ML20070S271

Rev 0 to RPP 07-102, Solid Radwaste Process Control Program

ML20070S271
Person / Time
Site:	Wolf Creek
Issue date:	10/03/1990
From:	WOLF CREEK NUCLEAR OPERATING CORP.
To:
Shared Package
ML20070S264	List: ML20070S261 ML20070S271
References
RPP-07-102, RPP-7-102, NUDOCS 9104020216
Download: ML20070S271 (41)

Text

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WOLF CREEK NUCLPAR OPERATING CORPORATION WOLF CREEK GENERATING STATION SOLID RADWASTE PROCESS CONTROL PROGRAM RPP 07-102 Revision 0 Classification:

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s TAnu OF CONTENTS

.PAGE 1.0 PURPOSE 1

2.0 DISCUSSION 1

3.0 REFERENCES

S 4.0 RESPONSIBILITIES 8

4.1 Health Physics Supervisor 8

5.0 DEFINITIONS / ABBREVIATIONS-8 5.1 D9finitions 8

5.2 Abbreviations 11 6.0 PREREQUISITES 11 7.0 PRECAUTIONS / LIMITATIONS 13 8.0 SPECIAL TOOLS AND EQUIPMENT 14 9.0 PROCEDURE 15 9.1 Methods'and frequency for determining 15 tha radionuclide concentration for each e

) stream 9.2

.o.ent and planned practice for each 16 waste stream is as follows:

9.3 Sample evaluation 12 9.4 Sample analysis and comparison 21 9.5 Sample frequency 23 9.6 Scaling factors 24 9.7 Waste classification.

24 9.8 Quality control for sampling and 25 classification 9.9 Non-waste classification-25 9.10 Processing general requirements 26 9.11-Processing requirements during 27 dewatering operations 9.12 Packaging general requirements 28 9.13 Packaging vendor requirements 28 9.14 Additional Barnwell Waste Management 31 Facility requirements i

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RPP 07-102 Rev. O j

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TABLE OF CONTErfS FAGE 10.0 RECORDS REQUIREMENTS 32 10.1 Verification and Quality Assurance 32 Records 32 11.0 ATTACHMENTS l

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RPP 07-102 Rev. 0

1.0 PURPOSE 1.1 This procedure provides instructional guidance and a description of the solid waste Process Control Program (PCP).

The PCP describes the methods used for processing wet low-level radioactive waste into a waste form acceptable for disposal, in accordance with 10 CPR 61 requirements, at a licensed land disposal facility.

1 1

2.0 DISCUSSION 2.1 This procedure describes current and planned practice for sampling, sample evaluation, classification, processing and packaging of radioactive material.

This p..'ocedure does not address irradiated hardware which will be managed on a case-by-case basis under the direction of the MRP.

System description and operating practices are described in the following steps.

2.2 Waste Stream Identification - The station has identified eight different waste streams and treats each separately for classification purposes.

O DAW 0

Steam Generator Blowdown Bead Resin Chemicy})andVolumeControlSystemBead 0

Resin (CVCS) 0 Reactor Coolant System Filters O

Floor Drain Tank Filters O

Spent Fuel Pool Filters 0

Waste Monitor Tank Filters O

Steam Generator Blowdown Filters (1) Combination of CVCS, DURATEK, and Spent Fuel Pool Resins.

RPP 07-102 Rev. O Page 1 of 35

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2.3 Non-waste Stream Identification - The station has-1 identified two different sources and treats each separately for classification purposes.

O Non-irradiated material removed from the Spent Fuel Pool.

Any other radioactive material generated-O by the station.

2.4 Disposition of Radioactive Material Sent to a Vendor for-Intermediate-Processing - Planned practices may include sending radioactive material packages generated by the station to'SEG or other vendors for.

volume reduction (VR)/ processing instead of directly to a burial site.

2.4.1 This-procedure addresses the requirements for 10 CFR 61.55 (Waste-Classification) for radioactive material sentLto vendor facilities.

2.4.2 This-procedure does HQI address-the requirements-for 10 CFR 61.56 (Waste Characteristics), since the final processing and packaging is performed-at the vendor facilities.

2.4.3 Possible types of radioactive' material include, but are HQI limited to the followings O

DAW 0

Steam Generator Blowdown Resin 0

Steam Generator Blowdown Filters O

Contaminated 011 0

Contaminated Soil.

2.5 Disposition of Waste ~Sent Directly to a Burial Site --

This-procedure addresses both the;10-CFR 61'.55'and-

61. 6 requirements?for the waste' streams listed-in 5

Section:2.2.

l RPP 07-102 Rev. O l

Page 2 of 35 l

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2.6 Waste Management Practices 2.6.1 DAW.

O This waste stream consists of plastic, wood, paper, metal, cloth, etc.

generated-at various locations within the station.

Station processing equipment consists of O

a 55 gallon drum compactor.

All compressible waste _ material is compacted in 55 gallon drums and_non-compactible raaterial is packaged in metal B-25 boxes.

Future practice may include shipping O

uncompacted DAP packaged in 55 gallon drums, B-25 boxes or large sea-Land containers to a volume reduction processor.

Prepacking inspection criteria includes O

the removal of liquid, protective clothing and equipment, paints, solvents, lead, instruments, gages and other valuable plant equipment.

2.6.2 Steam Generator Blowdown Bead Resin (S/G BD).

0 This waste stream consists of only S/G blowdown resin.

The depleted resins are sluiced from the individual' processing vessels to the S/G Blowdown Resin:

Storage Tank and then to a CNSI 6-80 or 8-120 High Integrity Container (HIC), QR any other container approved by the Health Physics Supervisor Radwaste.

O once a container is full, the resins are then dewatered using_ plant equipment and-approved vendor dewatering procedures.

O Future practice may include shipping dewatered resins to a volume reduction processor.

RPP 07-102 Rev. O Pege 3 of-35 l

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2.6.3 Chemical eid Volume Control-System Bead f

Resin (CVCS).

O This waste stream consists of CVCS,-

various DURATEK media and Spent Fuel Pool resins.

The depleted charcoal filter media and resins are sluiced from the individual processing vessels to a common Spent Resin Storage Tank.

The media is then transferred in a batch mode-to a CNSI 6-80 or 8-120 HIC, set any other container approved by the Health Physics Supervisor Radwaste.

