ML20096C110

Rev 3 to OSR/GP-1, WVDP Operational Safety Requirements

ML20096C110
Person / Time
Site:	West Valley Demonstration Project
Issue date:	04/24/1992
From:	Humphrey R, Roberts C, Steffes D WEST VALLEY NUCLEAR SERVICES CO., INC.
To:
Shared Package
ML20096C107	List: ML20096C099 ML20096C110
References
REF-PROJ-M-32 OSR-GP-1, NUDOCS 9205130174
Download: ML20096C110 (22)

Text

.

. ~.

Occ. Nuccer O SR / CP-)._

j Revisien Nu=cer 3

Revision Date 04/24/92 Engined.ng Release #1430 Per ECN #33$3 Per ECN 0902 l

West a ey 36m O n STTG'" On

._,TO; e ct OPE 8. ATI0tlAL S AF!*Y REOU:8EMENT!

M

0. R. Steffes Cate

'T

'c'.

PP.EPARE Ocgr.::an:, Enginee APPP.0VE3,1Y a

C. J. P.c D e r ts Date Y W

Cpgna:an: Manager-Oace [!7.4 !f.

kN ~,b R. A. Humpnrey APPROVED BY l

,Qctation &lEAfsty Q C* -" L,*. t e e. Cha ir ma n Oate E/.U b AP.PROVEDBYl_)e he D. L. Shugars I

'uaa :y As urance I/' dlM

.J f

APPROVED-BY

/

R. P. Cessner Cate LL4 Trea =en* Pr jeg e

J. L. Kna:ense..un Date 824.c/T3 APPRCVED SY

,I d

f.ac:. clog cal & Environmental

/

'1(ety. Manager APPROVE 0 BY-bdl. ! '.4.6 R. E. La' r e nc e. Jr.

Date i b i/o :i Superna: ant Tredtment Project Manager West Vciley Nuclear S ervices Co.

P.O. Sox 191 West Valley, N.Y.14171-CISI OSR 0001274.RF!

DOE Approved: DW:92:0397

-w v.1816 Dated 03/17/92

(.N (74920429 R

N-32 PDR

.1

osR-/CP-1 Rev. 3 RECORD OF REVISIpy PROCEDURE If there are-changes to the procedure, the revision number increases by one.

These changes are indicated in the lef t margin of the body by an arrow (>) at the beginning of the paragraph that contains a change.

Examoles

> The arrow in the margin indicates a change.

Revision on Rev. No.

Descriotion of Chances Peopfs)

Dated 0

original Issue All 1

Dated 5/20/88 All 1

Engineering Release 1430 N/#.

8/88 2

Per ECN 3353 Page 4 1/90 3

complete Revision Per ECN 3902 All-04/24/92 f

\\

l i

J i

W-1807, Rev.

3.

1

-OSR:0001274.RM

...,. _ _. _ -..... _ _ _. ~.. _.. _. _. -,., _. ~ - - -. _ _.. ~...

-. - -. - - _ _. ~... _.... _,.,

l OSR-GP/-1 i

+

Rev. 3 l

l

+

RECORD OF REVXSIOf4 ' f COffTItitf AT10N SHFET)

'u l

Revision On Rev. No.

Descridtion of Chenster Pace (s)

Dated W-1807, Rev. 1 11 OSR 0001274.RM

-_ - ~... ~..

OSR/GP-1 Rev. 3 OPERATIONAL SAFETY REQUIREMENT OSR/GP-1 r

TITLE:

WDP Airborne Radioactive Release Limits CRITERIA: 1.

Release of airborne radioactive effluents shall not exceed limits established by DOE orders.

UNACCEPTABLE EVENTS: 3. Releases of airborne radioactivity exceeding DOE limits.

REPORTING REQUIREMENTS: Por Operational Safety Requirement (OSR) violations, W-987 " Initial Investigation, Oral Reporting, and Written Critique of Occurrences at WNS" shall be followed.

operational Safety Requirement OSR/GP-1 Page 1

Safety Limit 1

Limiting Conditions for Operation (LCOs)

Surveillance Requirements (SRs) 2

~

2 Basis 3

Attachments References 3

IMPLEMENTING PROCEDURES:

EH-11 EM-101 SOP 15-11 SOP 15-48

SOP 50-35 SDP 70-30 SOP 80-5 SOP 80-6 i

/'

111

(

OSR:0001274.RM 4

, v

-r

--,..,~m-,-,--w,,,.-

,r,.

