ML20127C979

Semi-Annual Radioactive Effluent Release Rept for Jan-June 1992

ML20127C979
Person / Time
Site:	Callaway
Issue date:	06/30/1992
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-2690, NUDOCS 9209110077
Download: ML20127C979 (48)

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, August 28, 1992 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, D.C. 20555 ULNRC-2 6 9 0 Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT EEMIAl{l{UAL_ RADIOACTIVE EFFLUENT RELEASE REPORT The enclosed Semiannual Radioactive Effluent Release Report for the first half of 1992 is submitted pursuant to Section 6.9.1.7 of the Callaway Plant Technical Specifications.

As of the Submittal date of this report, we have not received the results of the quarterly effluent composite samples for the second quarter. If any activity is detected in these samples an amended report will be submitted.

If there are any questions relating to this information, please contact us.

Very truly yours, p ,

Donald F. Schnell BFH/ dis Enclosure

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920911O0I7 f20630 PDR ADOCK 05000483 f- 1 R PDR \

cc: 1. A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 H. Street, N.W.

Washington, D.C. 20037 Dr. J. O. Cermak CFA, Inc.

18225-A Flower Hill Way Gaithersburg, MD 20079-5334 L. Robert Greger Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Bartlett Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 L. R. Wharton (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 William Kesler Regional Administrator Department of Natural Resources Central Regional Office P.O. Box 176 Jefferson City, MO 65102

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Callaway Plant l

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l Semiannual Radioactive E" fluent 9elease Report

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SEMI A!!]EJAL PADLQACTIZE_FE, Elf?FNT RELEASE REPOPT CALLAWAY frJCLEAR PLANT UNIO!1 ELSCTRIC COMPANY LICEllSE ;'?F - 30 JANUARY - JUNE, 1992 I

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IABLE OF_ CONTE!TTS

1.0 INTRODUCTION

2 2.0 SUPPLE!GITTAL INFOPNsTION 2.1 Regulatory Limits 2.2 Maximum Pomissible Concentrations 4

I 2.3 Average Energy 2.4 Measurements and Approximations of Total Radioactivity l 2.5 Batch Releases 2.6 Abnormal Releasen 3.0 SUM!iARY OF GASEOUS PADIOACTIVE EFFLUENTS 4.0

SUMMARY

OF LIQUID RADIOACTIVE EFFLUEITrS I 5.0 6.0 SOLID WASTE SHIPMENTS RELATED INFORMATION 6.1 Unplanned Releases 6.2 Changes to the Process Control Program i

I 6.3 Changes to the Offsite Dose Calculation Manual

g 6.4 Major Changes to Radwaste Treatment Systems i

g 6.5 Land Use Census Changes 6.6 Inoperability of Effluent Monitoring Instrumentation 6.7 Instances of Liquid Holdup Tanks or Waste Gas Decay Tanks Exceeding Technical Specification Limits Table 1A Semiannual Summation of Gaseous Releases

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Table IB Semiannual Airborne Continuous and Batch Releases Table 2A Semiannual Summation of Liquid Releases I" Table 2B Semiannual Liquid Continuous and Batch Releases Table 3 Solid Waste and Irradiated Fuel Shipments Attachment 1 APA-ZZ-01011, Process Control Program Manual, Revision 2 LI .

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Thin Semiannual Radioactive Effluent Felcace Repott is submitted in I accordance with Section 6.9.1.7 of the Callaway Plant Technical Specifications.

I The report presents a cummary of radioactivity released in liquid and gaseous effluents, and colid wacte chipped from the Callaway Plant during the period from January 1, 1992 to June 30, 1992. The information is presented in the f ormt outlined in Appendix B of I Regulatory Guido 1.21, Revision 1, June 1974.

All liquid and gaseous effluents discharged during this reporting I period were in complia.nce with federal regulations and the limito of Union Electric Administrative Procedure IsPA-ZZ-01003, "Offuite Dose Calculation Manual *.

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I 2.0 SUPPLFZF!HAL m INFQRlq1l.QN 2.1 Pagulatory Limits

" Specified as follows are the radioactive effluent control limits applicable to the release of radioactive material in liquid and gaceous effluents.

2.1.1 Fission and Activation Gases (!;oble Gases)

The done rate due to radioactive ncble gases released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to less than or equal to 500 mrem /yr to the total body and less than or equal to 3000 mrem /yr to the skin.

The air dose due to noble gases released in gaseous effluents, from I each unit, to areas at and beyond the site boundary nhall be limited to the following:

a. During any calendar quarter: Less than or equal to 5 mrad for I gamma radiation and less than or equal to 10 mrad for beta radiation and, I b. During any calendar year: Less than or equal t: 10 mrad for gamma radiation and less than or e qt. a1 to 20 mrad for beta radiation.

2.1.2 Radiciodine, Tritium, and Particulates The dose rate due to Iodine 131 and 133, Tritium and all ,

radionuclides in particulate f onn with half lives greater than eight (8) days released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to less than or equal to 1500 mrem /yr to any orgsn. _

The dose to a member of the public from Iodine 131 and 133, Tritium, I and all radionuclides in particulate form with half-lives greater than eight (8) days in gaseous effluents released to areas at and beyond the t te boundary shal] be limited to the following:

I a. During any calendar quarter:

any organ and, Less than or equal to 7.5 mrem to I b. During any calendar year:

organ.

Less than or equal to 15 mrem to any I

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-I 2.1.3 Liquid Effluents i

The concentration of radioactive material teleased in liquid efflu- l I ents to unrestricted areas shall be limited to the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases. For j

i I dianolved or ent.r aine d noble gases, the concentration shal3 t>e limited to 2.0E-04 microcuries/ml total activity.

The dose or dose commitment to an Individual trom radioactive materials in liquid effluents released to unrestricted areas chall be litnited:

I a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and less than or equal to 5 mrem to an'/

organ, and

b. During any caler-lar year to less than or equal to 3 mrem to the whole body and to less tnan or equal to 10 mrem to any organ.

2.1.4 Uranium Fuel Cycle Sources The annual (calendar year) dose or done commitment to any member of I the public due to relenaes of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mrom to the total body or any organ, except the thyroid, which I shall be limiten to less than or equal to 75 mrem. I 2.2 Maximum Permingil1g_Cprrefyt 2 rations 2.2.1 The maximum permissible concentrations opecified in 10 CFR Part 20, Appendix B, Teble II, Column 2 are used to calculate release rates and permissible concentrations of liquid radioactive effluents at g the unrestricted area boundary. A value of 2.0E-4 microcuries/ml is g used as the MPC for dissolved and entrained noble gases in liquid effluents.

2.2.2 For gaseous effluents, maximum permissible concentrations are not directly used in release rate calculations since applicable limits are stated in terms of dose rate at the unrestricted area boundary.

2.3 byerace Enerav I This is not applicable to the Callaway Plant's radiological effluent control limits.

2.4 Meagp.Jements_and Anorgs.imations of Total Padioactiv uy a The quantity of radioactivity released in liquid and gaseous effluents was determined by sampling and radiological analysis of

,I l-effluents in accordance with the requirements of Table 9.3-A and Table 9.6 A of APA-ZZ-01003, Offsite Dose Calculation Manual.

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!I l Gamma spectroscopy was the primary analysis technique used to det ermine l the radionuclide composition and concentration of liquid and gasecua l effluents. Composite samples were analyzed for Sr-89, Sr-90, and Fe-55

} by an independent l aborat o ry . Tritium and Gross Alpha were measured for j bo':h liquid and gaseous effluents using liquid scintillation counting and gas flor proportional counting techniques, respectively.

! The total radioac'.ivity in effluent releases was determined from the I

measured concentration of each radienuclide present and the total effluent volume discharged.

