ML20005E365

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Process Control Program
ML20005E365
Person / Time
Site: Rancho Seco
Issue date: 12/27/1989
From: Keuter D
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20005E342 List:
References
PROC-891227, NUDOCS 9001050130
Download: ML20005E365 (28)


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1 RANCHO SECO NUCLEAR GENERATING STATION PROCESS CONTROL PROGRAM F

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i EFFECTIVE DATE:

Initial Issue 9001050130 891228 PDR ADOCK 05000312 P

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0-5028b TABLE OF CONTENTS

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List of Floures 111 Definitions iv 1.0 ' INTRODUCTION-1-1 1.1 -

PURPOSE 1-1 1

1.2 SCOPE 1-1 1.3 PRECAUTIONS / LIMITATIONS 1-1 1.4 RESPONSIBILITIES 1-2

'2 0 RADI0 ACTIVE HASTE PROCESSING REQUIREMENTS 2-1 2.1 -

SOLID RADI0 ACTIVE WASTE 2-1 j

l l-2.1.1 Operability Criteria 2-1 1

E 2.1.2 Tests / Inspections 2-1 2.1.3 Basis 2-2 I-2.2 MAJOR CHANGES TO LIQUID, GASEOUS, & SOLID L

RADWASTE TREATMENT SYSTEMS 2-2 l

3.0 PROGRAM DESCRIPTION 3-1 3.1 PROCESSING OF HET RADI0 ACTIVE NASTE 3-1 l

3.1.1 Processing Methods 3-1 l-3.1.2 Processing System Description 3-1 l

3.1.3 Prequalification Testing 3-1 3.1.4 System Qualification Tests 3-1 3.1.5 Equipment / System Operability Requirements 3-2 3.1.6 Batch Preprocessing Sampling 3-2 E

3.1.7 Surveillance Testing 3-2 l

3.1.8 Acceptance Criteria 3-3 l

3.1.9 Corrective Actions 3-3 3.2 PROCESSING OF DRY ACTIVE HASTE 3-4 3.3 MIXED HASTE 3-5 4.0 HASTE CLASSIFICATION AND CHARACTERIZATION 4-1 4.1 HASTE CLASSIFICATION 4-1 l

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TABLE OF CONTENTS (Continued)

EL9t-4.2 NASTE CHARACTERISTICS 4-1 5.0 SPECIFIC NASTE STREAM PROCESSING DESCRIPTIONS-5 1

- 5.1 NET RADIOACTIVE WASTE STREAMS 5-1 5.1 -.1 Resins 5-1

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5.1.2 Cartridge Filters 5-2 5.1.3 Evaporator Concentrates 5-2 5.1.4 Sludge 5-3 5.1.5

'Hiscellaneous Liquids 5-3 5.2 DRY ACTIVE HASTE 5-3 6.0 ADMINISTRATIVE CONTROLS 6-1 6.1 PROCEDURES 6-1 6.2 QUALITY ASSURANCE 6-1 J

6.3 CHANGES TO THE PCP 6-1 l:

6.4 DOCUMENTATION 6-2 6.5-TRAINING 6-2

7.0 REFERENCES

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'l Restn Processing Flow Chart 5-4 e-1 15 Liquid Process-Flow Chart 5-5 E

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i DEFINITIONS Terms in this manual which have a specific definition or meaning are capitalized (e.g., OPERABILITY). Definitions for such capitalized terms are found in Sections 01.0 of Technical Specifications, with the exception of

" PROCESSING" which is defined below:

i PROCESSING PROCESSING shall be the conversion of wet radioactive waste into a form that meets shipping and burial ground requirements.

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SECTION

1.0 INTRODUCTION

T 1.1 PURPOSE e

The purpose of the Process Control Program (PCP) are to:

(1)

Establish a program which will provide reasonable assurance that all radioactive wastes generated at Rancho Seco that are to be disposed of at a land disposal facility are PROCESSED and packaged such that applicable Federal regulations, State rules and regulations, and disposal site criteria are satisfied.

e (2)

Assure that major changes to the Liquid, Gaseous and Solid Radwaste Systems are properly reviewed, evaluated and approved.

The PCP contains a general description of the methods for controlling the PROCESSING and packagir.g of solid and liquid radioactive wastes, specific parameters for each method, and the administrative controls and quality assurance required to ensure compliance with applicable regulations and requirements.