-_ycm

,.,y-m.,,m,

,.,m w--w,-

---y-

,-r

-- - - - - + -

-w-+---*--t-'T

OSR/GP-1 Rev. 3

~

OPERATIONAL SAFETY REQUIREMENT O

WVDP AIRBORNE RADIOACTIVITY RELEASE LIMITS APPLICABILITY This OSR applies to all aitborne radioactive emissions from WVDP permitted process and ventilation stacks.

g)JFCTIVE This specification ensures that the off-site doses from airborne radioactive releases from WVDP operations are less than the guideline values stipulated by DOE Order 5400.5, and 40 CFR 61, for individuals in uncontrolled (off-rite) areas.

EfgCIFICATION SAFETY LIMIT OFF-SITE RADIATION DOSE TO THE MAXIHALLY EXPOSED INDIVIDUAL DY THE AIRBORNE PATHWAY SHALL BE LESS THAN 10 MREH/ YEAR EFFECTIVE DOSE EQUIVALENT.

1.

LIMITING CONDITIONS FOR OPERATION A.

THE TOTAL PARTICULATE RADIOACTIVITY RELEASE RATE FROM THE WVDP MAIN PLANT STACK SHALL NOT EXCEED 18 NANOCURIES/SECOND FOR LONG-LIVED GROSS BETA ACTIVITY AND 0.10 NANOCURIES/SECOND FOR LONG-LIVED GROSS ALPHA ACTIVITY AVERAGED OVER A CALENDAR QUARTER.

B.

THE TOTAL PARTICULATE PADICACTIVITY RELEASE FROM EACH OF THE OTHER STACKS AND ANY FUTURE VENTS OR STACKS FOR WHICH HONITORING IS OR WILL BE REQUIRED (UP TO A TOTAL OF NINE STACKS), SHALL NOT EXCEED 3 NANOCURIES/SECOND/ STACK FOR LONG-LIVED GROSS BETA ACTIVITY AND 0.03 NANOCURIES/SECOND/ STACK FOR LONG-LIVED GROSS ALPHA ACTIVITY AVERAGED OVER A CALENDAR QUARTER.

2.

SURVEILLANCE REOUIREMENT A.

THE TOTAL PARTICULATE RADIOACTIVITY RELEASED FROH THE WVDP MAIN PLANT STACK SHALL BE MEASURED TO ENSURE THAT THE AVERAGE AIRBORNE

\\

OSR:0001274.RH Page 1 of 3

OSR/GP-1 Rev. 3

~

RADIOACTIVITY RELEASED DOES NOT EXCEED 47 HILLICURIES GROSS BETA ACTIVITY OR 0.47 HILLICURIE GROSS ALPHA ACTIVITY IN ANY ONE HONTH.

THE TOTAL PARTICULATE RADIOACTIVITY RELEASED FROM ALL OTHER STACKS FOR m.

WHICH HONITORING IS REQUIRED SHALL BE HEASURED TO ENSURE THAT THE AVERAGE AIRBORNE RADIOACTIVITY RELEASED DOES NOT EXCEED 7.8 HILLICURIES/ STACK GROSS BETA ACTIVITY OR 0.078 HILLICURE/ STACK GROSS ALPHA ACTIVITY IN ANY ONE MONTH.

3.

RECOVERY IF THE RELEASE RATES SPECIFIED IN THE SURVEIL ANCE REQUIREMENT ARE EXCEEDED, OPERATIONS SHALL BE CURTAILED AND CONDITIONS EVALUATED AND CORRECTED TO ASSURE THAT THE QUARTERLY LIMITS CAN DE HET BEFORE FURTHER OPERATIONS ARE PERMITTED.

RAI.11 Per DOE Order $400.5 and 40 CFR 61 Subpart H, the committed offective dose equivalent (EDE) from all stack effluents is limited to 10 mrem / year to any off-site resident, with an administrative surveillance level set at 1/12 of 10 percent of this limit per month for each stack or vent requiring monitoring.

