ML20155E934

Process Control Program

ML20155E934
Person / Time
Site:	Comanche Peak
Issue date:	10/07/1988
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20155E922	List: ML20155E934 TXX-8869, Requests Approval of Encl Final Draft, Process Control Program
References
PROC-881007, NUDOCS 8810130064
Download: ML20155E934 (27)

Text

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g PROCESS COSTROL PROGRAM TU ELECTRIC COMANCllE PEAK STEAM ELECTRIC STATION

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TABLE OF CONTENTS Page List of Figures iii

1.0 INTRODUCTION

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1.1 PURPOSE 1-1 1.2 SCOPE l-1 1.3 PRECAUTIONS / LIMITATIONS 1-1 l

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j 1.4 RESPONSIBILITIES 1-2 2.0 PROGRAM DESCRIPTION 2-1 t

i 2.1 PROCESSING OF WET RADIOACTIVE WASTE 2-1 2.1.1 Processing Methods 2-1

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2.1.2 Processing System Description 2-1 2.1.3 Prequalification Testing 2-1 2.1.4 System Qualification Tests 2-1 2.1.$

Equipment / System Operability Requirements 2-2 2.1.6 Batch Preprocessing Sampling 2-2 2.1.7 Surveillance Testing 2-2 2.1.8 Acceptance Criteria 2-3 l

2.1.9 Corrective Actions 2-4 2.2 PROCESSING OF DRY ACTIVE WASTE 2-5 2.3 MIXED WASTE 2-6

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3.0 WASTE CLASSIFICATION AND Cl. "4 'r.RIZATION 3-1 3.1 WASTE CLASSIFICATION 3-1 4

5 3.2 WASTE CHARACTERISTICS 3-1 l

4.0 SPECIFIC WASTE STREAM PROCESSING DESCRIPTIONS 4-1 1

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4.1 WET RADI0 ACTIVE WASTE STREAMS 4-1 4.1.1 Resins 4-1 j

4.1.2 Cartridge Filters 4-2 4.1.3 Evaporator Concentrates 4-3

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4.1.4 Sludge 4-3 4.1.5 Miscellaneous Liquids 4-3 1

4.2 DRY ACTIVE WASTE 4-4

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TABLE OF CO iTENTS (cont)

?*LL 5.0 ADMINISTRATIVE CONTROLS 5-1 5.1 PROCEDURES 5-1 5.2 QUALITY ASSURANCE 5-1 5.3 CHANGES TO Tile PCP 5-1 5.4 DOCUMENTATION 5-2 5.5 TRAINING 5-2

6.0 REFERENCES

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LIST OF FIGURES Figure No.

Title Page

.i l-1 CPSES Radioactive Waste Management 1-4 Organizational Responsibilities 4-1 Dewatering Process Flow Chart 4-5 4~2 Solidification Process Flow Chart 4-6 4-3 DAW Process Flow Chart 4-7 i

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SECTION 1.0 INTRODUCTION I

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1.1 PURPOSE i

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The purpose of the CPSES Process Control Program (PCP) is to establish l

a program which will provide reasonable assurance that all radioactive 3

wastes generated at CPSES that are to be disposed of at a land disposal i

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facility are processed and packaged such that applicable Pederal regulations. State rules and regulations, and disposal site criteria are satisfied. The PCP contains a general description of the methods for controlling the processing and packaging af radioactive wastes, specific parameters for each method, and the administrative controls and quality assurance required to ensure compliance with applicable 4

regulations and requirements.

j' 1.2 SCOPE This program defines criteria for the processing of the following waste j

streams for disposal at a land disposal facility:

I (1) Wet Wastes l

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(a) Resins (bead cud powdered) l (b) Cartridge Pilters (c) Evaporator Concentrates i

I (d) Sludge l

(e) Miscellaneous liquids (O Dry Active Wastes (DAW) l (a) Compactible l

(b) Noncompactible J

i 1.3 PRECAUTIONS / LIMITATIONS

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Except as specifically described herc.in, the following general precautions and limitations apply to the processing and packaging of l

1 all radioactive vastes generated at CPSES for disposal at a land t

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disposal facility. These precautions and limitations shall be included I

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(1) No liquid materials within the scope of this program shall be f

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(2) No package shall be loaded for shipment if it has any indication of

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a hole or failure. These packages shall either be repacked, or l

placed in an overpack.