2.5 Bntsh_EgleAgen t

2.5.1 Ligaid 1

i fiumber of batch releasea 84 n

i Total time period for batch releaces: 33,437 minutes Mtximum time potiod for a batch release 659 minutes 1

Average time period for batch releanes

390 minutes l

! Minimum time period for a batch release: 206 minute 4

1 Average stream flow during periods of effluent release into a l flowing stream: 62,426 cfs'

) *Ref: 1,etter, United States Department of the Interior-Geological Survey Missouri, dated July 7, 1992.

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2,5.2 Gaseous

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I number of batch releases: 55 Total time period for batch teleases: 1,937 minutes Maximum time period for a batch releane: 11,043 minutes Average time period for batch releases: 1,726 minutes Minimum time period for a batch release: 35 minutes 2.6 leagma1 Faltagga ,

2.6.1 Liquid Number of releases: 0 Total Activity released: 0 I

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l 2.6.2.1 Thunber of releases: 1 4

j 2 . 6 . 2 . .' Totsl Activity released: 7.BE-05 Ci  !

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! 3.1 The quantity of radioactive material released in gaseous effluento is j summarized in Tabic 1A and IB, For this reporting period no gaseous effluents were considered elevated releases.

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4 .1 The quantity of radioactive material released in liquid effluents is summarized in Table 2A and 28.

! S.0 EQhlD WAS.IES l

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{ 5.1 The quantity of radioactive material released in shipments of solid

! waste and irradi.ited fuel during. the reporting period is summarized in

= Table 3. Tne ac0ivity and fractional a.>undance of each nuclide was j determined for each waste type by an independent laboratory based upon jg radiochemical analysis. The activity of each nuclide listed in Table 3

'W was detennined as the product of the fractional abundance and the total i activity shipped. Those nuclides which comprise at least it of the total i activity for a pastacular waste type are presented in 'lable 3.

a 6.0 EFMTIP INF0FMATION

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6.I Unn}3nnsd Relsperm d

Unplanned releases are inadvertent or accidental releases of radioactive

g material, or releases of radioactive material via normal pathways without

!g a release permit or proper authorization, or without proper campling and j analysis, or releases which are conducted in such a manner as to result l in significant deviation from the requirements of the release permit.

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l There was one unplanned release during the reporting period.

i On March 24, 1992, the auxiliary boiler was sampled and found to be contaminated. Isotopic analysis.indicatea that I-131 was present at a concentration of 2,9E 8 pCi/ gram. A resample on 03/05/92 confirmed the presence of I-131 at 2.5E-8 pCi/ gram.

The plant operations department was notified immediately to ensure that area drains and boiler blowdown were routed to the liquid radwaste system.

A 10CFR50.59 evaluation was initiated immediately along with an I investigation to determine the source of the activity which had concentrated in the auxiliary boiler.

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To assure that no offsite dose limits would he approached with continued operation of the auxiliary boiler during ref uel 5, a conservative dose calculation was performed assuming a maximum I-131 concentration of i

I 5.0E 08 pCi/ml. The dose to a Mend >er of the Public was calculated to be 2.8E 02 mrem to the child age group which is insignificant with respect to the quarterly and annual critical organ dose limits of 7.5 and 15 I mrem, respectively. The dose rate at the site boundary was calculated to be 1.35E-03 mrem /yr which is also well below the release rate limit of 1500 mrem /yr.

l The post release evaluation showed that 7.8E 05 Ci of I-131 was released to the environment. That was less than 25% af the I-131 activity assumed to be released in the initial dose evaluation described above. The

actual done to the public from this release is negligible when compared to the quarterly and annual effluent control lim!' As a result, the release of radioactive material from the operation of the auxiliary boiler did not endanger the health or safety of the public or the environment.

The activity released is reported in Table 1A and 1B for this reporting i period and will be included in the annual dose calculations.

I The safety evaluation completed for this event was documented in Request l

I for Resolution (RFR) 10028 Rev. A.

Suggestion Occurrence Solution (SOS) 92-0376.

This event was also described by 6.2 ChaDqes to.1he Preteen Centrol Proqrc0 i

I Revision 2 to APA ZZ-01011, PROCESS CONTROL PROGRAM MANUAL (PCP), was reviewed and approved by the Onsite Review Committee. Approval by the Manager, Callaway Plant was obtained on 1/28/92.

This revision incorporated a new section detailing process controls for I the newly installed advanced liquid waste volume reduction system (RVR-800) for the processing and packaging of liquid wastes at Callaway Plant. This section lists the general requirements for waste sampling l and process control conditions to en.<ure that resulting packaged wastes meet the applicable requirements for radioactive waste disposal.

Additional sections were added to the manual entitled " Reporting of

.E Mishaps" and "PCP Archive Sarple Requirements" which detail the '

3 corresponding guidante found in the recently issued NRC Branch Technical Position (BTP) Paper on Jaste Form. Applicable reporting and follow-up requirements are incDwed in these new sections.

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m Changes made in this t 'sion do not alter or otherwise reduce the overall conformance of packaged and/or solidified waste products to exinting requirements of federal, state, or other applicable regulationc.

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A copy of Revision 2 of ndministrative Procedure APA-ZZ-01011 is included as Attachment 1.

6.3 QJan_o,en To The OfLE i te Dose Caj_gy.lation h ia_1 There were no changes made to Administrative Procedure APA-ZZ-01003, "Offsite Dose Calculation Manual", during the reporting period.

6.4 MalpI_Djanges to Padwaste TrealyfJnt Svetems During the reporting period, there were no changes which could Le considered a major change to a Liquid, Gaseous, or Solid Radwaste l Treatment System.

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There were no changes in critical receptor locations for dose calculations during the reporting period.

6.0 Inonerobility qf Ef fluent Monitoripo IrtELI.umentt i;i2D t All effluent monitoring instrumentation was OPERABLE within the limits lI specified by APA-::Z-01003 Sections 9.1.1 and 9.2.1 during the reporting p e ri ot.# .

I C.7 Inntifices of Li.nuid_liglj.up Tanks or Waste Gan Decay Tanks ExqLeding Igghnical Sna.tification Limits I All liquid tanks and waste gas decay tanks were within the limits of Specifications 3.11.1.4 and 3.11.2.6 during the reporting period.

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I 1 ADLE 1 A SUAIANNUAL SUMMA 110N OF OASEOUS RELEASES ALL AIRDORNE ElFLUENTS QUARTERS 1 AND 2,1992 I TYPE OF EFFLUENT UNITS FIRST QUARTER SECOND QUARTER EST TOTAL' ERROR %

A. FISSION AND ACTIVAllON GASES

1. TOTAL RELEASE CURIES 2.72E+ 02 5.8GE+02 20

2. AVERAGE RELEASE RATE FOR PERIOD ACi/SEC 3.40E4 01 7.45E* 01

% N/A N/A I

3. PERCENT OF TECH SPEC LIMIT B. RADIOIODINES

1. TOTAL IODINE-131 CURIES 2.03E-04 2 08E-04 23

2. AVERAGE RELEASE RATE FOR PERIOD sfi/SEC 2.58E-05 3.40E-05

3. PERCENT OF TECH SPEC LIMIT  % N/A N/A W- C. PARTICULATES I

1. PARTICULATE (HALF-LIVES > 8 DAYS) CURIES 6.2SE-07 2.06E-05 30

2. AVERAGE RELEASE RATE FOR PERIOD vCi/SEC 7.95E-08 2.G3E-06

3. PERCENT OF TECH SPEC LIMIT  % N/A N/A _

L4. GROSS ALPHA RADIOACylTY CURIES 1.9CE-06 1.28E-0G

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D. TRITIUM

1. TOTAL RELE ASE CURIES 7.40E+ 00 1.70E+ 01 14

2. AVERAGE RELEASE RATE FOR PERIOD ACi/SEC 9.42E-01 2.10E + 00

3. PERCENT OF TECH SPEC LitffT  % N/A N/A em , o,1

I DLE tu SEMIANNUAL AIRDORNE CONTINUOUS AND DATCH RELEASES I GROUND LEVEL RELEASES FISSION GASES, IODINES, AND PARTICULATES OUARTERS 1 AND 2,1932 I CONTINUOUS RELEASES DATCH RELEASES I FIRST SECOND flRST SECOND j NUCLIDE UNIT QUARTER QUARTER QUARTER OUARTER i

