ML20012D604
| ML20012D604 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1990 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Miller V NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 9003280125 | |
| Download: ML20012D604 (8) | |
Text
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7.
MAR I 4 1990
' MEMORANDUM FOR: Van (y L. Miller, Assistant Director for State Agreenent Programs State Programs FROM:
Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NMSS
SUBJECT:
LLWM STAFF COMMENTS RESULTING FROM PARTICIPATION IN THE WASHINGTON AGREEMENT STATE PROGRAM YlSIT, NOVEMBER 27-DECEMBER 1,1989 As you know, the LLWM staff. assisted Jack Hornor, Region V RSA0, in the visit to the Washington State Radiation Control Program (RCP), November 27-December 1, 1989. At the end of the visit Jim Shaffner, LLOB, provided information relevant to the LLW portion of the visit to Mr. Hornor. The attached report provides a more complete sunanary of staff comments and recommendations relative to the review of the LLW portion of the Washington RCP.
Overall, we deem the Washington LLW regulatory-program to be adequate to protect public health and safety and compatible with that of NRC. There are several areas, however, which we feel require additional attention.
Please forward these comments and recommendations to the Washington RCP L
director and ' advise me of the responses you receive. Thank you for the opportunity to participate in this review.
L ORIGINAL SIGNED BY Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NMSS
Enclosure:
As stated DISTRIBUTION:
(LLWM90-028)
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LLWM COMMENT 5 FM PARTICIPATION IN WA AGREEMENT STATE PROGRAM VISIT, 11/27-12/1/89
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,e-2 MEMORANDUM FOR:
Vandy L. Miller, Assistant Director for State Agreement Programs State Programs FROM:
Richard L.-Bangart, Director Division of Low-Level Waste Management l
and Decomissioning, HMSS t
S JECT:
LLWM STAFF COMMENTS RESULTING FROM PARTICIPATION IN THE WASHINGTON AGREEMENT STATE PROGRAM VISIT, NOVEMBER 27-DECEMBER 1, 1989 As you k' w, the LLWM staff assisted Jack Hornerton State Radiation Contr Re the Wash
, November 27-December 1, 1989. At t end of the visit Jim Shaffner, LLOB, provided information relevant to t e LLW portion of the visit to Mr. Hornor.
The attached report provides a mor complete summary of staff comments and recomendations relative to the review o the LLW portion of the Washington RCP.
Overall we deem the Washington LLW regulatory program to be adequate to
. protect public healt and safety and compatible with that of NRC. There are several areas, however which we feel require additional attention.
Please forward these co ents and recommendations to the Washington RCP l-
' director and advise me o the responses you receive. Thank you for the opportunity to participate in this review.
Richard.L. Bangart, Director ivision of Low-Level Waste Management nd Decomissioning, NMSS l
Enclosure:
As stated DISTRIBUTION:- (LLWM90-028)
Central File # 409.48 RLBangart PLohaus JJSurmeier HMSS r/f LLOB r/f JGreeves RBoyle JShaffner LOB t/f PDR Yes: [{/
PDR No: C/
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L SUBJECT ABSTRACT:
LLWM COMMENTF FM PARTICIPATION IN WA AGREEMENT STATE PROGRAM VISIT, 11/27-12/1/89
- See Previous Concurrence
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MEMORANDUM FOR: _Vandy L. Miller, Assistant Director i
for State Agreement Programs State Programs FROM:
Richard L. Bangart, Director Division of' Low-Level Waste Management and Decommissioning. NMSS
SUBJECT:
LLWM STAFF COMMENTS RESULTING FROM
= PARTICIPATION IN THE WASHINGTON AGREEMENT STATE PROGRAM VISIT, NOVEMBER 27-DECEMBER 1, 1989 the Washington Stat ' Radiation Control Program (RCP)gion V RSA0, in the visit'to As you know,< the L M staff assisted Jack Horner, Re
, November 27-December 1, 1989. At the end of.
e visit Jim Shaffner, LLOB, provided information relevant to the LLW por ion of the visit to Mr. Hornor. The attached report:
provides a more complete ummary of staff comments and recommendations relative-to the review of the LLW p tion of the Washington RCP.
Overall we deem the Washingto LLW regulatory program to be adequate to prctect public health and safet and compatible with that of NRC. There are several areas, however,~ which we el require additional attention.