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i (3) Radioactive vaste shall not be packaged for disposal in cardboard l

or fiberboard boxes.

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(4) Only High Integrity Containers (HIC) approved for burial at a land disposal facility shall be utilized for packaging devatered wastes requiring waste form stability.

(5) No objects or materials shall be placed into HICs that may cause chemical or physical damage to the container.

(6) As much as practical, polyethylene HICs shall be kept out of direct sunlight to prevent ultraviolet light degradation.

Protection from direct sunlight shall be provided when HICs are stored for extended periods.

(7) Radioactive vaste shall not be packaged for disposal if it is pyrophoric. Pyrophoric materials contained in radioactive vaste shall be treated, prepared, and packaged to be nonflammable prior,

to disposal.

(8) Radioactive waste in gaseous form shall not be packaged for disposal.

(9) Radioactive vaste containing hazardous material shall be treated to reduce to the maximum extent practicable the potential hazard from the nonradiological materials.

Biological, pathogenic or infectious material is not expected to be produced and will be handled on a case by case basis.

(10) Radioactive wastes shall not be packaged for disposal if it is readily capable of detonation or of explosive decomposition or reaction at normal pressures and temperatures, or of explosive reaction with water.

(11) Radioactive vaste shall not be packaged for disposal if it contains, or is capable of generating quantities of toxic gases, vapors, or fumes harmful to persons transporting, handling or disposing of the vaste.

(12) Samples shall be handled and collected in accordance with applicable CPSES procedures and in keeping with ALARA principles.

(13) Devatering and solidification processes should be periodically monitored for adverse chemical reactions and temperature changes.

1.4 RESPONSIBILITIES 1.4.1 Vice President. Nuclear Operations It is the responsibility of the Vice President, Nuclear Operations, to ensure that the requirements contained in this manual are achieved during the processing of radioactive vaste by developing appropriate administrative and implementing procedures.

An organizational chart showing specific station responsibilities for radioactive vaste processing assigned by the Vice President, Nuclear Operations, is shown on Figure 1-1.

Administrative control of this ennual is the responsibility of the V.ce President. Nuclear Operations.

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1.4.2 Station Operations Review Committee The Station Operations Review Committee (SORC) shall review the Topical Reports and Process Control Programs of vendors selected for contracted solidification or dewatering servcies prior to their initial use at the station. Any subsequent revision to these documents shall also be reviewed by SORC prior to the initial use of the revision. These reviews shall ensure compatibility with Station equipment and operation.

Additionally, SORC is responsible for reviewing changes to this PCP prior to implementation.

SORC also reviews station administrative and implementing procedures for radioactive waste processing activities.

1.4.3 Radiation Protection Manager The Radiation Protection Manager (RPM) is responsible for coordinating the review of, and for approving, vendor procedures for dewatering, solidification, and/or DAW proceesing prior to the initial use of the documents at the station. He shall also approve any revisions to these documents prior to initial use of the revision. Review of vendor procedures for Bewatering and/or solidification shall include technical review by the Operations, Chemistry, and Results Engineering departments.

1.4.4 Other Responsibilities The Manager, Plant Operations, and the Chemistry and Er.vironmental and Results Engineering Managers shall support the RPM in reviewing vendor procedures for solidification and dewatering.

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a FIGURE 1-1 CPSES RADIOACTIVE WASTE MANAGEMENT ORGANIZATIONAL RESPONSIBILITIES i

VICE PRESIDENT, v

NUCLEAR OPERATIONS i

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MANAGER, MANAGER, l

TECIINICAL PLANT SUPPORT OPERATIONS Responsible for:

• FILTER /DEMINERALIZER I RADIATION CllEMISTRY &

OPERATION PROTECTION ENVIRONMENTAL

• EVAPORATOR OPERATION MANAGER MANAGER

• RESIN TRANSFERS I

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Responsible for:

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• WET WASTE PROCESSING

• SAMPLING (i.e., solidification /

• FADIOLOGICAL/NONRADIOLOGICAL dewatering ANALYSES

• DAW COLLECTION / PROCESSING I

• 10 CFR 61 CIASSIFICATION

• STORAGE

• TRANSPORTATION j

• DISPOSAL

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• llEALTil PHYSICS SUPPORT i

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J SECTION 2.0 PROGRAM DESCRIPTION 1

2.1 PROCESSING OF WET RADIOACTIVE WASTE 2.1.1 Processing Methods P

Wet radioactive waste generated at CPSES shall be processed into a form acceptable for disposal at a licensed facility by i

solidification, encapsulation, or dewatering. All processing t

shall be performed utilizing vendor supplied services and i

i equipment operating in accordance with the vendor's Process Control Program (PCP) and procedures. Any vendor selected to provide such services shall have a topical report under review I

or approved by the NRC. When a vendor is initially selected, this document shall be revised to incorporate by reference the vendor's Topical Report and PCP.