(~'T The straight line gaussian plume dispersion model, he terrestrial food-chain pathway models in NRC's Regulatory Guide 1.109, and external and internal dose factors (using the ICRP's organ weighted risk model), are incorporated in the computer model required by 40 CFR 61.

This model forms the calculational basis for the radionuclide release limits in the Limiting Conditions for Opsration (LCO) and the Surveillance Requirement (SR) of this OSR.

Annual average measurements of stack effluents show that the concentration of long-lived gross beta activity is typically on the order of 100 times the long-lived gross alpha component. Measured effluent ratios of Sr-90 to es-137 are approximately 1:1; effluent ration of Pu-239 to km-241 are approximately 1:3. Using these data, gross beta activity is conservatively assumed to be 50 percent Sr-90 plus 50 percent Cs-137, and gross alpha activity is assumed to be 25 percent Pu-239 and 75 percent Am-2A1.

The ventilation flow rates are not factors in the computer model.

The four radionuclides in the above ratios were input to the EPA-approved air dispersion and dose assessment code AIRDOS-PC (Version 3.0, 1990). One computer run was performed for the main plant stack using wind data collected during 1989 at tne 60 meter elevation of the on-site meteorological tower.

OSR:0001274.RH Page 2 of 3

~ - _ _ _. - _

OSR/GP-1 Rev. 3 Another run was performed for all other stecko (assuming a 10 meter release height) using find data collected at an clavation of 20 metere.

i As determined f rom the AIRDOS-PC predictione and a survey of nearby residences, the maximally exposed off-site individual (for both vievated and h

ground-leval releases) lives approximately 1900 meters NKW from the main plant stack.

The results from the computer runs were used to reale the radionuclide releave rates so that the EDE to the maximally exposed resident from any stack or vent that requires monitoring would not exceed 10 percent of the limit (i.e.,

1 mrem / year) if the LCOs were met.

II, in the future, more than ten stacks (including the main plant stack) require monitoring, this limit on cach stack will be revised to accommodate the additional stacks.

The administrativ; level of 1/12 mrem / month from any monitored stack or vent was obtained by reducing the 10 mrem /yr limit by a factor of.10 and dividing by 12 months. To obtain the monthly limits in SR Parte A and B, the release rate limits in LCO Parts A and B, respectively, were multiplied by the number of seconds in 30 days.

Procedurally, action is requAred to investigate and report to management release levels at or above 75 percent of OSF limits (EM-11).

In addition, monthly-tracking of airborne releascs ir trovided to site management.

ATTACNMENTS None RETERENCES DOE /ET JO96, A Guide for Effluent Radiological Haasurements at DOE Installations, 7/83.

DOE /EP-0023, A Guide for Environmental Radiological Surveillance at U.S. Department of Energy Installations, 7/81.

DOE Order 5400.5, Radiation Protection of the Public and the Environment, 2/90.

40 CFR 61, Subpart H, National Emission Standards for Emissions of Radionuclides other than Radon from Department of Energy Facilities.

DOE-ID Order 5400.1 General Environmental Prctection Program, 8/12/91 OSR:0001274.RM Page 3 of 3

5

(^)

West Valley D.. N.er os-Ts-n Demonstration Project Revision Date 04/29/92 Engineering Release (12333 TITLE:

SUPERNATANT TREATMENY EYSTEM FEED REQUIREMENTS

/

J. J. Prowse Date N/

PREPARED BY W -

Cognizant ingirppr

/

D. C.

Heems Date 0'"

APPROVED BY Dognizant Design Manager I!/C !'IV APPROVED BY d '1WV n R. A. Humphrey Date hadiatibn & Safety Committee Criakrman

//[l[d97 M

D. L. Shugars Date APPROVED BY

-p Wiit'y %seur'iince

'p N

"W I/

P. J. Valenti Date / [

APPROVED BY Pac 111 ties Manager y

APPROVED BY 4

D. J. Harward Date /

h

/

Radiation &j#af aty 13epartmen[Hanager 4

West Valley Nuclear Services Co., Inc.

