ML20097B202

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Draft Rev 1 to Radioactive Matls Control Procedure RW-200, Process Control Program
ML20097B202
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 11/27/1991
From:
OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20097B178 List:
References
RW-200, NUDOCS 9206040195
Download: ML20097B202 (18)


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Fort Calhoun Station Unit No. 1 RW-200 RADIOACTIVE MATERIALS CONTROL PROCEDURE

Title:

PROCESS CONTROL PROGRAM Setpoint/ Procedure Form Number (FC-68): 36895 Reason for Change: Reflect change in vendor for Liquid Radwaste Processing.

Contact Person: Joe Mattice ISSUED: 11-27-91 4:00 pm R1 9206040195 920601 PDR ADOCK 05000285 P PDR

FORT CALHOUN STATION C'

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PAGE 1 OF 17 PROCESS CONTROL PROGRAM 1.0 EUBPREE To provide guidance and bouncary conditions for preparation l

of specific procedures for processing, sampling, analyzing, packaging and shipping solid rsdioactive waste in accordance with State and Federal regulatory requirements i and the Fort Calhoun Station Unit No. 1 Radiological l Effluent Technical Specifications. '

This program is applicable to the Fort Calhoun Station Unit  !

No. 1 solid radwaste system. Wastes considered in this program are primary and radwaste liquid processing resins, oil and filters. Dry Active Waste is only included as it applies to assurance that packaged waste is suitable for shipment and burial in accordance with applicable State and Federal regulations. Concentrates and aqueous liquids are not considered due to the pres.nt decisions not to utilize the waste evaporator as a means for processing liquid '

wastes.

2.0 RESPONSIBILITIES 2.1 The Radioactive Waste Operations Supervisor is responsible for:

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2.1.1 Maintenance of and complicnce with this Frocess Control Program; 2.1.2 Record keeping and document control of shipping and processing data; and 2.1.3 Assuring Radwaste Personnel are appropriately trained and qualified to perform waste processing and packaging activities.

2.2 The Operations Supervisor is responsible for:

2.2.1 Providing trained personnel to operate appropriate radwaste process equipment; and 2.2.2 Defining those Operations positions which require training.

-2.3 The Manager Training is responsible for:

2.3.1 Development and implementation of performance-based training for designated

_ personnel in accordance with Training Division procedures.

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RADIATION PPOTECTION PROCEDURE PAGE 2 OF 17 2.4 All OPPD and-OPPD contract arsonnel are responsible for:

2.4.1 Implementation of procedures and good practices so as to provide Quality Assurhnce and maintain exposures ALARA.

2.5 The Nuclear Quality Assurance Department is responsible for:

2.5.1 Establishment of a Quality Assurance Program addressing Radwaste processing and packaging; and 2.d i Pertorming audit *; of activities associated with this Process Control Program to assure compliance with the Quality Aseurance Plan.

2.6 The Plant Review Committee as _esponsible fo) 2.6.1 Reviewing and approving changes to this Process Control Program prior to implementation of the changes; and 2.6.2 Reviewing and approving engineering ar.1 safety evaluations performed in support of changes to this Process Control Program.

2.7 The Station Engineering Manager is responsible for:

2.7.1 Ensuring engineering and safety evaluations are performed for changes made to this Process Control Program; and 2.7.2 Submitting these evaluations to the Plant Review Committee for review and approval prior to implementation of the changes evaluated.

3.0 DEFINITIONS 3.1 Batch - An isolated quantity of feed waste to be processed having essentially constant physical and chemical characteristics. For the purpose of resin type wastes a batch is defined as the volume of retins in the Spent Resin Storage Tank or in a vendor supplied system intended to process a quantity of feed waste.

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7 h 1[ RW-200 RADIATION PROTECTION PROCEDURE b Ij J U PAGE 3 OF 17 3.2 Operable - A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s),

and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrichtion or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function (s) arc also capable of performing their related support function (s).

3.3 /rocessing - Changing, modifying, and/or packaging plant generated radioactive waste into a form that is acceptable to a disposal facility.

3.4 Quality Assurance / Quality Control - As used in this document, " quality assuranca" comprises those planned and systematic actions necessary to provide adequate confidence that a structure, system, or ccaponent will perform satisfactorily in service.

Quality assurance includes quality control, which comprises those quality assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means to c.ontrol the quality of the material, structure, component, or system to predetermined requirements.