1. FISSION C ASES KR-65M CURIES 1.50E- 01 1.27E-03 I

0.00E 4 00 0.00E 4 00 KR-05 CURIES 2.13E+ 01 8G8E ? 3.29E* 00 1.9BE + 02 KR-07 CURIES 1.86E-01 0.00E+ 0.00E+ 00 0.00E* 00 KR- 08 CunlES 3.71E-01 0.00E+ 00 8.03E-04 0.00E+ 00 I XE- 131M XE-133 XE-133M CURIES CURIES CURIES 0.00E*00 1.03E+ 02 1.05E-01 1.48E+ 00 3.45E+ 00 0.0c 00 1.54 E+ 00 1.30E + 02 1.21 E+ 00 5.35E+01 3.21 E + 02 0.00E

• 00 XE-135 0.00t:.JO I

CURIES 4.57E + 00 3.72E-01 1.02E-01 AR-41 CURIES 0.00E+00 0.00E* 00 4.51 E-01 1.52E-01 4

TOTAL FOR PERIOD CURIES 1.35E+02 1.36E+ 01 1.36E+ 02 5.72E+ 02 I 2. lODINES l-131 l-132 CURIES CURIES 5.41 E-05 0.00E+00 3.27E-05 0.00E+00 1.38E-04 0.00E+ 00 2.33E-04 2.84 E-07 1-133 CURIES 4.05E-06 2.00E-06 6.17E-06 0.00E + 00 TOT AL FOR PERIOD CURIES 5.82E-05 3.47E-05 1.45E-04 2.33E-04

3. PARTICULATES CR-51 CURIES 0.00E+00 7.70E-07 4.05E-07 3.59E-07 CO-57 CURIES 2.20E-07 0.00E + 00 0.00E+ 00 1.13E-10 I CO-58 CO-60 BR-82 CURIES CURIES CURIES 0.00E+00 0.00E+00 0.00E+00 7.53E-06 0.00E+ 00 0.00E+ 00 0.00E+ 00 0.00E+ 00 2.95E-15 1.08E-05 2.57E-07 0.00E+ 00 I ND-95 BR-82 G ALPHA CURIES CURIES CURIES 0.00E+00 0.00E+00 9.78E-07 7.75E-07 0.00E4 00 6.06E-07 0.00E+ 00 2.95E-15 9 83E-07 1.22E-07 0.00E+ 00 6.77E-07 TOTAL FOR PERIOD CURIES 1.20E-06 9.68C-06 1.39E-06 1.22E-05j l 4. TRITlUM __

H-3 CURIES 6.79E+00 7.47E+ 00 614E-01 9.5hi+00 I

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M TABLE 2A SDAIANNUAL SUMMATION OF LIQUID RELEASES ALL LIOUID EFFLUENTS OUARTERS 1 AND 2,1992 FIRST SECOND EST TOTAL 1 I. TYPE OF EFFLUENT UNITS OUARTER OUARTER ERROR 04 A FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) CURIES 1.76E-03 2.12E-03 20

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD Ci/ML 5.34E-09 6.39E+09

3. PERCENT OF APPLICABLE LIMIT 64 N/A N/A D. TRITIUM I 1. TOTAL RELEASE

2. AVERAGE DILUTED CONCENTRATION CURIES 2.35E+ 02 7.18E+ 01 14 DURING PERIOD ,_

Ci/ML 7.12E-04 2.16E+04

3. PERCENT OF APPLICABLE LIMIT  % N/A f;/A C. DISSOLVED AND ENTRAINED GASEL

1. TOTAL ,

• ASE CURIES 5.06E-01 3.82E-03 27

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD vCi/ML 1.54 E-06 1.15E-08 I D. GROSS ALPHA RADIOACTIVITY 2.00E-04 2.27E-04 29

1. TOTAL RELEASE CURIES E. WASTE VOL RELEASED (PRE-DILUTION) GAL 3.69E+ 06 3.89E+ 06 10 F. VOLUME OF DILUTION WATER USED GAL 8.34E+07 8 38E+07 10 PAGE 1 OF 1 I

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TABLE 2B

! SEM1 ANNUAL LIOUlO CONTINUOUS AND DATCH RELEASES i

1OTALS FOR EACH NUCLIDE RELEASED J

OUARTERS 1 AND 2,1992 CONTINUOUS RELEASES BATCH RELEASES FIRST SECOND FIRST SECOND NUCLIDE UNITS OUARTER OUARTER OUARTER OUARTER

1. ALL NUCLIDES H-3 CURIES 0.00E+00 0.00E+ 00 2.35 E+ 02 7.18E + 01 CR-51 CURIES 0.00E+00 0.00E+ 00 9.41 E-05 0.00E+ 00 MN-54 CURIES 0.00E+00 0.00E+ 00 1.04E-04 9.33E-05 CO-58 CURIES 0.00E+00 0.00E+ 00 2.20E-04 3.66E-04 CO-00 CURIES 0.00E+00 0.00E+ 00 7.47E-04 5.93E -04 I I ZN-65 ZR-95 NS-95 CURIES CURIES CURIES 0.00E+00 0.00E+00 0.00E+00 0.00E+ 00 0.00E + 00 0.00E+ 00 2.69E-06 4.97E-05 6.52E-05 0.00E+ 00 0.00E+ 00 2.63E-06 RU-103 CURIES 0.00E+00 0.00E+ 00 1.50E-06 0.00E400 SB-125 CURIES 0.00E+00 0.00E* 00 0.00E+ 00 1.84 E-05 CS-134 CURIES 0.00E+00 0.00E+ 00 4.87E-05 1.07E-05 CS-137 CURIES 0.00E+00 0.00E4 00 9.29E-05 2.93E-05 I l-131 1-133 XE-131M CUR!ES CURIES CURIES 0.00E400 0.00E+00 0.00E+ 00 0.00E+ 00 0.00E+ 00 0.00E+ 00 3.24E-04 8.4BE-00 5.69E-03 1.00E-03 0.00E + 00 0.00E+ 00 I XE-133 CURIES 0.00E+00 0.00E+00 4.89E-01 3.75E-03 XE-133M CURIES 0.00E+00 0.00E+ 00 6.36E-03 0.00E+ 00 XE-135 CURIES 0.00E+00 0.00E+ 00 4.50E-03 7.64E-05 G ALPHA CURIES 0.00E400 0.00E4 00 2.00E-04 2.27E-04 i

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TOTALS FOR PERIOD CURIES 0.00E+00 0.00E 001 2.35E+ 02 7.16E+ 01 i

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TABLF 3

SQLID WASTE (LIRRADI ATED FUEL CHIMTLES 4 CLUARTERS 1 & 2 4 1992

\ A. S$JD WASTL_SJ11EPED OFFSITE FOR 111]EI AL OIL,9ISPOEAL (DOES NOT INCLUDE IRRADIATED FUEL)

{ TYPF OF WASIS G-MONTH EST. TOTAL 1

PERIOD E]LPQE, a K) i 1

a. Spent recina, filter sludges 3.85 m' 1 25%

lg evaporator bottoms, etc. 1.91E+2 Ci i f:

Eg.r gan t Abundanen i (' . Quries ll j

E Co-60 Fe-55 Ni-63 40.420%

32.09C%

21.414%

7.72E+1 6.13E+1 4.09E+1 Mn-54 3.477% 6.64E40

b. Dry compressible waste, 11.4 m' 1 25%

contaminated equipment, etc. 0.773 Ci Percent Abundanca f.u r.i e r Fe-55' 44.79% 3.46E 1 Co-58 23.441 1.81E-1 I co-co 23 o2' 2 o13-2 l g Nb-95 9.34% 7.22E 2 l Mn-54 7.47% S.78E-2 i Zr+95 1.924 1.48E-2 t

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c, Irradiated components, control 0 m' l

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Solid Waste Disposition l Number of Mode of Class of Solid Type of Shinments IIansnortation Destinati2D Wa s t e Shi. pre _d d Container i

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6 Cask Truck Richland, WA Oak Ridge, TN (SEG)

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LSA LSA W

I Solidification Acent i N/A

! D. JJ_ RADIATED FUEL SJIPMENTS (DISf0SITIO!1 j

hThtr of S}tir1nenta Mode of TransnertaticD Destination 0 NA NA l

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I ATTACllMENT 1 APA Z7A1011, PltOCESS CONTitOL pit 0GitAM h1 ANUAL. ILEVISION 2 4

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APA-ZZ-01011 Revision 2 January 27, 1992

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NUCLEAR PUNCTION ADMINISTRATIVE PROCEDURE APA-2Z-01011 PROCESS CONTROL PROGRAM MANUAL (PCP)

RESPONSIBLE DEPARTMENT )O E' Y $ / .t&$ ,

PREPARED BY I f,h . T/N D/\ DATE / 2-

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APPROVED BY / DATE . [J d'/4 2

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4 f - k$- b C5 IS 'o DATE ISSUED fQ r" iI '

JM4 2 91992 ACCOUNTA!KE This procedure contair , the following:

I Pages ,_ _  : through 2S

. Attachments 1 through 2 Tables through Figures- through Appendices through Checkoff Lists , through ___

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APA-ZZ-01011 Rev. 2 L

S i TABLE OF CONTENTS Section race Number

1.0 Purpose and Scope

1 2.3 Definitions 1 3.c Administrative Controls 2 3.1 Major Changes to Solid Radwaste Treatment Systems 2 3.2 Changes to the Process Contrcl Program 3 3.3 Report of Solid Waste Released from the Plant 4

3.4 Reporting of Mishaps Involving Waste Stabilization and High Integrity Containers 5 4.0 10CFR61 Compliance Methodology 7 5.0 Process Controla 8 I 5.1 5.2 Administrative Requirements Collection and Analysis of Samples 8

9 5.2.1 General Requirements 9 5.2.2 PCP Archive (Radioactive) Samples 10 5.2.3 Collection of Samples 11 cc e 5.2.4 Chemical Analysis of Waste Samples 13 1'f 5.2.5 5.3 5.3.1 Radiochemical Analysis of Waste Samples Test Solidification and Acceptance Criteria Waste Conditioning 13 14 14 5.3.2 Test Solidification 14 5.3.3 Test Solidification Acceptability 15 6.0' Radioactive Waste Processing Using Installed 16 i 6.1 6.2 Liquid Volume Reduction System General Requirements Waste Sampling 16 17 6.3 . Process Controls 17 7.0 Radioactive Waste Processing Using 18 Bulk Disposal Methods 7.1 Radioactive Waste Processing Using 18 I Contracted Vendor Services 7.1.1 General Requirements 18 g 7.1.2 Co'M.rol of Vendor Procedures and Documentation 20

[ 7.2 Radioactive Waste Processing Using 21 In-House Bulk Disposal Options 7.2.1 General Requirements 21 lP 7.2.2 7.2.3 Waste Sampling Packaging of Spent Filter Cartridges 22 23 7.2.4 Packaging of Spent Ion Exchange 24 Bead Resin 8.0 References 25

APA-ZZ-01011 Rev. 2 TABLE OF CONTENTS Eection face Nutnbe,E Attachment 1 - Topical Reports Applicable to Callaway t or rU a '}

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APA-ZZ-01011 Rev. 2 I 3 PECORD OF REVISIONS Revision NumLer Revision Date Reason for Revision Erocess Control Program (PCP)

Rev. 0 5er 1983 Initial issue.

Rev. 1 February 1984 Incorporation of NRC review comments.

Rev. 2 Deceaber 1984 Revised to generic, non-procedural format; 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 l I analysis documentation requirements.

Rev. 4 August 1985 I _)

Incorporated Class A " unstable" resin solidification formulation (based upon in-plant testing).

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

Rev. 6 April 1986 Incorporated section

!g dealing with control lg of vendor sen' ices for l packaging of solid

! 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 contracted vendor services to clarify type of senrices involved.

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L Rev. 8 September 1987 Revised recorded boundary conditions / ratios for batch

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solidification; revised acceptance criteria for structural stability incor-porated wording regarding full scale test solidi-fication; minor text wording changes.

Rev. 9 Dacember 1988 hevised format to reflect actual use of document I (program vice procedure) ;

incorporated new section(s) dealing with bulk disposal I of wet radioactive waste; revised solidification formula (s) in-stalled system I solidification based upon vendor recommendation.

hPA-ZZ-010L1 Rev. O July 1989 Incorporation of Tech.

Spec. Amendment OL #1087.

I Formal controls on PCP placed under Admi).istrative Procedure.

Added Commitment Tracking System Numbers (CTSNs).

Rev. 1 August 1991 Removal of installed 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 solic radwaste systems and changes I to the Process Control Program (PCP) Manual. Added new attachment detailing which vendor topical I report / systems approved for use anc new attachment listing High Integrity Containers (HICs) authorized for use at Callaway.

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l Rev 2 January 1992 Incorporation of new process controls text detailing J process controls applicable to use of new installed liquid

'n volume reduction system (RVR) for j processing liquid wastes; added i

nov Administrative Controls Sections detailing " Reporting of I Mishaps" and "PCP Archive Sample Requirements" per requirements found in NRC BTP on Waste Form; added several new commitments to I PCP; Minor text wording changes. _

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i PROCESS CONTROL PROGRAM MANUAL (PCP) 1.0 PURPOSE AND SCOPE l4166 1.1 The purpose of the Process Control l4700 Program (PCP) is to provide reasonable l41638 assurance and documentation that the

_l processing and packaging of solid ra-l dioactive wastes based on demonstrated i processing of actual or simulated wet solid wastes will be accomplished in I l I

l such a way as to assure complianc7 with 10CFR Parts 20, 61 and 71, State i regulations, burial ground require-monts, and other requirements govern-1 l 1 ing the disposal of the radioactive I wastes.

2791 1.2 The PCP contains the sampling, tests, analyses, determinations and formula-tions by which vaste classification, I solidification and/or dewatering of radioactive wastes from liquid systems 2

is assured. The PCP is implemented by Radwaste operating procedures.

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

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

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

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

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g 2.4 Batet - A specified quantity of liquid vactos/ sludges requiring solidifica-tion or dewatering (ie., the amount of

{ vaste content within a tank, or, the amount of vaste content within two or i

I 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

.I have the same physical and chemical characteristics as the whole. If new material is added to a tank's contents I which is currently being processed, a new batch is created and further sam- -

pling must be performed prior to so-lidification or dewatering.

3.0 ADMTNISTRATIVE CONTROLS 3.1 MAJOR CHANGES TO SOLID RADWASTE TREAT-

, MENT SYSTEMS l

l NOTE Union Electric Co. may choose to submit the in-I.

formation called for in i this section as part of the annual FSAR update.

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

l 3.1.1.1 Shall be reported to the commission in the Semiannual Radioactive Effluent I

Release Report for the period in which tae evaluation was reviewed by the On-Site Review Committtee (ORC). The I discussion of each change shall con-tain:

3.1.1.1.1 A summary of the evaluation that led 1 to the determination that the change could be made in accordance with 10 CFR 50.59.

