ML20135G087

Rev 0 to Radwaste Solidification Sys

ML20135G087
Person / Time
Site:	Yankee Rowe
Issue date:	08/26/1985
From:	PACIFIC NUCLEAR SYSTEMS, INC.
To:
Shared Package
ML20135G079	List: ML20135G078 ML20135G087
References
TP-05, TP-05-R00, TP-5, TP-5-R, NUDOCS 8509180141
Download: ML20135G087 (56)

Text

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i 4 i i TOPICAL REPORT

} No. TP-05, Rev. 0 l

l RADWASTE SOLIDIFICATION  :

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i PNSI Radwaste Solidification System - TP-05 8/85  ;

O TOPICAL REPORT No. TP-05, Rev. O covering

PACIFIC NUCLEAR SYSTEMS, INC.

1 i RADWASTE SOLIDIFICATION SYSTEM Submitted to:

-l The Nuclear Regulatory Commission I

under the Procedure for Review of

Topical Reports on Solidification Agents i

() and High Intregity Containers April 1982 I By

, PACIFIC NUCLEAR SYSTEMS, INC.

1010 South 336th Street Federal Way, Washington 98003 1

August 26, 1985 1

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ABSTRACT

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This Topical Report is prepared by Pacific Nuclear Systems and J

describes the design and operation of a Portable Solidification l System, which has been developed to provide a portable, economi-

! cal and reliable method of solidifying radioactive waste, while ensureing that the waste form produced meets all of the require-I ments for the shipment and disposal of radioactive waste mater-4 ials. The-system described in this Report has been developed to allow use of the same liners and in-container mixing blade assem-blies that are used with the portable solidification system that 3 was described to the NRC in our Topical Report TP-04, dated April J

-11, _1985. The system has been designed to provide easier cement loading and added mixer torque. Testing was performed on the unit to verify the overall capability of the unit to perform i large liner solidifications and to confirm that~the liner in-3 container mixing assemblies, when used with the system, will t

produce a homogenously mixed, free standing monolith with no free I water.

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This Report includes a description of the solidification system,

! typical operation procedures, Process Control Procedures for j solidification o f- various waste forms using Envirostone(TM) or cement chemistry, and a description of the full scale testing of 4

the system. Use of Envirostone to solidify the waste forms l identified in this report is covered in United States Gypsum's Topical Report on Envirostone. Cement 10 CFR 61 Compliance Test-ing, dated May of 1984. For waste forms that do not fall within the Envirostone Topical, PNSI has initiated complete 10 CFR 61 Compliance Testing of various waste solidification chemistries,

and this information will be submitted to the NRC for review

under a separate topical report.

Use of the Pacific Nuclear System's Radwaste Solidification System, in compliance with the

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described PCP's, has proven to produce a final waste form which meets or exceeds all of the requirements of 10 CFR 61 and the NRC Technical Position on Weste Form.

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PNSI Radwaste Solidification System - TP - 05 8/85 i

I TABLE OF CONTENTS i

INTRODUCTION -------------------------------------------- 1.0 REFERENCES ---------------------------------------------- 2.0 EQUIPMENT DESCRIPTION ----------------------------------- 3.0 EQUIPMENT OPERATION ------------------------------------- 4.0 PROCESS CONTROL PROGRAM --------------------------------- 5.0 QUALIFICATION TESTING ----------------------------------- 6.0 QUALITY ASSURANCE --------------------------------------- 7.0 t

I APPENDICES

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A. Solidification System Pictures and Drawings B. Process Control Percedures C. Operating Procedure

D. Quality Assurance Program i

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PNSI Radwaste Solidification System - TP-05 8/85 O

1.0 INTRODUCTION

The Pacific Nuclear Radweste Solidification System is a portable system consisting of four component skids anu a fillhead and is designed to solidify various forms of radioactive waste using Envirostone or Portland Cement chemistry. The System uses in-container mixing in container sizes from 50 to 210 cubic feet.

The system has been designed and tested to ensure that a quality solidified end product can be consistently produced, while operat-ing the system in accordance with ALARA principles.

Process Control Procedueres addressed in this Topical call for the use of Envirostone(TM) to solidify all of the waste forms covered under United States Gypsun's Topical Report, dated May 12984. For waste forms that Pacific Nuclear will solidify that do not fall under the Envirostone Topical, PNSI will provide 10 CFR 61 test data using Envirostone or Portland Cement Chemistry to verify that a final waste product can be produced that will meet the requirements of the NRC. This test data will be pro-vided in a separate topical report at a later date.

This Topical Report has been written to provide the Nuclear Regulatory Commission with the information necessary to evaluate the adequacy of Pacific Nuclear System's Radwaste Solidification O System, with respect to it's ability to produce a solidified radioactive waste product which will meet the needs of nuclear utilities in the United States and the regulatory requirments of the US NRC.

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PNSI Radwaste Solidification System - TP-05 8/85

2.0 REFERENCES

I 2.1 10 CFR 61 2.2 United States Nuclear Regulatory Commission, " Technical Position on Waste Form", Dated May 1983 2.3 Criteria for High Integrity Containers, Washington State Radiation Control Program, August 25, 1983 2.4 Information to be Submitted in Support of a High Integrity Container Approval by the South Carolina Department of i

Health and Environmental Control Bureat of Radiological Health.

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, 2.5 Nuclear Packaging, Inc. Quality Assurance Program (USNRC System Approval No. 0192) 2.6 State of South Carolina Barnwell Site License 2.7 State of Washington Hanford Site License 2.8 Procedure for Review of Topical Reports on Solidification Agents and High Integrity Containers, dated April 1982 2.9 United States Gypsun's Topical Report for Envirostone (TM)

Gypsum Cettent 10 CFR Compliance Testing, dated May 1984 2.10 Pacific Nuclear Portable Solidification System Topical Report, TP-04, dated April 11, 1985 2-1

I 1 PNSI Radwaste Solidification System - TP-05 9/85

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5.0 EQUIPMENT DESCRIPTION f i The Pacific Nuclear Radweste Solidification System is a portable system consisting of four component skids and a fillhead, which can be positioned on a liner using a portable gantry crane. The ,

. system consists of a piping and offgas skid, a hydraulic power

! skid, a cement hopper and transfer system, a control skid, a

- gantry crane, a fillhead and the necessary interconnecting hoses and cables. The system is designed to provide Envirostone (TM) l or Portland Cement solidification of various waste forms using in-container mixing assemblies in liner sizes from 50 to 210 cubic feet. A description of the system components is as t

follows:

i Piping and Offgas Skid: The system piping skid houses the waste, dewater, service air, and service water valves and piping to i connect the power plant systems to the solidification fillhead.

I It -provides for sampling of waste atreams and contains valving

that ' allows an operator to flush the waste line into either the disposable container or back to the plant. Piping and valving 1 are provided to allow the return of excess slurry water to the  !

i plant, recirculation of the material in the disposable container

! for mixing or sampling, and pumping of the waste stream from the plant into the disposable container. The skid assembly contains

, casters for easy positioning and slots for handling with a fork- '

i lift truck. The syeten offgas blower and filter are also mounted ,

, on the piping skid frame. The offgas system consist of a regen-

! erative blower in combination with a replaceable cartridge type i particulate prefilter with a HEPA filter on the discharge. The ,

offgas system maintains a slight negative pressure on the solidi- ~

j fication liner, to preclude release of radioactive gases to the.

l atmosphere during waste processing. Air from the offgas sytem i can be discha,rged to the plant offgas vent system or directly to j atmosphere, at the plants option. '

Hydraulic Power t

1 Skid: The hydraulic power skid provides the l I motive' force.to turn the in-container mixing assembly within the

liner. It contains a 6000 psi hydraulic pump driven by a 30 Hp, 480 VAC motor, control valves, regulators, reservoir, and hy-draulic oil cooler. The maximum system operating pressure is l

regulated at 2500 psi-using an adjustable pressure relief valve.

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i Fillhead: The solidification fillhead connects to the disposable container- and provides the piping connections for waste inlet,

dewatering, offgas, waste treatment chemical addition, cement j addition, and air and water connections for internal washdown of i the fillhend. Housed in the fillhead are a CCTV camera and light, level controls, pressure and proximity switches and hyd- l raulic mixer noter. The cement conveyor motor is mounted on the

!, top of the fillhead. The fillhead is.provided with a hinged, )

! removable lower door for ease in connecting and disconnecting i i '

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a PNSI Radwaste4 Solidification System - TP-05 8/85

() from the dewatering leg (for removal of excess slurry water) level tubes, which connect to the inside of the disposable con-and

. tainer. The level controls are the bubbler type and provide for

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indication of waste full level, cement full level and liner high 4

level. A float switch is provided to prevent liner overflow and will provide automatic shutoff of the waste fill and cement transfer system, if actuated. Included in the fillhead design is>,

a camera port cleaning system using air to blow away dust from dry cement and water for removal of wet material.

Cement Hopper and Transfer System: Cement is transferred into

, the disposable container via a flexible tube cement auger system.