3.5 Sampling Plan - A sampling program implemented to ensure that representative samples from the feed waste and the fina.1 waste form are obtained and tested for conformance with parameters stated in the Process Centrol Program and waste form acceptance criteria.

3.6 Low-Level Radioactive Waste (LLW) - Those low-level radioactive waates containing source, special nuclear, or by-product material that are acceptable for disposal in a land disposal facility. For the purposes of this definition, low-level radioactive waste has the same meaning as in the Lcw-Level Waste policy Act, that is radioactive wsste not classified as hign-level radioactive waste, transuranic waste, spent nuclear fuel, or by-product material as defined in Section 11e.(2) of the Atomic Energy Act (uranium or thorium tailings and waste).

3.7 Waste Con'cainer - A vessel of any shape, size, and composition used to contain the final processed waste.

3.8 Waste Form - Waste in a waste container acceptable for disposal at a licensed disposal facility.

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RADIATION PROTECTION PROCEDURE PAGE 4 OF 17 3.9 Stability - As used in this program, STABILITY means structural stability. Stability requires that the vaste form maintain its structural. integrity under the expected disposal conditions.

3.10 Chelating Agent - For the purpose of this program CHELATING AGENTS are amine polycarboxylic acids (e.g., EDTA, DTPA), hydroxy-carboxylic acids, and polycarboxylic acids (e.g., citric acid, carbolic acid, picolanic acid and gluconic acid ) as defined in 10CFR61.2.

4.0 AEPARATUS 4.1 None.

' EEEBIOUl.filIEH 5.1 All personnel performing activities under the control of and described by this Process Control Program shall have been successfully trained and qualified to perform the described activities before actually performing the activities.

5.2 Procedures shall have been developed for implementation of this Proccss Control Program and shall be reviewed and approved by the Plant Review Cornittee prior to performing activities described and required by this Process Control Program.

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6.0 PRECAUTIONS 6.1 None.

7.0 PROCEDURE 7.1 WASTE TYPES 7.1.1 Primary Resin A. The contaminated waste product generated as a result or reactor water purification and demineralization, cation ion exchange, deborating ion exchange and spent fuel pool demineralization.

B. Waste consists of contaminat"1 bead ion exchange resins st varying degrees of exhaustion, small concentrations of various solids, activated and non-activated corrosion products and fission products.

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, - cp-i J U Attachment 1 5.3 The equipment or subsystem (s) of the solid radwaste system shall be operated to provide for the solidi-fication of wet solid wastes and the compaction of compressible wastes. Waste solidification will be verified by the requirements of the appropriate sec-tion in this procedure. If solidified radwaste fails to meet the acceptance criteria contained in t~ tis procedure or in any Federal Regulation, no offsite shipments shall be made of nonconforming materials, f

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T7 s JL b Attachment 2 5.4 Solidification of wet radioactive waste (e.g., evaporator concentrates) shall be verified by confirmation of least one representative test speciman (drum) from at least every twelfth batch of wet radioactive waste (e.g., evaporator concentrates).

I 5.4.1 If any test speciman fails to verify solidification, the following actions shall be taken:

A. Verify solidification of all other drums from the batch under test.

B. Review the adequacy of the solidification parameters and develope / verify alternative solidification para-meters, if required.

5.4.2 If the- solic.fication parameters are altered, the following actions shall be taken:

A. Select one representative drum from each consecutive batch to verify solidification until at least 3 con-secutive drums verify solidification. The sampling j requirements of section 5.4 may be resumed after 3 consecutive drums verify solidification.

B. Modify the appropriate procedure as required and report the changes to the NRC in accordance with p Technical Specification 5.18 l

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0 a ca FORT CALHOUN STATION $ RW-200 RADIATION PROTECTION PROCEDURE i I -

PAGE 5 OF 17 7.1.2 Radwaste Licuid Processinc Resin A. The contaminated waste product .

generated as a result of processing radwaste liquids using a demineralization system. This system may be vendor supplied.

B. Waste consists of contaminated bead ion

^vchange resins at varying degrees of exhaustion, small concentrations of various solids, activated and non-activated corrosion products and fission products.

7.1.3 Filters A. The contaminated vaste product generated as a result of liquid or secon'dary system _ processing activities and the removal of cartridge elements from the processing systems.

B. Waste consists of contaminated mechanical filtration cartridges containing various amounts of particulate solids, corrosion products, activation and fission products.