The Topical Reports and PCPs

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of multiple vendors may be referenced in this PCP even if all vendors are not actively providing services at CPSES. However, if any vendor is selected whose documents are not referenced, this document shall be revised to reference them.

2.1.2 Processing System Description Detailed descriptions of the vendor's processing system shall be facluded in the vendor's Topical Report.

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2.1.3 Prequalification Testing l

J Prequalification tests shall be performed on each type of wet

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radioactive waste strean to demonstrate the ability of the l

process to produce an acceptable waste form per the requirements of 10 CFR 61.

This prequalification testing is performed by the vendor and documented in the vendor's Topical Report.

i 2.1.4 System Oualification Tests I

Prior to the initial processing of a given waste stream type I

using a specified process, a test shall be conducted to f

demonstrate the ability of the process system to produce an acceptable vaste form over the range of critical parameters identified during the prequalification testing.

Bounds for i

critical parameters and specific operating limits shall be specified in the vendor's PCP.

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These tests shall be perforned on laboratory scale or full scale I

specimens and shall ensure that the acceptance criteria l

I specified in Section 2.1.8 are achieved.

These tests apply to

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solidification and dewatering processes, j

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i 2.1.5 Equipment / System Operability Requirements Prior'to each processing evolution, the vendor shall demonstrate operability of the processing equipment which shall include but not be limited to the following:

I (1) Control Panel (2) Instrumentation and Controls (3) Mechanical Equipment (4) Electrical Equipment The operability test shall be performed in accordance with station procedures and the vendor's PCP and procedures.

2.1.6 Batch Preprocessing Sampling Each batch of waste offered for processing shall be sampled and analyzed, as appropriate, in accordance with station procedures and the vendor's PCP.

3 (1) For batches offered for solidification or dewatering, this sampling shall provide necessary data to estimate curie evntent and perform the vaste classification analysis.

j (2) In addition to (1) for batches offered for solidification, j

this sampling shall provide data necessary to:

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(a) Ensure that vaste stream parameters are within the i

j bounds for critical parameters established in the

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vendor's PCP.

NOTE:

Results of waste stream chemical analyses shall be reviewed by the solidification vendor to ensure chemical constituents do not exist which could react adversely with solidification agents (see Reference 6.5.7),

j (b) Verify the applicability of pre-established mix ratios.

l 2.1.7 Surveillance Testing 1

i To satisfy the requirements of the CPSES Radioactive Effluent f

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and Environmental Monitoring Manual (REEMM), solidification of j

at least one representative test specimen from at least every tenth batch of each type of wet radioactive waste offered for solidification shall be verified in accordance with the vendor's i

j PCP. The purpose of this testing is to provide assurance that

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an acceptable vaste form is produced using the pre-established 1

l formulations provided in the vendor's PCP.

j This test shall be performed on a laboratory scale or full scale j

test specimen which is similar both chemically and physically to

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the unadjusted waste stream to be processed. After the sample I

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is collected, it should be conditioned in accordance with the vendor's PCP. The sample should then be mixed with the binder and additives in ratfor determined using the vendor's pre-established formulations. The specimen should be observed to ensure the applicable acceptance criteria specified in Section 2.1.8.2(2) are achieved.

If the surveillance test results fail to meet the acceptance criteria, the following steps, as per the REEMM, shall be followedt (1) Solidification of the batch under test shall be suspended until such time as additional test specimens can be obtained, alternative solidification parameters can be determined, and subsequent testing verifies solidification.,

Solidification of the batch may then be resumed using the alternative solidification parameters.

The vendor's PCP shall provide the method for determining the alternative solidification parameters. Alternative solidification parameters shall be approved by the Radwaste Coordinator or his designee and shall be documented in accordance with the vendor's PCP.