Cement bags are added to a hopper, which is equipped with two air driven vibrators, and a dust collection system. The cement auger is controlled from the main control panel and is powered by a

! variable speed, 480 VAC, 5 Hp motor. The cement hopper is j mounted on casters for ease in positioning and can be up to 30 i feet from the fillhead. '

t Gantry Crane: Positioning of the fillhead is accomplished with a 1 ton capacity gantry crane. The gantry is adjustable in size and is designed to straddle a truck mounted cask and allow placement and removal of the fillhead. The gantry is mounted on casters and can be easily pushed over a liner placed in a trailer mounted cask. Vertical positioning of the fillhead is O accomplishe'd by operation of a 1 ton capacity, chain hoist.

I Hp, The hoist is operated from a local pendant.

480 Vic i' i Control Skid: Control of the system is accomplished from the j operators panel on the control skid. The control skid houses the j

CCTV monitor and indications and controls for the following:

1 i a. Cement conveyer ON/0FF with indicator lights

{ b. Hopper Vibrator ON/0FF with indicator lights

c. Offgass Blower ON/0FF with indicator lights I

d. Dewater Pump ON/0FF with indicator lights

, e. Waste Valve OPEN/ CLOSED with indicator lights

f. Waste Level, Cement Level and High Level indicator j lights with audible alarm 4 g. Dimmer switch for fillhead light '

h. Keyed Main Power ON/0FF switch with indicator light

! i. Emergency Stop switch

! j. Container High Pressure indicator light with audiblg j alarm l k. Fillhead In-Position indicator light

1. High-High Level indicator light with audible alarm

m. Oil Heater ON/0FF with indicator light

n. Mixer Motor FORWARD / REVERSE selector switch

o. Mixer Motor Speed Control (0 - 100 %)

p. Hydraulic Power Supply ON/0FF with indicator lights

q. Hydraulic Tank Low Level indicator light l

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Hopper Filter System ON/0FF with indicator light Conveyor Motor Speed Control (0 - 100 %)

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i PNSI Radwaste Solidification System - TP-05 8/85 O The control system also provides interlocks such that:

e. The fillhead must be in position to allow operation of the waste valve, the dewater pump or cement conveyor.

b. A High-High container level condition will automatically 4

close the waste valve and shut-off the cement conveyor.

c. A container high pressure condition will prevent opera-tion of the waste valve, cement conveyor and dewater pump (to preclude operations where the dewater pump is used to transfer waste into the liner).

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4.0 EQUIPMENT OPERATION '

i The Pacific Nuclear Radwaste Solidification System has been designed to be transportable and to provide simplicity of opera-tion, remote control of the process, and remote indication of important process par.queters. Prior to operation of the system or filling of the rantainer with waste, the Process Control Program is implemented to ensure that the solidification process chemistry calculations have been made and control parameters have l been met.

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An empty solidification container is placed in a process shield or cask and verification is made that the in-container mixing assembly can turn freely and that the level bubble tubes have

been placed at the appropriate positions to determine the ade-quate waste fill level and cement level for the. liner being used and as calculated by the PCP. The solidification fillhead is ,

then moved into position for coupling with the liner by the gantry crane and hoist. After the fillhead has been positioned on the liner, it is firmly attached to the liner by tightening the racket binder fasteners. The level bubble tubes and dewatering line, if necessary, are then connected to the liner by the operator by opening the fillhead lower door. The lines for cement transfer, offgas, hydraulic pressure, waste fill, dewater, O rinse and air and electrical connections are then made between the fillhead and the respective component skids.

The fillhead is

then inspected to ensure that a seal has been made with the liner j and the CCTV and light are operated to ensure that visual

indication inside of the liner is adequate. The drive system is '_

! operated at low speeds to ensure that there is free rotation of

! the mixing assembly within the liner.

After the system has been setup and preoperationally tested and I after the plant staff has lined up the proper valves to perform a l waste transfer, the operator begins filling the liner by opening i

the waste inlet valve from the operators panel. Waste filling is i

closely monitored by-viewing the CCTV and when the waste level i reaches the predetermined volume, as indicated by the bubble tube level indicator, the waste fill valve is closed. When resins are being transferred into the liner, the operator will operate the dewatering pump as necessary to control the liner resin and water levels.

After the liner has been filled with the appropriate volume af waste, waste conditioners, as needed and determined from the PCP can be added in dry form via the cement transfer system or in liquid form via the chemical addition nozzle. The waste will have been sampled during the transfer cycle or in the waste holding tanks and a sample solidification will have been O performed to determine the appropriate chemistry for waste solidification.

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PNSI Radwaste Solidification System - TP-05 8/85 O After the waste has been conditioned, the Cement Hopper will be loaded and the appropriate amount of cement or Envirostone, as determined from the PCP, will be transferred into the liner and mixed with the waste. The operator will control the speed of the mixer to ensure adequate mixing of the cement with the waste and to prevent excessive splashing inside of the fillhead. The operator will monitor the operating pressure of the hydraulic system during the mixing operation and after visual indication by the CCTV confirms that the waste / cement mixture is thorougly blended together, the operator will be able to confirm that the mixture is beginning to setup by observing an increase in the hydraulic operating pressure. At this point the mixer can be secured. The offgass blower wil? be allowed to operate untill the waste has cured.

When the waste mixture has been allowed to setup for the minimum set time, as determined by the PCP, the offgas blower can be secured and the fill head can be removed. A brief visual inspec-tion of the waste product should be made to verify that there is no free standing liquid and the container can then be capped.

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C) 5.0 PROCESS CONTROL PROGRAM The Pacific Nuclear System's Process Control Procedures for solidification are designed to ensure that the various waste '

forms that are to be solidified will produce a quality end pro-duct which meets or exceeds the waste form regulations. Copies of the specific PCP's for various waste forms to be solidified, using this system, are included in Appendix B of this Topical Report. Pacific Nuclear System's currently uses Envirostone to i solidify those waste forms that are covered in the Envirostone l Topical Report. For . waste forms that PNSI intends to process 3

that are not covered under thra Envirostone Topical, PNSI has

initiated complete 10 CFR 61 compliance testing of specialized cement or Envirostone chemistries and this information will be submitted to the NRC for review under a separate topical report, in the near future.

Prior to a full scale liner solidification, a laboratory solidification of each batch of.a particular waste stream is performed to ensure that the contents of the waste stream are indentified and that the solidification chemistry is adjusted, within the limits of the specific PCP, such that the waste i product will solidify as expected and the calculations for the full scale solidification can be made. A representative sample i () of the waste product to be solidified is collected and solidified in a 300 to 500 ml beaker. This scaled down solidification is performed using the exact ratios that will be used in the full 4

scale liner solidifications. The full scale solidification will i proceed only after it is confirmed that the chemistry to be used will produce a quality end product. The laboratory solidifica-tion test will identify any problem areas in the solidification formula and will ensure that appropriate adjustments to the formula are made, prior to performing the liner solidification.

The Pacific Nuclear operator will record each sample solidifica-tion on the Sample Verification Worksheet. The information con-tained on this Worksheet will be used to calculate the quantities of each chemical to be added to the liner solidification on the Solidification Worksheet. The operator will also maintain a record of each solidification on the Solidification Operations

, Logsheet.

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P SI Radwaste Solidification System - TP-05 8/85 l CE) 6.0 QUALIFICATION TESTING I

The Pacific Nuclear System's Radwaste Solidification System was assembly and thoroughly tested to ensure that; (1) adequate torque was available to mix powdered resin which had settled  !

overnight in a 210 cubic foot liner (the largest torque require-

ment for solidification processing to be performed by this sys- i J

tem), and (2) to ensure that adequate agitation was available in

! the range of liner sizes to be used and (3) to ensure that the integrated operation of the system components would provide a l l repeatable process in an easily controlled operation.

The system was initially tested to ensure that the torque produced by the mixer would be adequate to mix the most difficult waste materials, with respect to being able to turn the mixing assembly within the material. To perform this test, 160 cubic feet of powdered resins was transferred into a 210 cubic foot j solidification container. This volume represents an 85

• waste j

loading of the 190 cubic feet of available liner volume. The i powdered resin was allowed to settle overnight to simulate worst .

I case conditions. The mixer was started the next day and the  !

resin was freely turned within the liner, verifying adequate i

mixer torque.

( To ensure that the system mixer and liner mixing assembly

provided adequate agitation of the waste and cement mixture, a i

full scale solidification of waste oil and Envirostone was

! performed in a 210 cubic foot liner. Waste oil was selected for

! this test because it is the most difficult waste material to

, six and form into a solidified billet. To prepare the waste oil for solidification, 585 gallons of oil was emulsified with 65 gallons of emulsifier and 305 gallons of water. After mixing these liquids for 15 minutes, 7600 pounds of Envirostone was

, added to the liner and thoroughly mixed into the emulsified waste. Visual indication of the mixture verified that the mixing blade design providied vigorous agitation of the waste and Envir-ostone mixture. The waste mixture began to thicken 65 minutes after the completion of the addition of the Envirostone,. as evidenced by an increase in the mixer hydraulic operating pres-sure and visual indication of the mixture. At this point the mixer was secured and the fillhead removed from the liner. The

following day bore holes were made into the botton and middle sections of the liner and it was confirmed that the solidified billet was homogenous throughout.

