ATTACHMENT9

Unit 1 Unit 2 X Reporting Period Janus - June 1992

SUMMARYOF INOPERABLE MONITORS

Monitor Dates of Inoperability Cause and Corrective Actions

1. Vent Noble Gas Monitor 6/19/92 to 7/29/92 Tho cord used to supply power fromthe pro-amplifier to tho amplifier wasmade from wire with an incorrectgauge causing loss of power to thepro-amp. This affected the FieldEffect Transistor causing becameinoperability. This is being tracked bya DER 2-92-2792.

Corrective Actions included:(1) 12-hour sampling analysis of grabsamples, and l2) replacement,recalibration, and restoration of thosystem's noble gas detector.

2. Stack GEMS 4/21/92 to 5/21/92 During a routine channel functionaltest, it was determined that tho 1ststage dilution pump flow controllerwas inoporablo. Since this dilution isrequired for high range monitoring,tho monitor was declared inoperable.

To comply with TechnicalSpocifications for gaseous offluonts,12-hour grab samples were analyzedfor noble gases and flow rate wasestimated every 4 hours. Iodine andparticulates were analyzed from a

cartridge on tho auxiliary samplingstation. The flow rate monitoringinstrument was repaired off sits. Amodification request to improveinstrument reliability has beensubmitted.

002753LL'zr20'zr0'zr0075 920827PDR ADOCN 050004|0'DR

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NIAGARA MOHAWK POWER CORPORATION

NINE MILE POINT NUCLEAR STATION

GENERATION ADMINISTRATIVE PROCEDURE

GAP-RMP-02

REVISION 00

UNIT 2 RAOWASTE PROCESS CONTROL PROGRAM

TECHNICAL SPECIFICATION

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Approved By:M. J. McCormick, Jr. P1an nit 2 Date

THIS PROCEDURES SUPERSEDES AP-3.7.1

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PERIODIC REVIEW DUE DATE: JUNE 1994

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Coversheet .

LIST OF EFFECTIVE PAGES

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SECTION

TABLE OF CONTENTS

PAG

1.0 PURPOSE

2.0 PRIMARY RESPONSIBILITIES .

3.0 PROCEDURE

3. 1 System Description .

3.2 Radioactive Waste Dewatering System (RDS 1000)

3.3 Disposition of other Radioactive Haterial

3.4 Sampling . .

3.5 Waste Classification .

3.6 Administrative Controls

4. 0 DEFINITIONS

5.0 REFERENCES AND COMMITMENTS .

6.0 RECORD REVIEW AND DISPOSITION

ATTACHMENT 1: UNIT 2 RADWASTE PROCESS CONTROL PROGRAMIMPLEMENTING PROCEDURES

ATTACHMENT 2: SOLID WASTE SOURCES

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Page ii GAP-RMP-02Rev 00

1.0 PURPOSE

1.0. 1- -To describe the methods for processing, packaging andtransportation of low-level radioactive waste and provideassurance of complete stabilization of various radioactive "wetwastes" in accordance with applicable NRC regulations andguidelines.

1.0.2 To satisfy the Nuclear Regulatory Commission's Low-Level Wasteand Uranium Recovery Projects Branch (WMLU) requirement andestablish process parameters within which the Chem-Nuclear RapidDewatering System (RDS-1000) must be operated to meet currentdisposal criteria at low-level waste disposal facilities.NOTE: Conformance with WMLU requirements provides assurance

that the requirements identified in 10CFR61, Sub Part D,Technical Requirements for Land Disposal Facilities andFinal Waste Classification,

This procedure applies to the Unit 2 Radwaste Process Control Programfor Dewatering and transportation of radioactive waste.

2.0 PRIMARY RESPONSIBILITIES

2. 1 The Plant Mana er is responsible for:

2. 1. 1 Ensuring the Unit 2 Radwaste Process Control Program providesfor the health and safety of the general public as it applies toRadwaste Management.

2. 1.2 Reviewing and approving changes to the Unit 2 Radwaste ProcessControl Program in accordance with Unit 2 TechnicalSpecification, Section 6.5.2. 11, Review and Audit, TechnicalReview and Control Activities.

2.2

2.3

The Mana er 0 erations is responsible for the content and maintenance ofthis procedure.

The General Su ervisor Radwaste is responsible for overallimplementation of the Radwaste Process Control Program.

