ML19351D528

Forwards Responses to NRC 800822 Comments & Questions Re EPICOR-II Resin Solidification Program

ML19351D528
Person / Time
Site:	Crane
Issue date:	10/03/1980
From:	Hovey G METROPOLITAN EDISON CO.
To:	Jay Collins Office of Nuclear Reactor Regulation
References
TLL-502, NUDOCS 8010100343
Download: ML19351D528 (15)

Text

.

v Metropolitan Edison Company Post Office Box 480 gj

'g g Middletown, Pennsytvania 17057 writer's Direct Dial Number e

October 3,1980 TLL 502 TMI Program Office Attn:

Mr. John T. Collins, Deputy Director U. S. Nuclear Regulatory Commission c/o Three Mile Island Nuclear Station Middletown, Pennsylvania 17057

Dear Sir:

Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 I

EPICOR II Resin Solidification Program In your letter of August 22, 1980, NRC/TMI-80-126, you had commented on the EPICOR II Resin Solidification Program, as discussed in my letter to you, dated June 5, 1980. Attached please find our responses to your comments /

questions. The item numbers correspond to your comments.

We appreciate receiving your early review so that the NRC concerns can be properly addressed before we proceed with the final plans for resin solidification.

If you have any further concerns, please do not hesitate to contact us.

Sin

ely, O. 2 '^Mr iD"~

(J G. K. Hovey Vice-President and Director TMI-2 GRH:EDF: dad cc:

Bernard J. Snyder Attachment f00I -

.s 8010:t00 N g

f/

Metropohtan Edison Comoany :s a Memcer o: tre General Pubttc U**t es Sys:em

EPICOR II RESIN SOLIDIFICATION PROGRAM (II CO3NENTS/ RESPONSES p

a

's i

i

TLL 502 Paga 1 QUESTION 1 How will you ascertain whether tha resins used in the test program are representative of the resins?

i

RESPONSE

The resins being used in the test program were provided by J. Levendusky i

of Epicor, Inc., as being representative of those used at TMI-2.

These l

resins span the range of possible resin mixes. The fact that these various mixes solidify roughly the same provides assurance that in-between mixes should solidify equally well.

4

?

1 I

i e

/

l k l' f

.q 1

TLL 502

( ~j P 33 2 f

QUESTION _2, Now will compression and tensile test data be used to characterise the solidified waste product?

RESPONSE

Tensile tests have been deleted from.the test program. The next revision of the document will reflect this. Compression tests give an indication t

of the strength of the final product. A product with higher strength is more desirable than one with lower strength from integrity and rehandling stand points.

/

/

4

/

f

,.d 4

W f

S

( '

/

)

-<p'

/

i l

l 3

ei

)

/

4 p;

2 1.

4 y

+

ir m -

9-i TLL $02 Pzg2 3 QUESTION 3 Attachment.1 of. the referenced letter, TLL 241, states that a few full-sized liners will be solidified as part of the demonstration. However, the Hittman test program addresses the full-scale testing in terna of 30 gallon drums. Tests should be performed using container sizes and designs which will be actually used in the EPICOR II resin solidification

=yetem.

RESPONSE

T e full-scale testing of 30 gallon drums has been deleted from the test program, and will be reflected in the next revision. One (1) full-scale j

solidification test will be performed on a modified 4 X 4 liner.

- I I

'j f

-l,/

f I

I 2

O 5

i e

8 hi v-w----

,- v -

TLL 502 P gs 4 6

OUESTIO4 4

., page 3, paragraph 2:

i NRC Standard keview Plan 11-4 ETSB Branch Technical Position No. 11-3, states that uniform distribution is required. This is interpreted to mean evenly distributed resin. Without criteria for resin homogeneity, test samples may not be representative of the full-scale product.

Leachability, compression and tensile strength, and hardness may vary as the location of;. r ; sin concentrations change.

l

RESPONSE

Homogeneity is addressed in the program and defined on page 6, item 3, as j

a solidified product that contaias no voids or pockets of unsolidified q

materials. ~ We are confident chat with the mixing blade design, reasonably

]

uniform distribution of resin will occur within the cement matrix. To validate this claim, a 4 X 4 liner will undergo solidification, and then i

be sectioned to demonstrate homogeneity and the other criteria of section C i

of the test document.

i

)

Leachability has not been addressed in this test program for lack of any i

specific NRC or regulatory requirements or guidelines, whereas the tensile tests have been deleted from the program.

1 i

ll*

i 4

b

~

'/ '

l e-y i

e' i

//

.TLL 502 Pzgs 5 OUESTION 5,Section IV.c pages 6-7:

Identify the method used to verify that the desired resin depletion levels are achieved.

RESPONSE

The method of' resin depletion was provided to us by J. Levendusky of Epic [r, Inc., who also supplied the resins. Recent analysis of the resins by BNL (Letter, R. E. Browning to Arshard Navae, September 24, 1980) has shown that the desired depletion levels were not achieved. We are cur-rently working to determine the ranges of chemical loading actually

)

experienced in terms of pounds of boron and sodium per cubic foot-of.

resin. Additional resins have been procured and will be chemically depleted to ensure that the entire range of boron and sodium loadings are tested.

i

\\

i i

j i

4 i

I

+

~

1 i

1 g

1 a

s TLL 502 Ptg2 6 p:.

OUESTION 6

' Attachment 3,Section IV.D. last paragraph, page 7:

The sample cure time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been changed to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.' The cure time should be respecified.

RESPONSE

The next revision of the test document will reflect these changes.

I l

l i

)

Lo O

s Y

~ ""

m.

.g y

.+;

TLL 502 Pego 7 l

QUESTION 7

,,Section IV.E. item.7, page 9:

4 An electric mixer.is used rather than a spatula.

)

RESPONSE

The next revision of the test document will reflect these changes.

l r

4 5

y

TLL 502 Pagt 8 QUESTION 8, Sect. inn IV.E, item 12, page 10:

See specific coment 6.

\\

RESPONSE

The next revision of the test document will reflect these changes, l

1 l

~

TLL 502 Pegs 9 QUESTION 9,Section V.B. item 4, page 16:

See specific comment 6.

RESPONSE

The next revision of the test document will reflect these changes.

a

.,.m...

~

QUESTION 10,Section V.G, page 18:

There will be no samples which have been immersed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after molding.

This section should respecify when inanersed samples will be compression 4

tested.

f

RESPONSE

Section V-G, page 18, r.pecifies that one sample is air cured, the other j

air cured for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and then inanersed in water. Compression test follows the water immersion.

~

I t

1 I

6

)

a

i QUESTION 11

• .Section V.H, page 18:

See specific comment 12.

RESPONSE

This will be identified in the next revision of the document.

I a

e I

e

, ~

-r m

p w

r-e-,

Pega 12 QUESTION 12.Section V.I, 1st paragraph, page 23:

The quantities of the contaminants to be added to the resins in the i

special tests should be identified and the basis for assuming that this will represent conditions in the EPICOR II liners generated to date should be explained.

In addition, the tests under which the special samples will be subjected should be identified.

RESPONSE

This will be identified in the next revision of the document.

l 9

e

c.'

P go 13 QUESTION 13, page 15, observation Criteria, item 2:

Probing with stirring rods is not an appropriate means to determine cement hardness.

RESPONSE

Cement hardness is not being measured in quantitative terms. Probing with a rod is merely to identify if the sample has hardened.

R O

• h[

4j i

s

- -. -