ML20082K821
| ML20082K821 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/03/1991 |
| From: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | |
| Shared Package | |
| ML20082K806 | List: |
| References | |
| VPAP-2104, NUDOCS 9109030048 | |
| Download: ML20082K821 (16) | |
Text
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.. l P OR M T 03 0 4.Y l O
VIR0lNIA POWER Station Administrative Procedure M: Radioactive Waste Process Control Program (PCP)
Lia.d, Denartment: Radiological Protection Deedure Number: Revision Number: Effective Date:
VPAP 2104 1 05/10/91 Revision Summary:
- 1. Item 3.1.6, add revision date for BTP on Waste Form
- 2. Item 3.1.17, add reference for US Ecology Topical Report
- 3. Item 4.5, revise section number to reflect new BTP
- 4. Item 6.1.2.a. add "and/or evaporator bottoms"
- 5. Item 6.2, add NOTE associated with solidification as performed at Surry Power Stations Radwaste Facility VRGI A 30WIR 3RD?ERIi Thin exu ent t .s nm n% 7, y g '
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Surry Power Station North Anna Power Station Approved by:
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. VIRGINIA VPAP 2104 POWER REVISION 1 PAGE 2 OF 16 TABLE OF CONTENTS Section Pagt 1.0 PURPOSE 3 2.0 SCOPE 3 3.0 REFERENCE /C0hth11ThtENT DOCUMENTS 3 4.0 DEFINITIONS 4 5.0 RESPONSIBILITIES 6 6.0 INSTRUCTIONS 7
.~,,1 General Descriptions and Requirements 7 6.1.1 Types of Wet Radioactive Waste 7 6.1.2 Waste Sources 7 6.1.3 Requirements for Processing Wet Radioactive Waste .
8 6.1.4 Process Contml P.ogram Implementing Procedures 8 6.1.5 Requirttnents For Use of Contractor Services 9 6.2 Solidifleation of M , Waste 10 6.2.1 Solidification Pammeters 10 6.2.2 Adverse Chemical Reactions During Solidification 10 6.2.3 Sampling. Analysis. and Process Surveillance 11
- 6.2.4 Processing Acceptance Criteria 12 6.3 Dewatering and Encapsulation of Filttr Elements 13 I
6.3.1 General Requirements 13 6.3.2 Filter Elements to be Disposed of as Class A Waste 13 - 6.3.3 Filter Elements to be Disposed of as Class B or C Waste 14 6.4 Reporting Requirements 15 6.4.1 Major Changes to Radioactive Solid Waste Treatment Systems 15 l 6.4.2 Changes to the Process Control Program (PCP) 16 7.0 RECORDS 16
,. VIRGINIA VPAP.2104 POWER REVISION 1 PAGE 3 OF 16 1.0 PURPOSE This procedure establishes Virginia Power's PROCESS CONTROL PROGRAM (PCP) including associated requirements and responsibilities. The PCP provides instructions for pmcessing and packaging of wet radioactive wastes to assure compliance with applicable Federal and State regulations for disposal of solid radioactive waste.
2.0 SCOPE This procedure is applicable to the processing and packaging of wet radioactive waste performed at or by the Station. Systems and procedures used for implementing the PCP, including vendor supplied systems and procedures, shall be considered a pan of the PCP.
3.0 REFERENCES
/ COMMITMENT DOCUMENTS 3.1 References 3.1.1 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Pnx!uction and Utilization Facilities 3.1.3 10 CFR 61, Licensing Requirements for Land Disposal of Radioactive Waste 3.1.4 10 CFR 71, Packaging and Transponation of Radioactive Material 3.1.5 49 CFR Pans 170 to 189, Depanment of Transportation Regulations for Transponation ofllazardous Materials 3.1.6 USNRC I.ow 1.evel Waste Licensing, Branch Technical Po's ition on Radioactive t Waste Classification (May 1983 Rev. 0) and Technical Position on Waste Form, (January 1991, Rev.1) l 3,1.7 INPO 88-010, Guicelines for Rad:ological Protection at Nuclear Power Stations 3.1.8 NUREG 0800, USNRC, Standard Review Plan 11.4, Solid Waste Management Systems, Rev 2, July 1981 [
3.1.9 NRC Generic letter 89-01, Implementation of Programmatic Controls for l Radiological Effluent Technical Specifications (RETS)in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the PROCESS CONTROL PROGRAM , , 3.1.10 Surry and Nonh Anria Technical Specifications 3.1.11 NODS lip 01, Radiation Protection Plan l 3.1.12 VPAP 0102. Station Nuclear Safety and Operating Committee l _. ~ , . - -.
