ML18019A370

Rev 0 to Plant Operating Manual PLP-300, Process Control Program.

ML18019A370
Person / Time
Site:	Harris
Issue date:	07/31/1985
From:	Joseph Willis CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML18019A369	List: ML18019A368 ML18019A370
References
PLP-300, NUDOCS 8509110338
Download: ML18019A370 (31)

Text

~

f CAROLINA POWER 6 LIGHT COMPANY SHEARON.HARRIS NUCLEAR POWER PLANT PLANT OPERATING MANUAL VOLUME 1 PART 2 PROCEDURE 'TYPE: PLANT PROGRAM '(PLP)

NUMBER: PLP"300 TITLE0 PROCESS CONTROL. PROGRAM .

REVISION 0 APPROVED+

Signature Date TITLE f'.. 8SO9X.X OSIS: SSO9oO

)' PDR ADOCK 0500D400 PDR m

Page 1 of 21

t 4 I 4

g

TABLE OF" CONTENTS SECTION PAGE, 1.0 PURPOSE 4

2.0 REFERENCES

4 3.0 DEFINITIONS ~

4 4.0 GENERAL 5 4;1 'Review, Approval and Changes 5 4.2 Use of Solidification Vendor Service 6 5.0 IMPLEMENTATION 6 5.1 Waste Streams 6 5.2 Cement Solidification 7 5.2.1 Solidification Formulas 7 5.2.2 Control of Process Parameters 8 5.2.3 Pre-Solidification Sampling and Testing 10 5.3 Polymer Solidification 12'2 5.3.1 Solidification Formulas 5.3.2 Control of Process Parameters 12 5.3.3 Pre-Solidification Sampling and Testing 15 5.4 10 CFR61 Implementation 16 5.4.1 Waste Classification 16 5.4.2 Waste Characteristics 16 5.4.3 Labeling 18 5.5 10 CFR20.311 Implementation 18 5.5.1 Shipment Manifest 18 5.5.2 Quality Control Program 18 6'0 FIGURES, TABLES, ATTACHMENTS . 18 6.1 Process Control Program Implementing Pr'ocedures 19 6.2 SHNPP Radioactive Waste Streams 20 6.3 Waste Stream Sample Points 21 PLP-300, Rev. 0 Page 2 of 21

LIST OF EFFECTIVE PAGES

/

~Pa e Revision 1 thru 21 0 PLP-300, Rev. 0 ,Page. 3 of 21

sc'

~

1

~

e 1 ' PURPOSE The purpose of the Process Control Program (PCP) is to establish a set of process parameters which,pr'ovide reasonable assurance of com-plete solidification of various radioactive waste and compliance with 10 CFR 20, 10 CFR 61, the Plant Technical Specification,, Federal and-State regulations','urial site requirements and other requirements governing the disposal of radioactive waste. The Process Control Program is a requirement of Technical Specification 3/4.11.3.

2.0 REFERENCES

2.1 Code of Federal Regulations, Title 10 Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste"..

2.2 Code of Federal Regulations, Title 10 Part 20.311, "Transfer for DisPosal and Manifestsue s

2.3 NUREG-0472, "Radiological Effluent Technical Specification for PWR" " Jul.y 1979.

A

. 2.4 NUREG"0133, "Preparation of Radiological Effluent Technical Specification for Nuclear Power Plants".

2a5 General Process Control Program, "Cement Solidification of Low Level Liquid Waste at Pressuriz'ed Water Reactors", Stock Equipment Company RPA 8.3.1.2-A; 2.6 General Process Control Program, "Polymer Soli:dification of Dry Products," Stock Equipment Company RPA 8.3.2.1-0.

2.7 Technical Specification, "Shearon Harris Nuclear Power Plant Technical Specifications".

2.8,'outh Carolina Department of Health and Environmental Control Radioactive Material License Number 097.

s 2.9 State of Washington Radioactive Material License Number WN"I019-2.

3.0 DEFINITIONS 3.1 Batch - A specified quantity of waste mater'ial which can be isolated from further, inputs.

~

3.2 Exothermic Period - For polymer soli.dification, the period

, beginning at the point at which the rate of temperature increase is

'equal to 1'F per min. =

3.3 Solidification - The conversion of radioactive waste into a form that meets shipping and burial site requirements.

3.4 Waste Classification " The determination of a waste class as outlined, in 10CFR61 by radionuclide isotopic analysis, and/or corre-

'lation with other measuredsnuclides.