(2) Testing shall be performed on representative test samples from each consecutive batch of the same waste type until three consecutive initial test specimens demonstrate solidification using the alternative parameters.

The vendor's PCP shall be modified as required to assure solidification of subsequer.t batches of waste.

(3) If the surveillance test results failure is due to malfunction of the processing equipment or the processing equipment ic inoperable, the equipment shall be returned to an operabis condition or an alternate vendor chall be obtained to process waste as necessary to satisfy applicable transportation and disposal requirements.

Similar surveillance testing of batches of wet wastes offered for dewatsring is not required since the applicable vaste form stability requirements are achieved by the container and since a specified end point for the dewatering process is verified for each dewatering evolution.

2.1.8 Acceptance Criteria 2.1.8.1 Dewatering Acceptance Criteria (1) Non-Stable Waste Form -

For wastes dewaterad in non-HICs, the acceptance criteria shall be less than or equal to one-half of one percent (0.5".) of the internal volume of the container for free standing water.

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i (2) Stable Waste Form -

For wastes dewatered in HICs, the acceptance criteria shall be less than or equal to one percent (1%) of the internal volume of the HIC for free standing water.

Vendor documents for the dewatering process si.all include a specified end-point for each dewatering i

evolution which ensures that these acceptance criteria l

are achieved.

l 2.1.8.2 Solidification Acceptance Criteria i

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(1) Solidification of each liner of solidified wastes i

shall be verified by visual observation that the I

waste slurry has hardened and tha t there is no l

apparent free standing water.

I (2) The following acceptance criteria apply to evaluation of tho test samples as specified in Section 2.1.4 and 2.1.7.

(a) Non-Stable Waste Form -

1 The acceptance criteria shall be a hard, free i

standing monolith that is resistant te l

i penetration and that contains no more than one-half of one percent (0.5%) free standing l

water by volume of the container. Criteria for s

l defining "resistant to penotration" shall be established in station and/or vendor I

procedures.

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(b) Stable Waste Form -

The acceptance criteria shall be a hard, free q

standing monolith that is resistant to j

penetration and that contains no more than j

one-half of one percent (0.5%) free standing j

water by volume of the container.

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Additionally, it shall be verified that the waste is processed by a method which produces a stable waste form as documented by a

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prequalification testing program as required per Section 2.1.3 of this manual.

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i 2.1.9 Corrective Actions

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With solidification or dewatering not meeting the above acceptance criteria or otherwise not meeting disposal site and q

shipping and transportation requirements, suspend shipment of i,

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i the inadequately processed waste and correct the Process Control Program, the procedures, and/or the waste processing equipment as necessary to prevent a recurrence. Additionally, an evaluation of similar wastes processed since the last successful surveillance test shall be conducted to determine the extent of the inadequately processed waste. If such wastes have been shipped for dicposal, the disposal site operator shall be contacted and the problem addressed.

l If solidification or dewatering is not performed in accordance with this PCP, the improperly processed waste shall be tested to ensure that it meets burial ground and shipping requirements.

Appropriate corrective actions shall be taken to prevent recurrence.

Disposition of inadequately processed wastes will be handlad on' a case-by-case basis.

2.2 PROCESSING OF DRY ACTIVE WASTE Dry Active Waste (DAW) generated at CPSES shall be processed by segregation, sorting, and/or compaction.

Processing of DAW is performed to accomplish the following functions:

(1) Package DAW in a fashion acceptable for disposal at a licensed disposal facility.

(2) Remove const.tuents not acceptable for disposal as DAW.

(3) Minimize vstumes of DAW shipped for disposal by:

(a) removing reuseable and uncontaminated items; and (b) reducing shipped vol.umes by compaction.

All processing of DAW at CPSES shall be performed in accordance with approved station procedures or vendor procedures that have been reviewed by the Radiation Protection Manager. Vendor equipment.

persor.nel and procedures may be used for DAW processing and packaging.

The segregation of uncontaminated ware from DAW is performed to minimit. volumes of DAW shipped for disposal.

In order to provide reasonable assurance that radioactive materials are not released as clean vaste, the following requirements shall be included in the segregation program, as discussed in Reference 6.5.3:

(1) Surveys, using equipment and techniques for detecting low levels of radioactivity, shall be made of materials that may be contaminated and that are to be disposed of as clean vastes.

