ML20137F250
| ML20137F250 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/21/1985 |
| From: | Mittl R Public Service Enterprise Group |
| To: | Butler W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20137F256 | List: |
| References | |
| NUDOCS 8508260180 | |
| Download: ML20137F250 (3) | |
Text
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Puthc Servce lAS G Company
{
E Electnc and Gas 80 Park Plaza, Newark, NJ 07101/ 201430-8217 MAILING ADDRESS / P.O. Box 570, Newark, NJ 07101 Robert L. Mitti General Manager Nuclear Assurance and Regulation August 21,-1985
< Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention:
Mr. Walter Butler, Chief Licensing Branch 2 Division of Licensing Gentlemen:
PROCESS CONTROL PROGRAM HOPE CREEK GENERATING STATION DOCKET NO. 50-354 This correspondence transmits for~NRC review the Hope Creek Process Control Program (PCP), as qualified for solidified Class A waste consistent with the requirements of 10CFR61 "Licen' sing Requirements for Land. Disposal of Radioactive Waste".
This submittal supercedes our initial PCP submittal as provided for NRC review in letter from R.L.
Mittl, Public Service Electric & Gas Company (PSE&G) to A. Schwencer (NRC) dated April 8, 1985.
The PCP presented herein addresses the concerns discussed at the meeting between PSE&G repre-sentatives and Mr.
R.
Fell of the NRC on June 19, 1985 at the Hope Creek site, and those areas of concern identified in the NRC draft document entitled " Guidelines for Prepara-tion of a Solid Waste Process Control Program".
This document was provided to PSE&G in a letter from Walter Butler (NRC) to R.L.
Mittl (PSE&G) dated May 15, 1985.
As the attached PCP presents our submittal for a Class A waste program, a description of our prequalification program
-for Class B and Class C waste as required by section 2.2.2.1.1 "Prequalification Tests" of the " Draft Guidelines" is not presented.
PSE&G is currently participating in a testing conformance program sponsored by the Waste Chem Corporation.
8508260180 850821 DR ADOCK 05000354
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Director of Nuclear 2
8/21/85 Reactor Regulation Results of this program shall become available by January 1986.
The objective of the testing program is to demonstrate the ability of the asphalt binder to maintain stability while encapsulating Class B and C wastes.
Based upon the results of this testing program, the Hope Creek PCP will be modified in order to qualify for solidification of Class B and C wastes.
The Hope Creek PCP does not address the production level sampling criteria presented in section 2.2.2.1.2 " Production l
Level Sampling" of the " Draft Guidelines".
PSE&G believes that the inherent design features of the Hope Creek Solid Waste System and associated waste testing conformance program do not mandate such production level sampling.
PSE&G offers the following justification in support of this position:
1.
The Hope Creek solid waste system equipment specifications (M137A and B) include provisions for vendor involvement i
in a rigorous acceptance test program (20 batches of i
500 gallons each produced over 7 days of testing).
This program will assure proper operation of the system for turnover to PSE&G Operations.
2.
Werner/Pfleiderer (WP) Topical Report WPC-VRS-001 Revision 1, May 1978 accepted by NRC, as documented in letter from Karl Kniel (NRC) to Richard Doyle (WP) dated April l
12, 1978, has demonstrated the use of a visco-elastic l
product (Bitumen) for solidification as a mechanical, l
not chemical process.
Removal of heat, forces the waste form to solidfy.
3.
Constitutents such as oil which typically soften the end product are sampled for.
Training of all equipment operators for proficiency plus sampling procedures shall combine to preclude production of a poor waste form.
4.
Commitment to sample the in-coming asphalt supply for compliance with ASTM-D312-71, as stated in section 4.1 of the attached.
5.
Section 4.5 of the PCP identifies the minimum operable components without which this station will not begin to process waste.
This will avoid producing a waste form with a compromised system.
6.
During the processing, if the extruder temperature profile remains in an alarm state for over 2 minutes, interlocks prevent passing water through the machine.
Director of Nuclear 3
8/21/85 Reactor Regulation 7.
PSE&G shall have extensive test data as a result of Branch Technical Position testing performed by Waste Chem.
.This prequalification testing program shall demon-strate the ability of~the system to produce acceptable waste forms, with Class B~and C. waste.
Upon NRC approval of the attached Solid Waste Process Control Program for Class A wastes, Public Service Electric and Gas Company respectively requests that the Hope Creek Gener-ating Station Safety Evaluation Report, Section 11.4.2 be modified to remove the imposition-of an operating license condition for. Class A wastes.
Should you have any questions in this regard, please contact us.
Very truly yours, k.L. YNY 6(!
y Attachment - HCGS Solid Waste Process' Control Program C
D.H. Wagner USNRC Licensing Project Manager A.R.
Blough USNRC Senior Resident Inspector
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