ML20066A418

Rev 1 to Process Control Program

ML20066A418
Person / Time
Site:	Comanche Peak
Issue date:	12/31/1990
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20066A409	List: ML20066A407 ML20066A418
References
PROC-901231, NUDOCS 9101030256
Download: ML20066A418 (44)

Text

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O PROCESS CONTROL PROGRAM TV ELECTRIC COMANCHE PEAX STEAM ELECTRIC STATION t

Revision 1 l- December 1990 l

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CPSES/PCP

$ TABLE OF CONTENTS Pne Definitions iv

1.0 INTRODUCTION

1-1 1,1 PURPOSE 1-1 1.2 SCOPE l1 1.3 PRECAUTIONS / LIMITATIONS 1-2 1.4 RESPONSIBILITIES 1-4 1.4.1 Vice President, Nuclear 1-4 Operations 1.4.2 Station Operations Review 1-4 Committee 1.4.3 Radiation Protection Manager 15

,fms 1.4.4 Other Responsibilities 1-5 OI 2.0 RADI0 ACTIVE WASTE PROCESSING REQUIREMENTS 2-1 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 23 t 2.2 MAJOR CHANGES TO LIQUID, GASE0US, & 23 l

SOLID RADWASTE TREATMENT SYSTEMS l 3.0 PROGRAM DESCRIPTION 3-1 3.1 PROCESSING OF WET RADI0 ACTIVE WASTE 3-1 l 3.1.1 Processing Methods 3-1 3.1.2 Processing System Description 3-2 3.1.3 Prequalification Testing 3-2 3.1.4 System Qualification Tests 3-2 3.1.5 Equipment / System Operability 3-3 x Requirements a

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3,1.6 =B6tch Preprocessing Sampling f 3 .- l . 7 _ Testing / Inspections 3 4-3.1.8- Acceptance Criteria- 36 3.1.9 Corrective Actions 37 3.2 PROCESSING OF DRY ACTIVE WASTE 3-8 3.3- MIXED WASTE 3-9 [

t 4.0 WASTE CLASSIFICATION AND CHARACTER 12ATION 4-1 4.1 WASTE CLASSIFICATION 41 4.2 WASTE CHARACTERISTICS 4-2 i

-5. 0 - SPECIFIC WASTE STREAM PROCESSING DESCRIPTIONS 51 r 5.l' WET RADI0 ACTIVE WASTE STREAMS 5-1 i 1

5.1.1 Resins 51 4 5.1,2 Cartridge-Filters 5-3 5.1.3 Evaporator Concentrates 54 5.1.4 Sludge 5-5 5.1 5. Miscellaneous Liquids 5 5.2 -DRY ACTIVE WASTE 5-6 6.0 ADMINISTRATIVE CONTROLS 6 l'

'6.1 PROCEDURES 6-1 h 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 O

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CPSES/PCP D)

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LIST OF FIGURES Fiaure No. Title PJLqn 1-1 CPSES Radioactive 16 Management Organizational Responsibilities 51 Dewatering Process Flow Chart 5-8 5-2 Solidification Process Flow 5-9 Chart 5-3 DAW Process Flow Chart 5-10 l

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CPSES/PCP 73 Q DEFINITIONS 1

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

PROCESSING PROCESSING shall be the conversion of radioactive waste into a form that meets shipping and burial ground requirements.

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CPSES/PCP-SECTION 1.0 0 INTRODUCTION 1

- 1.1 PURPOSE:

The purpose of the CPSES-Process Control Program (PCP) is- to 1 establish a program which prM ides reasonable assurance that all~ radioactive wastes PROCESSED at CPSES for disposal at a land disposal facility are PROCESSED and packaged such that applicable Federal regulations, State rules and regulations, and disposal site criteria are satisfied. The PCP contains a general description of the methods for contr3111ng the PROCESSING and packaging of radioactive wastes, specific parameters-for each method,_and the administrative controls and qu'ality assurance required to ensure compliance with applicable regulations and requirements, _This PCP is not 'I applicable to radioactive wastes transported to an offsite

-vendor for PROCESSING. 1 1,2 1CDPE 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 and_ powdered)  ;

(b) Cartridge Filters-(c) Evaporator Concentrates-(d) Sludge (e) Miscellaneous liquids G.