7.1.4 Qil A. The contaminated waste product generated as a result of leakage or intentional drainage and replacement of various plant component lubricating and/or coatrol fluids.

B. Waste consists of contaminated oils and greases of various grades both synthetic and natural, in free form or.

containing various amounts of FQlid material.

7.1.5 Drv Active Waste A. The contaminated waste product generated as a result of plant maintenance and repair and routine plant operations.

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FORT CALHOUN STATION RADIATION PPOTECTION PROCEDURE hi) M[b Mh2f _

RW-200 PAGE 6 OF 17 7.1.5 B. Waste generally consists of contaminated trash in the form of plastics, papers, wosd, steel and cloth items with varying concentrations of corrosion, activation and fission products.

7.1.6 Non-Standard Wastes A. The contaminated waste product generated as e result of non-routine plant operation, maintenance and or repair activities.

B. Waste consists of plant components, irradiated hardware and other specialty items contaminated with varying concentrations of corrosion, activation and fission productu. The waste may also be those items which have become activated with contamination being a minimal fraction of the total radioactivity.

7.2 PROCESS DESCRIPTION 7.2.1 ' Primary Resin A. Primary resinc are obtained from the domineralizer filtration system, purification ion exchangers, the cation ion exchanger, the deborating ion exchanger and the spent fuel storage pool demineralizer.

B. The resins from the demineralizer filtration system are sluiced into a container for processing and shipment l from the plant.

C. The resins from other sources and their sluice water are collected in the spent resin storage tank.

D. The contents of the spent resin storage tank are recirculated with sufficient liquid to keep resin flowing. Nitrogen gas is used to break up solid chunks during this recirculation process.

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E. The contents of the tank are pumped into a disposable container within a shielded shipping cask or process shield after which the contents are i processed and shipped from the plant.

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f - PAGE 7 OF 17 7.2.1 F. Due to the infrequent need to dispose of spent primary resins (approximately every 2-3 years) the most efficient method of disposal is to use a vendor supplied nrocessing system. A NRC.

approved container (e.g. high Integrity Container or HIC) or solidification process shall provide the required stability.

7.2.2 Radwaste Licuid Processino Resin A. Radwaste liquids are processed using a demineralization system in lieu of using the installed plant evaporator l system.

B. Radioactive liquids are normally transferred from the waste holdup tanks to the demineralization system using the waste holdup transfer pumps.

Specific maintenance and/or decontamination activities may require-the use of portable transfer pumps and hoses.

C. _The orocessed liquids are directed to the monitcr tanks to be analyzed and discharged to the Missouri River through the overboard discharge piping.

D. The depleted resins'in the demineralization system vessels are sluiced from the demineralizer vessels into a container which will provide the required stability either-through design (HIC) or by solidification.

E. Multiple sluices may be performed to fill the container.

F. Once the container is filled, processed and stabilized; the waste will be shipped for disposal.

7.2.3 Filters A. Used filter baskets originate from the purification filters, the waste filters, the spent fuel pool cooling system filter, ultrasonic cleaning unit, laundry machines and various other decontamination equipment.

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7.2.3. B. Filters are removed from their

-respective system and permitted to drain excess-liquids from the elements.

x C. The filters are then transferred in a container-for disposal.

(1) When stabiliz: tion is not required, (i.e.-Class A Waste) a Type A Container'may be used providing sufficient, approved absorbent is added as necessary to absorb twice the volume of liquid-anticipated.

(2) When stabilization is required, 4^ (i.e. Class B or C) the filters shall be-disposed-of in a HIC.or shall be solidified.

7.2.4 Q11 A. Oil generated-during operation and maintenance is collected in containers in appropriate approved areas of the plant. ,

B. The filled m:d labeled containers ans sealed and moved to available areas for temporary storage.

C. ' Oils may be decontaminated using a vendor:provided filtration process, or shipped off site.to a contracted and-licensed vendor-for processing and release or_ disposal.

L 7.2.5 -Drv Active Waste A. Dry Active Wastes are collected from

, radiologically controlled areas-l throughout the plant.

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B. 'The waste is sorted to remove reusable and wet items and then can be further segregated to remove non-contaminated e ,.

materr.al from the collected waste.

C. The. contaminated waste material is then L^ <

either compacted into metal 55 gallon drums-in the waste baler or packaged in metal boxes. Contaminated waste will l be disposed of by an approved burial-site or processed (e.g. incinerated, etc.) by an approved vendor. l.

