ML20033F490
| ML20033F490 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1990 |
| From: | Hurt R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bixby W ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 9003210212 | |
| Download: ML20033F490 (1) | |
Text
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MAR 191990 Project M-32l
_ Willis W. Bixby, Director West Valley Project Office U. S. Department of. Energy Idaho Operations P. O. Box 191 West Valley, NY 14171
Dear Dr. Bixby:
Enclosed for your information is a trip report prepared by NRC's Division of High-Level Waste Management concerning a visit to the West Valley Demonstration Project from October 31 to November 1,1989.
Sincerely, M.88"
- R. Davis Hurt West Valley Project Manager Advanced fuel and Special Facilities Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety
Enclosure:
Letter from J. J. Linehan to R. Stein dated 2/13/90 (DH/LTP,TO BIXBY)
Distribution:
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Mr. Ralph Stein 1.
-Mr. Ralph Stein 4
Associate. Director for Systems Integration and Regulations.
Office of C1viliarc Radioactive Waste Management U.S. Department of Energy RW-24 Washington, D.C.
20545
Dear Mr. Stein:
SUBJECT:
TRIP REPORT FROM THE OCTOBER 31 AMD NOVEMBER 1, 1989 U.S. NUCLEAR REGULATORY COMMISSION VISIT'TO THE WEST VALLEY DEMONSTRATION PROJECT Enclosed for your information is a trip report from the October 31 and November 1, 1989 U.S. Nuclear Regulatory Commission (NRC) staff visit to the West Valley) Demonstration Project (WVDP) operated by the U.S. Department of Energy (DCE.
In summary, the NRC staff found the visit'to be helpful in understanding the glass production program at WVDP. The staff also believes that WVDP's work on obtaining an outside review of its planned glass-making activities will be beneficial to DOE's overall program.. Moreover, WVDP may want to consider soliciting additional input from those in industry with experience L
in commercial glass making.
Such input might be advantageous in providine.
P WVDP with the advice it seeks concerning the adequacy of certain technical y
aspects of its glass-making program, However, as a result of this visit, the staff has three major comments it
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E believes DOE should consider. The first major comment concerns the WVDP l
Product / Process Control Program. While the staff believes that a well-L developed process control program can provide a good measure of confidence 1
in the quality of products resulting from WVDP radioactive glass-making operations, DOE should consider conducting some tests (e.g., leach tests) on l
archived glass samples of production glass retrieved from the pour canisters.
l It is believed that such tests would verify the quality of the glass actually L
produced and provide confidence in related performance measurements of the glass waste form in the context of the overall waste package container and anticipated repository conditions.
The second major staff comment addresses the lack of plans for dealing with any production glass that is "out-of-specification" with the Waste Acceptance Preliminary Specification (WAPS). At present, WVDP has no plans to develop the capability to rework or reprocess production glass that is found to be "out-of-specification" with WAPS. The staff suggests that before taking a final position on the need not to have such a capability, that DOE should have a strategy with respect to how it will deal with such glass, m
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FEB 181990 Mr. Ralph Stein The third trajor staff comment focuses cn the linkage of the WVDP glass U
and the MCC-1 -leach test in WAPS to the post-containment performance allocation in the SCP.
Based on the presentations of the waste form research currently sponsored by DOE, WVDP did not indicate how their MCC-1 test for " durable glass"_ complies with the SCP's post-containment performance allocation.
Furthermore, the staff understands that both kVDP and DOE / Office.of Civilian
- Radioactive Waste Management (OCRWM) recognize that this linkage has yet to be established. With this linkage undefined, it is not clear what basis would exist for asserting that WVDP's proposed glass composition is adequate. ' DOE
- needs to establish a specification that will-link the performance of the glass to the allocation defined'in the SCP.
~A fourth area addressed by WVDP during the briefings and identified by the staff-as an area of' concern at the bi-monthly quality assurance (QA) meetings, is the lack of a fully developed and implemented QA program for both DOE-glass producers:
the WVDP and the Defense Waste Production Facility (DWPF)..The staff'is concerned that DOE has not sufficiently developed and implemented the QA programs for the glass producers and submitted that information for NRC review.