PLP-300, Rev. 0 Page 4 of 21

~'

4.0 GENERAL Plant Technical Specification 3/4.11.3 requires the. Solid Radwaste System to be used in accordance with a Process Control Program to meet shipping and'transportation requirements and disposal site criteria. t It is'he intent of the Process Control Program to provide reasonable assurance of meeting these regulations and to demonstrate'ompliance with 10CFR61 for'the Solid Waste Processing System at Shearon Harris Nuclear Power Plant by.'

4 f

~ -'efining the various waste. streams',

Establishing a set of process parameters that affect solidifi-cation and developing operational contxols for those parameters',

Providing a Pre-solidification Sampling and Testing Program in accordance with Technical Specification 3/4.11.3; Implementing a Waste Classification System in accordance with

~ , 10CFR61 and applicable Regulatory Guidance; Referencing the 'performance of a 10CFR61 Waste Form Stability Testing Progxam for the Stock Cement and DOW Polymer Solidifi-cation Systems; and Providing appropriate Quality Control Program required by 10CFR20.311.

C

,. If solidification does not meet disposal site and shipping/transportation requirements immediately suspend shipment of inadequately processed waste and correct the Process Control Program, the -implementing procedures, and/or the Solid Waste Processing System to pxevent recurrence.

If solidification is not performed in accordance with this or other approved/qualified Process Control Programs, test the processed waste

.in each container to ensure it meets burial site and shipping

,requirement and take appxopriate actions to prevent recurrence.

With the installed Solid Waste Processing equipment incapable of meeting requirements of Technical Specification 3.11.3 or declaxed inoperable restorethe equipment'o operable status or provide f6r

. contract capability to process waste as necessary to satisfy applicable transportation and disposal requirements.

4.1 Review A royal and Chan es The Process Control Program shall be reviewed by PNSC and approved by the Nuclear, Regulatory Commission. priox to implementation.

PLP-300, Rev. 0 Page 5 of 21

~ 5 4

4.1 Review A royal and Chan es (continued)

Changes to the Process Control Program shall be reviewed 'by the Plant Nuclear Safety Committee and approved by the Plant General Manager in accordance with Technical Specification 6.5.3 and 6.13.

Changes shall be 'submitted to the Nuclear Regulatory Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change was made in accordance with Technical'Specification 6'. 13.

4.2 Use of Solidification Vendor Services

~

Solidification vendor services may be use to solidify or dewater any radioactive waste stream provided the solidification or dewatering is done in accordance with an approved or qualified Process Control ~

Program. If the Solidification Vendor's Process Control Program is used'he requirements of this Process Control Program are not applicable.

5.0 IMPLEMENTATION The Process Control Program shall be implemented by the use of approved plant procedures which provide step-by-step direction for the operation of the 'solidification systems and .shipment of waste to-a licensed burial site. Deviation from these procedures shall not be permitted except in the case of an emergency. A list of plant proce-dures which implement the Process Control Program is given in Table 6.1.

5.1 Waste Streams Seven major waste streams for Shearon Harris Nuclear Power Plant are listed in Table 6.2 along with the sources and the Solidification System, used to process and/or package the waste in accordance with 10CFR20 and 10CFR61. solidification' For the purpose of Technical Specification 3/4.11.3 a batch shall consist of,a particular amount of waste requiring (For example, the amount of waste contained within a tank). If, new'.

material .is added'o a tank's content .after sampling, a new batch is created which requires further sampling prior to solidification.

Normally.a batch is defined'ut not limited to the following'.

Waste. Batch Spent Resin The volume contained in an isolated Solidification Decant Tank.

PLP-300, Rev. 0 Page 6 of 21

5.1 Waste Streams (continued)

Waste Stream Batch Evaporator Bottoms- The volume contained in an isolated Secondary Waste Evaporator Concentrates Tank, Waste Evaporator Concentrates'Tank or Solidification Pretreatment Tank.

Filter Sludge The Volume contained in "an isolated Filter Particulates Concentrates Tank, or Solidification Decant Tank.

