PY-CEI-NRR-0329, Forwards Response to 850808 & 14 Ltrs Re Radwaste Solidification Sys.Responses Incorporated Into Rev 3 of Process Control Program.Proprietary NUS Process Svcs Repts FO-013 & SS-001 Withheld (Ref 10CFR2.790(b)(1))

Forwards Response to 850808 & 14 Ltrs Re Radwaste Solidification Sys.Responses Incorporated Into Rev 3 of Process Control Program.Proprietary NUS Process Svcs Repts FO-013 & SS-001 Withheld (Ref 10CFR2.790(b)(1))

ML20133H720
Person / Time
Site:	Perry
Issue date:	08/30/1985
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML20133H723	List: ML20133H789 ML20133H799 PY-CEI-NRR-0329, Forwards Response to 850808 & 14 Ltrs Re Radwaste Solidification Sys.Responses Incorporated Into Rev 3 of Process Control Program.Proprietary NUS Process Svcs Repts FO-013 & SS-001 Withheld (Ref 10CFR2.790(b)(1))
References
RTR-REGGD-01.052, RTR-REGGD-01.140, RTR-REGGD-01.143, RTR-REGGD-1.052, RTR-REGGD-1.140, RTR-REGGD-1.143 PY-CEI-NRR-0329, PY-CEI-NRR-329, NUDOCS 8510180082
Download: ML20133H720 (8)

Text

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P o. BOX 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMIN ATING BLOG - 55 PUBLIC SoVARE Semng The Best Location in the Nation MURRAY R. EDELMAN VICE MtESIDENT THIS SUBMITTAL CONTAINS NUCU AR PROPRIETARY INFORMATION PER

~f 10CFR 2.790(b)(1)

August 30, 1985 PY-CEI/NRR-0329 L Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Conformance with Regulatory Guides 1.52, 1.140 and 1.143 and Process Control Program for Radwaste Solidification

Dear Mr. Youngblood:

Attached is our response to your letters dated August 8,1985 and August 14, 1985 concerning the PNPP Radwaste Solidification System. These responses have been incorporated into Revision 3 of the Perry Process Control Program.

Also enclosed with this letter are the following documents for your staff's review:

Enclosure A: Perry Process Control Program, Rev. 3 PROPRIETARY Enclosure B: NUS Process Services Report No. FO-013, " Process Control Program for Dewatering Liners with NUSPSC Internals,"

Revision D. (Ref. 11 of Perry PCP).

PROPRIETARY Enclosure C: NUS Process Services Report No. SS-001, " Process Control Program for NUSPSC Radwaste Solidification System,"

Revision H. (Ref.12 of Perry PCP).

Enclosure D: Perry Nuclear Power Plant Operations Manual, " Shipment of Radioactive Waste for Disposal," OM1A: PAP-1309, The Cleveland Electric Illuminating Company (Ref. 18, or Perry PCP and response to Comment 4 in your August 8, 1985 letter above).

Enclosure E: FSAR Table 11.2-10 Table 11.4-2, Table 11.4-4. (Response to Comment 5 in your August 8,1985 letter).

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h b 4 Mr. B. J. Youngblood August 30, 1985 PY-CEI/NRR-0329 L Enclosures B and C contain information proprietary to NUS Process Services Corporation and it is requested that they be withheld from public disclosure as permitted by 10CFR2.790(b)(1). An affidavit to this effect is attached.

Please feel free to contact me if you have any questions concerning this matter.-

Very truly yours, Murray R. Edel Vice President  ;

Nuclear Group MRE:nje Attachment cc: Jay Silberg, Esq.

John Stefano (2)

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NUu ) PROCESS SERVICES

) CORPORATION Affidavit Submitted to the Nuclear Regulatory Commission Concerning Confidential Information and Trade Secrets Contained in Procedures Prepared by NUS Process Services Corporation State of South Carolina County of Richland Regan E. Voit states as follows on behalf of NUS Process Services Corporation:

1. I am the Director of Waste Management Services for NUS Process Services Corporation.

2. I have prepared and am familiar with the following procedures prepared by NUS Process Services Corporation:

o SS-001, Revision H, Process Control Program for Radwaste Solidification Service

3. NUS Process Services Corporation, hereinafter "NUSPSC" has granted permission for Cleveland Illuminating, to submit copies of the above to the Nuclear Regulatory Commission. The copies of the above contains proprietary information which should be withheld from public disclosure.