For example, the NRC staff transmitted comments to DOE on 0GR/B-14, entitled " Quality Assurance Requirements for High-Level Waste Form Production,"
on February 7, 1989.
DOE has not responded to these comments, to date.
However, at the September 9, 1989 bi-monthly QA meeting, DOE indicated that the
_QA requirements for waste form production would be incorporated into the OCRWM Quality Assurance Requirements (QAR) document.
NRC comments would be addressed in a-QAR revision, and'0GR/B-14 would be superseded.
During the September 9, 1989 bi-monthly QA meeting, DOE noted that the schedule for submitting the QAR revision to NRC for review was November 1, 1989. DOE also stated that milestones and schedules for the qualification of one of the glass producer programs would be provided. At the December 13, 1989 bi-monthly 0A meeting, the NRC staff proposed a set of milestones that could be used to accept the glass producers QA program. At the meeting, DOE committed to reviewing the staff's proposal and providing comments no later than the next bi-monthly QA meeting scheduled for February 1990.
As of February 9,1990, the NRC staff has received neither the QAR revision nor the Quality Assurance Program Descriptions for both the WVDP and the DWPF.
Although the glass producers have been performing work under a QA program, the programs have neither been accepted by DOE OCRWM nor reviewed by the staff.
Without having an accepted QA program in place, DOE OCRWM may be unable to ensure that those activities that need to be conducted under a 10 CFR Part 60, Subpart G QA program are properly controlled.
The final staff comment covers one topic which was not addressed during the visit.
It concerns DOE's demonstration of compliance with the requirements of the Resource Conservation and Recovery Act (RCRA).
d n.
S 1 8 1990 Mr. Ralph Stein 3
In this regard, DOE did not indicate how its glass-making programs would address the applicability of or its compliance with the requirements of RCRA.
However, as a n sult of the December 14, 1989 letter from DOE, we understand that DOE is working with the the U.S. Environmental Protection Agency, the agency responsible for enforcing RCRA, to determine what course of action night be necessary to ensure that the pertinent requirements of RCRA receive consideration during-the development of all aspects of the repository program.
We would appreciate being kept informed of the status of this effort.
In closing, the NRC staff found this particular forum to be a very. effective means for gaining insight into DOE's glass producer program under the WAP.
Moreover, we would appreciate an opportunity to continue the dialogue with DOE as a means of understanding its WAP for the vitrification of high-level radioactive wastes. As an example, the staff was interested to learn.that DOE had been tracking aevelopments in foreign glass-making programs; consequently, the staff intends to accept b DOE invitation to be briefed on these activities.
If you have any questions or desire. additional clarification regarding this correspondence, please contact flichael P. Lee of iny staff. Mr. Lee can be reached at FTS 492-0421.
Sincerely, QRIMAL SIGNED BY John J. Linehan, Director Pepository Licensing and Quality Assurance Project Directorate Division of High-Level Waste llanagement Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
R. Loux, State of Nevada M. Baughman, Lincoln County, NV S. Bradhurst, Nye County, NV D. Bechtel, Clark County, NV C. Gertz, DOE / Nevada K. Turner, GA0 DISTRIBUTION AND CONCURRENCE:
See Next Page
4-Enclosure
SUMMARY
OF STAFF COMMENTS OF THE SF-12 VITRIFICATION RUN AT THE WEST VALLEY DEMONSTRATION PROJECT On October 31.and November 1, 1989, members of the staff from the U.S. Nuclear Regulatory Commission (NRC) met with representatives of the the U.S. Department of Energy (DOE). The meetin Demonstration Project (WVDP)g was arranged by the staff of the West Valley so that it could provide a briefing on its plans and schedules for conducting high-level waste (HLW) glass production to those DOE organizations also involved in HLW glass production. The staff attended at the invitation of DOE's Office of Civilian Radioactive Waste Management (OCRWM).