Page 1 GAP-RHP-02Rev 00

3. 1.4 Waste Slud e Tank

-a. The waste sludge tank is supplied with waste from thefollowing sources:

1. Radwaste filters,2. The floor drain filter,3. The spent resin tank, and

4. The Advanced Liquid Processing System (ALPS).

b. The waste sludge tank has the ability for decantation. Adecant pump takes a suction off the sludge tank anddischarges to the spent resin tank.

c. Contents of the waste sludge tank are fed by one of tworedundant waste sludge pumps, to the Radwaste Truckbay fordewatering by the RDS 1000 or cement solidification by anapproved vendor.

3.1.5

3.1.6

Ventilation S stemI

The Radwaste Building Ventilation System (HVW) providesfiltered, conditioned outside air to various areas of theRadwaste Building and exhaust the air to the atmosphere throughthe Reactor Building Vent. The HVW system maintains the buildingat a pressure below atmospheric to help prevent any unmonitoredair leakage to the environment.

e

Liners

a. The RDS-1000 system is compatible with Chem-Nuclear SystemIncorporated (CNSI) dewatering waste containers.

b. These containers and their dewatering internals are designedto ensure uniform dewatering of waste slurries. They arefabricated and inspected in accordance with CNSI gualityAssurance Program.

c. Waste classification requirements will enter into selectionof liner type.

3.1.7 Crane

a. All liners movements are completed using a radiocontrolled/operated crane.

b. Liners are moved if required by crane to the RadwasteBuilding storage area using a ceiling grid coordinatedsystem for placement of the liner.

'age 3 GAP-RHP-02Rev 00

3.2.1 (Cont)

f. The type of media which can be dewatered by the RDS-1000 isdivided into two categories:

1. Granular media which includes bead resin, charcoal, andzeolites

2. Filter precoat media which includes ecodex, powdex,ecosorb, ecocoat, and diatomateous earth.

3.2.2

g. All discharge air is passed through HEPA filtration unitscontained within the RDS-1000 Skid before passing toperminate plant vent.

Acce tance Criteria

3.2.3

Acceptance Criteria for process completion is established by aminimum dewatering time and a maximum water collection rate. Theresultant waste form meets the requirements of 10 CFR 61"Licensing Requirements for Land Disposal of Radioactive Waste"and NRC Branch Technical Position on Waste Form(May, 1983 Rev 0).

a. Bead Resin

1. The dewatering pump has run for one hour after the finalwaste transfer.

2. The RDS-1000 has been run for a minimum of four hours.

3. The moisture separator sight glass does not increasemore than 1/2 inch during a thirty minute period.

b. Precoat Hedia

1. The dewatering pump has run, after the final wastetransfer for a minimum of one hour and dewatering pumpsuction is equal to or less than 16" of mercury with alllateral suction valves opened

2. The RDS-1000 has been run for a minimum of eleven hours.

3. The moisture separator sight glass does not increasemore than 1 inch during a thirty minute period.

la t Connection ta d

The plant connection stand, consists of the following:

a. A remotely operated waste inlet valve to control influent tothe processing liner. This valve is interlocked to close onHigh Level, High High Level (mechanical float insidefillhead), and decreasing air pressure or loss of electricalpower.

'Page 5 GAP-RHP-02Rev 00

3.2.8 Radwaste 0 erators

-Radwaste Operators shall ensure proper equipment is availablebefore beginning radwaste processing. Radwaste Operators mayprocess wastes when the following equipment is operable:

a. Closed circuit television system stations

b. Radwaste Building Ventilation

c. Radwaste Building Floor Drain System

d. Radwaste Building CNS System

e. Service Air System

3.2.9 Vendor 0 erators

All operations of RDS-1000 shall be performed by techniciansthat have successfully completed the CNSI technicians trainingprogram. Initial indoctrination training includes approximately30 days of general knowledge examinations, health physicsinstructions, and equipment operation. The operator shall havepractical experience, certification on the RDS-1000 system andis subjected to bi-annual recertification. Each phase of thetraining is monitored by the use of qualification cards,, on the'job training reports, written tests and certificates ofcompletion.

Chem-Nuclear's Quality Assurance Program, CNSI Procedure, QA-AD-001, shall be employed to control the design, fabrication,inspection, testing, operation, and record keeping for the RDS-1000,

3.2.11 Records

CNSI maintains records of the design, fabrication and testing ofeach RDS-1000 system. The setup and operation of the system ismaintained in accordance with CNSI Procedures, FO-OP-032, Setupand Operating Procedure for RDS-1000 unit and FO-OP-035, Setupand Operating Procedure for Dewatering Precoat Media in a 21-300Liner Using the RDS-1000.

Page 7 GAP-RHP-02Rev 00

3.3.2 Tem orar Radwaste Processin

The General Supervisor Radwaste shall ensure:

a.

b.

c ~

d.