Please forward these comments and commendations to the Washington RCP director and advise me of the respon s you receive. Thank you for the:
opportunity to participate in this rev w.
Richard L. B art, Director Division of Lo Level Waste Management s
and Decommissi ing, NMSS s
Enclosure:
As' stated
< DISTRIBUTION:
.gCentral File # 409.48
- RLBangart PLohaus JJSurmeier NMSS r/f OB r/f '
'JGreeves RBoyle JShaffner LLOB t/f t
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SUBJECT ABSTRAC LLWM COMME
~FM PARTICIPATION IN WA AGREEMENT STATE PROGRAM VISIT, 11/27-12/1/89
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p Washington Radiation Control Program-Program Visit Nov. 17 - December 1, 1989 Low-Level Waste Management Report.
Washington Department of Health DOH)
Office of. Radiation Protection ORP)
Waste Managerfent Section WM) heview Staff:
J. Shaffner 11/27 - 12/01 R. Shewmaker 11/27 - 11/28 M. Dunkelman 11/29 - 12/01 DRP Staff Contacted / Interviewed:
G. Robertson, WM M. Elsen WM J. Ahmad WM (by Shewmaker)
A. Rainey WM (by Dunkelman)
K. Felix.
WM
'i T. Frazee ORP B. Verellen ORP (telecon)
J. Erickson ORP (re:
Plant u take to Tritium Materials Reviewed:
On-Site Inspection Procedures; Draft t
Administrative and Licensing Procedures; Letterbooks; Log Books; LLW Incidents; 1988, 1989 Waste Site Inspection Reports; Misc. follow ups on permittee violations; Misc. variances and-specific approvals; Contingency plan for LLW facility administration; On-site inspector audit / accompaniment; Daily 8 weekly inspection reports.
Review Objectives:
- 1) WDOH Radiation Control Program Agreement State Program visit; comments - recommendations.
- 2) Orientation of Shewmaker, Dunkelman re:
LLW review of Agreement State programs.
Supplemental Reports Prepared: Engineering Report - LLW (Shewmaker) (Shaffner)
Present Status vs Current Guidelines PresentStatusvsProposedGuidelines(Shaffner).
Exit Interviews:
- 1) Shaffner & Dunkelman w/Robertson & Eisen 11/30
- 2) Shaffner & Shewmaker w/Robertson & Eisen 11/28
- 3) Hornor & Shaffner w/ Strong et al 12/01 Summary of Findings Overall, the WM Program is adequate to protect public health & safety. There have been several specific improvements made since last review, including:
a)
An increase in staffing level & capability - The program now includes a l
nuclear engineer and engineering geologist; L
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A more consistent follow up on. licensee delinquency in reporting requirements;-
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Clear, specific and timely deficiency letters, d)-
Escalated dialogue with the licensee to minimize licensee misunderstandings and seek cooperation infornally before formal notification; e)
A clear, comprehensive on-site inspector procecures manual; f)
An initiative to develop a process for approval of waste products / waste forms.
Co_mments & Recommendations I.
Site Closure'and Decommissioning:
Comment-ORP has not yet approved a closure plan for the LLWDF. This has-limited the ability to assess the license for a surety for closure. Current estimates indicate that $20M may be required for site closure. The closure fund currently contains $1+M. The state has potential alternative mechanisms for funding closure but legislative remedies may be necessary to implement a preferred mechanism. There are several other l
factors to consider in this multifaceted issue:
1 a)
ORP has not accepted the licensee's technical conclusions concerning closure, particularly with regard to infiltration.
4 b)
ORP and Washington Department of Ecology (WDOE) are still seeking a consensus on an acceptable site closure strategy.
3 c)
USD0E's willingness to accept a closed site has not yet been established.
Reconnendations It is reconnended that ORP develop a conservative estimate for surety requirements based on-the best information currently available. They should insist'that the licensee show cause through his own analysis that an alternate surety is appropriate or accept the one developed and agreed upon by the State of Washington.
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II.
Staffing Levels:
Comments Staffins levels and the funding of the entire regulatory program are tied to waste volumes. Waste volunes are projected to decrease below a level that can support 4 full-tine technical staff and an inspector.
