ML20090A560
| ML20090A560 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/13/1991 |
| From: | DETROIT EDISON CO. |
| To: | |
| Shared Package | |
| ML20090A441 | List: |
| References | |
| PROC-911113, NUDOCS 9203030017 | |
| Download: ML20090A560 (16) | |
Text
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Nuoleer Producti:n - Fermi 2 PCP Manuel I
Technic:1 Manuel R:visl:n 14 c
I Page 1 FERMI 2 PROCESS CONTROL PROGRAM
{
Revislen Summary:
1)
Cancelled procedure SD-OP-090.
2)
Added procedure SD-OP-090-48300. Process Control Pro 0 ram for Coment Solldlifcation of 011, Olly Studges, and Oil Residuos at Fermi li.
4 implementetlen Plan:
1)
This revision goes into effect upon approval.
2)
Ongoing work may proceed using previous revision.
3)
Procedures Coordination shallissue a Notice of New/ Revised Procedures to communicate this change.
4)
No additional training is required.
Attachments - None Enclosures - None ARMS - INFORMATION SE VICES -
Date approved://-/J 7 /
Release authorized by:
[. 7-/~_
Change numbers incorporated: NA I
Date / 6.'M 4 f t 43 /f h/
/
DSN PCP MANUAL.
Rev 14
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DTC TMPLAN File 1715.01 Recipient 9203030017 920220 PDR ADOCK 05000341 R
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t PCP Manual Revisicn 14 -
i Page 2 TABLE OF CONTENTS Pese 3
1.0 Introduction 5
2.0 References t
7 3.0 Responsibilities 8
4.0 Definitions l
D 10
' 5.0 Controls and Surveillance Requirements 11 6.0 Reporting Requirements 12 7.0 Procedufe 12 7.1 General Requirements 12 7.2 Solidification Requirements l
13 7.3 Dewatering Requirements 13 7.4 Encapsulation Requirements 13 7.5 '
- Solidification Process Control Program 14 7.6 Dewatering Process Control Program 14 7.7 -
Encapsulation Process Control Program
-15 8.0 Acceptance Criteria f
16 9.0 Documentation y
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R3 vision 14 Pags 3 1.0 WTRODUCTION 1.1 Purpene The Fermi 2 Process Control Program provides reasonable assurance that all Radweste processed at Fermi 2 will be processed to that the final product will be l
suitable for both transportation to a disposal facility and disposal at that facility.
L 1.1.1 The Fermi 2 Process Control Program contelns/ controls the sampling, i
analyses, testing and formulation determinations to be made to ensure that the processing and packaging of solid radioactive waste will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61 and 71 plus State, Burial Site and other requirements goveming the disposal of solid radioactive waste. Process parameters specified may include, but are not limited to, waste pH, oil content, weter content, solids content, ratio of solidification agent to waste and/or necessary additives for each type of anticipated waste, and the acceptable boundary conditions for 1
the process parameters shall be identified for each waste type, based on laboratory scale and full scale testing or experience.
1.1.2 Change Control - The Fermi 2 Process Control Program also specifies the controls over changes in waste processing methodologies to ensure that any revised methodology is adequate to meet the requirements of 1,1,1.
1.1.3 Reporting - The Fermi 2 Process Control Program specifies the required regulatory reports regarding solid waste shipments and changes to the solid radweste processing system.
i 1.1.4 Records - The Fermi 2 Process Control Program specifies the required records regarding reviews performed for changes to the Program.
1.2 Regulatory Basis 1.2.1 100FR20.311 d(3) requires that all radweste generators cont'act a quality control program to assure compliance with 10CFR61.55 and 61.56.
1.2.2 10CFR50, Appendix A. General Design Criterion 60, specifies that a nuclear power plant shall be designed to handle radioactive solid waste produced during normal reactor operation, including anticipated operational occurrences.
1.2.3 10CFR61.56 specifies minimum waste form requirements for all redweste, as well as specifications for stability when this is required by regulations or disposal site criteria.