The principal focus of the briefing was a demonstration of the final full-scale qualification run (designated "SF-12") of the vitrification testing program prior to preparation of the WVDP facility for radioactive glass production.
Such operations are currently scheduled to commence in October 1993.
A list of attendees at this demonstration is given in attachment 1.
No representatives from the State of Nevada or the affected units of local governments attended.
The briefings were conducted by both DOE and DOE's on-site contractor, West Valley Nuclear Services (WVHS).
Following a general. briefing on the HLW vitrification technology being used at WVDP, the attendees were briefed on WVDP's strategy for producing glass that complies with DOE's Waste Acceptance Preliminary Specification (WAPS). Based on the briefings and demonstrations, the staff understood the essential elements of this strategy to include the following:
The definition of an acceptable envelope of glass compositions to meet the pertinent requirements in WAPS.
The development of a Product / Process Control Program sufficient to meet the desired range of target glass compositions.
Reliance on a qualification testing program and integrated test-runs in order to certify the WVDP program prior to the commencement of full-scale operations.
The proper development and implementation of an NRC-approved quality assurance program. contains copies of the presentations that were made on these aspects of the WVDP program.
In addition to the briefings, the staff participated in two tours of the WVDF f acility; one which was general in nature and the other a more detailed tour involving a demonstration of the slurry-fed ceramic melter facility, s
2 During the meeting, DOE and the WVHS contractor asked the attendees for feedback on the briefings and demonstration test run. They requested that specific concerns be documented by the audience in order to focus the forthcoming technical discussions.
It was understood, though, that NRC staff were in attendance at these sessions.only es " observers" and, as such, would not participate in the drafting of any meeting notes nor would the staff concur in them. However, it was understood that the staff would be preparing a trip report which would document the staff's comments regarding the SF-12 briefings and demonstrations.
Based upon the SF-12 briefings and demonstrations, the staff understood the WVDP presentations to be focused to make the case that, based on the research sponsored by DOE.(principally at the Catholic University of Ameriu -- CUA),
there was a solid technical basis for the glass design (composition) selected by WVDP based on durability; and that through its full-scale demonstrations with simulated waste, WVDP could demonstrate that by controlling the composition of the glass melt, they could. assure the quality of the production glass without the need to test the product.
Given this premise, the WVDP staff indicated that the current plan is to rely on " process control" of the feed composition and melter temperature as indicators of glass quality. The WVDP staff noted that this approach, which relies upon previous operational experience, is one which has been used with
. great success by the commercial glass industry. The WVDP staff went on to state that because of this approach, there were no plans to have the capability to test production glass (in a hot cell), either with respect to its properties or composition.
Based on the information presented at the briefings, the staff had two general comments about DOE's proposed approach to the production control of gless composition. The first is that the WVDP briefings did not demonstrate that a credible linkage between the verified performance of glass with simulated waste and production glass with actual waste bas been established.
Consequently, it was not clear if WVDP's process control strategy alone is a sufficient indicator of glass quality and performance. The staff believes that, until the need is demonstrated to the contrary, WVDP develop plans for a testing program to confirm the expected performance of its production glass.-
With regard to the staff's second general comment on WVDP production control, the staff queried the WVDP staff about how production glass that was found to be "out-of-specification" with WAPS would be handled. The WVDP staff stated that it had no plans to develop the capability to rework or reprocess any "out-of-specification" glass. This question was raised by the staff owing to its interest in understanding what plans DOE might have relative to the repository to treat such wastes.
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In a related matter, the staff noted that WVDP intends to archive samples of
. production glass from each pour canister; however, the WVDP staff indicated that there were no plans to perform quantitative tests on the samples. The-staff suggested that~it would be desirable'for WVDP to perform such tests, as
- previously noted, as an independent means of verifying the results of its Product / Process Control Program and expected performance. This would also add confidence to any waste package related performance assessments.
