Using Process Knowledge to Manage Disposal Classification of Ion-Exchange Resin - 13566
It has been previously shown by EPRI [1] that Class B and C resins represent a small portion by volume of the overall generation of radioactively contaminated resins. In fact, if all of the resins were taken together the overall classification would meet Class A disposal requirements. Lowering the classification of the ion exchange resins as they are presented for disposal provides a path for minimizing the amount of waste stored. Currently there are commercial options for blending wastes from various generators for Class A disposal in development. The NRC may have by this time introduced changes and clarifications to the Branch Technical Position (BTP) on Concentration Averaging and Encapsulation [2] that may ultimately add more flexibility to what can be done at the plant level. The BTP has always maintained that mixtures of resins that are combined for ALARA purposes or operational efficiency can be classified on the basis of the mixture. This is a point often misinterpreted and misapplied. This paper will address options that can be exercised by the generator that can limit B and C waste generation by more rigorous tracking of generation and taking advantage of the normal mix of wastes. This can be achieved through the monitoring of reactor coolant chemistry data and coupled with our knowledge of radionuclide production mechanisms. This knowledge can be used to determine the overall accumulation of activity in ion-exchange resins and provides a 'real-time' waste classification determination of the resin and thereby provide a mechanism to reduce the production of waste that exceeds class A limits. It should be noted that this alternative approach, although rarely used in a nuclear power plant setting, is acknowledged in the original BTP on classification [3] as a viable option for determining radionuclide inventories for classification of waste. Also included is a discussion of an examination performed at the Byron plant to estimate radionuclide content in the final waste stream from upstream sampling of reactor coolant and fuel pool water. (authors)