An additional test of the integrated operation of the system was performed by solidifying 38 cubic feet of Citrox decontamination solvent depleted resins in a 50 cubic foot liner. This test also provided large scale solidification chemistry testing of this O specific waste form. Pacific Nuclear will later compare the large scale solidified waste form to the test results from 10 CFR 61 compliar.ce testing currently being performed on Citrox deplet-6-1 l

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PNSI Radwaste Solidification System - TP-05 8/85 O ed resins solidified with Envirostone, in accordance with the PNSI PCP. To solidify the Citrox depleted resins, it was first necessary to pretreat the waste with calcium hydroxide and WC-785, a PNSI propriatary waste conditioner. After conditioning the waste, 1300 lbs of Envirostone was added to the liner. The waste mixture began to thicken 45 minutes after completion of the Envirostone addition and the mixer was secured. Visual inspec-tion of the waste the following day indicated that the waste contained no liquids and resisted penetration when probed with a

! small pipe, Later core samples of the waste were taken from the

middle and bottom sections of the liner and it was confirmed that the solidified billet was completely homogenous.

The qualification testing performed on the Pacific Nuclear Rad- ,

waste Solidification System proved that the System and the in- !

container mixing blade design can repeatedly provide a controlled solidification of various waste forms in large containers, will being operated remotely for ALARA purposes and that the final ,

waste product produced will be a homogenously mixed, free

• standing monolith, with no free water, when appropriate waste solidification chemistry is used.

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. PNSI Radwaste Solidification System - TP-05 8/85 7.0 QUALITY ASSURANCE The Pacific Nuclear Radwaste Solidification System was designed

. fabricated and tested by Nuclear Packaging, a wholly owned subsidiary of Pacific Nuclear Systems, Inc. The Nuclear Packaging Quality Assurance Program has received Nuclece Regula-tory Commission (NRC) program approval number 0192. i. synopsis of the program appears in Appendix D, for reference. The full program is available for review upon request to the Nuclear Packaging Quality Manager. The program fully covers the 18

quality criteria that are applicable from initial design to site operations.

The Process Control Procedure (PCP) was designed for the solidification system by Nuclear Packaging Engineering in

conjunction with Quality Assurance.

The Quality Assurance Program exist to assure a quality product and operation. The goal is to prevent discrepancies. However, when discrepancies do occur, a Quali;ty Discrepancy Report is employed to insure complete resolution of the non-conformance.

As a- result of MRB dispositions it may take the form. of an engineering review and resolution or a change in procedures. A copy of a Quality Discrepancey Report can be found in Appendix B.

The centralization of procedures on the Nupac Quality Assurance System assures consistent site operations' and compliance to burial and transportation regulations.

The Nuclear Packaging Quality Assurance System is assured of

staying up to date with the' evolutions of the system by receiving

copies of site operator instructions, pertinent menos, design changes and informal project information. Quality Assurance is

) involved in the procurement and acceptance of all materials i

pertaining to the system's construction and operation.

Nuclear Packaging's Quality Assurance Program assures complete compliance with the specified quidelines and regulations.

Nuclear Packaging's goal is to fully optimize the role of Quality Assurances's involvement in site operations. To that end, Nuclear Packaging is completing a separate modification of their existing NRC Approved Quality Assurance Program as-an enhanced operations oriented Quality Assurance Program. That prograu, when completed, can be forwarded as an addendum to this report,

, if requested.

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PNSI Radwaste Solidification System - TP-04 8/85  !

PACIFIC NUCLEAR SYSTEMS i SOLIDIFICATION PROCESS CONTROL PROCEDURES FOR GEhERAL NUCLEAR POWER STATION EXAMPLE i

1.0 SCOPE

This document contains the Process Control Procedures I for the solidification of various radioactive waste forms using the PNSI Radwaste Solidification Unit. Control of the process parameters involves the solidification of a laboratory sample of 2

each separate batch of waste product to be solidified, calcula-tion of the chemical volumes to be added in the specific waste container to be used and logging of the solidification details, while following the solidification operating procedures. Log sheets for each of these three separate tasks are included in this document.

2.0 REFERENCES

United States Gypsum's Topical Report on Envirostone 1 10 CFR 61 l NRC Branch Technical Position on Waste Form t

Nupac Services Inc. Operating Procedure Nuclear Packaging, Inc. Quality Assurance Program 3.0 PROCESS DESCRIPTION: The PNSI Solidification System is spec-i

() ifically designed to facilitate solidification of various forms and mixtures of radioactive waste in large scale liners. The

} waste is effectively immobilzed using Envirostone or Portland '

i Cement, which is thoroughly mixed with the waste using the system

} in-container mixing blades. The final product has proven to be a j homogenously mixed, free standing monolith with no free standing

!- water.

I

.I 4.0 PROCESS PARAMETERS: Waste can be solidified using the PNSI Radwaste Solidification Unit in accordance with the specific PCP for the waste form being solidified. Specific waste conditioners are required for some waste forms before solidification. PH control of the waste product plays a primary role in the solidification process. When soliaification of a waste with a PH of less than 3.0 is required, concentrated NaOH can be added to raise the PH to between 3.0 and 6.0. When solidification of waste with a PH of above 9.0 is required, concentrated Sulfuric Acid or Boric Acid can be added to lower the PH to between 5.0 and 7.0. Waste solutions with a PH between 3.0 and 9.0~normally require no PH adjustments.

When using Envirostone with the System, it may be necessary to extend or accelerate the setup time of the waste. If the labora-

, tory analysis of the waste solidification shows that the waste setup time will be less than 30 minutes, Red Top Retarder can be added in small amounts to extend the setup time to.long enough to i

O ensure that the full volume of Envirostone can be thoroughly blended with the waste to form a homogenous mixture. If the B-2

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PNSI Radwaste Solidification System - TP-05 8/85 e waste /Envirostone mixture requires a long setup time, as indi-cated by laboratory testing, accelerator can be added to the mixture. The exact amount of retarder or accelerator will be i determined during the laboratory solidification and then will be applied in exact porportion in the liner solidification.

5.0 SYSTEM OPERATION: The PNSI Solidification Unit is operated i in accordance with the approved procedures, which ensure reproducibility of the waste product from batch to batch. The process parameters and chemical ratios used in each solidification are specifically calculated for each waste batch and laboratory tested before attempting a full scale solidification.

6.0 PREREQUISITES

6.1 Due to the importance of obtaining a representative sample for use in the verification procedure, the PNSI operator

shall confirm that the contents of the waste form to be solidi-

fled have been adequately mixed and that the sample is a part of a homogenously mixed waste batch.

6.2 The PNSI operator shall ensure that a Radiological Work Permit has been issued for performance of the radwaste processing activity and that adequate personnel monitoring and radiation detection equipment is available.

4

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6.3 The PNSI operator shall ensure that all necessary materials and equipment are on hand prior to beginning a solidification process. Equipment and materials for a sample ,

solidification are as listed below:

6 - 300 to 500 al plastic beakers 1 - portable mixer

' 1 - 500 gram capacity scale 10 grams - Envirostone Accelerator 10 grams - Red Top Retarder, or equivalent 1000 grams - Envirostone 1

6.4 A sample shall be taken and solidified in the laboratory for each separate batch of waste to be processed. Additionally, one additional sample shall be taken and solidified in the i

laboratory for every 10 liners of waste that are solidified from a batch or every 7 days of waste processing from the same batch.

7.0 SAMPLE VERIFICATION: Prior to the full scale solidificaton of each batch of waste product, a representative sample of each waste product shall be test solidified in the laboratory. This test solidification confirms the correct process chemistry ratios to be used batch.

in the full scale solidifications of the same waste Prior to proceeding with the full scale solidification, the sample solidification should verify that the solidified waste O product will be a uniform, dry, free standing monolith. The end product should resist penetration when probed with a firm object.

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PNSI Radwaste Solidification System - TP-05 8/85

, This sample solidification will be recorded on the Sample Verification Logsheet.

8.0 FULL SCALE SOLIDIFICATION CALCULATIONS: After a laboratory sample has been solidified and it has been confirmed that the waste product will meet the requirements for a satisfactorily solidified end product, the calculations can be made for solidification of the waste form in liners. Calculations will be made and recorded on the Solidification Worksheet included in the following pages.

9.0 PROCEDURE

9.1 Notify plant personnel that preparations for sample verification testing have been completed and that a sample will be drawn. Confirm that the waste to be sampled has been thoroughly mixed to ensure that a representative sample can be obtained. Record all information on the Sample Verification Worksheet.

9.2 Place 200 ml of the sample in a 300 to 500 ml plastic beaker and take PH, radiation level and temperature readings.

9.3 Adjust PH by adding NaOH to obtain a PH of 3.0 to 6.0 if the sample PH is less than 3.0 or by adding Sulfuric or Boric O Acid to obtain a PH of 5.0 to 7.0 if the sample PH is greater than 9.0. Waste solutions with a PH of between 3.0 and 9.0 normally require no PH adjustment.