1.2.4 The Nuclear Regulatory Commission's Technical Position on Weste Form, Revision 1, provides guidance on waste form test methods and results l
acceptable to the NRC staff for implementing the 10CFRG1.56 waste form requirements.
l-l l-
PCP Manual C:visl:n 14 Page 4 1.3 Administrative Controls 1.3.1 All waste processing methodologies requiring stability in accordance with reference 2.3 included in the Fermi 2 Process Control Program shall be in compilance with the Nuclear Regulatory Commission's Technical Position on Waste Form, Revision 1. In some cases, the Nuclear Regulatory Commission has granted interim approval to a methodology, pending final approval. It is
)
acceptable to use such methodologies when accompanied with an NRC interim approval cover letter.
1.3.2 Uconsee initiated changes to the Fermi 2 Process Control Program shall be processed and documented in occordance with Fermi 2 Technical toecification 6.13.2.
1.4 Semlannual Radioactive Effluent Release Report 1.4.1 Solid redweste shipmer.t data and discussions of major changes to the solid radioactive waste system shall be included in the Semisnnual Radioactive Effluent Release Reports in accordance with Technical Specification 6.9.1.8.
1.5 Records 1.5.1 Reviews performed for changes to the Formi 2 Process Control Program shall be retained in accordance with Technical Specification 6.10. Record Retention.
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PCP Manual Revision 14 Page 5
2.0 REFERENCES
2.1 NRC Technical Position on Weste Form, Revision 1 2.2 10CFR20, Standards for Protection against Radiation 2.3 10CFR61, Uconsing Requirements for Land Disposal of Radiative Material.
2.4 Formt 210CFR61 Compliance Program Manual 2.5 Technical Specification 6.10, Record Retention 2.6
'schnical Specification 6.13.2. Uconsee-intitiated Changes to the PCP 2.7 Technical Specification 6.15, Licensee-Intitlated Major Changes to Radioactive Uquid, Gaseous, and Solid Waste Treatment Systems 2.8 UFSAR Chapter 11, Radioactive Waste Management 2.9 NE-85-0722, Nuclear Engineering Letter to NRC concerning Fermi 2 Process Control Program 2.10 NUREG - 0800, Section 11.2. Liquid Waste Management Systems 2.11 NUREG - 0800, Section 11.4, Solid Waste Management Systems 2.12 Safety Evaluation 88-0186, Revision 1, Present Use of Radweste System Equipment 2.13 Safety Evaluation 91-0015, Temporary Storage of Mixed Waste in the Onsite Storage -
Facility (OSSF) 2.14 Design Calculation 4945, UFSAR Update Analysis for the Present Radwaste System Operations 2.15 Generic Letter 81-38, Storage of Low-Level Radioactive Wastes at Power Reactor Sites 2.16 Regulatory Guide 1.143, Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Ught-Water-Cooled Nuclear Power Plants 2.17. Utility Nuclear Weste Management Group (UNWMG) PCP Ouldelines, LLW-86-65 l
2.18 Chem-Nuclear Topical Report CNSI-2 (4313-01354-01) Mobile Coment Solidification System.
2.1g Chem-Nuclear Weste Form Topical P. sport, WM 97, WM 98, WM 101 l
2.20 CNSI RDS-1000 Radioactive Weste Dewatering System Topical Report, RDS-25506-01-P-A. Revision 1 2.21 CNSI Procedure FO-AD-002. Operating Guidelines for Use of Polyethylene High Integrity Containers 1
1.
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PCP Manual Revisien 14 Page 6 2.22 CNSI Procedure FO-OP-032-483, Set Up and Operating Procedure for the RDS-1000 Unit at Detroit Edison - Fermi 2 2.23 CNSI Procedure SD-OP-003, Process Coritrol Program for Solidification of Stable Weste Forms 2.24 CNSI Procedure SD-OP-048, Process Control Program and Operating Procedure for in-Situ Solidification of Suspended Objects 2.25 CNSI Procedure SD-OP-063, Set Up and Operating Procedure for the Coment Solidification Unit 2.26 NSI Procedure SD-OP-064, Operating Procedure for the Portable Coment Solidification Unit No.125 2.27 CNSI Procedure SD-OP-090-48306, Process Control Program for Cement Solidification of Oil, Olly Studges and Oil liesiduos at Fermi ll.