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CPSES/PCP (2) _ Dry Active Wastes-(DAW)

-(a) Compactible  !

(b) Noncompactible 1.3 PRECAUTIONS / LIMITATIONS 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 4 land disposal facility. These precautions and limitations shall be included in appropriate station or vendor implementing procedures.

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

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?(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 cardboard or fiberboard boxe's.

_(4) Void spaces within the waste and-between the waste and 1 ,

l its package shall be reduced to the extent practicable.

L (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.  !

l (7) As much as practical, polyethylene HIL. shall be kept out i of direct sunlight to prevent ultraviolet light l 4 degradation. Protection from direct sunlight shall .be provided when'HICs are stored for extended periods. ,

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.(8) Radioactive waste shall not be packaged for disposal if )

it is pyrophoric Pyrophoric materials contained in ]

radioactive waste shall be treated, prepared, and' l par'79ed to be nonflammable prior to disposal.

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

(10) Radioactive waste containing hazardous material shall be l 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 reactien with water.

(12) Radioactive waste shall not be packaged for disposal if-i it 'contains, .or is capable of generating quantities of.

toxic gases, vapors, or fumes ~ harmful to persons transporting, handling or disposing of the waste. 1 O

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

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

1.4 RESPONSIBillTIES .

1.4.1 Vice President. Nuclear Operationi It is the responsibility of the Vice President, Nuclear Operations, to ensure that the requirements contained in this manual are achieved during the PROCESSING of radioactive waste by developing appropriate administrative and implementing procedures. An organizational chart showing specific station responsibilities for radioactive waste PROCESSING assigned by the Vice President, Nuclear Operhtions, is shown on Figure 1-1. The Vice President, Nuclear Operations, is responsible for approving changes to this PROCESS CONTROL PROGRAM, as required by Technical Specification 6.13.

1.4.2 Station Ooerations Review Committee The Station Operations Review Committee (SORC) shall 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 S0RC prior to the initial use o of the revision. These reviews shall ensure b compatibility with station equipment and operation.

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CPSES/PCP Additionally, SORC is responsible for reviewing changes to this PCP prior to implementation. SORC also reviews station administrative and implementing procedures for radioactive waste PROCESSING activities.

1.4.3 Radiation Protection Manaaer The Radiation Protection Manager (RPM) is responsible for coordinating the review of, and for approving vendor procedures for waste PROCESSING prior to the initial use of the documents at the station. He shall also approve any revisions to these documents prior to their initial use. Review of vendor procedures for 1 waste PROCESSING shall include technical review by the Operations, Chemistry, Technical Support and Quality Assurance denartments.

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Vice President.

Nuclear Operations l

Plant Manager I

Chemistry &

Manager, Radiation Protection Operations Manager hnvironmental Responsible for: Responsible for: Responsible for:

p- Filter /Demineralizer -Wet waste processing Sampiing operation ( i.e., solidification Radiological and Evaporator operation & dewatering) nonradiological analyses Resin transfers DAW collection / processing 10CFR61 waste classification

. - Storage L- - Transportation l - Disposal

- Radiation Protection support L

l Figure 1 1 CPSES Radioactive Waste Management Organizational Responsibilities 16 Rev. I 12/90

CPSES/PCP SECTION 2.0 RADI0 ACTIVE WASTE PROCESSING REQUIREMENTS 2.1 SOLID RADIOACTIVE WASTES OPERABillTY CRITERIA 2.1.1 Radioacative wastes shall be PROCESSED in accordance with this PROCESS CONTROL PROGRAM to meet shipping and transportation requirements during transit, and disposal site requirements when received at the disposal site.

APPLICABIllTY: At all times.

COMP ESATORY MEASURES:

e (m) a. 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.

l b. ~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 l requirements and take appropriate administrative action to prevent recurrence.

c. The provisions of Technical Specifications 3.0.3 and 3.0.4 are I

not applicable.

