ML20207G206

Discusses Results of Samples from Recent Solidification Efforts of Decontamination Solution Liner.Nine Samples Shipped to Inel as Part of Research Project.Difficult Conditions During Sample Collection Listed

ML20207G206
Person / Time
Site:	Quad Cities
Issue date:	08/15/1988
From:	Johnson I COMMONWEALTH EDISON CO.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20207G213	List: ML20207G206 ML20235A892
References
5003K, NUDOCS 8808240018
Download: ML20207G206 (4)

Text

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• e i / One First Nabonsi Plaza, CNea0o,1:linois V 1 Address Reply ta: Post Omoe Box 767 Chce0o. Enois 60690 0767.

August 15, 1988 1

l Mr. Thomas E. Murley, Director )

Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conunission Washington, DC 20555

Subject:

Quad Cities Station Units 1 and 2 4 "Transmittal of Samples Resulting from Quad Cities LOMI Decontamination to >

Idaho National Engineering Laboratory $

(INEL)"

NRC Docket Nos. 50-254 and 50-265 References (a): Letter from I.M. Johnson to T.E. Murley I dated July 15, 1988.

(b): Letter from T. Ross to H.E. Bliss {

dated July 14, 1988.

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. Dear Mr. Murley l I

. Reference (a) transmitted information to your stsff regarding the t recent solidification efforts of a decontamination solution (LOMI) liner at  !

the Quad Cities Station. During the course of the decontamination and  ?

l solidification, representatives of Idaho National Engineering Laboratory (INEL)  ;

i were onsita and collected eight (8) coment samples containing decontamination-- i radwaste and one (1) sample of lon-exchange resin. The INEL personnel were  !

j. employed by the NRC in a research program on the characteristics of low-level  !

j decontamination radwaste. i 5 In a May 24, 1988 meeting with members of your staff, it was agreed 1 i that the samples would be transmitted to INEL after receipt of information regarding the disposition of these samples. The staff provided CECO with such -

1 information in Reference (b). Pursuant to that agreement and-commitments made j in Reference (a), Commonwealth Edison is hereby notifying the NRC of the ,

i' shipment of the nine total samples to your contractor as part of your ongoing l research project..  :

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T.E. Murley August 15, 1988 In Reference (a), it was indicated that the representativeness of the various samples to the contents of the LOMI liner is uncertain. The conditions under which each type (resin, cement) of sample was collected were.less than model and therefore these samples do not completely reflect, to different degrees, the actual Quad Cities resin mixture as it existed prior to solidification, or the final solidified product.

The f actors that contributed to dif ficult conditions during sample collection and may have affected the ability of the INEL Individual to obtain a completely representative sample are described-as follows:

1. The distances between the sample media and the top of the liner was about 22 inches in the case of the resin mixture and 15-20 inches in the case of the cement samples.

2. The samples were obtained through the cement addition hole on the solidification fill head. In the case of the resin mixture dample a make-shif t remote sampling rig was used that consisted of a polyethylene bottle on the end of the device that held it in place. Efficient operation of the device was not easily accomplished through the cement fill hole. The cemeat samples were obtained by the individual extending his arm through the cement addition hole, and scraping the IQE of the cement / resin mixture, as it was hardening, with the polyethylene bottles (one at a time).

3. None of the samples were collected while the waste was mixing.

Although the resin mixture sample was collected shortly after the mixing had stopped, it was noted that settling of the resin was already occurring, as it was observed that there was about two inches of water on top of the resin. The samples  !

obtained af ter the addition of the cement were taken af ter the j mixture had stopped due to the hydraulic mixing device torquing I out.