Misc. Chemical Solution The Volume of Chemical waste co'ntained in an isolated Solidification Pretr'eatment Tank Volume Reduction 4 Dry Product The volume contained in an isolated Secondary Waste Evaporator Concentrates Tank,

.Waste Evaporator Concentrates Tank, or Solidification Pre-Treatment Tank. 'Algorithm will be used for correlation of liquid to dry product.

Oils The volume of"oil in"one container or from a single source to be solidified.

'ry Active Waste One month volume of compactable and non-compactable waste 5.2 Cement Solidification 5.2.1 Solidification Formulas Testing of cement as a.solidification agent indicates the amount of cement'utilized will vary depending on the waste stream and its chemical and physical 'properties.. In addition waste streams which contain boric acid'equire the use'f 'a solidification aid.

Solidification formulas .for each waste stream to'e solidified wj.th cement. at- Shearon Harris Nuclear Power Plant are given in the Cement Solidification System Operating Procedure, OP-120.05.03. The formulas include the required amount of cement, the type and amount of solidification aid, if req'uired, the amount of waste, and drum PLP-300, Rev. 0 Page 7 of 21

C ~

5.2.1 Solidification Formulas (continued) mixing times. These values shall be 'recorded on the Solidification Worksheet. The formulas are pre-tested in "a solidificati'on Laboratory in order to verify the solidification results in a free-standing mass without free liquids.

New solidification formulas may be developed a'nd added to the operating procedures., New formulas will be pre-tested in accordance with applicable portions of Section 5.2.3 to verify that solidifi-cation results in a free-standing mass without free liquids. New formulas or changes in formulation shall be reviewed by the, Operati'ons Radwaste Engineering and approved by the Operations Manager.

5=.2.2 Control of Process Parameters Type 2 Portland Cement shall be used for cement solidifi-cation at Shearon Harris Nuclear Power Plant. Purchase requisitions shall'require the supplier to meet the speci-fication of ASTM C150. Radwaste personnel shall verify proper certification prior to unloading cement'.

H of ~

Waste Stream The recommended range. for borated waste streams pH is 7 to 9 inclusive and greater than 6 for other waste streams.

-The waste stream is sampled and analyzed for pH prior to solidification. Spent resin beads are characterized by analyzing the water surrounding the beads. The pH shall be adjusted if it is outside of the recommended range. Sample results shall be documented on the Solidification Worksheet.

3 ~ Boric Acid Concentrations The addition of a solidification aid is based on the boric acid concentration of the waste stream. Each batch of waste is sampled and anal'yzed for boric acid concentration.

Boric acid. concentration of 'spent resin is determined by an assay of the boric acid separated from the Anion resin beads. ,The amount of solidification'aid required and the boric acid concentration shall be documented on the Solidi-fication Worksheet.

PLP-300, Rev. 0 Page 8 'of 21

IE I'P

=-5-.2.2 Control of Process Parameters (continued) 4~ Chemical/Solids Concentrations Solidification formulation is based on a maximum chemical/

solid concentration. Evaporator bottoms are sampled and analyzed for chemical concentration. 'eprocessing or dilution shall be required if concentrations are above maximum concentrations. Filter sludges are sampled and analyzed for solids concentrations and may be adjusted in

, the decant tanks. Solids concentrations for spent resins are adjusted in the decant tanks to obtain the specified amount of free standing water required by the solidification formulas. Results shall be documented for concentrations of each waste stream as appropriate on the

. Solidification Worksheet.

5. Presence of Oil in Waste Stream Solidification test involving typically encountered oil types indicate that up to 2X concentration by weight do not adversely affect solidification. Each waste stream is sampled for organics prior to solidification and guidelines established to limit unintentional oil concentrations below 1X as required by burial site. Oil concentration shall be indicated on the Solidification Worksheet.

6. Slurr Settlin Times Zn order to allow bead resin sluries to settle to a uniform bed of solids in the decant tank a timer is provided at the solidification control station. Settling time is controled by the operating procedure at a minimum of one hour.

7 ~ Drum Mixin Times Drum mixing times are automatically controlled by an adjustable timer at the solidification control station.

Mixing times vary from waste stream to waste stream from 10 to 30 minutes. Recommended mixing times for each waste stream is given in the operating procedures and recorded on the Solidification Worksheet.