! 9.4 After thoroughly mixing the waste solution and ensuring that the PH is between 3.0 and 9.0, add the volume of waste conditioners and Envirostone or Portland Cement, as listed in the specific waste form PCP, to the 200 ml of weste solution. Con-tinuously mix the waste / cement mixture untill a thickened paste is formed. Add retarder or accelerator in measured quantities,

, if neccessary, to obtain a setup time compatable with the liner being used and the waste form PCP. Continue to perform sample-solidifications untill a satisfactory waste product is obtained.

If a satisfactory sample solidification can not be readily ob-tained, the PNSI operator shall contact the PNSI Director of Operations before proceeding.

9.5 After a satisfactory sample solidification has been obtained, the proper volume of waste, additives and cement to be used in the liner solidification should be calculated and docu-mented on the Solidification Worksheet.

9.6 Adjust the solidification liner bubble tubes in accor-dance with the levels determined in the Solidification Worksheet.

O 9.7 Fill'the waste liner untill the waste full bubble tube indicates full and as confirmed via the CCTV. Operate the soli-dification system in accordance with the operating procedure.

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PNSI Radwaste Solidification System - TP-05 8/85 SAMPLE VERIFICATION WORKSHEET Operator: ______________________Date: ________________NO: __________

Utility / Location: ________________________________________________

Waste Type: ______________________________________________________

Waste Sample From/By:____________________________________________

Waste Temperature: ______F Waste PH: ______ Sample Rad Level: _______

Physical Characteristics (Viscosity, color, sedimentation, clarity, etc.)___________________________________________________

Sample Proportions:

Waste Sample ______________________ml C) '

Envirostone/ Cement ______________________gm PH Adjustment (and what, if any)______________________ml Retarder (if any) ______________________gm j Accelerator (if any) ______________________gm conditioners (and what, if any) ___________________gm/ml Blend the waste thoroughly (with PH adjustment additives, retarder, or conditioners, if required) and record the time when finished: _________________________________

Blend the required volume of Envirostone into the waste and i record the time when finished: ____________

Record the time when the mixture viscosity increases to the point when the mixer is secured: ________________(1) l Record the time when the mixture is firm to the touch: ________(2) 1

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PNSI Radwaste Solidification System - TP-05 8/85 Sample Verification Worksheet Sample results:

Mix time (1): _______________________ minutes Setup time (2): _____________________ minutes Final Solidified Volume: ____________ minutes Soldification Eff: _______* (waste Vol/ Solidified Vol x 1004)

Free Water, If any:____________________________________________

Relative set (soft, firm, very hard): __________________________

Observations: __________________________________________________

Sample proportions and solidification results acceptable for calculation of large scale solidification ratios: _ _ _ _ _ y e s _ _ _ _ _ _ n.o m

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. . PNSI Radwaste Solidification System - TP-05 8/85

)

SOLIDIFICATION WORKSHEET Operator: ____________________________Date: __________No.________

Utility / Location: ______________________________________________

Waste Type: ____________________________________________________

Satisfactory Sample Verification No: ,__________Date: ___________

Waste Solidification Efficiency:_,._________________________% (a) 4 Liner Size: ______________ Inches High x _______________ Inches Dia Liner Usable Volume.(with 2" safety margin): ______________CF (b) l Liner Volume Per Inch of Height: _____________________CF/ Inch (c) i i

WASTE VOLUME to be Added to Liner _____________________CF (a x b)

! HEIGHT OF WASTE In Liner: ___________________________In (a x b/c) i (Waste Level Bubble Tube to be Set at this Height)

WEIGHT OF ENVIROSTONE to be added to the Liner: (Use the Values O Determined from the Sample Verification Worksheet.)

______gus of Envirostone in Sample /_______al of Waste in Sample x 62.38 = _________lbs of Envirostone/CF of Waste X _________________CF of Waste to be Added to the Liner

=

_________________lbs of ENVIROSTONE to be Added to the Liner NOTE: Go to Page 2 of the Solidification Worksheet only if the waste to be solidified requires additional ingredients, as noted in the sample verification; such as Sulfuric Acid or NaOH for PH adjustment, retarder to extend the waste setup time, or accelerator to increase .the setup time. (Use the values determined from the Sample Verification Worksheet.)

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O PNSI Radwaste Solidification System - TP-05 8/85 Solidification Worksheet WEIGHT OF RETARDER to be Added to the Liner: (Add only when needed to extend the waste setup time, as necessary to ensure that all of the Envirostone can be safely added to the liner prior the the setup time.

________gus of Retarder /_______ gas of Envirostone in Sample x ________lbs of Envirostone to be Added to the Liner

=

________lbs of RETARDER to be Added to the Liner PH ADJUSTMENT: The PH of the waste solution may be adjusted by adding NaOH to increase the PH to between 3.0 and 6.0 for waste streams with a PH below 3.0 or by adding Sulfuric or Boric Acid to lower the PH to 5.0 to 7.0 for waste streams with a PH above 9.0. Waste streams with a PH between 3.0 and 9.0 normally require no adjustment.

O _______gus of ________in Sample /_______al of Waste in Sample x 62.38 = ______________1bs of __________/CF of Waste x _______Cf of Waste to be Added to the Liner

=

_______1bs of ________PH ADDITIVE to the Liner WEIGHT OF ACCELERATOR OR WASTE CONDITIONER to be Added:

Accelerator or Waste Conditioner can be added up to 2.0 % of the weight of the Envirostone to increase the setup time, if the the setup time is greater than 60 minutes, or to improve the quality of the solidified waste product if needed.

_______ gas of Accelerator / Conditioner in the Sample /_____ gas of Envirostone in the Sample x _______lbs of Envirostone to be Added to the Liner

=

_______lbs of ACCELERATOR / CONDITIONER Added to the Liner B-8

PNSI Radwaste Solidification System - TP-05 8/85 T l

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1 PNSI SOLIDIFICATION OPERATIONS LOGSHEET Operator: ___________________________Date: _____________No._______

Utility / Location: _______________________________________________

Waste Type: _____________________________________________________

Waste From: _____________________________________________________

Solidification Worksheet No: ____________________________________

Waste Volume Added: ___________CF: Time ConPleted: _______________

Height of Waste: ______________ Inches From Inside Bottom Of Liner Time Mixer Started: ______________ Hydraulic Press: _______________

Retarder Added: ______________lbs: Time Added: __________________

Waste Conditioner Added: __________ Type: ________lbs: Time: _______

Waste Conditioner Added: __________ Type: ________lbs: Time: -___-__

PH ADJUSTMENT Added: ______________ Type: ________lbs: Time: _______

Envirostone Added: _______lbs: Time Started: ______ Complete: ______

Mixer Hydraulic Pressure PSI Time l

1 i

Time Mixer Secured: _________________

J Waste Setup Time: ___________________

Time Fillhead Removed: ______________ Time Liner Capped: __________

Comments and Observations: ______________________________________

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PNSI Radwaste Solidification System - TP-05 8/85 O

APPENDIX C O

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PNSI Radwaste Solidification System - TP-05 8/85 PACIFIC NUCLEAR SYSTEMS RADWASTE SOLIDIFICATION SYSTEM OPERATING PROCEDURES FOR GENERAL NUCLEAR POWER STATION EXAMPLE

1.0 Scope

This procedure covers the necessary instructions required to properly operate the PNSI Portable Solidifica-

] tion System using Envirostone as the solification binder.

1 2.0

References:

PNSI Process Control Procedures Nuclear Packaging, Inc. Quality Assurance Program '

U.S. Gypsum's Topical Report on Envirostone 10 CFR 61 NRC Branch Technical Position on Waste Form Plant Specific Radiological and Safety Procedures 3.0 Plant Interface Requirements:

120 Vt AC, 1 Phase, at 15 Amps 480 Vt AC, 3 Phase, at 50 Amps Service Air - 40 CFM at 100 PSI Os Flush Water Available - 25 GPM at 25 PSI Radiation Monitoring Equipment Available Work Area - Min Space Requirements; 25ft x 12ft x 17ft H Dewatering Line Return to Plant, if Required Offgas Return to Plant, if Required 4.0 System Setup and Preoperational Testing: (Perform when the System is initially setup at a power plant, or when the System has not been operated for a period of greater than 10 days.)

4.1 Plug in the System electrical cord to the plant 480, 3 phase AC outlet rated for 50 amps.

4.2 Plug in the System control power cord to the plant 120 Vt. AC outlet rated for 15 amps.

4.3 Plug in the fillhead gantry crane power cord to the plant 120 Vt, AC power outlet rated for 15 amps.

4.4 Close the System main power switch, and the auxiallary breakers for the cement conveyer system and hydraulic power supply system.

4.5 Ensure that the in-container mixing assembly rotates freely by hand and place the fillhead in position on

%- l the liner. Ensure that the fillhead drive shaft mates i

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i PNSI Radwaste Solidification System - TP-05 8/85 O with level the internal mixing blade assembly and that bubble tubes have been installed in accordance the with the PCP.