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4. The performance of this task by the INEL individual is not one j of his routine activities. Add to this he had to climb on top I of the cask wearing the full set of protective clothing, rubber outer protective clothing and a full face respirator, work in a high radiation field (800 mr/hr), work from the top of a liner stacked with lead blankets sitting inside a cask, use a make-shift 1

device to obtain one sample, scrape cement that was setting-up

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on the other samples; all this through the cement addition hole, )

and it can be seen that even an experienced radiation worker would I have a dif ficult time obtaining a completely rapramantative sample, i

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.T.E. Murley *3- August 15, 1988 Other circumstances existed specific to the drawing of the cement samples which lead us to conclude that these samples are especially nonrepresentative. Our understanding of the condition of the liner, at the time the cement samples were drawn, was that there existed a mound of mixed cement powder on top of the hardened cement which the INEL representative was .

attempting to sample. As previously mentioned, the top of the cement mixture was 15 to 20 inches directly below the small fill head opening through which the samples had to be drawn. The INEL representative commented after drawing the cement samples that it was very difficult to extend his arm outward away fro the mound of unmixed cement (to the outer perimeter where good mixing had occurred).

The INEL representative also commented that he could not see into the l liner while drawing the cement samples due to the presence of a dense cloud of ,

water vapor rising out of the liner (which is consistent with the fact there I was a very severe exotherm taking place at that time). He further commented that the cement mixture had hardened to the point where it was very difficult j to scoop the already hard cement mixture using the lip of the sample bottle.

It c6n be seen through visual observation of the cement samples that those j

( samples consist mainly of small lumps of cement, which indicatei that these l l samples are in part, samples of the above mentioned mound of unmixed cement )

l which had become moistened by the cloud of water vapor. Some samples appear to consist, in part, of larger but still monolithic lumps of cement. Under the circumstances given above, it can be seen that it would have been virtually impossible for INEL representative to have obtained a representative sample of hardenao cement.

Furthermore, even if it were possible to draw samples consisting only of the hardened cement mixture, such samples would likely not be representative of the cement mixture in the liner by virtue of the scraping method used to draw the samples. This scraping would have likely disturbed the already well formed crystalline matrix that existed in the liner at the time the samples were drawn.

Still, further information is available regarding the representative-I ness of these cement samples. CECO has found that the measured dose rates of the cement samples vary by a f actor of 10 to 15. CECO further believes these cement samples are not representative by virtue of the fact they were drawn fron the immediate surface of the cement mixture. The existence of the dense cloud of water vapor rising out of the liner is an indication that circum-stances could have existed whereby any small steam and air bubbles which perhaps could have formed within the mixture could have been trapped near the surface of the cement mixture as it hardened. These voids may contribute to the lack of representativeness of these samples.

This information is based is based upon a review of the solidification vendor's logbook and discussions with personnel involved in the solidification.

The nature of that information available to CECO leads us to conclude that testing of these samples would yield a nonrepresentatively poor indication of the physical characteristics of the contents of the liner.

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S T.E. Murley August 15, 1988 It is important to note that Commonwealth Edison does not intend to declare the contents of this liner to meet the stability criteria of 10 CFR

61. This liner received less than one third of the cement the vendor intended prior to the seizure of the mixer shaft. As t'9ted in Reference (a),

Commonwealth Edison intends to render stability via encapsulation. Attached, please find Revision 6 to the Quad Cities Station Process Control Program for Processing of Radioactive Wet Waste, dated July 1988. This revision to the PCP includes the encapsulation method to be used on the affected'11ner. This is provided to your staff for their information as was agreed to in Reference (a).

It is Commonwealth Edison's belief that the methodology used to collect these samples is scand and can result in the collection of a represen-tative sample under the proper conditions. It is our belief, however, that such conditions may not have existed at the time the samples were taken, and therefore the samples may not be totally representative.

Lastly, Reference (b) also refers to Process Control Program (PCP) samples that were generated by the solidification vendor (as required by the vendor's PCP). These samples are the property of the solidification vendor and, as a result, we are not at liberty to transmit them to the staff.

With the importance of this project and its effect upon the nuclear industry, Commonwealth is concerned regarding the conclusions that may be drawn f rom the analysis of the Quad Cities samples.

Please direct any questions you may have regarding this matter to this office.

l Very truly yours, i i J i

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I. M. Joh on Nuclear Licensi Administrator 1m cc T. Ross - NRR, w Att.