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o VIRGINIA VPAP 2104 : POWER REVISION 1 . PAGE 4 OF 16 l I 3.1.13 VPAP 2101, Radiation Protection Plan
.i 3.1.14 VPAP 2103,Offsite Dose Calculation Manual (ODCM) !
4 3.1.15 VPAP 3001, Safety Evaluations (when issued) ! 3.1.16 Chem Nuegar Systems,Inc. Letter (conceming limitation of package void space), : October 6,1989. OAR 196 89,[4605g] ! 3.1.17 US Ecology Topical Report USE-61002 P. NRC Docket No. WM 102 " Stability of low 1.cvel Radioactive Wastes Solidified with liigh Strength Asphalt, Rev. 0" 3,2 Commitment Documents ! None 4,0 DEFINITIONS 1 NOTEt Terms which are defined in Surry and North Anna Technical Specifications appear as all capitalized letters in the text of this pmcedure for identification. 4.1 Hatch :
- A quantity of waste that is or may be mixed to produce a homogeneous mixture for the ,
t purposes of sampling, testing, and processing. Different samples of a homogeneous mixture are expected to exhibit similar chemical and physical properties. , 4,2 l Composite - A mixture of samples, proportional by volume to the individual transfers making up a batch, that creates a test specimen repstsentative of the batch. 4,3 Free Liquid Free liquid is the liquid still visible after solidification or dewatering is complete, or is drainable from the low point of a punctured container (NRC SRP 11.4, ETSB 11 3). , 4.4 .lligh Integrity Container A container designed to provide long term structural stability to contained waste during the - required disposal perici May be used as an attemative to waste solidification. See section C 4 of NRC BTP (Waste Form) for more details. High integrity containers mus' be approved by the appropriate agency. , Uw.. , r .yw-m----~m-my,m ,,,y-,ye. . . . , . , ,,w-,ww,w'.-,c.,v-yy., _m,,%..m.,,,w,,.,-.-,-,w%,y s,--.,--#-.-ym.,~~y,
VIRGINIA VPAP 2104 IOWER REYlSION 1 PAGE 4A OF 16 SUPPLEhlENTAL REFERENCE PAGE This Supplemental Reference Page is provided to aid the procedure user in detennining the appropriate procedures to use until such time that proceduns referenced in the References Section, which reflect "When issued", are approved and issued,
- n. Upgraded Procedure Reference VPAP 3001, Safety Evaluations (When /ssued)
The following existing procedures shall be used with respect to Safety Evaluations until such time that the new referenced procedure is approved and issued:
- a. Surry
- 1. SUADht LR 12, Safety Analysis /10CFR50.59/10CFR72.48 Safety Evaluations and Justifications for Continued Operations
- b. North Anna
- 1. ADht.3.9.10CFR 50.59 Safety Evaluation and JCOs (North Anna)
- 2. ADht 3.15, Tracidng of Justifications for Continued Operation (JCO)
NOTE: This Supplemental Refemnce Page shall be amoved and processed as directed upon notification from Records hianagement. j T i t 1 i
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\ . VIRGINIA VPAP.2104 POWER REVISION 1 PAGE 5 OF 16 4,5 Non. Corrosive Llquid in lieu of specific tests, a liquid may be considered non-corrosive ifit has a pil between 4 and 11 (based on section C.2.g of NRC BTP (Waste Form)).
