ML20094H282

Rev 2 to Administrative Procedure APA-ZZ-01011, Process Control Program Manual

ML20094H282
Person / Time
Site:	Callaway
Issue date:	01/28/1992
From:	Blosser, Hamilton G UNION ELECTRIC CO.
To:
Shared Package
ML20094H274	List: ML20094H268 ML20094H275 ML20094H282
References
APA-ZZ-01011, APA-ZZ-1011, NUDOCS 9203090240
Download: ML20094H282 (27)

Text

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I APA-ZZ-01011 Revision 2 January 27, 1992 NUCLEAR PUNCTION ADMINISTRATIVE PROCEDURE APA-ZZ-01011 PROCESS CONTROL PROGRAM MANUAL (PCP)

I RESPONSIBLE DEPARTMENT GM ' V f / M?$~ t -

l PREPARED By bM:t mdv'i DATE / 27

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APPROVED BY L/ dbW DATE // /J d' 42

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I II C l _.) 04, f - k$- hd ISSUED 'o I DATE ISSUED l

Q JMI 2 91992 F

I ACCOUNTABLE HOLDFA IIS This procedure contains the following:

Pages 1 through 25 Attachments I through 2 Tablas through I Figures through Appendices through Checkoff Lists through I

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1888R as888 6 PDR

'g APA-ZZ-01011 3 Rov. 2 TABIE OF CONTENTS Section Paac Number 1

1.0 Purpose and Scope

1 2.0 Definitions 1 3.0 Administrative Controls 2 3.1 Major Changes to Solid Radwaste Treatment Systems 2 .

I 3.2 3.3 3.4 Changes to the Process Control Program Report of Solid Waste Released from the Plant Reporting of Mishaps involving Waste 3

4 Stabilization and High Integrity Containers 5 4.0 10CFR61 Compliance Methodology 7 I 5.0 5.1 5.2 Process Controls Administrative Requirements Collection and Analysis of Samples 8

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5.2.1 General Requirements 9 I 5.2.2 5.2.3 PCP Archive (Radioactive) Samples Collection of Samples Chemical Analysis of Waste Samples 10 11 13 N 5.2.4 J 5.2.5 Radiochemical Analysis of Waste Samples 13 5.3 Test Solidification and Acceptance Criteria 14 5.3.1 Waste Conditioning 14 Test Solidification 14

'I 5.3.2 5.3.3 Test Solidification Acceptability 15 6.0 Radioactive Waste Processing Using Installed 16 Liquid Volume Reduction System 6.1 General Requirements 16 6.2 Waste Sampling 17 6.3 Process Controls 17 7.0 Radioactive Waste Processing Using 18 Bulk Disposal Methods I 7.1 7.1.1 Radioactive Waste Processing Using Contracted Vendor Services General Requirements 18 18 7.1.2 Control of Vendor Procedures and Documentation 20 7.2 Radioactive Waste Processing Using 21 In-House Bulk Disposal Options 7.2.1 General Requirements 21 I. 7.2.2 7.2.3 Waste Sampling Packaging of Spent Filter Cartridges 22 23 7.2.4 Packaging .f Spent Ion Exchange 24 I B.O Bead Resin References 25

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TABLE OF CONTENTS t

I Section Paac Number I Attachment 1 - Topical Reports Applicabic to callaway Process Control Program (PCP)

I Attachment 2 - High Integrity Containers (HICS)

Authorized for Use at Callaway I _

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RECORD OF REVISIONS Revision Number Revision Date Feason for Revision Process Control Procram (PCP)

Rev. O October 1983 Initial issue.

Rev. 1 February 1984 Incorporation of NRC review comments.

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

Rev. 3 March 1985 Added solidification I nomogram for concentrated borated wastes and renumbered attachments; clarified sample I analysis documentation requirements, j Rev. 4 August 1985 Incorporated Class A " unstable" resin solidification formulation (based upon in-plant testing).

I Rev. 5 March 1986 Update solidification formulation nomograms; revised coversheet and I " preface" portion of document; removed section dealing with solidification agents from document; made formulations propietary documents.

Rev. 6 April 1986 Incorporated section l

I dealing with control of vendor services for packaging of solid l radioactive wastes; revised purpose to agree more closely with wording shown in Technical Specification definition for

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

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j Rev. 8 September 1987 Revised recorded boundary I conditions / ratios for batch solidification; revised acceptance criteria for I structural stability incor-porated wording regarding full scale tect solidi-fication; minor text wording changes.

Rev. 9 December 1988 Revised format to reflect I actual use of document (program vice procedurc}

incorporated new sect!'"

dealing with bulk disp. sal I- of wet radioactive vaste; revised solidification formula (s) in-stalled system solidification based upon vendor recommendation.

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

Spec. Amendment OL (1087.

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Formal controls on PCP placed under Administrative Procedure.

Added Commitment Tracking System Numbers (CTSNs).