P.O. Box 191 West Valley, NY 14171-0191 OER:0001256.RM DOE Approved: DW: 92:0546 Dat e d:: April 17, 1992 WV 1816, Rev.1

0$R/IRTS 12 Rev. O e,(h v

RECORD OF REVISION PROCEDURE If there are changes to the precedure, the revision number increases by one.

These changes are indicated in the left margin of the body by ar arrow (>) at the beginning of the paragraph that contains a change.

Ex3wnle:

The arrow in the margin indicates a change 4

Rev. No.

Description of Changes Revision On Dated

.' age (s) 0 Original Issue All 04/29/52 l

^

l f\\

(xJ l

l l

l l

l i

1 e%

l

\\~-)

l WV 1807, Rev. 1 OSR:0001256.RM i

OSR/IRTS 12 Rev. O RECORD OF REVISION (CONTINUATION SHEET)

' Revision On

~

Rev. No.

Descriation of Ch9nras Pare (s)

Dated

.+

W-1807, Rev. 1 05R:0001256.RM 11

(

s

__s____

OSR/IRTS 12 Rev. 0 OPERATIO4NAL SAFETY REQUIREMENT IRTS-12 TITLE:

Supernatant Treatment System (STS) Feed Requirements CRITERIA:

1.

The concentration of the STS liquid feed from Tatk 8D 2, sludge wash solution, shall be less than 0.25 pCi ALPHA Pu/mL during the first WASH CYCLE and 0.1 pCi ALPHA Pu/mL for each of the remaining 3 WASH CYCLES.

1 2,

'Less than 264,000 gals. (=1,000,000 L) of undiluted s?udge vash

-solutior. from Tank SD-2 during the first WASH CYCLE shall be processed through any ion exchange column charge loaded with Ti-treated eolite between its TI treated zeolite discharges.

3.

Less than 79? 000 gals. (=3,000,000 L) of undiluted sludge wash solution from Tank 8D 2 in the )ast 3 WASH CYCLES shall be processed through any ion exchange column charge loaded with Ti-treated seolite between its Ti treated zeolite discharges; however, if a Ti-treated zeolite charge is used in the first WASH g'

CYCLI and continues to be used in subsequent WASH CYCLES then 2.5 times the volume processed through the charge from the first WASH CYCLE must be included as pt.rt of the volume limit for the remaining 3 WASH CYCLES.

UNACCEPTABLL EVENTS:

1.

Processing undiluted sludge wash solution with a concentration greater than 0.25 pCi \\LPHA Pu/mL for the first WASH CYCLE or 0.1 pCi ALPHA Pu/mL for the remaining.3 WASH CYCLES through Ti-treated ecolite, 2.

Processing greater than 264,000 gals. (=1,000,000 L) of undiluted sludge wash solution during the first WASH CYCLE through any ion exchange column charge loaded with'Ti-treated zeolite without the Ti-treated zeolite being discharged.

.3.

Processing greater than 762,000 gals. (=3,000,000 L) of undiluted sludge wash solution in the last 3 WASH CYCLES through any ion exchange column charge loaded OSR:0001256.RM 111

A OSR/IRTS 12 Rev. O I

with Ti-treated zeolite without the Ti treated zeolite being discharged; however, if a Ti-treated zeolite chargo is used in the first WASH CYCLE and continues to be used in subsequent VASH CYCLES then 2.5 times the volume processed through the charge from the first WASH CYCLE must be included as part of the volume limit for the remaining 3 VASH CYCLES.

REPORTING REQUIREMENTS: For Operational Safety Requirement (OSR) violations, WV-987

" Occurrence Investigation and Reporting" shall be followed.

. Operational; Safety Requirement-(OSR)/IRTS-12 Page No.

Applicability.-..

3 3

Objectives Violation - Criteri a

-4 4

Applicability of LIMITING CONDITION FOR OPERATION.

}'"

Applicability of SURVEILLANCE REQUIREMENTS 5

Definitions 6

8 SPECIFICATIONS Bases.

11 Attachments

.,. 13 13 References

-IMPLEMENTING PROCEDURES: The following procedures are listed for information only,-

thus cnan;es to these procedures.do D21 require an Unreviewed Safety Question 4

Determination (USQD) in accordance with DOE 5480.21 "Unreviewed Safety Questions"

- Chapter.II. Section 3.a.