(2) Surveys may be conducted on individual items using portable survey instruments, such as pancake GM probes. However, in all cases, final measurements of each package (e.g., bag or box) of aggregated 2-5

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waste to be released as clean waste shall be performed to ensure l

that there has not been an accumulation of radioactive material due l

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to the buildup of multiple quantities of contamination which were j

nondetectable with portable instrumentation.

Final measurements shall be' performed using set sitive detectors in a low background area, s6ch as scintillation detectors.

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2.3 MIXED WASTE l

9 Mixed Waste'is defined as waste that contains constituents that satisfy 2

2 the definition of radioactive waste, subject to the Atomic Energy Act, 1

and contains hazardous waste that either (1) is listed as hazardous l

vaste in 40CFR261 Subpart De or (2) causes the waste to exhibit any of the hazardous waste characteristics identified in 40CFR261 Subpart C.

1 Under current federal law, this vaste is subject to dual regulation by l

the NRC and EPA where both agencies have control over the same waste.

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Due to the complex regulatory issues that must be resolved pertaining l

co mixed waste, there are currently no authorized disposal sites in the United States which are licensed to receive and dispose of mixed j

hazardous and radioactive waste.

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Since there is currently no avenue for disposal of mixed waste, efforts j

shall be made to redu:e the generation of such waste at CPSES. To j

i accomplish this, station procedures for chemical control and

j radioactive vaste processing shall include the following requirements

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j (1) The Station chemical control program shall include a method to l

identify hazardous constituents of chemicals / chemical products and to evaluate and authorire any usage of these products in j

areas where mixed waste generation is likely to occur. This l

evaluation shall considet the substitution of piaducts which are j

evaluated as non-hazardous per 40CFR261.

(2) Radioactive waste processing procedures shall include provisions for segregation and removal of non-radioactive hazardous l

constituents. Upon removal, such constituents voi:1d be handled as hazardous waste as required by the EPA.

(3) Mixed low-IcVel radioactive waste generated at CpSES shall not be shipped for disposal to a low-level radioactive waste disposal facility unless specific approval for such disposal is granted by

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the appropriate regulatory agencies.

Such wastes shall be stored

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at CpSES until regulatory changes allow for disposal or they are otherwise approved for disposal by appropriate regulatory agencies, i

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SECTION 3.0 I

WASTE CLASSIFICATION AND CHARACTERIZATION i

3.1 VASTE CLASSIFICATION Radioactive waste generated at CPSES shall be classified as Class A B.

or C in accordance with the requirements of 10 CFR 61, Section 61.55, using one or more of the classification methods given in the USNRC's t

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-l "Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification (May 1983)". Waste classification shall be performed in accordance with approved station procedures.

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The following specific requirements shall be incorporated in the program for sampling and analysis for waste classification:

(1) Annual analyses shall be performed on representative samples of 1

each waste stream or, alternatively, a process stream associated with the generation of the waste, for the nuclides listed in Table 1 and Table 2 of 10 CFR 61 Section 61.55.

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(2) The results of these annual analyses shall be used to develop isotopic abundances and scaling factors for difficult to measure nuclides (i.e., beta emitters and transuranics) based on correlations between those nuclides and more easily measured gamma

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(3) Gansna spectroscopy or gross radioactivity measurements shall made for each cor.tainer of waste processed for disposal.

Calculational methods for determining the total activity in each l

container shall be developed which use the results of the gamma spectroscopy or gross activity measurements, and the percent isotopic abundances and scaling factors from the annual analyses.

(4) The classification program shall establish criteria and include f

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provisions for increased frequency for the sampling and analysis l

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required by paragraph (1), above, if'the failed fuel fraction l

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(5) Each package of waste shall be clearly labeled as class A. Class B, l

or Class C.

3.2 WASTE CHARACTERISTICS Waste processed for disposal at CPSES shall meet the applicable characteristics specified in 10 CFR 61 Section 61.56. Waste classified as

'** B or Class C shall be processed into a stable waste

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form. This ma, seceeplished by placement into a HIC (waste f

container meets ti.. stability requirements) or by solidification using i

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a process which produces a product that meets the stability requirements of 10 CFR 61.56, per Section 2.1 of this manual. The vendor's topical report shall include documentation of testing which verifies that the solidified product meetc these stability requirements.