P,ev. 1 August 1991 Removal of installed i solidification system (STOCK I Solidification System) from text.

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

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

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

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I PROCESS CONTROL PROGRAM MANUAL (PCP) 1.0 PtrRPOSE AND SCOPE l4166 1.1 The purpose of the Process Control l4700 Program (PCP) is to provide reasonable l41638 assurance and documentation that the i processing and packaging of solid ra-l dioactive vastes based on demonstrated l processing of actual or simulated wet I I l

l solid wastes will be accomplished in such a way as to assure compliance with 10CFR Parts 20, 61 and 71, State l regulations, burial ground require-l ments, and other requirements govern-l ing the disposal of the radioactive l vastes.

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

2.0 DEFINITIONS 2.1 folidification - The conversion of wet wastco into a form that meets shipping and burial ground requirements.

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

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

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

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2.4 Batch - A specified quantity of liquid

-wastes / sludges requiring solidifica~

tion or dewatering (ie., the amount of waste content within a tank, or, the

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

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

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

3.1.1.1 Shall be reported to the commission in the Semiannual Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the On-Site Review Committtee-(ORC). The discussion of each change shall con-tain:

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

3.1.1.1.2 Sufficient detailed information to to-tally support the reason for the I change without benefit of additional or supplemental information; I

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

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

2814 3.2 CHANGES TO THE PROCESS CONTROL PROGRAM 20174 (PCP) l 3.2.1 All changes to the PCP shall be com-1 pleted pursuant to Technical Specifi-I cation 6.13 and approved as per APA-

! ZZ-00101, Preparation, Review, Appro-l val and Control of Procedures.

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! 3.2.2 Documentation of the change (s) shall i include:

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l 3.2.2.1 Suf ficient information to support the change together with the appropriate I. I l analyses or evaluations justifying the l change (s); and 1

. I- l 3.2.2.2 A determination that the change will i maintain the overall conformance ,f the solidified waste product to exist-I l

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l ing requirements of federal, state, or other applicabic regulations.

I i - l 3.2.3 Cross Disciplinary Review for each re-l Vision of the PCP must include as a j minimum Radwaste and Quality Assu-I l I

l 3.2.4 rance.

All changen shall be reviewed and app-l roved by the ORC and approved by the I l l

Manager, Callaway Plant PRIOR to im-plementation.

I 3.3 EEPORT OF SOLID WASTE RELEASED FROM LHE PLANT 2805 3.3.1 The Semiannual Radioactive Effluent Release Report covering the operation of Callaway Plant during the previous 6 months of operation shall include a I summary of the quantitics of solid ra-dioactive waste released from the plant as outlined in Regulatory Guide 1.21, Measuring, Evaluating, and Re- ~

porting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents frem I Light-Water-Cooled Nuclear Power Plants, " Revision 1, June 3974, with data summarized on a quarterly basis following the format of Appendix B thereof.

3.3.1.1 For solid wastes, the format for Tabic I 3 in Appendix B shall be supplemented with three additional categorics; class of solid waste (as defined by 10 CPR Part 60), type of container (c.g.,

_I 1sA, Type A, Type B, Large Quantity) ,

and SOLIDIFICATION agent or absorbent (e.g., coment, ure- formaldehyde).

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' l42377 3.4 BEPORTING OF MISH%PS INVOLVING WASTE l ETABILIZATION AND HIGH INTEGRITY CON-l TAINXBE l

[ l 3.4.1 As per the requirements of the NRC I l l

Branch Technical Position paper on Waste Form, dated 1/24/91, information I on misuse or failure of vaste forms or l centainers used to meet the stability I requirements of 10CTH61 shall be pro-l vided to the commission. Such mishaps l include, but are not necessarily lim-ited to, the following:

1 3.4.1.1 The failure of high integrity contain-I )

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era used to ensure structural stabil-ity. Such failure may be evidenced by changed container dimensions, cracking l or injury from mishandling (e.g.,

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dropping or impacting against another object).

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The misuse of high integrity contain-crs, as evidenced by quantity of frec

. I liquid greater than one percent of l container volume, or an excessive void I} I 1

space within the container; (such use is in violation of 10CFR61.56(a)).

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l 3.4.1.3 The production of a solidified Class E I l l

1 or c waste form that has any of the following characteristics:

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1. greater than 0.5 percent volume of free liquid.

l 2. concentrations of radionuclides I l l

greater than the concentrations demonstrated to be stable in the I waste form in qualification test-

-3 l ing accepted by the regulatory E I a9ency-l

3. greater or lessor amounts of so-I l

l lidification media than were used j in qualification testing accepted I by the regulatory agency.

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

I latory agency.

s l S. shows instability evidenced by IJ l 1

l crumbling, cracking, spalling, voids, softening, disintegration, nonhomogeneity, or change in di-g l mensions.