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' TESTS / INSPECTIONS

,, 2.1.2 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 7 PROCESS CONTROL PROGRAM:

a .- If any test specimen fails to verify satisfactory PROCESSING, l 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. PROCESSING of the-batch may then be resumed using the alternative PROCESSING parameters determined by this PROCESS CONTROL PROGRAMt e

< This PROCESS CORTROL PROGRAM shall be modified as required, as provided in Technical Specification 6.13, to assure satisfactory PROCESSING of subsequent batches of waste; and

b. 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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BASIS

.i 2.1.3 This requirement implements the requirements of_10 CFR 50 36a and-General Design Criterion 60.of Appendix A to 10 CFR Part 50._ The PROCESS parameters included in establishing this PROCESS CONTROL PROGRAM may include, but are not limited to, waste type, waste pH, waste / liquid / solidification agent / catalyst ratios, waste oil content, F: principal chemical constituents of the waste, mixing and curing t'imes, j and dewatering. parameters, i

2.2 MAJOR-CHANGES TO L10VID. GASEOUS. AND SOLIO RADWASTE TREATMENT SYSTEMS ,

Licensee initiated majcr e=nges-to the Radwaste Treatment Systems (liquid, gaseous, and plid):

a. Shall be reported to the Commission in the Semiannual- 1 O' Radioactive Effluent Release Report for the period in which i _the changes were reviewed by the SORC. The discussion of each change shall contain:

1) A Summary of the evaluation that led to the determination that the change could be made in accordance with'10 CFR 50.59;

2) Sufficient detailed information to support the reason -1 l_

for the change without benefit of additional or supplemental information; 3)- A detailed description _of the equipment, components, and PROCESSES involved and the interfaces with other-plant systems; l

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CPSES/PCP 4)- An evaluation of the change, which shows tne 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 &mendments thereto; -1

5) An evaluation of the change, which shows the expected i maximum exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general oopulation that differ from those previously estimateC in the License  !

application and amer.dments thereto;  ;

6)_ A comparison of the predicted releases )f radioactive materials, in liquid and gaseous efflueats and in -!

solid waste, to t'he actual releases for the period )

prior to when the change is to be made; l 2q.

V 7) An estimate of the exposure to plant operating personnel as a result of the change; and 1

8) Documentation of the fact'that the change was reviewed and found acceptable by the 50RC.  !

b. Shall become effective upon review and acceptance by the SORC.

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CPSES/PCP 4 SECTION 3.0 PROGRAM DESCRIPTION 3.1 PROCESSING OF WET RADIOACTIVE WASTE 3.1.1 PROCESSING Methods Wat radioactive waste PROCESSED at CPSES shall be 1 PROCESSED into a. form acceptable for disposal at a

-licensed facility. PROCESSING shall be performed <

utilizing vendor supplied services and equipment operating in accordance with the vendor's PROCESS Control Program (PCP) and procedures. Any vendor selected to provide services or products used for compliance with 10 CrR 61 stability requirements shall O s ve tePic i <ePert 88cos 4,e io cra ei requiremerits under review or approved by the NRC. The Topical Reports and PCPs af ather vendors may be referenced in this PCP e.ve,1 if all vendors are not actively providing serW ces 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 Processina System Descriotion Detailed descriptions of the vendor's PROCESSING system shall be included in the vendor's Topical Report.

3.1.3 f.tnualification Testina 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. ~;

prequalification testing is performed by the vendor and documented in the vendor's Topical Report.

3.1.4 System Oualification Tests Prior to the initial solidification of a given waste ,I stream type using a specified PROCESS, 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. Bounds for critical parameters and specific operating limits shall be specified in the vendor's PCP.

These tests shall be performed on laboratory scale or full scale specimens and shall ensure that the 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 acceptance criteria specified in Section 3.1.8 are O achieved.

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CPSES/PCP 3.1.5 Eculoment/ System Ooerability Cecirements Prior to each PROCES$1NG evolution, the vendor shall demonstrate operability of the PROCESSING equipment which shall include, but not be limited to, the following:

(1) Control Panel (2) Instrumentation and 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.

3.1.6 Batch Precrocessina Samolina 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 Topical Report that addresses the 10 CFR 61 stabilitv 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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CPSES/PCP (a) Ensure that waste stream parameters ,

are within the bounds for critical parameters established in the vendor's PCP and 10 CFR 61 Topical Report.

HQlf, : Results of waste stream 1

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r.hemcial analyses shall be revieweo by the PROCESSING vendor to ensure l chemical constituents do not exist which could cause adverse chemical ren;ctions during the solidification '

PROCESS or react adversely with the j solidification container, i

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

3.1.7 Testino/Insoectiqni 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 l verifying that a specified end point is' achieved for each dewatering evolution of the actual waste stream.