_Reconcendation It is recommended that ORP seek administrative or legislative remedies that will protect a minimum basic LLW regulatory program which includes at least a staffing level noted above.
III. Licensing and Administrative Proceoures:
There is a need for licensing and administrative procedures to establish clarity aad consistency of regulatory activities. Currently these activities are dependent on the knowledge and capability of the incunbents. The program managenent is aware of the need for such procedures.
Hcwever, higher priority work items have delayed their development.
Recommendation L
- It is recommended that the program manager develop work plans for the development of licensing and administrative procedures including time tables for development, milestones for progress assessnent, and resource p
requirenants.
L IV. Compliance Program - Facility Operator Compliance' Program l
l Comment l
The facility operator compliance program is being transferred from the Radioactive Materials Section to the Waste Management Section. Guidelines for the compliance program will be developed by RAM personnel to be used by WM personnel in developing procedures for inspections. The new structure is supposed to be in place by next October (next site inspection).
Recommendation We recommend that, during the transition period, inspection teams be comprised of both RAM and WM personnel in order to ensure consistency in inspections.
Further, we recommend that procedures be expanded to include the inspection of site engineering aspects of LLW f acility (water management, soils engineering, slope stability) and that inspections be conducted by multidisciplinary teams with expertise in radiation protection, engineering, geoscience and environmental science.
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V.
Emergency Response Plan:
Comment The ORP needs a LLW specific coroponent to its Energency Response Plan.
They are planning to adapt, as necessary, the licensee's emergency -
response plan, once approved, to be used as'the LLW portion of the Washington. Energency Response Plan.
Recommendation i
ORP approval or disapproval of the licensee's Emergency Response Plan should be based on the ways and means by which the licensee plan allows for interaction and involvenent by state personnel in emergency situations. ORP'should ensure that ORP advice and consent is factored l.'
into licensee emergency response.
VI. On-Site Incidents:
Comment The ORP staff is aware of the significant decrease in the number of incidents reported by the on-site inspector, but have not taken actions other than sone short accompaniments to determine the reason for this.
They speculate that the decrease is due to:
- 1) decreased activity at the
[,
facility leading to both less chances of having an incident and less L
pressure during operations making it easier for USE to avoid incidents; l
a different threshold being used by the ORP fielo staff to report incidents; or both.
Reconsnendation l
It is recommended that WM management follow up with the on-site inspector to ascertain the reasons for recent dramatic. decreases in reporting i
on-site incidents.
VII. Review of Concrete Overpack Acequacy:
Conunent Since the completion of the visit, the State has issued the TER on the concrete overpack design. In reading the document NRC staff was unable to determine how the state review handled our consnents (see attached report by R. Shewmaker) on the concern for corrosion of reinforcing steel.
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- Recommendation It is recommended that ORP document clearly in its TER how it evaluated corrosion aspects for the reinforcing steel used in the concrete overpack.
VIII. Waste Acceptance Comment In the area of waste acceptance, we found that the State had not taken action to preclude acceptance of two of three waste forms whose topical reports the' NRC had either disapproved or hao caused to be withdrawn.
In each case the State had been informed, in two separate docunents, of the NRC action.
This is an item requiring follow-up by the State as it represents a potential deficiency in the State's program implenentation.
Recommendation It is recommended that ORP take tinely action to ensure that the State's acceptance of waste forms is consistent with NRC's determinations of the waste forms' ability to meet Part 61 requirements.
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JAN il W
' MEMORANDUM FOR: John J. Surmeier, Chief Technical Branch Division of Low-Level Waste Management and Decomissioning, NMSS
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THRU:
Michael Tokar, Section Leader Technical Branch lA Division of Low-Level Waste Management C
and Decomissioning, NMSS FROM:
Robert Shewmaker Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS
SUBJECT:
TRIP REPORT ON REVIEW 0F' WASHINGTON STATE LOW-LEVEL WASTE REGULATORY PROGRAM This letter transmits the results of my review conducted on November 27 and 28 in the area of low-level waste in support of the review of the Washington State Agreements Program..The review was conducted during the week of November 27, 1989, with the team leader being Jack Horner, RSA0 Region V.
l The effort represents the first involvement of the Technical Branch in support of the program reviews conducted by the State Agreements Program Office.
