ML20042G634
| ML20042G634 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1989 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20042G626 | List: |
| References | |
| REF-WM-3 PROC-890630, NUDOCS 9005150185 | |
| Download: ML20042G634 (23) | |
Text
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LLWM ADMINISTRATIVE PROCEDURE FOR THE REVIEW OF TOPICAL REPORT 5 l
RELATED TO THE IMPLEMENTATION OF 10 CFR PART 61 JunFi071989 A.
Purpose:
This procedure establishes the guidelines for the NRC review of topical reports on Classes B and C solidified waste formulations, high integrity containers (HICs), and waste classification computer codes, B.
Background:
i To meet 10 CFR 20.311(d),10 CFR 61.55, and 10 CFR 61.56, waste generators and waste disposal operators need to demonstrate compliance with the waste classification and waste form requirements. One acceptable a reference topical reports reviewed and approved by NRC staff.pproach is-to A to report is a document submitted by an industry organization (vendor)pical for.
review by the-NRC outside of a specific licensing action.
The advantages of the topical report review are as follows: (1) it provides a single review consistent with the 10 CFR Part 61 requirements and with NRC technical positions; (2) it reduces burden on State ~ regulatory agencies; (3) it reduces burden on issuing license-conditions and inspections; and (4) it increases user knowledge of the acceptability of specific solidification formulations, HICs and waste classification computer codes.
C.
Responsibilities:
i 1.
The Division of Low-Level Waste Management and Decommissioning.(LLlet):
i a.
Has responsibility for the review of topical reports on solidified stable waste forms, HICs and classification codes.
l The reviews use 10 CFR Part 61 requirements and criteria contained in LLWM technical positions on waste-form and waste.
classification and other related documents.
b.
Provides technical assistance through the State, Local & Indian Tribe Programs (SLITP) to Agreement States that receive applications for topical report approval. Through this mechanism, LLWM has the lead responsibility for the technical review of the application and preparation of an evaluation report.
c.
Publishes its evaluation findings in a Technical Evaluation Report (TER) issued for each topical report that is reviewed to completion. The TER is used as the basis for certificates of compliance and other approvals of the topical reports.
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i 1
. KM/WM ADMINISTRATIVE' PROCEDURE
! I d.
Provides to the' Agreement States (thru SLITP) the official rounds of staff questions.and comments on the topical reports.
Vendor's responses are also provided to the States.
Provides~the i
Agreement States an advanced copy of the final TER two weeks.
prior to publication.
e.
Takes -into consideration during the staff's review any concerns submitted in a timely-fashion to LLWM by the States regarding.
.the rounds of questions and responses between LLWM and the i
vendors.
Transmittal of the advanced TER to the States is for informational purposes only.
f.
Assigns a Project Manager for each topical report review. The-I assigned Project Manager is responsible for recommending to LLWM management either acceptance or rejection of specific topical l
reports submitted to the NRC for "eview.
The final acceptance decision.is made by management.
When a report is accepted the t
l-Project Manager is responsible for directing and monitoring the i
staff-review and for all liaison and correspondence between the-NRC staff and the vendor.
L 2.
State, Local & Indian Tribe Programs'(SLITP):
[
a.
Coordinates all reviews between LLWM and Agreement States.
)
K t
b.
Distributes all documents between LLWM and Agreement States.
l c.
Provides assistance to LLWM in determining the timing of actions l
involving the Agreement States, l
h 3.
The participating Agreement State:
a.
May request technical assistance from NRC for topical report applications dealing with implementation of 10 CFR Part 61.
NRC's.SLITP will be the focal point for coordination.
4 E
b.
.May provide questions and comments to LLWM regarding LLWM's questions to the vendors and the vendor's responses.
While State's comments will be considered by NRC, the State's review 1s not part of the critical path review of the topical report.
c.
Issues certificates of compliance for products found acceptable for use at the State's commercial disposal f acility on the basis of NRC's TERs and any additional State requirements that need to be met.
Copies of certificates are provided to the NRC.
l l
x-KM/WM ADMINISTRAT!YE PROCEDURE 3
d.
Takes prompt action to implement restrictions, limitations and/or rejections of products consistent with NRC findings.
D.
Procedure:
1.
Vendors should submit copies of their topical reports to NRC's Docket ~
Control Desk (DCD).
Reports should be in the form of hard copies.
Submittals shall be in the following quantities with the understanding that additional copies will be made available to the staff upon request.
The number of hard copies required from the vendor are broken down below:
Non. Proprietary Proprietary Retained by DCD 4
2 NRC staff 3
3
.SLITP-3 3
NRC contractors 3
3 TOTAL ---
13 11 All topical reports submitted must be accompanied by.an initial review fee consistent with 10 CFR Part 170 and will be treated as a fee. recoverable review.
