Latest revision as of 03:51, 20 June 2019

Text

to EN-RW-105, Process Control Program.
	ML16132A507
Person / Time
Site:	Waterford
Issue date:	08/27/2015
From:	Marvel D; Entergy Operations
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16132A496	List: ML16132A494; ML16132A506; ML16132A507; ML16132A508; ML16132A509; ML16132A510; W3F1-2016-0038, UNT-005-014, Rev. 306, Offsite Dose Calculation Manual.;
References
	W3F1-2016-0038 EN-RW-105, Rev 5
	Download: ML16132A507 (21)
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NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 1 OF 21PROCESS CONTROL PROGRAMProcedure Contains NMM ECH eB REFLIB Forms:

YES NOProcedure Revision Type: NewNON-EditorialEditorial TCCancellationHQN EffectiveDateProcedure Owner:Title: Site:Donnie MarvelManager, RP ANOGovernance Owner:Title: Site:Reid TagliamonteManager, Fleet RPHQN8/27/15 SiteSite Procedure ChampionTitle ANODonnie MarvelManager, RP BRPN/AN/A CNSChris SundermanManager, RPGGNSRoy MillerManager, RP IPECFrank MitchellManager, RP JAFRobert HeathManager, RP PLPDavid NestleManager, RP PNPSAlan ZelieManager, RP RBSShannon PeterkinManager, RP W3Daniel FreyManager, RPHQNReid TagliamonteManager, Fleet RPFor site implementation dates see ECH eB REFLIB using site tree view (Navigation panel).Site and NMM Procedures Canceled or Superseded By This Revision NoneProcess Applicability Exclusion:All Sites:Specific Sites: ANO BRP CNS GGNS IPEC JAF PLP PNPS RBS W3Change StatementThe primary purpose of this revision is to incorporate GGNS Temp Change in response toCR-GGN-2015-1277. Specifically: Step 5.1[1](b) added the words "owned by Entergy" Added new step 5.9[2] (same as step 5.1[1](b))Other changes: Removed VY from coversheet and deleted step 5.8[4](e) as fleet procedures no longer apply to VY. Reformatted table in section 8 for compliance with EN-AD-101-01, updated the table and deleted VYentries from the table. Updated cross references to section 8 within the body of the procedure. Deleted reference to VY commitments from step 5.8[3]Associated PRHQN #:

2015-00273Procedure Writer:Ron SchwartzContains Proprietary Information:

YES NO NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 2 OF 21PROCESS CONTROL PROGRAM__________________________________________________________________________TABLE OF CONTENTSSection Title Page1.0PURPOSE ................................................................................

32.0REFERENCES

......................................................................... 33.0DEFINITIONS ........................................................................... 64.0RESPONSIBILITIES ................................................................. 95.0DETAILS ................................................................................ 106.0INTERFACES ......................................................................... 207.0RECORDS ............................................................................. 208.0SITESPECIFICCOMMITMENTS ........................................... 219.0ATTACHMENTS ..................................................................... 21__________________________________________________________________________

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 3 OF 21PROCESS CONTROL PROGRAM1.0 PURPOSEThe Process Control Program (PCP) requires formulas, sampling, analyses, test anddeterminations to be made to ensure that the processing and packing of solidradioactive wastes based on demonstrated processing of actual or simulated wet solidwastes will be accomplished in such a way as to assure compliance with 10 CFR Parts20, 61 and 71, State Regulations, burial ground requirements, and other requirementsgoverning the disposal of solid radioactive waste. The scope of a PCP is to assurethat radioactive waste will be handled, shipped, and disposed of in a safe manner inaccordance with approved site or vendor procedures, whichever is applicable.[GGNSUFSAR, Chapter 16B.1 / TRM - 7.6.3.8 paragraph 1]1.1 The purpose of this document is to provide a description of the solid radioactivewaste Process Control Program (PCP) at all the Entergy fleet sites. The PCPdescribes the methods used for processing, classification and packaging low-levelwet radioactive waste into a form acceptable for interim on-site storage, shippingand disposal, in accordance with 10 CFR Part 61 and current disposal site criteria.1.2 To ensure the safe operation of the solid radwaste system, the solid radwastesystem will be used in accordance with this Process Control Program to processradioactive wastes to meet interim on-site storage, shipping and burial groundrequirements.1.3 This document addresses the process control program in the context of disposalcriteria, on-site processing and vendor processing requirements.1.4 The Process Control Program implements the requirements of 10CFR50.36a andGeneral Design Criteria 60 of Appendix A to 10CFR Part 50. The processparameters included in the Process Control Program may include but are notlimited to waste type, waste pH, waste/liquid/solidification agent/catalyst ratios,waste oil content, waste principal chemical constituents, and mixing and curingtimes.1.5 This document does NOT address the requirements for 10CFR Part 61.56 (wastecharacteristics) for material sent to intermediate processors, because the finaltreatment and packaging is performed at the vendor facilities.