1.2 SCO2E This program defines criteria for the PROCESSING of the following waste streams for disposal at a land disposal facility:

(1)

Het Hastes (a)

Resins (bead)

(b)

Cartridge Filters (c)

Evaporator Concentrates (d)

Sludge (e)

Miscellaneous liquids (2)

Dry Active Wastes (DAW)

(a)

Compactible (b)

Noncompactible This program defines the requirements for major changes to Liquid, Gaseous, and Solid Radwaste Treatment Systems.

1.3 PRECAUTIONS / LIMITATIONS Except as specifically described in this document, the following general precautions and limitations apply to the PROCESSING and packaging of all radioactive wastes generated at Rancho Seco for disposal at a land disposal facility.

These precautions and limitations shall be included in appropriate station or vendor implementing procedures.

(1)

No liquid materials within the scope of this program shall be packaged for disposal.

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(2)

No package shall be loaded for shipment if it has any indication of a hole or failure.

These packages shall either be repacked, or placed in an overpack.

(3)

Radioactive waste shall not be packaged for disposal in cardboard or fiberboard boxes.

(4)

Only High Integrity Containers (HIC) approved for burial at a land disposal facility shall be utilized for packaging dewatered wastes i

when waste form stability is required per 10 CFR 61.

i (5)

No objects or materials shall be placed into HICs that may cause chemical or physical damage to the container per the vendors 10 CFR 61 Topical Report or other Federal, State or Burial Facility requirements.

(6)

As much as practical, polyethylene HICs shall be kept out of direct sunlight to prevent ultraviolet light degradation.

Protection from direct sunlight shall be provided when HICs are stored for extended periods.

(7)

Radioactive waste shall not be packaged for disposal if it is pyrophoric. Pyrophoric materials contained in radioactive waste shall be treated, prepared, and packaged to be nonflammable prior j

to disposal.

(8)

Radioactive waste in gaseous form shall not be packaged for disposal.

(9)

Radioactive waste containing hazardous material shall be treated to reduce to the maximum extent practicable the potential hazard from the nonradiological materials.

Biological, pathogenic or infectious material is not expected to be produced and will be handled on a case by case basis.

(10)

Radioactive wastes shall not be packaged for disposal if it is readily capable of detonation or of explosive decomposition or reaction at normal pressures and temperatures, or of explosive reaction with water.

(11)

Radioactive waste shall not be packaged for disposal if it contains, or is capable of generating quantities of toxic gases, vapors, or fumes harmful to persons transporting, handling or disposing of the waste.

(12) Samples shall be handled and collected in accordance with applicable Rancho Seco procedures and in keeping with ALARA principles.

(13) PROCESSING evolutions should be periodically monitored for adverse chemical reactions and temperature changes.

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l.4 RESPONSIBILITIES 1.4.1 Assistant General Manaaer. Nuclear i

It is the responsibility of the AGM, Nuclear, to ensure that i

t the reautrements contained in this manual are achieved during the PROCESSING of radioactive waste by developing appropriate administrative and implementing procedures, i

The AGM, Nuclear, is responsible for approving changes to this PROCESS CONTROL PROGRAM, as required by Technical Specification 06.13.

1.4.2 Plant Review Committee The Plant Review Committee (PRC) shall review the Topical Reports and Process Control Programs of vendors selected to provide waste processing services or products prior to their initial use at the station. Any subsequent revision to these documents shall also be reviewed by PRC prior to the initial use of the revision.

These reviews shall ensure compatibility with Station equipment and operation.

Additionally, PRC is responsible for reviewing changes to this PCP prior to implementation.

PRC also reviews station administrative and implementing procedures for radioactive i

waste processing activities.

l 1.4.3 Radiation Protection Manaaer The Radiation Protection Manager (RPM) is responsible for coordinating the review of, and for approving, vendor procedures for waste processing prior to the initial use of the documents at the station.

He shall also approve any revisions to these documents prior to initial use of the revision.

Review of vendor procedures for waste processing shall include technical review by the Operations Chemistry, and Nuclear Engineering departments.

