NRC Generic Letter 1991-02
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555 FC 2 8 1990
TO: ALL OPERATORS OF LOW-LEVEL RADIOACTIVE WASTE (LLW) DISPOSAL SITES,
WASTE PROCESSORS, AND ALL HOLDERS OF LICENSES FOR
NUCLEAR FUELS, NUCLEAR MATERIALS AND NUCLEAR POWER REACTORS
SUBJECT: REPORTING MISHAPS INVOLVING LLW FORMS PREPARED FOR DISPOSAL
(GENERIC LETTER 91-02)
Purpose
For the reasons presented below, the Nuclear Regulatory Commission (NRC) has decided to rely on voluntary submittal of informational reports by both waste form generators and processors regarding mishaps to LL forms prepared for disposal. This Generic Letter is intended to encourage this action on such mishaps. Licensees are also reminded of their obligation to report defects and deviations in accordance with NRC requirements in 10 CFR Part 21.
Discussion:
Background -
NRC has incomplete information on mishaps to LLW forms prepared for disposal.
Four incidents have been reported in which pressurization resulted from chemical reactions in LLW shipping containers storing dewatered synthetic organic materials, such as resins (NRC Information Notices 83-14, "Dewatered Spent Ion Exchange Resin Susceptibility to Exothermic Chemical Reaction," March
21, 1983; 84-72, "Clarification of Conditions for Waste Shipments Subject to Hydrogen Gas Generation," September 10, 1984; 90-50, "Minimization of Methane Gas in Plant Systems and Radwaste Shipping Containers," August 8, 1990).
Another incident was reported in which, during solidification of the waste, a violent reaction occurred between a chemical detergent and a vendor's waste solidification agent (NRC Information Notice 88-08, 'Chemical Reactions with Radioactive Waste Solidification Agents," March 14, 1988). This reaction resulted in boiling of the mixture so-that it overflowed the liner, then hardened, and had to be chipped away. Other problems have been encountered in the use of cement to solidify and stabilize bead resin wastes. Thus, there have been multiple incidents in which cement-solidified bead resin wastes have either not solidified properly or have disintegrated over a period of time after solidification. Although mishaps such as these generally have been made known to regulatory authorities, mainly through indirect and informal means, there is presently no established method to encourage the reporting of such events and the providing of adequate information on them.
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All three currently-sited Agreement States (Nevada, South Carolina, and Washington) have established requirements in the State licenses for the reporting of waste form and container deficiencies identified by the site operators in wastes shipped to the sites for disposal. In addition, all three facilities have on-site State inspectors who inspect the condition of shipments received by the disposal-facility operators. This information is provided to NRC as part of the NRC/Agreement State exchange of information program. The staff further notes, however, that neither the Agreement States nor NRC have specific regulatory requirements that apply to all licensees for reporting of waste form or container deficiencies. Therefore, the States do report what they find, but they may not find some of these problems, because they have no requirement to look for all such events at their disposal facilities, and they do not presently have the means to be informed routinely of mishaps that occur at NRC-licensed facilities.
Existing reporting requirements contained in 10 CFR 20.403, 50.72, 50.73 and
61.80 do not require reporting of waste form mishap information. The reporting requirement in 10 CFR Part 21 is associated with safety-significant defects or noncompliances, and may not be interpreted by some to cover mishap information.
Classes of Needed Information -
The staff has identified three classes of useful information that interest NRC and could be reported. These three include:
1. The failure of high-integrity containers used to ensure a stable waste form. Container failure can be evidenced by changed container dimensions, cracking, or damage resulting from mishandling (e.g., dropping or impacting against another object).
2. The misuse of high-integrity containers, evidenced by a quantity of free liquid greater than 1 percent of container volume, or by an excessive void space within the container. Such misuse is prohibited by 10 CFR 61.56.
3. The production of a solidified Class B or C waste form that has any of the following characteristics:
- Contains free liquid in quantities exceeding 0.5 percent of the volume of the waste.
- Contains waste with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the regulatory agency, which could lead to errors in assessment of waste class.
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- Contains a significantly different waste loading than that used in qualification testing accepted by the regulatory agency.
- Contains chemical ingredients not present in qualification testing accepted by the regulatory agency, and those quantities are sufficient to unacceptably degrade the waste product.
- Shows instability evidenced by crumbling, cracking, spalling, voids, softening, disintegration, nonhomogeneity, or dimensional changes.
- Evidence of processing phenomena that exceed the limiting processing conditions identified in applicable topical reports on process control plans, e.g., foaming, temperature extremes, premature or slow hardening, and production of volatile material.