2.0 REFERENCES

[1]EN-QV-104, "Entergy Quality Assurance Program Manual Control"

[2]Title 49, Code of Federal Regulations

[3]Title 10, Code of Federal Regulations, Part 20 NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 4 OF 21PROCESS CONTROL PROGRAM2.0 continued

[4]Title 10, Code of Federal Regulations, Part 61

[5]Title 10, Code of Federal Regulations, Part 71, Appendix H[QAPM, Section A.1.c]

[6]Low-Level Waste Licensing Branch Technical Position on Radioactive WasteClassification, 11 May 1983

[7]Disposal Site Criteria and License

[8]Waste Processor Acceptance Criteria

[9]EN-LI-100, "Process Applicability Determination"[10] NRC Information and Enforcement Bulletins NRC Information Notice 79-19: Packaging of Low-Level Radioactive Waste forTransport and Burial. NRC Information Notice 80-24: Low-Level Radioactive Waste Burial Criteria. NRC Information Notice 80-32: Clarification of Certain Requirements for Exclusive-Use Shipments of Radioactive Materials. NRC Information Notice 80-32, Rev. 1: Clarification of Certain Requirements forExclusive-Use Shipments of Radioactive Materials. NRC Information Notice 83-05: Obtaining Approval for Disposing of Very-Low-LevelRadioactive Waste - 10CFR Section 20.302. NRC Information Notice 83-10: Clarification of Several Aspects Relating to Use ofNRC-Certified Transport Packages. NRC Information Notice 83-33: Non-Representative Sampling of Contaminated Oil. NRC Information Notice 84-50: Clarification of Scope of Quality AssurancePrograms for Transport Packages Pursuant to 10CFR 50 Appendix B. NRC Information Notice 84-72: Clarification of Conditions for Waste ShipmentsSubject to Hydrogen Gas Generation. NRC Information Notice 85-92: Surveys of Wastes Before Disposal from NuclearReactor Facilities. NRC Information Notice 86-20: Low-Level Radioactive Waste Scaling Factors, 10CFR 61. NRC Information Notice 86-90: Requests to Dispose of Very Low-Level RadioactiveWaste Pursuant 10CFR 20.302 NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 5 OF 21PROCESS CONTROL PROGRAM2.0[10], continued NRC Information Notice 87-03: Segregation of Hazardous and Low-LevelRadioactive Wastes NRC Information Notice 87-07: Quality Control of On-Site Dewatering/ SolidificationOperations by Outside Contractors[11] NRC Information and Enforcement Bulletins (continued) NRC Information Notice 89-27: Limitations on the Use of Waste Forms and HighIntegrity Containers for the Disposal of Low-Level Radioactive Waste NRC Information Notice 92-62: Emergency Response Information Requirements forRadioactive Material Shipments NRC Information Notice 92-72: Employee Training and Shipper RegistrationRequirements for Transporting Radioactive Materials NRC Generic Letter 89-01, "Implementation of Programmatic Controls forRadiological Effluent Technical Specifications in the Administrative Controls Sectionof the Technical Specifications and the Relocation of Procedural Details of RETS tothe Offsite Dose Calculation Manual or to the Process Control Program".[12] Nureg-0800 Standard Review Plan Section 11.4 Revision 2, Solid WasteManagement Systems.[13] NRC Waste Form Technical Position, Revision 1 Jan 24 1991.[14] NRC SECY 94-198 Review of Existing Guidance Concerning the Extended Storage ofLow-Level Radioactive Waste.[15] EPRI TR-106925 Rev-1, Interim On-Site Storage of Low Level Waste: Guidelines forExtended Storage - October1996[16] NRC Branch Technical Position On Concentration Averaging And Encapsulation Jan 17 1995[17] Commitment Documents (U-2 and U-3) IPN-99-079, "Supplement to Proposed Changes to Technical SpecificationsIncorporating Recommendations of Generic Letter 89-01 and the Revised 10 CFRPart 20 and 10 CFR Part 50.36a. Appendix B Technical Specifications, Section 4.5[IP, RECS ODCM Part 1]

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 6 OF 21PROCESS CONTROL PROGRAM3.0 DEFINITIONS

[1]Batch - A quantity of waste to be processed having essentially consistent physicaland chemical characteristics as determined through past experience or systemoperation knowledge by the Radwaste Shipping Specialist. A batch could be a wastetank, several waste tanks grouped together or a designated time period such asbetween outages as with the DAW waste stream. An isolated quantity of feed wasteto be processed having essentially constant physical and chemical characteristics.(The addition or removal of water will not be considered to create a new batch).