-Once a container is full l the filter O

l media (charcoal) and resins are then dewatered per RPP 07-131.

4 2.6.4 Cartridge Filters.

0 This category includes several waste streams which were defined in Section 2.2 and includes all filters generated by the station.

O Filters are removed from service based on operating parameters determined by-

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the operations Department, o

The filter housings are drained prior-to filter removal.

The filters 1are then gravity drained prior to being placed i

into an intermediate storage container 4

QR the final disposal container.-

O A' final dewatering. verification is performed on the disposal container i

after it has been loaded with filters.

2.6.5 Solidification / Encapsulation Methods.

O Present and planned practice is HQI to solidify or encapsulate any waste etreams.

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0-Alliliquid waste is dewatered to less than 1% by volume prior to shipment, i

J RPP 07-102 Rev. O Page 4 of 35 i

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4 2.6.6 Operation and Maintenance of Dewatering i

Systems and Equipment.

Present and planned practico is to O

utilize station personnel to operate and maintain dewatering systems and equipment using station procedures.

All disposal liners are manufactured by O'

and purchased from QA approved vendors.

2.6.7 High Integrity Container Usage.

High Integrity Containers (fabricated O

from high density cross-linked polyethylene) may be used as the disposal package for NRC Class "A"

waste.

High Integrity Containers may also be O

used for NRC Class "B" and "C" waste, but enhanced structural stability is required for Poly HICs received at the CNSI Barnwell site.

O Enhanced structural stability to meet the requirements of 10 CFR 61.56 and the State of South Carolina is accomplished by the-use of DHEC approved concrete overpack structures.at the Barnwell burial site.

3.0 REFKRENCES 3.1 RPP 07-101, " Control of Radioactive Material Management Software and Data Bases" 3.2 RPP 07-120, " Preparation and Shipment of Radioactive Waste" i

3.3 RPP 07-121, " Preparation and Shipment of radioactive Material"-

3.4 RPP 07 '33

" Bead Resin / Activated Carbon dewatering Procedure for CNSI 14-215~or Smaller Liners" 4

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!I RPP 07-102 Rev. 0 Page 5 of 35 4

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3.5 10 CFR 20, " Standards for Protection Against J

Radiation" 3.6 10 CPR 61, " Licensing Requirements for Land Disposal of Radioactive Waste" 3.7 10 CFR 71, " Packaging and Transportation of radioactive Materials" 3.8 40 CFR 302, "Repertable Quantity Adjustment -

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Radionuclides" 1

l 3.9 49 CFR 171, " General Information, Regulations, and Definitions" s

j 3.10 49 CFR 172, " Shippers' General Requirements for Shipments and Packaging" l

3.11 49 CFR 177, " Carriage by Public Highway" 3.12 Barnwell Waste Management Facility Site Disposal Criteria; CNSI-S20-AD-010 3.13 CNSI's South Carolina Department of Health and Environmental Control (DHEC) Radioactive Materials License No. 097 3,14 CNSI's United States Nuclear Regulatory Commission (NRC) Radioactive Materials License No. 12-13536-01' 3.15 South Carolina DHEC Regulation 61-83, Transportation of Radioactive Waste Into or Within South Cerolina 3.16 USNRC Branch Technical Position on Radioactive Waste Classification, May 1983 3.17 USNRC Branch Technical Position on Waste Form, May 1983 3

3.18 NRC Bulletin No. 79-19, " Packaging of Low Level Radioactive Waste for Transport and' Burial" 3.19 NRC Information Notice No. 80-24, " Low Level Radioactive Waste Burial Criteria" s

4 RPP 07-102 2

Rev. O Page 6 of 35

3.20 NRC Information Notice No. 93-33, ONon-representative Sampling of Contaminated 011" 3.21 NRC Information Notice No. 85-92, " Surveys of wastes Before Disposal from Nuclear Reactor Facilities" 3.22 NRC Information Notice No. 86-20, " Low Level Radioa;

.ve Waste Scaling Factors, 10 CFR 61" 3.23 NRC Information Notice No.88-101, ' Shipment of Contaminated Equipment Between Nuclear Power Stations" 3.24 WMG-SW-006, " Computer Softwe.re Quality Assurance Program" 3.25 WMG-QA-011, " Quality Assurance Program" 3.26 "RADMAN Operating Manual" 3.27 RADMAN Computer Code, Main Topical Report to the USNRC 3.28 WMG-P-007, "FILTRK Operating Procedure" 3.29 WMG-P-009, "RAMSHP Operating Procedure" 3.30 WMG-P-010, "TRASHP Operating Procedure" e

3.31 WMG Report #9006, " Computer Program Dose to Curie Methodology Verification and Validation" 3.32 U.S. Nuclear Regulatory Commission, " Radiological Effluent Technical Specifications for PWRs", NUREG-0472.

3.33 NRC Guidelines for Preparation and Implementation of Solid Waste Process Control Program " DRAFT", Revision 4, October 1986 3.34 CNSI FO-AD-002, " Operating Guidelines for Use of Polyethylene High Integrity Containers" 3.35 CNSI, FO-OP-023, " Bead Resin / Activated carbon Dewatering _ Procedure for CNSI 14-215 or Smaller Liners" RPP 07-102 Rev. O Page 7 of 35

4.0 RESPONSIBILITIES 1

4.1 Health Physics Supervisor Radwaste is responsible for 4.1.1 Implementing this procedure.

4.1.2 Ensuring that radioactive waste is classified and characterized in accordance with 10 CPR 61.55 and 61.56.

4.1.3 Designating other approved procedures (if required) to be implemented in the packaging of any specific batch of waste.

5.0 DEFINITIONS / ABBREVIATIONS 5.1 Definitions Waste Stream - A station specific and constant source of waste with a distinct radionuclide content and distribution.

Waste Tvoe - A single packaging configuration tied to a specific waste stream, or multiple package types tied to the same waste stream.

Scalina Factor - A dimensionless number which relates the concentration of an easy to measure nuclide (gamma emitter) to one which is difficult to measure (bota/ alpha emitters).

Soecial Nuclides - RADMAN Computer Code term for 10 CFR 20.311 required nuclides.

Gross Radioactivity Measurements - More commonly known as Dose to Curies conversion for packaged waste characterization and classification.