8. Solidification'et Times Since solidification is not an instantaneous occurrence, a range o'f 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is recommended to assure solidifi-cation. Administrative controls are used to prevent ship-ment of waste within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after solidification.

PLP-300, Rev. 0 Page 9 of 21

V II

.5.2.2 Control of Process Parameters (continued)

9. Tem erature a

Concentrate waste temperature of 120'F to 160'F is recom-mended and is monitored with a thermocouple. In the event of waste temperature exceeding 160'F the solidification process is stopped until temperature is adjusted. 'The recommended temperature forother.waste is 40'F to 130'F.

Due to the indoor location of the waste streams, these

- limits are not expected to be exceeded.

10.'ater f to Cement Ratio The recommended range for water to,cement ratio is 0.4 to 1.0 and varies with waste stream. -This ratio is controlled by solidification formulas inclu'ded in the operating proce-dure.

5..2.3 ~

Pre-Solidification Sam lin and Testin Pro ram

l. ~Sam lia a

A sample of the waste requiring solidification must be taken'n. order to determine any pretreatment of waste needed prior to solidification, determine- waste-characteristics,,perform test solidification and determine wa'ste classification of the waste to be solidi. fied. If the radioactivity."levels are too high t'o permit full size .

samples -to be~ taken, then smaller samples shall be taken with the results corrected accordingly. Normal sample.

points are given in Table 6.3, however," any sample point

.which provides a representative sample may.be used to obtain a sample.

2. Chemical Anal sis of Waste Sam les Evaporator bottoms, filter sludges, and chemical waste shall be analyzed for percent solids concentrations, pH, boric acid concentration, and oil content and the results recorded on the Waste Solidification Worksheet.

Spent resin beads shall be characterized by analyzing the water surrounding the beads for oil content and pH. Boric acid concentration shall be determined by an assay of the boric acid separated from the anion, bead resin. The result shall be recorded on the Waste Solidification Worksheet.

PLP-300, Rev. 0 Page 10 of',21

~ \

5.2.3 Pre-,Solidification Sam lin and Testin Pro ram (continued)

3. .Radiochemical Anal sis of Waste Sam les 4

A gamma isotopic analysis shall be performed on each batch of waste to be solidified. This analysis is used to deter-,.

mine the proper waste classification in accordance with 10CFR61 Waste Classification System.. The results of the gamma isotopic analysis 'shall be attached to- the Waste Solidification Worksheet.

4~ Test Solidification As .required by Technical Specification Surveillance requirements 4.11.3 a test solidification of at least every tenth batch of each type of wet radioactive waste shall be performed. Whenever pretreatment of a batch is necessary the waste sample shall hive the required pretreatment accomplished prior to the test solidification. The appro-priate proportional amount of Portland cement and sodium metasilicate, as applicable, required by the Solidification Formula shall be used. Where practical, all chemicals used

, to condition or solidify waste or simulated waste in the solidification test shall be "identified to actual chemicals which are used in the full scale solidification. The

-chemical analysis required by this section, the amounts of cement, sodium metasilicate, and waste, and the percent of free liq'uid shall be recorded on the Test Solidification Worksheet. A copy of this worksheet shall be present with the Solidification System operator prior to solidification operation.

performing'aste If any'est solidification fai1s to verify solidification, solidification of the batch under test shall not be per-formed until such time as additional "test samples can be obtained, alternative solidification parameters can be determined and a subsequent test verifies solidification.

If the initial test sample from a batch .of waste fails'to verify solidification, then representative test samples shall be collected from each consecutive batch of the same type of waste until three consecutive test=specimens demon-strate solidification with le'ss thin or equal'to 0.5X 'free

'iquid.

activity waste, 4

For high where handling samples could result in personnel radiation exposures which are incon-sistent with ALARA principles, representative non-radioactive samples may be test solidified. These samples shall be. as close to the actual waste and chemical.,

properties as possible. For resins, the resi'n beads shall be depleted prior to test solidification.

, PLP-300, Rev. 0 Page 11 of 21'

1 Pre-Solidification I'.2.3 Sam lin and Testin Pro ram (continued)

Test solidification shall be done in accordance with Plant Procedure CRC-858 Test Solidification of waste.

