ML20205A948

Administrative Procedure AP 1.10, Process Control Program

ML20205A948
Person / Time
Site:	FitzPatrick
Issue date:	04/17/1985
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Vassallo D Office of Nuclear Reactor Regulation
References
AP-1.10, JPN-85-32, NUDOCS 8504260199
Download: ML20205A948 (11)

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NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES -

TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10 REVIEWED BY: PLANT OPERATIONS REVIEW COMMITTEE Mceting No. $&G3 / Date f // 7 / W APPROVED BY:

[ 4 Date 7 Resident Manager CONCURRED BY: hbt/fYk  : Date Yf/7fff Quality Assurance Superintendent 9

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' NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10 1.0 PURPOSE The purpose of the Administrative Procedure is to implement a Process Control Program (PCP) for the stabilization and solidification of radwaste at the James A. FitzPatrick (JAF)

Plant. The objective of the PCP is to provide basis crite-ria to assure that liquid wastes, evaporator concentrates, resins and filter sludges generated at JAF and destined for offsite burial in a licensed facility are properly sta-bilized and packaged to meet current Nuclear Regulatory Commission (NRC), Department of Transportation (DOT), state and burial site regulations and criteria.

1.1 Systems Overview 1.1.1 Spent filter /demineralizer sludges from the reactor cleanup system are backwashed into the cleanup system phase separatora for storage and are transferred to the Sludre Tank prior te processing. Spent powdered r~esin sludges fro:

the fuel pool and radwaste filters are dis-charged - to the Sludge Tank for storage. Resin sludges are either transferred from the Sludge Tank to High Integrity' Containers (HICs), dewa-tered by a contractor mobile dewatering skid and

,, shipped offsite for burial, or are transferred from the Sludge Tank to the Concentrated Waste Tank.

1.1.2 Spent bead resins from the c'ondensate polishers and waste demineralizer are stored in the Spent Resin Tank. Spent resins are subsequently transferred to HICs, dewatered and shipped offsite for burial.

1.1.3 Concentrates from the radwaste evaporator are stored in the Concentrated Waste Tank. Concen-trated wastes (plus any sludges from the Sludge Tank tank, as in 1.1.1 above) are recirculated in the transferred to a 200 cubic foot steel liner and solidified in the liner using a con-tractor mobile cement solidification system.

1.1.4 Contaminated oils and oily wastes are trans-ferred to containers and solidified using con-tractor mobile solidification equipment.

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NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10 2.0 APPLICABILITY The Administrative Procedure applies at all times whenever lic uid and/or wet-solid low-level radwastes are processed anc. packaged for shipment and disposal in a licensed burial facility.

3.0 REFERENCES

3.1 Title 10, Code of Federal Regulations, Part 20.

3.2 Title 10, Code of Federal Regulations, Part 50.

3.3. Title 10, Code of Federal Regulations, Part 61.

3.4 Title 10, Code of Federal Regulations, Part 71.

3.5 Title 49, Code of Federal Regulations, Parts 172 and 173.

3.6 USEcology - State of Washington Radioactive Materials License, WN-IO19-2.

3.7 CNSI -

Barnwell, Waste Management Facility Criteria, S20-AD-010.

1 3.8 South Carolina, Department of Health & Environmental Control, Radioactive Materials License No. 097.

3.9 Operating Guidelines for Use of Polyethylene High Integrity Containers (vendor document).

3.10 Powdered Resin Dewatering Procedure for Liners (vendor document).

3.11 Bead Resin Dewatering Procedure for Liners (vendor document).

3.12 Process Control Program for Cement Solidification Systems (vendor document).

3.13 Waste Management Group Inc. Topical Report on "RADPAN"

- A Computer Code to Classify and Document Packaged LLW in Accordance with 10 CFR Part 61 Regulations, WMG-102, May, 1983 (proprietary document).

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NEW YORK POWER AUTHORITY JAVES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10 3.14 RES Department Procedures and Programs, Radiation Pro-tection Procedures.

4.0 DEFINITIONS None 5.0 RESPONSIBILITIES AND COMMITMENTS 5.1 Respcnsibilitieu The Superintendent of Power is responsible for ensuring that radioactive wastes destined for burial in a li-censed disposal facility are packaged, classified and shipped in accordance with NRC, DOT and burial site regulations and criteria.