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4. NUSPSC's Radwaste Solidification and TRANSPIX' systems are major components of its waste processing business.

These systems for processing radioactive liquid wastes are unique to NUSPSC. Design and fabrication details for these systems are held in strictest confidence by all employees.

All employees of NUSPSC complete an agreement with NUSPSC regarding protection and non-disclosure of trade secret information at the commencement of their employ-ment. The information included in the procedures contains the type of information covered under the non-disclosure agreement. NUSPSC routinely stresses that such information is not to be discussed outside the company either during or after employment.

NUSPSC is in the process of making its initial entry into the radwaste processing service market. The Radwaste Solidification and TRANSFIX" systems and associated chemical control information represent a substantial commitment of personnel and financial resources for research, development, design and procedural controls. This commitment has resulted in systems currently superior to that provided by competitors and this superiority is the basis on which system details are withheld from public disclosure.

The information included in the aforementioned documents is not available through public sources. Release through public channels of the procedures will substantially harm the competitive position of NUSPSC.

J

• s 'y NUSPSC has expended over $750,000 in salaries and capital equipment during the last year and is engaged in a capital building project to make these systems available. Duplication of this effort by competitors would require both similar capital expenditures and the assembly of a team of experts similar to the design team employed by NUSPSC Regan E. Voit Director Waste Management Services Sworn and subscribed before me this )'26( day of August, 1985.

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I Attachment PY-CEI/NRR-0329 L Page 1 of 3 '

Comment 1 Identify any exceptions or deviations f rom the NRC approved NUS Topical Report (noted in your July 24, 1985 response) dated April 1983, and the NUS response to the NRC licensing review questions in letters dated July 9, 1984 and April 2, 1985.

Response

The following two deviations from the NRC approved NUS Topical Report PS-53-0378 dated April 1983, and NUS letters to the NRC dated July 9, 1984, and April 2, 1985 are taken:

(a) Test solidifications will be run on each batch of the same waste type instead of every tenth batch, and (b) Waste will be supplied to the NUS equipment at 20 gpm instead of 40 gpm due to pump limitations.

Comment 2 Identify interf aces between the Perry Plant and NUS System including:

(a) Means to contain spills or overflow (b) Liquid tank failure analyses implication (c) Radiological and effluent monitoring (d) ALARA considerations.

Response

(a) All of the process equipment is located in the fill aisle and storage area adjacenc to the truck bay (see Figure 2 of the Perry Process Control Program). These areas are surrounded by concrete walls that will contain any postulated spill or overflow. A floor drain, routed to the liquid radwaste system provides drainage of each of these areas.

(b) We postulate the worst case scenario to be the rupture of the NUS liner.

This equates to approximately 1500 gallons of waste. The contents of the liner will be contained per item (a) above.

(c) All liquid radwaste discharges are sampled and monitored prior to their release to the environment.

Gaseous discharges from the liners are processed through the vendor's off-gas blower system as described in NUS Topical Report PS-53-0378. The vendor's equipment incorporates radiation monitors on the fillhead assembly and the process piping skid.

I Attachment

. PY-CEI/NRR-0329L Page 2 of 3 Ventilation from the areas housing the radwaste treatment and processing equipment, including the vendor's off-gas blower system, is routed through HEPA filters and charcoal beds prior to release to the environment via the Unit 1 Vent. Radiological monitoring is provided for Regulatory Guide 1.21 compliance to meet applicable Federal Code requirements.

(d) All three ALARA principles are incorporated into the design of the Radwaste Bldg. (time, distance, shielding).

The permanent plant equipment is located in shielded cubicles. All process functions are operated from a remote control panel. The vendor's equipment uses a remote control panel for system operation. This panel is located away from the processing equipment behind a 2-foot thick concrete wall. A one-toot thick wall separates the liner and its associated components. A one-foot thick wall also separates the liner storage from the cement supply system.

Closed circuit television provides remote viewing of the processing area.

An overhead crane with a dedicated camera allows for remote transfer of solidified liners.