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l SECTION 2.0 RADIOACTIVE NASTE PROCESSING REQUIREMENTS 2.1 SOLID RADIQACTIVE MASTES 2.1.1 Ooerability Criteria Radioactive wastes shall be PROCESSED in accordance with this PROCESS CONTROL PROGRAM to meet shipping and transportation requirements during transit, and disposal site requirements when received at the disposal site.

APPLICABILITY: At all times.

COMPENSATORY MEASURES:

a.

With PROCESSING not meeting disposal site and shipping and transportation requirements, suspend shipment of the inadequately processed wastes and correct this PROCESS CONTROL PROGRAM, the procedures, and/or the Weste Processing System as necessary to prevent recurrence, b.

With PROCESSING not performed in accordance with this PROCESS CONTROL PROGRAM, test the improperly PROCESSED waste in each container to ensure that it meets burial ground and shipping requirements and take appropriate administrative action to prevent recurrence.

2.1.2 I.ests/Insoections Satisfactory PROCESSING of wet radioactive wastes (e.g., filter sludges, spent resins, evaporator bottoms and boric acid solutions) shall be verified in accordance with this PROCESS CONTROL PROGRAM:

a.

If any test specimen fails to verify satisfactory PROCESSING, the PROCESSING of the batch under test shall be suspended until such time as additional testing can be performed, alternative PROCESSING parameters can be determined in accordance with this PROCESS CONTROL PROGRAM, and subsequent testing verifies satisfactory PROCESSING.

PROCESSING of the batch may then be resumed using the alternative PROCESSING parameters determined by this PROCESS CONTROL PROGRAM.

This PROCESS CONTROL PROGRAM shall be modified as required, as provided in Technical Specification D6.13, to assure satisfactory PROCESSING of subsequent batches of waste; and l

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b.

With the installed equipment incapable of meeting Operability Criteria 2.1.1, above, or declared inoperable, restore the i

equipment to OPERABLE status or provide for contract capability to process wastes as necessary to satisfy all applicable transportation and disposal requirements.

2.1.3 B1111 f

This requirement implements the requirements of 10 CFR 50.36a and General Design Criterion 60 of Appendir A to 10 CFR Part 50.

The process parameters included in establishing this PROCESS CONTROL PROGRAM may include, but are not ilmited to, waste type, waste pW, waste /11guld/ solidification agent / catalyst ratios, waste oil content, waste principal chemical constituents, mixing and curing times, or dewatering parameters.

2.2 tE1QR3tiMtGES TO LIQUJD. GASEOUS. AND SOLID RADNASTE TREATNENT SYSTQtSI Licensee-initiated major changes to the Radwaste Treatment Systems (11guld, gaseous, and solid):

a PRC approved changes shall be retained for review by the Commission.

The description for each change shall contain:

t 1)

A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; 2)

Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information; 3)

A detailed description of the equipment, components, and processes involved and the interfaces with other plant systems; 4)

An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the License application and amendments thereto; 5)

An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC outside of the RESTRICTED AREA and to the general population that differ from those previously estimated in the License application and amendments thereto:

6)

A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the change is to be made; 2-2

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An estimate of the exposure to plant operating personnel as a result of the change; and 8)

Documentation of the fact that the change was reviewed and found acceptable by the PRC.

b.

Shall become effective upon review and acceptance by the PRC.

' Licensees may choose to submit the information called for in this Requirement as part of the annual FSAR update.

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SECTION 3.0 PROGRAN DESCRIPTION 3.1 Eg g 111]lG OF WET RADIQACTIVE MASTE l

l 3.1.1 PROCESSING Methods Wet radioactive waste generated at Rancho Seco shall be i

PROCESSED into a form acceptable for disposal at a licensed facility by dewatering, drying or solidification.

PROCESSING shall be performed utilizing vendor supplied services and 3

equipment operating in accordance with vendor's Process Control Program (PCP) and procedures. Any vendor selected to provide services or products used in compliance with 10 CFR 61 stability requirements shall have a topical report addressing 10 CFR 61 requirements under review or approved by the NRC.

When a vendor is initially selected, this document shall be ravised to incorporate by reference the vendor's Topical Report and PCP. The Topical Reports and PCPs of multiple vendors may be referenced in this PCP even if all vendors are not actively providing services or products at Rancho Seco. However, if any vendor is selected whose documents are not referenced, this document shall be revised to reference them.