[2]Certificate of Compliance - Document issued by the USNRC regulating use of aNRC licensed cask or issued by (SCDHEC) South Carolina Department of Health andEnvironmental Conservation regulating a High Integrity Container.

[3]Chelating Agents - EDTA, DTPA, hydroxy-carboxylic acids, citric acid, carbolic acidand glucinic acid.

[4]Compaction - The process of volume reducing solid waste by applying externalpressure.[5]Confirmatory Analysis - The practice of verifying that gross radioactivitymeasurements using MCA are reasonably consistent with independent laboratorysample data.

[6]Dewatered Waste - Wet waste that has been processed by means other thansolidification, encapsulation, or absorption to meet the free standing liquidrequirements of 10CFR Part 61.56 (a)(3) and (b)(2).

[7]De-watering - The removal of water or liquid from a waste form, usually by gravity orpumping.[8]Dilution Factor - The RADMAN computer code factor to account for the non-radioactive binder added to the waste stream in the final product when waste issolidified.

[9]Dry Waste - Radioactive waste which exist primarily in a non-liquid form and includessuch items as dry materials, metals, resins, filter media and sludges.

[10]Encapsulation - Encapsulation is a means of providing stability for certain types ofwaste by surrounding the waste by an appropriate encapsulation media.

[11]Gamma-Spectral-Analysis - Also known as IG, MCA, Ge/Li and gammaspectroscopy.

[12]Gross Radioactivity Measurements - More commonly known as dose to curieconversion for packaged waste characterization and classification.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 7 OF 21PROCESS CONTROL PROGRAM3.0 continued

[13]Homogeneous - Of the same kind or nature; essentially alike. Most Volumetric wastestreams are considered homogeneous for purposes of waste classification.

[14]Incineration - The process of burning a combustible material to reduce its volumeand yield an ash residue.

[15]Liquid Waste - Radioactive waste that exist primarily in a liquid form and is containedin other than installed plant systems, to include such items as oil, EHC fluid, and otherliquids. This waste is normally processed off-site.

[16]Low-Level Radioactive Waste (LLW) - Those wastes containing source, specialnuclear, or by-product material that are acceptable for disposal in a land disposalfacility. For the purposes of this definition, low-level radioactive waste has the samemeaning as in the Low-Level Waste Policy Act, that is, radioactive waste not classifiedas high-level radioactive waste, transuranic waste, spent nuclear fuel, or by-productmaterial as defined in section 11e.(2) of the Atomic Energy Act (uranium or thoriumtailings and waste).

[17]Measurement of Specific Radionuclides - More commonly known as direct sampleor container sample using MCA data for packaged waste characterization andclassification.

[18]Operable - A system, subsystem, train, component or device SHALL be OPERABLEor have OPERABILITY when it is capable of performing its specified functions(s), andwhen all necessary attendant instrumentation, controls, electrical power, cooling orseal water, lubrication or other auxiliary equipment that are required for the system,subsystem, train, component, or device to perform its function(s) are also capable ofperforming their related support function(s).

[19]Prequalification Program - The testing program implemented to demonstrate that theproposed method of wet waste processing will result in a waste form acceptable to theland disposal facility and the NRC.

[20]Processing - Changing, modifying, and/or packaging radioactive waste into a formthat is acceptable to a disposal facility.

[21]Quality Assurance/Quality Control - As used in this document, "quality assurance"comprises all those planned and systematic actions necessary to provide adequateconfidence that a structure, system, or component will perform satisfactorily in service.Quality assurance includes quality control, which comprises those quality assuranceactions related to the physical characteristics of a material structure, component, orsystem to predetermined requirements.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 8 OF 21PROCESS CONTROL PROGRAM3.0, continued

[22]Reportable Quantity Radionuclides (RQ) - Any radionuclide listed in column (1) ofTable 2 of 49CFR Part 172.101 which is present in quantities as listed in column (3) ofTable 2 of 49CFR Part 172.101.

[23]Sampling Plan - A program to ensure that representative samples from the feedwaste and the final waste form are obtained and tested for conformance withparameters stated in the PCP and waste form acceptance criteria.

[24]Scaling Factor - A dimensionless number which relates the concentration of an easyto measure radionuclide (gamma emitter) to one which is difficult to measure (betaand/or alpha emitters).