2.
Upon receipt, the DCD retains their copies and forwards remaining copies to the LLWM Engineering Section, Section Leader.
The DCD forwards the initial fee to the Licence Fee Management Branch for processing.
3.
The Section Leader assigns a Project Manager to the review.
4.
The Project Manager performs an Acceptance Review by reviewing the contents of the report to determine if adequate information has been provided-to perform a review.
The Technical Positions on Waste Classification and Waste Form and other related documents should be used as guidance. In addition, the following criteria should be met:
a')
The report should deal with specific solidification formulations used for solidifying low-level radioactive waste streams that are typically found at nuclear facilities, HICs, and classification codes, which can be evaluated independent of any specific license application.
.o 3?
.KM/WM ADMINISTRATIVE PROCEDURE -
-b)-
The report should contain complete and detailed information on the specific subject presented.
Conceptual or incomplete
^t preliminary information will. not be reviewed, c)
Approval of the report must result in increased efficiency of the. review process for disposal site approval of solidification t
L.
formulas, HICs, or classification codes.
l.
5.
If the submittal fails the Acceptance' Review the Project Manager.
shall provide guidance to the DCD on the appr,opriate actions the DCD should-take regarding the LLWM file copies of the topical report and shall also notify the vendor, vie letter, of the rejection.of the
(
topical report.' Deficiencies resulting in rejection.should be brought forth in the letter in order to help vendors make corrections for their resubmittal.
The Project Manager's copies of the topical report shall also be disposed of properly.
6.
If the submittal passes the' Acceptance Review, the Project Manager requests a new project file number for the review from the DCD. The
-i non-proprietary portions of _the topical report and all related non-proprietary correspondence will be sent' to the NRC Public i
. Document Room (PDR) by the DCD.
7.
The Project Manager sends a copy of the incoming topical report cover letter from the vendor to the Program Analysis. Branch for casework-t setup. An~NMSS PPSAS number is assigned to the review in order to-record and track all staff review efforts.
s 8.
The Project Manager prepares a letter,to the vendor acknowledging acceptance of the topical report for review. A proposed schedule for the review of the topical report shall be included in the acceptance letter.
The Project Manager informs the vendor of the new file number assigned to the review and requests.that the vendor clearly mark all correspondence related to the review with the file number. All correspondence, originals and/or copies, must be entered into the DCD
- system, p
1 L
9.
If proprietary information is claimed by the vendor, the NRC staff, o
during the course of the review, treats the inf tion as proprietary under the provisions of 10 CFR 9.
- 4) and will notify the the vendor.
1 4.Obh
q KM/WM ADMINISTRATIVE PROCEDURE j 1
The Project' Manager establishes a control co)y log for all proprietary topical report copies submitted ay the vendor.
- 10. 1The Project Manager prepares a memorandum requesting SLITP to send the topical report to the Agreement States.
The Project Manager i
provides SLITP with copies of the report for transmittal, i
11.
The Project Manager, if reqcired, prepares a letter requesting technical assistance from ut.her NRC groups and/or outside contractors.
2 12.
The Project Manager performs and coordinates among the' appropriate individuals in LLWM and outside contractors a technical review based
-on NRC criteria.
l l
13.
The' Project Manager receives comments from the NRC staff and/or contractor and prepares the first round of comments and requests for
}
L additional information (RAI #1) for the vendor.-
L 14.
The Project Manager prepares a letter transmitting RAI fl. to the -
vendor, requiring a response within 30 days.
15.
The Project Manager prepares a. memorandum requesting SLITP to send RAI #1 to the Agreement States in order to afford them the opportunity to comment.
States' comments are considered _in the review if received in'a-timely fashion.
- 16.,If the vendor's responses adequately resolve the consnents, go-inmediately.tc the next step.
If the responses are inadequate, a l
second set of comments (RAI #2) is prepared and transmitted to the vendor requiring a response within 30 days.
This step is repeated L
until the NRC comments are resolved.
As with RAI fl. the States are provided with subsequent RAIs in order to comment.
Two rounds of questions are expected.
Additional rounds are not recommended.
NRC may discontinue the topical report if excessive delays occur in response to NRC comments.
17.
The Project Manager prepares a TER. The TER shall indicate that the topical report and all supplemental submittals have been reviewed.
Conclusions shall be presented stating whether or not the 10 CFR Part
s.
4 KM/WM ADMINISTRATIVE PROCEDURE i t
(1 requirements have been met and if there is consistency with the
[
guidance-presented in the technical positions.
18.