3.1.2 Processina Svstam Desertotion Detailed descriptions of the vendor's PROCESSING system shall be included in the vendor's Topical Report.

3.1.3 Preaualification Testina Prequalification tests shall be performed on each type of wet radioactive waste stream to demonstrate the ability of the process to produce an acceptable waste form per the requirements of 10 CFR 61.

This prequalification testing is performed by the vendor and documented in the vendor's Topical Report.

3.1.4 System Oualification Tests Prior to the initial PROCESSING of a given waste stream type using a specified process, a test shall be conducted to demonstrate the ability of the process system to produce an acceptable waste form over the range of critical parameters identified during the prequalification testing.

Bounds for critical parameters and specific operating limits shall be specified in the vendor's PCP.

These tests shall be performed on laboratory scale er full scale specimens and shall ensure that the acceptance criterla specified in Section 3.1.8 are achieved.

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i 3.1.5 Lautoment/ System Operability Reautrements l

Prior to each PROCESSING evolution, the vendor shall demonstrate operability of the processing equipment which shall include but not be limited to the following:

(1) Control Panel (2)

Instrumentation and Controls (3) Mechanical Equipment (4)

Electrical Equipment The operability test shall be performed in accordance with station procedures and the vendor's PCP and procedures.

t 3.1.6 Batch Precrocessina Samolina L

Each batch of waste offered for PROCESSING shall be sampled and analyzed, as appropriate, in accordance with station procedures l

L and the vendor's PCP and the Topical Report that addresses the 1

10 CFR 61 stability requirements.

This sampling shall:

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(1) Provide necessary data to estimate curie content and i

perform the waste classification analysis, (2)

Ensure that waste stream parameters are within the bounds for critical parameters established in the vendor's'PCP and 10 CFR 61 Topical Report.

fl01E:

Results of waste stream chemical analyses shall be reviewed by the PROCESSING vendor to ensure chemical constituents do not exist which could cause adverse chemical reactions during the dewatering process or react adversely with the waste container.

3.1.7 Testina/Insoettions To satisfy the Test / Inspection requirements of Section 2.1.2 of this Program, a test or inspection shall be performed for each PROCESSING evolution to ensure that the applicable acceptan:e criteria of Section 3.1.8 are achieved.

This is accomplished by verifying that a specified end point is achieved for each PROCESSING evolution of the actual waste stream.

If the test results fail to meet the acceptance criteria, the following steps, as per the Compensatory Measures of Section 2.1.1, shall be followed:

(1) PROCESSING of the batch under test shall be suspended untti such time as additional testing can be performed, alternative PROCESSING parameters can be determined, and i

subsequent testing verifies satisfactory PROCESSING of the 3-2

W waste.

PROCESSING of the batch may then be resumed using the alternative PROCESSING parameters if the alternative e

parameters will produce a product that falls within the vendors qualification envelope.

The vendor's PCP shall provide the method for determining the alternative PROCESSING parameters. Alternative PROCESSING parameters which fall within the vendor's qualification testing envelope shall be approved by the Radwaste Superintendent or his designet and shall be documented in accordance with the vendor's PCP.

The vendor's PCP shall be modified as required to assure adequate PROCESSING of subsequent batches of waste. Any changes should be consistent with the conditions, limitations, and restrictions addressed in the vendor's 10 CFR 61 Topical Report.

(2) If the test results failure is due to malfunction of the processing equipment or the processing equipment is i

inoperable, the equipment shall be returned to an OPERABLE condition or an alternate vendor shall be obtained to process waste as necessary to satisfy applicable transportation and disposal requirements.

3.1.8 Accentance Criteria (1) Non-Stable Waste Form l

For wastes PROCESSED in non-HICs, the acceptance criteria shall be less than or equal to one-half of one percent (0.5%) of the internal volume of the container for free standing water.

(2) Stable Waste Form Waste shall be PROCESSED in an approved HIC, and the acceptance criteria shall be less than or equal to one percent (1%) of the internal volume of the HIC for free standing water.

OR Waste shall be PROCESSED in a non-HIC using a solidification media approved by.the NRC, or submitted to the NRC that shows compliance with 10 CFR 61.

Vendor documents for the dewatering process shall include a specified end-point for each dewatering evolution which ensures that these acceptance criteria are achieved.

