l l volume of any incidental liquid within 4 l

l the container. Packaging methods gov-l erning this process m..C; be covered in ,

l approved plant operating procedures.  !

l l42376 7.2.3.4 Spent filter cartridges requiring sta-l bilization per the requirements.of l 10CFR61 or having concentration ex-l ceeding 1 pCi/cc for radionuclides l with half lives greater than 5 years l shall be packaged in HICs. Specific l radiation and curie content limita-l tions for use of the HIC, as iden-  ;

l tified on the applicable Certificate l l of Compliance, must be met and ensured l l prior to disposal of the waste. Pack-l l aging and dewatering of the HIC con-l tents must be performed and documented ,

l using approved procedures. (See att- l l

l ach:: tnt 2, High Integrity Containers l l (HICs) Authorized for Use at Calla-l way).

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APA-ZZ-01011 Rev. 3 42375 7.2.3.5 HICs purchased for use in packaging spent filter cartridges shall be de-( signed to meet the applicable require-ments found in the NRC Branch Techni-cal Position paper on Waste Form dated 1/24/91.

7.2.3.6 Common packaging of spent filter car-tridges and spent ion exchange bead

'( resin may be performed in HICs pro-vided for that purpose, with specific instructions for loading and dewater-ing covered in approved plant proced-ures.

7.2.4 Packagina Of Spent Ion Exchance Bead Resin 7.2.4.1 Spent resin to be packaged should be sampled prior to sluicing in order to ensure the proper container required for packaging the resin is utilized.

41638 7.2.4.2 Packaging of spent ion exchange bead resin may be performed utilizing dewa-tering processes in lieu of solidifi-cation. Class A Unstable wastes may be dewatered in steel containers, while Stable wastes, regardless of class, shall be Gewatered in HIC's.

7.2.4.3 High Integrity Containers must be used for the disposal of unsolidified spent ion exchange bead resin when the con-centration of radionuclides with half lives greater than 5 years exceeds 1 pCi/cc. (See Attachment 2).

42375 7.2.4.4 HICs purchased for use in packaging spent ion exchange bead resin shall be designed to meet the applicable re-quirements found in the NRC Branch Technical Position paper on Waste Form dated 1/24/91.

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1 APA-ZZ-01011 Rev. 3 7.2.4.5 Procedures governing the sluicing of spent resins from demineralizer beds and/or storage tanks must be written and approved for use prior to commenc-ing sluicing operations. Applicable radiological controls (i.e., shield-ing) should be utilized to ensure the process is ALARA.

42374 7.2.4.6 Dewatering processes utilized inust be performed and qualified using approved plant procedures. Appropriate methods shall be employed to ensure the appli-cable drainable liquid criteria of 10CFR61 is met prior to final sealing of the container for disposal.

8.0 . REFERENCES 8.1 10CFR20 8.2 10CFR61 8.3 10CFR71 8.4 Reg. Guide 8.8, Revision 3 8.5 Callaway Plant FSAR Chapter 11.4 8.6 Technical Specification 6.13.1 (CTSN

1. 20174) 8.7 Technical Specification 6.13.2 (CTSN

1. 2814) 8.8 APA-ZZ-00101, Preparation, Review, Approval and Control of Procedures 8.9 NRC BTP on Waste Form (dated 1/24/91) 8.10 Reg. Guide 1.21, Revision 1, June 1974 r' (

APA-ZZ-01011 Rev. 3 TOPICAL REPORTS APPLICABLE TO Cf.LLAVAY PLANT PROCESS CONTROL PROGRAM (PCP)

The Following vendor topical reports have been reviewed and incorporated, as appropriate, into procedures which implement the Callaway Plant Process Control Program (PCP).

1. VMG 102-NP-A, RADMAN-A Computer Code to Classify and Document Packaged LLU In Accordance with 10CFR Part 61 Regulations; Vaste Management Group, Inc.

2. WF-C-01-NP, Topical Report for Chem-Nuclear Systems, Inc. 10CFR61 Waste Form Certification-Cement; Chem Nuclear Systems, Inc.

3. 4313-01354-01-A, Topical Report for Chem-Nuclear Systems, Inc.

Mobile Cement Solidification System; Chem-Nuclear System, Inc.

4. DW-11118-01-NP-A, Topical Report for Chem-Nuclear Systems, Inc.

Dewatering Control Process Containers; Chem Nuclear System, Inc.

5. STD-R-05-OllNP-A, Topical Report for Vestinghouse Hittman Mobile Incontainer Dewatering and Solidification System (MDSS);

Westinghouse Hittman Nuclear, Inc.

Page 1 of 1 Attachment 1

APA-ZZ-01011 Rev. 3 HICH INTEGRITY CONTAINERS (HICs) AUTHORI' ZED FOR USE AT CAllAWAY PLAITT The following High Integrity Containers (HICs) have been authorized for use in packaging Callaway Plant wastes. Applicable requirements for their use, as defined in their individual Certificates of Compliance, are detailed in plant operating procedures.

HIC CERTIFICATION # DESCRIPTION VENDOR / SUPPLIER DHEC-HIC-PL-004 RADLOK-55 Westinghouse Hittman or SEG DHEC-HIC-PL-014 RADLOK-500 Westinghouse Hittman or SEG DHEC-HIC-PL-001 CNSI-PL6-80 Chem Nuclear Systems, Inc.

DHEC-HIC-PL-010 NUHIC-120F TFC Nuclear Associates, Inc.

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Page 1 of 1 Attachment 2

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