ML20129H155

Proposed Tech Spec,Incorporating Surveillance Requirements for Solid Radwaste Into Section 3.12.Discussion of NSHC Encl

ML20129H155
Person / Time
Site:	Fort Calhoun
Issue date:	06/04/1985
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20129H137	List: ML20129H134 ML20129H144 ML20129H155
References
NUDOCS 8506070495
Download: ML20129H155 (2)

Text

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. , a 3.0 SURVEILLANCE REQUIREMENTS 3.12 Radiological Waste Sampling and Monitoring (Continued) 3.12.2 Solid Radioactive Waste Applicability Applies to the sampling, testing, and analysis of the wet radioactive waste.

Objective l

t To ensure that the solid radioactive wastes meet the limits specified +

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in Section 2.9.2 of these Specifications.

I l Specifications (1) The Process Control Program (PCP) shall be used to verify the solidification of at least one representative test specimen (drum) from at least every twelf th batch of wet radioactive waste (e.g., evaporator concentrates).

A. If any test spec' men fails to verify solidification, the following actions shall be taken:

(i) Verify solidification of all other drums from the batch under test.

(ii) Review the adequacy of the solidification parame- )

ters defined in the PCP and develop / verify alter-

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native solidification parameters, if required, in accordance with the PCP. I j In the event the solidification parameters are al-tered:

(a) Select one representative drum from each con-l secutive batch to verify solidification until l at least 3 consecutive drums verify solidt fi-l cation. The surveillance schedule defined in i Speci fication 3.12.2(1), above, may be re-sumed after 3 consecutive drums verify solid-i fication. .

(b) Modify the PCP as required and report the changes to the NRC in accordance with Speci-fication 5.9.4.a.

Basis This specification was developed to e..:ure the requirements of 10 CFR Parts 20 and 71 for solid radioactive waste are met. The purpose of placing wet radioactive wastes in a solid, dry fonn is to limit dis-persion of radioactive material to the environs in the event of fail-ure of a disposal container (drum) before, during or after disposal.

These requirements provide periodic documentation that solidified wet radioactive waste materials are in suitable fonn for transportation and disposal. 6 P

Discussion, Justification and

! Significant Hazards Consideration Discussion The surveillance requirenents which will be established by proposed Technical Specification 3.12.2 will ensure that solidified wet radioactive waste mater-ials meet the requirenents of 10 CFR Parts 20, 50 and 71 and are in an accept-able form for transportation and disposal. These. surveillance requirements and the referenced Process Control Program (PCP) provide for documented inspec-tions of representative test specimens (drums) approximately every six (6) months. In the event complete solidification does not occur, this specifica-tion provides for inspection of other drums from the batch under test, review of the solidification parameters for adequacy, development of alternative solidfication parameters, if necessary, and subsequent verification of alter-native solidification parameters, if implemented.

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Justifiestion The proposed. Technical Specification 3.12.2 is submitted in response to the re-quirements of the Radiological Effluent Technical Specifications for PWR's (NUREG-0472).

The model specification presented in NUREG-0472 has not been duplicated due to the District's current methodology for solidification of wet radioactive waste materials. The proposed specification will satisfy the requirenents of the Federal Regulations governing solid radioactive waste materials in addition to

' the requirenents of specific disposal sites.

l Significant Hazards Consideration The proposed Technical Specification 3.12.2 has been reviewed with respect to l the requirements of 10 CFR 50.59 and resulted in the following conclusions:

The change will not increase the probability or consequences of an accident previously evaluated because the change does not involve or affect any equipment necessary to mitigate the consequences of an accident. The change provides surveillance requirements necessary to implement specification 2.9.2 for Solid Radioactive Waste.

-The change will not create the possibility of a new or different kind -

of accident from any previously evaluated because no new equipment or systems are being installed. The change is to provide adminstrative controls which will ensure all solidified wet radioactive wastes are acceptable for transportation and disposal.

The change will not reduce any margins of safety because it estab-itshes administrative controls to ensure compliance with applicable regulations. The margin of safety may actually be increased because the change will result in formal documentation that the PCP is effective and that waste is solidified prior to shipping.

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