The Project Manager prepares a memorandum requesting SLITP to send an advanced copy of the TER to the States. for information.only, two.
weeks _ prior to sending to the vendors.
19.
The Project Manager prepares a letter to the vendor transmitting-the TER and stating the conclusions of the review, i.e., approved..
L disapproved, conditionally approved, etc.
If approval is granted.
the vendor is requested to make the necessary revisions to the final L
L topical report.'
20.
The vendor revises the topical report, incorporating the TER, within 60 days from receiving the lett.r in step fl9 and transmits the final 1
proprietary and non-proprietary versions to the NRC.
The Project Manager reviews these-documents within 30 days of receipt to ensure l
that all the required changes have been incorporated.
If changes have not been incorporated as previously agreed,- the Project Manager requests the vendor to make the necessary modifications, a
l 21.
The Project Manager shall inform the DCD and the Program Analysis Branch that the review is now closed.
t E.
Document Concurrence:
Key steps resulting in written documents requiring concurrence are listed below.
Step #
Document Description LLWM Signature Authority 5
Rejection letter Director 8
Acceptance letter Section Leader-10 Memo - Topical to States Branch Chief 3
14 Letter - RAI #1 to vendor Section Leader 15 Memo - RAI #1 to States Branch Chief
)
.b~
6
- KM/WM ADMINISTRATIVE PRCCEDURE 16-Letter - RAI #2 to vendor Section-Leader 16 Memo - RAI #2 to. States-Branch Chief 18 Memo - TER to States.
Branch Chief 19 Letter - TER to vendor Section Leader F.
Fees:
A system to account for staff review time and technical assistance services has been initiated for the topical report reviews in a manner similar to the NRR accounting system for topical report reviews.
Fees charged will be consistent with 10 CFR 170.31.
The Staff Input Report will be used to track' staff time s ant on each topical report.
Actual hours should be charged against tie correct PPSAS numbers.
Milestones to'be used are listed below with their corresponding review steps.
The number of milestones have been kept to a mininum (6) for simplicity sake, however, all of the review steps have been incorporated.
Milestone #
Description Review Step 1
Acceptance Review 1-10 2
Complete'RAI #1 11-15 3
Complete RAI #2
.6 4
Complete TER 17-18 5
Revise Topical Reports 19-20 6
Closecut Review 21 v.
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f U.S. NUCLEAR REGULATORY COMMISSION LOW-LEVEL WASTE MANAGEMENT RELATED NUREG REPORT 5 r
BRANCH TECHNICAL POSITIONS AND ORAFT REGULATORY 69 IDES The following reports may be ordered from:
Public'DocumentRoom(PDR)
US NRC~
Washington, DC 20555 -
(202)634-3273 Letter or telephone requests are accepted. There is a copying fee for each cocument.
For price information, call the PDR.
i WM-7902 Low-Level Waste Burial Ground Site Closure.& Stabilization,
>I Revision 1, May 1979.
WM-8204 Technical Position--Waste Form, May 1983.
WM-8205 Technical Position on Radioactive Waste Classification, May 1983.
s WM-8206 Fcnding Assurances for Closure, Postclosure and Long-Term Care of a Low-Level Waste Disposal Facility, June 1982.
F-WM-8207 Near-Surface Disposal Facility Design and Operation, November 1982.
WM-
-Environmental Monitoring, draft-issued November 1987.
C WM-408-4 Final Regulatory Guide for Selecting Sites for Near-Surface
~
Disposal of Low-Level Radioactive Was';e, August,1988 WM-Draf t Regulatory Guide on Waste' Form Stability, August 1987.
l NUREG DOCUMENTS-l.
PERSONS OUTSIDE NRC MAY OBTAIN SUBSCRIPTION INFORMATION OR SPECIFIC REPORTS BY WRITING TO THE FOLLOWING ADDRESS.
(" DRAFT" REPORTS ARE FREE; " FINAL" REPORTS MAY BE PURCHASED.)
L Superintendent of Documents I
h U.S. Government Printing Office l
P.0 Box 37082 Washington, D.C.
20013-7082 202/275-2060 or 2171 L
ATTN:
Ann Butler 1
PERSONS WITHIN NRC MAY OBTAIN REPORTS BY CALLING EXT. 27333.