5. Test Solidification Acce tabilit The test solidification will be considered acceptable if the test solidification, produces a free standing mass with the free liquid less than or equal to 0.5X by volume.

.If either or both of the above checks fail to meet the stated criteria, alternative solidification parameters must be'determined before solidification can proceed.

5.3 Pol er'Solidification 5.3.1 Solidification Formulas The- solidification of volume reduction system dry product is achieved by the use of a three component polymeric system developed by DOW

~

Chemical Company. It consists of a polymer binder, which is a modified vinyl ester resin, a promoter and a catalyst. Dry products are solidified by mixing with the polymer to acheive a homogeneous mixture.

Solidification formula,.for dry product waste is given in the Polymer Solidification System Operating Procedure, OP-120.05.04. The formula includes the required amount of binder, catalyst, promoter, and dry product. These values shall be recorded on the Solidification Worksheet. The formula is pre-tested in a solidification laboratory in order to verify the solidification results in a free-standing mass.

New solidification formulas may be developed and added to operating procedures. New formulas will be pre-tested to verify that solidi-fication results *in a free standing mass. New formulas or changes in formulation shall be reviewed by Operations Radwaste Engineering and approved by the Operations Manager.

5.3.2 Control of Process Parameters

1. Pol er Stora e Tem erature and A e

Temperature and'ge can affect the polymer by causing .

premature initiation of the polymerization reaction, although at a slow rate. Over time this may result in thickening of the polymer which may cause the amount of polymer added to the drum to be incorrect. Dow Binder has a recommended storage life of 6 to 12 months. To maximize PLP-300, Rev. 0 Page 12 of 21

Y'"

5.3.2 Control of Process Parameters (continued) this life the polymer is recirculated and air-sparged.

Polymer temperature is automatically controlled by recir-

"culating the polymer through a chiller package heat exchanger when temperature reaches 65'F. The promoter and catalyst have a storage life in excess of one year.

Manufacturers'emperature, storage and shelf life recom-mendations shall be observed or chemical integrity shall be verified by a lab scale solidification test without waste.

V

2. Com onent Pro ortions,

,.The solidification agent is a multicomponent polymer system consisting of a polymer binder, a promoter and a catalyst. Careful control of each of these components is required for proper solidification. The promoter controls how soon the solidification begins. If too much promoter is used, then the reaction begins before addition of the dry product is complete, whereas too little results in excessive curing times. The catalyst controls the rate of reaction. Too much catalyst results in excessively high rates which in turii leads to a build up of internal stress and ultimate m'echanical failure of the solidified product. Conversely, too little catalyst again results in excessive curing times. The quantity of polymer binder and promoter. is controlled by flow instrumentation. The catalyst comes in 'premeasured packets and is inserted by the operator. The amounts of polymer binder, promoter, and catalyst shall be recorded on the Solidification Worksheet.

3. Maxi.n The polymer solidification syst'm is designed with an in drum mixer that effectively coats the dry product with polymer and is a single-use item. The mixer is. placed in the drum by the operator at the Polymer Filling Station.

The polymer-promoter combination, the in-drum mixer, and the catalyst'ontainer should be placed in 'the drum in the appropriate sequence as described in the Polymer Solidi-fication System Operating Procedure. To maintain proper mixing speed, a speed indicator, system interlock and alarms are provided; Tem erature of Dr Product The curing of the polymer is an 'xo thermi c reac t ion . The react ion rat e is increased by heat and thus is self-accelerating . It is important to note that any source

~

of heat accelerates the reactant . Therefore , the incoming dry product must be maintained below a maximum temperature PLP-300, Rev. 0 Page 13 of 21

4 5.3.2 Control of Process Parameters (continued) of 130'F.'his I condition is monitored by the system and must be satisfied. for the drumming process to commence.

Temperature of dry product shall be recorded on the Solidi-fication Worksheet.

Dr Product Particle Size Distribution I'ecause mixing the dry product with polymer is actually a.

coating operation, the total surface area to be covered is a process parameter. The surface area to'be covered is a function of particle diameter which is controlled by the process parameters in the Fluid Bed Dryer. Bed temperature, feed pH and atomization air is carefully monitored and controlled to produce an acceptable product. These. system parameters are monitored and.

controlled in accordance with the Volume Redu'ction System Operating Procedure, OP-120.05.02.