The vendor is NRC approved and has demonstrated a commitmentto 10CFR61, Sub Part D, Technical Requirements for LandDisposal Facilities and Final Waste Classification and WasteForm Technical Position Papers stability requirements.

The vendor has completed Class 8 and C waste testing or hasprovided a schedule of completion.

The vendor has an approved procedure to process Class Awaste (Dewatering, Solidification).

Vendor procedures are acceptable as follows:

1. Vendor procedures are reviewed and approved inaccordance with NIP-PRO-03, Preparation and Review ofTechnical

Procedures'.

A production sample level process control procedure isimplemented.

3. The vendor is provided samples in accordance withN2-0P-41, Solid Radwaste, and N2-CSP-14, Solid RadwasteChemical Surveillance at Unit 2.

3.3.3 Dry Active Waste (DAW)

The

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General Supervisor Radwaste shall ensure:

The proper and safe steps are performed to collect andprepare low specific activity (LSA) DAW in accordance withN2-WHP-12, Solid Dry Waste Collection and Compaction.

Items most directly influencing the quality of the endproduct are identified and controlled in accordance withN2-WHP-11, Solid Dry Waste Process Control Procedure .

DAW is examined for liquids or items that would compromisethe integrity of the package or violate the burial sitelicense and/or criteria before compacting is removed orseparated.

DAW is shipped in containers meeting the transportrequirements of 49CFR173.425, Transport Requirements for LowSpecific Activity (LSA) Radioactive Materials.

Waste precluded from disposal in LSA boxes or drums due toradiation limits is disposed of in liners in accordance withN2-WHP-4, Waste Transfer Procedure.

DAW shipped off-site for vendor processing meets49CFR173.425, Transport Requirements for LSA, and anyadditional vendor requirements, if specified.

Page 9 GAP-RNP-02Rev 00

3.5 (Cont)

d. The Manager Chemistry and Manager Radiation Protection shall ensureclassification of waste is performed in accordance with S-RPIP-7.3,Determination of Shipment Type.

3.6 dministrative Controls

The Manager, Nuclear gA, Operations has the authority to stopwork when significant conditions adverse to quality exist andrequire corrective action.

guality Assurance (gA) procedures and the Nuclear gA Programrequire:

a. Ongoing review, monitoring, and auditfunctions'.

Performance of audits, under the cognizance of the SRAB, ofthe Process Control Program and implementing procedures forprocessing and packaging of radioactive waste at least onceevery 24 months as required by Unit 2 TechnicalSpecification 6.5.3.8.i, Review and Audit, Safety Review andAudit Board.

c. Compliance with the waste classification andcharacterization requirements of 10CFR61.55, WasteClassification and 10CFR61.56, Waste Characteristics.

d. guality Assurance Inspectors performing radwaste inspectionshave documented training in Department of Transportation andNRC radwaste regulatory requirements.

e. guality Assurance review of vendor programs to ensurecompliance with 10CFR71, Packaging and Transportation ofRadioactive Materials, guality Assurance requirements.

3.6.2 Training Procedures and Training Programs require:

a. Radwaste Operator qualification by completion of theRadwaste Operations Unit 2 Plant Training Program with:

1. An average grade of 80 percent or above.

2. On-the-job training in conjunction with classroominstruction to ensure each radwaste operator maintainsan acceptable level of skill and familiarity associatedwith radwaste controls and operational procedures.

3. Training in accordance with NTP-13, Training andContinued Training of Radwaste Operators.

Page 11 GAP-RMP-02Rev 00

3.6.2.e (Cont)

2. Successful completion of the accelerated trainingprogram is evaluated by a written and/or oralexamination as directed by the General SupervisorRadwaste.

EMOTE: The Requalification Training Program covers afundamental review of system modifications,revisions or changes to procedures, and changesor experiences in the nuclear industry.

f. Training records to:

1. Be maintained for audit and inspection purposes.

2. Be considered permanent records.

3. Meet the applicable requirements of gATR-I, gualityAssurance Program Topical Report for Nine Mile PointNuclear Station Operations, Section 17.0, gualityAssurance Records, NIP-TIIS-OI, gualification andCertification, and NIP-RMG-01, Identification,Maintenance, Storage and Transfer of Nuclear DivisionRecords

3.6.3 Documentation Control and Record Retention

a. Station management shall evaluate gA program audits of wasteclassification records to sat.isfy the requirements of10CFR20.311.d.3, Transfer for Disposal and Hanifests.

b. Personnel shall forward changes affecting operatingprocedures to Nuclear-gA for review in parallel with theNMPC Operations review as required.

c. Site Records Management shall maintain waste managementrecords in accordance with the appropriate administrativeprocedures.