The third staff concern focused on the correlation of the performance allocation for glass in the Site Characterization Plan (SCP) with the WAPS.
One of the stated objectives of the SF-12 briefings and demonstrations was to seek a consensus that high~ quality, durable glass would be produced at WVDP.
u In orcer to reach that consensus, the staff would expect DOE to demonstrate
.what linkace exists between the post-containment performance allocation for glass in the SCP and the radionuclide release rate specification for glass defined in the WAPS.
Based upon the SF-12 briefings and demonstrations, the staff understands that both WVDP and DOE /0CRutt recognize that a correlation of both the WVDP glass design and the MCC-1 leach test in WAPS to the post-containment performance allocation for plass in the SCP has not yet been made. This observation was reinforced in so far that while it was stated that the MCC-1 test was a measure of durability, there was no attempt to demonstrate that this test would meet the perfurmance allocation stated in the SCP. Moreover, in presenting the case regarding CUA's design for " durable" glass, the presentations did nut attempt to show that the CUA design would meet the SCP's post-containment performance
- allocation for glass.
Before WVDP can take credit for producing an acceptable glass, the staff believes.that necessary correlation between the performance allocation for glass in the SCP and the WAPS must be demonstrated.
Through the course of the briefings, the staff also queried DOE on its understanding of the foreign experience in radioactive glass making and
' how that understanding was presently being applied to DOE's glass-making operations. A DOE contractor indicated that DOE had been tracking foreign L
developments in this area for a number of years and that a knowledge of this experience was presently being applied to WAP, to the extent practical.
Moreover, the contractor offered to brief the staff on DOE's assessment of foreign experience in the area of vitrified weste production and how it was being applied by DOE to the WAP.
Additional detailed staff comments are listed in attachment 3.
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3 ATTENDEES AT THE OCTOBER 31 AND NOVEMBER 1,1989 SF-12 VITRIFICATION RUN AT THE WEST ~ VALLEY DEMONSTRATION PROJECT
' DOE-NRC E7 Rengier-37 Bunting D. Shellor*
R. Weller C. Macaluso*
J. Swift
- J. Hale..
D. Hurt
- W. Stringfield
'J. Schiffgens W. Wrzensinski M. Lee C. Conner
- H. Manaktala (CNWRA)
T. Gutmann*
B. Adams (PrecisionAnalytical)
P. LaMout T. McIntosh WVNS C. Enos#
E! RcVay S. Volger (Argonne Nat. Lab.)
D. Shugars D.Eggett(PacificNorthwestLab.)
D. Dempster
- B. Pulsipher'(Pacific Northwest Lab.)
J. Buggy D. McIntosh-(DWPF)
J. Dempston W. Bixby (WVDP)I J. Pope T. Rowland (WVDP)
R. Palmer *
-P. Allen (DWPF)
S. Barnes A.Spooner(Weston)
K. Routt#
M..Plodinec (DWPF)*
M. Henderson 04 Lege' (BDM Corp.)
P. Klaniani K. Hall (DWPF)
- 0. Kruger#
P. tiacedo (CUA)
E. Maestas (WVDP)
NYSERDA0
.N.
Chapman.(DWFF)
F. Lorey W.Ross(PacificNat. Lab.)
S. Harbison A. Schneider (Georgia Tech.)
n Only attended on October 31, 1989.
- Only attended on November 1, 1989.
0 New York State Energy Research and Development Administration
.00E/WVHS PRESENTATIONS AT THE SF-12 VITRIFICATION RUN AT THE WEST VALLEY DEMONSTRATION PROJECT ON OCTOBER 31 AND NOVEMBER l', 1989 TOPIC / PRESENTER Final Agenda for October 31, 1989 Proposed Tour for SF-12 Review Meeting Revised Agenda for November 1, 19E9 WVDP Overview -- W. Bixby SF-12 Meeting Objectives -- E. Maestas UVDP Physical Plant -- J. Buggy WVDP Process Technology and Testing -- J. Pope WVDP Process Technology and Testing:
Backup materials -- J. Pope CUA/VSL Activitics -- P. Macedo Chemical Duratiility of Nuclear Waste Glasses -- P. Macedo Nelter Feed Composition Control -- W. Ross WVDF. Full-scale Testing Results -- S. Barnes Waste Glass Product Control -- M. Plodinec Slurry Feed Makeup -- K. Routt WVDP Quality Assurance -- D. Shugars
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i DETAILED STAFF COMMENTS OF.THE SF-12 VITRIFICATION RUN AT THE WEST VALLEY DEMONSTRATION PROJECT 1.