[25]Significant Quantity - For purposes of waste classification all the followingradionuclide values SHALL be considered significant and must be reported on thedisposal manifest. Any value (real or LLD) for radionuclides listed in Appendix G to 10CFR20 (H-3,C-14, I-129, Tc-99). Greater than or equal to 1 percent of the concentration limits as listed in 10CFR Part 61.55 Table 1. Greater than or equal to 1 percent of the Class A concentration limits listed in10CFR Part 61.55 Table 2. Greater than or equal to 1 percent of the total activity. Greater than or equal to 1 percent of the Reportable Quantity limits listed on49CFR Part 172.101 Table 2.

[26]Solidification - The conversion of wet waste into a free-standing monolith by theaddition of an agent so that the waste meets the stability and free-standing liquidrequirements of the disposal site.

[27]Special Radionuclides - The RADMAN computer code term for radionuclides listed inAppendix G to 10CFR20 (i.e., H-3, C-14, I-129 & Tc-99)

[28]Stability - Structural stability per 10CFR61.2, Waste Form Technical Position, andWaste Form Technical Position Revision 1. This can be provided by the waste form, orby placing the waste in a disposal container or structure that provides stability afterdisposal. Stability requires that the waste form maintain its structural integrity underthe expected disposal conditions.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 9 OF 21PROCESS CONTROL PROGRAM3.0, continued

[29]Training - A systematic program that ensures a person has knowledge of hazardousmaterials and hazardous materials regulations.

[30]Type A Package - Is the packaging together with its radioactive contents limited to A1or A2 as appropriate that meets the requirements of 49CFR Part 173.410 and Part173.412, and is designed to retain the integrity of containment and shielding undernormal conditions of transport as demonstrated by the tests set forth in 49CFR Part173.465 or Part 173.466 as appropriate.

[31]Type B Package - Is the packaging together with its radioactive contents that isdesigned to retain the integrity of containment and shielding when subjected to thenormal conditions of transport and hypothetical accident test conditions set forth in10CFR Part 71.

[32]Volume Reduction - any process that reduces the volume of waste. This includesbut is not limited to, compaction and incineration.

[33]Waste Container - A vessel of any shape, size, and composition used to contain thewaste media.

[34]Waste Form - Waste in a waste container acceptable for disposal at a licenseddisposal facility.

[35]Waste Stream - A Plant specific and constant source of waste with a distinctradionuclide content and distribution.

[36]Waste Type - A single packaging configuration and waste form tied to a specificwaste stream.4.0 RESPONSIBILITIES

[1]TheVice President Operations Support (VPOS) is responsible for theimplementation of this procedure.

[2]Each siteSenior Nuclear Executive (SNE) is responsible for ensuring that necessarysite staff implements this procedure.

[3]TheLow Level RadWaste (LLRW) Focus Group is responsible for evaluating andrecommending changes and revisions to this procedure.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 10 OF 21PROCESS CONTROL PROGRAM4.0, continued

[4]Each siteRP Department - Radwaste Supervisor / Specialist (title may vary at thesite's respectively) has the overall responsibility for implementing the PCP and isresponsible for processing and transportation is tasked with the day-to-dayresponsibilities for the following: Implementing the requirements of this document. Ensuring that radioactive waste is characterized and classified in accordance with10CFR Part 61.55 and Part 61.56. Ensuring that radioactive waste is characterized and classified in accordance withvolume reduction facility and disposal site licenses and other requirements. Designating other approved procedures (if required) to be implemented in thepackaging of any specific batch of waste. Providing a designated regulatory point of contact between the Plant and theNRC, volume reduction facility or disposal site. Maintaining records of on-site and off-site waste stream sample analysis andPlant evaluations. Suspending shipments of defectively processed or defectively packagedradioactive wastes from the site when the provisions of this process controlprogram are not satisfied.5.0 DETAILSAn isotopic analysis SHALL be performed on every batch for each waste stream sothat the waste can be classified in accordance with 10CFR61. The isotopic and curiecontent of each shipping container SHALL be determined in accordance with 49CFRpackaging requirements. The total activity in the container may be determined byeither isotopic analysis or by dose-rate-to-curie conversion.5.1. Precautions and Limitations

[1]Precautions(a) Radioactive materials SHALL be handled in accordance with applicable radiationprotection procedures.(b) All radioactive waste owned by Entergy processed on-site OR off-site byvendors must be processed or packaged to meet the minimum requirementslisted in 10CFR Part 61.56 (a) (1) through (8).

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 11 OF 21PROCESS CONTROL PROGRAM5.1[1], continued(c) If the provisions of the Process Control Program are not satisfied, suspendshipment of the defectively processed or defectively packaged waste from thesite. Shipment may be accomplished when the waste is processed / packagedin accordance with the Process Control Program.(d) The generation of combustible gases is dependent on the waste form,radioactive concentration and accumulated dose in the waste. Changes toorganic inputs (e.g. oil) to waste stream may change biogas generation rates.