3.6.4 Licensee-initiated changes to the Unit 2 Radwaste ProcessControl Program:

a. Are submitted to the Commission in the SemiannualRadioactive Effluent Release Report for the period in whichthe change(s) was made, and contain the information requiredby Technical Specification 6. 13, Process Control Program.

b. Become effective upon review and acceptance by the SORC.

Page 13 GAP-RMP-02Rev 00

5.0 REFERENCES AND COMMITMENTS

5. 1 Licensee Documentation

5. 1. 1 gATR-I, guality Assurance Program Topical Report for Nine MilePoint Nuclear Station Operations, Section 17.0, gualityAssurance Records

5. 1.2 Unit 2 Technical Specifications:

a. Section 3. 11.3-Action a, Solid Radioactive Wastes

b. Section 3. 11.3-Action b, Solid Radioactive Wastes

c. Section 4. 11.3.a, Solid Radioactive Wastes

d. Section 4. 11.3.b, Solid Radioactive Wastes

e. Section 6.5.2. 11, Review and Audit, Technical Review andControl Activities

f. Section 6.5.3.8.i, Review and Audit, Safety Review and AuditBoard

g. Section 6.9. 1.8, Semi-Annual Radioactive Effluent ReleaseReport

h. Section 6. 13, Process Control Program

5.2 Standards Re ulations and Codes

5.2.1 ANSI/ANS 55. 1, 1979, American National Standard for SolidRadioactive Waste Processing System for Light Water CooledReactor Plants

5.2. 2 10CFR20.311, Transfer for Disposal and Manifest

5.2.3 10CFR20.311.d.3, Transfer for Disposal and Manifest

5.2.4 10CFR61, Sub Part D, Technical Requirements for Land DisposalFacilities and Final Waste Classification and Waste FormTechnical Position Papers

5.2.5 10CFR61.55, Waste Classification

5.2.6 10CFR61.56, Waste Characteristics

5.2.7 10CFR71, Packaging and Transportation of Radioactive Material

5.2.8

5.2.9

49CFR173. 1.b, Transportation

49CFR173.425, Transport Requirements for Low Specific Activity(LSA) Radioactive Materials

'Page 15 GAP-RMP-02Rev 00

0

5.3. 16 N2-WHP-2, Paperwork for a Radioactive Waste Shipment

5.3. 17 N2-WHP-3, Cask/Van/Flatbed/Seavan Arrival Procedure

5.3. 18 N2-WHP-4, Waste Transfer Procedure

5.2. 19 N2-WHP-6, Cask/Van/Flatbed/Seavan Loading Procedure

5.2.20 N2-WHP-7, Cask/Van/Flatbed/Seavan Departure

5.3.21 N2-WHP-9A, Cement Solidification Procedure

5,3.22 N2-WHP-98, Process Control LN Cement Solidification

5.3.23 N2-WHP-11, Solid Dry Waste Process Control Procedure

5.3.24 N2-WHP-12, Solid Dry Waste Collection and Compaction

5.3.25 N2-WHP-14, Solidified Liner Inspection Procedure ~ram5.3.26 N2-WHP-15, Portable Waste Processing

5.3.27 N2-WHP-16, Radwaste Water and Solids Inventory Logs

5.3.28 N2-WHP-17, RDS-1000 Process Control Procedure

5.3.29 N2-WHP-18, ROS-1000 Dewatering Procedure

5.3.30 NTP-13, Training and Continued Training of Radwaste Operators

5.3".31 NTP-TgS-201, Training for Chemistry Technicians, RadiationProtection Technicians, and Radwaste Operators

5.3.32 S-RPIP-7. 1, Movement and Storage of Radioactive Material on Site

5.3.33 S-RPIP-7.2, Receipt of Radioactive Material

5.3.34 S-RPIP-7.3, Determination of Shipment Type

5.3.35 S-RPIP-7.4,

5.3.36 S-RPIP-7.5,

Cask Shipments

Van and Flatbed Shipments

5.3.37 S-RPIP-7.6, Activated Materials Shipments

5.3.38 S-RPIP-7.7,

5.3.39 S-RPIP-7.8,

Non-Waste Radioactive Shipments

Shipping Documents

.Page 17 GAP-RMP-02Rev 00

0

UNil L NAUSEA~)t rKUl.the vvoit(VL rxuuknnIMPLEMENTING PROCEDURES

(Sheet 1 of 2)

Waste Handlin Procedures WHPs

N2-WHP-1 Required Documents Concerning Packaging and Shipping ofRadioactive Wastes