GENERAL L
Final Environmental Statement. Transportation of L
Radioactive Material by Air and Other Modes, 12/77 NDREG-0300 -
Proposed Goals for Radioactive Waste Management, 5/78 1
88/09/06 NUREG-0412 -
Essays on.lssues Relevant to Regulation of Radioactive =
Waste Management, 5/78 NUREG-0527 -
Regulation of Federal Radwaste Activities and Summary, 2/79; for B-2270 NUREG-0539 -
Means for Improving State Participation in the Siting, Licensing and Development of Federal Nuclear Waste Facilities, A Report to-the Congress.-3/79-(by OSP) llVREG-1213 -
Plans and Schedules for Implementation of U.S. Nuclear Regulatory Commission Responsibilities Under the Low-Level Radioactive Waste Policy Amendments Act of 1985 (P.L.99-240)
Compilation of Contract Research for the Chemical Engineering Branch, Division of Engineering Technology Annual Report for FY 1985,.7/85,7/85 C NUREG-1243'-
Ground-water Protection Activities of the USNRC, 2/87 NUREG/CR-0028 --
Institutional Radioactive Wastes, 3/78 NUREG/CR-1137 -
Institutional.Racioactive Wastes 1977, 10/79, for B5959 NUREG/CR-3959 -
Transition to an Operating Environment --Implications for NRC Quality Assurance Programs Based on Nuclear Power Industry and Regulatory Projections Through 1995,3/86 (PNL-5769)
O I4UREG/CR-4555 -
Generic Cost Estimates for the Disposal of Radioactive Wastes, 3/86 LOW-LEVEL-WASTE-NUREG-0172 -
Age-Specific Radiation Dose Commitment Factor for a One-year Chronic Intake,'11/77 NUREG-0217 -
NRC Task Force Report on Review of the Federal / State Program for Regulation of Commercial Low-level Radioactive Waste Burial Grounds, 3/77 NUREG-0456 -
A Classification System for Radwaste Disposal-What Waste Goes Where? 6/78 NUREG-0782 -
Draft Environmental Impact Statement on 10 CFR Part 61:
Licensing Requirements for Land Disposal of Radioactive Waste (Vols. 1 - 4), 9/81 NUREG-0868 -
A Collection of Mathematical Models for Dispersion in Surface Water and Groundwater, 6/82 0 NUREG-0879 -
Environmental Assessment for the Barnwell Low-Level Waste Disposal Facility, 1/82 l
l 2
l
_ _ - ~
)
'f 88/09/06 NUREGIO902 --
Site Suitability, Selection and Characterization ' Branch 4
_ Technical Position --Low-Level Waste Licensing Branch, 4/82 o? NUREG-0945 -
Final Environmental Impact Statement on 10 CFR Part 61:
Licensing Requirements for Land 01sposal of Radioactive Waste (Vols. 1 - 3), 11/82 HUREG-0959 -
User's-Guide for 10 CFR 61 Impact Analysis Codes,1/83 4
c: ~ NUREG-0962 -
The Role of the State in the Regulation of Low-Level.
R6dioactive Waste, 3/83 o NOREG-1101 -
On-site Disposal of Radioactive Waste:
Vol. 'l - Guidance for Disposal by Subsurface Burial, 3/86 y
Vol. 2 - Methodology for the Radiological Assessment of Disposal by Subsurface Burial, 2/87 Vol. 3 - Estimating Potential Groundwater Contamination, 12/86 f
i NUREG-1183_-
Nonradiological Groundwater Quality at Low-Level j
Radioactive Waste Disposal Sites, 5/86 L
.NUREG-1199 -
Standard Format and Content of a License Application for a l
REV.1-Low-Level Radioactive Waste Disposal Facility,1/88 l
SRP for the Review of-a License Application for a Low-Level-REV.1 Radioactive Waste Disposal Facility, 1/88 o NUREG-1213 -
Plans and Schedules for implementation of U.S. Nuclear REV.1 '
Regulatory Commission's Responsibil'ities Under the low-Level Radioactive Waste Amendments Act of 1985 (P.L.99-240), 8/87 0 NUREG-1241 -
Licensing of Alternative Methods of Disposal of Low-Level Radioactive Waste, 1/87 NUREG-1268 -
Staff Analysis of Public Comments on ANPRM for 10 CFR 30.40 3
61,70,and72(accidents),9/87-NUREG-1300 -
Environmental Standard Review Plan for the Review of a License Application for a low-Level Radioactive Waste Disposal Facility, 4/87 NUREG/CP-0028 -
Proceedings of the Symposium on Low-Level Waste Disposal:
Vol.1--Site Suitability Requirements, 9/82, Vol. 2--Site Characterization and Monitoring,12/82 Vol. 3 -Facility Design, Const uction, and Operating Practices, 3/83 NUREG/CP-0030 -
Symposiur. en Unsaturated Flow and Transport Modeling, 9/82 c NUREG/CP-0055 -
Proceeding of the State Workshop on Shallow Land Burial and Alternative Concepts, 10/84
~NUREG/CP-0085 --
Meeting with States in the Low-Level Radioactive Waste Policy Amendments Act (LLRWPAA) of 1985, 2/87 3
88/09/06-
/
Technology, Safety and Costs of Deconsnissioning-A Reference Pressurized Water Reactor Power Station Classifi-s cation of Decommissioning Wastes NUREG/CR-0308 -
Screening of Alternative Methods for Disposal of Low-Level Radioactive Wastes, 10/78 NUREG/CR-0456 -
A Classification System for Radioactive Waste Disposal
-What Waste Goes Where? Characterization of the Class B Stable Radioactive Waste of the Union Carbide Corporation 11/83 NUREG/CR-0570 -
Technology, Safety, and Costs of Decomissioning a Reference Low-Level Waste Burial. Ground, 6/80 C) NUREG/CR-0680 -
Evaluation of Alternative Methods for Disposal of Low-Level-Radioactive Wastes, 7/79 NUREG/CR-0707 -
Evaluation of Isotope Migration-Land Burial, Water-Chemistry at Commercially Operated Low Level Radwaste Disposal Sites, Progress Rept 9, Apr-June 1978, 2/79 NUREG/CR-1005 -
Radioactive Waste Disposal Classification System (Vol. I --
t General, Vol. II - Detailed), 9/79 I
Evaluation of Isotope Migration, Land Burial, 9/79 NUREG/CR-1167 -
Evaluation of Isotope Migration, Land Burial, 9/79.
