ML20072S840

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Rev 5 to Davis-Besse Process Control Program
ML20072S840
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 12/18/1992
From:
TOLEDO EDISON CO.
To:
Shared Package
ML20072S827 List:
References
PROC-921218, NUDOCS 9409140263
Download: ML20072S840 (9)


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C8 k,_el DAVIS-BESSE PROCESS CONTROL PROGRAM REVISION 5, 1992 Effective Dates fs

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Approval r4 , 'O Sky SRB Chairman g Dafte M&b 4 Am%j Plan t' Manager i g8DEC::^

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9409140263 940826 DR ADOCKOSOOg6

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Davis-Besse PCP LIST OF EFFECTIVE PAGES Revision 5 ]

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LOG OF PREVIOUS REVISIONS

- Revision Approval / Effective Date 0 2/21/84

.1 8/29/85-2 5/21/86 O 3 4

1/27/89 2/22/91 O

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Davis-Besse PCP Revision 5 2 of 8 DAVIS-BESSE NUCLEAR POVER STATION PROCESS CONTROL PROGRAM ,

Solid Radioactive Vaste Process Control Program i

l I. PURPOSE l l

The processing of radioactive vaste for disposal at a licensed I radioactive vaste burial site requires that the vaste be i appropriately analyzed, processed and packaged, representing a final l vaste form that is acceptable for transportation to and burial at l a licensed radioactive vaste disposal site. The purpose of this Process Control Program is to document the radioactive vaste i processing methods and the quality control steps that are taken '

at Davis-Besse to verify compliance with applicable regulatory 1 requirements and, in particular, to assure an acceptable vaste I product meeting the applicable vaste stability characteristics of 10 CFR 61.56.

This Process Control Program covers all major vaste processing

streams at Davis-Besse and the resulting final vaste products, including

. Compressible and non-compressible trash; Spent aqueous system filter cartridges; g

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. Spent resins; and

. Use of contractor for vaste processing.

This Process Control Program shall be used to verify the i Solidification or Devatering of at least one representative test l specimen from at least 10% of the batches of each type of vet radioactive vaste (e.g., filter sludges, spent resins, evaporator bottoms, boric acid solutions, and sodium sulfate solutions).

Solidification shall be the conversion of vet radioactive vastes into a form that meets destination vaste disposal site criteria l

by the removal of freestanding water through chemical processes.

Devatering shall be the conversion of vet radioactive vastes into a form that meets destination vaste disposal site criteria by the removal of freestanding water through physical processes.

l If the provisions of this Process Control Program are not satisfied, shipments of defectively processed or defectively packaged solid radioactive vastes from the site shall be suspended.

The requirements for solid radioactive vaste handling and disposal given under this program provide assurance that solid radioactive materials shipped offsite, meet destination disposal site requirements and are packaged in conformance with 10 CFR Part 20, 10 CFR Part 71, 10 CFR Part 61 and 49 CFR Parts 170-178.

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Davis-Besse PCP' Revision 5 II. REGULATORY OVERVIEV All.vaste processing, packaging and shipping are conducted in accordance with approved procedures to assure compliance with applicable federal, state and burial site requirements. Vaste processed for disposal is evaluated for compliance with:

1. The vaste classification requirements of 10 CFR 61.55.
2. The vaste characteristic requirements of 10 CFR 61.56.

The manifest reporting requirements of 10 CFR 71 and-

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3.

10 CFR 20.2006.

Packaging of vaste is in containers meeting DOT specifications and is appropriate for the applicable vaste class. Shipments are conducted in accordance with the requirements of 49 CFR 172-177 and 10 CFR'71.

All vaste processing is performed in a manner consistent with the principles of ALARA. . The procedures that have been developed to cover vaste processing operations address appropriate radiation safety measures such as job preplanning (RVP), radiation source shielding, and job prerequisites and' material requirements so as to minimize stay times.