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6. evidences processing phenomena 1 that exceed the limiting process-l ing conditions identified in app-t licable topical reports or process I control programs, such as foaming, excessive temperature, premature I l i

I or slow hardening, production of volatile material, etc.

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

l cident.

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I APA-ZZ-01011 Rsv. 2 3.4.3 For any such vaste form mishap occur-I l

1 rence, the affected vaste form should l not be shipped off-site until approval l is obtained from the disposal site l regulatory authority.

l 3.4.3.1 Either adequate mitigation of the po-l tential effects on the vaste form or an acceptable justification concerning I- l l the lack of any potential significant l effects of the affected vaste form on

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the overall performance of the dispo-sal facility must be provided to the i disposal site authority and other reg-I l I

I ulatory agencies, as appropriate, prior to the waste form being shipped to a disposal facility.

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I JJOTE The reason for this is that the low-level waste generators and proces-I l 1

l sors are required by 10CFR 20.311 to certify that their waste forms I meet all applicable re-I ).. l i

quirements of 10CFR Part 61, and waste forms that are subject to the types I

'g I of mishaps mentioned

,3 1 above may not possess

! _the required long-term l structural stability.

4.0 10CFR6) COMPLTANCE METHODOLOGY

'l 12713 4.1 All packaged radioactive vastes

,5 l2720 generated at the Callaway Plant shall 142371 meet the requirements of Title 10 Code iI l

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I of Federal Regulations Part 61 (10CFR61). As a minimum, all radioac-tive waste stream sources must be l sampled and analyzed on an annual ba-sis for development of applicable ra-

'-1 1 l dionuclide correlations for determin-l ing waste classification and packaging l

I requirements.

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T I APA-2Z-01011 R3v. 2 l2715 4.2 Waste Classification (10CFR61.55)

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requirements shall be met by the methodology established in plant oper-nting procedure (s) governing Waste l Classification. Waste Characterization

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(10CTR61.56) requirements shall be met by a combination of the methodology l stated in the Process control Program l and related Callaway Plant Operating I. l Trocedures. Stability requirements l stated in 10CFR61.56 (b) and by burial site shall be met and ensured prior to I

l l shipping packaged radioactive waste i offsite for burial.

I 4.3 Additionally, the use of NRC-approved topical reports may be utilized in meeting specific requirements of I 10CFR61. (See Attachment 1, Topical Reports Applicable to Callaway Plant PCP).

5.0 JLR_0_ CESS CONTROIS 5.1 ADMINISTRATIVE REQi)JRMENTS 5.1.1 All samples must be handled in accor-dance with applicable Callaway Plant procedures and in keeping with ALARA principles. Test samples containing radioactive vaste and contaminated disposable labware utilized in the g performance of the methods described B in the PCP should be disposed of as radioactive waste.

5.1.2 Administrative controls governing the use and disposal of oils, greases and chelating agents should be utilized as I a means to control and/or limit the production of wastes containing these substances. In the event that chemical l analysis of process wastes for these substences is impractical due to phys-

ical restrictions or analytical con-l straints, determinat. ion of their pres-ence (or absence) may be made utiliz-ing appropriate evaluation techniques.

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l41885 5.1.3 With solidification or devatoring not I l1911 l

meeting disposal site and shipping and transportation requirements, shipment l of the inadequately processed wastes shall be suspended. Additionally, the I- l l Process Control Program, its imple-l menting procedures and/or the Solid I l l

l Waste System shall be corrected, as necessary, to prevent recurrence.

l41885 5.1.4 With solidification or dewatering not I ]1911 l

l performed in accordance with the Pro-cess Control Program, the improperly processed waste in each container, as I l l

1 applicable, shall be tested to ensure that it meets burial ground and ship-ping requirements. Appropriate admi-l nistrative actions shall be taken to prevent recurrence.

l4166 5.1.5 Prior to batch solidification of I l l

l vastes to be solidified, vaste classi-fication and acceptability for near-surface disposal shall be deternined.

l This will involve calculating the ac-I3 ) l l

tivity within the projected waste con-tainer using the isotopic analysis of 1 the batch and the actual solidifica-l tion formulas to be used.

l 5.'.6 Prior to packaging of wastes using other processes (e.g., immobilization I l I

l or dewatering, etc.), vaste classifi-cation and acceptabili'.j of process l method chosen for near-surface dispo-l nal must be determined. This will in-I_ l volve calculating the activity within I the projected waste container using I I l

the isotopic analysis of the waste to be processed and packaged.

5.2 COLLECTION AND ANALYSIS OF SAMPLES l 5.2.1 Genera) Recuirements (applicable to l cement solidified wastes only) 41886 5.2.1.1 The PCP shall be used to verify the solidification of at least one repre-6 ser.tative test sample from at least 8

every tenth batch of each type of wet radioactive waste solidified.

