ML20035B132
| ML20035B132 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1993 |
| From: | Gary Comfort NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rowland T ENERGY, DEPT. OF |
| References | |
| REF-WM-3 NUDOCS 9303310184 | |
| Download: ML20035B132 (4) | |
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k.%j NUCLEAR REGULATORY COMMISSION UNITED STATES
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MAR 171993 Mr. Thomas Rowland, Director West Valley Project Office Department of Energy P.O. Box 191 West Valley, New York 14171
Dear Mr. Rowland:
This letter is in response to issues discussed in a February 3, 1993, meeting at Rockville, MD, between U.S. Nuclear Regulatory Commission staff, Steve Ketola of the Department of Energy (DOE), and Dan Meese of West Valley Nuclear Services. For each of the issues discussed, a summary and NRC response is given below.
1:
The West Valley Project Office (WVPO) would like NRC approval for processing both Class A and Class C wastes under one technical evaluation report (TER), so that if the TRU/Pu concentration or ion exchange column efficiency changes, processing will not be interrupted.
RESPONSE
NRC is able to approve, under a single technical evaluation report, solidification processes for both Class A and C waste. However, decisions whether one TEP, is involved are not usually based on a specific waste's classification, but rather on the specific cement formulation that has been qualified for the actual waste stream chemical constituents and concentrations. The Process Control Program (PCP) would have sufficient verification activities (e.g.,
testing) to ensure that the waste stream constituents and concentrations are within the bounding conditions of the qualified formulation, regardless of the classification of the waste being processed.
If the chemical concentrations and ion exchange column efficiencies are changing and going beyond the bounding conditions of the qualified formulation, the solidification process would need to be stopped.
Qualification of a new formulation for the changed waste stream would need to be developed and approved.
Note that Class A waste that is to be placed with Class C waste must meet the Class C stability requirements in 10 CFR Part 61.
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a Thomas Rowland.
2:
WVP0 submitted a summary report covering Phase II (Type I Ordinary Portland Cement with 20% TDS) of their operation. This is a draft version and WVP0 requested NRC input so that the number of DOE 1
revisions cculd be minimized.
RESPONSE
NRC encourages WVP0 to continue to' submit documents for information. and comment. However, in consideration of other licensing issues and program priorities, NRC review and comment of such draft documents will be performed on a time available basis.
In addition, at these early stages only informal NRC guidance and suggestions can be provided.-
3:
WVP0 has expressed concerns over the transition wastes,-which were processed during the time when the waste solidification process moved from supernatant to the first sludge wash. WVP0 would like these initial 200 or so drums of solidified sludge wash to be
" grandfathered" under the supernatant approval.
In-this approach questions about the Branch Technical i
Position (BTP) revision requirements (specifically the immersion test) could more easily be. answered. WVP0 feels that the BTP is inadequate in that it does not explicitly address ssch transition periods.-
The transition drums are considered by DOE different from the initial sludge wash drums in that they include supernatant heels from the exchange columns and Cement Solidification System (CSS) feed tanks.
l The drums are identified by a gradual change in pH i
from 10.5 to 12.5. The initial cemented sludge wash specimens that failed the immersion tests were from the early transition drums.
RESPONSE
Appendix A,Section V of the NRC 8r' anch : Technical' Position on Waste Form states "As. part of process control, mixing of different wastes in holding tanks and transfer of liquid wastes without adequate flushing of lines should generally be avoided, because such mixing.might introduce ingredients into.the waste that were not-present in the qualification testing program that was conducted for the waste stream in question." NRC believes tha.t this BTP section does explicitly cover the situation that occarred in.he West Valley CSS during the transition period.
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Thomas Roaland.
~
The Process Control Program (PCP-001, Section 7.0) submitted by WVP0 for the supernatant indicated pH as a parameter which was to be monitored in the sampling / verification procedure during solidification campaigns. The changes in the chemistry in the tank (e.g., the increasing pH) should have triggered a reassessment of the acceptability of the qualified formulation.
NRC concludes that the transition wastes are different from the supernatant and must be treated as sludge wash. Given DOE's decision to fulfill the requirements of Part 61, it would appear that DOE has several options. WVP0 can provide to NRC additional data or methods that would demonstrate stability as required by 10 CFR 61, or place the " transition" solidified sludge wash in approved high-integrity containers as committed to NRC during the review efforts for the supernatant cement solidification program.
As a follow up to our efforts in review of the supernatant, NRC requests the available results, with your evaluations, of the short-term and long-term testing programs which DOE had committed to complete in its Topical Report submittal and which are described in NRC's Technical Evaluation for the i
solidified decontaminated supernatant.
If you should have any questions, please feel free to contact John Thoma, Section Leader, Technical and Special Issues Section, Low Level Waste Management Branch, Division of Low-Level Waste Management, Office of Nuclear Material Safety and Safeguards at NRC on (301) 504-3450.
Sincerely, ggg Gary C. Comfort, Jr., Project Manager Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety i
and Safeguards TICKET:
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, Thomas Rowland.
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The Process Control Program (PCP-001, Section 7.0) submitted by WVP0 for the supernatant indicated pH as a parameter which was to be monitored in the sampling / verification procedure during solidification campaigns. The changes in the chemistry in the tank (e.g., the increasing pH) should have triggered a reassessment of the acceptability of the qualified formulation.
NRC concludes that the transition wastes are different from the supernatant and must be treated as sludge wash. Given DOE's decision to fulfill the requirements of Part 61, it would appear that DOE has several options. WVP0 can provide to NRC additional data or methods that would demonstrate stability as required by 10 CFR 61, or place the " transition" solidified sludge wash in approved high-integrity containers as committed to NRC during the review efforts for the supernatant cement solidification program.
As a follow up to our efforts in review of the supernatant, NRC requests the available results with your evaluation of the short-term and long-term testing programs which DOE had committed to complete in its Topical Report submittal and which are described in NRC's Technical Evaluation for the solidified decontaminated supernatant.
If you should have any questions, please feel free to contact John Thoma, Section Leader, Technical and Special Issues Section, low Level Waste Management Branch, Division of Low-Level Waste Management, Office of Nuclear Material Safety and Safeguards at NRC on (301) 504-3450.
l Sincerely, Gary C. Comfort, Jr., Project Manager Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards TICKET:
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NO Delete file after distribution:
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