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[ RW-200 RADIATION. PROTECTION PROCEDURE _L _ PAGE 9 OF 17 7.2.6 Non-Standard Waste A. Reactor components and irradiated hardware are waste which are not routinely generated.

B. These types of non-standard waste will be handled on a case-by-case basis through the implementation of special procedures approver by the Plant Review Committee.

7.3 PROCESS CONTROL 7.3.1 Radioactive waste processing instrumentation and equipment shall be subject to formal calibration and preventative maintenance programs.

7.3.2 Primary and Radwaste Licuid Processina Resin A. Primary resins will be transferred into containers for processing using plant installed and vendor supplied equipment.

B. Radwaste Liquid Processing will be performed using a vendor supplied system with transfer of depleted resins from the demineralizer vessels into a processing container by means of sluicing.

C. Primary and Radwaste Liquid Processing Resin dewatering will be performed using an NRC and PRC approved Process Control Program.

D. Referenced Radwaste Procedures

! controlling the processing, transfer I

and dewatering activities shall be observed.

E. The Process Control Program which specifically controls processing of the wa7' s (i.e. the vendors PCP) shall identify the mechanisms and frequency of test / measurements used to verify stability and free standing liquid requirements are satisfied.

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T p r7 FORT CALHOUN STATION j }]< $ ~1 RW-200-RADIATION' PROTECTION PROCEDURE h I PAGE 10 C7 17 7.3.2 F. Successful completion of applicable portions of the vendor Process Control Program shall serve as an indicator of system operability.

G. Containers used for dewatering and l

packaging for disposal at the Barnwell disposal facility shall be approved for use and disposal by the South Carolina Department of Health and Environmental Control.

H. The vendor supplied system shall be l operated in accordance with the system operating procedures and applicable station Radwaste Procedures.

.) I. Station to vendor interfacing is l

addressed in the Safety Evaluation for the processing and dewatering operations.

7.3.3 Filters A. Filter processing is controlled by referenced Radwaste Procedures.

B. Filters requiring stability are packaged.as described in Section 7.2.3.

The containers and/or process used shall be approved by either the South Carolina Department of Health and Control or the Washington State Department of Radiological Health as appropriate for the disposal site to be used.

7.3.4 Q11 A. Processing of oil shall be performed in accordance with referenced Radwaste Prccedures and applicable vendor procedures and topical reports for the methodology applied to the processing activity.

7.3.5 Drv Active Waste A. Dry Active Waste is processed in accordance with referenced Radwaste Procedures.

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FORT CALHOUN STATION M f' f" RW-200 RADIATION PROTECTION PROCEDURE b JJ t. J . PAGE 11 OF 17

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7.3.6 Non-Standard Waste A. Non-Standard Waste is processed in accordance with special Radwaste Procedures germane to the specific non-standard waste being processed.

7.4 PRODUCT CONTROL 7.4.1 A sample from each batch of waste shall be analyzed quantitatively for activity and isotopic identity as required in station procedures. If radionuclide distributions are snown to be consistent between similar batches, consideration may be given to decreasing the frequency of routine measurements. Frequency of sampling is as described in Radiation Protection Procedure RW-221, "10CFR61 Sampling". This constitutes the sampling plan.

7.4.2 Scaling factors for nuclides which are hard to identify are established for waste streams by using analyses performed and provided by an off-site vendor.

7.4.3 This frequency of campling shall be raised or lowered based upon consideration of waste stream or radionuclide characteristics. Factors which would influence this consideration include the frequency of process vessel changeout or waste shipment, the difficulty (e.g. Costs, occupational exposures) in obtaining a representative sample of a particular waste stream, the variability of the radionuclide distribution within-the wante stream over time, and the availability of analytical capability for particular radionuclides.

If radionuclide distributions are shown to Ebe consistent between similar hatches, consideration may be-given to decreasing the frequency of routine measurements. If onsite samples show a variation from presently used scaling factors by more than a factor of 10, samples will be sent offsite for analysis to establish new scaling factors.

l 7.4.4 Radionuclide concentrations and classification of future waste shipments are expected to be similar to those of previous shipments for each specific waste stream. Values are available from shipment manifest forms.