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If any test Lample fails to solidify, solidification of the batch under test shall be suspended until such time as l

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l additional test samples can be ob-tained, alternative solidification pa-re. meters can be determined in accor-dance with the Process Control Pro-I l l

.l gram, and a subsequent test verifics solidification. Solidification of the l batch may then be resumed using the I l l

l alternative solidification parameters determined.

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If the initial test sampic from a batch of waste fails to verify solidi-fication, then representative test l sampics shall be collected from each I l l

1 consecutive batch of the same type of waste until three (3) consecutive in-itial tent specimens demonstrate so-

. l lidification.

5.2.1.4 For high activity wastes, where han-

.s dling sampics could result in person-

) nel radiation exposures which are in-consistent with AIARA principles, re-presentative non-radioactive samples I may be test solidified. These samples must be as close to the actual waste and chemical properties as possible.

Typical unexpended mixed bead resin I may be used to simulate the spent bead resin, I 5.2.1.5 Where practical, all chemicals used to condition or solidify waste (or simu-lated waste) in solidification tests must be identical to the actual chemi-

.I cals to be used in full scale solidi-fication.

l 5.2.2 PCP ARCHIVE SAMPLE REOUIREMENTS l 5.2.2.1 As per the Appendix to the NRC Branch

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Technical Position paper on Waste Form, dated 1/24/91, archiving of PCP

{ test sampic specimen must be performed I for all Class B and C vastes that are stabilized using cement.

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l 5.2.2.2 These specinens are to be tested and I l l

I cvaluated at 6 and 12 nonth intervals after the actual stabilization.

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l 5.2.2.2.1 Testing nust enconpass a verification of cottpressiva strength > 60 lbs after immersion in Vater for at least 14 1 days.

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If a tested specimen does not neut the acceptance test above, it shall be i g i presumed that all containers of vaste g i packaged per that PCP formulation do

, not meet 10CFR61 stabilization requir-ements.

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l l 5.2.2.3.1 Reporting of failure of tested speci-I non to meet acceptance criteria shall 3 l be nado te the Commission as voll as 5 I to the burial facility where the pach-l aged vaste had been disposed.

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l 5.2.2.3.2 Any containers of natorial packaged I with this formulation on site vill 1 need to be retested or othervice re-packaged to ensure 10CFR61 stability I) l l requirements are adhered to.

5.2.3 Collection of E3 roles 5.2.3.1 Earnie Analycis DocumentatLED I l l

l 5.2.3.1.1 For vastes that are to be solidified, p Atinent information on the charac-teristics of test sample solidifica-tion nuot be recorded in order to ver-I l l

ify solidification of subsequent batches of similar vaste without re-testing. If vante pretreatment is ne-I I

I cessary prior to actual batch solidi-l fication, the agent used and amount I added must be recorded.

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5.2.3.1.2 The test sample data for vaste must I include, but is not limited tot the type of vasten soljdified; percent to-tal solids; p11; amount of oil in the I canple. Additionally, recorded infor-nation should include the batch number, vaste type, vasto classifica-I tion, total vastes received, total binding agent (s) added and the dato solidified.

5.2.3.2 Takino Sampleg l 5.2.3.2.1 A sample (s) of the waste tank's con-I l l

I tents to be processed / packaged must be taken in order to determine the actual process formulation for solidifica-l tion, any protreatment of the vasto l needed prior tc, solidification or oth-l cr process and packaging method, and I the vaste classification of the final l packaged waste product.

5.2.3.2.2 Sample sizes, as determined by the Radwaste Department, should be compat-II idle with the standard sito camples used foi radioactivity and chemical analysis. If the radioactivity Icycla are too high to permit full size sam-plos to be taken, then smaller samples should be taken with the results cor-rected accordingly.

1 5.2.3.2.3 Sufficient sampling lead time should l be allotted prior to planned waste so-I l l

I lidification of a batch to allow ade-quate time to completc the required testing and verification of solidifi-I 1 l

I cation, as applicable. The contents of the vaste tanks that are to be pro-ceased / packaged must be recirculated (mixed) prior to sampling to ensure I

l 1 that a representative sample is ob-I tained.

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l 5.2.3.2.4 If the contents of more than one tank i or container are to be packaged in the i name container, then representative i samples of each tank (container)

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I should be drawn. These samples should be of a sufficient composition that if "X" percent of the total vasto to be packaged is to be taken from one of I I l

I the tanks, then the sample taken from that tank should be the same percen-tago in the composite sample. The sam-l I l i

l ples taken of each should be mixed in the proper proportions to yield a standard B)z0 sample.

5.2.4 phemical Analysis of Waste Samnica 5.2.4.1 Evaporator bottoms and chemical vastes I must be analyzed for total solids, oil content, boric acid concentration and pH. Spent resin beads and charcoal to be solidified must be characterized by analyzing the water surrounding the beads and charcoal for oil content and pH. (Chemical analysis of resins / char-I ,'

coal is not required for packaging via devatoring).