Evaluation of Isotope Migration-Land Burial: Water-Chemistry at Commercially Operated Low Level Radwaste Disposal Sites, 3/80 NUREG/CR-1325 -
Evaluation of Isotope Migration:
Land Burial, 12/79.
'O NUREG/CR-1358 -
Vegetational Cover in Monitoring and Stabilization of Shallow Land Burial Sites, Annual Report for 10/78-9/79, 8/80 NUREG/CR-1513 -
Evaluation of Isotope Migration-Land Burial Chemistry at Comercially Operated Low-Level, 5/80 l
A General Investigation of Radionuclide Retention in l
Migration Pathways at West Valley, New York Low Level Burial Site.
Final Report 10/78-2/80,10/80 NUREG/CR-1683 -
Characterization of Existing Surface Conditions at g
l Sheffield Low Level Waste-Disposal Facility.
Final Report for 7/80, 7/80 o
Data Base for Radioactive Waste Management (Vols. 1, 2, r
dnd 3), 11/81 NUREG/CR-1793 -
Study)of Chemical Toxicity of low-Level Wastes (Vols.1 and 2, 11/80 1
L h
4
z, 88/09/06' NUREG/CR-1832 -
Research. Program at' Maxey Flats and Consideration of Other Shallow Land Burial Sites. 3/81 NUREG/CR-1862 -
Evaluation of Isotope Migration-Land Burial, 4/81 NUREG/CR-1963 System Analysis )f Shallow Land Burial, Vols. 1-3, Vol. 1 - Code Manual, Vol. 2 -' Technical Background, 3/81 1
Evaluation of Trench Subsidence and Stabilization at Sheffield Low-Level. Radioactive Waste Disposal Facility, 5/81 NUREG/CR-2192 -
Evaluation of Isotope Migration-Land Burial'5/62 NUREG/CR-2206 Volume Reduction Techniques in LL Radioactive Waste, 9/81' NUREG/CR-2212 -
An-Evaluation of Ground Penetrating Radar for' Assessment of Low Level Nuclear Waste Disposal Sites, 2/82 NUREG/CR-2383 -
Radionuclide Distributions and Migration Mechanisms-at' Shallow Land Burial Sites, 7/82 O
A Study of Trench Covers to Minimize Infiltration at Waste Disposal Sites, Vol.1-Task I 3/82, Vol. 2-Task.II 7/83:
s
Users Guide ano. Documentation for Adsorption and Decay Modif.ications to the USGS Solute Transport Model, 1/82 NUREG/CR-2589 -
.A Ground Penetrating Radar Survey of the Maxey Flats low Level Nuclear Waste Disposal Site, Fleming County, Kentucky, 6/82 A
Evaluation of Isotope Migration-Land Burial, 5/82, i
Parameters for Characterizing Sites for Disposal of
'i Low-Level Radioactive Waste, 5/82-n i
Training Course No.1:
The Implementation of Femwater (0RNL-5567)ComputerProgram,6/82 NUREG/CR-2706 --
Training Course No. 2: The Implementation of FEMWASTE Computer Program:
Final Report, 11/82-NUREG/CR-2721 -
Scoping Study of the Alternatives for Managing Waste Containing Chelating Decontamination Chemicals, 2/84-q NUREG/CR-2785 -
Irradiation of Zeolite Ion-Exchange Media,.5/83 NUREG/CR-2808 -
GWNBL'1:
A Computer Model for Groundwater Transport of Radioactive Isotopes and Dose Rate Calculation, 11/83 O NUREG/CR-2813 --
Development of Low Level Waste Form Criteria Testing of Low-Level Waste Forms, 11/83 5
88/09/061
Permissible Radionuclide Loading for Organic lon Exchange
~
Resins from Nuclear Power Plants, 9/83
_NUREG/CR-2862'--
Geomorphic Processes and Evolution of Buttermilk Valley and Selected Tributaries,_ West Valley, New York, 7/82 NUREG/CR-2870 -