Vendor documents for solidification shall include a specified test to verify solidification.

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3.1.9 Corrective Actions With processing not meeting the above acceptance criteria or otherwise not meeting disposal site and shipping and transportation requirements, suspend shipment of the inadequately PROCESSED waste and correct the Process Control Program, the procedures, and/or the waste processing equipment as necessary to prevent a recurrence. Additionally, an evaluation of similar wastes PROCESSED since the last successful surveillance test shall be conducted to determine the extent of the inadequately processed waste.

If such wastes have been shipped for disposal, the disposal site operator shall be contacted and the problem addressed.

If PROCESSING is not performed in accordance with this PCP, the improperly FROCESSED waste shall be tested to ensure that it meets burial ground and shipping requirements. Appropriate corrective actions shall be taken to prevent recurrence.

Disposition of inadequately PROCESSED wastes will be handled on a case-by-case basis.

3.2 P30CESSI E OF DRY ACTIVE NASTE Dry Active Waste (DAW) generated at Rancho Seco shall be processed by segregation, sorting, and/or compaction. Processing of DAW is performed to accomplish the following functions:

(1)

Package DAW in a fashion acceptable for disposal at a licensed disposal facility.

(2)

Remove constituents not acceptable for disposal as DAW.

(3)

Minimize volumes of DAW shipped for disposal by:

(a) removing reuseable and uncontaminated items; and (b) reducing shipped volumes by compaction.

All processing of DAW at Rancho Seco shall be performed in accordance with approved station procedures or vendor procedures that have been reviewed by the Radiation Protection Manager. Vendor equipment, personnel and proceduret may be used for DAW processing and packaging.

The segregation of uncontaminated waste from DAW is performed to minimize volumes of DAW shipped for disposal.

In order to provide reasonable assurance that radioactive materials are not released as clean waste, the following requirements shall be included in the segregation program, as discussed in Reference 7.5.3:

(1)

Surveys, using equipment and techniques for detecting low levels of radioactivity, shall be made of materials that may be contaminated and that are to be disposed of as clean wastes.

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(2)

Surveys may be conducted on individual items using portable survey instruments, such as pancake GM probes.

However, in all cases, final measurements of each package (e.g., bag or box) of aggregated waste to be released as clean waste shall be performed to ensure that there has not been an accumulation of radioactive material due to the buildup of multiple quantities of contamination which were nondetectable with portable instrumentation.

Final measurements shall be performed using sensitive detectors-in a low background area, such as scintillation detectors.

3.3 MIXED NASTE Mixed Waste is defined as waste that contains constituents that satisfy the definition of radioactive waste, subject to the Atomic Energy Act, and contains hazardous waste that either (1) is listed as hazardous waste in 40 CFR 261, Subpart D, or (2) causes the waste to exhibit any of the hazardous waste characteristics identified in 40 CFR 261, Subpart C.

Under current federal law, this waste is' subject to dual regulation by the NRC and EPA where both agencies have control over the same waste. Due to the complex regulatory issues that must be resolved pertaining to mixed waste, there are currently no authorized disposal sites in the United States which are licensed to receive and dispose of mixed hazardous and radioactive waste.

Since there is currently no avenue for disposal of mixed waste, efforts shall be made to reduce the generation of such waste at Rancho Seco.

To accomplish this, station procedures for chemical control and radioactive waste processing shall include the following requirements:

(1)

The Station chemical control program shall include a method to i

identify hazardous constituents of chemicals / chemical products i

and to evaluate and authorize any usage of these products in areas where mixed waste generation is likely to occur.

This evaluation shall consider the substitution of products which are evaluated as non-hazardous per 40 CFR 261.

(2)

Radioactive waste processing procedures shall include provisions for segregation and removal of non-radioactive hazardous constituents. Upon removal, such constituents would be handled as hazardous waste as required by the EPA.

(3)

Mixed low-level radioactive waste generated at Rancho Seco shall not be shipped for disposal to a low-level radioactive waste disposal facility unless specific approval for such disposal is granted by the appropriate regulatory agencies.

Such wastes shall be stored at Rancho Seco until regulatory changes allow for disposal or they are otherwise approved for disposal by appropriate regulatory agencies.