For solidification this is accomplished by performing 1 a solidification of at least_one representative test I 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 V produced using the pre established formulations provided in the vendor's PCP.

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l O This test shall be performed on either a laboratory )

}k scale or full scale test specimen which is similar j both chernically and physically to the unadjusted waste stream to be PROCESSED, After the sample is collected, it should be conditioned in accordance with the vendor's PCP. The sample should then be mixed with the binder and additives in ratios determined using the vendor's pre established formulations. The specimen should be observed to ensure that the applicable acceptance criteria specified in Section 3.1.8 are achieved.

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:

(1) PROCESSING of the batch under test shall be O suspended until such time as additional testing can be performed, alternative PROCESSING parameters can be determined, and subsequent testing verifies satisfactory PROCESS!(4G 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.

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 35 Rev. I 12/90

CPSES/PCP required to assure adequate PROCESSING of

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subsequent batches of waste. Any changes should be consistent with the conditions, limitations, and restrictions addressed in the vendor's 10 CFR 61 Topical Report.

(2) If the test results failure is due to a malfunction of the PROCESSING equipment or the PROCESSING equipment is inoperable, the equipment shall ba returned to an OPERABLE condition or an alternate vendor shall be obtained to PROCESS waste, as necessary, to satisfy applicable transportation and disposal requirements.

3.1.8 Acceptance Criteria (1) Minin.um Requirements 1 All classes of waste shall satisfy the I following acceptance criteria:

(a) Liquid wastes shall be solidified. 1 (b) Solid waste containing liquids shall 1 not contain freestanding liquid in l excess of 1% of the internal volume of the container.

(2) Stability Requirements 1 l

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

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,) (a) The waste shall have structural 1 stability.

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CPSES/PCP i (b) Notwithstanding the provisions of 1 Section 3.1.8 (1)(al and (b), liquid wastes or wastes contcining liquid shall be (.onverted 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 l extent of the inadequately PROCESSED waste, if such l wastes have been shipped for disposal, the disposal site operator shall be contacted and the problem addressed.

l-If PROCESSING is not performed in accordance with this 1 PCP, the improperly PROCESSED waste shal_1 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 t

Dry Active Waste (DAW) generated at CPSES shall be PRDCESSED by segregation, sorting, and/or compaction. PRDCESSING of DAW is performed to accomplish the following functions:

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

(2) Remove constituents not acceptable for disposal as DAW.

(3) Minimize volumes of DAW shipped for disposal by:

(a) removing reuseable and uncontaminated items; and (b) reducing shipped volumes by compaction.

Onsite PROCESSING of DAW at CPSES shall be performed in 1 accordance with approved station procedures or vendor procedures that have been reviewed by the Radiation Protection Manager. Vendor equipment, personnel and procedures may be used for DAW PROCESSING and packaging.

The segregation of uncontaminated waste from DAW is performed to minimize the volume of DAW shipped for disposal. In order to provide reasonable assurance that radioactive materials are not released as cleen waste, the following requirements shall be included in the segregation program, as discussed in Reference 7.5.3:

(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 clean waste.

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(2) Surveys may be conducted on individual items using portable survey instruments, such as pancake GM probes. However, in all cases, final measurements of each package (e.g., bag or box) of aggregated waste to be released as clean waste shall be performed to ensure that there has not been an accumulation of radioactive material due to the buildup of multiple quantities of contamination which were not detectable with portable instrumentation. Final measurements shall be performed using sensitive detectors, such as scintillation detectors, in a low background area.

3.3 MIXED WASTE Hixed Waste is defined as waste that contains constituents-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 D, or (2) causes the waste to exhibit any of the hazardous waste characteristics identified in 40 CFR 261, Subpart C.

Under current federal law, this waste is subject to cual regulation by the NRC and EPA, where both agencies have control over the same waste. Due to the complex regulatory issues that must be resolved pertaining to mixed waste, there currently are no authorized disposal sites in the United States which are licensed tt, receive and dispose of mixed hazardous and radioactive waste.