[2]Limitations(a) Only qualified personnel will characterize OR package radioactive waste ORradioactive materials for transportation or disposal.(b) All site personnel that have any involvement with radioactive waste managementcomputer software SHALL be familiar with its functions, operation andmaintenance.5.2. Waste Management Practices

[1]Waste processing methods include the following: (a)Present and planned practice is NOT to solidify or encapsulate any waste streams.(b)Waste being shipped directly for burial in a HIC (High Integrity Container) isdewatered to less than 1 percent by volume prior to shipment.(c)Waste being shipped directly for burial in a container other than a HIC is dewateredto less than 0.5 percent by volume prior to shipment.(d)IF solidification is required in the future, THEN at least one representative testspecimen from at least every 10th batch of each type of radioactive waste will bechecked to verify solidification.

(1)IF any specimen fails to verify solidification, THEN the solidificationof the batch under test SHALL be suspended until such time asadditional test specimens can be obtained, alternative solidificationparameters can be determined, and a subsequent test verifiessolidification. If alternative parameters are determined, thesubsequent tests shall be verified using the alternative parametersdetermined.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 12 OF 21PROCESS CONTROL PROGRAM5.2[1](d), continued (2)IF the initial test specimen from a batch of waste fails to verifysolidification, THEN provide for the collection and testing ofrepresentative test specimens from each consecutive batch of thesame type of waste until at least 3 consecutive initial test specimensdemonstrates solidification. The process SHALL be modified asrequired to assure solidification of subsequent batches of waste.

[2]Operation and maintenance of dewatering systems and equipment include the following: (a)Present and planned practice is to utilize plant personnel supplemented by vendorpersonnel or contracted vendor personnel, to operate AND maintain dewateringsystems and equipment (as needed to meet disposal site requirements).(b)All disposal liners are manufactured by and purchased from QA-approved vendors.

[3]ALARA considerations are addressed in all phases of the processes involving handling,packaging AND transfer of any type OR form of radioactive waste (dewatered or dry).Resin, charcoal media, spent filter cartridges AND sludges are typically processed withinshields. Sluiceable demineralizers are shielded when in service. Radiation exposure andother health physics requirements are controlled by the issuance of a Radiation WorkPermit (RWP) for each task.5.3. Waste Stream Sampling Methods and Frequency

[1]The following general requirements apply to Plant waste stream sampling:(a) Treat each waste stream separately for classification purposes.(b) Ensure samples are representative of or can be correlated to the final wasteform.(c) Determine the density for each new waste stream initially or as needed (notapplicable for DAW and filters).(d) Perform an in-house analysis for gamma-emitting radionuclides for eachsample sent to an independent laboratory.(e) Periodically perform in-house analysis for gamma emitting radionuclides forcomparison to the current data base values for gamma emitters. (The currentdatabase is usually based on the most recent independent laboratory results.)(f)Resolve any discrepancies between in-house results AND the independentlaboratory results for the same or replicate sample as soon as possible.(g) Maintain records of on-site and off-site waste stream sample analysis andevaluations.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 13 OF 21PROCESS CONTROL PROGRAM5.3, continued

[2]When required, waste stream samples should be analyzed, re-evaluated and ifnecessary, shipped to a vendor laboratory for additional analysis. The same is truewhen there is a reason to believe that an equipment or process change hassignificantly altered the previously determined scaling factors by a factor of 10.Specific examples include but are not limited to: Changes in oxidation reduction methods such as zinc, injection,hydrogen water chemistry, Changes in purification methods including media specialization, mediadistribution, ion/cation ratios, Changes in fuel performance criteria including fuel leaks Other changes in reactor coolant chemistry. Sustained, unexplained, changes in the routinely monitored Beta/Alpharatios, as determined by Radiation Protection, When there is an extended reactor shutdown (> 90 days). When there are changes to liquid waste processing, such as bypassingfilters, utilizing filters or a change in ion exchange media. When there are changes to the waste stream that could change the biogasgeneration rate.

[3]The following requirements apply to infrequent or abnormal waste types:(a) Infrequent OR abnormal waste types that may be generated must be evaluatedon a case-by-case basis.(b) The RP Department Supervisor / Specialist responsible for processing ANDshipping will determine if the waste can be correlated to an existing wastestream.(c) IF the radioactive waste cannot be correlated to an existing waste stream,THEN the RP Department Supervisor / Specialist responsible for processingand shipping SHALL determine specific off-site sampling and analysisrequirements necessary to properly classify the material.