QC Resident Inspector, w/o Att.

P. Reed - NRR Research, w/o Att.

C. Meissaac - INEL. w/o Att.

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, 00AD-CITIES STATION . .

PROCESS CONTROL PROGRAM l

FOR  ;

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PROCESSING OF RADIOACTIVE WET WASTE

'L REVISION 6 l

JULY 1988 i

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. .l. PURPOSE

. The purpose of this Process Control Program (PCP) is to insuro that~

all low level radioactive wet wastes solidified or dewatered at Quad-Cities Nuclear Power Station meet the applicable federal, state, and burial site requirements. This PCP sets forth the steps used to solidify or dewater radioactive wet wastes and to verify the final product meets the applicable requirements. This program covers the in-plant cement, vendor cement, vendor dewatering and vendor encapsulating systems. Wet wastes at Quad-Cities Station consist of filter media (powdered ' resin and fiber) and bead resin. When expended, these wastes are transferred to various storage tanks or in some cases these wastes are transferred directly into a liner for processing. Vendor processing of the waste is

. done in either a transportation cask or a process shield and offers the advantage of reduced radiation exposure to personnel involved in -

performing the necessary package handling operations.

II. IN-PLANT CEMENT SOLID WASTE SYSTEM ,

A. Description (Class A unstable waste form only)

The resin slurry is transferred to one of two centrifuges for dewatering. The centrifuges have a capacity of 25 gpm. The solids are separated from the water and drop into a hopper associated with each centrifuge. The water is routed back to a storage tank.

Each hopper has a 40 cubic foot capacity. At the bottom of the t

hopper there is a hopper discharge valve. This is a remotely  ;

operated, air operated, fail closed valve. Connected to the hopper discharge valve is the sludge chute and the drum feed valve. The sludge chute is 8 inches in diameter and 6 feet 5 inches long, with a

, capacity of 2.2 cubic feet. The drum feed valve is also remotely operated, air operated, and fall-closed. The hopper discharge valve 01530/0229Z i i

,. and the drum feed value are interlocked to prevent both valves from

.' being opea simultaneously.

Cement is added to a drum from the cement silo. The cement silo has a capacity of 620 cubic feet. Cement is fed through a rotary .

feeder down a transfer tube through the mixer head, into the drum.

The mixer goes into the drum and forms a seal to p'revent dispersion of cement dust or spillage during mixing. The mixer has two speeds, 100 rpm and 200 rpm, that are programmed into the mix cycle.

Drums are capped at the load-out conveyor area before loading into a shipping vehicle. A cap is set in place and a seal ring is snapped over it. A threaded bolt is used to tighten the seal ring.

Drum storage consists of three conveyor lines, with room for 25 drums on each line. Drums stored on the storage lines are removed and either shipped, stored in storage bins located in the radwaste

, facility, or stored in the Interim Radwaste Storage facility.

B. Operation of the In-Plant Cement Solid Waste System in order to insure solidification of spent resins with no free water, tests were conducted at Quad-Cities Station using unspent resin. Fresh resins were mixed up in the proportions that would be expected to be normally processed. These resins were then put into a drum and the drum was processed through the cement system. The drum was capped as normal and allowed to set in storage for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the drum was cut open lengthwise and inspected. The results of the inspection resulted in a change of the proportions of water and' cement until the final product was solid and free of water. A series of drums were processed using spent resins, and the drums were visually inspected for no free water prior to shipping.

No free water was observed.

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. The gengral procGduro that is followed to process spent resins is described below. Specific plant operating procedures are followod

." by the operator.

1.

The empty drum is covered with a plastic bag and taped in place to prevent external contamination.

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A half of a bag of dry cement is added to the empty drum.'

3.

3 The empty drums are loaded on a conveyor.

4 One empty drum from the conveyor is loaded on a' transfer cart (remote operation). ,

5.

The transfer cart is advanced to the selected hopper station

, (remote operation).

6.