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m SECTION 4.0 1

SPECIFIC WASTE STREAM PROCESSING DESCRIPTIONS

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4.1 WET RADIOACTIVE WASTE STREAMS i

4.1.1 Resins Resins will be accumulated from one or more of the following i

systems:

l (1) Chemical and Volume Control System (CVCS)

(2) Spent Fuc1 Pool Cooling and Purification System l

(3) 1.iquid Waste Processing System (including the

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filter / demineralization syces)

(4) Boron Recycle System (5) Boron Thermal Regeneration System

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(6) Steam Generator Blowdow System (SGBS)

(7) Condensate Polishing Dericeralizer System i

I (8) Other miscellaneous ion exchange medium as generated 1

I Sper' NSSS and SGBS system resino are collected in their respective Spent Resin Storage Tanks (SRSTs). These resins may be transferred directly to the vendors processing skid from the i

i SkSTs or, if desired, routed through the Waste Conditioning Tank.

If it is necessary to process secondary condensate j

polishing powdex resins, they are transferred from the Hot Phase Separator Tank, through the Waste Conditioning Tank, to the l

5 vendor's processing skid.

j Normally, spent resins will be processed for disposal by dcwatering. The curie content and waste classification of each l

1 resin batch shall be estimated prior to sluicing of the spent l

resin to the vendor dewatering skid.

Based on these estimates, i

the proper liner or HIC and cask for transport.4 tion and disposal l

j are selected. The resin is transferred to the liner or HIC where it is dewatered utilizing vendor supplied dewatering services per Section 2.1 of this manual. A representative l

sample of the resin is collected fer final calculations of curie content and waste classification. Containers are sealed.

surveyed, and labeled, as appropriate, and stored in a j

designated storage area until they are shipped for disposal.

l Alternatively, resins may be processed for disposal by i

solidification. Resins are transferred from the SRSTs or Hot j

Phase Separator Tank to the Waste Conditioning Tank where they

'l are isolated and sampled for PCP parameters and isotopic content.

If necessary, the resins are chemically conditioned.

The isotopic analysis results are used to estimate the waste classification, determine the proper waste from stability j

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requirements, and select the proper container for transportation i

and disposal. Then the resins are transferred to the vendor's processing skid where they are solidified per Section 2.1 of l

this manual. Containers are sealed, surveyed, and labeled, as l

j appropriate, and stored in a designated storage area until they i

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are shipped for disposal.

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Flow charts of typical dewatering and solidification processing

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paths are shown on Figures 4-1 and 4-2, respectively, j

4.1.2 Cartridge Filters

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Cartridge filters will be accumulated from one or more of the following systems:

i (1) Chemical and Volume System j

(2) Spent Fuel Fool Cooling and Purification System i

(3) 1.iquid k'aste Processing System (including l

1 filter / demineralization system)

(4) Boron Recycle System f

f (5) Boron Recovery System l

(6) Steam Generator Blowdown System (7) Miscellanecus l

Spent filter cartridges are surveyed for dose rate upon removal from the system. The measured dose rate is used to calculate l

1setopic content using a dose-to-curie conversion factor and i

scaling factors per section 3.1 of this manual.

Based on the l

I calculated isotopic content, the waste classification and the

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appropriate process and container for disposal are determined.

4 Normally f11ters are placed in a liner or HIC and dewatered.

i However, filters may be dried and handled as DAk', if conditions

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allow, or encapsulated in an appropriate solidification agent.

7 Upon completion of the processing, containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal, j

For purposes of waste classification, isotopic concentrations of i

filters devatered in a liner er HIC should be determined ao i

l calculated over the volume of the cartridge filter itself, i

rather than averaged over the gross volume of the container, j

j k' hen filters are encapsulated by solidification in a container, isotopic concentrations may be determined by averaging over the j

volume of the solidified mass.

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Flow charts of typical dewatering and solidification processing 1

paths are shown on Figures 4-1 and 4-2, respectively.

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i 4.1.3 Evaporator Concentrates l

Evaporator concentrates resul't from operation of evaporators for processing of liquid wastes (e.g., floor drains) and boron recovery. Normally, liquid waste streams are processed through 4

I the filter /demineralizer system for release to the environment.