S0P 00-13 05R:0001256.RM iv

,v 4

+s,.e-

---s v-w-wewe-e

-e=<s-s

.=-

l OSR/IRTS 12 Rev. 0 OPERATIONAL SAFETY REQUIREMENT SUPERNATANT TREATMENT SYSTEM FEED REOUIREMENTE APPLICABILITY This Operational Safety Requirement (OSR) applies to the requirements of the liquid feed (sludge wash solution) for the Supernatant Treatment System (STS) while processing through ion exchange columns containing Ti-treated zeolite.

OBJECTIVES 1.

To assure that the concentration of undiluted sludge wash solution from Tank 8D-2 to-the STS is less than 0.25 pCi ALPHA Pu/mL during the first WASH CYCLE h

and 0.1 pCi ALPHA Pu/mL for each of the 3 remaining WASH CYCLES while processing through any ion exchange column loaded with Ti-treated zeolite.

s s

..,)

2.

To assure that less than 264,000 gals. (=1,000,000 L) of undiluted sludge wash solution from Tank BD-2 during the first WASH CYCLE shall be processed through any ion exchange column charge loaded with Ti-treated zeolite without the Ti-created zeolite being discharged.

3.

To assure that less than 792.000 gals. (=3,000,000 L) of undiluted sludge wash solution from Tank 8D 2 in the last 3 WASH CYCLES shall be processed through any ion exchange column charge loaded with Ti-treated zeolite without the Ti-treated zeolite being discharged; however, if a Ti-treated zeolite charge is used in the first WASH CYCLE and continues to be used in subsequent WASH CYCLES then 2.5 times the volume processed through the charge from the first WASH CYCLE must be included as part of the volume limit for the remaining 3 WASH CYCLES.

A (v)

OSR:0001256.RM Page 1 of 9

[

l OSR/IRTS-12 Rev. O DL)

VIOLAT, ION CRITERIA Violation of this OSR occurs solely as a result of failure to tahe the required ACTIONS with'a the required time limit 911owing:

l (1) failure to meet a LIMITING CONDITION FOR OPERATION (LCO). EI (2) failure to meet a SURVEILLANCE REQUIREMENT (based on performance of SURVEILIANCE TESTS), RI (3) failure to perform a SURVEILIANCE TEST within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the SURVEILLANCE INTERVAL, whichever is less, when it is discoverea that the delinquent SURVEILLANCE TEST was not performed within the applicable SURVEILLANCE INTERVAL plus a 25% extension, APPLICABILITY OF LIMITING CONDITION FOR OPERATION o

Compliance with a LCO contained in the SPECIFICATIONS is required during the

()

conditions specified therein except that upon failure to meet the LCO, the associated ACTION shall be met.

Completing the associated ACTION within the specified time interval is considered compliance with the SPECIFICATION o

The time limits of the ACTION associated with a LCO are applicable from the time it is identified that the LCO is not satisfied.

o Noncompliance with a SPECIFICATION shall exist when the requirements of the LCO add the associated ACTION are noc met within the specified time irtervals.

If the LCO is restored before expiration of the specified time intervals, completion of the ACTION is not required.

Thus, not meeting the requirements of a LCO, by itself, is not considered noncompliance with a SPECIFICATION.

APPLICABILITY OF (?RVEILLANCE REOUIREMENTS o

SURVEILLANCE REQUIREMENTS shall be met during the conditions specified for an individual LCO unless otherwise stated in an individual SURVEILLANCE REQUIREMENT.

OSR:0001256.RM Page 2 of 9

. ~,.

03R/IRTS 12 Rev. 0

)

o Each SURVEILIANCE TEST shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the SURVEILLANCE

-. INTERVAL.

-o

-Failure to meet a SURVEILLANCE REQUIREMENT with!.n the applicable SURVEILLANCE INTERVAL plus 25% extension shall constitute noncompliance with the associated LCO if, upon diccovery, the associated SURVEILIANCE TEST is not performed

. within the permitted DEIAY PERIOD (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the SURVEILIANCE INTERVAL,.

whichever is less).