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

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CPSES/PCP (1) The station chemical control program shall include a method to identify hazardous constituents of chemicals / chemical products and to evaluate and authorize any usage of these products in areas where mixed waste generation is likely to occur. This evaluation shall consider the substitution of products which are evaluated as non hazardous por 40 CFR 261.

(2) Radioactive waste PROCESSING procedures shall include 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 shall not be shipped for disposal to a low-level radioactive waste disposal facility unless specific approval for such disposal is granted by the appropriate regulatory agencies. Such wastes shall be stored until regulatory changes allow for disposal, or they are otherwise approved for disposal by appropriate regulatory agencies.

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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:

O (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 gro;s radioactivity measurements shall be made for each container of waste PROCESSED for disposal. Calculational methods for determining 41 Rev. 1 l 12/90

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

(4) The classification program shall establish criteria and include provisions for an increased frequency for the sampling and analysis required by paragraph (1),

above, if the failed fuel fractior, changes by a factor of 10.

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

4.2 WASTE CHARACTER 1STICS Waste PROCESSED for disposal at CPSES shall meet the applicable characteristics = specified in 10 CFR 61.56. Waste classified as Class B, Class C, or Class A waste that will not

-be segregated from Class B and C wastes at the burial facility, shall be PROCESSED into a -stable waste form. .This I shall be accomplished by placement into a HIC, or by 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 vendorfs topical report shall l include' documentation of testing which verifies that the HIC

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L or solidified product meets- these stability requirements.

Additionally,' TV Electric shall comply with Federal or State requirements imposed specifically on an approved HIC or solidification product which limit the type and/or radioactive I

concentration of the waste-to be placed in the approved HIC or I solidified product.

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b SECTION 5.0 SPECIFIC WASTE STREAM PROCESSING DESCRIPTIONS 5.1 WET RADIOACTIVE WASTE STREAMS 5.1.1 Resins Radioactive resins may be Ac:umulated 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

,e3 filter / demineralization system) b (4) Boron Recycle System (5) Baron Thermal Regeneration System (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 1 PROCESSING skid, to the SRSTs or routed to the Waste Conditioning Tank. If it is necessary to PROCESS secondary condensate polishing powdex resins, they are transferred to the vendor's PROCESSING skid.

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,... 3 CPSES/PCP Normally, spent resins are PROCESSED for disposal by 1

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dewatering. The resin is transferred to the liner or HIC where it is PROCESSED utilizing vendor supplied 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 classi fication. Containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage aren until they are shipped for disposal, i Alternatively, resins may be PROCESSED for disposal by 1 solidification. Resins are transferred to the Waste Conditioning Tank-where they are isolated and sampled for isotopic content and PCP parameters as defined in the vendor's PCP, If necessary, the resins are chemically conditioned. The isot pic analysis -

i results are used to estimate the waste classification, determine the proper waste form stability requirements, and. select the proper container for transportation and disposal. The resins are then transferred to the vendor's PROCESSING skid where they are solidified.per Section 3.1 of this manual.

Containers are sealed, surveyed, and labeled, as appropriate, and are stored in a designated storage area until they are shipped for disposal, i Flow charts of typical dewatering and solidification 1-PROCESSING paths are shown on Figures 5 1-and 5-2, respectively.

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i CPSES/PCP 5.1.2 Cartridae Filters Cartridge filters will be accumulated from one or more i of the following systems:

(1) Chemical and Volume Control System (2) Spent fuel Pool Cooling and Purification System (3) Liquid Waste Processing System (including filter /demineralizationsystem)

(4) Boron Recycle System -

(5) Boron Recovery System (6) Steam Generator Blowdown System (7) Miscellaneous ,

Spent filter cartridges are surveyed for dose rate upon removal from the system. The measured dose rate is used to calculate isotopic content using a dose to- -

curie conversion factor and scaling factors per Section 4.1 of this manual. Based on the calculated isotopic content, the waste classification and the ,

appropriate PROCESS and container to be used for disposal are determined. Normally, filters are placed 1 l in a' liner or HIC and.dewatered; however, filters may >

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

{ appropriate, and stored in a designated storage i sa l~ until they are shipped for disposal, i

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CPSES/PCP for purposes of waste classification, isotopic concentrations of filters dewatered in a liner or Hit ,

l should be determined as calculated over the volume of the cartridge filter itself, rather than averaged over the gross volume of the container. When filters are 1 encapsulated by solidification in a container, isotopic concentrations may be determined by averaging over the volume of the solidified mass.