\I

6. Dr Product Feed Rate Since the first step in the solidification sequence is

, actually a coating step, the rate at which the dry product is introduced into the drum containing the polymer must be controlled. The feed rate is automatically controlled by.

the Polymer Solidification System. V 7.'roduct-to-Pol er,.Ratio, The polymer .solidification system controls the ratio of to polymer at, approximately 2.5:1'y weight. dry'roduct Although it is possible-to exceed this ratio,'esting has shown that long term performance is reduced. Resistance'to leachability is a major long term performance goal of the solidified waste material. As the Product-to-Polymer ratio increases, the resistance to leachability is reduced; The ratio given above is a reasonable compromise between achieving adequate resistance to leaching and obtaining drum loadings that result in solidification economy for the particle size distribution. 1 ll

8. Contaminants Carbon in some forms interferes with polymer solidification process. Activated charcoal can be solidified'in concen-trations up to 2 percent by weight, however carbon will not be processed through the Volume Reduction System or, solidified by the Polymer Solidification System.

PLP-300; Rev. 0 Page 14of 21

5.3.2 Control of Process Parameters (continued)

\

9. 'xothermic Period Because of the chemistry involved in the polymerization

, process, it is possible to follow the course of the

'reaction by monitoring temperature as a function of time.,

During dry product addition there is only a moderate increase in the temperature of the-bulk material inside the drum. Because'the chemi'cal reac'tion is exothermic,. the

. temperature of the mixture in the drum increases., This reaction is self-accelerating until polymerization is complete. A rapid temperature increase is readily detectable and is a definite indication that polymerization is proceeding normally. This period of temperature rise is referred to as the exothermic period. and starts about 45 minutes after the catalyst release and lasts about 20 minutes. The beginning of this exothermic period has been defined to be the point at which the rate of temperature increase is equal to 1'F per minute. It should be noted that, given the chemistry of the reaction, there is virtually no other cause for such a rapid temperature increase except for polymerization. Verification of the onset of the exotherm periods(1'F/mi.n,temperature increase) shall be logged on the Sol'idification Worksheet.

5.3.3 Pre-Solidification Sam lin and Testin .Pro ram

~Sam lin Direct sampling of Volume Reduction Dry Product is not feasible due to- the nature of the product. Samples of liquid inputs .to the Vo'lume Reduction System will be taken and 'calculational methods will be used to determine concen-trations of radionuclides in the dry product.

2 ~ Chemical Anal sis of Waste Sam les Evaporator bottoms, chemical waste and decontamination

'olutions shall be analyzed for pH and adjusted between 10 and ll in the solidification pre-treatment tank as necessary.

3~ Radiochemical Anal sis of Waste'Sam les A gamma isotopic analysis shall be'performed on each batch of Volume Reduction feed. Calculational methods will be used to determine concentrations of radionuclides in the dry product and to determine proper waste classification. in accordance with-10CFR61 Waste Classification System. The results'of the gamma isotopic analysis and calculational results shall be attached to the Waste Solidification Worksheet.

PLP-300, Rev. 0 Page 15 of 21

5.3.3 Pre-Solidification Sam lin and Testin Pro ram (continued)'

4. Test SoLidification Since the Volume Reduction System Dry Product is not a wet waste no pre-solidification tests are required by Technical Specification Surveillance requirement 4;11.3. Test solidification without waste shall be performed to verify chemical integrity if manufactuiers'emperature, storage o'r shelf life recommendations are not met.

5.4 10CFR61 Im lementation Solidified radioactive waste generated at Shearon Harris Nuclear Power Plant shall meet the requirements of Title 10 Code of Federal Regulations Part 61.

5.4.1 Waste Classification 10CFR61.55 For wet waste streams, waste classification shall be based upon isotopic analysis and the use of scaling factors for hard to measure isotopes. For dry product isotopic anaLysis of feed streams to the Volume Reduction'System, scaling factors for hard to measure isotopes,'and calculational methods shall be used to determine con-centrations of radionuclides in the dry product and provide the appropriate waste classification'.,

Initially generic scaling factors will be used for waste classifi-cation. Each waste stream shall be sampled after the first three months of commercial operation and on an annual basis thereafter.