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

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!n Rev. 2 I 3 i 3.1.1.1.3 A detailed description of the equip-I 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-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 maximum 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 lg of radioactive materials in solid lg waste, to the actual releases for the l 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

!g change was reviewed and found accepta-g ble by the ORC. -

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

I 2814 3.2 CHANGES TO THE PROCESS CONTROL PROGRAM 20174 (PCP) l 3.2.1 All changes to the PCP shall be com-I l l

I pleted pursuant to Technical Specifi-cation 6.23 'nd approved as per APA-ZZ-00101, Preparation, Review, Appro-I val and Control of Procedures.

l l 3.2.2 Documentation of the change (s) shall I include:

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APA-ZZ-01011 I- Rev. 2 I3 3.2.2.1 Sufficient information to support the I

l l change together with the appropriate l

analyses or evaluations justifying the l change (s); and I l l

l 3.2.2.2 A determination that the change will maintain the overall conformance of 1

the solidified waste product to exist-

) ing requirements of federal, state, or I other applicable regulations.

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

I l rance.

4 I l 3.2.4 All changes shall be reviewed and app-l roved by the ORC and approved by the I l 1

Manager, Callaway Plant PRIOR to in-plementation.

I 3.3 PEPORT OF SOLID WASTE RELEASED FROM THE PIANT 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 quantities of solid ra-dioactive waste released from the plant as outlined in Regulatory Guide 1.21, Measuring, Evaluating, and Re-I- porting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power I- Plants, " Revision 1, June 1974, with data summarized on a quarterly basis following_the format of Appendix B I- thereof.

3.3.1.1 For solid wastes, the format for Table 3 in Appendix B shall be supplemented with three additional categories; class of solid waste (as defined by 10 CFR Part 60), type of container (e.g.,

I- LSA, Type A, Type B,Large Quantity),

and SOLIDIFICATION agent or absorbent (e.g., cement, urea formaldehyde).

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l42377 3.4 REPORTING OF MISHAPS INVMNING WASTE I l l

l STABILIZATION AND HIGH INTEGRITY CON-TAINERS 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 l cn misuse or failure of waste forms or

_g l concainers used to meet the stability 3 l requirements of 10CFR61 shall be pro-l vided to the Commission. Such mishaps I include, but are not necessarily lim-l ited to, the following:

I l 3.4.1.1 The failure of high integrity contain-ers used to ensure structural stabil-I- _

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l ity. Such failure may be evidenced by l changed container dimensions, cracking 1 or injury from mishandling (e.g.,

~I-l dropping or impacting against another l object).

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3.4.1.2 The_ misuse of high integrity contain-ers, as evidenced by quantity of free liquid greater than one percent of

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l container volume, or an excessive void I_ _ l space within the container; (such use l is in violation of 10CFR61.56(a)).

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APA-ZZ-01011 I-_ Rev. 2 l 3.4.1.3 The production of a solidified Class B l or C waste form that has any of the I following characteristics:

l l 1. greater than 0.5 percent volume of I- l l

free liquid.

l 2. concentrations of radionuclides l greater than the concentrations l demonstrated to be stable in the l waste form in qualification test-l ing accepted by the regulatory I agency.

l 3. greater or lessor amounts of so-lidification media than were used l

I in qualification testing accepted I by the regulatory agency.

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

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latory agency.

l S. shows instability evidenced by l

E l c rumbling, cracking, spalling, l voids, softening, disintegration, l nonhomogeneity, or change in di-l mensions.

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l 6. ovidences processing phenomena l that exceed the limiting process-l ing conditions identified in app-

.I l licable topical reports or process l control programs, such as foaming, I l I

j excessive temperature, premature or slow hardening, production of volatile material, etc.

1 l 3.4.2 Waste form mishaps should be reported I to the NRC's Director of the Division l of Low-Level Maste Management and De-E l commissioning and the designated State 5 1 disposal site regulatory authority I within 30 days of knowledge of the in-l- cident.

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L l 3.4.3 For any such vaste form mishap occur-1 rence, the affected waste form should 1 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 I an acceptable justification concerning l

the lack of any potential signiticant i effects of the affected waste form on I I l

1 the overall performance of the dispo-sal facility must be provided to the disposal site authori"y and other reg-ulatory agencies, as appropriate, I

l 1 prior to the vaste form being shipped i I to a disposal facility.

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I NOTE The reason for this is that the low-level waste generators and proces-sors are required by I l 1

I 10CFR 20,311 to certify that their waste forms B

fT l meet all applicable re-I j> l i

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

of misheps mentioned I l I

1 above may not possess the required long-term l structural stability.

I 4.0 10CFR61 COMPLTANCE METHODOLOGY I

12713 4.1 12720 142371 All packaged radioactive vastes generated at the Callaway Plant shall meet the requirements of Title 10 Code l42372 of Federal Regulations Part 61 1 (10CFR61) . As a minimum, all radioac-l tive waste stream sources must be l sampled and analyzed on an annual ba-l sis for development of applicable ra-l dionuclide correlationc for determin-1 ing waste classification and packaging i requirements.

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-g. Rev. 2 l2715 4.2 Waste Classification (10CFR61.55) requirements shall be met by the I 12728 l2731 l

methodology established in plant oper-ating procedure (s) governing Waste l Classification. Waste Characterization I l

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l (10CFR61.56) requirements shall be met by a combination of the nethodology stated in the Process Control Program I l l

j and related Callaway Plant Operating Procedures. Stability requirements stated in 10CFR61.56 (b) and by burial site shall be met and ensured prior to I

1 l shipping packaged radioactive waste I offsite for burial.

4.3 Additionally, the use of NRC-approved

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

5.0 PROCESS CONTROLS 5.1 bDMINISTRATIVE RECUIRMENTS

. 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

.adioactive waste and contaminated disposable labware utilized in the performance of the methods described y in the PCP should be disposed of as radioactive waste.

5.1.2 Administrative controls governing the

'bse and disposal of oils, greases and chelating agents should be utilized as

E a means to control and/or limit the

'E production of wastes containing these substances. In the event that chemical analysis of process wastes _for these I' substances is imprectical due to phys-ical restrictions or analytical con-strai'ts, determination of their pres-ence (or absence) may be made utiliz-ing appropriate evaluation techniques.

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l APA-ZZ-01011 m Rev. 2 I~ 3 l41885 5.1.3 With solidification or dowatering not I l1911 I

meeting disposal site and shipping and transportation requirements, shipment of the inadequately processed wastes l

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l shall be suspended. Additionally, the Process Control Program, its imple-menting procedures and/or the Solid Waste System shall be corrected, as I

l I necessary, to prevent recurrence.

l l41885 5.1.4 With solidification or dewatering not I 11911 l

l performed in accordance with the Pro-cess Control Program, the improperly processed waste in each container, as applicable, shall be tested to ensure I l l

1 that it meets burial ground and ship-ping requirements. Appropriate admi-I nistrative actions shall be taken to prevent recurrence.

l4166 5.1.5 Prior to batch solidification of I l I

l wastes to be solidified, vaste classi-fication and acceptability for near-curface disposal shall be determined.

g i This will involve calculating the ac-I j' l

I l tivity within the projected waste con-tainer using the isotopic analysis of the batch and the actual solidifica-I l I

l 5.1.6 tion formulas to be used.

Prior to packaging of wastes using other processes (e.g., immobilization I

l i or dewatering, etc.), waste classifi-l cation and acceptability of process l method chosen for near-surface dispo-I I l

l sal must be determined. This will in-volve calculating the activity within the projected waste container using g I the isotopic analysis of the waste to ig I be processed and packaged.

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5.2 COLLECTION AND ANALYSIS OF S AMPLES l

B l 5.2.1 _ General Requirements (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-sentative test sample from at least L cvery tenth batch of each type of wet radioactive vaste solidified.