Keasurement of Specific Rad.*,onuclides - More commonly known as core sample or package sample using MCA data for packaged waste characterization and classification.

Gamma-Soectral Analysis - Also known as IG, MCA, Ge/Li and gamma spectroscopy.

RPP 07-102 Rev. 0 Page 8 of 35

5.1 Continued Confirmatory Analysis - Verification of gross radioactivity measuraments using MCA and independent laboratory sample data.

Homoceneous - Of the same kind or nature; essentially alike.

Most waste streams are considered homogeneous for purp'oses of waste classifications Density Correction - Density corrections must be made to convert sample data reported in uCi/g to uCi/cc prior to characterization using the RADMAN core sample mode.

Chelatino Acents - EDTA, DTPA, hydroxy-carboxylic acids, citric acid, cartolic acid and glucinic acid.

Sienificant Ouantity - For purposes of waste classification and sample evaluation the following radionuclide limits shall be considered significant Any value for a 10 CFR 20.311 required 0

radionuclide.

O Greater than or equal to 1% of the Class A 1Laits listed in 10 CFR 61.55.

Greater than or equal to 1% of the total O

activity.

O Greater than.or equal to 1% of the reportable quantity limits listed in 49 CFR 172.101, Table 2.

Batch - An-isolated quantity of feed wasto to be processed having essentially constant physical and chemical characteristics.

(The addition or removal of water will not be considered to create a new batch.)

Dewatered Waste - Dewatered Waste refers to wet waste that has been processed by means other than solidification, encapsulation,.or absorption to meet-the free standing liquid requirements of 10 CFR 61.56 (a)(3) and (b)(2).

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

RPP 07-102 Rev. O Page 9 of 35

4 J

5.1 Continued Operable - A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s),

and when all necessary attendant instrumentation, controls, electrical power, cooling or seal 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 of performing their related support function (s).

Pre-cualification Procram - The testing program-implemented to demonstrate that the proposed method of wet waste processing will result in a waste form acceptable to the land disposal facility.

Processino - Changing, modifying packaging the commercial nuclear power plant generated wet radioactive waste into a_ form that is acceptable to a disposal facility.

-Ouality Assurance /Ouality control - As used in this document, " quality assurance" comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or componcnt will perform satisfactorily in service.

Quality assurance includes quality control, which comprises those quality ansurance actions related to control of the physical characteristics and quality of a material' structure, component, or system to predetermined requirements.

Samolino Plan - A sampling program implemented to ensure that representative samples from the feed waste and the final' waste form are obtained and-tested for conformance with-parameters stated in the PCP and waste form acceptance criteria.

Stability - As used in this document, " stability" means structural stability.

Stability requires that' the waste form maintain its structural-integrity under the expected disposal conditions..

OA Verification Samole - A-representative sample of the waste that is tested to demonstrate control of the waste processing.

The sample shall lxs obtained from at least every tenth batch of each type of wet radioactive waste processed for stabilization.

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l 1 RPP 07-102 Rev. O Page 10 of 35

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F 5.1 Continued Low-Level radioactive Waste (LLW) - Those low-level radioactive wastes containing source, special nuclear, or by-product material that are acceptoble for disposal in a land disposal facility.

For tae purposes of this definition, low-level radioactive waste has the sane meaning as in the Low-Level Waste Policy Act, that is, radioactive waste not classified as high-level radioactive waste, transuranic waste, spent nuclear fuel, or by-product material as defined in Section 113.(2) of the Atomic Energy Act (uranium or thorium tailings and waste).

Waste container - A vessel of any shape, size, and composition used to contain the final processed waste.

Weste Form - Waste in a waste container acceptable for disposal at a licensed disposal facility.

5.2 Abbreviations

<G - Activity Per Gram BTP - Branch Technical Position 2

CNSI - Chem Nuclear System, Inc.

ITS - Health Physics Supervisor LLD - Lower limit of detection MCA - Multichannel Analyzer 6.0 PREREOUISITES 6.1 Ensure that a current set of DOT and NRC regulations are maintained at the station and.are available for reference.

6.2 Ensure that representative sample data is on file for each waste stream.

Data is considered to be current if it meets the following:

6.2.1 The waste stream must be sampled at least every two years for NRC Class "A"

waste.

6.2.2 The waste stream must be sampled at least every year for NRC Class "B" or "C" waste.

RPP 07-102 Rev. O Page 11 of 35

6.2.3 Non-waste radioactive material shall be 4

sampled on an annual or as generated basis i

with (non-irradiated) fuel pool material differentiated from balance of plant material.

6.3 A training program shall be developed and implamented for personnel having responsibilities related to-waste processing operations to ensure the waste processing shall be performed within the requirements of the PCP.

6.3.1 The training program shall be repeated and the personnel requalified on a periodic-

schedule, 6.3.2 The individual's training records shall be maintained and available for audit and inspection.

6.4 Additional requirements for contracted vendors processing waste.

6.4.1 Management shall_ review vendor (s) topical reports.

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The.PCP does EQI-have to include the vendor's Topical Report ifLit has NRC.

approval, or has.been previously-submitted to the NRC.

o This review will assure that the-vendor's operations:and requirements are compatible withithe responsibilities and i

operation ci the plant.

O The training requirements and records-2 listed in Section 6.3 also apply to contracted vendors.

O The station shall maintain co, ties of-records-to-verify training of vendor personnel.

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RPP 07-102

.Rev. 0 Page'12 of 35

i 7.0 PRECAUTIONS / LIMITATIONS

'i 7.1 All plant personnel that have any involvement with the RADMAN, TRASHP, and FILTRK computer codes shall be familiar with its functions, operation, and maintenance.

7.2 Only authorized personnel will characterize or package radioactive wasta or radioactive materials.

7.3 Radioactive materials shall be handled in accordance with applicable Radiation Protection Procedures.

7.4 Pressure and heat may.be encountered during the operation of liquid waste processing systems.

7.4.1 Caution must be' exercised during disassembly and disconnection of lines or equipment and valve realignments.

7.5 Each HIC is matched with specific closure components and seals at time of manufacture.

7.5.1 All components are identified using a common serial number.

7.5.2 Should components become mismatched, contact the Health Physics Supervisor Radwaste for instixctions prior to use.

7.6 Waste must EQT be packaged for disposal in cardboard or fiberboard boxes.

7.7 Liquid waste must be solidified or packaged in sufficient absorbent material to absorb twice the volume of the liquid.

7.8 Solid waste containing liquid shall contain as-little free standing and non-corrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 1% of the volume.

7.9 Waste must NOT be readily capable of detonation or of explosive decomposition or reaction at normal-pressures and temperatures, or of explosive reaction with water.

RPP 07-102 i

Rev. O Page 13 of 35 e

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7.10 Wasto must EQI contain, or'be capable of-generating,.

quantities of toxic gases, vapors, or fumes harmful to persons transporting,-handling, or disposing.of the waste.

This does EQI apply to radioactive.

gaseous waste packaged in accordance with Section 7.12 of this section.

7.11 Waste must EQI be pyrophoric.

Pyrophoric materials contained in waste shall be treated, prepared, and.

packaged to be non-flammable.

7.12 Waste in a gaseous form must be packaged at a pressure that does not exceed 1.5 atmospheres at 200C.

Total activity must not exceed 100. curies per container.

7.13 Waste containing hazardous, biological, pathogenic, or infectious material must be treated to reduce to the maximum-extent practicable the potential hazard from the non-radiological materials.

7.14 All data entries shall use three significant figures gnly (i.e., X.XXE-x).-. II, more significant figures are provided, round off to' generate three significant figures.

7.15 Use only those isotopes reported aus real values, ignore all isotopes reported as LLD' values, except' those nuclides listed in Section 9.3.7.

7.16 Delete all radioisotopes with half lives less than five (5)-days,!with a concentration less than=1% of the total activity.

8.0

. SPECIAL TOOLS AND EOUIPIDOIT 8.1 Required tools and equipment' will vary depending. on the specific process-and-waste container that is used 8.2 The-various tools-and equipment-which may be required are. detailed in the vendor proceduresiliated:in (3.34 and 3.35).

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RPP 07-102-Rev. Page 14 of 35

9.0 PROCEDURE t

9.1 Methods and Prequency for determining the Radionuclide Concentration for each Waste-Stream 9.1.1 Ensure samples are representative of the final waste form.

9.1.2 Determine tho density for each waste stream 'EQI applicable for DAW and filters).

NOTE For WCGS, waste streams are considered to be homogeneous for purposes of waste classification.

9.1.3 Treat each waste stream separately for.

classification purposes.

9.1.4 Send all NRC Class "A" waste samples to an independent laboratory for gamma, beta and alpha analysis at least once every two years.

a.

Perform an in-house analysis for gemma emitting radionuclides for each sample sent to an independent lab for future comparison.

b.

Periodically perform in-house analysis for gamma emitting nuclides for comparison to the current-data base values for gamma emitters (the current data base is usually_ based on the most recent independent laboratory,results).

9.1.5 Send all NRC Class "B" and "C" weste samples to an independent' laboratory for gamma, beta and alpha analysis at least once c year.

The additional steps required-are identical toH9.1.4 a.-and b..above.

9.1.6 Determine the status of the 10~CFR 20.311 required nuclides (real value, LLD or not present) for each waste stream from the most recent independent-laboratory data.

9.1.7 Document _and track all samples-per RPP 07-101, Attachments 11.2, 11.3, 11.4, 11.5 and 11.6.

RPP.07-102 Rev. O Page 15 of 35

9.2 Currehtandplannedpracticeforeachwastestreamis as follows:

9.2.1 DAW.

Obtain composite smears from various O

contaminated areas of the plant on a quarterly _ basis and analyze (IG) them in-house-for gamma emitters.

compare the results of the quarterly 1

O samples to the data base to ensure adequacy of sample frequency.

O Send the most recent group of composite smears.to an independent laboratory for analysis once per year or more often IE determined necessary by the Health Physics. Supervisor Radwaste.

O Maintain records for all samples for nuclide identification, distribution:and scaling factors.

B9TE The_ specific activity (uC1/cc or uci/g is EQI required since all characterization /

classification calculations are performed using a dose / curie: methodology which only relies on fractional-abundance-and scaling-factors.

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0 Both in-house and independent laboratory results_are normally_ reported in uC1/ sample.-

9.2.2 S/G' Blowdown Resin.

O Obtain several (as. determined by the Health Physics-Supervisor Radwaste) composite. samples from the resin

-transfer line during liner loading operations =on an as generated basis.

RPP 07-102 Rev. O Page-16 of?35

9.2.2 Continued 10E Each liner is considered a different batch for sampling and classification purposes.

Analyze the samples in-house (IG) and O

retain thi. results for future comparison to the replicate independent laboratory results.

Send the samples to an independent O

laboratory for analysis once per year or as generated.

O Maintain records for all samples for nuclide identification, distribution and ccaling factors.

O Both in-house and independent-laboratory results are normally reported in the same units (uCi/g or uCi/cc).

9.2.3 CVCS Resin.

O The sampling procedure is exactly the same as listed above for S/G Blowdown Resin in Step 9.2.2.

9.2.4 Filters.

O Obtain samples from each individual filter waste stream defined in Section 2.2 on an annual ggi as generated basis.

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Samples (usually multiple) may be taken from the actual filter media,_from a smear of the filter media or from a smear of-the filter housing,' as determined by the Health Physics Supervisor Radwaste.

O Perform an in-house (IG) analysis of the sample (or replicate sample) and retain the output record for future comparison to the independent laboratory results.

RPP 07-102 Rev. 0-Page 17 of 35

9.2.4 Continued Send the sample to an independent 0

laboratory for analysis once per year or more often'if' determined necessary by the Health Physics Supervisor.Radwaste.

O Maintain records for all samples for nuclide identification, distribution and scaling _ factors, llGZE The specific. activity (uci/cc or uC1/g is not required since all

-_ characterization / classification calculations are performed using a dose / curie methodology which only relies on fractional abundance and scaling factors.

O Both in-house and laboratory-results are normally reported in uCi/ sample.

9.3 Sample Evaluation.

9.3.1 Infrequent or Abnormal Waste Types, Infrequent or abnormal waste types that a.

may_be generated must be evaluated en a case-by-case basis, b.

The Health Physics Supervisor Radwaste will determine-if the. waste can-be correlated 1to an existing waste stream; c.

If the radioactive material.cannot-be-

. correlated 1to an existing waste stream, the Health Physics Supervisor Radwaste-shall determ!.ne specific:offsite l

sampling'and analysis requirements-

'necessary to properly--classify the l

material.

l RPP 07-102-I hev. O Page:18 ofL35 l

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I 9.3.2 Examples of these radioactive materials include, but are not lOnited to O

Cont:vainated Soil.

0 Contaminated 011.

O Special Filters or Resin.

O A mixture of radioactive material types in one container.

9.3.3 Requirements for Analysis to be Performed by an Offsite Vendor are as follows:

a.

All sample results must include sample density and volume.

b.

All samplo results shall be decay corrected to a reference date.which is normally the sample date.

c.

The sample results shall be reported in uCi/ sample, uCi/g or uCi/cc as determined by the Health Physics Supervisor Radwaste.

i NOTE Outside analysis is EQI performed for any radionuclides with a half-life less than five days.

9.3.4 The vendor shall perform analysis for the following radionuclides.11sted-in Table 1 of 10 CFR 61.55.

O C-14,-Tc-99, I-129, Pu-241, Cm-242 and

-the following trancuranics (TRUs) with half-lives greater than five years, Np-237, Pu-238, Pu-239/240,JPu-242, Am-241, Am.243 and Cm-243/244.

RPP 07-102 Rev. 0-Page 19 of 35

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9.3.4 Continutd

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EQII If evaluation of several sets (i.e., 3 or more) of waste stream specific historical sample data shows that some TRUs with half-lives greater than five years are consistently reported as LLD values,-sample analysis may be discontinued for those specific radionuclides.

Analysis for the " activated metal" O

radionuclides listed in--Table 1 of 10 CFR 61 are }gDC currently required for the waste streams identified at WCGS.

It is E22 necessary to contract for an O

offsite vendor to perform analysis for enriched uranium or.other naturally occurring radionuclides not delineated in this procedure.

Radionuclides listed'in Table 1 of O

10 CFR 61.55 shall be specifically identified and-the quantitres reported on shipping manifests-if they are significant for purposes of classification.

9.3.5 The vendor shall perform analysis for the following radionuclides listed in Table 2 of 10 CFR 61.55.

H-3, Co-60, Ni-63, Sr-90 and Cs-137.

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Radionuclides listed in= Table 2 of 10 CFR'61.55 shall be specifically identified and the quantities reported on shipping manifests if they are 3

significant for purposes.of classification.

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RPP 07-102 Rev. 0 Page 20 of 35 1

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9.3.6 The vendor shall perform analysis for the following radionuclides U21 listed in Table 1 or Table 2 of 10 CFR 61.

O Activation Products - Cr-51, Mn-54, Fe-55, Co-58, Fe-59, Sb-124, Sb-125, En-65, Ag-110m and any other nuclides identified in significant quantities by in-house IG equipment.

O Fission Products - Zr-95, Nb-95, Ru-103, Ru-106, Cs-134, Ce-141, Sr-89, Ce-144 and any other nuclides identified in significant gaantities by in-house IG equipment.

9.3.7 A waste stream specific data base must include the following radionuclides, even if they are reported as LLD values:

H-3, C-14, Tc-99, I-129 required by 10 0

CFR 20.311 (H-3 is considered real or LLD for DAW because not present cannot be substantiated.

Co-60, Cs-137, and Ce-144 required by O

the RADMAN computer code.

They are used as the primary scaling radionuclides.

9.4 Sample Analysis and Comparison.

9.4.1 Whenever a sample is sent offsite for analysis, count the same sample (or replicate) in-house with the station IG system.

NOTE Isotopic results exhibiting a standard error equal to or greater than 40% are considered as " suspect" values and shall be discarded as necessary.

RPP 07-102 Rev. O Page 21 of 35

9.4.2 Comparisons of onsite versus:offsite

(

analysis shall be evaluated by the Health Physics Supervisor Radwaste to identify and resolve any discrepancies.

As a minimum,.

the comparison shall include O

Specific activity by gamma emitting radionuclides.

(HQI applicable for DAW or filter samples.)

O Co-60/Cs-137-Ratio.

O Presence or-absence of radionuclides.

0 Predominant radionuclides.

O Individual radionuclide fractional abundance.

-9.4.3 Records of onsite and r,ffette sample-analysis _and evaluati(nr. icy. waste-type are maintained by the Hea3tn Physics Supervisor-Radwaste.

-9.4.4 IE a comparison between the in-house and independent laboratory results shows a variance of 10%-or greater for specific-activity, the MCA resulta=shallibe adjusted accordingly_until the-discrepancy is resolved.

9.4.5 Radionuclides with a half-life less than five-days are also ignored from-internal MCA reports.

9.4.6 New sample data shall'be periodically-obtained and. evaluated.

9.4.7 New sample data-may-be either'offsite-analysis or in-house MCA_ analysis, 9.4.8 once a data base has been-established, based on offsite analysis,sthe MCA results are primarily used_as a " flag' to obtain-

.and send-additional samplesLoffsiter i

RPP 07-102 Rev, O Page.22 of 35 I

l

y@4.9 The SCAL utility program may be utilized to evaluate multiple sets of data.

IE-it is used, complete the SCAL loading form, RPP 07-101, Attachment 11.11.

NOTE Isotopic results exhibiting a standard error equal to or greater than 40% are considered as " suspect" values and shall be discarded as necessary.

9.4.10 Several comparisons to the existing data base shall be considered when evaluating new sample data.

O Radionuclide fractional abundance and scaling factor relationships.

O Spec!fic activity by radionuclide Swing in predominant radionuclide.

O O

Radionuclides present in data base, but NOT present-in new sample or vice versa.

O Total activity by sample set.

9.5 Sample frequency.

9.5.1 The following may require increased sampling:

0 Increase in failed fuel fraction as determined by:

D.E.I.

25% of Technical Specification limit.

- Increase of I-131/I-133 ratio at steady state power.

- Np-239. greater tha9.01 uC1/cc in reactor coolant.

- Positive in-house gross alpha sample l

results on any type of smear survey.

l l

RPP 07-102 Rev. O Page 23 of 35

J 9.5.1 Continued 0

Crud bursts during 100% lor'*, rejection or chemical cleaning.

O Extended reactor shutdown >90 days.

Changes to liquid waste processing, such O

as bypassing filters, utilizing filters or a change in ion exchange media.

9.6 Scaling Factors.

9.6.1 WCGS has established an inferential measurement program, whereby concentrations of radioisotopes which cannot be readily measured are estimated through ratioing to concentrations of radioisotopes which can be readily measured.

9.6.2 Scaling factors have been developed on a facility and waste stream specific basis, and are periodically confirmed through direct measurements.

9.6.3 Correlations between measured and inferred radionuclides are currently as follows:

O Ce-144 to transuranic nuclides.

O Co-60 to activation product nuclides and C-14.

c-137 to fission product nuclides.

O c

9.7 Waste Classification.

1. 2EE The volume and mass of the waste form (not the waste container) is used for most waste classification calculations.

9.7.1 Deternine - the waste classification (Class "A"

stable or unstable, Class "C")-by the concentration-of certain radionuclides in the final waste form as: listed in 10 CFR 61.55.

RPP 07-102 Rev. 0 Pago 24 of 35

9.7.2 Deter -ine the radion, lide concentrations per RPP 07-120 as follows:

O DAS

' Gross Radioactivity Maasurements' i

in con! unction with the RADMAN or TRASHP computer codes or hand calculations.

O Filters

' Gross radioactivity Measurements

• in conjunction with the FILTRK computer code or hand calculations.

O All other wafte streams

' Direct Measurement of Individual Radionuclides" in conjunction with the RADMAN or TRASHP computer codes or hand calculations.

98 Quality control for Sampling and Classification.

9.8.1 The RADMAN computer code provides a mechanism to assist WCGS in conducting a quality control program to aid in compliance with the waste classification requirements listed in 10 CFR 61.55.

j 9.8.2 Management audits of the WCGS Sampling and Classification Program shall be performed annually to verify the adequacy of maintenance sampling and analysis.

9.8.3 The audits are performed and documented-by any of the following:

0 Health Physics Depdrtment 0

Corporate Radwaste and Document Services Department 0

Quality Assurance Department-0 Qualified Vendors 9.9 Non-Waste Classification.

9.9.1 Determine the radioactive mategial classification (Limited quantity, LSA, Type-A, > Type A or Type B) by the total activ;.ty i

or activity.per gram as listed in DOT regulations and the receiver's-radioactive material licenses.

l RPP 07-102 Rev. O Page 25 of 35 l

l

9.9.2 Determine the radionuclide concentrations i

per RPP 07-121 ad follows:

0 Non-irradiated material removed from the spent fuel cool

" Gross radioactivity Measurements," ' Direct Heasurement of Individual Radionuclides," or measurement of rarface contamination levels'for non-radioactive material contaminated with radioactive material l

in conjunction with the RAMSHP computer code or hand calculations.

O Any other radioactive material cenerated by.the station - The same methods listed for fuel pool material may be used with a separate radionuclide data base.

9.10 Processing General Requiremento.

EM The dewatering capabilities are verified by vendor Topical Rep 9rts or Operating and Testing Procedures.

9.10.1 verify the wastes contain only trace amounts of drainable liquid. and in EQ case may the volume of free liquid exceed 1% of the waste volume when wastes are disposed of in containers designed to provide stability.

EM The following verification is performed on a case-by-case basis for each package using independent laboratory data and MCA data in conjunction with computer codes or hand calculations.

l 9.10.2

" rify that resins are E2I processed that l

'sve loadings which will produce greater than 1.0 E+8 rade total accumulated dose.

l l

9.10.3 The as generated waste must be compatible with the disposal container.

l l

l RPP 07-102 Rev. O Page 26 of 35

~

7..

9.11 Processing Requirements During Dowatering Operations.

9.11.1 Perform all dowatering operations por RPP 07-131, ' Dead Rosin / Activated Carbon Dowatoring" Procedure for CNSI 14-215 or smaller liners.

EZul This procedure may only be used to dewater CNSI's14-215 or smaller liners containing boad-type ion exchange resins and activated carbon with less than 14 oil.

9.11.2 Complete RPP 07-131, Attachment 11.1 for each liner prior to final closure.

9.11.3 RPP 07-131, Attachment 11.1 must be included in the shipping paperwork package with the shf.pment.

9.11.4 The final transfer /dowatering cycle shall be counted as the first pumping cycle IE after the transfer is completed, the liner is dowatering por this procedure.

9.11.5 Final dewatering verification is determined by the following:

0 1% Proe-Standina Water or Less - After a f

minimum of two (2) pumping cycles for bead resins or five (5) cycles for autivated carbon, a measured volume of sfive (5) gallons on the next eight (8) hours of pumping shall be the acceptance criteria.

21. five (5) gallons or more are collected, the waiting / pumping cycle shall be repeated until less than five (5) gallons are collected.

RPP 07-102 Rev. O Page 27 of 35

i 9.11.5 Continued 0

0.5% Proe-standino Water or Less - After a minimum of five (5) pumping cycles for bead resins or eight (8) pumping cycles for activated carbon, a measured volume of $(2) gallons on the next eight 8) hours of pumping shall be the accep(tance criteria.

jf. two 2

gallons or more are collected, the(wa)iting/ pumping cycle shall be repeated until less than two (2) gallons are collected.

9.12 Packaging General Requirements.

EZEE The following general requirements are normally verified by review of a HIC's Certificate of Compliance (C-of-C) and State /NRC approval.

9.12.1 Ensure that the waste is in a container or i

structure that provides stability after disposal.

9.12.2 Ensure that the container is resistant to degradation caused by radiation effects.

9.12.3 Ensure the container is resistant to blodegradation.

9.12.4 Verify that the container will remain stable under the compressive loads inherent in the disposal environment.

-9.12.5 Verify that the container will remain stable if exposed to moisture or water after disposal.

9.12.6 Ensure that the as generated waste is compatible with the container.

9.13 Dackaging Vendor Requirements.

9.13.1 Perform all inspection, handling and loading operations per CNSI, FO-AD-002.

i RPP 07-102 Rev. O Page 28 of 35

~

1 4

223 i

Prior to use, each user will have on file within Chem-Nuclear Systems, Inc.

Regulato n Affairs Department a

" Polyethylene High Integrity Container certification Statement".

y@.13.2 II not already on file, complete Attachment 11.3 and transmit it to CNSI, maintain a copy of file in the Health Physics Supervisor Radwaste's office, jf.13.3 Complete Attachment 11.1, " User Checklist" for each HIC liner to be shipped to CNSI.

9.13.4 1.1 must be included in the shipping paperwork package with the shipmeat.

y@.13.5 Complete Attachment 11.2, " Certification Statement for Disposal of Polyethylene High Integrity containers" for each !!IC liner to be shipped to CNSI.

9.13.6 1.2 must be included in the shipping paperwork package with the shipment.

9.13.7 Storage conditions.

O Store the High Integrity Containers for no more than two years before use.

O Ensure that containers-are stored out of direct sunlight (if possible) and away from any other sources of ultraviolet radiation.

E23 Containers stored out-of-doors in direct sunlight must be used within one year of fabrication.

O Store all containers in such a way that the bottom is flat and that no weight is located over the manway/ fill port area.

RPP 07-102 Rev. O Page-29 of-35 l

1

9.13.7 Continued 0

Each container shall be stored with its designated closure assemblies to prevent t

mismatching.

note The design of the storage facility must preclude the possibility of a wet or damp environment and any prolonged exposure of the container to any source of ultraviolet light.

Following filling and closure of the O

container, it may be stored onsito prior to shipment for burial for up to five years.

9.13.8 Inspection Prior to Use.

visually inspect thread areas and seal O

areas to verify they are free of foreign matter that could impair the seal or thread engagement.

O Visually inspect the exterior surfaces for damage that may have occurred during transport or storage that could lessen container integrity.

O Inspect the manway lid for sufficient Closure.

9.13.9 Handling and Lift Requirements.

O Use only lift band (s), lift lugs and slings provided with the liner for lifting.

NOTE Due to the nature of the container material, some bowing and deformation may be evident during lifting.

RPP 07-102 Rev. O Page 30 of 35

9.13.9 Continued Inspect the underdrain assembly prior to 0

use if the container was dropped or banged against another object.

9.14 Additional Barnwell Waste Management Facility Requirements.

9.14.1 Each package of waste must be clearly labeled to identify whether it is Class "A" waste, Class

'B" waste, or Class "C" waste, in accordance with 10 CFR 61.55.

9.14.2 Arrange for Class

'B' and Class "C" waste received at the Barnwell facility in poly HICs to be disposed within approved disposal overpacks.

9.14.3 Void spaces within the waste and between the waste and its packaging shall be reduced to the extent practicable, but in EQ case shall less than eight-five percent (85%) of the capacity of the container be filled.

9.14.4 The Health Physics Supervisor Radwaste must apply for a variance request prior to shipment if the 85% fill requirement is HQI achievable.

NOTE The South Carolina DHEC and CNSI recognise that filters and irradiated hardware will EQI routinely meet the 85% condition.

Provided that containers of these wastes types are packaged to the fullest extent practicable, no written justification is required.

9.14.5 Complete Item 9 of the CNSI (Barnwell)

Radioactive Shipment Manifest to indicate the actual percentage full for all packages.

O List the value for the least filled container.

RPP 07-102 Rev. O Page 31 of 35

o 9.14.6 Ensure that a copy of the certificate of Compliance (C-of-C) for the approved High Integrity Container (s) as issued and amended by DHEC is en file with the Barnwell Regulatory Affairs / Licensing Department.

10.0 RECORDS REOUIREMENTS 10.1 The following Lifetime QA Records are generated by this procedure.

10.1.1 HIC User's Checklist 10.1.2 Certification Statement for Disposal of Polyethylene High Integrity Containers 10.2 The following Lifetime Non-QA Record is generated by this procedure.

10.2.1 Polyethylene High Integrity Container Certification Statement 11.0 ATTACHKENTS 11.1 HIC User's Checklist 11.2 Certification Statement for Disposal of Polyethylene High Integrity Containers 11.3 Polyethylene High Integrity Container Certiiication Statement RPP 07-102 Rev. O Page 32 of 35 l

9

+

. 1.1Q USER'S CHECKLIST Page 1 of 1

-Step Item Reference

• Initialt Date 1.

Containers Stored Properly (3.1.1-3.1.4) 2.

Proper Lifting Devices Used (3.1.6) 3.

Internals Inspected (3.2.1) 1 (where feasible) 4.

Externals Inspected (3.2.2) 5.

Container Serial (3.2.3)

Number 6.

Lifting Sling Properly Fitted (3.2.4) 7.

Lid Vent in Place (3.2.7) 8.

Lid Vent _ Orifice and Lid

_(3.2.8)

Vent Holes Free of Debris 9.' Lid Tool Available and (3.2.5-3.2.6)

Acceptable 10.

Waste _ Stream Sample OK (3.3.1) 11.

Waste Stream (3.3.2)

Temperature OF 12.

Mechanical Filters or Other (4.4) f Hardware Stabilized, if Applicable 13.

If 3/4a Quick Turn Lid is Used, i

Step 3.3.4 is Complete 14.

If Buttress-Thread Lid is Used, Step 3.3.5 is Complete 15 Container Surface (3.4.1.1)

CF Temperature 16.

Contents Less Than 1700F (3.4.1.2) 17.

Container Loaded In Cask (3.4.2) 18.

Total Cumulative Days of (3.1.3.3)-

Sunlight (UV) Exposure _

19.

Manufactured Date of High Integrity Container

• (3.34)

OPERATION COMPLETED

/

Signature Date-COMMENTS:

Complete form and forward with shipment'to:

Chem-Nuclear Systems, Inc.

P. O. Box 726 Barnwell, SC 29812 ATTENTION:

Scheduling Of.fice 4

RPP 07-102 Rev. a Page 33 of 35

o s

. 1.2Q Page 1 of 1 4

CERTIFICATION STATElGNT FOR DISPOSAL OF POLYETHYLENE HIGH INTEGRITY CONTAIERRS For the Polyethylene High Integrity container to be disposed of at Chem-Nuclear's Barnwell, South Carolina, Low-Level Radioactive Waste burial Facility and ictentified by serial numbers (Company) hereby certifies that its use of.such containers is in compliance with the certain certificate-of compliance issued by the South Carolina Department of Health and Environmental control, bureau of Radiological Health, No. DHEC-HIC-PL-001, and all amendments thereto (for current revision level of the Certificate of Comp 11anco No. DHEC-HIC-PL-001 and the South Carolina Radioactive Materials License No. 097 contact CNSI Licensing Director).

COMPANY:

BY:

ITS:

DATE:

RPP 07-102

.Rev. a' Page 34 of 35_

',' 1.30 Pago 1 of 1 POLYETHYLENE HIGH INTMULITY CONTAINER CERTIFICATION STATEKFJfT

(' Company')

hereby certifies that for each High Integrity Container purchased directly or indirectly from Chem-Nuclear Systems, Inc. ("CNSI'),

and for which disposal is proposed, attempted, or completed at the Barnwell, South Carolina, Low-Level Radioactive waste burial Facility, or for which any use in connection with the collection, storago, processing, or transportation of low-level radioactive wasto is proposed, attempted, or completed, it has read and will comply with:

(1) the Cortificato of comp 11anco issued by the South Carolina Department of Health and Environmental Control, Bureau of Radiological Health, No. DHEC-HIC-PL-001, and all amendments thereto (the *C of C") and (2) the Seuth Carolina Radioactivo Materiale License No. 097 (for current revision level of the Certificate of complianco No. DHEC-HIC-PL-001 and the South Carolina radioactivo Materials License No. 097 contact CNSI Licensing Director).

In order to comply with the user quality assuranco requirements (Item 5) of the C of C, the Company cortifies that it either has a quality assuranco program approved by the U. S. Nuclear Regulatory Commission under 10 C.P.R. Part f

50, Ap. B, (which applies to its proposed use and handling of.High Integrity Containers), has a quality control program operated under the specifications of the Naval Reactors Program, or that is has allowed CNSI to audit and approve of its existing quality assurance program for High Integrity Containers.

Company further certifies that it will not make any modification or change in the High Integrity container design, materials, or usage from the design, materials, and usage described in the C of C without prior approval of the South Carolina Department of Health and Environmental Control and without prior written not!.ce to CNSI.

Company understands that the High Intogrity Containers purchased either directly or indirectly from CNSI will be maintained, stored, transported, and used in accordance with each of the above requirements.

When the High Integrity Container is disposed at the Barnwell, South Carolina, Low-Level Radioactivo wanto Burial Facility, Company will sign the attached certification (Addendum

) prior to such disposal.

DATE:

COMPANY:

BY:

ITS:

RPP 07-102 Rev. a Page 35 of 35

t e

Attactunent II to NO 91-0107 Page 1 of 3 ATTACIMENT II

e Attachment II to NO 01-0107 Page 2 of 3 BACKGROUND During the period of July 1, 1990 to December 31, 1990 the Process Control Program (PCP) was revised, part of the revision included the incorporation of the PCP into plant Radiation Protection procedures.

The PCP was rewritten and retitled ' Solid Radwaste Process Control Program',

and issued as RPP 07-102, Revision 0.

The new PCP procedure provided guidance for controlling the processing and packaging of radioactive wastes and described current operating practices.

The Plant Safety Review Committee approved RPP 07-102, Revision 0 on October 3, 1990.

This revision removed the system description of the cement solidification system installed at WCGS.

Current and planned practice is not to solidify or encapsulate any waste streams.

All reference to the installed solidification system and its operating procedures was removed.

Other revisions included updating the PCP to reflect current regulatory requirements and current WCGS operating practices.

The information necessary to support the rationale for changing the additional processing steps in the PCP is provided by the following:

PROCESSING RPP 07-102 only addresses the methods used for processing wet low-level radioactive waste as required by 10 CPR 61.

Discussion of preparation and shipping of radiocctive waste has been included in a separate procedure.

RPP 07-120, "Preparaticn and Shipment of Radioactive Waste".

RPP 07-120 addresses state burial requirements and Department of Transportation (DOT) requirements.

As previously discussed, current and planned practice at WCGS is not to solidify or encapsulate any waste streams.

Therefore reference to solidification performed by WCGS has been deleted.

RPP 07-102 still maintains that dewatering capabilities are verified by a management revj =w of the Nuclear Regulatory Commission (NRC) approved Vendor Topical Repor --

and Operating and Testing Procedures.

This review will assure that the vendor's operations and requirements are compatible with the responsibilities and operation of the plant.

HIGH INTEGRITY CONTAINERS (HICs)

HICs are specified to be compatible for specific wastes.

WCGS ensures, through a review of the HIC's Certificate of Compliance, that the as generated wasta is compatible with the container, as described by its Certificate et Compliance.

RPP 07-102 also specifies that inspection, handling and loading operations are to be performed in accordance with Chem-Nuclear Systems Incorporated.

(CNSI) FO-AD-002,

' Operating Guidelinec For USE of Polyethylene High Integrity Containers'.

The physical description of a HIC is no longer included because this information is included in the Certificate of Compliance for the specific HIC.

In addition, RPP 07-102 lista those general requirements normally verified by review of the HIC's Certificate of Compliance and State /NRC approval to ensure that the as generated waste is compatible with the container.

l l

4 Attachment II to NG 91-c107 Page 3 of 3 o

i The requirements in the PCP for the maximum allowable free standing liquid in a HIC has been changed from one half percent (0.52) of the vaste volume to one percent (12) of the waste volume as specified in 10 CFR 61.56(b)(2).

Compliance with free standing liquid requirements is now met through compliance with procedure EPP 07-130

" Verification of Free Standing Water in High Integrity Containers' FILTER CARTRIDGE !!ANDLING Encapsulation of filter cartridges has been deleted from the PCP.

Filter packaging and disposal is still performed in accordance with the latest state approved Certificate of Compliance.

As discussed previously, RPP 07-102 lists those general requirements normally verified by review of the HIC's Certificate of Compliance and State /NRC approval.

Filter transfer is now addressed in procedure RPP 07-111

" Handling Filter Cartridges" which provides the instructions for handling, processing and packaging cartridge filters.

RPP 07-130 provides instructions on verification of the free standing water criteria and RPP 07-120 provides for classification of the radioactive vastes.

The filter treatment method and determination sections have been deleted because they had addressed absorption methods which are not performed by WCGS.

Processing of filter cartridges at WCGS currently involves only devatering.

RPP 07-130 and RPP 07-111 provide the instructions on treatment and verification methods for dewatering.

In conclusion.

it has been determined that the aforementioned changes maintain the overall conformanc( of the solidified waste product to existing requirements of applicable regulations.

I