2.28 CNSI Procedure SD-OP-097, Process Control Program for Cement Solidification of Unstable Weste 2.29 CNSI Procedure SD-OP-098, Waste Solidification in Chem-Nuclear Systems, Inc.
Polyethyleno High Integrity Container 2.30 Regulatory Guide 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materialin Uquid and Oaseour Effluents from Light-Water-Cooled-Nuclear Powgr Plants, Revision 1, June 1974 l
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PCP Manual R:visi:n 14 Page 7 3.0 RESPONSIBILITIES 3.1 The Superintendent of Radweste/ designee is responsible for the implementation of the Fermi 2 Process Control Progrsm and ensuring the Vendors Process Control ProDram meets the requirements set forth by the NRC and that those Programs are approved by the OSRO prior to use.
3.2 The Radweste Supervisor is responsible for interfacing with contracted vendors. The purpose of this interface is to ensure the timely and efficient processing of waste forms generated at Fermi 2.
3.3 All personnel working under this procedure shall know their responsibilities to the ALARA Program.
3.4 The Vendor and General Supervisor, Radweste are to ensure that the general design of the processing equipment is in accordance with the vendors topical report and that this equipment is installed, and tested in accordance with Reference 2.2b for Solidification and 2.22 for Dewatering.
3.5 The Vendor and Radweste Supervisor are to ensure that the chemicals and/or materials used in a particular waste processing method are equal to or better than that which is required by the Vendor's approved Process Control Program.
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PCP Manuel Revisisn 14 Page 8 4.0 DEFINITIONS 4.1 Batch An isolated quantity of feed waste to be processed having essentially constant physical and chemical characteristics (i.e., the amount of waste contained within a tank). If new waste is added to the waste being processed then a new batch is created and further sampling is required.
4.2 Dry Active Waste (DAW)
Any dry radioactive material (i.e. contaminated tools, equipment, clothing, trash, etc.)
4.3 I watering The process of removing liquids from wet radioactive waste so that the form of waste is suitable for disposal.
4.4 Encapsulation The process of encapsulating,in coment, solid radioactive waste which is non-uniform in size and cannot normally be homogeneously mixed (i.e., filters, sources, etc.)
4.5 Free standing Liquid Uguld which is still visible after processing, or liquid drainable from the low point of a punctured container, 4.6 High integrity Container (HIC) p A container which provides stability Nr the type of waste being processed in accordance with Reference 2.3, 4.7 Prequalification Test Sample Test conducted on laboratory samples to demonstrate the ability to produce an acceptable waste form using the type of wet waste and solidification agent expected.
4.8 Production Test Sample
~A sample used to demonstrate the ability of the onsito solidification agent and waste batch to produce an acceptable waste form using the parameters identified ir the PCP.
4.9 Waste Classification The determination of waste class as outlined in Reference 2.3 (2.4) by radionuclide isotopic analysis and/or scaling factors between easy-to-measure isotopes and the difficult-to-measure isotopes.
PCP Menual e
Revision 14 Page 9 4.10 Wet Radioactive Waste Any radioactive liquid or fiquid/ solid slurry which does not meet the burial Site requirements for free standing liquiCr- (i.e. sludge, non-dowatered resin, evaporator bottoms, contaminated oil etc.)
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- PCP Manuel -
Revision 14 Page 10 -
5.0 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE 5.1
~ Solid Radweste shall stay within the Limiting Conditions for Operation in accordance with Technical Specification 3/411.3, Solid Radioactive Waste Treatment.
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Revision 14 Page 11 6.0 REPORTING REQUIREMENTS 6.1 Reporting Condition of Non-Acceptance 6.1.1 Documentation of the following will be required in accordance with FIP-RA1-01,
- General Regulatory Reporting Requirements,' and FIP-RA1-02,
- Notifications.*
1.
The failure of high Integrity containers used to ensure a stable waste form. Container failure can be evidenced by changed container dimensions, cracking, or damage resulting from mishandling (e.g.,
Moping or impacting against another object).
2.
Tite misuse of hlDh integrity containers, evidenced by a quantity of free liquid greater than 1% of container volume or other misuse as prohibited by 10CFR61.56.