1 5.1.3 Evaporator concentrates Evaporator concentrates result from operation of evaporators for PROCESSING of liquid wastes (e.g.,

floor drains) and boron recovery, Normally, liquid waste streams are PROCESSED through the p filter /demineralizer system for release to the i

V environment. The liquid waste evaporator is available as an alternate PROCESSING method. The boron eecove evaporator is used to remove boron from reactor grade water and the boric acid concentrates are normally recycled. Therefore, volumes of evaporator 1 concentrates from liquid waste PROCESSING and boron recovery, that must be solidified, are expected to be relatively small, if solidification of evaporator concentrates is required, they would be transferred from the evaporators to the Waste Conditionng Tank where batches are isolated and sampled for isotopic content and PCP parameters as defined in the vendor's PCP. if necessary. the concentrates are chemically conditioned. The isotopic analysis results are used 54 Rev. 1 12/90

. . . ~ .

1 CPSES/PCP l -to estimate the waste classification, determine the 1 jD proper waste form stability requirt.ments and select the proper container for transportation and disposal.

l The concentrates then are transferred to the vendor's PROCESSING skid where they are solidified per Section  ;

r 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.

5.1.4 Sly.dge ,

4 Radioactive sludge is accumulated and handled on a case by case basis by periodically removing the sludge from various tanks and sumps located throughout the plant. Each batch of sludge is sampled for isotopic 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 - Miscellaneous Liouids 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 l.

O G

55 Rev. I 12/90

CPSES/PCP and PCP parameters, chemically conditioned, if necessary, and transferred to the vendor's PROCES$1NG 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 stcrage area until they are shipped for disposal.

5.2 DRY ACTIVE WASTE Dry Active Waste (DAW) consists of radioactively contaminated i 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

" clean" or " contaminated" trash. " Clean" receptacles are used p

' to collect trash that potentially is not contaminated.

" Contaminated" containers are used to collect waste that is known or suspected to be contaminated. However, for purposes 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 taken to a designated sorting area for PROCESSING. Bags below 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 act surveyed for contamination, but are examined for reusable items and Dems not acceptable for disposal as DAW. Contaminated items

\ are then disposed of as DAW. Compactible items are collected 1 aad may be compressed into approved strong, tight containers, 56 Rev. I 12/90

i CPSES/PCP

(~)

V Noncompactible items are placed directly into approved strong, ,

I tight containers. Containers are sealed, surveyed, and 1 labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal or offsite l PROCESSING.

A flow chart of the DAW PROCESSING path is shown on Figure 5 3.

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CPSES/PCP

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FICtlRE 5-1 Devatoring Process Flow Chart l

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CPSES/PCP SECTION 6.0 ADMINISTRATIVE CONTROLS 6.1 PROCEDURES 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 raviewed and approved per Sections 1.4 and 3.2 of this manu al .

6.2 DVAllTY ASSURANCI Quality Assurance related activities for radioactive waste PROCESSING are implemented as described in the TV Electric CPSES Quality Assurance Manual. Such activities include:

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

(2) Review of procurement documents or services.

(3) Perform inspections as designated in applicable PROCESSING, packaging, and shipping procedures.

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

(5) Perform audits of the radioactive waste management program at least once per 24 months.

(Note: Technical Specification Administrative Control 6.5.2.8.1 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.)

61 12/90

.~,

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

These activities provide assurarce that the final waste form, packaging, labeling, and transptrtation are in accordance with applicat,lc regulations and requirements.

6.3 CHANGES TO THE PROCESS CONTROL PROGRAM 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 shell contain:

(a) Sufficient information to support the change together O 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.

(2) Shall become effective after review and acceptance by 50RC, and the approval of the Vice President, Nuclear Operattons.

6.4 D.QCUMENTATION 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.

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CPSES/PCP l

!-h 6.5 TRAINING TV Electric and vendor personnel responsible for waste I

PROCESSING, packaging and transportation activities shall' be trained and qualified to ensure that waste PROCESSING is I performed in accordance with applicabl_e requirements. Training programs shall establish a schedule for periodic requalification of at_least once every two years. TV Electric shall verify the j training of vendor personnel.