The drum is filled with resins to a prescribed level (remote operation).

The resin is transferred from the hopper to the drum through the sludge chute. The discharge valve on the -

sludge chute is a manually operated remote valve. The operator views the drum through a mirror and fills the drum to between the first and second roll hoop f rom the top of the drum.

Although this method of adding resin to the drum is not precise, h

it can be controlled to a high degree. If an operator determines that the quantity of resins varies from the prescribed level, he can compensate with water and/or cement.

7.

Water is added (remote operation). Normally 16-20 gallons of water are added to each drum. This amount can be varied if necessary for complete solidification. The amount of water required is selected, and a flow integrator gives the inlet valve a closed signal when that amount is delivered.

8, .

The drum is transferred to the mixing station (remote operation). i j 9. The cement timer is set, 01530/0229Z i i

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. 10. The mixer cycle (remote operation) is startcd. The mixer lowors into the drum and forms a tight seal. The mixer will begin to rotate at slow speed. The air slide blower and dust collector are started. The cement feeder and vibrators start and cement is metered to the drum. The mixer ine'reases to f ast speed,' The cement feeder stops and the air slide blower and dust collector stop. When the mixer completes the cycle, the RPM meter will start to decrease. At this point, the mixer control switch is moved f rom AUTO to FAST and the mixer is given an additional 5 minutes on fast speed. The switch is then returned to AUTO, and the mixer cycle is complete.

11. The drum is transferred to the inspection station (remote operation).

12. The mixed drum contact radiation reading are logged and the .

contents of the drum are observed. If it is determined th'at more cement is required, the drum is returned to the mixer and '

additional cement is added. When the mix is satisfactory, the drum is t.'ansferred to the drum storage lines.

C. Verification of in-Plant Cement System Solidification The solidified drum is verified to be void of f ree water prior to shipping or storage. The drum is transferred from the storage lines to the load-out conveyor. At this point, the drum is visually inspected to verify it is void of f ree water and the contents solidified. The protective plastic bag is removed, and the drum is ,

capped. The drum is then surveyed for smearable contamination and i

dose rate. The drum is then loaded into the shipping vehicle or placed in storage. ,  ;

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If a drum is found to contain free cater, dry cement will be added to solidi fy the f ree cator or the drum will be rccycled through the mixing line as required. The drum will not be shipped with more than 0.5 percent freestanding water.

Ill.

VENDOR SUPPLIED SOLIDIFICATION SYSTEM (Stable Waste Forms)

A. Description Contractor solidification services are utilized at the Station for wastes which are required to be classi fied as stable waste per -10 CFR 61 and/or burial site licenses. The contractor must have a PCP (Process Control Program) to produce a waste form which is stable as defined in 10 CFR 61. A copy of the vendor's procedures (which states station interface requirements), Process Control Program and NRC Approved Topical Report are submitted to an on-site review prior to use to assure compatability with Station Systems, procedures, and

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Technic'al Specifications. Specific station procedures are then developed f rom this vendor information and approved prior to use, 1

Normally, a batching tank is utilized to collect the radwaste to. ,

be solidified. The tank can be filled from any of the following:

1. Condensate Phase Separators.

2. Cleanup Phase Separators.

3. Spent Resin Tanks.

4. Waste Sludge Tank.

Af ter the tank is filled with radwaste, a decant pump is used to

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ren.ove water from the top of the settled sludge. When the decanting l l

operation is completed, the tank contains about 1,900 gallons of l

sludge. 1 i

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The mixing tank can be operated on recirculation to alloa a tank sample to be taken for analysis and sample solidification tests as required.

In certain cases, for example, wastes resulting from chemical decontaminations, the waste is sent directly to a liner in which the solidification will take place. In this case a PCP sample is taken out of the liner af ter it has been properly mixed prior to adding solidification chemicals. The recipe for solidification will be determined based on a successful solidification demonstration using the sample taken from the liner.

A temperature monitor in the liner is used to note the maximum temperature during the exotherm. Af ter suf ficient cooling the liner is prepared for shipment or storage.