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III. SOLID RADVASTE PROCESSING AND PACKAGING Prior to the placing.of any radioactive material in a container for shipment off-site, a visual inspection of the container's general condition and integrity is conducted. Specific items leading to potential container degradation that are examined and could result in rejection for use as a radvaste disposal container include

. Punctures

. Corrosion

. Cracked, separated, incomplete, or otherwise defective seams and welds

. bent, dented, cut or degraded gaskets and/or sealing surfaces Also, specific criteria prohibit the inclusion of liquid waste (e.g., free liquids,) and plastic wastes containing liquids (e.g.,

for devatering spent resins).

Compressible and Non-Compressible Vaste Miscellaneous compressible and non-compressible vastes are routinely ~ collected throughout the radiologically controlled O areas of the plant for the purposes of general housekeeping and radiological control.

Davis-Besse PCP Revision 5 4 of 8 Prior to filling a drum or a box vith vaste, the container is appropriately labeled. The loading of compressible and non-compressible vaste is conducted in a manner consistent with the philosophy of volume reduction and minimization of void  !

spacing. After completion of vaste compaction and/or container loading, each container is sealed, weighed and placed in I radvaste storage, pending shipment to a licensed vaste disposal  ;

site. i Liquid System Cartridge Filters l Cartridge filters can be a high radiation and/or contamination hazard, all spent filter removals are performed under health physics surveillance. Filters are placed in shielded storage to allow for radioactive material decay prior to placing in an approved, appropriate shipping container (e.g., high integrity container or HIC). j Spent Resin - Primary System Spent resins from primary systems are transferred from the Spent Resin Storage Tank to an appropriate disposable container in accordance with approved plant procedures. Normally transfer is to an HIC; however, a carbon steel container may be used provided radioactive material levels meet the criteria for Class A vaste per the requirements of 10 CFR 61.55. After transfer to a disposable container, the container is devatered in accordance with vendor-approved procedures that have been specifically developed for the devatering of resins for the applicable  !

vendor-supplied container. The specifics of the devatering ,

process must adequately demonstrate the removal of essentially )

all free standing water (i.e., meeting the free standing liquids I requirements of 10 CFR 61.56). Additional administrative l controls taken to assure the proper devatering of resin  !

utilizing vendor-supplied procedures and equipment, are addressed in Section IV.

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Spent Resin - Miscellaneous Vaste Monitor Tank Influent Processing Liquid radvaste from the miscellaneous vaste drain tank or the detergent vaste drain tank is processed when necessary thru an in-plant system provided for that purpose. The system consists of a combination of sluiceable resin vessels and a mechanical fil;ar vessel. The resin is transferred from the miscellaneous liquid vaste demineralizer to an appropriate disposal container.

The disposal container is normally a high-integrity container but a carbon steel disposal container may be used if the vaste satisfies all federal, state and disposal site criteria for the use of containers that do not provide stability.

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' O Q 5 of 8 The contents of the disposal container are devatered in accordance with approved procedures that are specific to the 2

type and vendor of the disposal container being used.

1 The devatering processes as provided by procedures must adequately demonstrate the removal of essentially all.

4 free-standing liquids (i.e. meeting the free-standing liquids

, requirements of 10 CFR 61.56). Additional administrative controls taken to assure the proper devatering of resin i utilizing vendor supplied procedures and equipment, are addressed in Section IV.

I The pH of influents to vaste processing systems is monitored l to assere the potential for an exothermic reaction in the processing system resin is minimized.

Spent Resin - Condensate Polishing Domineralizer Holdup Tanks i The processing of resin slurries from.the condensate polishing demineralizer holdup tanks is performed by a contractor-supplied i system. Refer to Section IV below for the administrative and operational controls that are taken to ensure the generation of an acceptable vaste product.

Spent Resin - Potential Exothermic Reactions Since we are not solidifying at Davis-Besse, exothermic 3 reactions which could potentially occur during the j solidification process vould not be a consideration. If, in i the future, a solidification process is used, an appropriate

{ time vill be allowed before solidifying to avoid any pressure

{ extremes in the closed container or matrix.