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FORT CALHOUN STATION b l RW-200 RADIATION PROTECTION PROCEDURE i dn . PAGE 12 OF 17 7.4.5 Administrative controle for preventing unsatisfactory waste forms from being released for shipsent are described in referenced station procedures.

7.4.6 ReferencLd Radwaste Procedures ensure wastes shall have no detectable free stunding liquids. No detectable free standing liquid is defined as low as practical but not more than 1% of the volume of the waste when the waste is in a disposable container designed to ensure stability or not more than 0.5% of the volume of the waste for waste processed in any other container.

7.4.7 Processed resin shall be sampled in accordance with regulatory guidance and referunced station procedures to verify that the free liquid content of the packaged product is within limits established by applicable regulatory agencies. Sampling and measurement of free liquid content shall be performed whenever process changes occur that may significantly alter system performance, until compliance with moisture content limits under these conditions can be demonstrated.

7.4.8 Each waste shipment-shall be accompanied by a shipping manifest giving a physical description of the waste, the volume, the radionuclide identity and quantity, the total radioactivity, the principal chemical form and waste class, based on 10CFR61.55.

7.4.9 Sufficient analysis shall be performed to verify that the quality of waste forms prepared for disposal by vendor's onsite processing shall be similar to vendoris test results.

7.5 TRAINING 7.5.1 Processing of solid radioactive waste shall be performeC by qualified and trained personne).

/.5.2 Training records of processing personnel shall be maintained by the Training Division.

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FORT CALHOUN STATION RW-200 RADIATION PROTECTION PROCEDURE I) Ed Jh j

3[0JU _ PAGE 13 OF 17 7.5.3 Training and qualification records for operators of mobile vendor processing units shall be maintained by the Radioactive Waste operations Supervisor while the vendor is active on site. These records shall be sent to the Nuclear Records Management System after the vendor has completed work on site.

7.6 PROCEDURE CONTROL 7.6.1 On site processing of radioactive waste shall be performed in accordance with approved station prec;3dures.

7.6.2 . Processing of radioactive waste by onsite vendors shall be performed in accordance with applicable Process Control Programs, procedures and applicable NRC guidance.

7.6.3 Procedures for processing, containerization and transport of wastes shall ensure that specific DOT, 10CFR and burial site requirements are satisfied.

7.6.4 Process Control Programs for specific radwaste systems supplied by vendors for on site processing shall be presented to the Plant Review Committee for review and approval prior to use of the system.

7.7 RECORDS 7.7.1 Waste classification records, waste form records and other records required for ti.u preparation of the Fort Calhoun Station Unit No. 1 Semiannual Radioactive Effluent Release Report shall be prepared and retained in accordance with the requirements of.10CFR20, 10CFR71, 49CFR170-178 and the Fort Calhoun Station .

Technical Specifications.

7.7.2 Records vf processing data, test and analysis results and results of training, inspection and audits are retained in accordance with the Fort Calhoun Station Quality Assurance Plan and applicable ,

. station Administrative Procedures.

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RW-200 PAGE 14 OF 17 7.7.3 All certificates of compliance, licenses, criteria and regulations pertaining to processing, packaging, shipment and disposal of radioactive materials controlled under this Process control Program shall be maintained in the most current status. OPPD, Fort Calhoun Station Unit No. 1 shall be currently registered, as necessary, to use applicable packagings.

7.7.4 Sufficient documentation shall be maintained to demonstrate compliance of solid radwaste processing with this Procqss Control Program.

7.8 QUALITY ASSURANCE 7.8.1 Quality Assurance shall be maintained as defined by the Fort Calhoun Station Quality Assurance Plan, Section 11.

7.8.2 The QA Plan shall e'.?sure compliance with NRC and burial.sito criteria for waste classification and waste form.

7.8.3 Audits shall be conducted in accordance with NQA Audit Section Instructions.

7.8.4 The Topiccl Reporte of vendor supplied radwaste processing systers shall undergo review either by the Radioactive Waste operations Supervisor or the Supervisor-Radiation Protection. The review shall ensure the vendor supplied system will be compatible with plant operations and that the Topical report has been submitted to the NRC for review. The review shall be documented by a memo addressed to file.

7.8.5 Audits of a sampling of implementing procedures shall be performed at least once every 24 months. Procedures should be reviewed to encure continual compliance with the requirements and process parameters of this Process Control Program.

7.8.6 Radioactive wastes not described within this document must-be evaluated and approved for inclusion in this Process Control Program or in a vendor Process control Program prior to processing.