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F SECTION 4.0 NASTE CLASSIFICATION AND CHARACTERIZATION 4.1 NASTE CLASSIFICATIQll Radioactive waste generated at Rancho Seco shall be classified as Class A B or C in accordance with the requirements of 10 CFR 61, Section 61.55, using one or more of the classification methods given in the USNRC's " Low-Level Haste Licensing Branch Technical Position on i

Radioactive Haste Classification (May 1983)".

Haste classification shall be performed in accordance with approved station procedures.

The following specific requirements shall be incorporated in the t

program for sampling and analysis for waste classification:

(1)

Annual analyses or an engineering evaluation shall be performed on representative samples of each waste stream or,

. alternatively, a process stream associated with the generation of the waste, for the nuclides listed in Table 1 and Table 2 of 10 CFR 61, Section 61.55.

(2)

The results of these analyses shall be used to develop isotopic abundances and scaling factors for difficult to measure nuclides (i.e., beta emitters and transuranics) based on, correlations between those nuclides and more easily measured gamma emitters.

(3)

Gamma spectroscopy or gross radioactivity measurements shall be made for each container of waste processed for disposal.

Calculationni methods for determining the total activity in each container shall be developed which use the results of the gamma spectroscopy or gross activity measurements, and the percent isotopic abundances and scaling factors from the annual analyses, or engineering evaluation.

(4)

The classification program shall establish criteria and include provisions for increased frequency for the sampling, analysis and evaluation required by paragraph (1), above, if the cobalt 60 to cesium 137 ratio changes by a factor of 10.

(5)

Each package of waste shall be clearly labeled as Class A, Class B, or Class C.

4.2 HASTE CHARACTERISTICS Haste PROCESSED for disposal at Rancho Seco shall meet the applicable characteristics specified in 10 CFR 61, Section 61.56 H&:te classified as Class B, Class C, or Class A waste that will not be segregated from Class B and C wastes at the burial facility shall be processed into a stable waste form.

This shall be accompiished by placement into a HIC or use of a solidification media which meets the stability requirements of 10 CFR 61.56, per Section 3.1 of this manual.

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s The vendor's topical report shall include documentation of testing which vertfles that the HIC or solidification media meets these stability requirements. Additionally, Rancho Seco shall comply with Federal-or State requirements imposed specifically on an approved HIC or solidification media which limits the type and/or radioactive concentration of the waste to be placed in the approved HIC or solidification media.

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4 SECTION 5.0

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SPECIFIC MSTE STREAN PROCESSING DESCRIPTIONS

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5.1 NET RADIOACTIVE E STE STREAMS 5.1.1 Resins Resins will be accumulated from one or more of the following systems:

l (1) Makeup and Purification System (2) Spent fuel Pool Cooling System (3) Miscellaneous Liquid Rad Haste System (4) Coolant Radwaste System (5) Condensate Polishing Demineralizer System (6) Other miscellaneous ion exchange medium as generated Spent Primary resins are collected in the Spent Resin Storage Tank (SRT).

These resins are transfttred directly to the vendors processing skid from the SRT.

If it is necessary to process secondary condensate polishinJ resins, they are transferred from the polisher to the vendor's processing skid.

Spent resins will be processed for disposal by dewatering or within an approved Solidification Media.

The curie content and waste classification of each resin batch shall be estimated prior to sluicing of the spent resin to the vendor dewatering skid.

Based on these estimates, the proper liner or HIC and cask for transportation and disposal are selected.

The resin is transferred to the liner or HIC where it is dewatered utilizing vendor supplied dewatering services per Section 3.1 of this manual. A representative sample of the resin is collected for final calculations of curie content and waste classification, unless an actual sample was collected prior to the transfer. Containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal.

A flow chart of a typical resin processing path is shown on Figure 5-1.

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4 5.1.2 Cartridge Filters Cartridge filters will be accumulated from one or more of the following systems:

j (1) Makeup and Purification System (2) Spent Fuel Pool Cooling System (3) Hiscellaneous Liquid Radwaste System (4) Coolant Radwaste System (5) Miscellaneous Spent filter cartridges are surveyed for dose rate upon iemoval from the system.

The measured dose rate is used to calculate isotopic content using a dose-to-curie conversion factor and scaling factors per Section 4.1 of this manual.