If the SURVEILLANCE TEST is not performed within the DEIAY PERIOD, the associated LCO must be IMMEDIATELY declared not mot and the associated ACTION taken. When the SURVEILIANCE TEST is performed within the DEIAY PERIOD and establishes that _ the associated LCO is not met, toe LCO must be IMMEDIATELY declared not met and the associated ACTION taken.

-o If the result of any SURVEILIANCE TEST executed to comply with a SURVEILLANCE i

REQUIRE!'ENT is unsatisfactory, thus establishing that the associated LCO is not met, then the time limits of the associated ACTION are applicable from the l

time it is identified that the LCO is not met.

If the-results of all required SURVEILLANCE TESTS executed to comply with o

- SURVEILIANCE REQUIREMENTS are satisfactory, then the associated LCO is met unless otherwise determined.

o SURVEILLANCE REQUIREMENTS do not have to be performed on INOPERABLE equipment.

DEFINITIONS Defined terms appear in capitalized type throughout this OSR.

L 1-ACTION -

ACTION shall be that part of a SPECIFICATION whit h prescribes remedial measures required under designated conditions.

I ALPHA Pu -

ALPHA Pu consists of Pu-238, Pu-239, Pu 240, and Pu-242.

LO

.OSS:0001256.PX Page 3 of 9

OSR/IRTS 12 Rev. 0 7-3 i

1 DELAY PERIOD -

Twenty four hours or the SURVEI?.IANCE INTERVAL, whichever is less.

IEMEDIATE/IKMEDIATELY -

As soon as practicable, yet without delay due to other distractions.

INOPERABLE -

A system, subsy. tem, train, component or device shall be INOPERABLS when it is not capable of performing its specified function (s), or when any necessary attendant instrumentation, controls, power systems or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function (s) are not capable of performing their related support function (s).

LIMITING CONDITION FOR OPERATION-LIMITING CONDITION FOR OPERATION shall be that part of a 3

SPECIFICATION which prescribes the minimum limits for safe operation, n

k~

SPECIFICATION-S?ECIFICATION shall be that part of an OSR which prescribes the LCO, ACTION and SURVEILLANCE REQUIREMENT (S).

SURVEILLANCE REQUIREMENTS -

SURVEILIANCE REQUIREMENTS shall be that part of a SPECIFICA'" ION which prescribes activities to be conducted within a specified time interval (SURVEILLANCE INTERVAL) in order to establish compliance with the associated LCO.

SURulL1ANCE INTERVAL -

SURVEILIANCE INTERVAL shall be that time interval in which the event, action, activity, etc., shall te executed.

Specific SURVEILLANCE INTERVALS are defined as follows:

PRIOR Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before initiation of an event DAY 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DAILY At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 7%

)

WEEKLY At least once per 7 days OSR:0001256.RM Page 4 of 9

~

OSR/IRTS 12 Rev 0

-p SURVEILLANCE TESTS -

SURVEILLANCE TESTS shall be those activities required to be performed to satisfy a SURVEILLANCE REQUIREMENT.

. WASH-CYCLE -

WASH CYCLE ir defined as the addition of approximately 264,000 gals. (=1,000,000 L) of dilute caustic solution to Tank BD-2 and its-subsequent processing through the STS.

.EFECIFICATIOES 1.

SUPERNATANT TREATMENT "YSTEM FEED 1.1 LIMITING CONDITION FOR OPERATION The concentration of undiluted sludge wash solution from Tank 8D-2 to the STS shall be less than 0.25 pCi ALPHA Pu/mL durir3 the first WASH CYCLE and 0 l ()

pCi ALPHA Pu/mL for each of the 3 remaining WASH CYCLES while processing through any ion exchange column loaded wir, Ti treated zeolite.

ACTION A.

If the concentration of the undiluted sludge wash solution from Tank 8D-2 to the STS exceeds 0.25 pCi ALPHA Pu/mL during the first WASH CYCLE or 0.1 pCi ALPHA Pu/mL for each of the 3 remaining WASH CYCLES,

.then processing through Ti-treated zeolite shall be discontinued "ithin 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The Ti-treated zeolite shall be discharged to Tank SD-1 as soon as practicable.