Characterization of'the Radioactive Large Quantity Waste
.of the Union Carbide Corp., 11/83
Review of Ground-Water Flow and Transport Models in the Unsaturated Zone, 11/82 NUREG/CR-2969 -
Solidification of Irradiated EPICOR-Il Waste Products, 5/83 NUREG/CR-2977 -
Tests of Absorbents and Solidification Techniques for Oil Wastes, 11/83 NUREG/CR-3018 -
Characterization of Class B Stable Radioactive Waste Packages of the New England Nuclear Corporation,12/83 NUREG/CR-3032 -
Studies of Transport of Waste Radionuclides through Soil at the Maxey Flats, Kentucky, Waste-Burial Sites, 3/83 NUREG/CR-3038'-
Tests for Evaluating Sites for Disposal of.LLW, 12/82 O NUREG/CR-3084 -
Low-Level Nuclear Waste Shallow Land Burial Trench Isolation,3/83 NUREG/CR-3125 -
Current Practices for Maintaining Occupational Exposures ALARA at Low-level Waste Disposal Sites, 12/83
Influence of Leach Rate and Other Parameters on Groundwater -
Migration,2/83 o : NUREG/CR-3144 -
Trench Design and Construction Techniques for Low-Level Radioactive-Waste Disposals ;/83 NUREG/CR-3164 -
Subsurface Monitoring Programs at Sites for Disposal of Low-Leve1' Radioactive Waste, 4/83 0'NUREG/CR-3168 -
Technical Considerations for High Integrity Containers for the Disposal of Radioactive Ion-Exchange Resin Waste, 10/83 NUREG/CR-3207 -
Geologic and Hydrologic Research at the Western New York Nuclear Service Center, West Valley, New York.
Annual Report.
8/81-7/82,3/83
A Sunnary of Computer Codes for Radiological Assessment, 3/83 NUREG/CR-3210 -
Low-Level Waste Risk Methodology Development, 5/83 NUREG/CR-3332 -
Radiological Assessment:
A Textbook on Environmental Dose Analysis, 9/83 l
l l
6
~^
~
~
~-
~
^
~ ~ ~
g 88/09/06 i
Recomendea Radiation Protection Practices for LLW Disposal Sites o
o NUREG/CR-3356 -
Geotechnical Quality Control:
Low-Level Radioactive Waste and. Uranium Mill Tailings Disposal Facilities, 6/83 NUREG/CR-3381 -
Evaluation of the Three Mile Island Unit 2 Reactor
-Building Decontamination Process, 8/83 1
Irraciation Effects on the Storage and Disposal of Radwaste Containing Organic lon-Exchange Media, Topical Report -4/84 NUREG/CR-3390 -
. Documentation and User's Guide:
UNSAT2 - Variably
[
Saturated Flow Model (Including 4 Example Problems);-
t NUREG/CR-3444 -
The lmpact of LWR.Decontaminations on Solidification I
Waste Disposal and Associated Occupational Exposure,
(Vol. 1 & Vol. 2), Annual Report, 2/84, 8/9/85; NUREG/CR-3554 -
Radionuclide Migration in Groundwater.
Annual Progress Report for 1982,1/84; 0' NUREG/CR-3570 -
Low-Level Nuclear Waste Shallow Land Burial Trench Isolation, Annual Report 10/82-9/83,12/83; l
Vol.1 - De Minimis Waste Impacts Analysis Methodology, 2/17/84, vol. z - De Minimis Waste Impacts Analysis Methodology:
IMPACT 5 - BRC User's Guide and Methodology for Radioactive Waste Below Regulatory Concern, 9/29/86 1
Intruder Dose Pathway Analysis for the Onsite Disposal of Radioactive Waste, 12/6/84; Supp. 1 Intruder Dose Pathway Analysis for the Onsite Disposal of Radioactive Wastes:
4 The 0NSITE/MAXIl Computer Program, 2/87 NUREG/CR-3712 -
Radionuclide Migration in Groundwater.