Bases for Needed Information -
The voluntary reporting of the three classes of information outlined above would allow the staff access to information on field experiences with LLW forms and to determine when modifications to test criteria are necessary. 10 CFR
rart 61 establishes certain "minimum"(61.56(a)) and "stability" (61.56(b))
requirements for LLW, whereas Part 20 (Section 20.311) requires waste generators and processors to certify that the waste satisfied the requirements of Part 61. The Nuclear Material Safety and Safeguards (NMSS) staff reviews topical reports and other documents provided by vendors and licensees to ensure that the waste-form requirements of Part 61 will be met and to provide a vehicle with which the certification requirements of Part 20 can be satisfied (by reference). In a parallel effort, the Office of Nuclear Reactor Regulation (NRR) staff reviews information on waste-processing equipment and procedures to ensure that 10 CFR Part 50, App. A, "General Design Criteria for Nuclear Power Plants," is satisfied. The NRC staff findings of acceptability and adequacy of process-control provisions affecting the characteristics of the waste-form produced may require modification, if subsequent experience in the field reveals that the bases for the approvals are being exceeded or are no longer relevant. Therefore, to make informed decisions on regulatory action, to inform licensees of events that may have generic implications, and to make inspectors aware of the reported information, the staff needs to have quantitative information on the nature and frequency of occurrence of mishaps regarding waste form and packaging for disposal.
It is suggested that the voluntary submittal of information regarding waste-form mishaps be reported within 30 days of the incident to NRC's Director of the Division of Low-Level Waste Management a-id Decoiraissioning and to the designated State disposal-site regulatory authority.
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This request is covered by Office of Management and Budget Clearance Number:
3150-0156, which expires November 30, 1993. The estimated average burden is approximately 8 person-hours per licensee response, including visual observation of the waste form mishap, drafting a description of the observation, and preparing a final mishap report for submittal to NRC.
Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of the Management and Budget, Room 3208, New Executive Office Building, Washington, D.C. 20503, and the U.S. Nuclear Regulatory Commission, Information and Records Management Branch, Office of Information Resources Management, Washington, D.C. 20555.
If you have any questions about this letter, please direct them to the technical contact listed below or to the appropriate regional office.
Sincerely, Richard L. Bangart, Directd'
Division of Low-Level Waste Management and Decommissioning, NMSS
Technical Contact:
Michael Tokar, NMSS
(301) 492-0590
Enclosure:
List of Recently Issued Generic Letters
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LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of Letter No. Subject Issuance Issued To
91-01 REMOVAL OF THE SCHEDULE FOR 01/04/91 ALL HOLDERS OF OLs THE WITHDRAWAL OF REACTOR OR CPs FOR NUCLEAR
VESSEL MATERIAL SPECIMENS POWER PLANTS
FROM TECHNICAL SPECIFICATIONS
90-09 ALTERNATIVE REQUIREMENTS FOR 12/11/90 ALL LIGHT-WATER
SNUBBER VISUAL INSPECTION REACTOR LICENSEES
INTERVALS AND CORRECTIVE AND APPLICANTS
ACTIONS
89-10 CONSIDERATION OF THE RESULTS 10/25/90 ALL LICENSEES OF
SUPP. 3 OF NRC-SPONSORED TESTS OF OPERATING NUCLEAR
MOTOR-OPERATED VALVES POWER PLANTS AND
HOLDERS OF CONSTRUC-
TION PERMITS FOR
NUCLEAR POWER PLANTS
90-08 SIMULATION FACILITY 08/10/90 ALL HOLDERS OF
EXEMPTIONS OPERATING LICENSES
OR CONSTRUCTION
PERMITS FOR NUCLEAR
POWER REACTORS
90-07 OPERATOR LICENSING NATIONAL 08/10/90 ALL POWER REACTOR
EXAMINATION SCHEDULE LICENSEES AND
APPLICANTS FOR AN
OPERATING LICENSE
89-10 AVAILABILITY OF PROGRAM 08/03/90 ALL LICENSEES OF
SUPP. 2 DESCRIPTIONS OPERATING NPPs AND
HOLDERS OF CPs FOR
88-20 COMPLETION OF CONTAINMENT 07/06/90 ALL LICENSEES HOLD-
SUPP. 3 PERFORMANCE IMPROVEMENT ING OLs AND CPs PROGRAM AND FORWARDING OF FOR NPP FACILITIES
INSIGHTS FOR USE IN THE EXCEPT LICENSEES
INDIVIDUAL PLANT EXAMINA- FOR BWRs WITH MARK I
TION FOR SEVERE ACCIDENT CONTAINMENTS
VULNERABILITIES
90-06 RESOLUTION OF GI 70, "POWER- 06/28/90 ALL PRESSURIZED
OPERATED RELIEF VALVE AND WATER REACTOR
BLOCK VALVE RELIABILITY," LICENSEES AND
AND GI 94, "ADDITIONAL LOW- CONSTRUCTION
TEMPERATURE OVERPRESSURE PERMIT HOLDERS
PROTECTION FOR LIGHT-WATER
REACTORS," PURSUANT TO
1OCFR50.54(f)
This request is covered by Office of Management and Budget Clearance Number:
3150-0156, which expires November 30, 1993. The estimated average burden is approximately 8 person-hours per licensee response, including visual observation of the waste form mishap, drafting a description of the observation, and preparing a final mishap report for submittal to NRC.
Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of the Management and Budget, Room 3208, New Executive Office Building, Washington, D.C. 20503, and the U.S. Nuclear Regulatory Commission, Information and Records Management Branch, Office of Information Resources Management, Washington, D.C. 20555.
If you have any questions about this letter, please direct them to the technical contact listed below or to the appropriate regional office.
Sincerely, ONGI'IA1 SiG
Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NMSS
Technical Contract: Michael Tokar, NMSS
(301) 492-0590
Enclosure:
List of Recently Issued Generic Letters EDO #90-229 (EDO WITS NO. 9000 LLWM r/f Distribution: Cent ral File# NMSS r/f EWick Mraus RECu nningham CERossi MTokar JSurmeier JGreeves RBan cart PLohaus R.O'Connell DMorris ,EDO
CJenkins LLWD t/f LLUR r/f EDO r/f PDR YES NO _ Category: Proprietary _ or u- unly ACNW YES NO
ABSTRACT SUBRRCT: REPORTING MISHAPS INVOLVING LLW FORMS PREPARED FOR
DISPOSAL (GENERIC LETTER 91-02)
- SEE PREVIOUS CONCURRENCE
OFC :LLWM* :TEDITOR* :IMNS* :LLWM* :LLWM* :LLWD* :LLWD*
____________________________________________________________________________________
NAME:EWick* :EKraus* :RCunningham*:MTokar :JSurmeier :JGreeves :RBangart
____________________________________________________________________________________
DATE:10/19/90 :10/22/90 :10/31/90 :12/27/90 :12/28/90 :12/28/90 :12/28/90
a.I.,sITA nrrfnln rfinv GENERIC LIK 91-UZ UrrLUIAL KLUUKU Wrl
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and Budget Clearance Number:
This request is covered by Office of Management The estimated average burden is
3150-0156, which expires November 30, 1993.response, including visual approximately 8 person-hours per licensee drafting a description of the observation of the waste form mishap, report for submittal to NRC.
observation, and preparing a final mishap and suggestions to reduce the burden Comments on the accuracy of this estimate and Budget, Room 3208, New may be directed to the Office of the Management D.C. 20503, and the U.S. Nuclear Executive Office Building, Washington, Records Management Branch, Office of Regulatory Commission, Information and D.C. 20555.
Information Resources Management, Washington, please direct them If you have any questions about this letter, to the appropriate regional office.
to the technical contact listed below or Sincerely,
(6e, OM1 L 9AK
Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NMSS
Technical Conta Michael Tokar, NMSS
01) 492-0590
Enclosure:
List of Recently Issued Ge ic Letters NMSS r/f LLRB r/f EWick Distribution: Central File# JSurmeier RECunningham ossi MTokar EKraus s R.O'Connell JGreeves RBangart PLo Category: Prop tary or CF Only PDR YES NO
ACNW YES NO =_\
- SEE PREVIOUS CONCURRENCE
OFC :LLTB C I :IN :L L :LL :LN
--- --- ----
--- --- --- ---
- RCunningham*:MToka :JSur er .a e NAME:EWick* :EKraus*
- 12/,.1/90 :12/26/90 :12/,p/90 :12/ 0
DATE:10/19/90 :10/22/90 :10/31/90
(as attacimt to doc CRGR' FFICIAL RECRD COPY
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It is requested that waste-form mishaps be reported within 30 days of knowledge of the incident to NRC's Director of the Division of Low-Level Waste Management and Decommissioning and to the designated State disposal-site regulatory authority.
This request is covered by Office of Management and Budget Clearance Number:
_ which expires . The estimated average burden is approximately 8 person-hours per licensee response, including visual observation of the waste form mishap, drafting a description of the observation, and preparing a final mishap report for submittal to NRC.
Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of the Management and Budget, Room 3208, New Executive Office Building, Washington, D.C. 20503, and the U.S. Nuclear Regulatory Commission, Information and Records Management Branch, Office of Information Resources Management, Washington, D.C. 20555.
If you have any questions about this letter, please direct them to the technical contact listed below or to the Regional Administrator of the appropriate regional office.
Sincerely, Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NMSS
Technical Contract: Michael Tokar, NMSS
(301) 492-0590
Enclosure:
List of Recently Issued Generic Letters Distribution: Central File# NMSS r/f LLRB r/f EWick EKraus RECunningham CERossi MTokar JSurmeier JGreeves RBangart PLohaus PDR YES NO Category: Proprietary _ or CF Only ACNW YES NO
SUBJECT ABSTRXCT:
OFC :LLTB E5H &kT :IM v :NRR/DOEA:LLTB :LLTB :LLWM :LLWM
__-----------------------------------------------------
NAME:EWick EKraus 'lfRC nningham:CERossi :MTokar :JSurmeier:JGreeves:RBangart DATE:10/i./90 10/szio :10/3//90 :10/ /90:10/ /90:10/ /90 :10/ /90:10/ /90
RE*
aE~ OFFICIAL RECORD COPY
befl rhecI2se 0
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