ML061370196
ML061370196 | |
Person / Time | |
---|---|
Site: | Catawba ![]() |
Issue date: | 11/06/2003 |
From: | Vaught D Duke Energy Carolinas |
To: | Office of Nuclear Reactor Regulation |
References | |
NEDL SDQA "C" | |
Download: ML061370196 (103) | |
Text
NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM REVISION NUMBER 14 ISSUE DATE _11/20/03___
Prepared by/ Date: ___David Vaught/_11/6/03____ Review by/ Date: _Graham Johnson/_11/6/03___
NGO Radwaste Staff NGO Radiation Protecti on CATAWBA MCGUIRE OCONEE Reviewed By/ Date Barry Kimray/ 11/12/03___
Station Radiation Protection Reviewed By/ Date _Doug Williams/ 11/13/03__
Station Radwaste Chemistry Approved By/Date Fred Smith/ 11/18/03___
Chemistry Manager Approved By/Date Mike Glover/ 11/18/03____
Station Manager Reviewed By/ Date: __Bob Beckham/ 11/10/03__ Station Radiation Protection Reviewed By/ Date ___John Gabbert/ 11/10/03_____
Station Radwaste Chemistry Approved By/Date __ __Jeff Bramblett/ 11/10/03__ Chemistry Manager Approved By/Date _Tom Harrall/ 11/12/03__
Station Manager Reviewed By/ Date: Rick Bowser/ 11/12/03___
Station Radiation Protection Reviewed By/ Date _Sheila Constance/ 11/12/03_
Station Radwaste Chemistry Approved By/Date Bryon Norris/ 11/14/03___
Chemistry Manager Approved By/Date Bruce Hamilton/ 11/19/03___
Station Manager Issued By: ____Dewey P Rochester__________________________
Technical Manager, Nuclear Chemistry
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP i NEDL SDQA "C" TABLE OF CONTENTS
- 1. INTRODUCTION.........................................................................................................................1 1.1 Purpose...................................................................................................................................1 1.2 Radioactive Waste Process Control Program Description.....................................................2 1.3 Radioactive Waste PCP Manual Contents.............................................................................2
- 2. APPLICABILITY.........................................................................................................................4 2.1 Liquid and Wet Radioactive Waste Disposal........................................................................4 2.2 Mixed Waste Disposal...........................................................................................................4 2.3 Radioactive Waste Oil Disposal............................................................................................5
2.4 Radioactive
Waste Interim Storage.......................................................................................6
- 3. REGULATORY REFERENCES................................................................................................6
3.1 Regulatory
Requirements.......................................................................................................6 3.2 Regulatory Guidance.............................................................................................................7 4. DUKE ENERGY PROGRAMMATIC REFERENCES...........................................................8
4.1 Oconee
Technical Specification 5.6.2 "Annual Radiological Environmental Operating Report"...................................................................................................................................8 4.2 Site-specific Selected Licensee Commitments......................................................................8 4.3 Oconee UFSAR Chapter 11...................................................................................................8
4.4 Catawba
UFSAR Chapter 11.................................................................................................8 4.5 McGuire UFSAR Chapter 13.................................................................................................8 4.6 Duke Power Company QA Program "Topical Report".........................................................8 4.7 "CNS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program"....8 4.8 "MNS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program"...8 4.9 "ONS 10 CFR Part 61 Waste Classification and Waste Form Implementation Program"...8 4.10 Duke Energy Information Retention Policy..........................................................................8 4.11 NSD 701 "Records Management".........................................................................................9 4.12 NSD 703 "Administrative Instructions for Technical Procedures".......................................9 4.13 Catawba, McGuire & Oconee Environmental Work Practice (EWP) 2.8 "Used Oil"..........9 4.14 Catawba, McGuire & Oconee EWP 2.9 "Mixed Waste"......................................................9 RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP ii NEDL SDQA "C" 4.15 Supply Chain Document (SCD) 510 "Approved Suppliers List"..........................................9 4.16 SCD 520 "Audits of Suppliers".............................................................................................
9 4.17 SCD 285 "Procurement of QA Condition 2, 3, and 4 Items"................................................9 4.18 Operating Experience (OE) & Problem Investigation Process (PIP)....................................9
- 5. DEFINITIONS..............................................................................................................................9
5.1 Safety
Analysis Report (SAR)...............................................................................................
9 5.2 Selected Licensee Commitments (SLCs)...............................................................................9 5.3 10CFR Part 61 "Licensing Requirements for Land Disposal of Radioactive Waste".........10 5.4 Free Standing Liquid (FSL).................................................................................................
10 5.5 Liquid Radioactive Wastes..................................................................................................
10 5.6 Wet Radioactive Wastes......................................................................................................10 5.7 Solidification........................................................................................................................10 5.8 High Integrity Container (HIC)...........................................................................................11 5.9 Dewatering...........................................................................................................................11 5.10 Unwatering (Gross Dewatering)..........................................................................................11 5.11 Mixed Waste........................................................................................................................11 5.12 QA Approved Supplier List.................................................................................................
12 5.13 Waste Batch.........................................................................................................................12 5.14 Waste Batch Mixing............................................................................................................12 5.15 Process Parameters...............................................................................................................12 5.16 Boundary Conditions/ Acceptance Criteria.........................................................................12 5.17 Topical Report (PIPs O-03-0624, M-03-2515, C-03-3385)................................................13
- 6. RESPONSIBILITIES.................................................................................................................13 6.1 Nuclear General Office........................................................................................................13 6.2 Nuclear Safety Review Board..............................................................................................14
6.3 Nuclear
Stations...................................................................................................................15
- 7. ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS.................................16 7.1 PCP Manual Administration................................................................................................16 7.2 PCP Revision Reports to the NRC......................................................................................16 7.3 PCP Audit Process...............................................................................................................16 RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP iii NEDL SDQA "C" 7.4 PCP Manual Revision Record Retention Requirements......................................................17 7.5 Periodic cross-checks & comparisons (PIP O-03-0624 CAPR)..........................................17 7.6 PCP Implementing Procedure Requirements.......................................................................17
- 8. APPROVAL PROCESS FOR QA APPROVED SUPPLIERS..............................................18
8.1 Technical
Review and Approval..........................................................................................18 8.2 QA Supplier Evaluation.......................................................................................................18 8.3 QA Approved Supplier Program.........................................................................................18
- 9. PCP REQUIREMENTS FOR VENDOR PROCESSES AND SERVICES..........................19
9.1 Topical
Report (or equivalent).............................................................................................
19 9.2 10CFR61 Waste Form Compliance.....................................................................................19 9.3 10CFR61Waste Classification Compliance.........................................................................19 9.4 Minimum Requirements for Onsite Process Vendors.........................................................20 9.5 Minimum Requirements for Offsite PCP Process Vendors.................................................21
- 10. PCP SOLIDIFICATION PROCESS DESCRIPTION...........................................................21 10.1 Waste Characterization........................................................................................................21 10.2 Mixed Waste Characterization.............................................................................................2 1 10.3 Minimum Solidification Acceptance Criteria......................................................................22 10.4 Representative Waste Sample..............................................................................................2 2 10.5 Bench Scale Test Solidification...........................................................................................
23 10.6 Full Scale Solidification.......................................................................................................26 10.7 Product Verification of Full Scale Solidification.................................................................26 10.8 Inoperable Equipment (SLC Remedial Action Requirements)...........................................28 10.9 Solidification Document Retention......................................................................................28
- 11. PCP DEWATERING PROCESS DESCRIPTION.................................................................29 11.1 Dewatering Mechanical Filters (e.g., cartridge, bag, membrane)........................................29 11.2 Dewatering Slurries.............................................................................................................30 11.3 Additional Conservatism in Slurry Dewatering Procedures to Address Variation from the Topical Report (PIP O-03-0624, M-03-2515, C-03-3385)..................................................31 11.4 Dewatering Process Requirements......................................................................................33 11.5 Product Verification.............................................................................................................34 RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP iv NEDL SDQA "C" 11.6 Inoperable Equipment (SLC Remedial Action Requirements)...........................................37 11.7 Dewatering Document Retention.........................................................................................37
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 1 of 37 Rev.14 NEDL SDQA "C"
- 1. INTRODUCTION
1.1 Purpose
The Duke Energy Radioactive Waste Process Control Program Manual addresses all the requirements for the "Solid Radioactive Waste" section in Selected Licensing Commitment 16.11, "Radiological Effluent C ontrols" at each of the Duke Energy nuclear stations.
1.1.1 The Process Control Program (PCP) describes the administrative and operational controls used for the solidif ication of liquid or wet radioactive wastes and the dewatering of wet radioact ive wastes. Its purpose is to assure that the final disposal waste product meets applicable Federal, State and Disposal Site waste form requirement s for burial at a 10CFR61 licensed Low Level Waste (LLW) disposal site per the "Commitment" section of the Solid Radioactive Wastes section in SLC 16.11.
1.1.2 Waste
processing (solidification or dewatering as described below) equipment and services may be provided by Duke Energy or vendors. Any process used shall meet all applicable requirements of the Process Control Program.
1.1.3 This Corporate PCP section specifically describes the processes required to meet the Remedial Action requirements and Surveillance Requirements of ONS SLC 16.11.5, MNS SLC 16.11.11 a nd CNS SLC 16.11-11. These are summarized below:
1.1.3.1 Actions required prior to the next shipment for disposal of solidified or dewatered wastes if applicable regulatory requirements for solidified or dewa tered wastes are not satisfied (See Corporate PCP Sections 10 & 11).
1.1.3.2 Actions required prior to next solidification for shipment of waste for disposal at a 10CFR61 disposal site if a solidification test fails to verify solidification (See Corporate PCP Section 10).
1.1.3.3 Actions required whenever so lidification or dewatering for disposal is not performed in accordance with the PCP (See Corporate PCP Sections 10 & 11).
1.1.3.4 Actions required with the solid waste equipment incapable of meeting SLC 16.11 Solid Radioactive Waste requirements, or not in service (See Corporate PCP Sections 10 & 11).
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 2 of 37 Rev.14 NEDL SDQA "C" 1.1.3.5 The Surveillance Requirement pert ains only to solidification and is contained in section 10. "The Process Control Program shall be used to verify the Solidification of at least one representative test specimen from at least every tenth batch of each type of radioactive waste to be solidif ied for disposal at a 10CFR61 disposal site per the CO MMITMENT of this SLC."
1.1.4 It is the responsibility of the LLW generator to ensure that PCP requirements are met and that the condition of the wa ste is acceptable upon arrival at the disposal site.
1.2 Radioactive
Waste Process Control Program Description The Radioactive Waste PCP Manual meets NRC requirements for a Process Control Program. It is published as a manual and controlled copies are maintained in the following locations: Online PCP Manual: NEDL (Portal)/Licensing/ELL Document Nuclear General Office (NGO) Chemis try copy of the PCP Manual: NGO Chemistry Satellite File
1.3 Radioactive
Waste PCP Manual Contents The PCP manual is comprised of:
1.3.1 CORPORATE
PROCESS CONTROL PROGRAM The Corporate Process Control Program (PCP) describes the technical and operational requirements that shall be me t by each nuclear station to ensure final solidification or de watering radioactive waste products meet applicable federal and state disposal regulations. It also includes documentation of the required approvals for the current revision of the Corporate PCP. The requirements comprise a system wide program and are applicable to all of the nuclear stations as defined in their individual PCP program appendices described below.
1.3.2 APPENDIX
A "OCONEE NUCLEAR STATION PCP" Each station has a site specific PCP describing the Nuclear Generation documents used for implementing the requirements of the Corporate PCP. The station PCPs are contained in APPENDIX A, B and C. Each site PCP contains the following:
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 3 of 37 Rev.14 NEDL SDQA "C" Documentation of the required approvals for the current revision of the station PCP per APPENDIX E A list of Nuclear Generation procedures used to implement the Corporate PCP requirements A list of drawings showing plant radwaste systems interfaces with solidification and dewatering equipment used to meet the Corporate PCP Exceptions to the Corporate PCP
1.3.3 APPENDIX
B "Mc GUIRE NUCLEAR STATION PCP" (for content see 1.3.2) 1.3.4 APPENDIX C "CATAWBA NUCLEAR STATI ON PCP" (for content see 1.3.2) 1.3.5 APPENDIX D "APPROVED SUPPLIERS OF PCP SERVICES" This table contains the following: List of vendors approved for PCP services Describes approved services and specific requirements
1.3.6 APPENDIX
E "PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS" This table describes who shall perform the reviews and approvals for each section of the PCP Manual.
1.3.7 APPENDIX
F "ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS" This appendix is a comprehensive administrative guideline for control and distribution of the PCP manual and its supporting documents. Its contents are summarized below.
1.3.7.1 Administrative processes for the PCP manual Revisions, reviews and approvals Electronic publication 1.3.7.2 Administrative processes for Nuclear Generation implementing procedures Revisions Retention requirements RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 4 of 37 Rev.14 NEDL SDQA "C" 1.3.7.3 Administrative processes for use of vendor documents Revision review and evaluation for impact Control, distribution and retention of vendor documents
1.3.8 APPENDIX
G "WASTE PROCESSOR CHECKLIST" This is a template of technical re view criteria used by NGO Radiation Protection and Chemistry to pre-appr ove and renew radwaste vendors for inclusion in the QA Approved Supplier List.
1.3.9 APPENDIX
H "REVISION
SUMMARY
- LICENSEE INITIATED CHANGES" This appendix summarizes changes for current PCP manual revisions for reference during reviews and for record retention.
- 2. APPLICABILITY
2.1 Liquid
and Wet Radioacti ve Waste Disposal
2.1.1 Final
Safety Analysis Report Chapter 16, Selected Licensee Commitments, Section 11 requires that the Solid Radwaste System or an approved alternative process be used in accordance with a PCP for the solidification of liquid or wet radioactive wastes or the dewatering of wet radioactive wastes to be shipped for direct disposal at a 10CFR61 licensed disposal site such that the final product meets all applicable disposal site requirements.
2.1.2 These
"Process Control Program" requirements are applicable to all liquid or wet radioactive wastes that are being prepared for direct disposal at a 10CFR61 LLW disposal facility.
2.1.3 Radioactive
wastes shipped for off site processing in accordance with the processor's specifications and transportation requirements are not required to be solidified or dewatered to meet disposal requirements and are not subject to the solidification or dewatering requirements of this PCP.
2.2 Mixed
Waste Disposal
2.2.1 Environmental
Work Practice 2.9 "Mixed Waste" defines the Mixed Waste program at Duke Energy nuclear stations.
2.2.2 The PCP is only applicable when Mixed Waste is solidified for disposal at a 10CFR61 disposal site.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 5 of 37 Rev.14 NEDL SDQA "C" 2.2.3 NGO Chemistry shall approve the use of solidification for disposal of Mixed Waste. 2.2.4 If Mixed Waste is to be disposed of as LLW at a 10CFR 61 disposal site by rendering it non-hazardous using solidificat ion, the solidificati on shall be done according to PCP requirements.
2.2.5 Disposal
of Mixed Waste at a Low Level Radioactive Waste disposal site is prohibited except under the following conditions:
2.2.5.1 The waste shall meet the 40 CFR part 266 exemption criteria, 10 CFR part 61 disposal requirements and all applicable state and disposal site requirements.
2.2.5.2 Approval for disposal shall be obtained from the disposal site prior to disposal. (e.g., Barnwell):
A. No mixtures of radioactiv e waste and hazardous waste (Mixed Waste), as defined by 40CFR261 and S.C.
Management Registration 61-79.261, are acceptable for burial in Barnwell.
B. However, a Mixed Waste which was classified as hazardous solely because it exhibited one or more characteristics
defined in 40CFR261 Subpart C, but has been treated in a manner such that it no longer exhibits any of these characteristics, will be reviewed on a case-by-case basis for burial acceptance.
2.2.6 All vendors supplying solidification services for Mixed Waste shall meet the requirements of applicable PCP sect ions and be listed in Appendix D "Approved PCP Service Suppliers".
2.3 Radioactive
Waste Oil Disposal
2.3.1 Radioactively
contaminated oil is to be managed as described in the EWP 2.8 "Used Oil".
2.3.2 Each disposal site defines the acceptable threshold fo r incidental levels of waste petroleum-based oil (e.g., less than 1% by volume). Solidified waste
containing oil shipped to a 10CFR61 disposal site shall meet the applicable requirements of this Process Control Program and all applicable disposal site acceptance criteria.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 6 of 37 Rev.14 NEDL SDQA "C" 2.3.3 If a disposal site accepts greater than incidental concentrations of oil to be solidified for disposal, an oil-specific procedure that meets the requirements of this PCP and the acceptance criteria of that disposal site shall be used (e.g., on a case-by-case basis, SCDHEC may approve solidification of synthetic oils for burial at the Barnwell, SC LLW disposal site).
2.4 Radioactive
Waste Interim Storage Nuclear Generation procedures shall be established to ensure that all of the following interim storage requirements are met.
2.4.1 Any processed (i.e., solidified or dewatered) radioactive waste that is stored for an interim period in a disposal contai ner shall be packaged such that there is no interaction between th e waste and its container.
2.4.2 If applicable, Certificates of Compliance shall be maintained at each station for all waste disposal containe rs used for interim storage.
2.4.3 Vendor
supplied containers used for st orage shall be ha ndled and stored according to applicable guidance in vendor procedures, including chemical compatibility requirements.
- 3. REGULATORY REFERENCES
3.1 Regulatory
Requirements The use of and content of the PCP addresses requirements found in the following regulations:
3.1.1 10CFR20, "Standards for Protec tion Against Radiation" 3.1.2 10CFR50, "Domestic Licensing of Production and Utilization Facilities" 3.1.3 10CFR61, "Licensing Requirements for Land Disposal of Radioactive Waste" 3.1.4 l0CFR7l, "Packaging and Transporta tion of Radioactive Materials" 3.1.5 40CFR, "Protection of Environment" 3.1.6 40 CFR Part 266 "Storage, Treatment, Tr ansportation, and Disposal of Mixed Waste" 3.1.7 Licensed radioactive wast e burial site criteria RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 7 of 37 Rev.14 NEDL SDQA "C"
3.1.8 State
hazardous waste regulations
3.2 Regulatory
Guidance In order to assure compli ance with the above regula tions, the NRC has provided guidance in the following documents:
3.2.1 NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants" 3.2.2 NUREG-0452, "Standard Technical Specifications for Westinghouse PWR's" (Superseded by NUREG 1431) 3.2.3 NUREG-1431 "Standard Technical Specifications Westinghouse Plants" 3.2.4 NUREG-1430 "Standard Technical Specifications Babcock and Wilcox Plants" 3.2.5 NUREG-800 "Standard Review Plan
", Section 11.4 "Solid Waste Management Systems"
3.2.6 NUREG
800, Section 11.4, Appendix -A, "Design Guidance for Temporary Onsite Storage of Low Level Radioactive Waste"
3.2.7 Branch
Technical Position - ETSB 11-3, "Design Guidance of Solid Radioactive Waste Management Systems" 3.2.8 NRC Review Criteria for Solid Waste Management Systems
3.2.9 Regulatory
Guide 1.143, "Design Gu idance for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Plants" 3.2.10 NRC "TECHNICAL POSITION ON WAS TE FORM" Revision 1 (January 1991) 3.2.11 ANSI/ANS-40.37-1993 "mobile radioactive waste processing systems" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 8 of 37 Rev.14 NEDL SDQA "C"
- 4. DUKE ENERGY PROGRAMMATIC REFERENCES
4.1 Oconee
Technical Specification 5.6.2 "Annual Radiological Environmental Operating Report" 4.2 Site-specific Selected Licensee Commitments
4.2.1 Catawba
SLC 16.11-11 "Solid Radioactive Waste"
4.2.2 Catawba
SLC 16.11-16 "Annual Radiological Environmental Operating Report and Radioactive E ffluent Release Report"
4.2.3 Catawba
SLC 16.13.2 "Technical Review and Control"
4.2.4 McGuire
SLC 16.11.11 "Solid Radioactive Waste"
4.2.5 McGuire
SLC 16.11.17 "Radioactive Effluent Release Report"
4.2.6 McGuire
SLC 16.13.2 "Technical Review and Control"
4.2.7 Oconee
SLC 16.11.5 "Solid Radioactive Waste"
4.2.8 Oconee
SLC 16.13.2 "Technical Review and Control"
4.3 Oconee
UFSAR Chapter 11
4.4 Catawba
UFSAR Chapter 11
4.5 McGuire
UFSAR Chapter 13 4.6 Duke Power Company QA Program "Topical Report" 4.7 "CNS 10 CFR Part 61 Waste Classifica tion and Waste Form Implementation Program" 4.8 "MNS 10 CFR Part 61 Waste Classificati on and Waste Form Implementation Program" 4.9 "ONS 10 CFR Part 61 Waste Classificati on and Waste Form Implementation Program" 4.10 Duke Energy Information Retention Policy Ref: (Legal 109, 10CFR20 Appe ndix G (III.A.3), 10CFR61.80)
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 9 of 37 Rev.14 NEDL SDQA "C" 4.11 NSD 701 "Records Management" 4.12 NSD 703 "Administrative Instructions for Technical Procedures" 4.13 Catawba, McGuire & Oconee Environmental Work Practice (EWP) 2.8 "Used Oil" 4.14 Catawba, McGuire & Oconee EWP 2.9 "Mixed Waste" 4.15 Supply Chain Document (SCD) 510 "Approved Suppliers List" 4.16 SCD 520 "Audits of Suppliers" 4.17 SCD 285 "Procurement of QA Co ndition 2, 3, and 4 Items" 4.18 Operating Experience (OE) & Problem Investigation Process (PIP) 4.18.1 G-99-00349 (NGO Radwaste Support PCP evaluation) 4.18.2 C-99-05094 (SLC 16.11 Issues related to PCP requirements) 4.18.3 G-00-401 (QA Audit -General Office Assessment SA-00-29(GO) (RA))
4.18.4 O-00-4680 (ONS filter dewatering procedure use) 4.18.5 C-01-02522 (2001 CNS NRC Audit) 4.18.6 O-01-01067 (Filter HIC dewa tering clarification) 4.18.7 G-02-00272 (QA Audit -Assessment GO-02-31(NPA) NSD) 4.18.8 O-03-0624, M-03-2515, C-03-3385 (ONS FS L Failure Root Cause)
- 5. DEFINITIONS
5.1 Safety
Analysis Report (SAR)
The station's Technical Specifi cations (Tech Specs) updated fi nal safety analysis report, licensee commitments, safety evaluation reports and the facility operating license.
5.2 Selected
Licensee Commitments (SLCs) Commitments to control important plant equipment and operating conditions not controlled elsewhere. Operational commitments which are to be removed from existing station Tech Specs may be included in the SLC program. Also included in this program RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 10 of 37 Rev.14 NEDL SDQA "C" can be selected NRC commitments contained in licensing documents such as the station's SERs, LERs, violation responses , generic letter and bulletin responses, submittal documents and other Duke letters to the NRC.
5.3 10CFR
Part 61 "Licensing Requirements fo r Land Disposal of Radioactive Waste" This NRC regulation requires that low-level radioactive waste (LLW) meet certain waste form acceptance criteria in order to be received for disposal at NRC and Agreement State licensed radioactive waste disposal sites.
5.4 Free Standing Liquid (FSL)
FSL is liquid that is in a disposal co ntainer but is not bound by the waste in the container. FSL is the liquid available for rele ase if disposal container integrity is lost (e.g., punctured). The amount of FSL in a radioa ctive waste disposal container shall be less than a specified threshold in order to meet 10CFR61, state and disposal site requirements for disposal.
5.5 Liquid
Radioactive Wastes Radioactive wastes comprised primarily of water containing a combination of dissolved and suspended solids (e.g., evaporator concentrates, lab wastes, floor and equipment drain water, laundry, wet waste decant or drainage, etc.).
5.6 Wet Radioactive Wastes Wet radioactive wastes are solid radioactive wastes containing l oosely bound liquid that can collect in the disposal container as FSL (e.g., slurry wastes are comprised primarily of solid particles suspended in loosely bound in terstitial water, spent mechanical filters are solid materials that are adsorb ent or porous and retain liquid).
5.7 Solidification
Solidification is a pr ocess that converts radioactive waste into a product meeting 10CFR61, State and disposal site requiremen ts for waste-form stability and FSL. Solidification is accomplished by mixing measured amounts of liquid or wet radioactive waste, binder and required additives that, after sufficient curing time, produce a solid homogeneous, freestanding monolith. At the end of the curing period, the absence of excessive FSL is verified either by confirmation that the PCP was followed or by physical verification/testing.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 11 of 37 Rev.14 NEDL SDQA "C" 5.8 High Integrity Container (HIC)
Disposal containers that have been a pproved by the NRC for disposal of Class A unstable, Class B or Class C LLW and meet the long term stability requirements of 10CFR61 and the disposal site.
5.9 Dewatering
Dewatering as used in this document is the removal of liquid using a process that is required to meet the requirements of th is PCP. Dewatering removes the loosely bound liquid from a wet radioactive waste such that accumulation of Fr ee Standing Liquid in the disposal container is un likely to approach the disposal limit threshold values as defined by applicable regulations and disposal site criteria. NRC regulations require that the process used to dewater radioactive wastes to meet disposal criteria shall be governed by a PCP.
5.9.1 10CFR61
FSL criteria requires less than 0.5% FSL by waste volume per container or less than 1.0% FSL if a hi gh integrity container (HIC) is used.
5.9.2 Typically, liquid and wet wastes are pre-st aged in vented tanks or containers and are therefore degassed prior to th e dewatering process. However, all vendor-required venting practi ces should be adhered to.
5.10 Unwatering (Gross Dewatering) Unwatering as used in this document is the removal of water using a process that is not required to meet the requirements of this PCP. Unwatering removes loosely bound excess or freeboard water from wet radioactive wastes such that only the requirements for transportation set forth in 49CFR are satisfied (e.g., unwatering may be used to prepare waste for shipment to an approved offsite processor who will perform additional processing that will meet the final disposal requirements).
5.11 Mixed Waste Defined in Resource Conservation Recovery Act (RCRA) as amended by the Federal Facility Compliance Act of 1992, a Mixed Waste contains both RCRA hazardous waste and source, special nuclear, or byproduct material subject to the Atomic Energy Act of 1954, as amended. The use of solidifica tion to render Mixed Wastes non-hazardous shall ensure that the final product meets all waste form requirements applicable to radioactive waste disposal at a 10CFR61 disposal site (R ef: 3.1.6. "40 CFR Part 266").
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 12 of 37 Rev.14 NEDL SDQA "C" 5.12 QA Approved Supplier List Radwaste vendors approved to provid e PCP processing are included on the QA Approved Supplier List and are subject to the requirements and audits of that program.
5.13 Waste Batch A "batch" shall be defined as an isolated quantity of waste to be processed having essentially consistent physical and chemical characteristics.
5.14 Waste Batch Mixing A Waste Batch shall be adequately mixed using a proceduralized process such as agitation via mixers, air spargi ng or recirculating flow which meets a specified minimum rate that has been determined to provide a representative sample for the vessel.
5.15 Process Parameters Those conditions measured or observed during a solidification or de watering process to ensure an acceptable product. These are determined for each waste type and are specific to the process method used.
5.16 Boundary Conditions/ Acceptance Criteria 5.16.1 Solidification Boundary Conditions or Acceptance Criteria are defined as, the bounding numerical values for solidification process parameters that produce an acceptable product.
5.16.1.1 The Boundary Conditions are verified by using a Bench Scale Test Solidification.
5.16.1.2 A Bench Scale Test Solidification is performed on a small representative sample of the Waste Batch using the prescribed formulation and conditions that model those parameters critical to the full scale solidification process 5.16.1.3 The Bench Scale Test product is then verified to meet the acceptance criteria for that waste form.
5.16.1.4 For Mixed Waste solidification, the Boundary Condition values also ensure that the final so lidified product is rendered non-hazardous and are verified through lab testing of the Bench Scale Test product.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 13 of 37 Rev.14 NEDL SDQA "C" 5.16.2 Dewatering Boundary Conditions or Acceptance Criteria are defined as the bounding numerical values for process parameters that ensure free standing liquid requirements are met.
5.16.2.1 Media: Acceptance Criteria for dewatering process media in disposal containers (e.g., HICs) have been determined by vendor tests using real or simulated waste to demonstrate the adequacy of the dewatering process for each combination of waste type and container. These tests are documented in dewatering Topical
Reports, or equivalent, that sha ll be approved by the NRC before the containers are certified for use. The Acceptance Criteria are then incorporated into the dewatering procedures for each combination of waste type and container.
5.16.2.2 Filters: Acceptance criteria for mechanical filters (e.g., cartridge, bag, membranes, etc.) are derived from tests performed on the various types of filters in use. Tests performed by Duke Energy should be documented in a retrievable manner (e.g., PIP, Memo in Master file, etc.). Acceptance criteria are then incorporated into the applicable procedure for each filter type (e.g., drainage time, drainage conditions, etc.).
5.17 Topical Report (PIPs O-03-0624, M-03-2515, C-03-3385)
A Topical Report provides the basis for a PCP technology & process. It documents test results that demonstrate regulatory requirements were met during the regulatory required testing for solidification or dewatering t echnologies and processes. All currently approved processes developed to dewater or solidify waste have been approved by the NRC based their review of the Topical Report for that process. T opical report testing was designed to envelope the worst case de watering scenarios given the industry's then current practices. As with any topical based program, the critical conditions and parameters identified during testing are incorporated into the implementing process with enough conservative margin to ensure success if you operate within the enveloping conditions and assumptions of the tests performed. When actual conditions vary from the conditions in the specific tests performed for the Topical Report, the correlation with the Topical testing is diminished and degree of conservatism must increase to compensate.
- 6. RESPONSIBILITIES
6.1 Nuclear
General Office 6.1.1 NGO Chemistry is the owner, sponsor and administrator for the PCP including the following activities:
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 14 of 37 Rev.14 NEDL SDQA "C" 6.1.1.1 Revises and publishes PCP Manual per APPENDIX F "Administration of the PCP and Support Documents" 6.1.1.2 Technical contact for PCP issues 6.1.1.3 Ensures corporate Chemistry program complies with applicable PCP requirements 6.1.1.4 Supports nuclear site Chemistry programs in complying with applicable PCP requirements 6.1.1.5 Provides review and approval of PCP service providers 6.1.1.6 Authors and approves PCP Manua l revisions per APPENDIX E "PCP Manual Review and Approval Requirements"
6.1.2 Nuclear
General Office Radiation Protection (RP) 6.1.2.1 Ensures corporate RP program complies with applicable PCP requirements 6.1.2.2 Supports nuclear site RP programs in complying with applicable PCP requirements 6.1.2.3 Provides review and approval of radioactive waste processors 6.1.2.4 Reviews PCP revisions per APPE NDIX E "PCP Manual Review and Approval Requirements"
6.1.3 Nuclear
Supply Chain 6.1.3.1 Maintains PCP vendors in Approved QA supplier list 6.1.3.2 Communicates NUPIC QA audits and issues related to PCP vendors to NGO Chemistry Radwaste support staff
6.2 Nuclear
Safety Review Board
6.2.1 Audits
of the Process Control Program and implementing procedures for Solidification of radioactive wastes shall be performed under the cognizance of the NSRB per Duke Power Company QA Program "Topical Report".
6.2.2 Copies
of revisions to the Duke Energy Radioactive Waste PCP manual are reviewed by the NSRB per SLC 16.13.2 "Technical Review and Control" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 15 of 37 Rev.14 NEDL SDQA "C"
6.3 Nuclear
Stations The PCP applies to all liquid or wet radioactive waste generated at the nuclear site when it is solidified or dewatere d for direct disposal at a 10CFR61 disposal site. Any group that has responsibility for activities that generate or manage these wastes shall ensure their programs and processes comply with and support compliance with the applicable portions of the PCP. The following responsib ilities are currently identified within specific groups or positions, but will be applicable to any group that has the responsibility. Any changes in these responsibilities and the groups to whom they are assigned should be evaluated for impact and potential incorporation into the PCP Manual.
6.3.1 Station
Manager approves PCP revisions per APPENDIX E "PCP Manual Review and Approval Requirements"
6.3.2 Station
Line Management responsible for programs impacting the PCP ensures those programs comply with the site PCP. Currently identified program owners:
6.3.2.1 Station Chemistry Manager approves PCP revisions per APPENDIX E "PCP Manual Review and Approval Requirements" 6.3.2.2 Station Chemistry General Supervisors ensure Chemistry programs and resources comply with and support the PCP
Manual, (e.g., site PCP, dewatering procedures) 6.3.2.3 Station RP Management ensures RP programs and resources comply with and support the PCP Manual, (e.g., site PCP, filter
dewatering, shipping process inte rface with PCP activities)
6.3.3 Station
Staff and Line Supervisors ensure applicable area-specific procedures and activities comply with the PCP 6.3.3.1 Station Chemistry Staff A. Ensures site PCP complies with the Corporate PCP B. Ensures Chemistry dewatering or solidification procedures comply with the Corporate PCP C. Serves as Subject Matter Expert on Chemistry PCP processes at the site RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 16 of 37 Rev.14 NEDL SDQA "C" D. Reviews PCP revisions per APPENDIX E "PCP Manual Review and Approval Requirements" 6.3.3.2 Station Radiation Protection Sta ff and/or RM&C Supervision A. Ensure RP procedures comply with applicable PCP Manual requirements (e.g., filter de watering/disposal, shipping procedures, shipping and disposal paperwork)
B. Reviews PCP revisions per APPENDIX E "PCP Manual Review and Approval Requirements"
6.3.4 Station
Technicians ensure current documents are used to implement PCP-related activities 6.3.4.1 Station Chemistry Technicians implement applicable portions of the site PCP, (e.g., dewatering process media) 6.3.4.2 Station Radiation Protection Technicians implement applicable portions of the site PCP, (e.g., dewatering mechanical filters)
6.3.5 Regulatory
Compliance incorporates the PCP revision summary report into the site Annual Effluent report.
6.3.6 Manager, Safety Assurance assures the performance of a review by a knowledgeable individual/organization of changes to the Process Control Program per SLC 16.13.2
- 7. ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS 7.1 PCP Manual Administration See APPENDIX F "Administration of the PCP and Support Documents" 7.2 PCP Revision Reports to the NRC Revisions to the PCP shall be reported to the NRC each year as described in APPENDIX F "Administration of the PCP and Support Documents".
7.3 PCP Audit Process The Duke Power Company QA Program "Topical Report" describes the internal auditing requirements for the Corporate PCP and Nuclear Generation implementing procedures under the cognizance of the NSRB at each station and the General Office.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 17 of 37 Rev.14 NEDL SDQA "C" 7.4 PCP Manual Revision Reco rd Retention Requirements See APPENDIX F "Administration of the PCP and Support Documents"
7.5 Periodic
cross-checks & comp arisons (PIP O-03-0624 CAPR) Periodic cross-checks & comparisons of each nuclear site's dewatering process guidance, dewatering techniques and equipment will be performed as part of the following activities:
7.5.1 Every
other year during the annual Chem istry Functional Area Evaluation as part of section 8.4 "Implementation of Process Control Program" of the Performance Attributes Matrix
7.5.2 Other
benchmarking opportunities (e.g., benchmark trips by Radwaste personnel, annual Radwaste workshop discussion groups identify current industry practices and site contacts for comparison of practices 7.6 PCP Implementing Procedure Requirements
7.6.1 Nuclear
Generation procedures shall be established to ensure that all requirements for solidification or dewatering are met when performed by site-assigned personnel.
7.6.2 The administrative requirements for PCP implementing procedures are described in APPENDIX F "Admin istration of the PCP and Support Documents".
7.6.2.1 Completed procedures documenting the solidification verification records described in section 10 shall be maintained by Duke Power Company on each vessel of solidified waste as described in section 5.5 of APPENDIX F.
7.6.2.2 Documentation of the dewatering verification records described in section 11 shall be maintained by Duke Power Company on each vessel of dewatered waste as described in section 5.5 of APPENDIX F.
7.6.3 Vendors
providing onsite PCP services may use their own vendor procedures to perform PCP services using non-installed equipment as described in NSD 703 provided they meet the applicable requirements of the PCP Manual.
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7.6.4 Vendor
documents directing solidification or dewateri ng activities of site assigned personnel shall be incorporated into site implementing procedures as described in APPENDIX F.
- 8. APPROVAL PROCESS FOR QA APPROVED SUPPLIERS Any supplier shall be approved and incorporated into the QA Approved Supplier Program prior to being contracted for PCP services.
8.1 Technical
Review and Approval Before vendors can provide PCP related servic es, they shall be evaluated against the Duke Energy Radioactive Waste PCP Manual and approved by the Technical Manager, Nuclear Chemistry or his designee.
8.1.1 Prior
to awarding a contract to a supplier for processing site radioactive waste, vendors are subjected to a review using criteria outlined in APPENDIX G "Waste Processor Checklist" 8.1.2 If the vendor provides PCP related serv ices, the vendor PCP and other related program documents are evaluated to ensure they meet the applicable requirements of the Duke Energy Radioactive Waste PCP Manual as
described in section 9 below.
8.1.3 The results of these reviews should be documented in a PIP for future reference.
8.2 QA Supplier Evaluation Upon meeting the requirements of the techni cal review, the supplie r is evaluated for incorporation into the QA Supplier program in accordance with the requirements of Duke Energy Nuclear Quality Assurance Program.
8.3 QA Approved Supplier Program All vendors approved to provide PCP related services are included in the QA Approved Suppliers List. The QA processes that apply are described in the following Supply Chain documents 8.3.1 SCD 510 "Approved Suppliers List" 8.3.2 SCD 520 "Audits of Suppliers" 8.3.3 SCD 285 "Procurement of QA Condition 2, 3, and 4 Items" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 19 of 37 Rev.14 NEDL SDQA "C"
- 9. PCP REQUIREMENTS FOR VENDOR PROCESSES AND SERVICES
9.1 Topical
Report (or equivalent)
Any vendor service or vendor supplied processe s utilized for solidif ication or dewatering by Duke Energy shall have a Topical Report or other form of certification documenting NRC approval of the process and associated containers, or shall s upply to Duke Energy sufficient documentation of the process and test results to demonstrate that an acceptable product will be produced using the describe d solidification or dewatering process.
9.2 10CFR61
Waste Form Compliance 9.2.1 The vendor(s) approved for solidification or dewatering services shall have NRC certification documenting compliance with waste form requirements in the final product, or shall supply Duke Energy sufficient documentation to demonstrate waste form compliance.
9.2.2 Any vendor providing High Integrity Containers (HIC's) to Duke Energy shall have a NRC approved report documenting compliance with waste form requirements, or shall supply Duke Energy sufficient documentation to demonstrate waste form compliance.
9.2.3 All vendor Topical Reports or equivalent shall certif y that the final product conforms to the appropriate waste form for Class A, B, or C waste.
9.2.4 Vendor
PCP Service Quality Requirements QA Approved PCP Service Suppliers shall meet the applicable quality requirements set forth in their Purchase Order. Examples of such requirements are described in APPENDIX D "Approved PCP Service Suppliers".
9.3 10CFR61Waste
Classification Compliance 9.3.1 Each container of processed (i.e., solidified or dewatered) waste shall be classified as Class A, B, or C waste using the "10 CFR Part 61 Waste Classification and Waste Form Implementation Program" for the applicable station.
9.3.2 Each container of processed waste shall be certified to the appropriate waste form for Class A, B or C waste. Greater-than-Class C waste may be approved for disposal on a case-by-case basis with appropriate approval from the disposal site and agreement state.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 20 of 37 Rev.14 NEDL SDQA "C" 9.3.3 Each container of processed Mixed Waste shall be certified to be non-hazardous.
9.4 Minimum
Requirements for Onsite Process Vendors
9.4.1 Vendors
providing PCP services onsite sh all fulfill all of the applicable requirements in the Radioactive Waste PCP Manual and the a pplicable quality requirements set forth in the Purchase Order prior to shipment of the solidified or dewatered waste offsite for disposal.
9.4.2 Onsite
Vendor System/Equipment Interface Requirements:
9.4.2.1 The vendor Topical Report or documentation supplied to Duke Energy shall include a detailed sy stem or process description of all vendor interfaces with installed plant equipment.
9.4.2.2 Drawings or diagrams shall be included detailing all solidification and dewatering system interfaces with installed plant systems and equipment.
9.4.2.3 Solidification system ventilation discharge is treated or routed to the plant's auxiliary building or radwaste facility ventilation system to meet effluent discharge requirements.
9.4.2.4 Decanted radioactive liquid is processed as required or routed to the station liquid radwaste systems.
9.4.2.5 This information may be included as part of a Topical Report furnished by the equipment manufactu rer or supplier or as part of the station specific Final Safety Analysis Report.
9.4.3 Onsite
Vendor System Design Requirements 9.4.3.1 The vendor Topical Report or equivalent documentation supplied to the Duke Energy shall include a statement that the design, construction, operation and quality assurance provisions are in accordance with NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143.
9.4.3.2 Permanent or portable solidification and dewatering systems used at nuclear sites shall meet the design, construction, operation and quality assurance provisions of NRC ETSB Branch Technical Position 11-3 and Regulatory Guide 1.143.
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9.5 Minimum
Requirements for Offsite PCP Process Vendors Vendors providing PCP services offsite shall meet the requirements of their PCP process and the applicable quality requirements set forth in the Nuclear Supply Chain Purchase Order prior to disposal of the final product.
- 10. PCP SOLIDIFICATION PROCESS DESCRIPTION Waste solidification at Duke Ener gy nuclear stations shall be performed in a manner equivalent to the process described below using approved procedures in a controlled and quality fashion which ensures that all applicable regulatory and disposal site criteria are met. Procedures used to direct solidification shall include the adequate detail to implem ent a process equivalent to that described below.
NOTE: Whenever a solidification process is used to meet 10CFR61 disposal site requirements, "Surveillance Requirements" in ONS SLC 16.11.5, MNS SLC 16.11.11 and CNS SLC 16.11-11 shall be fulfilled by using procedures that meet or surpass the Bench Scale Test solidification verification and frequency requirements below or by verifying these requirements are met by the vendor program/process being used.
10.1 Waste Characterization The waste sample shall be characterized chemically, physically and radiologically. Sample analyses such as the following shall be performed as outlined in site-specific procedures for the applicable waste form and solidification media to be used.
10.1.1 Waste pH 10.1.2 Waste density 10.1.3 Waste boron concentration 10.1.4 Waste oil content 10.1.5 Gamma Analysis 10.2 Mixed Waste Characterization 10.2.1 Process knowledge may be used for hazardous waste characterization with approval by the appropriate knowledgeable individual.
10.2.2 If process knowledge cannot be used, th e hazardous characte ristics shall be determined before solidification using an approved method.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 22 of 37 Rev.14 NEDL SDQA "C" 10.2.3 The disposal site shall be notified to obtain pre-approval for disposal whenever a waste determined to be a Mixed Waste is being rendered non- hazardous by solidification.
10.3 Minimum Solidification Acceptance Criteria Minimum Solidification Acceptance criteria are listed below, but additional criteria may be added by the disposal site and shall be included in the verification process:
10.3.1 FSL Criteria: Liquid wastes , or wastes containing li quid, shall be converted into a form that contains as little free standing and non-corro sive liquid as is reasonably achievable, but in no case shall the liquid exceed 1% of the volume of the waste when the waste is in a disposal container designed to ensure stability, or 0.5% of the volume of the waste for waste in a disposal container not designed to meet stability requirements and/or waste processed to meet waste form stability requirements independent of the disposal container.
10.3.2 Physical Criteria: the solidified prod uct shall be a free-standing, non-friable and homogeneous monolith.
10.3.3 Chemical Criteria: The solidified product of a Mixed Waste shall be rendered non-hazardous.
10.4 Representative Waste Sample A representative sample of the waste to be solidified shall be obtained by a process equivalent to the following as outlined in a pproved procedures for the applicable waste form and solidification media.
10.4.1 A representative waste sample shall include the characteristics of the waste that are critical to the soli dification process being used 10.4.2 The contents of the container to be sampled shall be adequately mixed to achieve a homogeneous mixture 10.4.3 During the mixing and sampling period, the vessel shall not be placed in a transfer mode nor shall additional waste be received 10.4.4 Vessel level readings or input isolation shall be documented at the time of mixing initiation, sampling, and process initiation 10.4.5 Recirculation or mixing time shall be uninterrupted until sample collection RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 23 of 37 Rev.14 NEDL SDQA "C" 10.5 Bench Scale Test Solidification The boundary conditions are demonstrated by pr oducing a solidified product during the Bench Scale Test that meets the minimum acceptance criteria described above. The test-proven boundary conditions will then be used to perform a full scale solidification that meets these same criteria. A Bench Scale Test Solidification shall be performed using a process similar to the following:
10.5.1 Frequency of Bench Scale Testing (Ref: Solid Waste SLC Surveillance Requirement) 10.5.1.1 The minimum frequency for performing Bench Scale Testing shall be as described in the Solid Waste SLC Surveillance requirement: The PCP shall be used to verify at least one test specimen from at least every tenth batch of each type of waste to be solidified for disposal at a 10CFR61 disposal site.
10.5.1.2 Where variability of critical waste parameters is known to be great or is uncertain, the follo wing more conservative frequency shall be followed:
A. An initial Bench Scale Test solidification shall be performed prior to the full-scale solidification of each distinct batch of waste. B. Where multiple solidifications of the same batch of waste occur after the successful initial Bench Scale Test, a Bench Scale Test shall be repeated at a frequency of no less than once per ten solidificatio ns of that batch.
10.5.2 Establish process parameters and boundary conditions Process parameters and boundary conditions (or a method by-which to establish them) are usually given in vendor procedures which have already been certified for a given radioactive waste type. Process parameters should include any of the followi ng that are applicable: Waste form Waste to solidification agent ratio Amount of each solidification additive Waste pH Waste boron concentration Waste density RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 24 of 37 Rev.14 NEDL SDQA "C" Waste oil content Mixer speed Mixing time Curing time Specific activity Pre-solidification hazardous waste characterization 10.5.3 Mixed Waste (additional requirements) 10.5.3.1 Vendor procedures used to solidify Mixed Waste shall be certified to be applicable to the specific waste stream being
processed.
10.5.3.2 For Mixed Waste solidified by D uke Energy personnel, a Nuclear Generation procedure shall be de veloped based on an approved demonstrated process for each specific Mixed Waste stream.
10.5.4 Bench Scale Test Solidificat ion product verification:
Physical testing and laboratory analysis, as described below, shall be utilized to determine if the Bench Scale Test solidified waste sample is a free-standing monolith with the % FSL volume within the acceptance criteria. This testing shall consist of:
10.5.4.1 The % by volume FSL criteria sh all be verified by visual inspection or by physical measurement of any visible FSL 10.5.4.2 Physical testing to determine if a solidified waste is a free-standing monolith shall consist of:
A. Visual inspection AND B. Probe penetration testing to demonstrate non-friability 10.5.5 Mixed Waste Bench Scale Test Solidif ication product verification:
10.5.5.1 In addition to the physical tests listed above, laboratory analysis using approved EPA methods shall be performed to determine if a solidified Mixed Waste has b een rendered non-hazardous.
10.5.5.2 Note that the solidified Mixed Wa ste need only be analyzed for those hazardous properties it exhibited prior to solidification or those that may have been introduced by the solidification process.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 25 of 37 Rev.14 NEDL SDQA "C" 10.5.6 Bench Scale Test Solidification failures (Ref: SLC Remedial Action Requirements) 10.5.6.1 Full Scale Solidification for disposal shall not be performed unless the Bench Scale Test Solidification is acceptable.
10.5.6.2 If any Bench Scale Test Solidification fails to meet the acceptance criteria set forth in section 10.3 "Minimum Solidification Acceptance Criteria", the following actions shall be taken prior to the next solidification for disposal at a 10CFR61 disposal site:
A. Suspend solidification of the batch under test B. Obtain additional representative samples from the current waste batch of waste C. Perform additional test solidifications until alternate solidification parameters are determined and solidification
verified D. Modify the PCP and or procedures as required to assure successful solidification of subsequent batches of waste 10.5.6.3 If the initial Bench Scale Test solidification fails SLC Remedial Actions requires that:
A. Representative test sampling solidifications from each consecutive batch of the same type of waste shall be performed using alternate solidification parameters until at least 3 consecutive initial test solidifications meet the minimum solidification acceptance criteria.
B. Modify the PCP and or procedures as required to assure successful solidification of subsequent batches of waste.
10.5.7 Bench Scale Test Solidification results performed onsite shall be submitted to Station Chemistry for review and authorization prior to initiating full scale waste solidification including the following:
10.5.7.1 Sample analysis 10.5.7.2 Test solidification results RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 26 of 37 Rev.14 NEDL SDQA "C" 10.5.7.3 Prescribed boundary conditions 10.5.7.4 Specific activity to ensure packaging limits of the disposal container will not be exceeded 10.5.8 Bench Scale Test Solidification results performed by an offsite processor shall be handled as follows:
10.5.8.1 Bench Scale Test Solidification failures shall be communicated to the originating site Chemistry supervision prior to performing full scale solidification for disposal.
10.5.8.2 Successful Bench Scale Test Solidification documentation shall be sent to the originating site in the completed PCP documentation for record retention.
10.6 Full Scale Solidification Actual full scale solidification shall be performed using approved procedures which ensure that the solidifica tion process is operated with in the established boundary conditions.
10.6.1 Full scale solidification pro cedures should contain step wise instructions with documentation of completion for the following activities:
10.6.1.1 The Bench Scale Test Solidific ation process described above 10.6.1.2 The full scale formulation of waste additives including mixing requirements 10.6.1.3 The verification described below 10.6.1.4 Documentation of verification that PCP requirements were met 10.6.2 Full Scale Solidification performed in drums shall use new drums (not reconditioned) that meet the requirements of 49CFR.
10.7 Product Verification of Full Scale Solidification Product verification shall be performed to ensu re the acceptance criteria have been met.
10.7.1 Documentation that the Process Control Program was followed and successfully completed may serve as verification of the final solidified
product.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 27 of 37 Rev.14 NEDL SDQA "C" 10.7.2 Non PCP verification (Ref: SLC Remedial Action Requirements) If the Process Control Program was no t followed or if any unusual condition existed during processing that inva lidates the PCP boundary conditions the following actions shall be taken:
10.7.2.1 Reprocess the waste in accordance with PCP requirements, OR 10.7.2.2 Physical testing may be used to verify that disposal site requirements are met:
A. Visual inspection for FSL on top of the waste B. Probe penetration testing and C. Puncturing the bottom of the vessel D. Visual inspection shall be utilized to determine if a solidified waste is a free-standing monolith.
10.7.2.3 Mixed Waste Additional Testing A. In addition to the above physical testing, laboratory analysis using approved EPA methods shall be performed to determine if a solidified Mixed Waste has been rendered non-hazardous.
B. The solidified Mixed Waste need only be analyzed for those hazardous properties it exhibited prior to solidification or
those that may have been introduced by the solidification
process. 10.7.2.4 Make programmatic changes as necessary to address any problems identified.
10.7.3 Full scale solidification does not meet the PCP Acceptance Criteria requirements or physical tests described above.
Any full scale solidification vessel that does not pass the verification requirements described above shall not be shipped to a burial site until reprocessing or repackagi ng has resulted in an acc eptable product (Ref: SLC Remedial Action Requirements). Prior to next shipment for disposal of solidified wastes:
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 28 of 37 Rev.14 NEDL SDQA "C" 10.7.3.1 Suspend shipments of the defectively packaged/inadequately processed solid radioactive wastes from the site AND 10.7.3.2 Initiate action to correct the PC P, procedures, or solid waste equipment as necessary to prevent recurrence 10.7.4 Mixed Waste Pre-approval:
Any solidified Mixed Waste that passes these tests shall not be shipped to a burial site until that burial site has given approval.
10.8 Inoperable Equipment (SLC Remedial Action Requirements) With the waste solidification equipment incapable of meeting PCP requirements or not in service:
10.8.1 Restore the equipment to operable status, OR 10.8.2 Provide alternative capability as necessary to process wastes per this PCP 10.9 Solidification Document Retention Solidification records shall be maintained on each vessel of solidified waste as described in section 7.5. of the Corporate PCP and s ection 5.5 of APPENDIX F "Administration of the PCP and Support Documents". All of the following records that are applicable should be included:
10.9.1 Representative sampling documentation 10.9.2 Sample analysis results 10.9.3 Test solidification results a nd prescribed boundary conditions.
10.9.4 Documentation of Acceptance Criteria verification from completed Nuclear Generation or vendor solidifica tion procedures such as:
10.9.4.1 FSL verification 10.9.4.2 Free-standing monolith verification 10.9.4.3 If applicable, verification that solidified Mixed Waste is non-hazardous.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 29 of 37 Rev.14 NEDL SDQA "C"
- 11. PCP DEWATERING PROCESS DESCRIPTION The methods used for removal of liquid from wet wa stes for final disposal shall comply with the specific requirements of the disposal site at which the waste is being disposed. Dewatering of wet wastes shall be performed in a manner equi valent to the process described below using approved procedures in a controlled and quality fashion which ensures that all applicable Selected Licensee Commitments and disposal site criteria are met. Procedures used to direct dewatering shall include enough detail to implemen t a process that addresses the applicable requirements described below.
11.1 Dewatering Mechanical Filters (e.g., cartridge, bag, membrane) The guidance below addresses dewatering methods and PCP issues unique to disposal of mechanical filters.
11.1.1 Dewatering is required so subsequent accumulation of free standing liquid in the disposal container is not likely to approach disposal site limits.
11.1.2 Wet spent mechanical filters can be dewatered by allowing liquid to drain freely from the filter, blowing the filter down with air, compacting the filter, etc. 11.1.3 The method of dewatering shall be in accordance with a previously defined, evaluated, and documented process.
11.1.4 The parameters of the process, referred to as boundary conditions, shall be defined and used to ensure quality in the process, which in turn serves to ensure an acceptable characteristic of the waste. An example of a boundary condition is the specified period of time for which a mechanical filter shall be allowed to drain freely to ensure FSL will be less than disposal requirements.
NOTE: Removal of free standing liquid fr om a disposal container shall not be considered the PCP method for dewatering mechanical filters.
11.1.5 Filters placed in a filter disposal container designed for removal of FSL shall meet the PCP boundary conditions for dewatering independent of removal of FSL from the container. If PCP boundary conditions are met after placing the filter in the disposal container, the container shall be unwatered to ensure FSL meets disposal requirements.
11.1.5.1 If the PCP boundary conditions have been met prior to placing the filters in the disposal contai ner, dewatering the container to remove incidental FSL is optional.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 30 of 37 Rev.14 NEDL SDQA "C" 11.1.5.2 Case-by case circumstances, such as the following, should be considered in the determining the appropriateness of performing additional filter disposal container dewatering: The time interval between removal of the filters from wet service and placement into the disposal container Size of the disposal container relative to the moisture content in the filters The number of filters The variety of filter types in a single container The environmental conditions of filter staging and interim storage 11.1.6 Use of absorbent package material in mechanical filter disposal containers is subject to the requirements of the disposal site acceptance criteria.
11.2 Dewatering Slurries The guidance below addresses dewatering issues associated with slurry wastes.
11.2.1 Dewatering of "slurried" wet wastes (e.g., resin, carbon, Zeolite, filter precoat, filter backwash, sludge) removes the loosely bound interstitial liquid from solids such that the disposal container meets applicable regulatory and burial site FSL criteria for disposal.
11.2.2 Wet spent process media dewatering shall be performed using processes, containers and procedures that have met the requirements described in section 9, "Process Control Program Requirements".
11.2.3 Typical container dewatering processes use a vacuum pump that takes suction from the vessel through a filter system in the vessel. The water is returned to a station liquid radwaste system and the waste solids are retained in the vessel
by the container filter(s).
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 31 of 37 Rev.14 NEDL SDQA "C" 11.3 Additional Conservatism in Slurry Dewatering Procedures to Address Variation from the Topical Report (P IP O-03-0624, M-03-2515, C-03-3385)
Dewatering processes based on Topical Reports are applied to actual conditions that can vary from the conditions of the Topical Re port testing. The results of a Root Cause investigation at ONS (O-03-0624) identified several i ssues and resolutions that should be incorporated into future revisions of dewatering implementing procedures. Vendor procedures applicable to th e technologies and processes used by DPCo in implementing the PCP provide the basis for minimal requirements in PCP implementing procedures.
In addition the guidelines below have been added based on the Root Cause findings at ONS: 11.3.1 All PCP dewatering procedures shall include flexibility/ guidance for Chemistry to add conservatism to the dewa tering process if waste content and/
or process conditions are atypical in a non conservative manner relative to the testing performed for the Topical report (e.g., greater than normal non media solids, dewatering boundary parameters are not easily met, higher than normal volume of FSL is collected during the final dewatering cycle, etc.)
11.3.1.1 Additional conservatism can include but is not limited to the following examples:
A. Additional dewatering cycles B. Additional settling time between pumping periods C. Additional processing by an approved offsite vendor to verify FSL prior to disposal 11.3.2 Guidance for dewatering all liners using a PCP for direct disposal at Barnwell (PIP O-03-0624 CAPR) 11.3.2.1 Require liner functional testing prior to filling liner with waste to ensure there are no leaks in the liner dewatering system. This testing should include:
A. filling the liner with water B. testing each level of the liner dewatering laterals using the dewatering procedure to unwater the liner, C. verifying that vacuum is not broken prior to exposing the filters for each set of laterals as described in the procedure RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 32 of 37 Rev.14 NEDL SDQA "C" 11.3.2.2 Ensure ambient temperature guidance for dewatering will preclude localized freezing c onditions during the dewatering sequence. After most of the water is removed during the first dewatering cycle, subsequent cycles pull air through the interstitial spaces of the medi a and the loss of heat due to evaporation can depress the temperature on surface of the media and dewatering filters below ambient temperature.
A. Follow guidance in the vendor documentation for the process in use B. If no other guidance is provided, dewatering should not be performed unless ambient temperature of air entering the liner is 40 degrees Fahrenhe it or higher (FO-OP-022) 11.3.2.3 Ensure final water collection samp le point is representative (e.g., as close as possible to the pump discharge) 11.3.3 Mixed Media: Additional guidance for dewatering liners containing Mixed Media with significant non media solids using a PCP for direct disposal at Barnwell (PIP O-03-0624 CAPR)
The guidance below applies to liners containing combinations of different media with significant quantities of non media so lids (e.g., spent zeolite, carbon, resin, etc. containing filtered particulate) 11.3.3.1 Require Ecodex filter system in all liners that contain mixed media with significant non-media solids 11.3.3.2 Clearly specify media loading sequence if media is not homogeneously mixed to minimi ze potential blinding of the lowest level of filters. (e.g., for layered media, largest diameter media in the bottom of the liner) 11.3.3.3 Require additional dewatering Cycles (e.g. minimum of 3 additional cycles after the acceptance criteria in the vendor procedure have been met) 11.3.3.4 Require longer settling periods during the additional dewatering cycles (e.g., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of the 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> required in the vendor procedure)
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 33 of 37 Rev.14 NEDL SDQA "C" 11.3.3.5 Require dewatering through bottom 2 laterals during liner filling (Topical Report requirement to establishes proper media compaction and capillary conditions) 11.3.3.6 Require initial liner unwatering upon completion of final waste transfer to liner (e.g., dewater to loss of vacuum in bottom dewatering laterals to establish capillary dewatering conditions) 11.4 Dewatering Process Requirements The procedures directing dewatering processes shall address all of the following activities that apply to the specific waste type being dewatered.
11.4.1 Waste Characterization Dewatering procedures shall describe how each type of waste is characterized. The characterization information determ ines what disposal and container requirements apply and may also be utilized to determine shipment packaging requirements (e.g., shielding). Much of the required information for slurried waste is obtained using a representative sample of the waste media. Characterization requires the following types of information:
11.4.1.1 Radioactivity content A. To determine 10CFR61 waste class, form and container requirements B. To provide waste content char acterization for packaging and disposal requirements 11.4.1.2 Waste compatibility with disposal container and process method A. Chemical Compatibility: Proce ss knowledge can be applied to determine chemical compatibility with the container.
B. Hazardous Characteristics:
Process knowledge can be applied to determine if the waste is a Mixed Waste.
C. If process knowledge is uncertain due to a potential input of incompatible or hazardous materials, then chemical analysis using an approved method shall be performed to determine chemical compatibility or hazardous characteristics.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 34 of 37 Rev.14 NEDL SDQA "C" 11.4.2 PCP process parameters shall be identified in implementing procedures. Typical parameters are:
11.4.2.1 Waste form 11.4.2.2 Settling time 11.4.2.3 Drain (or pump) time 11.4.2.4 Drying time 11.4.2.5 Specific activity 11.4.3 PCP boundary conditions shall be established for applicable process parameters to verify FSL threshold limits are met.
11.4.4 Sample analysis results and boundary conditions shall be reviewed by the appropriate knowledgeable individual re sponsible for the dewatering process.
11.4.5 Actual dewatering shall be performed us ing approved procedures that ensure the process is performed within the established boundary conditions.
11.5 Product Verification The amount of free-standing liquid shall be verifi ed to be within dis posal site criteria for each container of dewatered waste prior to disposal (e.g., 10CFR61 requires that each
container shall have less than 0.5% free-standing liquids by waste volume or less than 1.0% free-standing liquid if a High Inte grity Container (HIC) is used).
11.5.1 PCP Verification Verification may be accomplished by documenting that the Process Control Program was followed.
11.5.2 Non PCP Verification (SLC Remedial Action Requirements, PIP O-02-7159)
If the PCP was not followed or a non process control method is used:
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 35 of 37 Rev.14 NEDL SDQA "C" 11.5.2.1 Reprocess the waste in accordance with PCP requirements using an onsite process or approved offsite vendor process, OR 11.5.2.2 Use physical testing of the final dewatered product container to verify that the free-standing liquid content meets disposal site requirements. Physical testi ng shall be based on a process approved by the appropriate regulat or, disposal site operator, or applicable disposal site requirements document.
A. A disposal site may define a product verification testing method approved for use in lieu of a process control method.
- 1. That approved product verification process may be used for that category of disposal on a case-by-case basis, (e.g., bulk waste non-containerized disposal).
- 2. Any such product verification process shall be approved by the Nuclear GO Chemistry and Radiation Protection
groups. B. Physical testing may include actual measurement of the volume of FSL in each container as follows:
- 1. Puncture the bottom of the de watered disposal container and collect the FSL.
- 2. Measure the collected FSL and verify it meets the disposal site requirements.
- 3. Punctured containers shall be repaired in order to meet all applicable regulatory and disposal site requirements prior to disposal.
11.5.2.3 Documentation of the method us ed for product verification and the results shall be included in the dewatering record as described in the Dewatering Record Retention section below.
11.5.2.4 Make programmatic changes as necessary to address any problems identified.
11.5.3 Off-normal process or container conditions If any off-normal condition existed du ring processing that could invalidate boundary conditions the following guidance applies:
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 36 of 37 Rev.14 NEDL SDQA "C" 11.5.3.1 Reprocess the waste in accordance with PCP requirements using an onsite process or approved offsite vendor process, OR 11.5.3.2 Contact the process vendor for technical guidance. The vendor may be able to provide a contingency process to meet disposal requirements. The following examples may be considered:
A. If a dewatering lateral in a container fails to meet the process variable boundary requirement in the dewatering procedure, the vendor may be able to provi de procedural guidance to successfully complete the dewatering B. If a contingency dewatering process cannot be successfully completed refer to the dewatering failures guidance below 11.5.3.3 Make programmatic changes as necessary to address any problems identified 11.5.4 Dewatering verification failures (SLC Remedial Action Requirements) 11.5.4.1 Any dewatered vessel failing the product verification requirements shall not be shipped to a burial site until
reprocessing or repackaging has resulted in an acceptable product. 11.5.4.2 If applicable regulatory requirements for a dewatered waste container are not satisfied, the following actions shall be taken prior to next shipment of dewatered wastes for disposal:
A. Suspend shipments of defectively packaged/inadequately processed radioactive wastes from the site AND B. Initiate action to correct the PC P, procedures, or solid waste equipment as necessary to prevent recurrence.
C. If the process is a vendor pro cess, obtain technical guidance from the vendor in resolving the problem D. The reprocessing of a failed dewatering may be accomplished using an onsite process or approved offsite vendor process RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL CORPORATE PROCESS CONTROL PROGRAM CORP PCP Page 37 of 37 Rev.14 NEDL SDQA "C" 11.6 Inoperable Equipment (SLC Remedial Action Requirements) With the waste dewatering equipment incapable of meeting PCP requirements or not in service: 11.6.1 Restore the equipment to operable status, OR 11.6.2 Provide alternative capability as necessa ry to process wastes per this PCP 11.7 Dewatering Document Retention Dewatering records shall be maintained on each vessel of dewatered waste as described in section 7.5 of the Corporate PCP and s ection 5.5 of APPENDIX F "Administration of the PCP and Support Documents". All of the following records that are applicable should be included:
11.7.1 Sample analysis and boundary conditions 11.7.2 Dewatering record from completed Nu clear Generation or vendor dewatering procedures 11.7.3 Free-standing liquid verification
NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM NEDL SDQA "C"
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM REVISION NUMBER 12 ISSUE DATE
_______3/26/03_______ Prepared by/ Date: __DL Vaught/ 12/12/02 Review by/ Date: GT Johnson/ 12/16/02 NGO Chemistry NGO Radiation Protection OCONEE REVIEW AND APPROVALS Reviewed By/ Date: Reviewed By/ Date:
___AS Breland/ 1/6/03____
___RA Bowser/ 1/6/03______
ONS Radwaste Chemistry ONS Radiation Protection Approved By/ Date ___BL Norris/ 1/8/03____
ONS Chemistry Manager Approved By/ Date
__BH Hamilton/ 1/9/03__
ONS Station Manager
Issued By: __RW Eaker (Acting)
/_1/21/03___________
Technical Manager, Nuclear Chemistry
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM ONS PCP Page 1 of 2 Rev. 12 NEDL SDQA "C"
- 1. PURPOSE The Oconee Nuclear Station (ONS) Process Control Program (PCP) lists the documents used to implement all applicable requirements of the Corporate Process Control Program for each container of solidified radioactive or mixed wa ste and dewatered radioactive waste shipped for burial at a licensed burial facility. This PCP is applicable only to the solidification or dewatering of liquid or wet solid radioactive waste.
- A title page documenting approval of changes to the ONS Process Control Program per Appendix E of the PCP Manual
- A list of all the procedures used at ONS that implement the requirements of the Corporate Process Control Program
- Oconee Nuclear Station diagrams, drawings or drawing numbers showi ng interfaces between ONS radwaste systems and solidification and dewatering equipment
- Exceptions to the Corporate PCP section
- 3. IMPLEMENTING PROCEDURES 3.1 CP/0/B/5200/048 "Resin Recovery System Operation" 3.2 CP/0/B/5400/001 "RW Dewatering and Operating Guidelines" 3.3 SH/0/B/2004/002 "Preparation and Shipment of Radioactive Wastes" 3.4 TC/0/B/5400/001 "CNSI Procedure for Dewatering in PL8-120FEXM High Integrity Container"
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX A OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM ONS PCP Page 2 of 2 Rev. 12 NEDL SDQA "C"
- 4. DRAWING INDEX All system interfaces are shown on diagrams or described in the applicable station procedure.
- 5. EXCEPTIONS TO THE CORPORATE PCP SECTION None NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM NEDL SDQA "C"
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM REVISION NUMBER 16 ISSUE DATE
__3/26/03____ Prepared by/ Date: DL Vaught/ 12/12/02__ Review by/ Date: GT Johnson/ 12/16/02_
NGO Chemistry NGO Radiation Protection McGUIRE REVIEW AND APPROVALS Reviewed By/ Date: Reviewed By/ Date:
____JC Gabbert/ 1/13/03______ ___RE Beckham/ 1/8/03___
MNS Radwaste Chemistry MNS Radiation Protection Approved By/ Date
__JW Bramblett/ 1/16/03__
MNS Chemistry Manager Approved By/ Date
_TP Harrall/ 1/21/03_
MNS Station Manager Issued By: ______RW Eaker (Acting)/ 1/21/03_________
Technical Manager, Nuclear Chemistry RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM MNS PCP Page 1 of 2 Rev. 16 NEDL SDQA "C"
- 1. PURPOSE The McGuire Nuclear Station (MNS) Process Control Program (PCP) lists the documents used to implement all applicable requirements of the Corporate Process Control Program for each container of solidified radioactive or mixed wa ste and dewatered radioactive waste shipped for burial at a licensed burial facility. The PCP is applicable only to the solid ification or dewatering of liquid or wet solid radioactive waste.
- A title page documenting approval of changes to the MNS Process Control Program per Appendix E of the PCP Manual
- A list of all the procedures used at MNS that implement the requirements of the Corporate Process Control Program
- McGuire Nuclear Station diagrams, drawings or drawing numbers showing interfaces between MNS radwaste systems and solidification and dewatering equipment
- Exceptions to the Corporate PCP section
- 3. IMPLEMENTING PROCEDURES 3.1 CP/0/B/8300/022 "Handling of Laboratory Quantities of Spent Resin" 3.2 CP/0/B/8600/011 "Sampling Batching Tank and Resin Sample Preparation" 3.3 SH/0/B/2004/002 "Preparation and Shipment of Radioactive Waste" 3.4 HP/0/B/1004/012 "Utilization of Polyet hylene High Integrity Overpacks" 3.5 HP/0/B/1004/032 "Procedure for Packaging Radioactive Filters" 3.6 OP/0/A/6200/032 "Solid Waste System Operation" 3.7 OP/0/B/6200/064 "Transfer and Dewatering Bead Resin" 3.8 OP/0/B/6200/068 "Process Control Program for CNSI Cement So lidification Units" 3.9 OP/0/B/6200/084 "Solidification of Grit Waste" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX B McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM MNS PCP Page 2 of 2 Rev. 16 NEDL SDQA "C" 3.10 OP/0/B/6200/094 "Transfer and Dewatering Ra dwaste Media - Radlok High Integrity Containers" 3.11 OP/1/B/6200/102 "Unit 1 CM Backwash Tank Operation" 3.12 OP/2/B/6200/102 "Unit 2 CM Backwash Tank Operation" 3.13 OP/1/B/6200/104 "Unit 1 Operating, Dewate ring, and Shipping Liners Filled with Powdered Media and/or Bead Resin" 3.14 OP/2/B/6200/104 "Unit 2 Operating, Dewate ring, and Shipping Liners Filled with Powdered Media and/or Bead Resin" 3.15 OP/1/B/6700/016 "Operating Unit 1 Steam Generator Blowdown Demineralizers" 3.16 OP/2/B/6700/016 "Operating Unit 2 Steam Generator Blowdown Demineralizers"
- 4. DRAWING INDEX Plant Interfaces:
4.1 MC-1100-01.02 4.2 MC-1566-1.0 4.3 MC-1566-1.1 4.4 MC-1566-2.0 4.5 MC-1566-3.0 4.6 MC-1590-1.3 4.7 MC-1604-1.1 All system interfaces are shown on diagrams or described in the applicable station procedure.
- 5. EXCEPTIONS TO THE CORPORATE PCP SECTION None NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM
NEDL SDQA "C"
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM REVISION NUMBER 10 ISSUE DATE
____3/2 6/0 3______ Prepared by/ Date: DL Vaught/ 3/4/03 Review by/ Date: GT Johnson/ 3/4/03__
NGO Chemistry NGO Radiation Protection CATAWBA REVIEW AND APPROVALS Reviewed By/ Date: Reviewed By/ Date: _CD Williams/ 3/10/03__
__ BN Kimray/ 3/6/03_
CNS Radwaste Chemistry CNS Radiation Protection Approved By/ Date
__FK Smith/ 3/10/03___
CNS Chemistry Manager Approved By/ Date
__RM Glover/ 3/10/03__
CNS Station Manager Issued By: __DP Rochester/ 3/18/03________________
Technical Manager, Nuclear Chemistry
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM CNS PCP Page 1 of 2 Rev. 10 NEDL SDQA "C" 1. PURPOSE The Catawba Nuclear Station (CNS) Process Control Program (PCP) lists the documents used to implement all applicable requirements of the Corporate Process Control Program for each container of solidified radioactive or mixed wa ste and dewatered radioactive waste shipped for burial at a licensed disposal facility. The PCP is applicable only to the solidification or dewatering of liquid or wet solid radioactive waste.
- A title page documenting approval of changes to the CNS Process Control Program per Appendix E of the PCP Manual
- A list of all the procedures used at CNS that implement the requirements of the Corporate Process Control Program
- Catawba Nuclear Station diagrams, drawings or drawing numbers showing interfaces between CNS radwaste systems and solidification and dewatering equipment
- Exceptions to the Corporate PCP section
- 3. IMPLEMENTING PROCEDURES 3.1 OP/1/B/6250/016 "Condensate Polishing Demi neralizer Backwash Tank Subsystem -
Unit 1" 3.2 OP/2/B/6250/016 "Condensate Polishing Demi neralizer Backwash Tank Subsystem -
Unit 2" 3.3 OP/0/B/6500/013 "Operating Procedure for the Nuclear Solid Waste (WS) Disposal System" 3.4 OP/0/B/6500/046 "Radwaste Operating Procedur e for Solidification and Dewatering of Radioactive Waste" 3.5 OP/1/B/6500/053 "Transfer and Dewatering of Contaminated Secondary Resin Unit 1" 3.6 OP/2/B/6500/053 "Transfer and Dewatering of Contaminated Secondary Resin Unit 2" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX C CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM CNS PCP Page 2 of 2 Rev. 10 NEDL SDQA "C" 3.7 OP/0/B/6500/069 "Chemistry Operating Procedure for Monitor Tank Building (MTB) Ion Exchange and Filtration Media Operations" 3.8 SH/0/B/2004/002 "Preparation and Shipment of Radioactive Waste"
- 4. DRAWING INDEX Plant Interfaces:
4.1 CN-1566-1.6 4.2 CN-1565-3.2 All system interfaces are shown on diagrams or described in the applicable station procedure.
- 5. EXCEPTIONS TO THE CORPORATE PCP SECTION None NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D Rev. 0 APPROVED SUPPLIERS OF PCP SERVICES Prepared By/ Date:
DL Vaught/ 12/16/02 NGO Radwaste Support Reviewed By/ Date:
_GT Johnson/ 12/18/02_
NGO Radiation Protection Approved By/ Date: _____PW Downing/ 12/30/02______
Technical Manager, Nuclear Chemistry RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES PCP APP D Page 1 of 3 Rev. 0 NEDL SDQA "C" SUPPLIER QUALIFICATIONS
- 1. EVALUATION AND PREAPPROVAL The radwaste vendors listed in the qualified supplier table have met the following requirements:
1.1 They have obtained approval per the processor technical evalua tion as outlined in Appendix G "Waste Processor Ch ecklist" of the PCP Manual 1.2 They have been approved for incorporati on into the Nuclear QA Approved Supplier Program 2. SERVICE CONTRACT REQUIREMENTS Radwaste vendors in the QA approved supplier program are required to meet the applicable quality requirements set forth in the purc hase order governing th eir service contract. Examples of such requirements are:
2.1 Supplier
shall provide dewateri ng and/or solidification activities that meet disposal requirements of a qualified disposal site in accordance with 10 CFR Part 61 - 'Licensing Requirements for Land Disposal of Radioactive Waste'.
2.2 Suppliers
shall meet the applicable requirements of:
- 10 CFR 20 - Standards For Protection Against Radiation,
- 10 CFR part 71 - Packaging And Transpor tation Of Radioactive Material, and
- 49 CFR chapter I Subchapter C -
Hazardous Materials Regulations
2.3 Supplier
shall satisfy applicable requirements of the certificates of compliance for high integrity containers and shipping packages provided.
2.4 Must provide to Duke Energy corporate radw aste staff controlled copies of current revisions of applicable procedures for handling & dewatering NRC approved HICs. (Duke Energy 526 South Church St. Mail Code EC07D Charlotte, NC 28202) 2.5 For waste dewatered or solidified to meet 10CFR61 waste form requirements at the vendor's facility, copies of approved completed PCP procedures documenting compliance with PCP requirements shall be provided to the customer site prior to disposal of the final waste container. Solidification PCP documentation shall include the verification of successful laboratory scale test solidificati on as required in this Duke Energy PCP.
2.6 Any failure of PCP test solidification and corrective measures taken shall be communicated to the customer site prior to performing the final full scale solidification.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES PCP APP D Page 2 of 3 Rev. 0 NEDL SDQA "C" QUALIFIED SUPPLIERS VENDOR NAME SOLIDIFICATION DEWATERING MIXED WASTE COMMENTS Duratek (Chem-Nuclear) Solidification Services - Mobile Cement Solidification System, Ref: Topical Report
CNSI-2 (4313-01354-
01P-A). Approved waste streams:
- 1. boric acid evaporator concentrates
- 2. spent bead resin
- 3. spent powdered resin
- 4. filters 5. filter backwash slurry
- 6. resin regenerative chemical wastes
- 7. sludges Dewatering Services -
Ref: Topical Report CNSI-DW-11118-01.
Approved Media:
- 1. granular media
- 2. bead ion exchange resin
- 3. zeolite 4. activated carbon (course particle size, GAC 40) 5. pre-coat media:
- a. EcodexŽ b. PowdexŽ c. EpiflocŽ d. Solka -flocŽ and/or diatomaceous earth
- 6. Other media requires Duratek prior approval Duratek may be used to process this type of waste by solidification to render it
non-hazardous as described
in the Duke Energy Corporate PCP.
- 1. All other solidification requirements in this Process Control Program shall be met.
- 2. A description of the treatment process and results of the analytical tests of the final waste, using the Toxicity Characteristic Leaching
Procedure required by
40CFR261.24, shall be
reviewed by Duke Energy and Chem-Nuclear Systems, Inc. prior to shipment. Envirostone solidification compound, manufactured by U.S.
Gypsum, has been approved by Chem-Nuclear Systems, Inc.
(Duratek) and Duke Energy for solidification of specific class A unstable wastes that are characteristic mixed wastes. This waste may be treated by in-house personnel using this media in compliance with this Process Control Program. The media shall not contain more than one percent oil by volume.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX D APPROVED SUPPLIERS OF PCP SERVICES PCP APP D Page 3 of 3 Rev. 0 NEDL SDQA "C" QUALIFIED SUPPLIERS VENDOR NAME SOLIDIFICATION DEWATERING MIXED WASTE COMMENTS ATG - (previously
Molten Metals Technologies (MMT)) Solidifications Services -for use with the following approved waste streams
- 1. ion exchange resin
- 2. granular and powdered carbon consistent with the activity limits set forth in their State of
Radioactive Materials License 3. Zeolite material may be accepted for
processing with prior approval from ATG Dewatering Services -
liners and a dewatering (under drain) system for use with the following approved waste streams
- 1. ion exchange resin
- 2. granular and powdered carbon 3. Zeolite material may be accepted for
processing with prior approval from ATG
- 4. secondary system generated powdered and bead resin
NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX E Rev. 0 PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS Prepared By/ Date:
DL Vaught/ 12/16/02 NGO Radwaste Support Staff Reviewed By/ Date:
GT Johnson/ 12/18/02 NGO Radiation Protection Approved By/ Date: ___________PW Downing/ 12/30/02_________________
Technical Manager, Nuclear Chemistry RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX E PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS PCP APP E Page 1 of 1 Rev. 0 NEDL SDQA "C" Title Technical Author & Review Approvals CORPORATE PROCESS CONTROL PROGRAM NGO Chemistry Author NGO Radiation Protection Station Chemistry Staff Station Radiation Protection NGO Chemistry Technical Manager All Sites Chemistry Managers All Station Managers APPENDIX A:
OCONEE NUCLEAR STATION PROCESS CONTROL PROGRAM NGO Chemistry Author NGO Radiation Protection Staff ONS Chemistry ONS Radiation Protection NGO Chemistry Technical Manager ONS Chemistry Manager
ONS Station Manager APPENDIX B:
McGUIRE NUCLEAR STATION PROCESS CONTROL PROGRAM
NGO Chemistry Author NGO Radiation Protection MNS Chemistry MNS Radiation Protection NGO Chemistry Technical Manager MNS Chemistry Manager MNS Station Manager APPENDIX C:
CATAWBA NUCLEAR STATION PROCESS CONTROL PROGRAM
NGO Chemistry Author NGO Radiation Protection CNS Chemistry CNS Radiation Protection NGO Chemistry Technical Manager CNS Chemistry Manager
CNS Station Manager APPENDIX D:
Approved Suppliers of PCP Services NGO Chemistry Author NGO Radiation Protection NGO Chemistry Technical Manager APPENDIX E: PCP Manual Review & Approval Requirements NGO Chemistry Author NGO Radiation Protection NGO Chemistry Technical Manager APPENDIX F:
Administration of the PCP & Support Documents NGO Chemistry Author NGO Radiation Protection NGO Chemistry Technical Manager All Sites Radwaste Chemistry
APPENDIX G:
Waste Processor Checklist NGO Radiation Protection NGO Chemistry Author N/A APPENDIX H
- Revision Summary - Licensee Initiated Changes NGO Chemistry Author N/A
NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS REVISION NUMBER 0 ISSUE DATE
_____3/2 6/03______ Prepared by/ Date: _DL Vaught/ 3/14/03__ Review by/ Date: GT Johnson/ 3/17/03 NGO Radwaste Staff NGO Radiation Protection CATAWBA MCGUIRE OCONEE Approved By/Date CD Williams/ 3/19/03 Radwaste Chemistry
Approved By/Date
_JC Gabbert/ 3/17/03_
Radwaste Chemistry
Approved By/Date GP Denard/ 3/19/03 Radwaste Chemistry Issued By: _ _DP Rochester/ 3/20/03 __
Technical Manager, Nuclear Chemistry RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F i Rev 0 NEDL SDQA "C" TABLE OF CONTENTS
- 1. PURPOSE......................................................................................................................................1
- 2. REFERENCES..............................................................................................................................1 2.1 Duke Energy Corporation Quality Assurance Program Topical Report................................1 2.2 Nuclear Policy Manual Chapter 2..........................................................................................1
2.3 Nuclear
System Directive (NSD) 100 "Instructions for Administrative Procedures"...........1 2.4 NSD 703 "Administrative Instructions for Station Procedures"............................................1 2.5 NSD 704 "Technical Procedure Use and Adherence"...........................................................1 2.6 NSD 209 "10 CFR 50.59 Evaluations"..................................................................................1 2.7 NSD 319 "Vendor Technical Information (VTI) Program"..................................................1 2.8 NSD 702 "Document Management"......................................................................................1 2.9 NSD 800 "Software and Data Quality Assurance"................................................................1 2.10 NSD 301 "Nuclear Station Modifications"............................................................................1 2.11 Corporate Process Control Program.......................................................................................1 2.12 Chapter 16 FSAR "Selected Licensing Commitments".........................................................1 2.13 Procedure Writer's Manual.....................................................................................................1 3. DEFINITIONS AND DESCRIPTIONS......................................................................................2
3.1 Safety
Analysis Report (SAR)...............................................................................................
2 3.2 Selected Licensing Commitments (SLC)...............................................................................2 3.3 10CFR Part 61 "Licensing Requirements for Land Disposal of Radioactive Waste"...........2 3.4 Approved Radwaste Vendor/ QA Approved Supplier...........................................................2
3.5 Radwaste
Vendor Document..................................................................................................3
- 4. RESPONSIBILITIES FOR PCP RELATED DOCUMENTATION.......................................3
4.1 Nuclear
General Office (NGO) Chemistry (Nuclear Chemistry)..........................................3 4.2 Station Chemistry...................................................................................................................3 4.3 NGO Radiation Protection (RP).............................................................................................4
- 5. PROCEDURE................................................................................................................................4 5.1 PCP Manual Revision and Review........................................................................................4 5.2 PCP Manual Revision Record Retention Requirements........................................................5 RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F ii Rev 0 NEDL SDQA "C" 5.3 PCP Manual Revision Publication Process............................................................................5 5.4 Administration of Nuclear Generation Procedures for Implementing PCP Activities..........5 5.5 Retention Requirements for PCP Implementing Procedures.................................................6 5.6 Use of Vendor Procedures in Chemistry Procedures.............................................................7
5.7 Exclusion
of Vendor Procedures from NSD 228 "Applicability Determination".................8 5.8 Chemistry Control of PCP Related Vendor Documents........................................................9
- 6. ENCLOSURES..............................................................................................................................9 6.1 PCP Manual Revision Publication Process..........................................................................10 6.2 Chemistry Distribution of Radwaste Vendor Documents....................................................16 6.3 NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry.............................................................................................................................20
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 1 of 22 Rev 0 NEDL SDQA "C"
- 1. PURPOSE This document describes the administrative process for the Radioactive Waste Process Control Program (PCP) Manual and its supporting documents. These include but are not limited to documents used to accomplish the requirements of the PCP. (e.g., nuclear station implementing procedures, Radwaste vendor documents, etc.) It is intended to facilitate compliance with applicable Nuclear Generation Department (NGD) administrative procedures, Nuclear System Directives (NSD) and provide details of the process that are not described in those documents.
This document also contains a description of the Electronic publication processes for the PCP and the vendor documents used to implement the PCP. It is referenced in the SDQA plan for the PCP Manual.
- 2. REFERENCES 2.1 Duke Energy Corporation Quality Assurance Program Topical Report
2.2 Nuclear
Policy Manual Chapter 2
2.3 Nuclear
System Directive (NSD) 100 "Instr uctions for Administrative Procedures" 2.4 NSD 703 "Administrative Instructions for Station Procedures" 2.5 NSD 704 "Technical Procedure Use and Adherence" 2.6 NSD 209 "10 CFR 50.59 Evaluations" 2.7 NSD 319 "Vendor Technical Information (VTI) Program" 2.8 NSD 702 "Document Management" 2.9 NSD 800 "Software and Data Quality Assurance" 2.10 NSD 301 "Nuclear Station Modifications" 2.11 Corporate Process Control Program 2.12 Chapter 16 FSAR "Selected Licensing Commitments" 2.13 Procedure Writer's Manual RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 2 of 22 Rev 0 NEDL SDQA "C"
- 3. DEFINITIONS AND DESCRIPTIONS
3.1 Safety
Analysis Report (SAR)
The station's technical speci fications, updated final safety analysis report, licensee commitments, safety evaluation report s and the facility operating license.
3.2 Selected
Licensing Commitments (SLC) Commitments to control important plant equipment and operating conditions not controlled elsewhere. Operational commitments which are to be removed from existing station Technical Specifications (Tech Specs) may be included in the SLC program. Also included in this program can be selected NRC commitments co ntained in licensing documents such as the station's SERs, LERs, violation responses, generic letter and bulletin responses, submittal documents and other Duke letters to the NRC.
3.3 10CFR
Part 61 "Licensing Requirements fo r Land Disposal of Radioactive Waste" The applicable portion of this NRC regulati on requires that low-level radioactive waste (LLW) meet certain waste form acceptance criteria in order to be received for disposal at NRC and Agreement State licensed ra dioactive waste di sposal sites.
3.4 Approved
Radwaste Vendor/ QA Approved Supplier Vendors that provide dewatering or solidification processes shall be evaluated against Duke Energy PCP requirements for approval. Approved vendors are incorporated into the Supply Chain QA Approved Supplier Progr am as described in Corporate PCP.
Vendors offer the following kinds of services and products:
3.4.1 Turnkey
onsite service contracts including their transportable equipment and operators for the equipment
3.4.2 Offsite
intermediate processing of radw aste including packaging, shipping and final disposal at a licensed disposal site or return for disposition by the customer 3.4.3 Disposal containers and controlled copies of the associated documents and procedures for dewatering the containers to PCP requirements RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 3 of 22 Rev 0 NEDL SDQA "C"
3.5 Radwaste
Vendor Document A document provided by a vendor whose process has been approved for PCP processing. In order to implement the requirements of the PCP, Nuclear Generation operating procedures are devel oped that contain the applicable requirements described in the PCP manual. When the dewatering or solid ification process used is based on using a vendor developed process, or using vendor provided containers/components they are required to provide two types of documentation:
3.5.1 Documents
that were used to evaluate the vendor's program compliance with NRC, State, disposal site and Duke Energy PCP requirements in order to approve them for PCP services AND
3.5.2 Controlled
copies of operating proce dures for the vendor's dewatering or solidification process that are used to develop and maintain the PCP implementing procedures at each of the sites
- 4. RESPONSIBILITIES FOR PCP RELATED DOCUMENTATION
4.1 Nuclear
General Office (NGO) Chemistry (Nuclear Chemistry)
4.1.1 Radwaste
Support of NGO Chemistry (NGO Radwaste) is responsible for administration of the PCP and its supporting documents 4.1.2 NGO Radwaste also manages and distributes the vendor documents used by site Chemistry to implement the PCP.
4.2 Station
Chemistry
4.2.1 Station
Radwaste Chemistry approves this section of the PCP Manual.
4.2.2 The assigned staff and responsible Chemistry General Supervisor are responsible for ensuring that the site PCP related documents are properly updated, maintained and used to meet the requirements of th is section of the PCP Manual.
4.2.3 Members
of Chemistry Management and Staff are responsible for ensuring that all Chemistry personnel properly use PCP related documents as described in this document.
4.2.4 Each qualified member of the Chemistry group is expected to verify and use the most current and properly reviewed documents to perform PCP activities.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 4 of 22 Rev 0 NEDL SDQA "C" 4.3 NGO Radiation Protection (RP) 4.3.1 NGO RP is responsible for maintain ing and distributing current vendor documents used by site RP Radioactive Materials Control (RMC) to manage the site radioactive materials handling, packaging and shipping programs.
4.3.2 NGO RP reviews this document and ensures applicable RP program documents comply with its requirements.
- 5. PROCEDURE 5.1 PCP Manual Revision and Review 5.1.1 PCP Manual revisions are prep ared by NGO Radwaste.
5.1.2 The reviews and approvals required for the PCP are described in the Radioactive Waste PCP APPENDIX E "PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS".
5.1.3 All changes to the PCP and a description of the revisions sha ll be sent to the Nuclear Safety Review Board (NSRB). (Ref: 3.3.1 "SLC 16.13.2")
5.1.4 All changes to the Corporate PCP or station PCPs shall be sent to the NRC in each station's Annual Radioactive Efflue nt Report for the period in which the changes were implemented. This requirement is found in the following references:
5.1.4.1 NUREG-1431 "Standard Technical Specifications Westinghouse Plants" 5.1.4.2 NUREG-1430 "Standard Technical Specifications Babcock and Wilcox Plants" 5.1.4.3 Oconee Technical Specificati on 5.6.2 "Annual Radiological Environmental Operating Report" 5.1.4.4 Catawba SLC 16.11-16 "Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report" 5.1.4.5 McGuire SLC 16.11.17 "Radioactive Effluent Release Report" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 5 of 22 Rev 0 NEDL SDQA "C"
5.1.5 Proposed
PCP revisions shall be review ed against Technical Specifications, all applicable NRC guidance, and all applicable hazardous waste management regulations to ensure all requirements of a Process Control Program have been addressed. Documents reviewed shall include at a minimum the applicable documents listed in sections 3 and 4 of the Corporate PCP.
5.2 PCP Manual Revision Reco rd Retention Requirements PCP records described in this section shall be retained in a retrievable form using an approved method as described in NSD 701 "Records Management" for a period of time no less than as defined in the referenced record number of the Information Retention Policy. 5.2.1 PCP Manual Revision Reviews & Approvals Documentation of the reviews/ appr ovals and revisions of the following sections of the PCP Manual shall be retained for a period of time no less than as defined in the Information Retention Policy record # 006644.
- CORPORATE PROCESS CONTROL PROGRAM
- APPENDIX A "OCONEE NUCLEAR STATION PCP"
- APPENDIX B "MCGUIRE NUCLEAR STATION PCP"
- APPENDIX C "CATAWBA NUCLEAR STATION PCP"
- APPENDIX H "REVISION
SUMMARY
- LICENSEE INITIATED CHANGES" 5.2.2 A microfilm record of th e historical PCP revision reviews/approvals through 2001 is stored in the vault on roll
- 2096 per retenti on record # 006644. All revisions after 2001 shall be archived as described above.
5.3 PCP Manual Revision Publication Process The PCP Manual is published for viewing in the NEDL Portal under Electronic Licensing Library (ELL). The PCP Manual f iles are viewable under the document subtype ODCM-PCP. The process for publication is summarized in ENCLOSURE 6.1 "PCP Manual Revision Publication Process".
5.4 Administration
of Nuclear Generation Procedures for Implementing PCP Activities
5.4.1 Implementing
procedures shall be established to ensure that all requirements for solidification or dewatering are met when performed by Nuclear Generation personnel.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 6 of 22 Rev 0 NEDL SDQA "C" 5.4.2 The Nuclear Generation PCP implementing procedures are maintained per NSD 703 "Administrative Instructions for Technical Procedures". Revisions to all PCP implementing procedures shall be reviewed against the requirements in the PCP Manual to ensure that they do not conflict with the Corporate Process Control Program.
5.4.3 All PCP implementing procedures are identified in the station specific PCP contained in APPENDIX , A, B or C of the PCP Manual.
5.4.4 The PCP implementing procedures shall identify the fact that they are PCP related to ensure NSD 228 Applicab ility reviews consider the PCP requirements.
5.4.5 All revisions to procedures listed in the site PCPs shall be reviewed to determine if they alter or inhibit the procedure's performance of the Corporate PCP requirements.
5.4.6 NGO Radwaste is responsible for the interpretation and implementation of the PCP and shall be notified when any changes, deviations or questions concerning the interpretation of a requirement in the solidification or
dewatering of a radioactive waste is encountered which may affect the Duke Energy Radioactive Waste Process Control Program Manual.
5.5 Retention
Requirements for PCP Implementing Procedures
5.5.1 Chemistry
PCP procedures shall document the Radioactive Shipment Record (RSR) number for each dewatered or solidified container to provide a cross reference in the Chemistry record to the RMC shipment record.
5.5.2 All completed Chemistry PCP procedures shall be sent to Master File for archival under retention code # 004928 entitled "Operating Procedures", Classification: QA Record.
5.5.3 Applicable
documentation in Chemistry PC P procedures shall be forwarded to RMC for inclusion with the shi pping and disposal paperwork.
5.5.4 Offsite
vendor documentation of PCP compliance shall be returned to RMC (the site shipping contact) as desc ribed in the Purchase Order quality requirements.
5.5.5 PCP documentation from offsite PCP vendor s shall be incorporated into the shipping record when applicable.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 7 of 22 Rev 0 NEDL SDQA "C" 5.5.6 RMC shipment files (including PCP documentation either from Chemistry or vendor) shall be sent to Master file under the retention code # 000278 entitled "Radioactive Material Control Records", Classification: QA Record.
5.6 Use of Vendor Procedures in Chemistry Procedures
5.6.1 Technical
review of all vendor documents and procedures pertaining to PCP processing shall be performed by knowledgeable station and NGO Chemistry staffs as described in Enclosure 6.3 "NSD 319 VTI Impact Assessment Process for Radwaste Vendor Documents Used in Chemistry".
5.6.2 Current
revisions of vendor procedures th at direct the use of vendor containers or processes for solidification or dewatering to meet PCP requirements are received per the vendor control document program and maintained as references for Nuclear Gene ration operating procedures.
5.6.3 The vendor procedure steps that dire ct PCP solidification or dewatering performed by station assigned individuals shall be incorporated into Nuclear Generation procedures and maintained in the technical pr ocedure electronic repository for use by station personnel (e.g., NEDL/Scribe) as follows:
5.6.3.1 The vendor document is used as a reference.
5.6.3.2 The information from the vendor document is incorporated into the body and/or enclosures of the nuclear station implementing procedure.
5.6.3.3 The information is reformatted per the Procedure Writers Manual and NSD 703 except as described in 5.6.4.
5.6.3.4 The incorporation of vendor process information into the NEDL electronic procedure constitutes a technical procedure revision.
per NSD 703 including NSD 228 Applicability Determination and QR approval.
5.6.4 Some vendor procedure enclosures that document compliance with the vendor process or container certification requirements is required to accompany the container during shipment and receipt at the disposal site. The following are two approaches that may be used to maintain the standardized formatting of the form:
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 8 of 22 Rev 0 NEDL SDQA "C" 5.6.4.1 These enclosures may be referenced in the Nuclear Generation procedure rather than being incorporated into the NEDL electronic procedure.
A. When performing solidification or dewatering activities, a working copy of the enclosure is printed from the current
controlled copy of the vendor pr ocedure and incorporated as an enclosure in the working copy of the Nuclear Generation procedure.
B. This approach precludes revi sions to the nuclear station procedure every time the vendor enclosure is revised.
5.6.4.2 The vendor document enclosures ma y be incorporated into the Nuclear Generation procedure electronically while maintaining
the original vendor format.
A. This approach will require that formatting conflicts with applicable Nuclear Generation Writer's Manual guidelines be
addressed.
B. The incorporation of revised vendor information into the NEDL electronic procedure constitutes a technical procedure
revision per NSD 703, includi ng NSD 228 Applicability Determination and QR approval.
5.7 Exclusion
of Vendor Procedures from NSD 228 "Applicability Determination" 5.7.1 The vendor documents used to support PCP activities are exempted from the requirements of NSD 228 and NSD 703 pe r 703.1, subsection 5. "Procedures for Site Equipment NOT Installed".
5.7.2 Applicability
Determination (NSD 228), review, and approval under the site program are not required for the Ra dwaste vendor procedures or any subsequent revisions if all of the following criteria are met:
5.7.2.1 The Radwaste vendor procedures are from a QA approved vendor. 5.7.2.2 The procedures direct activities of QA approved vendors or site assigned personnel that do NOT involve direct work on plant installed equipment.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS PCP APP F 9 of 22 Rev 0 NEDL SDQA "C" 5.7.2.3 The vendor dewatering and solidif ication procedure addresses activities that could be performed off-site.
5.8 Chemistry
Control of PCP Related Vendor Documents 5.8.1 PCP related controlled vendor documents are distributed to NGO Radwaste per the vendor controlled document process.
5.8.2 NGO Radwaste is the Nuclear Genera tion Chemistry recipient for all Radwaste vendor documents used in PCP implementing Chemistry procedures.
5.8.3 Hard copies of controlled vendor documents are maintained as received in a Nuclear Generation Satellite File located in the NGO Chemistry area.
5.8.4 When NGO Radwaste receives vendor document revisions, they are distributed as described in Enclosure 6.2 "Chemistry Process for Publication of PCP Related Vendor Documents".
5.8.5 All PCP related vendor document revisions are reviewed by NGO Radwaste to determine their impact on Nuclear Generation Chemistry programs and procedures.
5.8.6 Radwaste
vendor documents that are in corporated into Nuclear Generation Chemistry PCP implementing procedures are subjected to a vendor technical impact assessment as described in Enclosure 6.3 "NSD 319 VTI Impact Assessment Process for Radwaste Vendor Documents Used in Chemistry".
- 6. ENCLOSURES 6.1 PCP Manual Revision Publication Process 6.2 Chemistry Distribution of Radwaste Vendor Documents 6.3 NSD 319 VTI Impact Assessment Proce ss For PCP Related Vendor Documents Used In Chemistry RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 "PCP Manual Revision Publication Process" PCP APP F 10 of 22 Rev 0 NEDL SDQA "C" 6.1 PCP Manual Revision Publication Process The PCP Manual is published for viewing in the NEDL Portal under ELL. The PCP Manual files are stored under the document subtype ODCM-PCP in an approved read-only format (e.g., PDF). The following process is used to publish the PCP Manual and ensure SDQA requirements are met:
6.1.1 PCP Manual Word File Management The PCP Word document files are managed in a secure server location (//ngofs1/Chemgo) using the following subfolders:
- "Revision PCP Word Files" Contains the Word files under revision (i.e., the "revision" Word files)
- "Archive PCP Word Files" Contains superseded revisions of PCP Word files * "Current PCP PDF Files" Contains copies of the current PDF files published for viewing in the NEDL Portal
- "Revision PCP PDF Files" Contains the PDF files under revision (i.e., the "revision" PDF files)
- "Archive PCP PDF Files" Contains copies of superseded PDF files 6.1.2 PCP Manual Revision and Publication Process 6.1.2.1 Copy the current PCP Word file to the subdirect ory, "Revision PCP Word Files" when editing is needed 6.1.2.2 This revision file shall be named to differentiate it from the current file 6.1.2.3 Edit the revision PCP Word file RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 "PCP Manual Revision Publication Process" PCP APP F 11 of 22 Rev 0 NEDL SDQA "C" 6.1.2.4 Covert revision PCP Manual Word files to PDF files in the "Revision PCP PDF Files" subfolder with internal TOC links in the following sections:
- Corporate PCP
- APPENDIX F "ADMINISTRATION OF THE PCP AND ASSOCIATED DOCUMENTS" 6.1.2.5 Route the revision PDF for the required reviews and approvals A. Email the instructions for review and approval B. Include the revision PDF as an attachment OR C. Include instructions for accessing the file on the Intranet 6.1.2.6 Have reviewers and approvers respond via email with their "approval" or comments 6.1.2.7 After all changes are approved, ed it the signature page in the revision Word files with approver "Names/ Dates" and "Issued Dates" 6.1.2.8 Create a PDF file of the title and approval page from each revised Word document 6.1.2.9 Insert the completed title and appr oval page into the appropriate revision PCP PDF file 6.1.2.10 Copy the current PCP PDF file into the "Archive PCP PDF Files" subfolder 6.1.2.11 Review the final PDF file cont aining the inserted title and approval page against the revision PDF file that was routed for review and approval to verify that only the approval "Names/
Dates" and "Issued Dates" entries changed 6.1.2.12 Save as final the revision PDF file with approval documentation in the "Current PCP PDF Files" subfolder.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 "PCP Manual Revision Publication Process" PCP APP F 12 of 22 Rev 0 NEDL SDQA "C" 6.1.2.13 Save a copy the current Word file into the "Archive PCP Word Files" subdirectory 6.1.2.14 Save the final of the revision Word file in the "Current PCP Manual Word Files"
6.1.3 Adding
a new PCP File to Scribe 6.1.3.1 Logon to Scribe Electronic Licensing Library (ELL) 6.1.3.2 Click the "New Docume nt" icon in tool bar 6.1.3.3 Enter or select from the drop down menus the following information under "Document Properties" in the "Add Document" screen:
A. Title: "Radioactive Waste PCP Manual: "PCP SECTION TITLE rev #
" B. Document Sub Type: Select "ODCM-PCP" C. Status: Select "Current" D. Doc Rev: enter the current revision #
E. Doc State: Select "Issued" F. Unit: Select the proper applicable initials for the PCP section. (e.g., since the Corporat e PCP applies to all units at all three sites select "OCM")
G. Section Name:
"PCP SECTION TITLE
" (e.g., "
ONS PCP") H. Document Date: enter the "Issued" date for this revision (e.g., "12/01/02") I. Retention Record Number:
"006644" J. Author: "D" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 "PCP Manual Revision Publication Process" PCP APP F 13 of 22 Rev 0 NEDL SDQA "C" 6.1.3.4 NGO Radwaste reviews the current PDF in NEDL Portal against the hard copy to verify all is correct
6.1.4 Revising
an existing PCP Manual File in Scribe 6.1.4.1 Logon to Scribe Electronic Licensing Library 6.1.4.2 Checkout the current PCP Manual PDF file 6.1.4.3 Check in the revised PDF 6.1.4.4 Revise the "Document Property" values in the "Checkin Document" screen to reflect the changes (e.g., rev # in the Document Title, Document Date, Doc Rev #, etc.)
6.1.4.5 NGO Radwaste reviews the current PDF in NEDL Portal against the hard copy to verify all is correct 6.1.5 PCP Manual Revision and Approvals Record Retention Transmit a hard copy of the following to NGO Document Support:
6.1.5.1 Verified current PDF 6.1.5.2 Email approvals 6.1.5.3 The appropriate transmittal form (e.g., Nuclear Work Request Transmittal Form) with the following information:
A. Record/ Retention Title:
"Process Control Program" B. Retention #:
"006644" C. QA Condition:
"N/A" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 "PCP Manual Revision Publication Process" PCP APP F 14 of 22 Rev 0 NEDL SDQA "C" D. Document Title:
"PCP Manual - "Section Name" rev # (ref: PCP Revision History - Rolling Frame # 2096)"
NOTE: Rolling frame # 2096 cont ains the PCP historical record of revisions prior to 2002. Example entry: "
PCP Manual-APPENDIX A ONS PCP rev 13 (ref: PCP Revision Hist ory - Rolling Frame # 2096
)" E. Handwrite the "Document Title" information on the front of the hard copy (e.g., "PCP Manual-APPENDIX A ONS PCP rev 13(ref: PCP Revision History - Rolling Frame # 2096
)) F. NGO Document Support films the hard copy of the PCP Manual section and the email approvals and sends the film to
the vault G. NGO Document Support adds the Microfiche reference information to the index in Scribe.
6.1.6 NSRB Review of PCP Manual Revisions 6.1.6.1 Each time a PCP Manual section is revised the NSRB shall review it.
6.1.6.2 Transmit a memo communicating what PCP Manual sections were revised and how to access the online manual to the NSRB through NGO Document Support.
6.1.6.3 NGO Document Support adds the transmittal information to the index in Scribe.
6.1.7 NGO Satellite File Print out hard copy to place in the NGO Chemistry Satellite File 6.1.8 NRC Review of PCP Manual Revisions PCP Manual revisions shall be sent to the NRC in each station's Annual Effluent Report each year. If no revisi ons occurred, a communication shall be RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.1 "PCP Manual Revision Publication Process" PCP APP F 15 of 22 Rev 0 NEDL SDQA "C" transmitted to Regulatory Compliance at each site documenting that no revisions occurred. During thos e years revisions do occur:
6.1.8.1 The transmittal shall be done in time to meet the May 1 deadline for the Annual Effluent Report.
6.1.8.2 The transmittal shall include a cover letter explaining the transmittal contents.
6.1.8.3 The transmittal shall include copies of all revisions to the PCP Manual effective during the report year using the media preferred by the NRC. (e.g., CD ROM, hard copy, etc.)
6.1.8.4 The transmittal shall include the current revisions of the following:
- The CORPORATE PCP
- The applicable site-specific PCP section, (i.e., APPENDIX A, B, or C) for each site
- APPENDIX D "APPROVED SUPPLIERS OF PCP SERVICES"
- APPENDIX E "PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS"
- APPENDIX F "ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS"
- APPENDIX G "WASTE PROCESSOR CHECKLIST"
- APPENDIX H "REVISION
SUMMARY
- LICENSEE INITIATED CHANGES"
- Include a copy of all intermed iate but superseded revised sections that were created during the report period as attachments for information.
6.1.8.5 NGO Document Support updates the Scribe index with the transmittal information.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.2 "Chemistry Distribution of Radwaste Vendor Documents" PCP APP F 16 of 22 Rev 0 NEDL SDQA "C"
6.2 Chemistry
Distribution of Radwaste Vendor Documents
6.2.1 Controlled
Radwaste vendor documents are received by NGO Radwaste via the vendor document transmittal process.
6.2.2 Radwaste
Vendor Document Review 6.2.2.1 The document is reviewed to determine the type of document and the revision scope 6.2.2.2 If it is a supporting document not referenced in Chemistry PCP implementing procedures, A. It is reviewed for impact but no VTI impact assessment is done. B. The Radwaste intranet home page index is updated and the controlled hard copy is placed in the NGO satellite file C. If the change is significant the sites are notified of the change and a summary is provided. The new revision is made available in the appropriate location and the Radwaste intranet home page index is updated D. If the change is not significant, the sites are not notified when the Radwaste intranet home page index is updated.
6.2.2.3 If the document is used or referenced in a PCP implementing procedure, A. The sites are notified of the document revision and pending assessment in case planned or current field activities or
operating procedure revisions could be impacted.
B. The NSD 319 VTI impact assessment is performed as described in Enclosure 6.3.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.2 "Chemistry Distribution of Radwaste Vendor Documents" PCP APP F 17 of 22 Rev 0 NEDL SDQA "C"
6.2.3 Radwaste
Vendor Document Publication and Storage 6.2.3.1 All vendor documents received by Nu clear Chemistry are filed as hard copies in the GO Nuclear Chemistry Satellite File located in
ECII 0745-59. The publication and ar chival of vendor documents are based on the categories below.
A. Vendor documents used in Nuclear Generation Chemistry PCP implementation procedures are published electronically in NEDL Miscellaneous Library and also filmed for archival under Retention Policy Record # 006644.
B. Radwaste Vendor documents that were used to approve a PCP vendor for the QA Approved Supplier List are not published but are filmed for archival under Retention Policy
Record # 006644 C. Miscellaneous vendor documents that NGO Radwaste maintains for PCP QA, program & contract support are not published, but are filmed for archival under Retention Policy
Record # 006644.
6.2.3.2 All Radwaste vendor documents on controlled distribution to Chemistry are listed in an index accessible from the NGO Radwaste Intranet home page. Vendor document numbers, titles and current revision numbers are displayed in the index on the NGO Radwaste intranet home page or via links on the home page
6.2.4 Radwaste
Vendor Document Prepara tion for Electronic Publication 6.2.4.1 NGO Radwaste is responsible for distribution of Radwaste vendor documents for Chemistry use 6.2.4.2 Controlled Radwaste vendor documents are received by NGO Radwaste in hard copy format. To accomplish electronic
distribution, an approved read-only electronic format (e.g., PDF) is created by one of the following methods:
A. Hard copies are scanned in to an approved read-only electronic file format using a software application approved RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.2 "Chemistry Distribution of Radwaste Vendor Documents" PCP APP F 18 of 22 Rev 0 NEDL SDQA "C" for such use by the applicable Nuclear Generation administrative program, or B. NGO Radwaste obtains electronic files from the vendor and the electronic files are convert ed to the approved read-only software application format.
6.2.4.3 Verify the read-only electronic file against the control hard copy. Document the verification date in the vendor document index on the NGO Radwaste intranet home page
6.2.5 Electronic
publication on the intranet Radwaste Home Page, 6.2.5.1 Copy the verified read-only file to the appropriate server location 6.2.5.2 Update the backup intranet hom e page files in the test environment with the new link information.
6.2.5.3 Verify the intranet page in the test environment.
6.2.5.4 Transfer the verified files to the production environment and verify the page functionality.
6.2.5.5 Notify NGO Radwaste customers of the updates.
6.2.6 Electronic
publica tion in NEDL, 6.2.6.1 Notify NGO Document Support of the revision.
6.2.6.2 NGO Document Support transitions the current NEDL revision of the read-only file to "WORK IN PROGRESS" 6.2.6.3 NGO Radwaste "Checks out" the file.
6.2.6.4 The new revision read-only file is "Checked In".
6.2.6.5 NGO Document Support transitions the current revision file to "REVISED" and the new revision file to "ISSUED".
6.2.6.6 NGO Radwaste is notified and the document view in NEDL is verified against the hard copy.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.2 "Chemistry Distribution of Radwaste Vendor Documents" PCP APP F 19 of 22 Rev 0 NEDL SDQA "C"
6.2.7 Archival
Transmit a hard copy of the verified new revision to NGO Document Support with the appropriate transmittal form, (e.g., Micrographics Nuclear Work Request form) including the following information:
6.2.7.1 "Record/ Retention Title": Process Control Program 6.2.7.2 "Retention #":
006644 6.2.7.3 "QA Condition":
N/A 6.2.7.4 "Document Title":
PCP-XX-XX-XXX, Rev XX
("PCP-" should precede the vendor assigned document number) 6.2.7.5 Handwrite the "Document Title" information on the front of the hard copy (e.g., "
PCP-FO-OP-023, Rev 20
") 6.2.7.6 NGO Document Support films the hard copy and sends the film to the vault 6.2.7.7 NGO Document Support adds the Microfiche reference info to the index in Scribe.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.3 "NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry" PCP APP F 20 of 22 Rev 0 NEDL SDQA "C" 6.3 NSD 319 VTI Impact Assessment Proce ss for PCP Related Vendor Documents Used In Chemistry
6.3.1 Vendor
Documents are r eceived by NGO Radwaste 6.3.2 The document is reviewed and its applicability is determined 6.3.3 If the document is a supporting reference document that is not specifically used in the Nuclear Generation Chemistry operating procedures for dewatering wet wastes, the VTI assessment is not performed.
6.3.3.1 The procedure is reviewed to determine if the changes are significant enough to be comm unicated to the sites.
6.3.3.2 If the change is significant, the changes are summarized in a communication to the sites 6.3.3.3 If the changes are editorial or ot herwise not significant, then the hard copy is placed into the NGO Radwaste controlled vendor document manual 6.3.3.4 The NGO Radwaste intranet hom e page index is updated per ENCLOSURE 6.2 6.3.4 If it is a procedure used in a Nuclear Generation Chemistry PCP implementation operating procedure, the VTI assessment is performed.
6.3.4.1 NGO Radwaste does a preliminary review of the procedure to determine how significant the changes are.
6.3.4.2 NGO Radwaste contacts the sites with the revision information and provides the preliminary review results 6.3.4.3 The sites each determine whether the changes appear significant and make a decision about placi ng the procedure on hold pending the VTI Assessment 6.3.4.4 NGO Radwaste creates the electr onic file per ENCLOSURE 6.2 RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.3 "NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry" PCP APP F 21 of 22 Rev 0 NEDL SDQA "C" 6.3.4.5 The read-only file is made accessible per ENCLOSURE 6.2 and becomes the current revision for site to use 6.3.5 VTI Assessment Process Steps 6.3.5.1 Radwaste Support performs the VTI assessment for each of the sites using the guidance in NSD 319 6.3.5.2 The assessments for all three sites are documented in a summary document form created for this process.
6.3.5.3 A GO PIP is initiated to document the review summary. These PIPs have no corrective actions unless a revision to the PCP is required.
6.3.5.4 A site PIP is initiated for each site to review the VTI assessment and document each site's determination:
A. That procedure changes are not needed and no Corrective Actions are taken, OR B. That a procedure change is needed and Corrective Actions are created accordingly to track the procedure change.
6.3.5.5 The DRAFT VTI file and the procedure file are transmitted via Email to the Radwaste PCP Subj ect Matter Expert (SME) and responsible General Supervisor at each site for their review and comments.
6.3.5.6 To edit the VTI file electronically and save the changes for NGO Radwaste to review, the file must be detached from the email:
A. The downloaded files are opened from the reviewer's hard drive to perform their assessment adding comments or changing answers in the draft VTI assessment file.
B. The file is saved and attached to an email & returned to NGO Radwaste.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX F ENCLOSURE 6.3 "NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry" PCP APP F 22 of 22 Rev 0 NEDL SDQA "C" 6.3.5.7 The review can be performed using a printed out copy A. Launch the file and print from within the application B. Review and red mark changes C. Return to NGO Radwaste by fax at 382-3797 or D. Interoffice mail to the NGO Radwaste person E. Send an Email to NGO Radwas te indicating that the comments are en route 6.3.5.8 The reviewer can use an electronic or printed copy to review the files and then send summary comments via email.
6.3.6 If no changes are needed, an email is sent to Radwaste Support to document the site's concurrence with the assessment.
6.3.7 If changes or comments are added, the revised VTI files are used by NGO Radwaste for incorporation of SME answers and comments into the final version. 6.3.8 NGO Radwaste finalizes the VTI assessment form and updates the GO PIP to document the review summary and cross reference the site PIPs.
6.3.9 The VTI summary information is added to the NGO Radwaste intranet home page index.
6.3.10 The VTI file is made accessible via a link in the index on the intranet home page 6.3.11 The need for a procedure change is documented in the index on the intranet home page 6.3.12 PIP numbers are documented in the i ndex on the intranet Radwaste Support home page for reference.
NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G WASTE PROCESSOR CHECKLIST REVIEWED BY/ DATE: __GT Johnson/ 12/18/02___ _DL Vaught/ 12/16/02___
NGO Radiation Protection NGO Chemistry
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev: 6-20-00 WASTE PROCESSOR CHECKLIST PCP APP G 1 (Revision 6-20-00) NEDL SDQA "C" NOTE: (This Checklist is a template and should be edited, as appropriate, for each individual company's Review)
Process Control Program (For Ven dors who use a PCP to process wet wastes for disposal at a 10CFR61 licensed disposal site)
- 1. Verify that the vendor's Process Control Program (PCP), Quality Assurance program and other Dewatering or Solidification process related documents as described in the Radioactive Waste PCP for Duke Energy meet the requirements of the PCP. This is a PCP requirement.
Site License
- 1. Review the Vendor's Radioactive Material License and ensure that the specific license requirements are being meet.
State Regulations
- 1. Review the applicable State Regulations and ensure that any specific requirements are being met.
DOT Regulations
- 1. Does the Vendor meet the requirements of 49 CFR 172 Subpart H-Training? Requirement: Each employer is required to provide general awareness, function specific, and safety awareness training for each Hazmat employee.
Training record keeping is required.
- 2. Does the Vendor meet the requirement s of 49 CFR 172 Subpart I-Radiation Protection Program? Requirement: Each employer is required to develop, implement, and maintain a written Radiation protection program. The Vendor should perform and document an audit of the RP program annually.
Pre-planning
- 1. Has the shipper been trained in D.O.T. hazardous materials requirements?
- 2. Has the shipper or other site designee been trained to sign a waste manifest?
- 3. Has the waste been characterized and a profile approved with the Treatment, Storage or Disposal Facility (TSDF)?
- 4. Are there State-specific ID numbers that must be obtained by the shipper or carrier?
- 5. Is the release criteria for low-level radioactive waste documented?
- 6. Can it be demonstrated that instruments used to determine release criteria have been calibrated?
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev: 6-20-00 WASTE PROCESSOR CHECKLIST PCP APP G 2 (Revision 6-20-00) NEDL SDQA "C"
- 7. Does the carrier have a hazardous waste/radioactive waste transporter permit valid in all states that will be traveled?
- 8. Insurance coverage in the amounts required by DOT and the relevant states?
- 9. Has the route to the TSDF from the site been planned in advance with the carrier?
- 10. Does this route cross any states that require a shippers permit (Examples: Mississippi, Colorado) or a carriers temporary trip permit (Examples: Georgia, Maryland) for hazardous or radioactive materials/wastes?
- 11. If yes to # 9, has the shipper or carrier obtained these permits in advance of the ship date (allow at least 30 days lead- time for a shippers permit)?
- 12. In South Carolina, has a specific route been documented for low-level radioactive waste? Packaging
- 1. Does the package meet D.O.T. specifications?
- 2. Is the package in good condition (no signs of weakness, deterioration or staining)?
- 3. Is the package securely closed/sealed?
- 4. Is there a package inspection process/documentation?
- The D.O.T. proper shipping name?
- The D.O.T. hazard class and corresponding labels?
- The UN/NA number?
- To and From addresses?
- EPA hazardous waste or Non-hazardous waste label?
- Manifest number?
- EPA Waste I.D. Number
- TSDF's Waste profile/approval code?
Manifest and Attachments
- 1. Are State or supplier-specific data pr ovided in the state manifest block?
- 2. Is the generator identification complete and correct including phone number?
- 3. Are the page numbers clearly marked?
- 4. If photocopies are used, is th e original identified as such in contrasting color?
- 5. Is the transporter's ID and correct phone number provided?
- 6. Are the D.O.T. descriptions correct and do they match the packaging?
- 7. Is the package count and weight correct?
- 8. Are waste codes and profile/approval codes entered?
- 9. Is a 24-hour emergency contact phone number provided? Is information truly available through this contact during off-hours? Are drills conducted?
- 10. Is the generator's printed name, signature, and date entered correctly?
- 11. Is the driver's printed name, signature, and date entered correctly?
- 12. Is a land disposal restriction (LDR) form attached for hazardous waste? If applicable:
- Does the LDR have the correct generator name/location?
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX G Rev: 6-20-00 WASTE PROCESSOR CHECKLIST PCP APP G 3 (Revision 6-20-00) NEDL SDQA "C"
- The EPA ID number?
- The manifest number?
- The waste profile/approval number and corresponding descri ption, treatability group, waste constituents, and universal treatment standards?
- Generator's printed name, title, signature, and date?
- 13. For low-level radioactive waste in South Carolina, is the Drivers Instruction Sheet attached?
- 14. Has it been confirmed with the TSDF that the third-signature manifest is returned to the generator within 20 days for low-level radioactive wast e or 30 days for hazardous waste? Transporter
- 1. Is there a vehicle inspection documented prior to departure?
- 2. Does the driver have a Commercial Dr ivers License with Hazardous Materials endorsement?
- 3. Does the driver keep the manifest and ot her shipping documents within reach in the truck? 4. Has the driver been instructed on the route for low-level radioactive waste?
- 5. Does the driver have copies of any shipper or temporary carrier permits needed for this route/trip?
Radiological Conditions
- 1. Are all radiological postings legible/consistent?
- 2. Are all radiological labels is legible/consistent?
- 3. Are RWP's posted?
- 4. Do workers read/understand the RWP?
- 6. Do the workers know the dose limits of their RWP?
- 7. Are workers properly wearing/read ing/recording their dosimetry?
Waste Tracking
- 1. How does the vendor track each customers waste through the different waste processes?
- 2. How does the vendor account for the waste activity through each process/disposal site? 3. How does the vendor determine Type Quantity/Waste Class on a package with several customer's waste?
- 4. Does the vendor consider (and document compliance with) requirements of the BTP on Concentration Averaging?
NEDL SDQA "C" RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Revision Summary - Licensee Initiated Changes RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 1 Current Revision Summary - Licensee Initiated Changes PCP APP H Page 1 of 2 Rev. 1 NEDL SDQA "C" NOVEMBER 2003 REVISION 14 OF CORPORATE PCP (CONSERVATIVE GUIDANCE FROM ROOT CAUSE)
Revision 14 to the Corporate PCP section of the Radioactive Waste Process Control Program Manual incorporates additional guidance for dewatering activities to ensure adequate conservatism is provided by the PCP implementing procedures. An event involving the failure of a dewatered HIC to meet the free standing liquid (FSL) limits at Barnwell and the subsequent root cause investigation identified changes that would provide greater confidence in meeting the FSL requirements. Also some editorial changes not related to the root cause evaluation were made. The changes are summarized below. Added the PIP references associated with the Root Cause in O-03-0624, and the applicability evaluation PIPs at MNS and CNS, M-03-2515 and C-03-3385 to section 4, "DUKE ENERGY PROGRAMMATIC REFERENCES". Added two additional Regulatory Guidance references to Section 3, "Regulatory References" 3.2.10 NRC "TECHNICAL POSITION ON WASTE FORM" Revision 1 (January 1991) 3.2.11 ANSI/ANS-40.37-1993 "mobile radioactive waste processing systems" Added item 5.17 in section 5, "DEFINITIONS" to describe the Topical Report, its significance in the development of the PCP and how its applicability to actual conditions can impact the degree of conservatism needed. Added section 7.5, entitled "Periodic cross-checks & comparisons" that addresses a requirement from the Root Cause evaluation for benchmarking the ONS dewatering processes. Added section 11.3 entitled "Additional Conservatism in Slurry Dewatering Procedures to Address Variation from the Topical Report (PIP O-03-0624, M-03-2515, C-03-3385)" to incorporate the specific additional guidance needed in dewatering procedures at all 3 sites. The Root Cause identified corrective actions required to prevent recurrence (CAPR) and other enhancements that were evaluated for consideration on a site by site basis. Only the corrective actions that were applicable to all three sites have been incorporated into the Corporate PCP. Those corrective actions that were more site-specific have been incorporated in the site implementing procedures as needed. Added section 11.3.1 that describes the need to include procedural flexibility/ guidance for Chemistry to add conservatism to any PCP dewatering process if waste content and/ or process conditions are atypical in a non conservative manner and provides examples of such actions. Added section 11.3.2 that provides guidance for procedures used to dewater liners using a PCP for direct disposal at Barnwell based on the PIP O-03-0624 CAPRs summarized below:
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 1 Current Revision Summary - Licensee Initiated Changes PCP APP H Page 2 of 2 Rev. 1 NEDL SDQA "C" requires liner functional testing prior to filling liner with waste to ensure there are no leaks in the liner dewatering system requires that ambient temperature guidance for dewatering will preclude localized freezing conditions during the dewatering sequence requires that the final water collection sample point must be representative (e.g., as close as possible to the pump discharge) Added section 11.3.3 to address PCP dewatering procedures for Mixed Media with significant non-media solids: requires use of Ecodex filter system in all liners that contain mixed media with significant non-media solids requires that procedures clearly specify media loading sequence if media is not homogeneously mixed to minimize potential blinding of the lowest level of filters requires additional dewatering Cycles for mixed media liners after the acceptance criteria in the vendor procedure have been met requires longer settling periods during the additional dewatering cycles requires dewatering through bottom 2 laterals during liner filling based on the Topical Report requirement to establishes proper media compaction and capillary conditions requires initial liner unwatering upon completion of final waste transfer to liner In Sections 11.5.2.1, 11.5.3.1, 11.5.4.2 D added wording to clarify that FSL verification can be accomplished using either an onsite PCP process or an approved offsite vendor process.
END OF CURRENT REVISION 1
SUMMARY
NOVEMBER 2003 REVISION 14 OF CORPORATE PCP (CONSERVATIVE GUIDANCE FROM ROOT CAUSE)
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 1 of 9 Rev. 0 NEDL SDQA "C" MARCH 2003 MANUAL REWRITE OVERVIEW The Duke Energy Radioactive Waste Process Control Program Manual is a rewrite of the original DPCo PCP. The Corporate PCP and Introduction chapters of the DPCo PCP have been revised many times to incorporate critical changes, but have not been rewritten since the original publication.
During the ensuing period many new programs and processes have been developed within Duke Energy, disposal site requirements and availability have changed and new process options are now available in the commercial Radwaste industry. This rewrite attempts to incorporate these changes, integrate the PCP Manual with other programs within Duke Energy and create flexibility for future
administration. The reissued manual attempts to address specific issues identified in numerous audits and Problem Investigation Process (PIP) reports. The PIPS listed below identified changes needed or were associated with this revision: G-00-0401 (QA Audit of NGO PCP & support documents. This PIP incorporated corrective actions from C-01-02522, O-01-01067, G-99-00349, C-99-05094) G-02-0272 (QA Audit of PCP Support Documentation) C-01-02522 (NRC CNS Audit - Offsite Vendors) O-01-01067 (ONS Filter HIC Dewatering Clarification) O-00-4680 (ONS Filter dewatering procedure use) G-99-00349 (NGO Radwaste Support PCP Evaluation) C-99-05094 (SLC Change Issues)
DETAILED DISCUSSION OF CHANGES
- 1. MANUAL ORGANIZATION AND FORMAT CHANGES The reorganization of the PCP segregates technical requirements from administrative information to reduce the necessity for performing revisions with their associated management approvals every time administrative and non-technical changes occur. (i.e., the Corporate PCP defines the program requirements, the administrative appendices provide details of how the program and associated documents are managed) The regulatory and SLC requirements are contained in the Corporate PCP section of the manual. Where guidance is addressed in more detail by other Duke Energy programs, a reference to that program replaced the redundant information in the earlier version of PCP. (e.g., EWP 2.8 "Waste Oil" and 2.9 "Mixed Waste")
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 2 of 9 Rev. 0 NEDL SDQA "C" The details of the manual reorganization are discussed below.
1.1 Old PCP Manual Organization The superseded DPCo Process Control Program was organized as follows: I. Introduction II. Corporate PCP Rev 12 III. ONS PCP Rev 11 IV. MNS PCP Rev 16 V. CNS PCP Rev 10 VI-IX. Contained FOR INFO ONLY regulatory and historical reference information that was not considered part of the controlled document.
1.2 New PCP Manual Organization The new PCP Manual is organized as follows: CORPORATE PROCESS CONTROL PROGRAM Rev 13 The Corporate Process Control Program (PCP) contains the technical requirements previously contained in Chapters I and II in the DPCo PCP. The details of this revision are summarized in section 2 below, "Corporate PCP Changes". APPENDIX A "OCONEE NUCLEAR STATION PCP" Rev 12 This revision of the Oconee PCP incorporates the new manual formatting and the removes the exception to the Corporate PCP pertaining to vendor approvals. Previously each site PCP contained an exception to the Corporate PCP requirement that the Station Manager or his designee had to approve solidification or dewatering services. This exception was incorporated into the Corporate PCP such that only corporate review and approval of vendor solidification and dewatering services are now indicated.( Ref: PIP
G-00-0401) The Chemistry procedure CP/3/B/5200/08A "Unit 3 High Activity Spent Resin Storage Tank (HASRST) Resin Transfer to Disposable Liner" was removed from the implementing procedures list because the PCP activities associated with this procedure have been eliminated.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 3 of 9 Rev. 0 NEDL SDQA "C" APPENDIX B "McGUIRE NUCLEAR STATION PCP" Rev 16 This revision of the McGuire PCP incorporates the new manual formatting and the removal of the exception related to vendor approvals. Previously each site PCP contained an exception to the Corporate PCP requirement that the Station Manager or his designee had to approve solidification or dewatering services. This exception was incorporated into the Corporate PCP such that only corporate review and approval of vendor solidification and dewatering services are now indicated.( Ref: PIP G-00-0401) The procedure OP/0/B/6200/065, "Transfer of Powdex to a Disposable Liner" has been removed from the McGuire PCP implementing procedure list. The PCP activities in this procedure have been incorporated into two other procedures already on the list, OP/1/B/6200/102, "Unit 1 CM Backwash Tank Operation" and OP/2/B/6200/102, "Unit 2 CM Backwash Tank Operation". The procedure HP/0/B/1004/032, "Procedure for Packaging Radioactive Filters", used for filter dewatering and packaging was added to the implementing procedure list. APPENDIX C "CATAWBA NUCLEAR STATION PCP" Rev 10 This revision of the Catawba PCP incorporates the new manual formatting and the removal of the exception related to vendor approvals. Previously each site PCP contained an exception to the Corporate PCP requirement that the Station Manager or his designee had to approve solidification or dewatering services. This exception was incorporated into the Corporate PCP such that only corporate review and approval of vendor solidification and dewatering services are now indicated.( Ref: PIP G-00-0401) The CNS PCP procedure list was revised as follows: Corrected the entry for Chemistry procedure OP/1(2)/A/6250/016 "Operating Procedure for the, Condensate Polishing Demineralizer Backwash Tank Subsystem" to reflect that it is a "B" procedure and is unit specific. The entries are now OP/1/B/6250/016 "Condensate Polishing Demineralizer Backwash Tank Subsystem -
Unit 1" and OP/2/B/6250/016 "Condensate Polishing Demineralizer Backwash Tank Subsystem - Unit 2". Revised entry for OP/1(2)/B/6500/053 to reflect current Unit specific titles OP/1/B/6500/053 "Transfer and Dewatering of Contaminated Secondary Resin Unit 1" and OP/2/B/6500/053 "Transfer and Dewatering of Contaminated Secondary Resin Unit 2". Removed Chemistry procedure OP/0/B/6500/072 "Operating Procedure for Filter HIC Operations" because it was deleted and is no longer needed.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 4 of 9 Rev. 0 NEDL SDQA "C" APPENDIX D "APPROVED SUPPLIERS OF PCP SERVICES" Rev 0 This appendix lists the approved vendors and their services and provides additional detail of requirements contained in other documents. (e.g., vendor contract, purchase order, etc.) Removal of this detail from the Corporate PCP minimizes the number of revisions to the technical portion of the manual due to the unpredictable nature of vendor ownership and commercial changes. The Corporate PCP still describes the approval process and requires PCP service vendors to be incorporated into the QA supplier program. This program utilizes industry QA audits to monitor and verify vendor performance against customer program requirements. A note has been added to the computerized "Approved Supplier List" to ensure PCP vendors are maintained in the program unless NGO Chemistry requests or approves their removal. APPENDIX E "PCP MANUAL REVIEW AND APPROVAL REQUIREMENTS" This section summarizes in a tabular format the required reviews and approvals for revisions to the PCP Manual. This was previously discussed in the body of the Corporate PCP. The approval process is described in APPENDIX F. Additional approval requirements were added for the new appendices based on their significance to the regulated portion of the manual. Additional reviews by RP will be documented for those parts of the manual affecting their programs. The previous PCP included only Chemistry and station manager reviews and approvals. The formal RP review is intended to broaden awareness of and input to PCP requirements and improve integration of the PCP with other related programs and activities. APPENDIX F "ADMINISTRATION OF THE PCP AND SUPPORT DOCUMENTS" This appendix describes the administrative processes used to manage and publish the PCP Manual and the supporting documents required to maintain it. This information was not contained in any detail in the prior versions of the PCP manual and has been added to address many of the document control issues identified in historical audits and recent PIPs. The process used to publish the manual electronically is described in detail to address SDQA requirements. APPENDIX G "WASTE PROCESSOR CHECKLIST" This document is a template used by NGO RP and Duke Energy Environmental Health Services to evaluate waste services. The document was revised and added to the PCP to ensure that vendors who provide PCP services are evaluated against the Duke Energy PCP and approved by the NGO Chemistry organization.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 5 of 9 Rev. 0 NEDL SDQA "C" APPENDIX H "REVISION
SUMMARY
- LICENSEE INITIATED CHANGES" This appendix incorporates revision summary information that in the past was contained in a transmittal letter. Incorporation of the revision discussion is consistent with the ODCM and other program documents where it is desirable to maintain a retrievable revision history.
1.3 Publication
Changes The manual reorganization facilitates the use of current administrative processes and electronic publication. Electronic publication is more user-friendly and addresses the PCP's problematic history related to the obscurity of the hard copy PCP manual. It also enhances administrative controls needed to ensure the most current revisions are used.
(Ref: PIPs G-99-00349, G-00-0401) The new PCP Manual is being published in the NEDL Portal under Electronic Licensing Library (ELL). Electronic publication enhances reference capability as described in NSD 228 APPENDIX B. In order to enhance the quality of NSD 228 applicability reviews, NSD 228 recommends that documents considered part of the licensing basis elements should be published electronically for easy and consistent utilization. The PCP and ODCM are licensing basis elements and historically have been grouped together in many Tech Spec and regulatory references. This revision aligns the PCP with the ODCM in its publication format, online accessibility, user interface, and administrative
processes.
1.4 Formatting
Changes The new PCP has been reformatted using Nuclear Generation document font and formatting standards as described in the Procedure Writers' Guide and NSD 100. The Word template used is "procopta.dot", modified to resemble the headings and hierarchy in the ODCM.
- 2. CORPORATE PCP CHANGES
2.1 Clarification
of Programmatic linkage between Tech Specs, SLC and the PCP (Ref: PIPs C-99-05094, G-00-0401) The references below contain specific PCP requirements. A list of these and other Duke Energy program documents that impact the PCP Manual was added to the Corporate PCP to ensure that future PCP Manual revisions and revisions to implementing procedures would include these documents in the review process.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 6 of 9 Rev. 0 NEDL SDQA "C" 2.1.1 The requirement to include revisions to the PCP in the Annual Radiological Effluents Report to the NRC is found in the following: Oconee Technical Specification 5.6.2 "Annual Radiological Environmental Operating Report" Catawba SLC 16.11-16 "Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report" McGuire SLC 16.11.17 "Radioactive Effluent Release Report" 2.1.2 The Commitment to have a Process Control Program, description of its applicability, specific Remedial Actions and Surveillance Requirement are in the following SLCs: Catawba SLC 16.11-11 "Solid Radioactive Waste" McGuire SLC 16.11.11 "Solid Radioactive Waste" Oconee SLC 16.11.5 "Solid Radioactive Waste" The "Solid Radioactive Waste" SLCs listed above were submitted for revision during 2001-2002 to address intersite program consistency issues, inaccurate references to the Process Control Program (PCP) applicability and content.
The wording in this PCP Manual rewrite incorporates the language in the SLC
revision. The SLC requirements were added to the Corporate PCP introduction to clarify SLC compliance. Those PCP requirements that specifically address SLC Remedial Actions and Surveillance Requirements in sections 10 and 11 are identified.
2.1.3 The following SLCs contain the commitment to have a Technical Review and Control Program covering the preparation, review, and approval of documents important to station operation, including review of PCP revisions by the NSRB: Catawba SLC 16.13.2 "Technical Review and Control" McGuire SLC 16.13.2 "Technical Review and Control" Oconee SLC 16.13.2 "Technical Review and Control" 2.2 New Sections in the Corporate PCP The following new sections were added to the Corporate PCP to consolidate and emphasize requirements under major headings that more closely align with the organization of other Duke Energy program guidance documents: Applicability RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 7 of 9 Rev. 0 NEDL SDQA "C" Duke Energy Programmatic References Definitions This section lists definitions needed to interpret the PCP and consolidates them into one section. Responsibilities Specific responsibilities were clarified and the need for all site programs that impact the generation and management of liquid & wet radioactive wastes to support compliance with the PCP was emphasized. Administration of the PCP and Support Documents Consolidates all of the administrative requirements into one section and refers to the details contained in APPENDIX F. Approval Process for QA Approved Suppliers This section describes and clarifies the linkage between existing Supply Chain processes and PCP compliance involving vendors. The incorporation of vendor PCP services into the QA Approved Suppliers List and its associated NUPIC QA Audit process is a critical component of maintaining required oversight of PCP compliance. PCP Requirements for Vendor Processes and Services This section consolidates vendor program and process requirements into one section. 2.3 PCP Retention Requirements Changes The record retention requirements were revised in the Duke Energy Information Retention Policy to align with other records that have long term litigation significance.
The PCP rewrite incorporates these changes in APPENDIX F. Archive requirements were expanded to include vendor documents used to implement the PCP requirements.
2.4 Vendor
Names and Service Information Update (Ref: PIPs G-99-00349, C-01-02522) The original version of the Corporate PCP was written when the only vendor services available were onsite mobile units that were interfaced with plant equipment and the final waste form was accomplished prior to shipping the waste offsite. Most current vendor services are offsite processes performed at the vendor location. To accommodate this, the discussion of Radwaste vendors was expanded to include offsite processing.
Details of the vendor approval process and documentation requirements were enhanced and the interface with Supply Chain processes emphasized.
RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 8 of 9 Rev. 0 NEDL SDQA "C"
2.5 Changes
in the Solidification Section The guidance for solidification was rewritten to be more of a guideline of the minimum content required for implementing procedures. The technical requirements for solidification of liquid or wet wastes to meet regulatory requirements have not changed. This section was reorganized to provide an outline of the major process steps that must be included in solidification procedures to adequately address the PCP requirements for a solidification process. Redundant presentation of information due to the organization of the prior version was removed. (e.g., the "Introduction" chapter contained solidification discussion that was repeated in the "Solidification" section of the Corporate PCP chapter) Notation identifying requirements derived from SLC was added for clarity in developing or reviewing implementing procedures. Guidance was updated to incorporate vendor support.
2.6 Expanded
Guidance for Dewatering (Ref: PIPs O-01-01067, G-00-0401) The dewatering section, 11, in the new Corporate PCP) contains all of the requirements from the previous version, but was revised to clarify the distinctive requirements for dewatering of mechanical filters and media. The discussion of mechanical filter dewatering was expanded to clarify the distinction between dewatering filters to meet PCP requirements and removal of FSL from the filter disposal container. Requirements derived from SLC are identified for clarity in developing or reviewing implementing procedures. Guidance was updated to incorporate vendor support and lessons learned.
- 3. ADMINISTRATIVE PROCESS CHANGES Most of the processes used to administer the PCP changed during the rewrite of the PCP Manual. This level of detail was not documented in the DPCo PCP. It was added to address the many administrative issues described in the PIPs listed above. APPENDIX F describes the requirements for administering the Process Control Program and the documents required to implement the program. It details the administrative processes used to implement several of the requirements contained in the Corporate PCP. The following list summarizes the major processes that are detailed in APPENDIX F. Enclosure 6.1 "PCP Manual Revision Publication Process" This enclosure describes in detail the revision process in the electronic environment. Significant changes from the old process are: Electronic routing of the manual for review and approval RADIOACTIVE WASTE PROCESS CONTROL PROGRAM MANUAL APPENDIX H Rev: 0 Prior Revision Summary - Licensee Initiated Changes PCP APP H Page 9 of 9 Rev. 0 NEDL SDQA "C" Electronic approval using email responses to communicate approval. The email will be printed out and included in the archive of the revision as documentation of required
approvals. Publication process using Scribe for user viewing in the NEDL Portal Process for transmittal of the PCP revisions to the NRC only once per year in the Annual Radioactive Effluents Report. Historically the PCP sections were transmitted to the NRC at the time they were revised to allow for page by page insertions in the hard copy manuals maintained by the NRC. The new process is similar to the process used for the ODCM. Enclosure 6.2 "Chemistry Distribution of Radwaste Vendor Documents" A detailed administrative process for electronic publication, archival and incorporation of documents from approved suppliers comprises this enclosure. Although portions of this process have been used for the past two years, it is now documented in the manual and adds the archival requirements and process. Enclosure 6.3 "NSD 319 VTI Impact Assessment Process for PCP Related Vendor Documents Used In Chemistry" This enclosure describes the process for evaluating vendor documents for technical impact to the PCP and implementing procedures. The basis for this process is NSD 319 "Vendor Technical Information Program". It requires technical review by NGO and station Chemistry using a list of criteria from NSD 319 to determine if the changes in the document require any PCP related document revisions and documentation of the conclusions of the review in PIP.