Annual Report for FY 1983, 12/84 NUREG/CR-3774 -
Alternative Methods for Disposal of Radioactive Wastes
}
!Vol.1-Task 1:
Description of Methods and Assessment-of l
j Criteria,5/84
/Vol. 2-Task 2a:
Technical Requirements for Belowground-Vault Disposal of Low-Level Radioactive Waste, 12/85 Vol. 3-Task 2b: Technical Requirements for Aboveground Vault Disposal of Low-Level Radioactive Waste, 12/85
/Vol. 4-Task 2c: Technical Requirements for. Earth Mounded Concrete Bunker Disposal of Low-Level Radioactive Waste, 12/85 Vol. 5-Task 2e:' Technical Requirements for Shaft Disposal of Low-Level Radioactive Waste, 12/85 Vol. 6-Alternative Methods for Disposal of Low-Level Radioactive Wastes:
Task 2d--Technical Requirements for Mined-Cavity Dispaal of Low-Level Waste,12/86 7
o 88/09/06-NUREG/CR-3838'-
An. Initial Review of Several Meteorological Models Sultable for Low-Level Waste Disposal Facilities, 6/84 NUREG/CR-3865 -
Evaluation of the Radioactive Inventory in and Estimation of Isotopic Release'from, the Waste in Eight Trenches at tne Sheffielo Low-level Waste Burial Site, 1/85 0-NUREG/CR-3973 -
Alternative Containers for Low-Level Wastes Containing Large Amounts of Tritium, 1/85
- NUREG/CR-3985 -
Organic Complexant-Erhenced Mobility of Toxic Elenents in Low-Level Wastes, Annual Report 7/83 - 6/84, dtd 11/84-NUREG/CR-3993 -
Geochemical Investigations at Maxey Flats Radioactive Waste Disposal Sites, 10/84 NUREG/CR-3994 -
Bury it/Analyz, 11/84 NUREG/CR-4030 -
Radionuclide Migration in Groundwater, 3/85 NUREG/CR-4062 -
Extended Storage of Low-Level Radioactive Waste:
Potential Problem Areas, 12/84 NUREG/CR-4069 -
Analyses of Soils From an Area Adjac6nt to the Low-Level Radioactive Waste Disposal Site at Sheffield, Illinois.
3/85 0 i NUREG/CR-4083 -
Analyses of Soils From the low-Level-Radioactive Waste Disposal Sites at Barnwell, SC, and Richland, WA, 3/85 NUREG/CR-4150 -
EPICOR-Il Resin Degradation Results from First Resin Samples of PF-8 and PF-20, 8/85 o NUREG/CR-4201 -
Thermal Stability Testing of Low-level Waste Forms, 5/85 NUREG/CR-4370 -
Update of Part 61 Impacts Analysis Methodology:
Vol. 1, Methodology Report and Vol. 2, Codes and Example Problems, 1/86 NUREG/CR-4406 -
An Analysis of Low-Level Wastes:
Review of Hazarcous
-Waste Regulations and Identification of Radioactive Mixed Waste, 2/86 NUREG/CR-4433 -
Document Review Regarding Hazardous Chemical Characterittics of Low-Level Waste, 3/86 NUREG/CR-4450 -
' Management of Radioactive Mixed Waste in Comercial Low-Level Wastes:
Draf t Report for Coment, 2/86 HUREG/CR-4592 -
Leaching of Solutes from lon-Exchange Resins Buried in-Bandelier Tuff, 12/4/86 NUREG/CR-4498 -
Field Testing of Waste Forms Containing EPICOR-Il Exchange Resins Using Lysimeters, 7/86 l
8 l
4 '-
y
_08/09/06 NUREG/CR-4601;-
Technical Considerations Affecting Preparation of lon-Exchange Resins for Disposal, 6/86 NUREG/CR-4608'-
EPICOR-Il Resin Degradation Results from Second Samples of-PF-8 and PF-20, 12/86 HUREG/CR-4615 -
Modeling Study of Solute Transport in the Unsaturated Zone:
Information anc Data Sets Vol. 1, 7/86-NUREG/CR-4622 -
Validation of Stochastic Flow and Transport Models for a
Unsatureted Soils: A Comprehensive Field Study, 9/86 NUREG/CR-4637 --
EPICOR-!! Resin Waste Form Testing,11/6/86 o NUREG/CR-4640 -
Handbook of Sof tware Quality Assurance Techniques Applicable to the Nuclear Industry, 8/87 NUREG/CR-4644 -
Geochemical Studies of Commercial Low-Level Radioactive Waste Disposal-Sites, 6/86 NUREG/CR-4701 -
Safety Assessment of Alternatives to Shallow Land Burial of Low-Level Radioactive Waste.