I 5.2.4.2 Results of chemical analysis must be documented.

5.2.5 Radicchemicql Analysis of Waste San-I ples -

l 5.2.5.1 A gamma isotopic analysis must be per-I l I

I formed on cach batch of vaste to bc packaged. This analysis is used in determining an acceptabic packaging I 1 I

I method as well as vaste classification of the packaged vaste.

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

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

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L 5.2.5.4 The results of tte gamma isotopic analysis nunt be recorded on/ attached

- to the documentation package.

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5.3 IEST SOLID 1'ICATION AND ACCEPTANCE

- ERITEB1h 5.3.1 Hapto ConditioniDS l 5.3.1.1 Prior to test sample solidification, I the pH of the tank nust be adjusted to I l I

l n range of 5 to 9 pH. Should adjust-cent be necessary, the agent and qu..n-tity used must be recorded.

l st. .2 If oil is present in quantities great-or than 1% by volume, dilution of the batch to below It is required prior to solidification.

5.3.2 Ient solidification 5.3.2.1 Whenever pretreatment of a batch is necessary, the tank contents must have the required pretreatment accomplished Ig 3 prior to pulling the uanple for tout solidification analysis.

5.3.2.2 A test solidification container should B be prepared with a mixing device.

5.3.2.3 The appropriate proportional amount of I portland cement and codium notacili-cate and/or other solidification nodia per the applicable test solidification I proceduro must be added. A known re-presentative voAume of the waste must be transferred to the test solidifica-tion container.

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5.3.2.4 Mixing of the vaste, portland cement l

I and/or other solidification media is then initiated. After appropriate mix-ing or when a homogenous mixture is I obteined, the cement /vaste mixture must be allowed to stand for a spec-ified time period. Any f ree liquid ob-served on the top of the test solidi-I fication must be decanted into a clear volumetric beaker (cylinder). The amount of liquid decanted is used to i g calculate the percent free liquid. Re-3 suits of this analysis must be docu-mented.

5.3.3 Test Solidification Acccotability 2720 5.3.3.1 The test sample solidification shall I be considered acceptable from a frec liquid standpoint if the amount of free liquid is the lessor of either it by volume or burial site limits.

5.3.3.2 The test sample solidification shs11 g be considered acceptable from a solid I/ mass standpoint (i.e., structural sta-bility) if the surface of the sample resists penetration when probed with a spatula or comparable firm object.

J.3.3.3 If either or both of the above checks fail to meet the stated criteria, the waste sample analysis and/or the sam-I ple solidification formula rust be verified as being correct. If this I verification shows an error in vaste sample analysis or sample solidifica-tion formula,a corrected solidifica-tion formula must be obtained and sam-I ple solidification performed using this corrected formula.

5.3.3.4 In the event that the analysis and I' formula previously derived and used are correct, alternative solidifica-tion parameters must be determined be-I fore solidification can proceed.

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41886 5.3.3.5 If the initial test solidification of a batch is unacceptable, then a repre-sentative sample shall be test solid-ified on each subsequent batch of the I came type of waste until three consec-utive test sampics demonstrate solidi-fication.

5.3.3.6 If a test sample fails to provide a:-

ceptable solidification of waste, equal volumes of dry cement and water I should be mixed to ensure that the problem is not due to a bad batch of cement.

l 6.O IMD10 ACTIVE WASIC_l2QUJ:fSJJ1G USIliG It1_-

l E711JLD_LlpVID VOLUME REDUCTIQJ1 SYSTEM l

6.1 General Renuirenents l 6.1.1 The installed radioactive vaste liquid I ]

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volume reduction (RVR) System will be used to process most aqueous vastes (i.e., evaporator concentrates, floor I drain and sump cludges, etc.) from I. ) {

l plant radioactive systems. Liquid vastes from other than installed Power l Block drain systems may be processed I l l

l in the RVR System but must be evaluat-ed for compatibility with materials of construction used in fabrication of the RVR System.

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l 6.1.2 A samplified system processing flow-I chart and system description of the I l l

I RVR System is detailed in chapter 11.0 of the callaway Plant FSAR.

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I 6.1.3 All containers used for packaging vastes processed using the RVR System must ba inspected prior to use to en-1 sure they are free from defectn.

I l l2713 I

6.1.4 The RVR System process produces a re-sulting vaste product that will not I l I

I meet 10CFR61 stability requirements.

The RVR shall only be used for pro-cessing / packaging vantes that will re-I sult in a waste classification of I Class A.

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I A PA-2::'- 01011 Rov. 2 l

l l 6.2 Faste Sanolina 6.2.1 Representative samples of liquid I wastes to be processed by the RVR Sys-I l I

l tem must be obtained and analyzed for chemical and radiochemical content, as appropriate.