These samples are analyzed by a commercial Laboratory to confirm the continued validity of the scaling factors. Calculational methods will be updated, as required, based on the results of these samples.

A computerized waste classification and'hipping program, WASTETRAK, is normally used to determine waste classification from isotopic analysis and scaling factors. Manual methods may be used if the computer system is not available.. Waste Classification is controlled by plant procedure HPP-115, Classification of Radioactive Waste for Shipment.

5.4.2 Waste Characteristics .LOCFR61.56 Waste Characterization requirements'is demonstrated .by a combination

,. of the methodology stated in this'rocess Control Program, Plant Procedures, and Waste Form Stability Testing Programs performed .by Stock Equipment Company and Dow Chemical Company.

PLP-300, Rev. 0 Page 16 of 21

5.4.2 Waste Characteristics-10CFR61.56 (continued)

Minimum Characterization Re uirements Waste at Shearon Harris Nuclear Power Plant. is normally packaged in 55 gallon drums. In no case shall, waste be packaged in cardboard or fiberboard boxes.

Liquid waste streams're solidified by the solidifica'tion system or by a solidification vendor in accordance with a qualified Process Control Program. For dry active waste absorbent,.material is added to absorb any unintentional liquids. The pre-solidification testing program and use of the process control 'program provides reasonable assurance that liquids do not exceed 1/ of the volume.

For any package containing water and/or organic substances in concentrations exceeding'Type A quantity that could radiolytically generate combustible gases, a determination by calculations, test, or measurements shall be performed to ensure that hydrogen generated is limited to a molar quantity that would be no more than 5% by volume or,the-equivalent limits for other inflammable gases, of the secondary container gas void at STP over, a period of time that is twice the expected shipment time. or the cask cavity will be inerted. For any package containing materials with radioactivity concentrations'ot exceeding 'Type A quantity this determination is not required; Experience has demonstrated utility waste streams do not contain or generate toxic gases, vapors 'or fumes and do not contain hazardous, biological, pathogenic or infectious materials.

2 ~ Waste Stabilit Waste stability testing .results for the Stock Cement Solidification System are contained in Stock Equipment Company Topical Report, "Waste Solidification Process For Low-Level Radioactive Waste.": The data presented in the report demonstrates that generic waste streams and s'imilar waste streams'of lower concentrations, solidified using'he Stock Waste Solidification Process, produce products which with existing stability regulations. 'omply Waste stability testing results for the Dow Waste

,Solidification -Process are contained in the. Topical Report, "The Dow Waste Solidification Process For Low Level Radioactive Waste Generic Waste Form Certification Results." The data presented,'in this report demonstrates that Volume reduction dry product solidified with the Dow Waste Solidification Process produces products which comply with existing stability regulations.

/

PLP-300, Rev. 0 Page 17 of 21

5,.4.2 Waste Characteristics 10CFR61.56 (continued)

Control parameters and limits established by these topical reports are, controlled by the PCP and the solidification formulas used in the system operating procedures.

Plant procedures ensure<<that all reasonable efforts are made to eliminate unnecessary voi'd spaces within the waste packages. 'owever, to ensure production of a stable waste form, void spaces are left within each contai'ner. Such void spaces are necessary to allow for proper mixing of the solidification medium. Therefore, processing does not eliminate void. spaces to the extent that the ability to produce a stable waste form is compromised.

5.4.3 ~Labels Each package of waste shall be, clearly labeled to'dentify waste classification in accordance with the appropriate shipping procedures in Table 6.1.

5.5 '10CFR20.311 .Im lementation

'I Solidified radioactive waste transferred for disposal by Shearon Harris Nuclear Power Plant shaLL meet -the requirements of Title 10 Code of Federal Regulations Part 20.311.

5.5.1 Shi ment Manifests The requirements of 10CFR20.311 for shipment manifest and record keeping are included in the appropriate shipping procedures in Table 6.1.

5.5.2 ualit Control Pro ram The quality control program consists of required'se of plant pro-cedures which implement the Process Control Program and requirements of Chapter 22 of the Carolina Power'nd Light Company, Corporate Quality Assurance Program, Radwaste Shipping QA Program. Audits by personnel'ndependent of the activities are performed and reviewed, by appropriate management personnel.