B. Operation of the Vendor Solidi fication System -

A liner is prepared for use by installing a thermocouple and tubing for level indication. The fill head is placed over the lider and locked in-place.

The radwaste is added to the liner. The mixing tank, if used, is l first mixed for about 10 minutes. The proper amount of radwaste is delivered by a radwaste pump or slurried from portable processing i equipment. Waste flow to the liner is r.onitored by a TV camera. The radwaste pipe lines and waste transfer hose to the fill head are then flushed.

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e After the rad aste has'been put into'the liner the process is completed by the contractor. The contractor adds cement and addit'ives in accordance with their approved PCP. After final mixing the temperat'ure is moni tored and the maximum temperature is noted. When the solidified liner has sufficiently cooled, the contractor and t

Station personnel visually inspect the product and verify that it is an acceptable product. The liner is then covered with a lid, secured, surveyed and shipped or stored in the Interim Radwaste Storage Facility.

C. Verification of Vendor Supplied Solidification System Verification of solidification first involves sampling the-radwaste prior to solidification in order to determine the proper

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proportions of the ingredients that will produce an acceptable -

product. A representative laboratory sample of waste is taken, in accordance with the vendor's PCP program, small, scaled-down amounts of cement and additives are added in the proper quantitles. Based on-

• an acceptable product, scale-up factors are developed for the full scale solidificatlon.

To further verify solidification, a visual inspection of the liner is performed by both the vendor and station personnel prior to installing the lid. The visual inspection verifies that the product is acceptable per the contractors PCP, l

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IV. VENDOR SUPPLIED DEWATERING SYSTEM (STABLE WASTE FORMS)

A. Description Contractor dewatering services may be utilized at the Station in lieu of so'lidification for stable waste forms as directed by station operating personnel. The contractor must have a Process Control Program (PCP) to produce a waste form which meets all the requirements of 10CFR61 and the applicable burial site criteria. A copy of the vendcr's procedures (which states station interface requirements),

Process Control Program and NRC Approved Topical Report are submitted to an on-site review prior to use to assure compatability with Station Systems, procedures, and Technical Specifications. Specific station procedures are then developed from this vendor information and approved. prior to use. -

A mixing tank is utilized to collect the radwaste to be < -

dewatered. The tank can be filled f rom any of the following:

1. Condensate Phase Separators

2. Cleanup Phase Separators

3. Spent Resin Tanks 4 Waste Sludge Tank After the tank is filled with radwaste, a decant pump is used to remove water from the top of the settled sludge. When the decanting operation is completed, the tank contains about 1,900 gallons of sludge.

The mixing tank can be operated on recirculation in order to allow a tank sample to be taken for analysis if required.

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8. Operation of the vendor 00aaterino System s . . .

A High Integrity Container (HIC) is prepared for use by ,

installing a thermocouple, if not already installed, and inspecting dewatering elements and thermocouple leads, if installed. The fill head is placed over the HIC and locked in-place.

The radwaste is added to the HIC. The mixing tank is first mixed for approximately 10 minutes.

The proper amount of radwaste is delivered by the radwaste pump. Waste flow to'the HIC is monitored a TV camera.

The radwaste pipe lines and waste transfer hose to'the fill head are then flushed.

Af ter the radwaste has been put into the HIC, the balance of the dewatering process is completed by the contractor.

The contractor dewaters in accordance with their approved PCP until the acceptance criteria is met. When the process is complete, the contractor and -

Station personnel verify that it is an acceptable product and samples are taken from the HIC.

The HIC is then covered with a lid, secured, surveyed and shipped or stored in the interim Radwaste Storage Facility.

C.

Verification of Vendor Supplied Dewaterino System Verification of an acceptable dewatered product is delineated in the contractors Process Control Program and operating procedures . The ,

criteria is dependent upon the type of dewa'tering system used and the '

material dewatered.