3.
The production of a solidified Class D or C waste form that has any of the following characteristics:
a.
Contains free liquid in quantities exceeding 0.5% of the volume of the waste.
b.
Contains waste with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the regulatory agency, which could lead to errors in assessment of wastc class.
c.
Contains a significantly different waste loading than that used in qualification testing accepted by the regulatory agency.
d.
Contains chemical ingredients not present in qualification testing accepted by the regulatory agency, and those quantities are sufficient to unacceptably degrade the waste product and cannot be pretreated prior to Solidification.
e.
Shows instability as evidenced by crumbling, cracking, spalling, volds, softening, disintegration. nonhomogeneity or dimensional changes.
f.
Evidence of processing phenomena that exceeded the limiting processing conditions identified in applicable topical reports on process control programs (e.g., foaming, temperature extremes, premature or slow hardening and production of a volatile material).
6.2 Solid radwaste shipment data and discussions of major changes to the solid radioactive waste system shall be included in the Semiannual Radioactive Effluent Release Reports in accordance with Technical Specification 6.9.1.8 Semlannual Radioactive Effluent Report.
l 6.3 Licensee-initiated major changes to the radioactive waste systems (liquid, gaseous, and solid) shall be reported in accordance with Technical Specification 6.15, Major Changes to Radioactive Liquid, Gaseous, and Solid Waste Treatment Systems.
PCP Manual i
Revisitn 14 Page 12 7.0 PROCEDURE I
7.1 General Requirements 7.1.1 All processing of radioactive waste shall be done under an approved Process Control Program for the type of waste being processed.
7.1.2 All solidification, dewatering and sampling activities performed inside the RCA shall have an RWP in accordance with FIP-RC1-01,
- Accessing and Working ;n Radiologically Controlled Araas.*
7.1.3 The Quality Control functions will be Audited by the Fermi 2 QA Department in accordance with FIP-AS1-01, ' Audits and Surveillances.*
7.1.4 All HlCs used at Fermi 2 for disposal of radioactive waste will be approved for the type of waste being processed. This approval will be based on the chemical and physical limitations of the container. Each HIC will be certified that it meets the acceptance criteria set by the Certificate of Compliance.
7.1.5 Reference 2.4 provides instructions for developing scaling factors necessary for ensuring compliance with 10 CFR 61.
7.1.6 Preparation of manifest and shipping paperwork shall be in accordance with NPP-RC3-01, *Radweste Shipping Operations.*
7.1.7 All documents shall be maintained in accordance with FIP-RM1-01, " Records Manag ement.*
7.1.8 With solidification or dewatering not meeting disposal site and shipping and transportation requirements, take Action in accordance with Technical Specification 3/411.3, Solid Radioactive Weste Treatment.
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7.2 Solidification Requirements 7.2.1 For high activity waste being solidified, where handling of the full sized Production Test Sample could result in personnel radiation exposure that is in consistent with the Al. ARA principles, a reduced sample size (25 ml) may be used.
7.2.2 A Production Test Sample shall be solidified from at least every tenth solidification from the same batch.
7.2.3 As a minimu.n the PCP for stable Cement Solidification Process shall require annually:
l 1.
A Production Test Sample selected from the most recent production level solidification batch will be subjected to the testing requirements in Appendix A. Section 11 of the NRC Technical Position on Waste l
Form, Revision 1.
j 7.2.4 Unstable Waste shall meet the following criteria:
1.
Resist penetration
PCP Manual R: vision 14 Page 13 2.
Free standing monolith 3.
No free standing water 7.3 Dewatering Requirements 7.3.1 As a minimum the PCP for Dewatering shall include and/or reference documentation necessary to ensure the dewatering process and equipment being used will produce a waste form that will meet the disposal facilities requirement for free standing liquids.
7.4 Encapsulation Requirements 7.4.1 As a minimum the PCP for Encapsulation shall include and/or reference documentation necessary to ensure the Encapsulation process and equipment being used will produce a waste %"m that will meet the disposal facilities requirement as stated in step 7.2.4.
7.5 Solidification Process Control Program 7.5.1 Sampling 1.
Obtain a representative sample of the waste batch. This sample will be used to determine the actual process formulation for solidification.