N2-WHP-2 Paperwork for a Radioactive Waste Shipment

N2-WHP-3 Cask/Van/Flatbed/Seavan Arrival Procedure

N2-WHP-4 Waste Transfer Procedure

N2-WHP-6 Cask/Van/Flatbed/Seavan Loading Procedure

N2-WHP-7 Cask/Van/Flatbed/Seavan Departure

N2-WHP-9A Cement Solidification Procedure

N2-WHP-9B Process Control LN Cement SolidificationN2-WHP-11 Solid Dry Waste Process Control Procedure

N2-WHP-12 Solid Ory Waste Collection and Compaction

N2-WHP-14 Solidified Liner Inspection Procedure

N2-WHP-15 Portable Waste Processin9

N2-WHP-16 Radwaste Water and Solids Inventory Logs

N2-WHP-17 RDS 1000 Process Control Procedure

N2-WHP-18 ROS 1000 Dewatering Procedure

Radiation Protection Procedures S-RPIPs

S-RPIP-7. 1 Movement and Storage of Radioactive Material on Site

S-RPIP-7.2 Receipt of Radioactive Material

S-RPIP-7.3 Determination of Shipment Type

S-RPIP-7.4 Cask Shipments

S-RPIP-7.5 Van and Flatbed Shipments

S-RPIP-7.6 Activated Materials Shipments

Page 19 GAP-RMP-02Rev 00

ATTACHNENT 2SOLID WASTE SOURCES

(Sheet 1 of 3)

1.0 RADWASTE FILTERS

1. 1 Mechanical radwaste filters filter resin and crud (backwash material)from the waste collector sub-system.

1.2 When a filter reaches a pre-determined differential pressure, the filterbackwashes the material into the backwash tank, which is then pumped tothe spent resin tank.

2. 0 RADWASTE DENINERALIZERS

2.1 The radwaste demineralizers are used as an ionic exchange media forprocessing high quality water from the waste collector tanks.

2,2 When determined the resin can NO longer be regenerated, the depletedresin is pumped to the spent resin tank.

3. 0 CONDENSATE DEMINERALIZER

3. 1 The condensate demineralizers remove soluble and insoluble impurities'from the condensate water to maintain reactor feedwater purity.

3.2 After it is determined these resins can NO longer be regenerated, thedepleted resins are pumped to the spent resin tank.

4.0 FLOOR DRAIN FILTER

4. 1 The floor drain filter contributes to solid waste because the filteruses diatomaceous earth to process liquid waste of low quality. Input tothe filter is from the floor drain system and the regeneration wastetank.

4.2 When the filter reaches a pre-determined pressure drop the filterbackwashes to the waste sludge tank for processing.

5.0 SPENT FUEL PHASE SEPARATOR

These tanks receive the exhausted powdered filter media (resins) fromthe fuel pool cleanup system which is subsequently pumped to the spentresin tank or directly to a liner in the Radwaste Truckbay forprocessing.

Page 21 GAP-RHP-02Rev 00

, ATTACHMENT 2 (Cont)SOLID WASTE SOURCES

(Sheet 3 of 3)

11.0 REGENERANT EVAPORATOR

11. 1 The regenerant waste evaporator receives regeneration solutions from thecondensate demineralizer system, the radwaste demineralizer resinregeneration system, and the radwaste regeneration sump. It can alsoprocess waste from the Floor Drain Collector System and the WasteDischarge Tanks.

11.2 The regenerant waste evaporator is designed to concentrate to a 25N byweight solid concentration of sodium sulfate.

11.3 The concentrates are then discharged to the evaporator bottoms tank fortransfer to the Radwaste Truckbay for vendor processing.

12.0 SPENT RESIN STORAGE TANK

12.1 Exhausted resin from the condensate demineralizer, the radwastedemineralizer, RWCU phase separator, the spent fuel pool phaseseparator, and the radwaste filter backwash tanks are sluiced to thespent resin storage tank.

12.2 The waste from the spent resin storage tank is pumped to the wastesludge tank for processing by the RDS 1000 in the Radwaste Truckbay.

13.0 ADVANCED LI UIO PROCESSING SYSTEM ALPS

13. 1 ALPS is a series of pressure vessels containing charcoal and resin usedto process low quality waste water from the floor drain collector systemand the regeneration waste tanks. If desired, waste from the wastedischarge tanks may also be processed by ALPS.

13.2 Exhausted resin and charcoal (from ALPS demineralizers and charcoalvessels) are sluiced to the filter sludge tank for storage or pumped tothe spent resin tank for storage.

13.3 Waste from the filter sludge tank is pumped to the Radwaste Truckbay forvendor processing using the RDS 1000

'age

23 GAP-RMP-02Rev 00