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V.. VENDOR ENCAPSULATION OF WASTE (STA81.E WASTE FORMS)

A. Description ,

Contractor encapsulation services may be utilized at the Station for stable waste forms as directed by station operating personnel.

The contractor must have a Process Control Program (PCP) to produce a waste form which meets all the requirements of 10CFR61 and the applicable burial site criteria. Vendor procedures are used to prepare specific Station procedures which are submitted to an on-site.

review prior to use.

8. Vendor Encapsulation Method A liner .is prepared by the vendor which has a prepoured bottom and partial sides. The item to be encapsulated is placed inside the prepour and the remaining portion of the liner is filled with a stable formula of cement. -

When the encapsulation has sufficiently cooled, the contractor and Station personnel visually inspect the product and verify that it is an acceptable product. The liner is then covered with a lid, secured, surveyed and shipped or stored in the Interim Radwaste Storage Facility.

C. Verification of Vendor Encapsulation To verify solidification, a visual inspection of the liner is performed prior to installing the lid. The visual inspection verifles that the product is acceptable per the contractors PCP.

• VI. HIGH INTEGRITY CONTAINER USAGE High Integrity container (HlC's) are used at the Station for various i l

approved waste packaging. The vendor which supplies the Hl0 must provide I the Station with a copy of the Certificate of Compliance for the HIC which details specific limitations on use of the HIC. l 01530/0229Z

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• ' , , V i l .' WASTE CLASSIFICATION Station wastes will be classified as Class A, Class B, or Class C 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 waste as outlined in 100FR61.55.

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 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 (gamma emitters) and the use of scaling factors to determine the radionuclide concentration of difficu.It to measure ,

radionuclides (normally non-gamma emitters). The use of the other suggested methods; material accountability, classification by source or gross radioactivi'y measurements may occur if the situation best fits the use of that methodology.

Approved Station procedures are used in the determination of radionuclide concentration for dif ficult to measure nuclides (normally non-gamma emitters) and for the classification of radioactive waste for near-surface burial.

Vll. SHIPMENT MANIFEST Each shipment of radioactive waste to a licensed land disposal  ;

facility will be accompanied by a shipment manifest as required by l 10CFR20.311(b) and 10CFR20.311(c). The manifest will contain the name, address, and telephone number of the waste generator. The manifest will i

also include the name, address, and telephone number or the name and EPA  !

hazardous was 4 identification number of the person transporting the waste i to the land disposal facility.

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- The manifest all? also iridicate to the extent practicable: a physical description of the caste:.the volume; radienuclide identity and quaqtity:

the total radioactivity; and the principal chemical form. The solidification agent, i f applicable, will be identi fied.

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.

Each manifest will include a' certification by the waste generator that >

the transported materials are properly classified, described, packaged, marked, and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation and the NRC. A representative of the Station will sign and date the -

manifest. Approved Station procedures are used for the preparation of burial site radioactive shipping mani fests. .

The Station will maintain a mani fest recordkeeping and tracking system that meets the requirements of 10CFR20.311(d). '

IX. ADMINISTRATIVE CONTROLS A. Training A training program will exist to ensure that waste processing will be performed according to Station procedures and in accordance with the requirements of the PCP. An individual's training record will be maintained for audit and inspection. The processing and 1 shipment of radioactive material will be performed by qualified and trained personnel.

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, ,* , B. Record Retention Records of processing data, test and analysis results, documents.

results of training, inspections and audits will be retained in accordance with company quality assurance requirements for record retention.

-C. Documentation Control Licensee initiated changes may be made to the PCP in accordance with Section 6.9 of the Technical Specifica* ions and shall become effective upon review and acceptance by the On-site Review function.

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.

O. Quality Control 1

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Licensee procedures ensure that a vendor processing radioactive waste, for burial, adhere to their procedures and that an acceptable product that meets regulatory requirements and burial site criteria

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results. This procedure addresses the requirement to assess the I impact of changes in a vendor's PCP or the Station's PCP and requires a 10CFR50.59 safety evaluation for any changes in the vendor's PCP.

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