[4]Specific sampling methods and data evaluation criteria are detailed in EN-RW-104 forspecific waste streams.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 14 OF 21PROCESS CONTROL PROGRAM5.4. Waste Classification

[1]General requirements for scaling factors include the following:(a) The Plant has established an inferential measurement program wherebyconcentrations of radionuclides which cannot be readily measured are estimatedthrough ratio-ing with radionuclides which can be readily measured.(b) Scaling factor relationships are developed on a waste stream-specific basis.These relationships are periodically revised to reflect current independent lab datafrom direct measurement of samples. The scaling factor relationships currentlyused by the sites are as follows: Hard to detect ACTIVATION product radionuclides and C-14 are estimated byusing scaling factors with measured Co-60 activities. Hard to detect FISSION product radionuclides and H-3, Tc-99 and I-129 areestimated by using scaling factors with measured Cs-137 activities. Hard to detect TRANSURANIC radionuclides are estimated by usingscaling factors with measured Ce-144 activities. Where Ce-144 cannot bereadily measured, transuranics are estimated by using scaling factors withmeasured Cs-137 activities. Second order scaling of transuranics isacceptable when Cs-137 and Ce-144 are not readily measurable.

[2]General requirements for the determination of total activity and radionuclideconcentrations include the following:(a) The activity for the waste streams is estimated by using either GrossRadioactivity Measurement OR Direct Measurement of Radionuclides. Currentspecific practices are as follows: DAW - Gross radioactivity measurement in conjunction with the RADMANcomputer codes, other approved computer codes or hand calculation. Filters - Gross radioactivity measurement in conjunction with the FILTRKcomputer code, other approved computer codes or hand calculation. All Other Waste Streams - Direct measurement of radionuclides inconjunction with the RADMAN computer codes, other approved computercodes or hand calculation.(b) Determination of the NRC waste classification is performed by comparing themeasured or calculated concentrations of significant radionuclides in the finalwaste form to those listed in 10CFR Part 61.55.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 15 OF 21PROCESS CONTROL PROGRAM5.5. Quality Control

[1]The RADMAN computer code provides a mechanism to assist the Plant in conductinga quality control program in accordance with the waste classification requirementslisted in 10CFR Part 61.55. All waste stream sample data changes are written to acomputer data file for future review and reference.

[2]Audits and Management Review includes the following:(a) Appendix G to 10CFR20 requires conduct of a QC program which must includemanagement review of audits.(b) Management audits of the Plant Sampling and Classification Program SHALLbe periodically performed to verify the adequacy of maintenance sampling andanalysis.(c) Audits and assessments are performed and documented by any of the following:Radiation Protection DepartmentQuality Assurance DepartmentQualified Vendors(d) Certain elements of the Entergy Quality Assurance Program Manual are appliedto the Process Control Program.[QAPM, Section A.1.c]5.6. Dewatering Operations

[1]Processing requirements during dewatering operations include the following:(a) All dewatering operations are performed per approved Plant or vendor operatingprocedures and instructions.(b) Dewatering limitations and capabilities are verified by vendor Topical Reports orOperating and Testing Procedures.

[2]Dewatered resin activity limitations include the following:(a) Dewatered resins will not be shipped off-site that have activities which willproduce greater than 1.0E+8 rads total accumulated dose over 300 years. Thisis usually verified by comparing the container specific activity at the time ofshipment to the following concentration limits for radionuclides with a half-lifegreater than five years: 10 Ci (0.37 TBq) per cubic foot. 350 uCi (12.95 MBq) per cubic centimeter NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 16 OF 21PROCESS CONTROL PROGRAM5.7. Waste PackagingWaste in final form will be packaged in accordance with Title 10 and Title 49 of theCode of federal regulations and in accordance with current burial site criteria as isdetailed in EN-RW-102.5.8. Administrative Controls

[1]Information on solid radioactive waste shipped off-site is reported annually to theNuclear Regulatory Commission in the Annual Radioactive Effluent Release Report asspecified by the Offsite Dose Calculation Manual (ODCM) or Technical Specification.[ANO1 Technical Specifications - 5.6.3] [ANO2 Technical Specifications - 6.6.3] [WF3 TechnicalSpecifications - 6.9.18] [GGNS ODCM - 5.6.3.c] [JAF Technical Specifications - 5.6.3] [JAF ODCM6.2.1] [PLP ODCM, Appendix A - IV. A].

[2]All changes to the PCP SHALL be documented. All records of reviews performedSHALL be retained as required by the Quality Assurance Program. Thedocumentation of the changes SHALL[GGNS UFSAR, Chapter 16B.1 / TRM - 7.6.3.8paragraph 2]:(a) Contain sufficient information to support the change with appropriate analyses orevaluations justifying the change.(b) Include a determination that the change will maintain the overall conformance ofthe solidified waste product (if applicable) to existing requirements of Federal,State or other applicable regulations.

