ML20207C280

Rev 7 to LACBWR Pcp

ML20207C280
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	11/11/1998
From:	Public Service Enterprise Group
To:
Shared Package
ML20207C270	List: ML20207C266 ML20207C273 ML20207C280 ML20207C287
References
PROC-981111, NUDOCS 9903080435
Download: ML20207C280 (9)

Text

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-e LA CROSSE BOILING WATER REACTOR PROCESS CONTROL. PROGRAM (PCP) l I

Prepared by: / ,

M 44 I U/(/ Date Health Physics Review- Mu /o-/V-98 i I Date OA Review: #Al . W /'O //C/98 \

' Dite l~ (l '

ORC Approved: '

1. 1. a s W6 # /!ff

/~ Date 4

)

October 1998 4

(Revision 7) i Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602 9903090435 990219 U PDR ADOCK 05000409 h gR . mvw PDR [

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' Safety Analysis in Accordance with Decommissionina Plan and Technical Specifications:

1. Will the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated either in the Decommissioning Plan or FSAR be increased? NO Justification ForAnswen ,

t The removal of a Tech. Spec. reference number and reorganizing of the PCP will not alter the PCP to increase the probability of an accident or malfunction important to safety previously evaluated.

2. Is there a possibility of an accident or malfunction of a different type than previously evaluated in the Decommissioning Plan or FSAR being created? NO Justification For Answec ,

l The handling of radioactive waste will not be changed in our Radiation Protection Program or PCP. Only the Tech. Spec. reference has been removed.

3. Is the margin of safety as defined in the bases for any Technical Specifications

~ reduced? NO Justification ForAnswen l

The Tech. Spec. criteria has not changed for the PCP. There is no program change from that specified in Technical Specifications.

1 ll 4., Will the proposed change result in a significant environmental impact not previously j evaluated in the Environmental Assessment in support of the August 7,1991,  ;

Decommissioning Order or the Final Environmental Statement (FES) related to operation of LACBWR, dated April 21,1980 (NUREG-0191)? NO

' Justification For Answen l

l The Tech. Spec. criteria is unchanged, so the PCP basis is unchanged. The PCP will continue to meet all criteria in order to ensure the safe handling storage and shipment of radioactive waste.

PCP Rev. 7

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t LACBWR PROCESS CONTROL PROGRAM (PCP) 1 I. INTRODUCTION i l

The purpose of the Process Control Program (PCP)is to describe the methodology and procedures used by the La Crosse Bolling Water Reactor (LACBWR) Facility during SAFSTOR, to ensure that radioactive waste material I processing, packaging, transportation and disposal will be accomplished in a i manner that is in compliance with all applicable federal, state, and burial site  !

regulations. The PCP will provide guidance for LACBWR's two basic waste streams: (1) dry active waste (DAW), or (2) wet radioactive waste (resin or filter media).

NOTE: If the methodology and/or procedures found in the PCP are being violated, all radioactive waste processing activities will be suspended until these violations can be investigated and corrected. j l

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II. SPECIFICATION Technical Specifications state:

a. "The PCP shall be maintained onsite and will be available for NRC review."

b. " Licensee-initiated changes to the PCP shall be submitted to the Commission in the annual Radioactive Effluent Release Report for the period in which the change (s) was made. This submittal shall contain:

= information to support the rationale for the change;

• A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria

• for solid wastes; and

- Documentation of the fact that the change has been reviewed and found acceptable by the ORC."

PCP 1 Rev.6

1 IIL WET RADIOACTIVE WASTE The PCP and Health and Safety Procedure (HSP) 4.1 establish the steps used to dewater and stabilize wet radioactive waste material from the process j water treatment systems and the liquid waste system. These wastes will be j transferred to the Waste Treatment Building (WTS) for storage and processing before its ultimate disposal.

The WTB is located to the northeast of the Containment Building. The WTB contains facilities and equipment for the collection, processing, storage and handling of low level solid radioactive waste materials.

The grade floor of the WTB contains a shielded compartment which encloses a permanent 320 ft3 stainless steel Spent Resin Receiving Tank (SRRT) with associated resin receiving and transfer piping, SRRT recirculation piping, SRRT demineralized water fluch piping, SRRT dewatering piping, SRRT air sparger piping, valves, and a SRRT ultrasonic level indication assembly. This cubicle is in the southeast corner of the building and has nominal 2'6" to 3' thick reinforced high density concrete shield walls on the outer sides.

Wet radioactive waste materials may typically be described as whole bead demineralizer resins, mechanical cartridge filters, waste sludge, and inorganic particulate residues. When expended, these wet wastes are transferred to the SRRT or, in some cases, directly into an High Integrity Container (HIC) for l processing. In the case of Class C wet radioactive waste, as an alternate method to transfer to the SRRT, they may be transferred to a HlC inside a transportation cask and dewatered from the cask to the plant process liquid waste system, thus reducing radiation exposure to personnelinvolved in performing the necessary package handling operations. Gamples of wet waste are analyzed for isotopic composition and for waste classification.