4.6 Process Control Program The PROCESS CONTROL PROGRAM OCP) shall contain the current formulas, sampling, analyses, tests and determinations to crisure that processing and packaging of solid radioactive wastes, based on demonstrated processing of actual or simulated wet solid wastes, will be accomplished in a w ay that assures compliance with 10 CFR Parts 20,61 and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste. 4.7 Site Iloundary The SITE BOUNDARY is that line beyond which the land is not owned, leased, or otherwise controlled by Virginia Power. 4.8 Solldlfication Solidification is the conversion of wet waste into a fonn that meets shipping and burial ground requirements. 4.9 Spent Ion Exchange Mate.lal Organic resins and other ion exchange materi11 are considered spent w hen decontamination factors decrease significantly or when activity levels reach a pre-determined level. 4.10 Stabilization or Stability A structurally stable waste form will generally maintain its physical dimensions and its form under the expected disposal conditions. Structum) stability can be provided by the waste form itself, processing the waste to a stable form (e.g solidify), or placing the waste in a disposal container or structure that provides stabilitv after disposal (10 CFR 61.56(b)). 4.11 Test Specimen #. A sample obtained from a batch of waste to be processed (solidified or absorbed), or a simulated sample of similar chemical and physical characteristics, on which a test can be performed to verify the intended pmcess will perform satisfactory.
., VIRGINIA VPAP 2104 POWER REYlS!ON 1 PAGE 6 OF 16 4.12 Unrestricted Area UNRESTRICTED AREA is defined as any area at or beyond the SITE BOUNDARY w here access is not controlled by Virginia Power for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the SITE BOUNDARY used for residential quaners or for industrial, commercial, institutional or recreational puqeses.
4.13 Wet versus Dry Wastes (from NRC SRP 11.4, IFTP ETSB 113) Radioactive waste is generated in the forms of" wet" and " dry" wastes. Wet wastes, including spent ion exchange material, filter sludge, evaporator concentrates, and spent cartridge filter elements, normally are byproducts from liquid processing systems. Dry wastes, including activated charcoal, HEPA filters, rags, paper, and clothing, nonnally are byproducts from ventilation air and gaseous waste processing systems, and maintenance and refueling operations. 5.0 RESPONSilllLITIES ; 5.1 IIcalth Physics Health Physics (HP)is responsible for: 5.1.1 Implementing the PROCESS CONTROL PROGRAM as a pan of the Radiaton Protection Program. 1 5.1.2 Ensuring that vendors brought on site by Health Physics to perform waste processing ' are cognizant of responsibilities in accordance with this procedure. 5.1.3 Maintaining procedures necessary for iruplementing the PCP. ; 5.2 Operations Department The Operations Department is responsible for: 5.2.1 Implementing the PROCESS CONTROL PROGRAM as part of normal Station operations. 5.2.2 Ensuring that vendors brought on site by Operations to perform waste processing are , j
- cognizant of responsibilities in accordance with this procedure.
1 5.2.3 Maintaining procedures necessary for implementing the PCP. l
.. VIRGINIA VPAP.2104 IVWER REVISION 1 PAGE 7 OF 16 6.0 INSTRUCTIONS 6,1 General Descriptions and Requirernents 1 6.1.1 Types of Wet Radioactive Waste i 1
Wet radioactive wastes produced at the Station w hlch must be processed for disposal ) include:
- Resin
- Filterelements
- Waste oil
. Liquid waste i
6.1.2 Waste Sources
- a. Station systems which normally pmcess radioactive liquids with the subsequent !
generation of spent radioactive ion exchange bead resin an&or filter elements and/or evaporator bottoms which must be pmcessed for disposal are:
. Primary Coolant System
. Boron Recovery System
+ Spent Fuel Pit Purification System
+ Vent and Drain System
+ Liquid Waste Pmeessing System
- b. If primary to secondary leakage occurs while the Condensate Polishing System is processing secondary condensate, resin and filter elements used in the system may become radioactive, if so, they shall be processed for disposal.
- c. Iflubricating/ cooling oil becomes contaminated with radioactive material, and if the oil is to be disposed of as radioactive waste in a licensed land disposal facility, the oil shall be considered and processed as wet radioactive waste.
- d. If liquid wet waste is produced which must be disposed of (e.g., evapomtor bottoms or decontamination solutions) it shall be treated as wet radioactive waste.
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4, VIRGINIA VPAP 2104 IOWER REVISION 1 PAGE 8 OF 16 6.1.3 Hequirements for Processing Wet Radioactive Waste
- a. Liquids which are to be processed as radioactive waste shall be processed by mlidification.