[3]All changes in the Process Control Program and supporting documentation areincluded in each site's next Annual Radiological Effluent Release Report to theNuclear Regulatory Commission.[ANO ODCM - L3.2.1.C] [RBS Technical Requirements5.5.14.1][4]The changes to EN-RW-105 SHALL become effective upon review and acceptance bythe site's General Plant Manager (equivalent title at Palisades is Plant Superintendent)except as listed below:[PLP Technical Specifications 5.5.15](a) For Grand Gulf Nuclear Station, the changes to RW-105 SHALL beaccomplished as specified in Grand Gulf Nuclear Station TechnicalRequirements Manual (TRM) Section 7.6.3.8. The changes SHALL becomeeffective upon review and acceptance by the On-site Safety Review Committee (OSRC)AND the approval of the GGNS Plant General Manager. [GGNS UFSAR,Chapter 16B.1 / TRM - 7.6.3.8 paragraph 2]

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 17 OF 21PROCESS CONTROL PROGRAM5.8[4], continued(b) For River Bend Nuclear Station, the procedure approval along with changes toRW-105 SHALL be accomplished per the River Bend Nuclear Station TechnicalRequirements, Section 5.5.14.1. The changes SHALL become effective uponreview and acceptance by approval from the River Bend Nuclear Station PlantManager or Radiation Protection Manager.[RBS Technical Requirements - 5.5.14.1,5.5.14.2 & 5.8.2](c) For Waterford 3, the procedure approval along with changes to RW-105 SHALLbe accomplished per Waterford 3 Technical Specifications 6.13.2. The changesSHALL become effective upon review and acceptance by the Waterford 3General Plant Manager.[WF3 Technical Specifications - 6.13.2.b](d) For James A. FitzPatrick Nuclear Station, the procedure approval along withchanges to EN-RW-105 SHALL be accomplished per the James A. FitzPatrickStation Technical Specifications, Section 5.6.3. The changes SHALL becomeeffective upon review and acceptance through approval from the James A.FitzPatrick Nuclear Station On-Site Safety Review Committee.[JAF FSAR 11.3.5,13.10.1.1](e) For IPEC, Changes to the Process Control Program SHALL become effectiveafter final review and acceptance by the On-Site Safety Review Committee(OSRC).5.9. Vendor Requirements

[1]Vendors performing radwaste services under 10CFR61 and 10CFR71 requirementswill be on the Entergy Qualified Supplier's List (QSL).[QAPM, Section A.1.c]

[2]All radioactive waste owned by Entergy processed off-site by vendors must beprocessed or packaged to meet the minimum requirements listed in 10CFR Part61.56 (a) (1) through (8) and any applicable burial site criteria.

[3]Vendors performing radwaste services on-site are to comply with the following:(a) Dewatering and solidification services SHALL have a NRC-approved TopicalReport or other form of certification documenting NRC approval of theprocesses and associated equipment/containers.[GGNS FSAR 11.4.4.S2,11.4.2.3AS7]

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 18 OF 21PROCESS CONTROL PROGRAM5.9[2], continued(b) All vendor procedures utilized for performing on-site radwaste processingservices (to assure compliance with 10 CFR Parts 20, 61 and 71, StateRegulations, burial ground requirements, and other requirements governing thedisposal of solid radioactive waste) will be reviewed per the requirements ofEN-LI-100, technically by the applicable site's Radiation Protection organizationand only be accepted per the approvals specified in Section 5.8 [4].(c) All changes to vendor procedures for ongoing on-site radwaste services will bereviewed technically by the site's Radiation Protection organization andscreened per the requirements of EN-LI-100. Significant procedural changeswill require the approvals specified in Section 5.8 [4]. During screening, thelevel of significance for procedural changes on equipment and processparameters may warrant the full 10CFR50.59 documentation and approvalprocess.(d) Plant management SHALL review vendor(s) topical reports and test proceduresper applicable requirements in Section 5.8.NOTEThe PCP does not have to include the vendor's Topical Report if it has NRC approval,or has been previously submitted to the NRC.(e) Plant management review will assure that the vendor's operations andrequirements are compatible with the responsibilities and operation of the Plant.(f)Training requirements and records listed in Section 5.10 also apply tocontracted vendors.5.10. Miscellaneous

[1]Special tools and equipment(a) Frequency of Use and DescriptionsRequired tools and equipment will vary depending on the specific process andwaste container that is used. The various tools and equipment which may berequired are detailed in specific procedures developed to govern activitiesdescribed in this document.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 19 OF 21PROCESS CONTROL PROGRAM5.10, continued