In addition, the Process Control Program and implementing procedures for solidification of radioactive waste is audited once per 24 months by the Quality Assurance Services Section in accordance with Plant Technical Specifi'cation 6.5.5.1.

6.0 . FIGURES TABLES ATTACHMENTS 6.1 Process Control .Program Implementing Procedures 6.2 Shearon.Harris Nuclear Po'wer Plant Radioactive Waste Streams 6.3 Waste Stream, Sample Poin'ts PLP-300, Rev. 0 Page 18 of 21

4 C

Table 6.1 Process Control Pro ram Im lementin Procedures

l. OP-120;05.01 Solidification Pretreatment Operating lt Procedure 2 ~ OP-"120.05.02 Volume Reduction System Operating Procedure 3~ OP-120.05.03 ~

Cement Solidification System Operating Procedure

4. OP-120.05.04 Polymer. Solidification System Operating Procedure

5. CRC 858 Test, Solidification of. Waste

6. HPP-103 Curie Determination of R.A.M.

7. HPP-111 Packaging of Compactable Waste

8. HPP-115 Classification of Radioactive Material for Shipment 9~ 'HPP-117 WASTRACK. Operation

10. HPP-123 Shipment of LSA-Type A to Barnwell, S.C.

4

11. -HPP-124 Shipment of LSA-Type B to Barnwell, S.C.

12. HPP-125 Shipment of Type A to Barnwell, S.C.

13. HPP-126 Shipment of Type B "to Barnwell, S.C.

14. HPP-127 Shipment of HWY RT Cont to Barnwell, S.C.

15. HPP-128 Shipment of LSA-Type A to Richland, WA.

PLP-300, Rev. 0 Page 19 of 21

Table 6.2 Shearon Harris Nuclear Power Plant Radioactive Waste Streams Solidification

, Waste Stream Source S stem

~

1. Mixed Bed Bead CVCS Letdown Demineralizers Resin (Borated) Boron Recycle Evap. Feed Demineralizers Cement

2. Cation Bead CVCS Letdown Cation Demineralizer Cement Resin (Borated)

3. Anion Bead Boron Thermal Regeneration Demineralizer Cement Resin (Borated)

4. Mixed Bed Bead Fuel Pool Cooling and Cleanup Demineralizer Resin Laundry & Hot Shower Demineralizer Cement'.

Secondary Waste Demineralizer Boron Recycle Evap. Condensate Demineralizer Waste Evaporator Condensate Demineralizer Condensate Demineralizer Cation Bed Waste Monitor Ta'nk Demineralizer Cement Resin II. Eva orator Bottoms

1. Sodium Sulfate Secondary Waste Evaporators Cement'ement 2 ~ Boric Acid Boron Recycle Evaporator Waste Evaporator

3. R.O. Concentrates R.O. Concentrates Evaporator Cement Filter Particulates Concentrates Cement IV. Misc. Chemical Solutions Chemistry Lab Drains Cement V. Volume. Reduction Evaporator Bottoms Polymer Product Chemical Lab Drains Decontamination Solutions VI. Oils Maintenance, Oil Spills, etc. Contractor VII. Dr Active Waste

1. Compactable Paper, rags, trash, etc. Compactor

2. Non-compactable Piping, valves, tubing, etc. Packaged in appropriate DOT package PLP-300, Rev. 0 Page 20 of 21

Table 6.3 Waste .Streams Sam le Points Tank Secondary Waste Evaporator Concentrates'ank 162 Sink 8, Point WL-ll Secondary Waste Evaporator Concentrates Tank 364 Sink 8; Point WL-12 Waste Evaporator Concentrates- Tank Sink 1, Point WL-4 Filter Particulate Concentrates Tank Sink 1, Point WL-5 Chemical Drain Tank 162 Sink 2, Point WL-13 Chemical Drain Tank 364 Sink 4, Point WL-26 Solidification Pretreatment a

Tank 1-4A Sink 9, Point WL-78 Solidification Pretreatment Tank 1-4B Sink 9, Point WL-79 I

Decant Tank A&B Local Dry Active Waste (DAW) Surface Contamin-j ation smears from representative plant locations PLP-300," Rev. 0 FINAL'AGE Page 21 of 21

C Cj h