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

6.2.1.2 A gacra isotopic analysis must be per-I formed on each batch of waste to be l proconsed. An appropriato concentra-I I I

l tion factor must be applied to the analysis results in order to derive the waste classification of the rc~

l sulting packaged waste.

l 6.2.1.2.1 Gamma isotopic analysis performed on procenned waste discharged from the I

l l RVR do not require application of a l concentration correction factor.

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I 0.2.2 Samples are drawn from the evaporator bottoms tank (s) or from individual containers of liquid waste sludges for I performing this batch analysis.

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

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l 6.3 0.3.1 Etogsn Controll Operation of the installed RVR System I must be performed and documented per approved plant operating procedures.

l 6.3.2 In order to encuro production of a I l I

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

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I APA-ZZ-01011 Rev. 2 I

6.3.3 ):cy operating parameters such as oper-I l

l nting temperatures and pressures with-l in the RVR System's blender / dryer must j be monitored and recorded.

l 6.3.4 A final naterial dryness " endpoint" l nust be not prior to considering the natorial dry within the blonder / dryer.

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l This "ondpoint" is not through a se-quence of system manipulations where the RVR blender /dryor contents are l

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l cycled above naturation temperature several times to drive off remaining water from the contents. The sequence of steps to do this is detailed in I l i

l system operating procedures.

l 6.3.5 rollowing the "ondpoint", parafin may I l i

l be added to thc blender / dryer f or nix-ing with the dried processed vasto powder to immobilito the powder and l keep it from readily dispersing in the l air.

I 12713 6.3.6 Should packaged vasten be created that I' l l

cxceed a vaste classification of Class A, the resulting packaged waste con-tainer shall be placed into an over-l I l l

l pack container capabic of nocting 10CFR61 stability requirements prior to shipment offsite for disposal.

7.0 PJ DLO30TIVE WASTE PRQCESSIliG JJfilLQ 13UM: DI EPOS AL_HJ1THODS I 7.1 RADIOACTIVE WASTE _PROCESSIl1C USIl1G

.C_OfiTP3sCTFJ VEllDDR SERVICES I l 1

7.1.1 Processina and PaclagjIn oLPrimary and_PpJwaste Systen vartes l 7.1.1.1 General Recuirements I l l41886 7.1.1.1.1 i

Contracted vendor services shall be provided to procons and package ra-I l I

I dioactive kastos to the required waste form to satisfy the applicable trans-portation and disposal requirements i for those instances when the installed I solid radioactive waste system in in-l capable of prococcing these wastes.

I

APA-'2-01011

- Rev. 2 l

s I

h l41886 7.1.1.1.2 Contracted vendor services will be es-l tablished for the packaging of wet ra-l dioactive wastes by vendor solidifica-l tion and/or devatering. Contracted I vendor services may be exorcised when,

' I in the opinion of plant management, I any of the following conditions exist:

1 l 1 n. The installed system is declared I out-of-service thereby reducing or l l climinating the capability of Cal-laway Plant to efficiently and le-E i l gally packago radioactive wastes l in accordance with all applicabic requirements governing the dispo-l l I nal of the wastest or, 1

1 b. The installed system is incapable I 1 of packaging those vasten in ac~

l cordance with any of the apr,lica-3 l bic requirements (e.g.. 10CTR61.)

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governing the disposal of these wastos; or,

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l C. When procesFing and packaging eco-P l nomics show an increased cost ef-I ficiency of vendor processing ver-l sus installed system processing.

13 7.1.1.1.3 Specific programmatic controls for these servicca will bo handled in ac-cordar.cc with the vendor's Quality As-curance program. This program shall be approved by Union Electric Quality As-ly surance prior to implementation of the contracted services.

7.1.1.2 Contro_1 Of Vendor Procedures And Dorq-I Fentatio2 7.1.1.2.1 Vendor procedures covering equipment cetup, operation, and removal must be reviewed and approved in accordance l with plant administrativo procedures l prior to implementation.

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I APA "t-01011 Rev. 2 I

7.1.1.2.2 Vendor procedures detailing the ven-I dor's Process Control Program (PCP) in addition to the review and approval mentioned above must also be reviewed and approved by the Onsite Review Com-I mittee prior to inplementation. The vendor PCP must provide for the sam-pling, tests, analyses and formulation I determination, as required by the Cal-laway Plant PCP.

4955 7.1.1.2.3 Results of all testing and analyses shall be documented, as nocospary, to ensure cottpliance with the vendor PCP and all applicable transportatior and burial ground requirements governing the disposal of these wastes.

E 4955 7.1.1.2.4 Copics of all documentation attesting E to conpliance with the requirements of the vendor PCP as well as any plant a operating procedures utilized in sup-g port of the contracted vendor survice

( chall be retained by the plant for in-clusion in plant files. Documentation I) containing proprietary information should be appropriately handled and controlled to ensure the required de-gree of confidentiality is not.