The staff would also'like to comment on what appeared to be a lack of coordination between DOE /0CRWM and WVDP on certain aspects of the engineered barrier system (EBS) design.
For example, the staff detected inconsistencies in several of the assumptions used to model waste form performance by the WVDP glass producers from-those understood to be used by the DOE /0CRWH waste package material designers. Consequently, the staff are concerned that the decisions on glass weste form and materials selection could be made independently of each other and independently of the assumptions regarding the site-specific conditions at the repository considering anticipated processes and events. The following ex6mples are cited to illustrate the point:
- a. In the discussions-about the conditions expected at Yucca Mountain, the emphasis was on the expected " baseline" conditions at the repository.
The staff dio net detect a strong recognition that post-containment release rate performance under anticipated processes and events, which is required to be demonstrated by 10 CFR 60.113, is part of this baseline.
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- b. To further emphasize this point, during the exchange between DOE and the audience regarding whether water could be present at in the near-field environment temperatures above boiling, it was apparent that the DOE's answer was valid for the assumption of matrix flow.
However, as fracture flow is also likely to occur at Yucca Mountain, DOE needs to demonstrate that fracture flow scenarios have been recognized as part of their I
baseline.
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- c. The NRC staff also understood DOE to say that, as a modeling assumption, all of the waste packages would isolate the glass for 1,000 years, and there was no need to address glass performance until after 1,000 years. The NRC staff believes this assumption is inconsistent with an earlier position taken by DOE's waste package designers in which they were understood to have said that some waste packages will be expected to f ail earlier than 1,000 years.
Moreover, the staff also notes that the DOE waste package materials selection program is faced with somewhat of the same dilemma. However, based on the very i
limited technical interactions to date, the staff perceives an attempt by the DOE waste package designers to deal with the uncertainties in site parameters, l
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' Accordingly, if the necessary site-specific data are not available to assess
- the performance of the various components of the EBS with respect to meeting the post-containment release rate requirement for the EBS, OCRWM may wish to consider conducting more generic tests that cover a wider range of repository environmental conditions before proceeding into glass production, and materials package design-and selection. Absent site-specific data, we believe,that such tests would aid the glass manufacturers in understanding what interactions might occur between the proposed waste form, the waste package, and the repository environment.
2.
The stcff would also like to express its concern for the possibility of an adverse interaction-(e.g., galvanic coupling) between the. glass waste form / pour canister product generated at UVDP and the waste package overpack material, which has yet to be selected. The staff believes that as part of its waste package design, that DOE consider how it will demonstrate that the pour canister /overpack product interaction does not pose en internal threat to
. containment.
- 3..
The staff understnod the WVDP staff to indicate that they only plan to
- test for 25 specific elements in the waste because these 25 elements account for the vast bulk of the total mass in the waste feed. On the other hand, the t;RC staff understood that a 10% variation in each of the 25 elements tested is permissible. The NRC staff recommends that WVDP be prepared to demonstrate that given the resultant maximum permissible variation in total mass balance,
-that no untested elements could be present in sufficient quantities such that they could significantly alter the performance of the production glass.
4.
The staff understood that the water content of commercial glass can vary as much as. tenths of a percent and that this variation can influence glass performance (e.g., durability). As part of its analyses, the staff believes that DOE should understand how variations in the water content of the glass would ultimately influence glass performance and implement the necessary measures in its product / process control program to control such variations to desired levels.