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IV. USE OF CONTRACTOR FOR VASTE PROCESSING 4

Contractor-supplied services may be used at Davis-Besse for the

processing of radioactive vaste, including miscellaneous radvaste

) liquids, oil vaste, and other types of vaste resulting from both l routine and non-routine operations. For the operation of such process systems, it may be desirable to use process control measures and procedures developed by the contractor specifically for the j system. Therefore, previously addressed process control measures j for a particular vaste stream may, as appropriate, be superseded 4

by contractor-supplied measures. The following discussion addresses t the administrative controls that are imposed to assure that contractor-supplied systems and services for processing radioactive vaste for disposal at a burial site are compatible with plant j operations, procedures and regulatory requirements.

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Davis-Besse PCP Revision 5 6 of 8 lf Prior to the use of any contractor for the processing of vaste I at Davis-Besse, a management review of the contractor's process controls and operating procedure is performed for the purpose of assuring safe operation in accordance with plant procedures and applicable , regulatory requirements. For the processing of vaste that is intended to be shipped for disposal at a licensed radioactive vaste burial site, additional precautions are taken ,

to assure a final vaste product that meets the appropriate vaste l characteristic requirements for solidification or devatering. l In particular, the following items, as applicable, are to be documented by the contractor (or Davis-Besse manuals or procedures) prior to utilization for solid vaste processing:

. a general description of the solidification process, including type of solidification agent, major process i equipment and interface with plant equipment, type of vastes l that can be processed, and operating parameters. l 1

. A process control program that provides for the verification ,

of the generation of a suitable vaste product, including i items such as representative sampling, laboratory tests to establish vaste-to-process medium ratios, and criteria for evaluating acceptability of the final vaste product.

If any test specimen fails to verify devatering/ solidification, the devatering/ solidification of that batch under test shall be suspended. Alternate devatering/ solidification parameters can then be determined. If a subsequent test verifies devatering/

solidification, devatering/ solidification of the batch may then be resumed using the alternative parameters.

If a test specimen fails to verify devatering/ solidification, testing of a representative specimen of the same type vet vaste from consecutive batches shall be performed until at least 3 consecutive test specimens demonstrate devatering/ solidification.

This Process Control Program shall be modified as required, as provided in Technical Specification 6.14, to assure solidification of subsequent batches of vaste.

V. Major Changes to Radioactive Solid Vaste Treatment Systems Licensee initiated major changes to the solid radioactive vaste system:

1. Shall be reported to the Commission in the update to the Safety Analysis Report. The discussion of each change shall contains
a. A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR Part 50.59;

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b. Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;
c. A detailed description of the equipment, components and processes involved and the interfaces with other plant systems;
d. An evaluation of the change, which shows the predicted l releases of radioactive materials in liquid and gaseous j effluents and/or quantity of solid vaste that differ from those previously predicted in the license application and amendments thereto; j e. An evaluation of the change, which shows the expected i maximum exposures to individual in the UNRESTRICTED AREA and l to the general population that differ from those previously.

estimated in the license application and amendments thereto;

f. A comparison of the predicted. releases of radioactive l materials in solid vaste, to the actual releases for the period prior to when the changes are to be made; i

l g. An estimate of the exposure to plant operating personnel as

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a result of the change; and ws

h. Documentation of the fact that the change was reviewed and

! found acceptable by the Station Review Board.

2. Shall become effective upon review and acceptance by the Station Review Board.

VI. Definitions

1. DEVATERING the conversion of vet radioactive vastes into a form that meets destination vaste disposal site criteria by removal of freestanding water through physical processes.
2. PROCESS CONTROL PROGRAM (PCP) details the sampling, analysis, and evaluation from which SOLIDIFICATION or DEVATERING radioactive vastes from liquid systems is assured.
3. SOLIDIFICATION the conversion of wet radioactive vastes into I a from that meets destina on vaste disposal site criteria by removal of freestanding water through chemical processes.

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