1 7.1.0 EragpIninq _and Paginning of Secon.dJry l _a n d Sunnort System Wanten I 1 l

l 7.1.2.1 psycral RJ1guiremente I l i

I 7.1.2.1.1 Contracted vendor services must be provided to process and package ra-dioactive wastes to the required wnste form to satisfy the applicable trans-I l

I portation and dispossl requirements l for vastos which are generated outside I the RCA/ Power Block of the plant or I l l

I where expertise in handling same is not availabic at Union Electric.

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I APA "Z-01011

}cv. 2 1

I Those contracted vendor services may I l 7.1.2.1.2 l be established and exerclued for pro-l cessing and packaging of any of the I following contaminated vastes

a. Contaminated Sowago Treatment l Plant sludges and similar aque-ous-based solutions.

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l b. Mixed vastes (i.e., vaste exhibit-1 ing characteristic hazardous mate-I l l

1 rial which have becomo radioac-tively contaminated.)

I l l4018 I

7.1.2.1.3 Specific programmatic controls for these services vill normally bo handled in accordance with the ven-l dor's Quality Assuranco Program. This I l l

I program shall be approved by Union Electric Quality Assurance prior to implementation of the contracted ser-I l I

l 7.1.2.1.4 vices.

For those cases where the vendor ser-g l Vico is not performed por an estab-Ir i l

lished, acceptable vendor Quality As-suranco Program, applicable require-l monts of the Union Elcetric Quality l Assurance Program are to be impicment-I- 1 ed.

I 7.1.2.1.5 I l l

i Control of vendor procedures and/or documentation utilized or created in support of the contracted service must I be handled por applicable guidance I l l

found in step 7.1.1.2 of this proced-ure.

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I APA-2"-01011 Rev. 2 I

7.2 R!DIOACTIVE WASTT.PRQCIFS211G_USI)LQ ll!-llQpfSX.J11LK DISPOSbb Oll10!iS 7.2.1 Genetal Renuirerentg 7.2.1.1 All containers used for polidification or devatoring nuot be inspected to en-oure they are free from defects. Steci containern used for devatoring nuot bu inspected to ensure that their inter-nals are intact and undamaged, liigh I Integrity Containern (!!ICs) nust be inspected to ensure that they are in compliance with their Certificate of compliance an voll an ensuring that I their internals are intact and undan-aged.

All vastes devatored in stool contain-I 2720 7.2.1.2 ers shall be devatored in accordance with approved proceduren for which testing has demonstra*.ed that the I one-half of one percent (0.S%) draina-ble liquid criteria can be net. All vanten to bt devatored in llICs shall s

be devatered in accordance with app-Ie roved procedures for which testing han demonstrated that the one percent (11) drainabic liquid criteria can be net.

I Test data to encure compliance nay be based upon container supplier tenting.

7.2.2 Unste Sarnling 7.2.2.1 ReprcGentative canples of vasten to be procensed by bulk dispocal means nunt I be obtained and analyzed for chemical and radiochemical content, an approp-riate. Based upon thin analycin, the I packaging process as well as the con-toiner to be utilized vill be deter-nined.

7.2.2.2 Results of all analysen reuct be docu-nonted, as nececcary, to encure cora-pliance with all applicabic packaging, I transportation and burial ground re-quirements governing the disposal of thece vantec.

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a . .

APA-ZZ-01011

I Rev. 2

'I 7.2.3 pgLg);acinu Of Snent Pilter Cnrtridgy 7.2.3.1 Packaging of spent filter cartridges will be periorped in either steel drums and bow Specific Activity (LSA)

I boxes or in liigh Integrity containers (liICs ) , dependent upon vastu classifi-cation of the spent filter car-tridge(u) involved.

7.2.3.2 Determination of vaste classification will be performed based upon done to I curie correlations of the cpent filter cartridges. The nethodology involved must be covered in approved plant I 2720 7.2.3.3 operating procedures.

Spent filter certridges which meet the requirements of Class A waste may be I packaged in co'-ten 1711 drums with up to 12 filter cartridges per drum or packaged in LSA boxes. Absorbent nodia I shall be utilized to absorb twice the volume of any incidental liquid within the container. packaging nethods gov-s erning this process must be covered in I' approved plant operating procedures.

(See attachment 2, liigh Integrity Con-tainers (llICs) Authorized for Uce at I Callaway).

Spent filter cartridges requiring sta-42376 7.2.3.4 I bilization per the requirements of 10CTR61 or having concentration ex-coeding 1 pCi/cc for radionuclides with half lives greater than 5 years I shall be packaged in !!ICr. Specific radiation and curie content limita-tions for une of the llIC, as iden-I tified on the applicable Certificate of Compliance, must be not and ensured prior to disptsal of the waste. Pack-aging and devatoring of the !!IC con-I tents must be performed and documented using approved procedures.

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APA-:' -01011 Rev. 2 I

142375 7.2.3.5 llICs purchased for use in packaging I l l

spent filter cartridges shall be de-signed to meet the applicable require-ments found in the NRC liranch Techni-I I 1 l

cal poultion paper on Waste Form dated 1/24/91.