Expended demineralizer resins and waste sludge material from sumps and tanks are transferred to the SRRT as described in the Operation Manual Volume Vll.

From the SRRT, partially dewatered spent resins and/or sludge material, which have been sluiced from plant demineralizers and/or tanks, are pumped at a

+ low flow rate / pressure with a Roper-type screw pump to a HIC, located in the adjacent shielded cubicle as described in Operating Manual Volume Vll. The wall l between the SRRT and the disposal HIC and other walls surrounding the HIC are a nominal 2' thick high density concrete. Also located in this cubicle is an air-driven Sandpiper-type diaphragm HIC dewatering pump, the resin transfer and dewatering valves and hoses, and the disposal HIC levelindication connecting cable. Once in the HIC, spent resins and sludge material is dewatered to the SRRT which is PCP 2 Rev.6

subsequently dewatered through a dewatering ion exchanger. A final dewatering is performed as described in Operating Manual Volume Vil and Health and Safety Procedure (HSP) 4.1.

The final dewatering will ensure that the contents of the HIC meets the requirements of 10CFR6 4.56(a)(3) and 10CFR61.56(b)(2) and burial site criteria for free-standing liquids. Stabilization of the dewatered wet waste is provided by the HIC as authorized by 10CFR61.56(b)(1). The contractor which supplies the HIC will provide DPC with a copy of the Certificate of Compliance for the HIC which details specific limitations on the use of the HIC.

Once final dewatering is completed, the HIC is inspected, sampled, and the HIC lid is sealed and closed. The blC is surveyed, decontaminated, and loaded into an appropriate shipping cask. Dewatered spent mechanical cartridge filters may be added directly to a HIC containing spent resins, if necessary.

The shipping cask is prepared for shipment in accordance to contractor's procedures. The vehicle is inspected both upon arrival onsite and after it is loaded prior to departure in accordance with procedure.

Once properly prepared for shipment, the wet waste will be either sent ,

directly to an approved disposal site for burial, or it will be sent to a licensed waste processor for volume reduction. Any material remaining after reprocessing will be sent to burial by the processor for DPC.

l IV. DRY ACTIVE WASTES The PCP and Health and Safety Procedure 4.2 establish the steps used to '

process, package and ship the Dry Active Wastes (DAW) from the plant, in accordance with 10CFR20,2006. The Dry Active Waste materials may typically be described as paper, cloth, metal, wood, plastic, concrete and other items or components which have become contaminated with radioactive materials. The DAW is normally characterized and labeled as Class A Unstable in accordance l with 10CFR61.55 and .56. l DAW will either be processed at LACBWR for burial at an approved burial site, or it will be processed for shipment to a licensed reprocessing contractor.  !

a. DAW for direct burial i l

These wastes processed for burial from LACBWR are normally compacted using a DAW compactor unit located in the WTB. They are packaged in DOT Spec 7A containers or SM 17H drums. Sufficient PCP 3 Rev.6

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absorbent materialis added to each waste container to limit free i standing and non-corrosive liquid to less than 1% of the volume. Some I dry waste' material may be plant components which had become ,

activated by neutron irradiation. Representative samples of DAW are )

analyzed for isotopic composition and for waste classification. l l

After packaging, these DAW wastes are transferred to the DAW storage l building which it located southwest of the Turbine Building. It is used l to store processed, packaged and sealed low level dry active waste j materials, and sealed low level activity components until they are sent to .

burial. The building has the capacity for 500 DOT 17H-55 gallon drums of waste.

b. DAW for Reprocessina Containers supplied by the contractor will be strategically placed within the controlled area to allow for the most efficient loading of these containers. The container size will vary due to the application required.

Once filled, the reprocessing contractor will be notified and shipping arrangements will be made. The containers will be sealed and surveyed before leaving LACBWR. Any waste volume remaining after reprocessing will be sent to burial by the contractor for LACBWR.

V. WASTE Cl.ASSIFICATION LACBWR wastes will be classified as Class A Stable or Unstable, Class B Stable, or Class C Stable to determine the acceptability for near-surface disposal and for the purpose of segregation at the disposal site. The waste class will be based on the concentration of certain radionuclides in the wcste as outlined in 10CFR61.55.

Radionuclide concentrations will be determined based on the volume or weight of the final waste form as discussed in Section C.2 of the Branch Technical j Position Paper on Waste Classification.

Of the four suggested methods for determining radionuclide concentration,

the one most commonly used is the direct measurement of individual radionuclides I

l (gamma emitters) and the use of scaling factors to determine the radionuclide l.

concentration of difficult to measure radionuclides (normally non-gamma emitters). I The'use of the other suggested methods; material accountability, classification by l

[

i source or gross radioactivity measurements may occur if the situation best fits the use of that methodology.

l PCP 4 Rev.5 i l

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Plant procedures are used in the determination of radionuclide concentra-tion for difficult to measbre nuclides (normally non-gamma emitters) and for the classification of radioactive waste for near-surface burialin accordance to  :

10CFR61.56(a)(3) and Table 1 and Table 2.