[2]Pre-requisites(a) Maintenance of Regulatory MaterialEnsure that a current set of DOT, NRC, EPA and applicable State regulations,vendor processing facility and disposal site regulations and requirements aremaintained at the site and are readily available for reference. The use of webbased regulations is acceptable.(b) Representative Radionuclide Sample DataEnsure that representative radionuclide sample data is on file for each activewaste stream. Unless operation conditions or changes in processing methodsrequire increased sample frequency, data is considered to be current if it meetsthe requirements of EN-RW-104.(c) Initial and Cyclic Training A training program SHALL be developed, implemented and maintained forall personnel involved in processing, packaging, handling and transportationof radioactive waste to ensure radwaste operations are performed within therequirements of NRC Information Bulletin 79-19 and 49CFR Part 172.700through Part 172.704. Training requirements and documentation also apply to contracted on-site vendors.NOTECyclic training is defined as within three years for DOT, and two years for IATA(d) Specific employee training is required for each person who performs thefollowing job functions [172.702(b)]. Classifies hazardous materials. Packages hazardous materials. Fills, loads and/or closes packages. Marks and labels packages containing hazardous materials. Prepares shipping papers for hazardous materials. Offers or accepts hazardous materials for transportation.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 20 OF 21PROCESS CONTROL PROGRAM5.10[2](d), continued Handles hazardous materials. Marks or placards transport vehicles. Operates transport vehicles. Works in a transportation facility and performs functions in proximity tohazardous materials which are to be transported. Inspects or tests packages.(e) Cyclic training is defined as within three years for DOT & within two years forIATA.Copies of training records are required for as long as a person is employed and90 days thereafter. The records should include, as a minimum, the following: Trainee's name and signature Training dates Training material or source reference Trainer's information 6.0 INTERFACES

[1]EN-LI-100, "Process Applicability Determination"

[2]EN-RW-104, "Scaling Factors"

[3]EN-QV-104, "Entergy Quality Assurance Program Manual Control" 7.0 RECORDS

[1]Documentation of pertinent data required to classify waste and verify solidification willbe maintained on each batch of processed waste as required by approved procedures.

[2]Documentation will also be maintained to ensure that containers, shipping casks, andmethods of packaging wastes meet applicable Federal regulations and disposal sitecriteria. The records of reviews performed and documents associated with thesereviews will be maintained as QA records.

NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 21 OF 21PROCESS CONTROL PROGRAM8.0 SITE SPECIFIC COMMITMENTS SiteDocumentCommitment Number or ReferenceNMM ProcedureSection/Step ANO ANO ODCML3.2.1.C5.8 [3]ANOANO1 Technical Specifications 5.6.35.8 [1]ANOANO2 Technical Specifications 6.6.35.8 [1]RBSRBS Technical Requirements5.5.14*RBSRBS Technical Requirements5.5.14.15.8 [3]5.8 [4] (b)

RBSRBS Technical Requirements5.5.14.25.8 [4] (b)

RBSRBS Technical Requirements 5.8.25.8 [4] (b)WF3WF3 Technical Specifications1.22*WF3WF3 Technical Specifications6.9.185.8 [1]WF3WF3 Technical Specifications6.13.2.b5.8 [4] (c)

JAF JAF ODCM 6.2.15.8 [1]JAFJAF Technical Specifications 5.6.35.8 [1], 5.8 [4](d)

JAFJAF FSAR11.3.5, 13.10.1 5.8 [4](d)WF311759 - NRC IN 79-19 All*GGNSGGNS UFSAR, Chapter 16B.1 /

TRM7.6.3.8paragraph 1 1.0 GGNSGGNS ODCM5.6.3.c5.8 [1]GGNSGGNS FSAR11.4.5.S2 5.9 [3](a)

GGNSGGNS FSAR11.4.2.3AS7 5.9 [3](a)IPECIPN-99-079 All*IPECAppendix B TechnicalSpecificationsSection 4.5, RECS ODCMPart 1*PLPPLP Technical Specifications5.5.155.8 [4]PLPPLP ODCMAppendix A - IV. A5.8 [1]PNPSNRC Letter 1.98.091 All*PNPSNRC Letter 1.88.078 All*All QAPMSection A.1.c

- Covered by directive as a whole or by various paragraphs of the directive.9.0 ATTACHMENTS None NUCLEARMANAGEMENTMANUAL QUALITY RELATEDEN-RW-105REV. 5 INFORMATIONAL U SEPAGE 1 OF 21PROCESS CONTROL PROGRAMProcedure Contains NMM ECH eB REFLIB Forms: