The Process Control Program (PCP) for Radwaste at NuclearPower Plants

[Charles Willis <CAW@nrc.gov>]

Eric, Mark and anyone with an interest,

I intended to respond in a more timely manner, but it did not work out that
way.  Anyway, I have finally gotten to it.

As with most regulatory matters, the PCP is best understood in its
historical context, and this does go back in time.  In the early 1970s,
there were numerous problems with the processing of wet wastes at
reactors.  A GAO report specifically identified a need for greater
regulatory control over such radioactive wastes (see GAO Report
EMD-78-101, August 1978).    The Commission committed to Congress to
provide the greater regulatory control (see the letter from NRC Chairman
J. M. Hendrie to Congressman Jack Brooks, January 24, 1979).  

In view of (a) the need for explicit requirements to make the regulatory
requirements enforceable and (b) the great diversity of processes then
in use, The PCP approach was chosen as having the least impact on
licensees.  The PCP was intended to be a document (similar to the
Offsite Dose Calculation Manual, ODCM) that was more flexible than the
technical specifications but more controlled than plant procedures.

In the 1970s, a variety of solidification systems were being offered and
many licensees were solidifying their own wet wastes.  The PCP was
intended as a document that would spell out what was being done (or
what was planned) for a specific facility.  It was to be in sufficient detail
to permit regulatory review and provide a framework for licensee
personnel to learn about their system.  (Yes, a number of problems
evidently were the result of personnel not understanding the
characteristics of their systems.)

The PCP requirement was established as a part of the "Radiological
Effluent Technical specifications" (RETS) program and essentially all the
nuclear power plant licensees had PCPs in place by the mid-1980s.  As
the industry matured, emphasis shifted to other issues and many of the
specifics of the RETS were shifted from the technical specifications to
the ODCM although the definition of, and requirement for, the PCP were
retained in the technical specifications (see Meinke and Essig,
NUREG-1301 and -1302, April 1991).  

There has been an effort to keep interested people informed about the
PCP.  Initially, there was extensive interaction between the NRC staff
and committees of the "Atomic Industrial Forum."  The last thing we have
published on the PCP was in the proceedings of the Health Physics
Society's 1994 Midyear Symposium (see paper by Willis and
Chandrasekaran in "Managing Radioactive and Mixed Wastes," John
Matuszek, Ed.).

Charlie Willis
caw@nrc.gov