VI. SIIIPMENT MANIFEST  ;

Each shipment of solid radioactive waste to a licensed land disposal facility l will be accompanied by a shipment manifest as required by 10CFR20.2006. The ,

manifest will contain the name, address, and telephone number of the waste generator. The manifest will also include the name, address, and telephone number or the name and EPA hazardous waste identification number of the person ,

transporting the waste to the land disposal facility. f The manifest will also indicate to the extent practicable: a physical j description of the waste; the volume; radionuclide identity and quantity; the total i I

radioactivity; and the principal chemical form. The solidification agent, if applicable, will be identified.

l Waste containing more than 0.1% chelating agents by weight will be identified and the weight percentage of the chelating agent estimated. Waste classification, Class A, B, or C, will be clearly indicated on the manifest. The total quantity of the radionuclides H-3, C-14, Tc-99, and 1-129 will be shown on the manifest. Source material mass, and the masses of U-233, U 235, Pu isotopes and total Special Nuclear Material will be calculated and shown on the manifest.

Each manifest willinclude a certification by DPC that the transported materials are properly classified, described, packaged, marked, and labeled, and are in y roper condition for transportation according to the applicable regulations of the Department of Transportation and the NRC. A qualified individual will sign and date the manifest. LACBWR procedures are used for the preparation of burial site radioactive shipping manifests.

LACBWR will maintain a manifest record-keeping and tracking system that meets the requirements of 10CFR20.2006.

Each shipment of radioactive waste to a licensed reprocessing contractor will be acenmpanied by a shipment manifest that meets the requirements of that contractor's license.

PCP 5 Rev.5

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' VIIL ADMINISTRATIVE CONTROLS A. Trainina A training program will be conducted to ensure that waste processing will be performed according to plant procedures and the PCP. An individual's training l record will be maintained for audit and inspection. The processing and shipment of  !

radioactive material will be performed by qualified and trained personnel.

All plant personnel who handle, package, and prepare for shipment radioactive material will receive appropriate DOT Hazardous Material Training, in accordance l with their duties, once every three (3) years.

- B. Record Retention Records of processing data, test and analysis results, results of training, inspections and audits wiil be retained in accordance with LACBWR Quality Assurance requirements for record retention, j C. Documentation Control i

DPC-initiated changes may be made to the PCP and procedures in accordance with j Technical Specifications and shall become effective upon review and acceptance by the Operations Review Committee (ORC).

Radioactive waste that does not fall within previous waste processing experience -

will be evaluated and, if necessary, included in the PCP prior to final processing and disposal. Approved changes in the PCP will be reported to the NRC in the subsequent annual Radioactive Effluent Release Report.

D. Quality Assurance The provisions of the NRC-approved LACBWR Quality Assurance Program apply to all activities performed under the PCP, and solid radioactive waste processing procedures, E. Voluntary information Submittal if any of the following mishaps occur during the preparcson of LLW waste for disposal, a voluntary submittal of information will be sent to the NRC. This will be a 30-day report to the NRC's Director of the Division of Low-Level Waste Management and Decommissioning and will also be sent to the designated State disposal-site regulatory authority.

J PCP 6 Rev. 7

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(1)- Failure of the high-integrity containers used to ensure a stable waste form. Container failure can be evidenced by changed i container dimensions, cracking, or damage resulting from mishandling (e'.g., dropping or impacting against another object). ,

(2) . Misuse o_f high-integrity containers, evidenced by a quantity of j

. free liquid' greater than 1' percent of container volume, or by an  ;

excessive void space within the container. Such misuse is {

- prohibited by 10 CFR 61.56. l (3) Pioduction of a solidified Class B or C waste form that has any ,

of the following characteristics: 1

{-

- Contains free liquid in quantities exceeding 0.5 percent of j the volume of the waste.

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Contains waste with radionuclides in concentrations I

! exceeding those considered during waste form qualification  !

l testing accepted by the regulatory agency, which could lead

! to errors in assessment of waste class, j

= .Contains a significantly different waste loading than that

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! used in qualification testing accepted by the regulatory agency.

= Contains chemical ingredients not present in qualification 1

testing accepted by the regulatory agency, and those quantities are sufficient to unacceptably degrade the waste product.

- Shows instability evidenced by crumbling, cracking, spalling, voids, softening, disintegration, non- homogeneity, or dimensional changes.

- Evidence of processing phenomena that exceed the limiting processing conditions identified in applicable topical reports on process controletans (e.g., foaming, temperature extremes, premature or slow hardening, and production of volatile material).

PCP 7 Rev.5

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