The the following departments are designated to implement respective portions of the radioactive waste program:

5.1.1 Operations The Operations Department (through the Waste Management Genera: Supervisor, the Radwaste 9 Supervisor, the Decon and Shipping Supervisor or their designated alternates) is responsibic for processing, loading and packaging wastes in compliance with applicabic burial facility regulations and criteria, for direct vendor contact to accomplish the same, and for final inspection of waste shipments. l 5.1.2 Radiological and Environmental Services (RES)

The RES Department (through the Health Physics d General Supervisor, the Radiation Protection Supervisors or their designated alternates) is responsible for ensuring that waste shipments are properly classified, packaged, described, marked and labeled and are in proper condition for transport in accordance with applicable DOT regulations.

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NEU YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES 4

TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10 5.1.3 Quality Assurance The Quality Assurance Superintendent is respon-sible for ensuring that routine audits are .

performed of selected activities in the plant's radwaste shipping and handling program.

5.2 Commitments 5.2.1 All liquid and wet solid wastes destined for burial in a licensed facility are stabilized in accordance with burial facility criteria prior to shipment.

5.2.2 All wastes destined for burial in a licensed tacility are classified in accordance with 10 CFR 20.311 according to the requirements of 10 CFR 61.55 and the burial facility criteria prior to shipment.

5.2.3 All wastes destined for burial in a licensed facility are certified to be properly packaged, marked, labeled and in proper condition for transportation in accordance with the applicable .

requirements of 49 CFR 172-173 and 10 CFR 71.

5.2.4 All container, shipping casks and methods of packaging used in the transportation of wastes to a licensed offsite burial facility will be in accordance with applicable NRC, DOT, state and burial facility criteria.

6.0 SPECIAL INSTRUCTIONS None 7.0 PROCEDURE - PROCESS CONTROL PROGRAM

7.1 Background

The JAF PCP provides the basis criteria that will be

. used to ensure that burial facility criteria for waste l content, class form and free-standing liquid are met.

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-NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT

-ADMINISTRATIVE PROCEDURES i  !

! TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10 The - JAF Plant currently does not have an installed waste solidification system. Solidification and/or dewatering are performed by a mobile cement unit owned and operated by an outside contractor whose equipment and services are provided at state-of-the-art levels in full conformance with the existing regulatory framework and in accordance with a Quality Assurance Program approved under 10 CFR 50 Appendix B and 10 CFR 71 Ap-pendix E.

This PCP is structured to provide management controls and assurances with regard to contracted services'and specialty containers that are used in lieu of an in-

stalled system.-

For the wastes and processing methods described in section 1.0 above, the process controls in this section apply.

7.2 Solidification of Liquid and Oilv Wastes 7.2.1 Power Authority - Contractor Interface  !

The JAF Plant will ensure that the solidifica- ,

tion contractor provides to the New York Power Authority ohe following documentation prior to the solidification of liquid wastes

a. A general description of the solidification process including type of solidification agent, process control parameter boundary conditions, proper waste form properties and ,

assurance the solidification system is .oper- 'l ated within the established parameters.

b. A general description of the laboratory '

mixing of a sample of the waste to establish process parameters prior to commencing the solidification process,

c. A general description of sampling of at least l one representative sample from every tenth l batch to ensure solidification and the l action (s) to be taken if the sample fails to verify solidification. ,

d The provisions to verify the absence of free liquid.

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NEW YORK POWER AUTHORITY '

JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10

e. The provisions to reprocess containers in which free liquids are detected.

f. For exothermic solidification processes, the process control parameters that must be met prior to capping the container.

7.2.2 JAF Implementation of Contractor Procedures With regard to the contractor documentation identified in step 7.2.1 above, the JAF Plant Operations Review Committee shall review and approve contractor's procedures and programs prior to performance of the process operations.

7.3 Dewatering of Soent Resins Spent filter /demineralizer sludges and spent bead resins are placed in containers and dewatered to ensure '

the stability of the packaged waste is in accordance with burial site criteria for waste form and minimum free standing liquid.

HICs are used as the method of packaging to ensure stability of wastes in which the specific activity of isotopes of greater than five year half-life exceeds one microcuric/ milliliter.

7.3.1 Power Authority - Contractor Interface HICs are provided by the same contractor that provides the mobile waste processing and de-watering service. The contractor provides the Authority with process control parameters and boundary conditions as well as operating guid-ance for each HIC type.

The wastes packaged in HICs are dewatered to below the burial site criteria for free-standing liquid using dewatering internals integral to the HIC and a contractor-supplied dowatering skid, accompanied by contractor procedures for dewatering.