This represents the Technical Branch's effort to support the new initiatives set by the Division Director in the area of the States Agreement Programs, It is rqy belief that this first effort was beneficial in two ways in that we i
were cble to learn more about the review efforts directed toward the State Agreements Program while at the same time we were able to provide some assistance to the State of Washington. We were able as well to critique the efforts by the State of Washington in evaluating a concrete overpack system and implementing waste form acceptances based on NRC's review of vendor topical reports.
Comments and recommendations were provided to the State's principal reviewer of the overpack system for his consideration in completing the l
review.
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1 Since the review conducted on November 27 and 28, 1989, the State of Washington
. has. completed the technical evaluation of the concrete overpack proposed by U.S. Ecology and has issued a. Technical Evaluation Report (TER), dated December 13, 1989.
In scanning the TER, I was unable to discern if any of Iqy coments end recommendations were factored into the review conducted by the State of Washington.
It is possible that the State may have addressed some of Iqy concerns in the review of the overpacks and concluded that inasmuch as Hanford is a relatively dry site at-present, it is unnecessary to require a more rigorous overpack design or analysis.
If this were the case, this would, l
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in myy professional opinion, be a mistake for two reasons:
(1)someofthedesign approaches utilized by USE are contrary to recomended methods of practice and standards for this type of application, even for " dry" environments; and, (2) to assume that' the current groundwater conditions will remain unchanged at Hanford for hundreds of years after disposal of the waste, places undue-(nonconservative) reliance on the hope that a benign environment surrounding l
the overpacks will compensate for design deficiencies and is inconsistent with Part 61 overall.
In the area of waste acceptance, I found that the State had not taken action to preclude acceptance of two of three sampled waste forms whose topical reports the NRC had either disapproved or had caused to be withdrawn.- In each case the State had been informed, in two separate documents, of the NRC action.
This is an item requiring follow-up by the State as it represents a potential deficiency in the State's program implementation.
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The input for an evaluation is provided in the enclosure.
If there are any questions, please contact me at Extension'205962 Original Signed By l
Robert Shewmaker Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS
Enclosure:
. Trip Report -
Washington State Program Review 1
cc: w/ encl.
J. Shaffner DISTRIBUTION:
Central File # 409.48 NM55 r/f LLTB r/f JSurmeier RShewmaker MTokar MBell PLohaus' JGreeves RBangart 1
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'PDR' No: /X/
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SUBJECT ABSTRACT:
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TRIP REPORT WASHINGTON STATE PROGRAM REVIEW November 27 and 28, 1989 by R. E. Shewmaker, LLTB, NMSS INTRODUCTION The material presented in this input document is based on a review of documents maintained by Washington State in the Offi.ce of Radiation Protection, Waste Management Section as well as on discussions held with G. Robertson, M. Eisen and J. Ahmad.
NRC reference documents were also utilized during the evaluation process.
B/C WASTE WITH EXCESSIVE VOIDS As a result of an exemption granted early this year for a waste package from Northern States Power's Monticello plant the State personnel were asked what arrangements were being made so that similar exemptions would not become
- routine. The original exemption was granted because the waste package contained in excess of 15% voids, and the container could not meet the conditions needed to assure long-term structural stability once the waste l
package had been disposed of. The package consisted of an FSV-1 liner of approximately 24 cubic feet containing stainless steel activated reactor hardware such as flattened control rods, shield tubes etc. To the extent practicable, when the liner was loaded undenvater in the fuel pool, compaction was accomplished, yet the voids were greater than the 15% defined in the license.
In granting the exemption the State noted that it was a one-time, one package approval. The State also informed U.S. Ecology-(1/24/89), the operator at the Hanford Waste Disposal Site, that in the future similar waste materials and packages should be disposed of by utilizing some external means, such as an approved engineered barrier, to provide the required stability.
f Since granting the exemption, Washington State has received a conceptual approach from U.S. Ecology to address the issue of providing long-term structural stability for waste fonns that are not easy to compact into a form y
with less than 15% voids. The State has provided comments to U.S. Ecology (USE) on problem areas needing additional stuGy and revision and is awaiting USE's response.
USE's proposed approach is based on what has been termed the caisson concept, where a cylindrical steel caisson is emplaced in the soil media and the liner containing the waste is then lowered into the caisson. Top closure and structural stability details were questioned, however, by Washington State, and U.S. Ecology is to revise and rework the concept and resubmit to the State.