Based on the calculated isotopic content, the waste classification and the appropriate process and container for disposal are determined.

Normally filters are placed in a liner or HIC. However, filters may be dried and handled as DAW, if conditions allow.

containers are sealed, Uponcompletionoftheprocessingiate,andstoredina surveyed, and labeled, as appropr designated storage area until they are shipped for disposal.

For purposes of waste classification, isotopic concentrations of filters in a liner or HIC should be determined as calculated over the volume of the cartridge filter itself, rather than averaged over the gross volume of the container.

5.1.3 Evaoorator Concentrates Evaporator concentrates result from operation of evaporators for processing of liquid wastes (e.g., floor drains) and boron recovery. The miscellaneous waste evaporator is available to PROCESS liquid waste.

The boron recovery evaporator is used to remove boron from reactor grade water and the boric acid concentrates are normally recy: led.

If PROCESSING of evaporator concentrates is required, the liquid will be solidified or dried in accordance with a vendor approved PROCESS CONTROL PROGRAM reviewed and approved by the PRC.

A flow chart of the liquid processing path is shown on Figure 5-2.

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5.1.4 ilukt Radioactive sludge is accumulated and handled on a case-by-case basis by periodically removing the sludge from various tanks and sumps throughout the plant.

Each batch of sludge is sampled for PCP parameters and isotopic content, chemically conditioned, if necessary, and PROCESSED per Section 3.1 of this manual. Containers are sealed, surveyed, and labeled, as appropriate, and stored in a designated storage area until they are shipped for disposal.

5.1.5 Miscellaneous Liouids Miscellaneous liquids generated in the station will be collected and processed on a case-by-case basis.

Such wastes may include decontamination wastes and chemical wastes collected from the Chemistry Labs.

Batches of such waste are 1

isolated, sampled for PCP parameters and isotopic content.

l chemically conditioned, if necessary, and transferred to the vendor's processing skid where it is PROCESSED per Section 3.1 of this manual. Containers are sealed, surveyed, and labeled, J

as appropriate, and stored in a designated storage area until they are shipped for disposal.

5.2 DRY ACTIVE H&SIE j

Dry Active Haste (DAH) consists of radioactively contaminated or activated waste which contains no liquids.

DAN may be compactible, such as paper, plastic and protective clothing, or non-compactible.

such as tools or plant equipment. This waste is segregated by station workers at the point of generation into receptacles designated for

" clean" or " contaminated" trash.

" Clean" receptacles are used to collect trash that is potentially not contaminated.

" Contaminated" I

containers are used to collect waste that is known or suspected to be contaminated. However, for purposes of DAN processing, all waste 1

collected in Radiation Controlled Areas (i.e., that collected in both the " clean" and " contaminated" receptacles) is assumed to be contaminated until it is surveyed and proven clean.

Bags are collected from the receptacles, surveyed for external dose rate, and taken to a designated sorting area for processing.

Bags below a 1

spectfied dose rate level, per station procedures, may be opened and the contents surveyed individually for radioactivity.

Items found to be not contaminated per station procedures, reusable items, and items not acceptable for disposal as DAW are removed.

In general, the contents of bags above the specified dose rate level are not surveyed for contamination, but are examined for reusable items and items not acceptable for disposal as DAH. Contaminated items are then disposed of as DAH. Compactible items are collected and compressed into approved strong, tight containers. Noncompactible items are placed directly into approved strong, tight containers. Containers are sealed, surveyed, and labeled, as appropriate and stored in a designated storage area until they are shipped for disposal, A flow chart of the DAW processing path is shown on Figure 5-3.

5-3

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l SECTION 6.0 ADMINISTRATIVE CONTROLS 6.1 PROCEDURES Activities associated with the implementation of the requirements of this program shall be conducted in accordance with approved station procedures or vendor documents and procedures that have been reviewed and approved per Sections 1.4 and 3.2.

6.2 OuALITY ASSUB& KE Quality Assurance related activities for radioactive waste processing l

are implemented as described in the Rancho Seco Quality Assurance Manual.

Such activities include:

(1)

Review of documents and procedures affecting the processing, packaging, handling, and transportation of radioactive waste.

(2)

Review of procurement documents or services.