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12/90

CPSES/PCP SECTION

7.0 REFERENCES

7.1 Code of Federal Regulations:

7.1.1 Title 10, Parts 20, 61, and 71 7.1.2 Title 49, Part 173 7.1.3 Title 40, Part 261 7.2 USNRC, Low Level Waste Licensing Branch, Technical Position on Radioactive Waste Classification, May 1983 7.3 USNRC, Low level Waste Licensing Branch, Technical Position on Waste Form, May 1983 7.4 USNRC, Guidelines for Preparation and Implementation of a Solid Waste Process Control Program (Proposed), Draft Revision 3, September 1986 7.5 USNRC, Office of Inspection and Enforcement, IE Information Notices:

7.5.1 IEN 79 09, " Spill of Radioactively Contaminated Resins" 7.5.2 IEN 83-14 "Dewatered Spent lon Exchange Resin Susceptibility to Exothermic Chemical Reaction" 7.5.3 IEN 85-92, Surveys of Wastes Before Disposal from Nuclear Reactor Facilities" 7.5.4 IEN 86 20, " Low-level Radioactive Waste Scaling Factors, 10 CFR Part 61" 7.5.5 IEN 87-03, " Segregation of Hazardous and Low-Level Radioactive Wastes" 71 12/90

CPSES/PCP 7.5.6 IEN 87 07, " Quality Control of Onsite Dewatering / Solidification Operations By Outside Contractors" 7.5.7 IEN 88 08, ' Chemical Reactions With Rad'onctive Waste Solidification Agents" 7.5.8 IEN 89 27, " Limitations on the Use of Waste Forms 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 7.7 CPSES Station Administrative Procedure STA 709, " Radioactive 1 Waste Management Program" 7.8 CPSES Radiation Protection Instructions:

7.8.1 RPI-203, " Shipment of Radioactive Materials" 7.8.2 RPi-204, " DAW Processing" 7.8.3 RPI 205, "Liquio Waste Processing" 7.8.4 RPI 209, " Radioactive Waste Classification" 7.8.5 RPI 216, " Waste Steam Sampling and Data Base 1 Maintenance" 7.9 CPSES Chemistry Procedures:

7.9.1 CHM 517, " Chemistry Control of Liquid Waste Systems" 7.10 CPSES Radioactive Waste Systems Procedure RWS 301, "Radwaste Solidification Systems" O

l l

l 72 Rev. I 12/90

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CPSES/PCP 7.11 Vendor Documents 1

7.11.1 CNSI 0W llllB 01 NP A, " Dewatering Topical - Chem- 1 Nuclear Systems, Inc." 1 7.11.2 S0 0P-003, " Process Control Program for CNSI Cement 1 Solidification Units' 7.11.3 CNSI-2 (4313 01354 01P-A) Rev. 2, " Topical Report 1 for Chem Nuclear Systems, Inc., Hobile Cement Solidification Systems" l

7.12 TV Electric CPSES Quality Assurance Manual O

O 73 Rev. 1 12/90

PROCESS CONTROL PROGRAM

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V. EFFECTIVE PAGE LISTING grd EFFECTIVE REVISION /DATE i December 1990 11 December 1990 tii December 1990 iv December 1990 1-1 Revision 1 1-2 Revision 1 1-3 December 1990 14 December 1990 1-5 Revision 1 1 6 (Figure 1-1) Revision 1 21 December 1990 22 December 1990 2-3 Revision 1 2-4 Revision 1 3-1 Revision 1 32 Revision 1 33 Revision ;

-(o; 3-4 Revision 1 v 3-5 Revision 1 3-6 Revision 1 3-7 Revision 1 3-8 Revision 1 3-9 December 1990 3 10 Revision 1 4-1 Revision 1 4-2 Revision 1 5-1 Revision 1 5-2 Revision 1 53 Revision 1 5-4 Revision 1 5-5 Revision 1 5-6 Revision 1 5-7 Revision 1 5 8 (Figure 5 1) December 1990 .

5-9 (Figure 5-2) Revision 1 5-10 (Figure 5-3) December 1990 6-1 December 1990 6-2 December 1990 6-3 December 1990 V 7-1 December 1990 7-2 Revision 1 .

7-3 Revision 1 EPL-1 December 1990 l