4.6 Ensure the piping skid valves WS-2, WS-3, DW-3 & DW-4 are closed. Operate the Waste Valve Control Switch on ,

the operators panel and observe operation of WS-1 on the piping skid.

4.7 With WS-1 open, manually trip the fillhead High-High level switch and confirm that WS-1 automatically closes and that the audible alarm and indicator light are energized on the operators panel. Return the Waste Valve switch on the operators panel to the Closed position.

4.8 Ensure that the cement hopper is empty and operate the Cement Conveyor On/Off Switch from the operators panel and confirm that the conveyor is operable and that speed control is available by turning the speed con-trol adjustment. Place the conveyor switch on Off.

4.9 Operate the cement hopper vibrator On/Off switch and

,t ensure operability of the hopper vibrators. Secure

! the vibrators.

() 4.10 Operate confirm the cement hopper filter system switch and that the vent blower pulls a slight negative pressure on the hopper. Return the filter system ,

switch to the Off positioa. I 4

4.11 Operate the Offgas Blower On/Off switch from the oper-ators panel and confirm operability of the offgas blower. Return the blower switch to the off position.

4.12 Operate the dewater pump On/Off switch from the operators panel and confirm operability of the dewater pump. Return the dewater pump switch to the off position.

4.13 Block air flow at the fillhead bubble tube connec-

tions for waste level, cement level and high level and verify that the indication lights for each level and aubible alarm are energized on the operators panel. Reinstall the bubble tubes to the appropriate fillhead connections.

4.14 Place the oil heater switch in the on position and allow the heater to operate untill the proper tempera-ture is reached and the heater cycles off.

O 4.15 Place the hydraulic power supply switch in the on pos-ition and ensure that the power supply is energized.

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PNSI Radwaste Solidification System - TP-05 8/85 O 4.16 With the fillhead firmly secured to the liner, oper-ate the mixor noter Forward Switch and ensure that speed control is avilable from 0 to 100 % and that the forward direction provides counter clockwise rotation of the liner mixer assembly when viewed from the top of the liner.

5.0 Prerequisites

5.1 Ensure that all plant interface requirements can be set.

'5.2 Confirm that a Radiological Work Permit has been establised for the solidification project.

5.3 Ensure that communications have been established be-between the personnel transferring the waste and the 1 l PNSI Solidification Operator for the waste transfer sequence.

l 5.4 Ensure that a laboratory solidification of the waste to be solidified, has been performed per the PCP, and l that the satisfactory results are recorded on the Sample Verification Worksheet.

(

5.5 Ensure that the calculation of the volumes and weights of the waste, Envirostone and additives to be mixed together for the liner (s) to be used for the solidifi-cation has been performed and that the results are recorded on the Solidification Worksheet.

5.6 Confirm that there are adequate supplies of Envirostone and additives to complete the solidifica-tion, as calculated from the Solidification Worksheet.

5.7 Confirm that tags, ropes, protective clothing and documentation forms are available, as required by the plant administrative and safety procedures.

6.0 Solidification System Operation:

6.1 Confirm that the prerequisites of section 5 have been met.

6.2 Confirm that the level tubes in the liner to be soli-dified has been set at the appropriate heights to indicate the Waste Level, Cement Level and High level positions, as determined by the Solidification Work-sheet.

6.3 Ensure that the fillhead has been properly installed C-4

PNSI Radwaste Solidification System - TP-05 8/85

(} on the liner to be solidified.

6.4 Ensure that the liner is shielded in accordance with '

the expected radiation levels.

6.5 With the fillhead setting firmly on the liner, start the mixer noter at slow speed in the forward direction and confirm freedom of rotation of the in-container mixing assembly in the counter clockwise direction, when looking down on the liner.

6.6 Adjust the CCTV and light such that good visual indication of the inside of the liner is available on 4

the remote TV at the operators station.

, 6.7 Connect the Inlet Offgas Filter Hose to the Fillhead Connection, and connect the Discharge of the Offgas a Filter to the plant offgas system, if the offgas is required to be returned to the plant.

6.8 Connect the Fillhead Waste Inlet Connection to the Discharge of Waste Isolation Valve WS-1.

6.9 FOR RESINS, OR SLURRIES WHICH REQUIRE DEWATERING:

Connect the Fillhead Dewatering Connection to the Dewatering Return to the Plant and verify that the Os Plant valve lineup is suitable for receiving liquid returned from the liner.

6.10 IF DEWATERING IS NOT REQUIRED, ensure that the Fillhead Dewatering Connection is capped.

6.11 Ensure that the cement conveyor dischare is properly attached to the fillhead connection and the hopper.

t 6.12 When it is confirmed that waste is ready to be transferred to the liner, confirm that valves WS-2 and WS-4 are open and open WS-1 from the operators station and observe filling of the liner from the CCTV. When the Waste Level Indicator shows that the proper waste level has been reached, the Waste Isolation Valve i

WS-1 should be closed. Confira via CCTV indication that the level appears to be as calculated. During the waste transfer sequence, operate the dewatering pump as necessary to control the level of water in the liner. Alternate the waste filling and dewatering se-s quence untill the resin waste level is slightly cover-ed by water.

6.13 Start the mixer noter in the forward direction and adjust the mixer speed as necessary to obtain maximum fs agitation within the liner, while avoiding excessive splashing into the fillhead internal cavity.

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PNSI Radwaste Solidification System - TP-05 8/85 e

U 6.14 If the waste solidification PCP requires that Retarder or chemical additives be added to the waste prior to addition of the Envirostone, add the dry powder additives to the screw feed area of the hopper and cover them with 100 lbs of Envirostone. Liquid additives can be pumped into the liner via the Chemical Conditioning System.

6.15 If Retarder or additives were added to the Hopper in Step 6.14, start the cement hopper filter system, the hopper vibrator and the cement conveyer in low speed and run untill all of the additives have been added to the liner. Secure the conveyer and vibrator and oper-ate the mixer drive motor as described in step 6.13 for a minimum of 15 minutes, to thoroughly blend the additives into the waste.

6.16 With the hopper filter system on, fill tha cement hopper with Envirostone and commence adding to the liner. (The hopper vibrators should be operated con-tinuously during cement transfer.) Adjust the speed of the conveyer to a fillrate which will ensure that all of the Envirostone to be added to the liner will be added in less than half of the waste setup time. Do O not run the conveyer at speeds which are faster than necessary. Observe agitation inside the liner during the Envirostone addition via the CCTV.

6.17 Continue to add Envirostone to the hopper untill the prescribed amount has been added, as determined by the PCP. Secure the conveyer and vibrator when the hopper and screw are empty. Monitor the inside of the liner via the CCTV to ensure that the liner is not over-filled.

6.18 Monitor and record the hydraulic operating pressure on the Solidification Operations Logsheet while the mixer is running. The mixer can be secured when the hydraulic pressure increases'by 20 % over the pressure noted just after the final addition of Envirostone.

6.19 The offgas blower should be allowed to continue to operate while the waste is setting up. After the waste has setup, secure the offgas blower and remove the fillhead.

6.20 After it is confirmed that the waste has setup and has no free standing water, the liner can be capped.

6.21 Fill Out an Solidification Operations

() each solidified liner.

Logsheet for C-6

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PNSI Hadwaste Solidification System - TP-05 8/85 APPENDIX D O

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. RECEIVED SEP 1 9 1533 i

1. o, UNITED STATES 8  % NUCLEAR REGULATORY COMMISSION

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I wAsmNGTON, D. C. 20556

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SEP 0 61983 i ._ .. _ _ . -- --  !

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To: Holders of, Quality Assurance Program Approval for Radioactive  !

Material Packages Gentlemen:

On August 5,1983, the U.S. Nuclear Regulatory Commission published a final rule in the Federal Register for the packaging and transportation of radioactive material (10 CFR Part 71). Corrections to the final rule were published in the Federal Register on August 24, 1983. The revised regulations will be effective on September 6,1983.

Enclosed is your Quality Assurance Program A;;roval which has been revised to reflect changes made in 10 CFR Part 71. On September 6,1983, this Quality Assurance Program Approval will supersede your current Quality Assurance Program Approval 'in its entirety.

Please note the conditions included in the approval.

.O-Sincerely, ,

./ JA _]

Cha les E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS Encicsure: As stated e

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I ,,, g U.S. NUCLEAR RIEGULATOGY COMMISSl!N 1. APP g NUMBER l, io a QUALITY ASSURANCE PROGRAM APPROVAL REv SION NUM8ER

, FOR RADIOACTIVE MATERIAL PACKAGES 7 g

hy g I

Pursuant to the Atomic Energy Act of 1954. as amended. the Energy Reorganization Act of 1974, as amended, and Title 10. Code of Federal g g Regulationst Chapter 1. Part 71, and in reliance on statements and representations heretofore made in item 5 by the person named in item

.: g' 2. the Quality Assurance Program identified in item 5 is hereby approved. This approval is issued to satisfy the requirements of Section

", g 71.101 of 10 CFR Part 71. This approval is subject to all applicable rules. regulations, and orders of the Nuclear Regulatory Commission g

now or hereafter in effect and to any conditions specified below.