Record this information as required by the PCP.
NOTE: To keep personal radiation exposure ALARA, the sample taken may be used for both test solidification and chemistry isotopic analyses.
2.
Chemistry shall obtain a representative sample of the waste batch in accordance with " Chemistry Specification". This sample will be used for radiochemical analysis and to determine the quantity of oil in the batch of waste. Record this information as required by the PCP.
7.5.2 Waste Classification 1.
Pdor to Solidification a Waste Classification will be determined by the Shipping Supervisor. Record this information as required by the PCP.
NOTE: The Weste Classification and Production Test Solidification may be performed at the same time.
7.5.3 Production Test Solidification 1.
Redweste will perform a test solidification of the waste batch in I
accordance with the PCP. Prior to the test solidification, Chemistry will obtain the pH of the weste. The pH of the waste will be edjustod, as necessary, to ensure it is within the desired range for the PCP to r
l be performed. The pH will be adjusted using the guidelines soecified in the PCP.
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PCP Manual e
Revision 14 4
Page 14 2.
If pretreatment of the batch of waste is necessary, the test sample shall have the required pretreatment prior to the test sample solidification, 3.
If the oil content of the waste batch is greater than 1% by volume, secure solidification operations and notify the Radwaste Supervisor. If the oil content of the waste batch is greater than 8% by volume then the solidification must be done using Reference 2.27, 4.
If the initial Production Test Sample from a batch of waste fails to verify solidification, obtain representative samples from the same batch of that wet waste until at least 3 consecutive initial Production Test Samples demonstrate solidification prior to full scale solidification.
7.6 Dewatering Process Control Program 7.6.1 Sampling 1.
Chemistry shall obtain a representative sample of the waste batch in accordance with
- Chemistry Specification." This sample will be used for radiochemical analysis and to determine the quantity of oil in the batch of waste. Record this information as required by the PCP.
7.6.2 Waste Classification 1,
Weste Classification will be determined by the Shipping Supervisor.
Record this information as required by the PCP.
7.7 Encapsulation Process Control Program High activity filters, Irradiated Components and other material which may require encapsulation 7.7.1 Sampling Chemistry shall obtain a sample of the waste to be encapsulated. This sample will be either a qualitative or a quanutative sample. This sample will be used for radiochemical analysis and to determine the quantity of oil in the waste.
7.7.2 Weste Classification 1.
Prior to encapsulation, a waste classification will be determined t y the Shipping Supervisor, i
PCP Manuel o
Revision 14 Page 15 8.0 ACCEPTANCE CRITERIA 8.1 Solidification Process Control Program 8.1.1 The test sample will be considered acceptable if it meets:
1.
Free standing liquid requirements for the disposal facility 2.
Stability requirements if it is evident from the physical appearance that the test sample will maintain its shape if removed from the container 8.1.2 Once the test sample demonstrates an acceptable waste form and waste classification is acceptable for near surface burial, solidification may be performed as per formulas stated in the PCP and the applicable Operating procedures. Tne container shall be considered acceptable if it meets the solidification limitations set forth in the PCP and the disposal site requirements for free standing liquids.
8.1.3 Once solidification is completed the container will be stored in accordance with NPP-RC3-03, "Use of the Onsite Redwaste Facility,' while waiting for shipment.-
8.2 Dewatering Process Control Program 8.2.1 The container shall be considered acceptable if it meets the dowatering
-limitations set forth in the PCP and the disposal site requirements for free standing liquids.
8.2.2 The dewatering results will be recorded in accordance with Reference 2.22, 8.2.3 Once dewaterlag is completed the container will be stored in accordance with NPP-RC3-03. "Use of the On Site Radweste Facility,* while waiting for shipment.
8.3 Encapsulation Process Control Program 8.3.1 The waste *orm will be considered acceptable if it meats the test l
requirements as outlined in the PCP and tha free standing liquid requirements for the disposal site.
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PCP Manual o
Revisi:n 14 i
Page 16 v.0 DOCUMENTATION 9.1 The data sheets will be included in the file copy of the shipping package, as required by the applicable shipping procedure.
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