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I APA-ZZ-01011 Rev. 2 141886 5.2.1.2 If any test sample fails to solidify, j solidification of the batch under test l shall be suspended until such time as I l l

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

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

I alternative solidification parameters determined.

I 141886 5.2.1.3 l

l If the initial test sample from a batch of waste fails to verify solidi-fication, then representative test 3 I samples shall be collected from each I consecutive batch of the same type of I waste until three (3) consecutive in-l itial test specimens demonstrate so-l lidification.

5.2.1.4 For high activity wastes, where han-dling samples could result in person-I ',) 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.

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I Typical unexpended mixed bead resin may be used to simulate the spent bead resin.

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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.

5.2.2 PCP ARCHIVE SAMPLE REOUIREMENTS l 5.2.2.1 As per the Appendix to the NRC Branch l Technical Position paper on Waste

~I l Form, dated 1/24/91, archiving of PCP l test sample specimen must be performed l for all Class B and C wastes that are I_ I stabilized using cement.

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

I evaluated at 6 and 12 month intervals after the actual stabilization.

l 5.2.2.2.1 Testing must encompass a verification I- l I

of compressive ctrength > 60 lbo after immersion in water for at least 14

[ days.

I l l43777 5.2.2.3 I

If a tested specimen does not meet the acceptance test above, it shall be I l l

i presumed that all containers of waste packaged per that PCP formulation do not meet 10CFR61 stabilization requir-l ements.

.I- l l 5.2.2.3.1 Reporting of failute of tested speci-l men to meet acceptance criteria shall NE l be made to the Commission as well as t$ l to the burial facility where the pack-l aged waste had been disposed.

5.2.2.3.2 Any containers of material packaged l with this formulation on site will l need to be retested or otherwise re-packaged to ensure 10CFR61 stability

'I .). I I requirements are adhered to.

5.2.3 Collection Of samples 5.2.3.1 Sample Analysis Documentation l 5.2.3.1.1 For wastes that are to be solidified, I pertinent information on the charac-I teristics of test sample solidifica-I l 1

i tion must be recorded in order to ver-ify solidification of subsequent batches of similar vaste without re-testing. If waste pretreatment is no-I l I

l cessary prior to actual batch solidi .

fication, the agent used and amount added must be recorded, i

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I- APA-ZZ-01011 Rev. 2 5.2.3.1.2 The test sample data for waste must include, but is not limited to: the type of wastes solidified; percent to-tal solids; pH; amount of oil in the

-E sarnic Additionally, reoorded infor-3 mation should include the batch number, vaste type, waste classifica-tion, total wastes received, total I binding agent (s) added and the date solidified.

5.2.3.2 Takina samples l 5.2.3.2.1 A sample (s) of the vaste tank's con.

tents to be processed / packaged must be I'

l l taken in order to determine the actual l process formulation for solidifica-l- tion, any pretreatment of the waste I l l-needed prior to solidification or oth-er process and packaging method, and l the waste classification of the final I packaged waste product.

5.2.3.2.2 Sample sizes, as determined by the Radwaste Department, should be compat-ible with the standard size samples used for radioactivity and chemical analysis. If the radioactivity levels I are too high to permit full size sam-ples to be.taken, then smaller samples should be taken with the results cor-rected accordingly.

l 5.2.3.2.3 Sufficient sampling lead time should i be allotted prior to planned waste so-1 lidification of a batch to allow ade-l quate time to complete the required l testing and verification of solidifi-l cation, as applicable. The contents of l the waste tanks that are to be pro-l cessed / packaged must be recirculated 1 (mixed) prior to sampling to ensure I that a representative sample is ob-l tained.

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L- l 5.2.3.2.4 If the contents of more than one tank l or container are to be packaged in che l same container, then representative l samples of each tank (container) should be drawn. Thece campics should I l

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l be of a sufficient composition that if "X" percent of the total waste to be l packaged is to be taken from one of l the tanks, then the sample taken from l that tank should be the same percen-

[ tage in the composite sample. The sam-I l l

l ples taken of each should be mixed in the proper proportions to yield a standard size sample, 5.2.4 Chemical Analysis of Waste Samples 5.2.4.1 Evaporator bottoms and chemical wastes I must be analyzed for total solids, oil content, boric acid concentration and pH. Spent resin beads and charcoal to I 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 dewatering).

I 5.2.4.2 Results of chemical analysis must be documented.

5.2.5 Radiochemical Analysis of Waste Sam-ples j 5.2.5.1 A gamma isotopic analysis must be per-I l i

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formed on each batch of waste to be packaged. This analysis is used in determining an acceptable packaging method as well as vaste classification I

l i of the packaged waste, l

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

5.2.5.3 Sampling of individual demineraliz-ers/charcoa) sdsorbers is performed during vesst changeouts. These sam-ples are composited to determine the batch sample f-or gamma isotopic analy-sis.

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5.2.5.4 The results of the gamma isotopic I analysis must be recorded on/ attached to the documentation package.

TEST SOLIDIFICATION AND ACCEPTANCE I

5.3 CRITERIA 5.3.1 Waste Coaditionin_g

( 5.3.1.1 Prior to test sample solidification, j the pH of the tank must be adjusted to I j 1

l a range of 5 to 9 pH. Should adjust-mont be necessary, the agent and quan-tity used must be recorded.

I 5.3.1.2 If oil is present in quantities great-er than it by volume, dilution of the batch to below 11 is required prior to solidification.

5.3.2 Test Solidi [,ication 5.3.2.1 Whenever pretreatment of a batch is necessary, the tank contents must have the required pretreatment accomplished Ig j prior to pulling the sample for test solidification analysis.

5.3.2.2 A test solidification container should II. be prepared with a mixing dcVice.

5.3.2.3 The appropriate proportional amount of portland cement and sodium metasili-I- cate and/or other solidification media per the applicable test solidification I procedure must be added. A known re-presentative volume of the vaste must be transferred to the test solidifica-tion container.

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5.3.2.4 Mixing of the vaste, portland cement I and/or other solidification media is then initiated. After appropriate mix-ing or when a homogenous mixture is I obtained, the cement / waste mixture must be allowed to stand for a spec-ified time period. Any free 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 calculate the percent free liquid. Re-sults of this analysis must be docu-mented.

5.3.3 Test Solidification Accootability 2720 5.3.3.1 The test sample solidification shall I be considered acceptable from a free liquid standpoint if the amount of free liquid is the lessor of either 1%

by volume or burial site limits.

I 5.3.3.2 The test cample solidification shall l

be considered acceptable from a solid

, mass standpoint (i.e., structural sta-l bility) if the surface of the sample

! resists penetration when probed with a spatula or comparable firm object.

5.3.3.3 If either or both of the above checks fail to meet the stated criteria, the I waste sample analysis and/or the sam-ple solidification formula must 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-ple solidification performed using this corrected formula.

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

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APA-ZZ-01011 I- Rev. 2 I) 41886 5.3.3.5 If the initial test solidification of a batch is unacceptable, then a repre-

.I sentative sample shall be test solid-ified on each subsequent batch of the I same type of waste until three consec-utive test samples demonstrate solidi-fication.

I 5.3.3.6 If a test sample fails to provide ac-coptable 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. -

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i 6.0 RADIOACTIVE WASTE PROCESSING USING IM-STALLED LIOUID VOLUME REDUCTION SYSTEM I l l

l 6.1 6.1.1 General Reauirements The installed radioactive waste liquid l volume reduction (RVR) System will be i used to process most aqueous wastes l (i.e., evaporator conenntrates, floor

.N l drain and sump sludges, etc.) from I- ) [

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

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

' l the RVR System.

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

I RVR Systen is detailed in chapter 11.0 of the Callaway Plant FSAR.