Based on the current status and the need to finalize a solution (since there will no doubt be similar waste packages containing activated stainless steel l'
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-2 reactor hardware that will require disposal and that will contain more than 15%
voids), the State of Washington needs to set a target date for U.S. Ecology to l
submit a finalized design with engineering and technical details so that it can be reviewed by the State.
This target date should be established so as to meet E
a date that the State defines as the time when the disposal technique is to be actually ready for use.
WASHINGTON STATE REVIEW 0F U.S. ECOLOGY CONCRETE OVERPACK At the time of the visit Washington State was in the process of completing a review of U.S. Ecology's concept for a concrete overpack design that will be used with high integrity polyethylene containers..The overpacks are intended l
to provide the long-term structural stability necessary for the Class B/C waste material.
Action by the State is the follow-up review and evaluation effort related to a letter dated August 28, 1989 that was sent to U.S. Ecology outlining the information necessary for the conduct of such a review effort.
The State appeared to be proceeding with a logical approach toward the review effort that is necessary to accomplish such an. evaluation.
The State effort has, in general, resulted in a more rigorous and controlled process to be developed which U.S. Ecology is being made to follow.
It was anticipated that the end result would be a good review and evaluation, problem identification and resolution.
The ap)arent major point of discussion centers around the question of whether sucian overpack must also be designed to resist moisture impacts.
I noted that the State was continuing to pursue the development of the overpack design to have the capability to resist moisture in spite of the current " dry" conditions at the Hanford disposal site.
I supported that position.
A review of the various topics pursued by the State in the review and evaluation process including the various documents submitted by U.S. Ecology was conducted and the following items were identified as areas for possible consideration by the State.
I held these detailed discussions with Mr. Jamil Ahmad who was the principal reviewer for the overpack system.
A.
Materials:
1.
The aggregate proposed for use has not been specified as being required to undergo testing along with the other constituents of the concrete for alkali-aggregate reactions or soundness.
I recommended use of ASTM C88 and C227, 2.
No grouting specification or controls on the materials or installation were identified.
I reconnended guidance of ACI 318-83, Section 18.14 because of grout contact with stainless steel.
3.
No chloride limits were provided in the concrete specification.
I recommended ACI 318-83, Section 4.5.4 as a minimum.
4.
Unprotected reinforcing being utilized with very minimal cover.
I reconnended consideration of galvanized reinforcing.
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Fabrication:
1.
Concrete cover over the reinforcing steel (deformed bar or welded wire fabric) is very minimal.
The cover on the top and bottom of an overpack ut.ing deformed bar is IP. The cover on the welded-wire fabric mesh in the barrel on cylindrical part of the overpack may be
.as little as 3/4" based on ASTM-C76 as well as ACI 318-83, Section 7.7.2, if the barrel is considered a wall.
I recommended a minimum of 2 inches of cover.
2.
Welding of reinforcing bar was allowed on overpack units constructed in 1988, but it is not known whether this.was tack welding for reinforcing steel cage fabrication or strength welds such as butt joint splices.
I recommended that no tack welding be allowed and strength welds require materials and/or welding controls per AWS 01.4-79.
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3.
Lids for the units are currently flat with a uniform thickness.
I recommended that the tops be finished.with a shallow conic with 4-5" rise at the center to promote drainage.
-4 Long-term stability of chloride ion within the PVC complex has been questioned in the concrete industry so that the use of concrete embeds of PVC is of concern.
I recommended that embeds of PVC not be used and that stainless steel be used, although the type of stainless should be controlled due to possible attack from the C1' content of the concrete and any moisture migrating-through the concrete. The duplex stainless steels have been shown to provide good resistance to chlorides and soil environments.
C.
Installation:
1.
No torque values for the top and bottom head connection to the barrel of the overpack have been provided.
I recommended that the designers specify some value so that the closure procedure can reflect the details of the head attachment.
2.
The stud sleeves in both the top and bottom heads should have the enclosed volume not taken up by the stud filled with material to preclude a cavity being left open that can become a reservoir for concentrating various substances that may be aggressive to the connection' detail. The bottom sleeves could tolerate cement based materials whereas those on top should probably utilize a material which could be removed so that if need be, the head could be removed. A bitumen based material could no doubt be utilized on the top head.