AIld B.

Sufficient sodium hydroxide (NaOH) shall be added to Tank 8D-2 to suppress the plutonium solubility such that the LCO is satisfied before-resumption of processing liquid STS feed through Ti-treated zeolite.

O 4

OSR:0001256.RM Page 5 of 9

_m

__m

'4 OSR/IRTS 12 Rev, 0 i

SURVEILLANCE REOUIREMENTS A.

PRIOR to initiation of STS processing and WEEKLY while processing, an undiluted sludge wash solution feed sample shall be taken.

3.

The sample shall be analyzed to determine the concentration of ALPilA Pu PRIOR to initiation of STS processing and within 4 DAYS from when the sample was taken while processing, 1,2 LIMITING CONDITION FOR OPERATION (Durinn VASH CYCLE 1)

Less than 264,000 gals. (=1,000,000 L) of undiluted sludge wash solution from Tank BD 2 during the first WASH CYCLE shall be proccased through any ion exchange column charge loaded with Ti-treated zeolite between its Ti-treated zeolite discharges.

If more than one ion exchange column charge loaded with Ti-treated zcolite is used during the first WASH CYCLE, then the volume processed through the existing ion exchange column charge loaded with Ti-()

treated. zeolite must be included as part of the volume limit for the

' additional ion exchange column charges loaded with Ti treated zeolite.

ACTION If the volume limit has been exceeded for an ion exchange column charge loaded with Ti treaced zeolite, processing of sludge wash solution shall be

-discontinued within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and the Ti-treatad zeolite shall be discharged to Tank 8D '. as soon as practicable.

SURVEILIANCE REOUIREMENT L

For each ion exchange column charge loaded with Ti-treated zeolite, the cumulative undiluted sludge wash solution volume shall be determined and l

documented DAILY while processing s.wJge wash solution.

l.3 LIMITING CONDITION FOR OPERATION (Durtnc UASH CYCLES 2. 3 & 41 Less than 792,000 gals, (=3,000,000 L) of undiluted sludge wash solution from Tank 8D 2 in the last 3 UASH CYCLES shall be processed through any ion

)

exchange column charge loaded with Ti-treated zeolite between its Ti treated OSR:0001256.RM Page 6 of 9

a OSR/IRTS-12 Rev.- 0 zeolite discharges; however,-if a Ti treated zeolite charge is used in the

.first WASH CYCLE and continues to be used in subsequent WASH CYCLES then 2.5 times the volume processed through the charge from the first WASH CYCLE nust be included as part of the volume limit for the remaining 3 WASH CYCLES.

If more than one_ ion exchange column charge loaded with Ti-treated zeolite is used during the 3 remaining WASH CYCLES, then the volume processed through the existing ion exchange column charge loaded with Ti-treated zeolite must be included as part of the volume limit for the additional ion exchange column charges loaded with Ti treated zeolite.

ACTION If the volume limit has been exceeded for an ion exchange column charge loaded with Ti-treated zeolite, processing of sludge wash solution shall be discontinued within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and the Ti treated zeolite shall be discharged to Tank 8D-1 as soon as practicable.

SURVEILLANCE REOUIREMENT For each ion exchange column charge loaded with Ti-treated zeolite, the cumulative undiluted sludge wash solution volume shall be determined and documented DAILY while processing sludge wash solution; however, if a Ti-treated zeolite charge is used in the first WASH CYCLE and continues to be used in subsequent WASH CYCLES then 2.5 times the volume processed through the charge from the first WASH CYCLE must be included as part of the volume limit for the remaining 3 WASH CYCLES.

BASES Eased upon documented criticality safety evaluations, there is no potential for criticality during STS-operations.

A fault tree analysis analyzed the administrati"- har. :ars provided by this OSR and demonstrated that each barrier has an annual probability of failure of less than 1E 06 (Prowse, 1992). To provide an operational envelope for purposes of-process control, the maximum concentration of ALPHA Pu is 0.25 pCi/mL. This value results in a maximum of 952 g of fissile Pu in OSR:0001256.RM Page 7 of 9

OSR/IRTS 12 Rev. 0

/k solution in Tank BD 2.