6.1.3 All containers used for packaging I

l l wastes processed using the RVR System 1 must be inspected prior to use to en-I sure they are free from defects.

2713 6.1.4 The RVR System process produces a re-l- sulting waste product that will not

.g I meet 10CFR61 stability requirements.

g l The RVR shall only be used for pro-l cessing / packaging wastes that will re-l sult in a vaste classification of l Class A.

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4 APA-ZZ-01011

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l 6.2 Waste Sand 1inc 6.2.1 RepresentcAve samples of liquid l wastes to be processed by the RVP Sys-6.em must be obtained and analyzed for I

l

] chemical and radicchemical content, as I appropriate.

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I 6.2.1.1 Chemical analyses required include as a minimum; total solids, oil content and pH, 6.2.1.2 A gamma isotopic analysis must be per-i formed on each batch of waste to be -

l proccused. An appropriate concentra-l l tion factor must be applied to the W l analysis results in order to derive l the waste classification of the re-I l l

l 6.2.1.2.1 sulting packaged waste.

Gamma isotopic analysis performed on l processed waste discharged from the l RVR do not require application of a

_I i concentration correction factor.

. l l 6.2.2 Samples are drawn from the evaporator I' l l

bottems tank (s) or from individual containers of liquid waste sludges for i performing this batch analysis.

l l 6.2.3 Results of chemical analyses and gamma l isotopic analyses must be recorded

.g i on/ attached to the applicable batch g-l documentation package.

} 6.3 Process Controls

.I i l 6.3.1 Operation of the installed RVR System i must be performed and documented per approved plant operating procedures.

1 6.3.2 In order to ensure production of a I I 1

l waste product meeting desired " dry-ness" prior to final packaging, pro-ass parameters must be controlled and i r .itored during all stages of system i operation (i.e., filling, drying , mix-l ing and final purpout of waste pro-l duct).

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APA-ZZ-01011 Rev. 2 l 6.3.3 Key operating parameters such as oper-I l l

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

6.3.4 A final material dryness " endpoint"

] must be met prior to considering the  !

material dry within the blender / dryer.

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l This " endpoint" is met through a se-l quence of system manipulations where 1 l the RVR blender / dryer contents are cycled above saturation temperature I. l l

l several times to drive off remaining water from the contents. The sequence I of steps to do this is detailed in system operating procedures.

l 6.3.5 Following the " endpoint", parafin may l be added to the blender / dryer for mix-1 ing with the dried processed waste l powder to immobilize the powder and l keep it from readily dispersing in the I- l 1

air.

1 l2713 6.3.6 Should packaged wastes be created that Ij j l

exceed a wasts classification of Class A, the resulting paesaged waste con-l tainer shall be placed into an over-I l l

l pack container capable of meeting 10CFR61 stability requirements prior

~

to shipment offsite for disposal.

7.0 RADIOACTIVE WASTE PROCESSING USING EULK DISPOSAL METHODS I 7.1 RADIOACTIVE WASTE PROCESSING USING CONTRACTED VENDOR SERVICES

.l 7.1.1 Processing and Packaging of Primary 1 and Radwaste System Wastes i

m s 1. 7.1.1.1 General Requirements

~ l41886 7.1.1.1.1 Contracted vendor services shall be

-l provided to process and package ra-l dioactive wastes to the required waste i form to satisfy the applicable trans-l portation and disposal requirements I for those instances when the installed l colid radioactive waste system is in-l capable of processing these wastes.

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g APA-ZZ-01011 g Rev. 2 l I )

l41886 7.1.1.1.2 Contracted vendor services will be es-tablished for the packaging of wet ra-

.I l l dioactive vastes by vendor solidifica-l tion and/or dewatering. Contracted I l l

l vendor services may be exercised when, in the opinion of plan

• management, any of the following conditions exist:

I 1

l l a. The installed system is declared l l out-of-service thereby reducing or g i eliminating the capability of Cal-1 laway Plant to efficiently and le-l3 l gally package radioactive wastes l in accordance with all applicable I requirements governing the dispo-l sal of the wastes; or, I

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b. The installed system is incapable of packaging these wastes in ac-cordance with any of the applica-

!g i ble requirements (e.g., 10CFR61.)

g l governing the disposal of these l l wastes; or, I c. When processing and packaging eco-

st l nomics show an incrocsed cost o f-- '

l l .ficiency of vendor processing ver-l sus installed system processing, j 4618 7.1.1.1.3 Specific programmatic controls for these services will be handled in ac-

,I cordance with the vendor's Quality As-surance program. This program shall bc l approved by Union Electric Quality As-surance pilor to implementation of the

.I contracted services.

l 7.1.1.2 Control Of Vendor Procedures And Docu-Inentation l

7.1.1.2.1 Vendor procedures covering equipment B setup, operation, and removal must be j reviewed and approved in accordance I with plant administrative procedures prior to implementation.

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!g APA-ZZ-010ll E Rev. 2 l )

l 7.1.1.2.2 Vendor procedures detailing the ven-l dor's Process Control Program (PCP) in addition to t> review and approval mentioned above must also t ?. reviewed and approved by the Onsite Review Com-

'I mittee prior to implementation. The vendor PCP must provide for the sam-pling, tests, analyses and formulation I determin*' ion, as required by the Cal-laway P3 3 - PCP.

I 4955 7.1.1.2.3 Results of all testing and analyses shall be documented, as necessary, to ensure compliance with the vendor PCP and all applicable transportation and burial ground requirements governing the disposal of these vastes.

I 4955 7.1.1.2.4 Copics of all documentation attesting to compliance with the requirements of the vendor PCP as wall an any plant operating procedures utilized in sup-

'I port of the contracted vendor service shall be retained by the plant for in-g clusion in plant files. Documentation

I containing proprietary information i- should be appropriately handled and I

controlled to ensure the required de-I 1 7.1.2 gree of confidentiality is met.

Processing.and Packagina of Secondary l and Support S_ynlem Wasten l

lI l 7.1,2.1 General Recuirements l 7.1.2.1.1 Contracted vendor services must bc l provided to process and package ra-l l dioactive wastes to the required waste I form to satisfy the applicable trans-l portation and disposal requirements i for wastes which are generated outside

! 1 the RCA/ Power Block of the plant or

'g I where expertise in handling same is 3 } not available at Union Electric, i

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' APA-ZZ-01011 Rev. 2 I 3 l 7.1.2.1.2 These contracted vendor services may

,l' l be established and exercised for pro-lm l cessing and packaging of any of the l following contaminated wastes:

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

I- l l b. Mixed wastes (i.e., waste exhibit-l ing characteristic hazardous mate-I l l

I rial which have become radioac-tively contaminated.)

l4618 7.1.2.1.3 Specific programmatic controls for i these services will normally be l handled in accordance with the ven-I dor's Quality Assurance Program. This I program shall be approved by Union

.I. l Electric Quality Assurance prior to l implementation of the contracted ser-I l l 7.1.2.1.4 vices.

For those cases where the vendor ser-i vice is not performed per an estab-

)f lished, acceptable vendor Quality As-I- l l surance F ogram, applicable require-I ments of the Union Electric Quality l Assurance Program are to be implement-1 ed.

l l 7.1.2.1.5 Control of vendor procedures _and/or I-. l documentation utilized or created in I support of the contracted service must i be handleo per applicable guidance I l I

found in step 7.1.1.2 of this proced-ure.

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J l APA-ZZ-01011 B Rev. 2

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7.2 RADIOACTIVE WASTE PROCESSING USDJG IN-HOUSE BULK DISPOSAL OPTIONS 7.2.1 General Recuirements 7.2.1.1 All containers used for solidification or dowatering must be inspected to en-sure they are free from defects. Steel l containers used for dowatering must be incpected to ensure that their inter-i nals are intact and undamaged. High I Integrity Containers (HICs) must be inspected to ensure that they are in compliance with their Certificate of Compliance as well as ensuring that I their internals are intact and undam-aged.