3.
The drawings show no grouting for the connection detail between the barrel and the head, yet the specification indicates that a 3/8-inch thick grout bed is to be used.
I recommended that the drawing be revised to incorporate the grouting requirement.
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Based on the review and efforts by the State on the evaluation of the concrete overpack design submitted by U.S. Ecology several conclusions or lessons 1
~ learned appear to emerge.
o For detailed technical reviews where specific disciplines may be l
needed that are not normally part of the staff of the Waste i
Management Section it may be advisable to obtain assistance from other units within.the Washington State government.
For example, support in the materials and civil engineering areas may be available within the Department of Transportation (or its equivalent) in the i
form of laboratory facilities as well as personnel.
Support can also be obtained via other government agencies such as the NRC or
,I via hired consultants.
In order to be prepared to utilize such methods on at.y reasonable schedule it is generally'necessary to prearrange technical support so that when the need arises it can be fulfilled on rather short notice.
This would mean a defined need in loaned / shared government personnel and/or funds available for 1
consultants, o
A significant amount of effort has been expended by the State in the I
L review and guidance of the U.S. Ecology work to produce an acceptable submittal with supporting documents, including calculations. At the outset the calculations lacked definition of the source of various formula and methodology as well as being in a 4
-condition such that they did not follow in a logical and well-developed engineering approach to the design problem. A reviewer should have found that the documentation was in a condition L
and presented in such a manner as to be self sufficient.and able to be followed by the reviewer.
This was not the case.
Based on the problems associated with the calculations and the quality of their
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execution and documentation, the State should consider conducting L
reviews in other areas and disciplines where U.S. Ecology is responsible for calculations or control of necessary documentation.
The State needs to take a position that the work being performed by I
U.S. Ecology should be of such a quality that if U.S. Ecology were I
to cease operations as an organization, the documents in existence would be adequete and sufficient for a new operator to assume the functions required'for the operation of the waste disposal site.
o The State has held a firm and defensible approach toward U.S.
Ecology in the review and approval process for the overpack concept.
At the time of nty visit progress had also been made on the preparation of a Technical Evaluation Report.
STATUS OF ACCEPTANCE OF LLW PACKAGES WITHOUT AN APPROVED TOPICAL REPORT A review was conducted using the information contained in NRC Information Notice 89-27. dated March 8, 1989, with the focus on Attachments 1 and 5. sumarized the various topical reports that have been submitted to the NRC for review and identified the current status of each topical report. provided a listing of the various waste packages that were being i.
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a, accepted at the Hanford Waste Disposal Site.
By comparing the two lists it was found that there were three types of waste packages apparently being accepted for burial where no NRC approved topical report existed.
Nor were the packages acceptable under the "grandfathering" agreement of 1983. The status of the acceptability of these at Hanford was explored via the Washington State records 1
and the cognizant personnel.
o U.S. Gypsum (Envirostone)-*-051-The State of Washington's file on i
this vendor contained a letter from the State to the waste site operator dated March 17, 1989 stating that as of April 1,1989 the waste stabilized using Envirostone would not be accepted except for certain bead resins in SS-gallon steel drums from mixed bed ion exchange usage and packaged in the drums with a 60t package i
efficiency that were stabilized prior to April 1,1989. These would i
be accepted until July 1, 1989. This action by the State of Washington reflects the fact that the NRC did not approve the topical report and had notified the State of Washington by letter dated l
April 12, 1988 of that fact. The State of Washington had sent a letter dated July 18, 1988 to U.S. Ecology, the operator at the Hanford site, that Envirostone would be accepted for one year under the conditions that the waste be in 55-gallon steel drums and that only the waste stream source be limited to only mixed bed ion exchange. The March 1989 action then closed the one year approval.
Actions by the State of Washington on this type of waste appear to have been adequate to end the use of Envirostone for stabilization i
of wastes.
o U.S. Ecology (ATI-Distilled Bitumen)-WM-091-The State of Washington's file on this vendor contained a letter dated March 24, 1988 from the NRC notifying the State that the review of the ATI Topical Report,
" Bitumen as a Radweste Solidification Agent," had been discontinued.
The reason was the inability of ATI to provide evidence that the stabilized waste would possess a minimum compressive strength of 60 psi.
Based on the files of the State and discussion with State personnel, no action had been initiated prior to November 28, 1989 to notify U.S. Ecology, the waste site operator, regarding acceptance of waste stabilized by the ATI method. This is apparently an oversight by the State.
It is not known whether or not such material has been accepted at Hanford since March of 1988.
As follow-up action the State should make a notification to its operator and determine whether or not such shipments have been accepted, and if so, the available details on the origin, burial etc. should be gathered for review and any action the State may deem necessary.
It should be noted that the NRC review of the U.S. Ecology (ATI-High-Strength 31tumen) now being proposed for waste solidification by U.S. Ecology is currently underway. This is identified as NRC Docket Nuiter WM-100, o
Stock Equipment Company (Coment)-*-092-The State of Washington's file on,this vendor contained a letter dated September 23, 1988 from
.5 the NRC notifying the State that the NRC had discontinued the review of the topical report, " Stock Equipment Company Waste Solidification Process for Low-Level Radioactive Waste Generic Waste Form Certification Test Results." The stated reason was that supporting information had not been provided and that the NRC's consultant had several findings.
Based on the files of the State and discussion with State personnel, no action had been initiated by the State prior to November 28, 1989 to notify U.S. Ecology, the waste site oprator, regarding the acceptability of waste stabilized by the Stock method. This is apparently an oversight by the State.
It is not known whether or not such material has been accepted at Hanford since September of 1988. As follow-up action the State should make a notification to its operator at the disposal site and determine whether or not shipments have been accepted, and if so, the available details on the origin, burial etc. should be gathered for review and any action the State may deem necessary.
While the impact of the oversights in the two out of three instances is not known, it points out that some control mechanism might be helpful for the State to devise so that the follow up action is taken and taken in a timely fashion.
METHODS USED BY STATE TO IMPLEMENT CONDITIONS DEFINED.IN NRC TERs.0,N, IUP10AL MLPUNT3 At the present time the State of Washington utilizes the certificate of compliance ("C of C") as the method to iglement the conditions of the approval of a topical report on a specific high integrity container (HIC). The "C of C" is issued to the vendor of the HIC with a specific "C of C" number and package identification number. The "C of C" provides a list of reference documents that forms the basis for certification. The list includes documerits submitted to the State as well as the NRC. This list may include the basic topical report as submitted in final fom, a user's manual, if a>propriate and perhaps reference to responses to NRC questions. A section of tw "C of C" is devoted to the requirements placed on the user of the HIC. This list addresses USDOT and State of Washington regulations as well as the condition of the license of the waste disposal operator. Additionally, it is stated that the user shall certify that all restrictions and required procedures have been adhered to.
This is followed by a list of specific limitations. Within this list would be the limits of use that formed the design or boundary conditions for the development of the HIC, physical features which are used to evaluate the container and the list of waste streams / forms for which the HIC can be used.
Finally the "C of C" states that the approval granted under the "C of C" is contingent upon successful use and demonstration of the package and the system is under continuing evaluation and if additional requirements are deemed necessary, appropriate modifications shall be made prior to continued use.
Lastly, it is noted the "C of C" is subject to revocation, presumably upon immediate action by the State.
The State plans to use the same concept and mechanism for overpack systems as they are approved. At the current time no similar system exists for waste forms / waste stabilization methods.
State personnel indicated that the
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implementation of a "C of C' system for waste form / waste stabilization will be considered for Jossible future actions based on the NRC's question regarding the control mec5anism over waste forms / waste stabilization.
At the present time the State and its disposal site operator, U.S. Ecology, use the certification supplied by the waste generator as the main basis for accepting the waste for those parameters conditions etc. that cannot be easily verified at the waste site. The State or its operator does not go to the waste generator's site to verify any conditions. Such an effort would apparently impact the small staff, and the question of the legality of State inspectors from Washington going into another state where the waste generator is located becomes an 1ssue. The fact remains that most of the important conditions contained in a "C of C" can only be verified at the location of the waste generator.
Two of the State of Washington "C of C's" were then selected for review.
A.