3 j 2.NAME 3. EXPtRATICN CATE i I Nuclear Packaging, Inc. '

. 11 37,,37 ,00,,33 December 31, 1985 ,)

l 815 So. 28th Street ( DOCxET NuMeER

$ l C2T

• STATE Z1P COOE l

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Tacoma WA 98409 71-019?.

'- a s. cUAUTY ASSURANCE PAOGRAM APPUCATION DATEtS) l l

-r i July 31, 1980  !

I+ l 6. CONO TICNS o y l h I Activities conducted under applicable criteria of Subpart H of 10 CFR

,' l Part 71 to be executed with regard to transportation packages.

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I t! A FOR THE U.S. NUCLEAR REGULATORY COMMISSION I I

C Y 'c on SEP 0 61083 l CHIEF. TRANSPORTATION CERTIFICATION BRANCH )

DATE l) l DIVISION OF FUEL CYCLE AND MATERIAL SAFETY g

l CFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

. __.____:_______________________________________g _

D-3

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l 10 CFR 71 QUALITY ASSURANCE PROGRAM 1

FOR SHIPPING PACKAGES FOR IRRADIATED FUEL,  ;

HIGH LEVEL WASTE AND PLUTONIUM  ;

LETTER NUMBER QA-78-1 REVISION 4 DATE: Manuary 28, 1985 PACIFIC NUCLEAR SYSTEMS', INC.

, 1010 South 336th Street.

Federal Way, WA 98003 l APPROVALS Approved BY Date Revision 3 R.OC h~ mA al'sl 84 8 d k L sdeJP & w ie v .r co s.s elms +

' Revision 4 A

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l January 28, 1985 Letter QA-78-1, Rev. 4 I IETaonocTIon Pacific Nuclear Systems, Inc. (PNSI) has developed a quality system to assure traceability and control the quality of all materials and processes utilized in the production of radioac-tive shielding, cask, containers, and other equipment pertaining to shipping packaging for irradiated fuel, high level waste, and plutonium.

. The Quality Manual delinaates requirements and procedures necessary to exercise control over design, documentation, procurement, material, fabrication, inspection, operational testing, equipment operation and use, maintenance, repair, modification, inventory, shipment and quality data retention. l PNSI Quality System and implementing Quality Procedures are de-

, signed and administered to meet the 18 criteria of 10CFR71, Sub- 1 part H. Figure 1 is a matrix delineating the relationship be-tween the 17 PNSI Quality Procedures and the 18 10CFR71, Subpart H criteria.

The Quality System is implemented throughout the company and its subsidiaries. The Subsidiaries include: Pacific Nuclear Systems, Inc., Nuclear Packaging, Inc., NuPac Leasing, Inc., and Pacific Nuclear Systems & Services, Inc.

O DESCRIPTION DE.2ER RESI 10CFR71. SUBPART E 00ALITY PROGRAM Criterion L Organization Full responsibility for the Quality Assurance (QA) Program ad-herence to 10CFR71, Subpart H criteria rests with PNSI. Quality i Program activities include calibration of measuring equipment, NDE and materials testing. PNSI surveys and qualifies all or-ganizations performing these services to assure adherence to the ,

18 criteria prior to their use. All other quality activities are - ,

performed by PNSI quality personnel. However, the responsibility l of the control of quality in the other organizations continues to  !

rest with PNSI. , i I

PNSI's President has full authority over all functions of the I company, and delegates authority and responsibility for selected functions to other personnel within the company.

The administrative function includes financial, legal, and marketing activities.

Procurement department personnel perform purchasing activities .

and maintain supplier performance records. The Engineering '

i Department is responsible for research and development of

) shipping container technology, design of casks for licensing and

] fabrication and design documentation. -

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January 28, 1985 Letter QA-78-1, Rev. 4 Q The PNSI Quality Department has sufficient authority and organizational freedom to identify quality programs, implement corrective. action and verify corrective action effectiveness.

Additionally, the Quality Department is independent from other l

organizations within PNSI and reports directly to the President of PNSI. The Quality Department is headed up by the Corporate ,

i Quality Director who is responsible for the development, l implementation and administration of the entire PNSI Quality l Program. He must have sufficient expertise in the entire field 1 of Quality to enable him to direct the entire quality function in close adherence to the 18 criteria and the PNSI Quality Manual.

Responsibility for development of quality acceptance requirements, inspections, and NDE activities rest with the Corporate Quality Director. It is his responsibility to delegate and evaluate the performance of all quality related tasks for PNSI through the authority of the president.

4 It is delineated in writing through the Corporate Quality Director that designated QA personnel have the authority to prevent the continued processing, fabrication, installation or delivery of unsatisfactory work.

This authority also extends to the quality monitoring of special processes utilizing PNSI equipment, personnel and procedures such as waste processing, in-service inspections, etc.

Production responsibilities include scheduling or in-service '

inspection and administration of all fabrication activities, both I

within PNSI and at qualified suppliers. The shipping and receiv-

, ing function is also the ' r~esponsibility of the Production Depart-

ment.

On-site activities such as waste processing, in-service inspec-tions, etc. are administered as a joint effort of the operations and ' engineering personnel. Quality supports these activities

with written procedures that provide methods, process controls -

and check points. Inspection personnel perform monitoring acti-vities and verifications of regulatory, contractual and technical requirements during these operations.

The Corporate Quality Director and all other quality personnel i

and/or organizations within, or utilized by PNSI, are fully '

qualified for their quality responsibilities. Qualification records are maintained in the PNSI Quality Record File.

Typical organizational charts are shown at the end of this synop-sis.

!O 1

D-6

January 28, 1985 Letter QA-78-1, Rev. 4 Criterion 2, Onality Assurance Program PUSI has established and implemented a QA Program for the control of quality in the design, fabrication, operation and maintenance  ;

of shipping containers for nuclear products. Training and/or evaluation of personnel qualification are required for all QA functions in accordance with written procedures and are approved by the Quality Manager. The QA Program assures that all quality requirements, engineering specifications, and specific provisions of any packgge design approval are met. Those characteristics critical to safety are emphasized. .

The President of PNSI regularly evaluates the PNSI QA program for adherence to the 18 criteria in scope, implementation, and effectiveness. Further, the' President requires that the Quality System, including the QA Manual Policies and Procedures, be implemented and enforced on all applicable programs at PNSI.

A Material Review Board, consisting of Engineering, Procurement

! -Production, and Quality Personnel has been established to dispo-sition all discrepancies or disagreements pertaining to the ac- '

ceptability of material, hardware, or safety related operations.

Their dispositions are final and binding. .

Criterion 3 Design Control PNSI Quality Procedures (QP's) have been developed, approved, and implemented to control design review in such a manner. to assure that the following occur:

(a) Design activity is planned, controlled, and documented.

(b) Regulatory and design requirements are correctly

, translated into specification, drawings, and procedures.

(c) Design documents contain quality requirements. -

(d) -Deviations from quality requirements are controlled.

(e) Design verification is performed by Quality Assurance #

personnel independent of the design activity. These ,

verifications may include tolerance studies, alternate '

calculations or tests. Qualification tests are con-ducted in accordance with approved test programs and procedures (f) Design verification is performed by Quality Assurance i

personnel independent of the design activity. These _-

verifications may include tolerance studies, alternate

, calculations or tests. Qualification tests are l Ov conducted in accordance with approved test programs and procedures. -

D-7

January 28, 1985 Letter QA-78-1, Rev. 4 (g) Interface control is established and adequate.

(h) Design and specification changes are reviewed and  ;

approved by the same organization (s) as the original 1 issue.

(i) Design errors and deficiencies are documented and corrective action to prevent recurrence is taken.

(j) Design organization (s) and their responsibilities and authorities are delineated and . controlled via written procedure.

Criterion L Procurement Document Control The PNSI QA Program assures that all purchased material, compo-nents, equipment, and services adhere to design specifications. -

Supplier evaluation and selection, objective evidence of supplier quality, assignment of quality requirements to procurement documents, and related design documents, and source, in-process and receiving inspection are all administered and controlled in accordance with approved PNSI QA procedures. .

All procurement activity is performed in accordance with written procedures delineating requirements for preparation, review, O aggrova1, and contro1 of grocurement documentation.

emphasis is placed on assuring that revisions to procurement marticu1ar documentation are reviewed and approved by the same cognizant groups as the original.

f Quality Assurance clause sheets are included with all request for quotes and purchase orders. Quality Assurance personnel assign j clauses from the sheets to the procurement document referencing 7 10CFR Part 71, Subpart H requirements appropriate to the contract. In addition, material information including grade, i type, size, special physical and chemical data requirements is

, included on the procurement documents. Other documentation and information such as drawings, procedures, inspection and test '

requirements, hold points, welding and other process .

qualification requirements are delineated on the procurement -

documents. by the Quality Assurance personnel as appropriate to the contract. ,

f The Quality Assurance personnel assure that requirements for l acceptance of hardware and documentation appropriate to the contract are included in procurement documentation. s

PNSI Quality Assurance personnel maintain the right of access to ,. f

all supplier facilities and documentation for source inspection  !

and/or audit activities. A statement to this effect is included

A on procurement documentaticn when it is appropriate to the -

i (> contract.

• t i

t f

D-8 k

i .

January 28, 1985 Letter QA-78-1, Rev. 4 4

Criterion is. Tnatruction. Procedures angl Drawings Quality planning is developed for all activities requiring quality participation. in accordance with approved PNSI QA procedures by qualified Quality Engineers (QE's) and are approved i by the Corporate Quality Director.

l All design documents, i.e., drawings, specifications, special l l

processes, etc. affecting quality are reviewed by the Quality Department and referenced in quality planning as necessary to assure adherence to package design approvals and the applicable criteria of 10CFR71, Subpart H.

! All instructions, procedures, and drawings are developed, reviewed, approved, utilized and controlled in accordance with the requirements of written quality assurance procedures.

Criterion f Docnnent Control Policy and procedure for review, approval, release and change

control of all controlled, quality related documents are delin-eated in approved PNSI QA Procedures. Provisions are provided in the QA Procedures for identification of individuals / organizations responsible for review, approval and issua~nce of documents. Doc-ument control responsibilities, facilities and distribution re- ,

quirements are also addressed.

Controlled documents include, but are not limited to:

, (a) Design specifications (b) Design manufacturing drawings

(c) Special process specification and procedures 4

' (d) Procurement documents '

(e) QA Procedures and manuals 4

(f) Quality Planning for receiving, in-process, source and in-service inspections t

(g) Source surveillance and evaluation reports (h) Test procedures (i) Audit reports (j) Operational test procedures and data. .

When revised documents appear in other documents as references, i supplements or exhibits, appropriate revisions are made'to those documents prior to the release of the basic approved change.

Documentation listings are maintained delineating the title, '

I number and current revision for all drawings, procedures, specifications, and purchase orders.

i The Quality Personnel assure that all required support ~

documentation is available at the work area prior to the Q initiation of the work effort.

l D-9 i

. , - - - _. - . . ,,,, .__,. _ ._..-, . , .- . _~ ,.~... ~ ,.__ _ ___ _, . ,_. .-_~,-., . _ ~__ ._ _ _

January 28, 1985 Letter QA-78-1, Rev. 4 O crit rie L co ere1 at >=rcs ea

• ri- - vare ==<1 co-ve e-  !

Procurement documents are reviewed for acceptability of suggested suppliers based on the PNSI approved supplier lists.

In addition, and as required, supplier surveys are conducted by qualified PNSI personnel to further assure supplier accepta-bility. These evaluations are based on one or all of the fol-lowing criteria:

(1) The supplier's capability . to comply with the requirements of 10CFR Part 71, Subpart H, that are applicable to the contract.

(2) A review of previous records.and performance of the supplier.

(3) A survey of the supplier's facilities and QA program to determine his capability to supply a product which meets the design, manufacturing, and quality requirements.

Results of all supplier evaluations are recorded.on Supplier Evaluation forms and are retained in the Quality Data File.

Ov Quality requirements and standard clauses are added to procure-ment documents to require suppliers to identify material, provide test reports, control special processes, certify equipment and personnel, etc. Requirements to identify material and specific codes, specifications and/or design requirements pertaining to the fabricated items and procurement specifications not adhered to with justification for " accept-as is" or " repair" dispositions are imposed on supplier as a minimum.

, Quality planning is prepared and approved by the Quality

! Department for performance of all source, test, shipping and/or l

receiving inspections in accordance with approved design requirements, applicable 10CFR71 criteria procurement document requirements and contract specifications.

Receiving inspection is performed to determine that the -

following, as appropriate to the contract, are assured:

(1) The material, component, or equipment is properly identified and corresponds with the identification on receiving documentation.

l (2) Material, components, equipment, and acceptance records are inspected and are acceptable in accordance with .- ,

inspection instructions, prior to installation or use. j O (3) 1a sectioa recora aa'or ceretric te- or coaror ace attesting to the acceptance of material and components -

l are available prior to installation or use. l l

l D--10

January 28, 1985 Letter QA-78-1, Rev. 4 O

(4) reem ccerted and re1 ed re ideatified to their inspection status prior to forwarding them to a controlled storage area or releasing them for further -

work.

All described activities are delineated in approved PNSI QA procedures.

Criterion L Tdentification angl control d Materials. Parts. angl .

Components The identification and control of materials, parts, components and completed and in-process assemblies is administered by the Quality Department in accordance with approved PNSI QA Proce-

, dures. These procedures address quality status tags, maintenance of material identification and traceability, part identification, and related documentation. Some of the details of these proce-dures follow:

(1) Material identification procedures included in i inspection planning and fabrication drawings require that identification of material, components, and/or hardware be maintained on the item or in traceable records to prevent use~of incorrect or defective items.

O (2) When appropriate, due to contractual or safety related requirements, Quality Assurance personnel assure that identification of materials, components, specifica-tions, procurement documentations, manufacturing, and

• i inspection records, discrepancy reports, and material i test data, i

I (3) Quality Assurance personnel assure, via drawings and '

! inspection planning requirements, that identification i locations do not affect the fitment, interfacing l capability, performance or overall quality of the

! finished product. Identification, in accordance with drawings and inspection planning requirements, is i i

verified prior to releasing the item for further i j processing or delivery.

{

Criterion is. Control d Special Processes

)' t PNSI approved QA Procedures delineate the policies and procedures I established to control such special processes as: welding, heat treating, lead pouring, non-destructive examination, waste pro-cessing, etc. in accordance with applicable codes, standards,

! specifications, 10CFR71 criteria and other requirements. Special processes developed by PNSI suppliers and by PNSI are documented. _-

O .

D-11

-..-~-sw. - a u . a. . - . . . ~ -~ ~ - - - -

j

, January 28, 1985 Letter QA-78-1, Rev. 4 O ^11 nroc aur ror 9 ci 1 stoc aa en to perform them are qualified under the cognizance of the Quality

> r oaa 1 r e=tr a

Department in accordance with applicable codes, standards, specifications and contract requirements.

?

All qualification records and support data are retained in the ,

Quality Data file, and are maintained in a current status by Quality Assurance personnel.

These documents are controlled as delineated in Criterion 6 of this Quality System description.

! critarion & Inspection All receiving, source, in-process and in-service inspection acti-vities are performed in accordance with approved PNSI-QA proce-4 dures. All inspection personnel and/or organization qualifica-tions are reviewed and accepted by the Quality Manager prior to inspection activity. The inspection activity is performed in strict accordance with approved quality planning prepared by j qualified QA personnel (See also Criterion 5 discussion).

4 Quality Inspection personnel are independent from all other organizations within PNSI and report directly 'c o the Corporate Quality Director or the subsidiary Quality M? nager.

! Inspection personnel qualifications are based on their capability  ;

, to perform the required inspection functions in accordance with applicable codes, standards, professional society programs such as the ASQC quality technician certification and PNSI training programs.- Qualification reviews are performed periodically to j maintain personnel proficiency and assure current qualification.

t 2

' Mandatory hold points, inspection equipment requirements, accept-reject criteria, personnel requirements, characteristics to inspect, variable / attributes recording instructions, reference l documentation and other requirements are included in the inspec-tion planning.

l The Quality Assurance department assures that any replacements, .

. modifications, or repairs performed af ter final acceptance of -

! material, components or hardware are inspected in accordance with

the original inspection planning or new planning prepared as ,

appropriate. j criterion L 2331 control A test control program, as it applies to quality, is addressed in approved PNSI QA Precedures and assures, via required planning, ,-

i that all required testing, such as proof and acceptance tests, are identified and performed in accordance with test procedures,

O a isa r e=te ===, aa 11 te eio==- 1r r e=1 te ,

I D-12

January 28, 1985 Letter QA-78-1, Rev. 4 l

I O cce9t're$ece criteri - ae recoraias criteri -

calibration, environmental conditions, documentation and iastru=e=t tioa i evaluation requirements, etc. are delineated in the test procedures. Changes to the test procedures are required to be reviewed / approved by the same organization (s) as the original issue.

Whenever equipment, components, and/or assemblies require modification, repairs, or replacement which could result in requirements for re-test or additional testing, Quality Assurance 1 -

personnel assure that original or new test inspection planning is prepared and adhered to as appropriate.

In any case, test results are documented, evaluated and accepted by qualified personnel as required by the test inspection plan prepared for the test under the cognizance of Quality Assurance personnel.

Criterion & Control nf Mannuring angi Testing Equipment Administration of the calibration of measuring equipment and instrumentation is performed by the Quality Department in accor-dance with approved PNSI QA Procedures. The calibration system assures that all standard measuring instruments (SMI) used in the acceptance of material, equipment, and assemblies are calibrated and properly adjusted at specified intervals to maintain accuracy O within pre-determined limits. Calibration is performed using equipment traceable to national standards. All calibrated equip-ment is identified and is traceable to the calibration test data.

Whenever SMI are found to be out of calibration during or immediately after use, all items inspected during that period are rejected by inspection and are submitted to review action for possible re-inspection or other appropriate corrective action.

Criterion m n=nr111ng. Storage, angl Shinpina PNSI approved QA Procedures require that handling, storage, and shipping requirements adherence verification criteria be included in quality planning. These requirements are designed to prevent damage or deterioration of material and equipment. Information

~

pertaining to shelf life, environment, packaging, temperature, cleaning, handling, preservation, etc., is included as required to meet design, NRC package approval and/or U.S. Department of Transportation shipping requirements.

Shipping documentation preparation, departure, and arrival time and destination data recording is also addressed in the planning, when applicable. The requirements in quality planning pertaining  ;

to shipping must be met prior to release for shipment.

D-13

d January 28, 1985 Letter QA-78-1,.Rev. 4 O crit rio m '- 9 ceie - re t ==a oP raei , se e - l l

The use of. inspection status tags, quality inspection stamps, and '

other means to indicate inspection and test status at, or for, PNSI are delineated in approved PNSI QA Procedures.

The clarity of the status indication, prevention of inspection,

and/or test step by-passing, and prohibition of removal or modi-fication of status indications, except with Quality Department approval / Material Review disposition is assured via these proce-dures. The Quality Assurance Department assures via Quality Procedure, interoffice memoranda, training sessions, and audit that all PNSI personnel are aware of and und.erstand the meaning and uses of status tags on all hardware, material, and test setups. (See also Criterion 15 discussion.)

Criterion & Mon-conforming Material. Parts gr Components PNSI approved QA Procedures require that material, components, and equipment that do not conform to requirements are controlled to prevent their inadvertent use. Identification, segregation, discrepancy reporting, disposition of non-conformances by I authorized individuals and re-inspection activities are performed and controlled in strict accordance with these procedures.

Quality Discrepancy Reports (QDR) are utilized by the PNSI Os quality department to identify discrepant items, describe the discrepancy, provide disposition and re-inspection requirements.

The signatures of authorized cognizant personnel are placed on the QDR to signify approval of the disposition. These personnel must be approved by the Co'rporate Quality Director and President and must be from the same groups approving the original design.

In conjunction with repair or re-work dispositions, quality assu-rance personnel provide supplemental inspection planning to verify proper implementation of the QDR disposition. This as-sures that the item is re-tested and/or re-inspected to a degree

at least equal to the original acceptance activity.

Criterion & Corrective Action l Failures, malfunctions, and deficiencics in material, components, -

l equipment and services are identified and reported to the Corporate Quality Director and the President. The cause of the condition and corrective action necessary to prevent recurrence is identified, implemented and then followed up to verify corrective action effectiveness. Detail requirements for this activity are delineated in approved PNSI QA Procedures.

O .

D-14

January 28, 1985 Letter QA-78-1, Rev. 4 Criterion L Onalitv Assurance Records A quality records system is in effect at PNSI and is administered in accordance with approved PNSI QA procedures. The purpose of the quality record system is to assure that documented evidence pertaining to quality related activities is maintained and avail-able for use by PNSI, its customers, and/or regulatory agencies as applicable. Quality Records include, but are not limited to, inspection and test records, audit reports, quality personnel qualifications, design reviews, quality related procurement data, supplier evaluation reports etc. All . records are identified by work order number, part number, contract number, or drawing number as appropriate to the record type. A complete list of all quality records is maintained and provides cross reference be-tween the different identity methods described above and pin-points the record location.

Design related records such as calculations, drawings, research and development test reports, etc., are retained in the Quality Assurance records system for the life of the shipping package.

All other quality related records are retained for a minimum of two years, but no more than five years unless otherwise specified by contract.

Inspection records retained in the Qua-lity Assurance records system provide the following data when applicable:

O (1) Inspection type, i.e., in-process, in-service, testing, receiving, and shipping.

(2) Evidence of completion and verification of manufacturing, inspection, or test operation.

(3) The date and results of the inspection or test.

(4) Information related to noted discrepancies.

(5) Inspector or data recorder identification.

(6) Evidence of acceptance.

Criterion & Andits Quality program audits are performed on a periodic, scheduled basis by personnel without direct responsibilities in the areas being audited. Audit personnel are certified quality assurance lead auditors who have met all requirements of ANSI N 45.2.23.

Written planning sheets and check lists are utilized. Audit results and corrective action activity are reported to manage- .-

ment, in writing, and are retained in the quality assurance record file. Responsible management personnel are required to O

D-}$

e January 28, 1985 Letter QA-78-1, Rev. 4 l

l 4

C respond to audit findings with the necessary action to correct the noted deficiencies. Current PNSI practice is to audit all i

quality functions on an annual basis. Areas found deficient during audits are reaudited on a first priority basis to verify corrective action implementation and effectiveness. Details of the PNSI Audit System are delineated in approved PNSI QA Proce-dures.

i i

i References (1) 10 CFR 71, Subpart H, Criteria 1-18 dated August 24, 1983,

" Quality Assurance Criteria for Shipping Packages for Radioactive Material."

(2) PNSI Corporate Quality Manual, dated August 13, 1984 i Attachments Figure 1: " Quality Requirements Matrix - 10 CFR 71, Subpart H, Criteria 1-18 vs. PNSI Quality Procedure Numbers 1-17".

Figure 2: " Organization Chart, Pacific Nuclear Systems, Inc.

O 4

D_-} 6

. . 1 January 28, 1985 Letter QA-78-1, Bev. 4 FIGURE 1

. QUALITI REQUIREMENTS MATRIX 10 CFR vs PESI 10 CFR 50, Appendix B PNSI Corporate Quality Manual 10 CFR 71, Subpart H I. Organization Quality. Program & Organization Chart QP 1 - Quality Control Manual QP 14 - Quality Assurance Training II. Quality Assurance Program Same as Above III. Design Control QP 2 - Design Review I

QP 15 - Engineering Holds QP 17 - Design Control I7. Procurement Document QP 4 - Procurement Control Control QP 15 - Engineering Holds

O V. Instructions, Procedures QP 3 - Document Control and Drawings QP 5 - Quality Planning QP 15 - Engineering Holds VI. Document Control QP 3 - Document Control QP 15 - Engineering Holds 4

VII. Control of Purchased ,QP 4 - Procurement Control Material, Equipment QP 12 - Material Control and Services .

VIII. Identification and Control QP 3 - Document Control of Materials, Parts and QP 12 - Material Control Components II. Control of Special Process QP 4 - Procurement Control QP 5 - Quality Planning -

QP 6 - Inspection and Verifica-

tion QP 16 - Special Process Qualifi-O cations and Control -

D-17

January 28, 1985 Letter QA-78-1, Rev. 4 l

q V

I. Inspection QP 6 - Inspection and Verifica-tion II. Test Control QP 5 - Quality Planning QP 6 - Inspection and Verifica-tion QP 15 - Engineering Holds

. III. Control of Measuring and QP 11 - Calibration Control Test Equipment XIII. Handling, Storage and QP 12 - Material Control Shipping XIV. Inspection, Test and QP 6 - Inspection and Verifica-Operating Status tion IV. Nonconforming Materials, QP 7 - Discrepancy Reporting Parts, or Components and Control XVI. Corrective Action QP 8 - Corrective Action IVII. Quality Assurance Records QP 1 - Quality Control Manual QP 9 - Quality Records QP 10 - Quality Forms Control XVIII. Audits QP 13 - Audits i

O .

D-18

O .

QA-7 8-1, - Rev. 4 ~

FIGURE 1 ORGANIZATION CHART PACIFIC NUCLEAR SYSTEMSi INC.

31 airman / President D.F. Jones Executive V. Pres.

Marketing J.C. Ritchie O .

Controller /Chiet Financial Officer D.J. Cook Director Quality Assurance J.R. Olivadoti President-PNSSI President-NuPac President-NPL L.B. Hebbard R.T. Haelsig M.P. Carson i

See Exhibit A-1 for Typical l Subsidiary Organization Chart D-19

_ l

O QA-7 8-1, Rev. 4 1

FIGURE 1-A l TYPICAL ORGANIZATION CHART PNSI SUBSIDIA'RY President t

t Office O Manager I

Manager Manager Mana r Engineerin9 Manager Manager Procurement flarkegn9 Operations ASanbe Engineers -

Project Mgr See Exhibit A-2 for Typical.0A .

Design Organization Chart Production .

t O Drafting . snip / Receive D-20

{ ,

QA-78-1, Rev. 4 FIGURE l-B TYPICAL ORGANIZATION CHART QA DEPARTMENT QA Manager O ,

Inspection Quality Eng.' Qualitykudit i

Qhtrs Receiving Special. Process I,nternal Control Audit l

1 IN-PR0' CESS /-

Design l Control ASSEMBLY Testirg/ Procurement -

Operctions Control  :

O Final / Shipping Document .

Control D-21

.