I 2720 7.2.1.2 All wastes dewatered in steel contain-ers shall be devatored in accordance with approved procedures for which testing has demonstrated that the I' one-half of one percent (0.5%) draina-ble liquid criteria can be met. All

) wastes to be dewatered in HICs shall IJ be dewatered in accordance with app-roved procedures for which testing has demonstrated that the one percent ( 1 %. )

I drainable liquid criteria can be met.

Test data to ensure compliance may be based upon container supplier testing.

7.2.2 Waste SamplirLq 7.2.2.1 Representative samples of wastes to be

,E processed by bulk disposal means must B be obtained and analyzed for chemical and radiochemical content, as approp-r riate. Based upon this analysis, the i

packaging process as well as the con-tainer to be utilized will be deter-mined.

l 7.2.2.2 Results of all analyses must be docu-mented, as necessary, to ensure com-

, pliance with all applicabic packaging, i transportation and burial ground re-quirements governing the disposal of these vastes.

AP?.-ZZ-01011 lI Rev. 2 1

l l

' 1 7.2.3 packacing Of Spent Filter Cartridges 7.2.3.1 Packaging of spent filter cartridges will be performed in either steel drums and Low Specific Activity (LSA) boxes or in High Integrity Containers (HICs), dependent ur9n vaste classifi-cation of the spent filter car-tridge(s) involved.

7.2.3.2 Determination of waste classification I will be performed based upon dose to curie correlations of the spent filter cartridges. The methodology involved must be covered in approved plant I. operating procedures.

2720 7.2.3.3 Spent filter cartridges which meet the requirements of Class A waste may be iI packaged in common 17H drums with up to 12 filter cartridges per drum or packaged in LSA boxes. Absorbent media I shall be utilized to absorb twice the volume of any incidental liquid within T the container. Packaging methods gov-IJ crning this process must be covered in approved plant operating procedurers .

(See attachment 2, High Integrity Con-tainers (HICs) Authorized for Use at I Callaway).

42376 7.2.3.4 Spent filter cartridges requiring sta-bilization per the requirements of 10CFR61 or having concentration ex-coeding 1 pCi/cc for radionuclides LE with half lives greater than 5 years lB shall be packaged in HICs. Specific radiation and curie content limita-

g tions for use of the HIC, as iden-g tified on the applicable Certificate of Compliance, must be met and ensured prior to disposal of the waste. Pack-

! aging and dewatering of the HIC con-ents must be performed and documented using approved procedures.

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_ APA-ZZ-01v11 3 Rev. 2

'4

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l42375 7.2.3.5 HICs purchased for use in packaging l spent filter cartridges shall ba de-1 -

I signed to nect the applicable regt11re-l nonts found in the NRC Branch Techni-l cal Position paper on Waste Forn dated l 1/24/91.

7.2.3.6 Common packaging of spent filter car-tridges and spent d on exchange bead

=

resin may be performed in HICs pro-vided for that purpose, with specific instructions for loading and dewater-1 ing covered in approved plant proced-ures.

^l 7.2.4 Pachacina of Spent Ton Exchance Boad Resin 7.2.4.1 opent resin to be packaged should be U

sampled prior to sluicing in order to ensure the proper container required for packaging the resin is utilized.

4. 9 7.2.4.2 Packaging of spent ion exchange bead 1 resin may be performed utilizing dowa-

-I j- tering processes in lieu of solidifi-cation. Class A Unstable vastes may be C Natered in steel containers, while

.ble wastes, regardless of class, 1 shall be dowatered in HIC's.

7.2.4.3 High Integrity Containers trust be used for the disposal of unsolidified spent l ion exchange bead resin when the con-centration of radionuclides with half lives greater than 5 years exceeds 1 1_ pCi/cc. (See Attachment 2).

[42375 7.2.4.4 HICs purchased for use in packaging i spent ion exchange bead resin shall be I designed to meet the applicable re-l quirements found in the NRC Branch l Technical Position paper on Waste Form 1 dated 1/24/91.

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APA-32-01011 Rev. 2 L I L 7.2.4.5 Procedures governing the sluicing of spent resins from domineralizer beds

. and/or storage tanks must be written and approved for use prior to commenc-ing sluicing operations. Applicable 1 radiological controls (i.e., shicid-ing) should be utilized to ensure the process in ALARA.

l42374 7.2.4.6 Dewatering processes utilized nust be i performed and qualified using approved plant procedures. Appropriato nethods I

l I shall be employed to ensure the appli-

! cable drainable liquid criteria of -

l 10CTR61 is met prior to final sceling i of the container for disposal.

8.0 EUFRENCES 8.1 10CF"20 8.2 10C1461 8.3 10CFR71 l 8.4 Reg. Guide 8.8, Revision 3 8.5 Callaway Plant FSAR Chapter 11.4 l 8.6 Technical Specification 6.13.1 (CTSN I l I

420174) l 8.7 Technical Specification 6.13.2 (CTSN l $2814) -

l 8.8 APA-ZZ-00101, Preparation, Review, l Approval and Control of Procedures

) 8.9 NRC BTP on Waste Form (dated 1/24/91) 8.10 Reg. Guide 1.21, Revision 1, June 1974

) . . . . _ _ . . . . _ . . . _

. _ _ _ . . . ~ _ _ . . . . _ _ _ _ _ _ _ _ . _ . _ _ . _ _ _ _ _ _ . _

I APA ZZ 01011 Rev. 2 ll >

TOPICAL REPORTS /tPPLICASLE TO CAL 1#.*AY PIRrr PROCESS CONTROL PPOGP>M (PCP) l l

The Po11owing vendor topical reports have been reviewed and

{

incorporated, as appropriate, into procedures which implement the l Callaway Plant Process Control Program (PCP).

I 1. VMC 102 NP A, RADMAN A Computer Code to Classify and Document I

i Packaged LLV In Accordance with 100FR Part 61 Regulations; Waste Management Croup, Inc.

2. VF C 01 NP, Topien1 Report for Chem Nuclear Systems, Inc. 10CTR61 Vaste Form Certificatio -Cement; Chem Nuclear Systems, Inc.

.I 3. 4313 01354-01-A, Topical Report for Chem Nuclear Systems, Inc.

Mobile Cement Solidification System; Chem Nuclear System, Inc.

4 DV 11118 01 NP A, Topical Repore for Chem-Nuclear Systems, Inc.

Dewatering Control Process Containers; Chem Nuclear System, Inc. ,

5. STD R 05-011NP A. Topical Report for Vestinghouse Hittm Mobile Incontainer Dewatering and Solidification System (MDSS); i Vestingbouse Hittman Nuclear, Inc.

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Page 1 of 1 Attachment 1

r. - . - . -., , , , , , , .--.s -- . , , . , -

,e., , , , ,4--- --.--,

APA :'2 01011

- Fev. 2

[' 15,?)1 s' ' eld' CONTAlt;ERS (IllCs ) AUT110F1 ZED FDP USP AT

^

CALIAVAY PINTT b

u The following liigh Inte3rity Containers (IllCs) have been authorized for use in packaging Callaway Plant vsstes. Applicabic requirements for

- their use, as defined in their individual Certificates of Compliance, are detailed in plant operating procedures-111C CERTIFICATION

• DESCRIPTION VE!! DOR / SUPPLIER D1tEC-li1C l'L-004 RADLOl: 55 Vestinghouse liittrr.an or JEC DilEC li1C PL-014 IMDLO) 500 Vestinghouse liittrz.an or SEC DliEC li1C PL-001 C11SI-PL6 60 Chett liuelcar Systems, Inc.

DilEC-ilIC PL-010 liUli1C-120F TFC liuelear Associates. Inc.

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J Page 1 of 1 Attachment 2