WN-HIC-03 Amend #2, Packa e DSHS-HIC-SFPIC'200L, dated October 31, 1988, ChichibudementCompany,LD The State of Washington "C of C" references the following documents issued by Chichibu for this HIC. Vol 1(non-proprietary), July 1986, was approved with the NRC TER dated June 1986. Vol. II(proprietary), Rev. 2, August 1988 and the Manual for Use of SFPIC's, Rev. 1. March 1988 represent the most recent documents. The NRC staff issued a revised TER in May 1987 that was incorporated by Chichibu into the topical report Vol. I in June 1987. Therefore, the State of Washington references the latest non-proprietary versions of the appropriate reports. Efforts are in progress to have Chichibu Coment Company, Ltd. incorporate the three documents into a single volume.
One discrepancy was found in the 'C of C' issued by the State of Washington.
This was contained in the body of the text where the June 1986 User's Manual is referred to, yet in Section 28 (in referencing the bases for the "C of C"), the reference is to Rev. I dated March 1988. This error needs to be corrected-in the "C of C" in the future. The conditions attached to the approval of the topical report as reflected in the TER are incorporated in the 'C of C',
B.
WN-HIC-05, Package DSHS-HIC-EA-142-A, dated September 12, 1988, Nuclear Packaging, Inc.
The State of Washington 'C of C" references the latest topical report by Nuclear Packaging for this HIC (TP-07-P(A), Rev. 2, July 1988).
The associated Users Manual is OM-32, Rev. 4 The NRC issued a TER on this HIC in April 1988 that addrested the March 1987, Rev.1 version that was then followed by the July 1988 version, which as directed by the TER, incorporated the regulatory position set forth in the TER.
It is recommended that for ease of review and linkage to NRC actions that the "C of C's' issued by the State also list the NRC docket number of the applicable topical report under the Title and Identification of l
Application'Information Section.
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CONCLUSIONS Four major areas of low-level waste regulation were sampled during this
'1 inspection effort:
- 1) B/C waste with excessive voids, 2) concrete overpack 4)impleme)ntationofconditionsassociatedwithapprovedtopicalreports.
system 3 status of LLW packages without an approved topical report and, Actions to allow disposal of B/C waste with excessive voids are being addressed with an effort by the State and its site operator to develop a i
burial caisson system.
The inspection determined that a specific target date to have such a system operational should be established and efforts directed to that goal.
Efforts by the State to review and evaluate the concrete overpack system proposed by U.S. Ecology were found to be nearing completion.
Comments and reconenendations were provided to the State for their use in reviewing areas concerning materials, fabrication and installation of the oversack system.
Though the State appeared to be addressing the appropriate tecinical areas in the review of the overpack design and placement, I identified several details involving issues within these technical areas that I believe require further attention in order to conclude that each of the technical areas is adequately addressed with regard to the needed characteristics of the overpack system.
Since the completion of the trip, the State has issued the TER on the concrete overpack design.
In reading the document I was unable to determine whether or not my comments and reconsnendations were addressed. It is possible that the State may have addressed some of sty concerns in the review of the overpacks and concluded that inasmuch as Hanford is a relatively dry site at present, it is unnecessary to require a more rigorous overpack design or analysis.
If this i
were the case, this would, in my professional opinion, be a mistake for two reasons:
(1) some of the design approaches utilized by USE are contrary to reconenended methods of practice and standards for this type of application, even for " dry" environments; and, (2) to assume that the current groundwater conditions will remain unchanged at Hanford for hundreds of years after disposal of the waste, places undue (nonconservative) reliance on the hope that a benign environment surrounding the overpacks will compensate for design deficiencies and is inconsistent with Part 61 overall.
I In the area of waste acceptance it was found that the State had not precluded the acceptance of two of three sampled waste forms which had the previously i
submitted topical re> orts to the NRC either withdrawn or disapproved.
In each l
situation the State ind received two separate NRC documents alerting the State to these facts.
Information was unavailable to determine whether or not actual waste packages have been accepted and buried after these notifications to the State by the NRC.
The State was requested to obtain the information from its site operator for future NRC review.
This is an open item for future follow-up.
The failure by the State to act in 2 of the 3 cases examined demonstrates that the topical report review system has not been fully implemented by the State, and represents a potential deficiency in the implementation of the State's program.
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The sample of two topical reports which had NRC approval indicated that the conditions and current documents were generally reflected in the C of C issued by the State.
In summary, it was concluded that the low-level waste functions being performed by the State in these areas were being adequately controlled, except as noted above, in order to protect the public health and safety, i
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