By employing remote control equipment, and through Health Physics pro-cedures, the time spent in this radiation area is minimized.

Comment 3 Provide location and arrangement drawings of the NUS System in the Perry Plant.

Response

Figure 2 of the Perry Process Control Program provides this detail.

Comment 4 Describe the waste classification program to demonstrate that the solid waste product is classified in accordance with 10 CFR 61, Section 61.55 and the NRC Branch Technical position on Waste Classification.

Response

PNPP will use the RADHAN computer code by Waste Management Group Inc. to perform the 10CFR61 classification. The RADHAN computer code is detailed in the WMG Topical Report, WMG 102-NP-A, entitled "RADHAN-A Computer Code to Classify and Document Packaged LLW in Accordance with 10CFR Part 61 Regu-lations," and found acceptable for referencing by letter f rom NRC (Leo B.

Higginbotham) to WMG (Peter T. Tuite) dated July 25, 1983. Procedure PAP-1309

" Shipment of Radioactive Waste for Disposal" (see Enclosure D) will be used for performing waste classification calculations manually should the computer code become inoperable for any reason.

I Plant procedures for the sampling of wastes for 10CFR61 classification are being developed at this time, i

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Attachment PY-CEI/NRR-0329 L Page 3 of 3 Manifest preparation is provided by the RADMAN computer code, and in PAP-1309.

Comment 5 Identify specific characteristics and volumes of '.et" radioactive waste to be

. processed by the NUS System.

Response

These characteristics are provided in FSAR Tables 11.2-10 (Stream Nos. 29, 34-a, 34-b, 40, 48,-62), 11.4-2, and 11.4-4 (see Enclosure E).

Comment 6 Describe the capability of the Perry plant to meet the criteria of Appendix 1 to.10 CFR Part 50 with the NUS System in operation.

Response

Since the NUS mobile system is located inside the Radwaste Building, as was the UNI System, there are no additional source terms introduced to the radwaste system and consequently the estimated offsite doses as presented in Section 5.2.4 of the PNPP Environmental Report will remain the same and will not exceed the 10 CFR 50 Appendix I design objective.

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! n NUCLEAR REGULATORY COMMISSION

$ p W ASHINGTON, D. C. 20555

%,...../ SEP 181985 Docket Nos.: 50-440 and 50-441 Mr. Murray R. Edelman Nuclear Operations Group '

The Cleveland filectric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101

Subject:

Request for Permission to Reprint Copyrighted Material By letter, dated August 30, 1985 you transmitted material on the Process Control Program for Radwaste Solidification and requested withholding from public disclo-sure as proprietary.

Some of the material submitted is owned and copyrighted by NUS, as in Enclosure B, and in order for us to enter this material into our system it must be microfiched.

Please forward permission for us to copy this material. The permission to release l

the material for copying should be on NUS letterhead and signed by an appropriate official.

. Sincer ly, .

B. h.YIungblo , Chief Licdnsi g Branch No. 1 -

Divisic n of Licensing f cc: See next page O

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• ATTACHMENT l

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NLJd CORPORATION September 25, 1985 PS-83-3088 Ms. Martha Takacs Cleveland Electric Illuminating Perry Nuclear Plant P. O. Box 97 North Perry, OH 44081

Dear Ms. Takacs:

Confirming our previous discussions, NUS Process Services Corporation will permit the NRC to place the f ollowing proprietary c.-

and _copywrited documents on microfiche. We understand that the -

NRC will' continue to control these documents as proprietary information.

. SS-001, Rev. H, " Process Control Program for Radwaste Solidification Systems"

. SS-001, Rev. I, " Process Control Program for Radwaste Solidification Systems"

. Procedure Change Requests (PCR's) to SS-001, Rev. I dated 9/11/85, 9/23/85 and 9/24/85

. FI-013, Rev. D, " Process Control Program for Dewatering Liners with NUSPSC Internals" (PCR #FI-013/D-1)

As you know, our laboratory in Columbia, South Carolina continues to perform 10 CFR 61 waste form testing to certify new, more efficient chemical formula tions . Revision I is the most recent revision and we do not anticipate another change within the next six (6) weeks.

Sincerely,

't s Regan E. Voit Director Waste Management Service s REV:pw

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