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The liquid waste evaporator is available as an alternate

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processing method. The boron recovery evaporator is used to j

j remove boron from reactor grade water and the boric acid 1

concentrates are normally recycled. Therefore, volumes of l

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evaporator concentrates from liquid waste processing sod boron recovery, that must be solidified, are expected to be toistively i

small.

i Concentrates are transferred from the evaporators to the Waste Conditionicg tank where batches are isolated and sampled for PCP

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I parameters and isotopic content.

If necessary, the concentratee I

are chemically conditioned. The isotopic analysis results are 1

used to estimate the wasto classification, determine the proper i

vaste form stability requirements and select the proper container for transportation and disposal. Then the 1

concentrates are transferred to the vendor's processing skid where they are solidified per section 2.1 of this manual.

j Containers are sealed, surveyed, and labeled, as appropriate, f

i and stored in a designated storage area until they are shipped l

I for disposal.

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j A flow chart of a typical solidification processing path is

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shown on Figure 4-2.

l 4.1.4 Sludge Radioactive sludge is accumulated and handled on a case-by-case i

i basis by periodically removing the sludge from various tanks and l

sumps throughout the plant.

Each batch of sludge is sampled for PCP parameters and isotopic content, chemically conditioned, if l

necessary, and solidified per section 2.1 of this manual.

Containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal.

A flow chart of a typical solidification processing flow path is i

shown on Figure 4-2.

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4.1.5 Miscellaneous 1.iquids 1

Miscellaneous liquids generated in the station will be collected and processed on a case-by-case basis.

Such vastes may include j

decontamination vastes and chemical wastes collected from the i

Chemistry 1. abs. Batches of such vaste are isolated, saepled for j

PCP parameters and isotopic content. chemically conditioned. if

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necessary, and transferred to the vendor's processing skid where i

it is solidified per section 2.1 of this manual.

Containers are sealed surveyed, and labeled, as appropriate, and stored in a l

designated storage area until they are shipped for disposal.

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4.2 DRY ACTIVE WASTE Dry Active Waste (DAW) consists of radioactively contaminated or activated waste which contains no liquids. DAW may be compactible, such as paper, plastic and protective clothing, or non-compactible, such as tools or plant equipment. This waste is segregated by station workers at the point of generation into Deceptacles designated for "clean" or "contaminated" trash.

"Clean" receptacles are used to collect trash that is potentially not con:aminated.

"Contaminated" containers are used to collect waste that is known or suspected to be contaminated. However, for purposes of DAW processing, all waste collected in Radiation Controlled Areas (t.e., that collected in both the "clean" and "contaminated" receptacles) is assumed to be contaminated until it is surveyed and proven clean. Bass are collected from the receptacles, surveyed for external dose rate, and taken to a,

designated sorting area for processing.

Bass below a specified dose rate level, per station procedures, may be opened and the contents surveyed individually for radioactivity.

Items found to be not contaminated per station procedures, reusable items, and items not acceptable for disposal as DAW are removed.

In general, the contents of bags above the specified dose rate level are not surveyed for contamination, but are examined for reusable items and items not acceptable for disposal as DAW. Contaminated items are then disposed of as DAW. Compactible items are collected and compressed into approved strong, tight containers.

Noncompactible items are placed directly into approved strong, tight containers. Containers are sealed, surveyed, and labeled, as appropriate and stored in a designated storage area until they are shipped for disposal.

A flow chart of the DAW processing path is shown on Figure 4-1.

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1 4-7

SECTION 5.0 ADMINISTRATIVE CONTROLS 5.1 PROCEDURES Activities associated with the implementation of the requirements of j

this program shall be conducted in accordance with approved station procedures or vendor documents and procedures that have been reviewed and approved per secti<.';s 1.4 and 2.2.

5.2 QUALITY ASSURANCE i

Quality Assurance related activities for radioactive waste processing '

t are implemented as described in the TU Electric CPSES Qus11ty Assurance l

Manual.

Such activities includes (1) Review of documents and procedures affecting the processing.

packaging, handling, and transportation of radioactive vaste.

[

-(2) Review of procurement documents or services.

t (3) Perform inspections as designated in applicable processing, i

packaging, and shipping procedures.

(4) Review applicable vendor QA programs for compliance with Regulatory and TU Electric requirements.

(5) Perform audits of the radioactive vaste management program at least i

once per 24 months.

]

(Note: Technical Specification Administrative Control 6.5.2.8.1 requires that audits of the Process Control Program and implementing procedures be performed under the cognizance of the j

Operations Review Co=mittee at least once per 24 months.)

a (6) Documentation and retention of documentation of waste processing, j

packaging and shipping activities.