(3)

Perform inspections as designated in applicable processing, t

l packaging, and shipping procedures.

l (4)

Review applicable vendor QA programs for compliance with' Regulatory and Rancho Seco requirements.

(5)

Perform audits of the radioactive waste management program at least once per 24 months.

(HQlE:

Technical Specification Administrative Control 06.5.3.m requires that audits of the Process Control Program and implementing procedures be performed at least once per 24 months.)

(6)

Documentation and retention of documentation of waste processing, packaging and shipping activities.

These activities provide assurance that the final waste form, i

packaging, labeling, and transportation are in accordance with applicable regulations and requirements.

6.3 CHANGES TO THE PCP Changes to this PCP shall be made in accordance with Technical Specification 06.13.

Technical Specification 06.13 requires that changes to the PCP:

(1)

Shall be documented and records of reviews performed shall be retained for the duration of the Unit Operating License.

This documentation shall contain:

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(a) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the l

change (s), and l

(b) A determination that the change will maintain the overall conformance of the waste product to existing requirements

)

of Federal, State, or other applicable regulations, i

(2)

Shall become effective after review and acceptance by PRC and the approval of the AGM, Nuclear.

l 6.4 DOCUMENTATION j

Procedures for radioactive waste PROCESSING, packaging, and transportation shall include requirements for maintaining and retaining LLW processing, packaging, and transportation records.

)

Detailed records for each container of waste shall be maintained.

6.5 IRAINING

)

Rancho Seco and vendor personnel responsible for waste processing, packaging and transportation activities shall be trained and quallfled to ensure that waste PROCESSING is performed in accordance with i

l appilcable requirements.

Training programs shall establish a schedule l

l for periodic requalification of at least once every two years.

Rancho l

Seco personnel shall verify the training of vendor personnel.

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SECTION 7.0 l

REFERENCES 7.1 Code of Federal Regulations:

1 7.1.1 Title 10. Parts 20, 61, and 71 l

7.1.2 Title 49, Part 173 7.1.3 Title 40, Part 261 7.2 USNRC, Low-level Haste Licensing Branch, Technical Position on Radioactive Haste Classification, May 1983 i

7.3 USNRC, Low-Level Haste Licensing Branch, Technical Position on Haste Form. May 1983 7.4 USNRC, Guidelines for Preparation and Implementation of a Solid Haste Process Control Program (Proposed). Draft Revision 3. September 1986 7.5 USNRC, Office of Inspection and Enforcement, IE Information Notices:

i 7.5.1 IEN 79-09,

" Spill of Radioactively Contaminated Resins" l

7.5.2 IEN 83-14 "Dewatered Spent Ion Exchange Resin Susceptibility

~

to Exothermic Chemical Reaction" 7.5.3 IEN 85-92,

" Surveys of Hastes Before Disposal from Nuclear Reactor Facilities" i

7.5.4 IEN 86-20

" Low-Level Radioactive Haste Scaling Factors, 10 CFR Part 61" l

7.5.5 IEN 87-03,

" Segregation of Hazardous and Low-Level Radioactive Hastes" 7.5.6 IEN 87-07,

" Quality Control of Onsite Dewatering /

Solidification Operations By Outside Contractors" 7.5.7 IEN 88-08,

" Chemical Reactions With Radioactive Haste Solidification Agents" l

7.5.8 IEN 89-27

" Limitations on the Use of Haste Forms and High Integrity Containers for the Disposal of Low-Level Radioactive Haste" 7.6 Rancho Seco Technical Specifications, Sections D6.5.3.m and 06.13 l

7.7 Radwaste Control Manual 7.7.1 R.P.309.I.07. Haste Stream Identification and Sampling 7.7.2 R.P.309.II.01, Resin and Filter Media Dewatering using PNSI Nuclear Packaging Dewatering System 7.7.3 R.P.309.II.04 Solidification of Hater or Resin using Cement l

with PNSI Radwaste Solidification System 7.7.4 R.P.309.II.09, Segregation and Free Release of Controlled Area Haste 7-1

7.8 Rancho Seco Quality Manual 7.9 Vendor Documents 7.9.1 TP-05 Radwaste Solidification System Topical Report i-7.9.2 02-P. Nuclear Packaging, Inc. Dewatering System Topical 7.10 RSAP-0303.. Plant Modiflcation

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