- b. Resins shall be processed by dewatedng and/or solidification.
- c. Filter elements shall be processed by dewatering or encapsulation in a solidification binder.
- d. W6ste oil shall be pacessed by solidi 6 cation or transferred to a licensed waste processor for disposal.
- e. Class B and Class C waste shall be stabilized prior to disposal (10 CFR 61).
- f. Cenain categories of Class A waste shall be stabilized prior to disposal as required by the disposal site and/or the disposal site license conditions.
6.1.4 Process Control Program Implementing Procedures
- a. Proceduns shall be maintained as necessary to implement the PCP. Procedures shall include acceptable methods for:
- 1. Radioactive waste sampling, analysis and waste classification. Waste classification shall be performed per 10 CFR 61.55, Waste Classification, and methods set fonh in NRC BTP on Radioactive Waste Classification.
- 2. Radioactive waste pmcessing including waste solidification and stabilization.
Acceptance criteria shall meet criteria set fonh in:
- 10 CFR 61.56, Waste Characteristics
- NRC BTP on Waste Form
. Disposal site criteria
- 3. Radioactive waste packaging and shipping. Acceptance criteria shall meet requirements set fonh in:
10 CFR 20.311, Transfer for Disposal and Manifests
+ 10 CFR 71, Packaging and Transporting of Radioactive Material
+ 49 CFR 170 189, Transponation of Hazardous Materials
- 4. Dewatering ion exchange resin.
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,, VIRGIN 1A VPAP.2104 POWER REVISION 1 PAGE 9 OF 16 6.1.5 Requirements For Use of Contractor Services The following actions shall be taken before a contractor supplied waste processing system is used on site:
- a. Obtain the following, as a minimum, for review and evaluation:
- A detailed system description, which may be included in a topical report or equivalent documentation
. System operating procedures, which include process control parameters
. A list of required physical interfaces and Station materials / services
. A list of chemicals to be brought on site, quantity to be used and material safety data sheets for each chemical
. A list of expected utility / contractor responsibilities including disposal of unused and contaminated chemicals
. Vendor's document control procedures / manual to ensure controls are in place which prohibits use of procedures not approved by Station Nuclear Safety Operating Committee (SNSOC)
- b. Compare the system description and operating procedures to the requirements provided in Subsection 6.2, Solidification of Wet Waste. Ensure that the system can be operated within requirements,
- c. Submit system operating procedures to SNSOC for review and approval in accordance with VPAP-0102, Station Nuclear Safety and Operating Committee.
Processing of radwaste shall not be performed without approved operating procedures, d, Ensure the contractor provides a system as proposed, described, and approved for u:e at the Station. 1 [
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.. VIRGINIA VPAP 2104 POWER REVISION 1 l PAGE 10 OF 16 !
6.2 Solidl0 cation of Wet Waste NOTE: Solidification performed at Surry Power Station's Radwaste Facility will be in accordance with approved procedures that incorporate requirements found in Reference 3.1.17. l Procedures used for wet waste solidification shall incorporate the following requirements:
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6.2.1 Solidification Parameters
- a. As appropriate, parameters used when performing solidification tnay include, but are not limited to: i i
+ Waste type
+ Waste pH f
+ Ratios of waste / liquid to solidification agent / catalyst ;
+ Waste oilcontent
+ Waste principal chemical constituents
+ Mixing and curing times
- b. Once established, solidification parameters shall provide boundary conditions to ;
ensure that:
. Solidification is complete
+ Requirements for waste form stability are met
. Itere are no detectable free standing liquids 6.2.2 Adverse Chemical Reactions During Solidification Adverse chemical reactions between waste contaminants and solidification ojents may not be noticeable during specimen tests performed to develop solidifintion parameters.
To preclude such adverse chemical reactions, the following shall be perfomied prior to initial solidification of wet radioactive waste :
,' VIRGINIA VPAP 2104 POWER REYlSION 1 PAGE 11 OF 16 NOTE: Performance of this subsection is not required if solidification is to be performed by a vendor and results of such testing performed by the vendor was included in a technical trport describing the proposed solidification methodology.
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- a. Prepare large volume (e.g.,1 or 2 gallons) non radioactive mixtures of the waste stream chemicals potentially present (e.g., resin beads, boric acid, acids, bases, detergents, decontamination solutions).