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RADIATION PROTECTION PROCEDURE c J PAGE 15 OF 17 7.9 REVISIONS.

7.9.1 Changes er modifications made to design and/or operation of radioactive waste processing, treatment and/or packaging systems or activitics, as described within this Process Control Program, shall require formal engineering evaluation and performance of a safety evaluation in accordance witr 10CFR50.59 and USNRC IE Circular No. 88-18.

7.9.2 Changes made to this Process Control Program and supporting engineering and safety evaluations shall be reviewed and approved by the Plant review Committee prior to implementing the changes.

7.9.3 Changes to the Process Control Frogram approved by the Plant Review Committee shall be submitted to the Nuclear Engineer-In-Charge of Licensing, for input to the Semi-Annual Radioactive Effluent Release Report.

8.0 REFERENCES

8.1 Radiation Protection Procedure RW-201, " Control of Containers" 8.2 -Radiation Protection Procedure RW-202,

" Collection / Sorting / Segregation of Dry Active Waste (DAW)"

8.3 Radiation Protection Procedure RW-203, " Compacting Dry Active Waste (OAW)"

8.4 Radiation Protection Procedure RW-204, " Packaging Non-Compactable Dry Active Waste" 8.5 Radiation Protection Procedure RW-206, " Transfer of Spent Primary Resin to Disposal Containers" l 8.6 Radiation Protection Procedure RW-207, " Operation of the Fix Radwaste Liquid Processing System" l 8.7 Radiation Protection Procedure RW-208, " Transfer of Spent Fix System Resin to Disposal Containers" l 8.8 Radiation Protection Procedure RW-209, " Dewatering Spent Radwaste Liquid Processing Resin and Primary Resin In Disposal Containers" l o

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8.9 Radiation Protection Procedure RW-211, " Removal of Filters From Radwaste Systems" 8.10 Radiation Protection Procedure RW-212, " Packaging Filters" 8.11 Radiation Protection Procedure RW-214, " Collection of Oils" 8.12 Radiation Protection Procedure RW-215, " Processing of Contaminated Oils" 8.13 Radiation Protection Procedure RW-216, " Testing of Sorbent Materials" 8.14 Radiation Protection Procedure RW-218, "10CFR61 Classification" 8.15 Radiation Protection Procedure RW-221, "10CFR61 Sampling" 8.16 49CFR Parts 170 through 178 8.17 10CFR Parts 20, 50, 61, and 71 8.18 USNRC IE Circular No. 80-18 8.19 Standard Review plan 11.4, Rev. 2, including Branch Technical Position ETSB 11-3, Rev. 2 8.20 USNRC Low Level Waste Licensing Branch; Technical Position-on Radioactive Waste Classification, Rev. 0 (5/83) 8.21 USNRC Low Level Waste Licensing Branch; Technical Position on Waste Form,.Rev. 0 (5/83) 8.22 General Criteria for High-Integrity Containers'(SCDHEC) dated 10/22/80 8.23 South Carolina Department of Health and Environmental Control Radioactive Material License

-No. 097, Amendment no. 44.-(Barnwell Facility) .

8.24 Barnwell Special Nuclear Material License No. 12-13536-01, issued'to Chem-Nuclear Systems, Inc.

8.25 Barnwell Site Disposal Criteria, (Chem-Nuclear Systems, Inc.) November 1982 8.26 State of Washington Radioactive Materials License No. WN-IO19-2, Amendment No. 17 (Richland Site)

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[i Mb FORT CALHOUN STATION 3 RW-200 RADIATION PROTECTION PROCEDURE J!) tri. [ . PAGE 17 OF 17 8.27 Hanford Special Nuclear Material License No. 16-19204-01, issued to U.S. Ecology 8.28 Current Vendor Processing Topical Report 8.29 Current Vendor Operating Procedures as referenced in RW-207.

8.30 TFC Nuclear Associates, Inc. Procedure No.

" SEALING", " Procedure for Sealing High Integrity Containers", Rev. 3 (4/9/87) l 8.31 FCS Quality Assurance Plan, Section 11.1 and 11.2 8.32 Fort Calhoun Station Unit No. 1, Updated Safety Analysis Report

'8.33 Fort Calhoun Station Unit hr 1 Technical Specifications Sections 2.9.2, 3.12.2, and 5.9.4 9.0 ATTACHMEffTS None i

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