7.2.3.6 Common packaging of spent filter car-I tridges and spent ion exchange bead resin nay be performed in !!ICs pro-vided for that purpose, with specific I instnictions for loading and devater-ing covered in approved plant proced-ures.

7.2.4 hgjinninn Of Spent _,JIII.Japhnane Pend lit 01D I 7.2.4.1 Spent resin to be packaged should be sanpled prior to sluicing in order to onoure the proper container required for packaging the resin 10 ut ili r.e d .

41038 7.2.4.2 Packaging of spent ion exchange bead resin may be performed utilizing dowa-Ij tering proconses in lieu of polidifi-cation. Class A Unstable vastes may be devatored in steel containcro, while a

I Stable vastes, regardless of clans, chall be devatored in llIC'c.

7.2.4.3 liigh Integrity Containers nuct be used for the dispocal of unsolidified opent ion exchange bead resin when the con-centration of radionucliden with half I lives greater than 5 years exceeds 1 pCi/cc. (See Attachment 2).

l42375 7.2.4.4 I

IIICn purchaced f or use in packaging I apent ion exchange bead resin shall bc I designed to nect the applicable re-l quircments found in the NRC 13 ranch l Technical Position paper on Waste Forn I. i dated 1/24/91.

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I

APA-l'Z-01011 Rev. 2

?.2.4.5 Procedures governing the sluicing of I spent resins from domineraliter beds and/oi storage tanks must be written aad approved for use prior to commenc-I ing sluicing operations. Applicable radiological controlo (i.e., shield-ing) should be utilized to ensure the process is AIARA.

l42374 7.2.4.6 Devatoring processes utilized must be i performed and qualified using approved I I I

I plant procedures. Appropriate nothods shall be enpinyed to ensure the appli-cable drainable liquid criteria of I l i

10CFR01 is not prior to final sealing of the container for disposal.

B.0 ETTERE!1Crd 8.1 10CTR20 8.2 10CFR61 8.3 10CTR71 g l 8.4 Reg. Guide B.8, Revision 3 IA S.5 Callavay Plant TSAR Chapter 11.4 I I l

l C.6 Technical Specification 0.13.1 (CTS!1

$20174) 8.7 Technical Specification 6.13.2 (CTSN I l l

i

$2814)

I B.E AFA-ZZ-00101, Preparation, Review, Approval and Control of Procedures l B.9 NRC BTP on Waste Forn (dated 1/24/91) 8.10 Reg. Guide 1.21, Revision 1, June 1974 I

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I APA C:' 01011 Rev. 2 I

TOPICAL REPORTS APPLICABLE TO CALIAVAY PIAliI PROCPSS C0b'TROI. PROCPM f PCP)

The To11oving vender topical reports have been reviewed and incorporated, as appropriate, into procedures which inplettent the Callaway Plant Process Control Program (PCP).

1. VM0102 lip A, RADMAll A Couputer Code to Classify and Doewtent l Packaged LLV In Accordance with 10CTR Part 61 Regulations; Vaste  ;

Managenent Group, Inc, j

2. VP C 01 tir, Topical Report for Chen liuclear systetts, Inc. 10CPR61 i Vaste Ports Certification Cettent; Chern liuclear Systens, Inc.

3. 4313 01354 01 A, Topical Report for Chen liuclear Systens, Inc.

Mobile Cenent Solidification Systero: Chen !iucicar System, Inc.  !

4. DV 11116 01 tiP A, Topical Report f or Chest tioclear Systetts. Inc.  ;

Dewatering Control Process Containers; Chem flucitar Systern, Inc.

5. STD R 05 011!ir /., Topical Report for Vestinghouse liittinan Hobile .

Incontainer Dewatering and Solidification Systen (MD55); '

g Vestinghouse liittnan liuclear, Inc.

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I m,~ ma_no g 1 l!

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Al'A.; .01011 Is e v . ?

}J1ril INTI'CRITY CONTAINTRS 011Cs) AUT}l0RIZl'D POR USE AT

] [A1.1AVAY PINiT

! The following liigh Integrity Containers (IllCs) have been authorized for i use in packaging Callaway Plant vastes. Applicable requirements for their use, as defined in their individual Certificates of Conpliance, are detailed in plant operating procedures.

ll1C CERTIP1 CAT 10N a DESCRIPTION V12iDDR/ SUPPLIER I

1 D1tEC illC PL 004 RADil3K $$ Vestinghouse liittnan or Si~C j DilEC 111C.PL.014 RAD 14K $00 Vestinghouse liittnan or SEC l DilEC IllC.PL.001 CNSI PL6 80 Chen Nuclear Systens, Inc. ,

DiiEC.li1C.PL 010 IN1110 120T TTC Nuclear Associates, Inc. l I

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I I -t"1 ^" - - "' :

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