- b. Solidify the mixture.
- 1. 'Ihe mixture shall be solidified using solidification procedure and parameters prepared for specified waste stream.
- 2. The solidification shall be performed within an insulated container to simulate the restricted heat removable capability of larger containers,
- c. Ensure the mixture solidifies without generating excessive temperatures or gases.
6.2.3 Sarnpling, Analysis, and Process Surveillance Wet radioactive waste shall be processed strictly in accordance with the approved solidification procedure for the specific waste stream substances to be solidified. Waste shall be sampled, analyzed, and compared to solidification parameters.
- a. Results of sample analysis shall be recorded on waste processing data sheets,
- b. A representative test specimen from at least every tenth batch of each type of waste to be solidified shall be used to verify solidificatiott. If any test specimen fails to solidify:
- 1. Solidification of the batch under test shall be suspended until such time as:
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. Additional samples can be obtained -
l l . Altemative solidification parameters can be determined H Subsequent tests verify solidification
- 2. Solidification of the batch may then be resumed using the attemative l solidification parameters determined.
- 3. A representative test specimen shall be obtained from each subsequent batch of the same type of waste and test solidification performed.
.* VIRGINIA VPAP 2104 POWER REVISION 1 PAGE 12 OF 16
- 4. Collection and testing of representative test specimens from each consecutive batch shall continue until three consecutive initial test specimens demonstrate solidification.
- c. If necessary, pmcedures shall be revised to ensure solidification of subsequent batches of waste.
- d. if provisions of the PROCESS CONTROL PROGRAM cannot be satisfied, suspend shipments of defectively processed er defectively packaged solid radioactive wastes fmm the site.
6.2.4 Solidification Acceptance Criteria NOTE: The following are general considerations. Specific site disposal criteria must be addressed based on the site to be used. Procedures for wet radioactive waste solidification shallincorporate the following requirements:
- a. Containers for processed waste shall be filled to at least 85% of capacity, if a container is processed to less than 85% of capacity, it shall not be shipped for disposal prior to approval from the disposal site,
- b. Solid waste that contains liquid shall have as little free standing liquid as is reasonably achievable, but in no case shall the liquid exceed 1% of the volume.
The liquid shall be noncorrosive, l If a high integrity container is not used, the maximum free liquid is 0.5% of the waste volume.
- 2. If a high integrity c'>ntainer is used, the maximum free liquid is 1.0% of the waste volume.
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.. i VPAP.2104 !
.- VIRGINIA POWER REVISION 1 I PAGE 13 OF 16 ! r 6.3 Dewatering and Encapsulation of Filter Elements , NOTE: Filter elements are nonelly mechanical filters with wound fiber canridges used for f removing paniculates from liquid systems. This procedure is only applicable to filter ! elements which are of the cartridge type. ;
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6.3.1 General Requirements f
- a. Spent filter elements removed from systems shall be placed in appropriate storage to await processing and shipment.
- b. Processing of spent fdter elements shall be based on waste classification of filter.
NOTEt Tbe following are general con.iderations. Specific site disposal criteria must be add *essed based on the site to be used.
- 1. If filter media is classified as Class A waste and does not contain nuclides with half lives greater than 5 years which have a total specific activity of 1 pCi/cc or greater,it may be disposed of as Class A waste.
f 2, if fdter media is classified as Class D or Class C waste (per 10 CFR 61.55), it [ shall be encapsulated in a solidification media prior to disposal or disposed of in a high integiity container (NRC BTP, C.5 (Waste Form)). P 6.3.2 Filter Elements to be Disposed of as Class A Waste i
- n. Fihers should be allowed to drain dry in such a manner that any liquid trapped in voids is allowed to drain,
- b. Filters shall not be compacted unless they are first allowed to dry essentially free of moisture, ,
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- c. If moist filters are to be packaged without compaction:
- 1. 'Diere shall be no indication of moisture on the filter in the form of drops or ;
surface wetness.
- 2. Place filters in a container or plastic bag to which absorbent material has been placed to absorb unintentional and incidental amounts of liquids. The amount of absorbent material should be equal to at least one.fourih the volume of filter.