This'is a safe mass, based upon the criticality safety evaluations performed (Caldwell, 1990: Yuan 1991).

The allowable safe fissile material concentration (0.25 pC1 ALPHA Pu/rL during the first WASH CYCLE and 0.1 pCi ALPHA Pu/mL for each of the 3 remaining VASH CYCLES) for the entire sludge mobilization and wash system (SKWS) process was established

-based on the vessel or component having the minimum critical concentration (i.e.,

the most-restrictive vessel).

It was determined that approximately 1.0 kg of 2nPu loaded onte Ti-treated zeolite within an ion exchange column in a sphere, radius 22.5 cm, would result in an effective multiplication factor (k.rr) + 20 - 0.95 (Caldwell, 1990 and Yuan, 1991).

The ion exchange column is the most restrictive vessel.

This evaluation was made using the KENO-V code and various cross section data sets

-compiled at the Argonne National Laboratory's IBM mainframe computer systems (Yuan, 1991) and independently verified using TWODANT compiled at the Los Alamos National Laboratory's Cray mainframe computer system (Caldwell,1990).

All differences 3

between calculational model and the actual configuration are conservative (i.e.,

result in'an overestimate of k rt)-

e Based on currently available Tank 8D 2 inventory data, the initial concentration for alpha plutonium is expected to be less than 0.03 pCi/ml. This-results in a maximum of 114 g of fissile plutonium in solution in tank 8D 2 for each WASH CYCLE which is a safe mass per DOE ORDER 5480.5.

Thus, there is no potential for a nuclear

criticality during the entire SKWS operation under normal and abnormal operating

conditions..The soluble fissile Pu mass is less than 952 g at 0,25 pCi ALPHA Pu/mL

-during_the first WASH CYCLE and less than 845 g at 0.1.pCi ALPHA Pu/mL for the entire 3 remaining VASH CYCLES as determined by laboratory analysis on several Tank 8D-2 sludge wash solution samples.

-The concentration of ALPHA Pu is determined WEEKLY from a Tank 8D-2 liquid sample of sludge wash solution prior to the transfer to ion exchange columns and dilution.

Cradual changes in ALPHA Pu content can then be tracked and active caustic additions t

made as required to reduce the ALPHA Pu concentration.

In addition, inadvertent OSR:0001256.RM Page 8 of 9

y OSR/IRTS-12 Rev. O additions of low pH solutions to Tank 8D 2 in violation of the limits in OSR/IRTS 1, would be detected in a timely fashion. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time interval for completion of the ACTION allows the STS to be placed into a safe stand by configuration in a methodical fashion. This time duration would have negligible impact on the total mass of fissile plutonium which could be loaded onto the Ti treated zeolite.

The surveillance interval of DAILY for the volume LCO allows for approximately 10,000 gallons (3,800 L) of liquid to be processed between readi.ngs. This verifies that the flow rate through the STS is within expected ranges and allows for intervention in a timely fashion in the event of equipment malfunction.

The resultant maximum mass of fissile plutonium processed per day would be less than 30 g or 3% of the safe mass limit for the STS. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time interval for completion of the ACTION allows the STS to be placed into a safe stand-by configuration in a methodical fashion. This time duration _vould have negligible impact on the total mass of fissile' plutonium which could be loaded onto the Ti treated zeclite.

ATTACHMENTS None REFERENCES Caldwell, 1990 J. T. Caldwell. October 1990 (FB:91:0129). " Criticality Safety Analysis for WNS Sludge Tanks and Related Processing Equipment."

DOE: Order 5480.5 September 1986.

" Safety of Nuclear Facilities."

Prowsa, 1992 J. J. Prowse. March 1992 (FB:92:0061).

" Fault Tree for TR-IRTS-12."

W-937, Rev. 8. February 1992.

" Occurrence Investigation and Reporting.*

Yuan, 1991 Y. C. Yuan.

October 1991 (FB:91:0012). " Criticality Evaluation:

Sludge Wash and Mobilization System --Zeolite Column."

O OSR:0001256.RM Page 9 of 9

>