1 These activities provide assurance that the final waste form,

)

packaging, labeling, and transportation are in accordance with applicable regulations and requirements.

5.3 CHANGES TO THE PCP Changes to this PCP shall be reviewed and found acceptable by SORC i

prior to ieplementation. Changes shall be submitted to the NRC in the Semiannual Radioactive Effluent Release Report for the period in which the changes were made. This submittal shall contain the information I

specified in Technical Specification Administrative Control 6.13.2.

I 5-1 l

e t

5.4 DoctHENTATION Procedures for radioactive vaste processing, packaging, and transportation shall include requirements for maintaining and retaining LLW processing, packaging, and transportation records. Detailed records for each containst of vaste shall be maintained.

5.5 TRAINING TU Electric and vendor personnel responsible for vaste processing, packaging and transportation activities shall be trained and qualified to ensure that vaste processing is performed in accordance with applicable requirements.

Training programs shall establish a schedulc for periodic requalification of at least once every two years.

TU Electric shall verify the training of vendor personnel.

P P

l l

l 5-2

i SECTION 6.0 l

l REFERFNLES i

i 1

6.1 Code of Federal Regulations:

+

6.1.1 Title 10. Parte 20, 61, and 71 J

6.1.2 Title 49. Part 173 j

6.1.3 Title 40. Part 261 6.2 USNRC, Low-Level Waste Licensing Branch. Technical Position on Radioactive Waste Classification. May 1983

)

6.3 USNRC. Low-Level Waste Licensing Branch. Technical Position on Waste l

Torm. May 1983 i

6.4 USNRC Cuidelines for Preparation and Implementation of a Solid Waste f

}

Process Control Program (Proposed). Draft Revision 3. September 1986 4

1

]

6.5 USNRC. Office of Inspection and Enforcement. IE Information Notices:

6.5.1 IEN 79-09. "Spill of Radioactively Contaminated Resins" 3

6.5.2 IEN 83-14. "Devatered Spent Ion Exchange Resin Susceptibility to Exotherraic Chemical Reaction"

[

6.5.3 IEN 85-92. "Surveys of Wastes Before Disposal from Nuclear Reactor Tacilities" l

6.5.4 IEN 86-20. "Low-Level Radioactive Waste Scaling Factors. 10 CTR Part 61" 6.5.5 IEN 87-03. "Segregation of Hazardous and Low-Level Radioactive i

Wastes" 6.5.6 IEN 87-07. "Quality Control of Onsite Devatering/Solidificatien Operations By Outside Contractors" 6.5.7 IF.N ES-08. "Chemical Reactions With Radioactive Waste Solidification Agents" l

6.6 Shockley. Vernon E. and Veitenheir.er. Steven J.. "Actions Tovard l

Resolving the Mixed Waste Issue", a paper presentation at the INFO f

Radiation Protection Managers' Workshop, Atlanta. Georgia June 7-8 1968 l

I

{

f.7 CPSFS Technical Specifications. Sections 6.5.2.8.1 and 6.13 l

6.8 CPSES Radioactive Effluent and Environnental Mcnitoring Farual. Section l

}

4.0 j

i b

6.9 CPSES Sta ica Administrative Procedure STA-614. "Radioactive Waste Control" l

l 4

i i

l 6-1 i

1

..___--.___..._-J

F O.

ok 6.10 CPSES Radiation Protection Instructions:

6.10.1 RPI-203, "Shipment of Radioactive Materials" 6.10.2 RPI-204 "Liquid Waste Processing" 6.10.3 RPI-205, "DAW Processing" 6.10.4 RPI-209, "Radioactive Waste Classification" 6.11 CPSES Chemistry Procedurest 6.11.1 CKM-517 "Chemistry Control of Liquid Waste Systees" 6.11.2 CRM-518 "Radionuclide Verification and Correlation Program" 6.12 CPSES Radioactive Waste Systems Procedure RWS-301, "Radwaste Solidification Systems" 6.13 Vendor Documents No vender documents have currently been reviewed and approved by the CPSES SORC. This section shall be revised to reference specific vendor documents approved for use at CPSES upon review and approval by the 50KC.

6.14 TU Electric CPSES Quality Assurance Manual i

1 9

6-2

.