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. o .. YlRGINIA YpAP.2104 IOWER REVISION 1 PAGE 14 OF 16 t
- d. Ensure documentation indication package contents describes the prrsence of nlters.
6.3.3 Filter Elements to be Disposed of as Class 11 or C Waste i
- a. If filters are to be solidified by being encapsulated in a solidification media: l
- 1. Place filters in a suitable container such that filters will be completely !
surrounded by the solidification media when added. A basket type armngement of thin wire is recommended to hold filters in a fixed geometry. NOTE: The solidification media, including absence of free liquid, must be tested and documented in a manner required for solidification described in subsection 6.2, Solidification of Wet Waste. ;
- 2. Fill container with solidification media until filters are completely covered and !
container is filled to at least 85% of capacity.
- 3. Place solidified filter container in container appropriate for shipping and ,
disposal at specified disposal site. A high integrity container is recommended to ensure compliance with all requirements.
- b. If an encapsulated filter is to be disposed ofin a high integrity container, properly place the container with the encapsulated filter in a high integrity container,
- c. If an un encapsulated filter is to be disposed of in a high integrity container:
- 1. Place filters in conta:ner such that filters will be held in a fixed geometry and such that liquids will not be trapped within filters. A basket type arrangement ;
of thin wire is recommended to hold filters provided container's C of C will not be violated.
- 2. If resin will be added, proceed with resin addition as appropriate.
- 3. Dewater the container, as applicable.
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.. YlRGINIA VPAP 2104 POWER REVISION 1 PAGE 15 OF 16 i 6.4 Reporting Requirements
[ 6.4.1 Major Changes te Radioactive Solid Waste Treatment Systems j NOTE: Information required by this subsection to be reponed to the NRC may be submitted as part of the annual FSAR update. ( Major changes to the radioactive solid waste systems:
- a. Shall become effective upon review and acceptance by SNSOC. l f
- b. Shall be reponed to the NRC in the Semiannual Radioactive Effluent Release I Repon for the period in which the evaluation was reviewed by SNSOC. The !
discussion of each change shall contain: l
- 1. A summary of the evaluation that led to the determination that the change could !
be made in accordance with 10 CFR Pan 50.59. Such evaluations shall bc made in accordance with VPAP 3001, Safety Evaluations. ;
- 2. Detailed information sufficient to totally support the reason for the change l without benefit of additional or supplemental information.
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- 3. A detailed description of equipment, components, and processes involved and ,
interfaces with other plant systems, j
- 4. An evaluation of the change,in quantity of solid waste differing fmm that previously predicted in the license application and amendments to the i application.
- 5. An evaluation of the change, which shows the expected maximum exposures to individualin the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license and amendments.
- 6. A comparison of the predicted releases of radioactive materials in solid waste, to the actual releases for the period prior to the changes. f L 7. An estimate of the exposure to plant operating personnel as a result of the !
change.
- 8. Documentation of SNSOC review and approval. ;
i t 9 i l l N. - - - - . . .- . . - - , . . . - . . . - - - -. -. -, ._,._:
.. VIRGINIA YPAP 2104 POWER REVISION 1 PAGE 16 OF 16 6.4.2 Changes to the Process Control Program (PCP)
Changes to the PCP shall be:
- a. Documented; reviews shall be retained as Station reconis. Documentation shall include:
- 1. Information to suppon the change together with the appropriate analyses or evaluations justifying the changes.
- 2. A determination that the change will maintain the ovtrall confonnance of the solidified waste product to existing requirernents of Federal. State, or other applicable regulations,
- b. Reviewed and approved by SNSOC and Plant Manager prior to implementation.
7.0 RECORDS
' Die following individual / packaged documents and related correspondence completed as a result of the performance or implementation of this procedure are records. Records shall be transmitted to Records Management in accordance with VPAP.1701, Records Management.
PROCESS CONTROL PROGRAM records shall include, but are not limited to:
. System description of any con:ractor's temporary processing system. Such a description may be provided in a topical repon or other equivalent documentation
- Approved solidification system operating procedures
+ Ds:a sheets used to record solidification data, including test specime.1 data
+ Records of reviews pezformed for changes made to the PROCESS CONTROL PROGRAM l
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