The JAF Plant will ensure that the contractor providing HICs and the associated dewatering service provides the following documentation prior to dewatering:

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NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10

a. A general discussion of the use of HICs for the stabilization of wastes, including process parameters, parameter boundary con-ditions, proper waste form properties and limitations, and storage and handling re-quirements,

b. A general description of the dewatering process, including process parameters, bound-ary conditions, appropriate waste form prop-erties and limitations and assurance that the dewatering process is performed within estab-lished boundaries.

c. The provisions to verify the absence of free liquid.

d. The provisions to reprocess containers in which free liquids are detected.

e. The process parameters that must be met prior to capping the container. '

7.3.2 Implementation of Contractor Procedurea With regard to the contfactor docueentation identified in step 7.3.1 above, the JAF Plant f Operations Review Committee shall review and approve contractor procedures and programs prior to performance of the process operations. This will ensure that the HIC and the dewatering process are used and operated within established limits.  !

7.4 Waste Classification {

In accordance with the provisions of 10 CFR 20.311, wastes destined for disposal in a licensed facility must be classified as Class A, B or C according to the requirements of 10 CFR 61.55.

To ensure that packaged wastes are properly classified tor burial, the JAF Plant utilices the methods of waste classification centained in the "RADMAN" computer code.

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NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTRATIVE PROCEDURES TITLE: PROCESS CONTROL PROGRAM * . PROCEDURE NO.: AP 1.10 ,

The "RADMAN" code is a series of routines which charac- '

terize packaged waster classify waste packages in accordance with Part 61 waste classification require-ments; conduct a quality control program as specified ,;

in 10 CFR 20.311: and prepare documentation required by i 10 CFR 61, DOT regulations, and license -conditions at l

the burial facilities. The "RADMAN" code operates on a .

waste stream characteristics data base which is specif-ic to the wastes shipped by the JAF Plant. The data base includes types and forms of waste as well as waste-stream-specific radionuclide distributions.

The vendor who developed the "RADMAN" code documented c the "RADMAN" methodology in a Topical Report (Reference I 3.13) and submitted it to the NRC (Low Level Waste Licensing Branch - Division of Waste Management) . The NRC has approved the "RADMAN" code as an acceptable vehicle which can be used as part of compliance to 10  :

CFR 20.311 and 61.55. The JAF Plant maintains a copy of the Topical Report as well as the NRC approval j document. 1 RES department procedures contain instructions re- ,

garding use of the "RADMAN" code, which the NRC has . i reviewed and concluded provides an acceptable vehicle i to implement waste classification requirements. The procedures also contain instructions for determining 10 CFR 61 waste classifications using methodologies i similar to "RADMAN" through manual (non-automated) means. l I

7.5 ALARA ALARA considerations are addressed in all phases of the

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solidification and stabilization process and all other processes involving handling, packaging and transfer of a all types and forms of radioactive waste. ALARA con-siderations are addressed in the plant's Radiation Protection Procedures, and where explicit conditions

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warrant, through a procedural detailed ALARA review. ,

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NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT ADMINISTPATIVE PROCEDURES TITLE: PROCESS CONTROL PROGRAM

• PROCEDURE NO.: AP 1.10 7.6 Ouality Assurance ki

• Contractor servic s related to processing, packaging and shipping of radwastes are performed under a 10 CFR 50 Appendix B quality Assurance Plan, which is reviewed and approved by the UAF Plant Operations Review Commit-tee. In additione selected activities in . the. plant 's radwaste shipping and handling program ar.e ; routinely audited under the existing JAF Quality As~surance Pro-gram.

8.0 FIGURES None >

s 9.0 EXHIBITS ,

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I' 123 Main Street l

,,# White Plains, New Wrk 10601 914 681.6800

1. > NewYorkPbwer l0!"1"=ce e,esioeo,

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. April 23, 1985 JPN-85-32 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Process Control Program

Reference:

NYPA letter, C. A. McNeill, Jr. to D. B. Vassallo, 4

dated December 21, 1984 (JPN-84-86)

Dear Sir:

Enclosed are three (3) copies of the FitzPatrick Process Control Program (PCP). This program is designed to accompany the proposed Radiological Effluent Technical Specifications submitted in the referenced letter.

d The PCP has been reviewed and approved by the Plant Operating Review Committee.

If you have any questions, please contact Mr. J. A. Gray, Jr. of

my staff.

Very truly yours, J. P. ayn Eirst Executive Vice President Chief Operations Officer Enclosure I cc: Office of the Resident Inspector U.S. Nuclear Regulatory Commission-P.O. Box 136 l Lycoming, New York 13093

\

Mr. J. D. Dunkleberger Division of Policy Analysis and Planning f[$ I l New York State Energy Office i I Agency Building 2,-Empire State Plaza Albany, New York 12223

.