(EGG-2465)
/Vol.1 - Failure Analysis of engineered Barriers, Au.86.
Vol. 11 - Environmental Conditions Affecting Reliabi ity of Engineered Barriers, Sept. 87 NUREG/CR-4709 -
Release of Organic Chelating Agents from Solidified Decontamination Wastes, 7/86 NUREG/CR-4720 -
Compilation of Field-Scale Caisson Data on Solute Transportation in the Unsaturated Zone, 12/86 NUREG/CR-4879 --
Demonstration of Performance Modeling of a Low-Level Waste Shallow Land Burial Site; etc Chalk River Nuclear Labs, Vol 1, 11/87 NUREG/CR-4897 -
Low-Level Waste Source Term Evaluation:
Review of Published Modeling and Experimental work, and Presentation of Low-Level Waste source Term Modeling Framework and Pre-liminary Model Development, 2/87 6 NUREG/CR-4918 -
Control of Water Infiltration into near Surface LLW Disposal Units, Vol 2, 3/88 NOREG/CR-5401 -
Recommendations to the NRC for Review Criteria for Alternative Methods of Low-level Radioactive Waste
- Disposal,
/yol 1 - Task 2a:
Below-Ground Vaults, 12/87 Wol 2 - Task 2b:
Earth-Mounded Concrete Bunkers, 1/88 M NUREG/CR-5054 -
Recommendations to the NRC'for Review Criteria for Alternative Methods of Low-Level Radioactive Waste Disposal, 7/88 i
9
m
- c 88/09/06:
0THER LOW-LEVEL WASTE REPORTS EXTERNAL TO HRC
- AECL-TR-314.
~ '
Preliminary Analysis of Seismic Concerns for the Siting of a Shallow Land y
- Burial-Facility At.
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. Ontario.
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. Proceedings of the-Workshop on Corrosion of LLW and ILW Containers, Harwell Laboratory, United Kingdom Atomic Energy Authority, Nov. 87
.ANL/EES-TM-344 Assessing Waste Management Systems Using Reginalt Software, March 88 ANL/EIS-17 Scoping Survey-of Perceived Concerns, Issues, and Problems for Near-Surface-Disposal of FUSRAP Waste, December 82 ANS-TN-J249-1 The Development of Biosphere Codes for Use in Assessment of the Radiological Impact of Geological Repositories for Radioactive Waste, December 82 ANS-TN-J249-3 SIOM00 - Preliminary Findings, by P. Kane, Associated Nuclear Services, June 83 ANS-318.
User's Guide to the Biosphere Code.BIOM00, May 83 ANS-319 Database Description for the Biosphere code BIOMOD,-March 83 BNL-NUREG-32070 Evaluation of Isotope Migration-Land Burial: Water Chemistry.
- Pietrzak,
' R. F.;. Dayal, R. (Brookhaven National Lab, Upton, NY (USA)).
Oct 82. 18p.
l BNWL-1754 Models and Computer Codes for Evaluating Environmental Radiation Doses, February 74' CFR', Section 10 i
Code of Federal Regulations, Part 500 to end, January 88 CONF-810217-4 Presto Low-Level Waste Transport and Risk Assessment Code.
Little, C.A..
et al.-
(Oak Ridge National Lab., TN (USA)).
1981. 14p CONF-810730-1
. Low-Level Waste Shallow Burial Assessment Code.
Fields, D.E.; Little, C.A.,
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((0ak Ridge National Lab., TN (USA)).
1981. 6p.
CONF-820303-20 Shallow-Land Burial of Low-Level Radioactive Wastes:
Preliminary Simulations of Long-Terin health Risks.
Fields, D.E.; Little, C.A., Emerson, C.J.,
Hiromote, G. (Oak Ridge ~ National Lab., TN (USA)).
1982. 15p.
I 10 i
e 88/Q9/06:
LCONF-8308106 Proceedings ~of the Fifth Annual Participants' Information Meeting:
DOE-Low-Level Waste Management Program.
((EG & G Idaho, Inc., ID (USA)).
-December 1983. 799p.
CONF-831047-49 Benefit-Cost-Risk Analysis of Alternatives For Greater-Confinement Disposal Waste. -Gilbert,-T.L.; Luner, C.; Peterson, J.M., (Argonne National Lab., IL (USA)). -1983. 6p.
' CONF-8509121 Proceedings of the Seventh Annual Participants' Information Meeting. DOE Low-Level Waste Management Program..(EG & G laaho, Inc., ID (USA)).
Feb 1986.
.927p.
CONF-860990 Weste-Acceptance Criteria for Greater-Confinement Disposal. Gilbert, T.L.,
Meshkov, N.K. -( Argonne National Lab., IL (USA)).
1986. 16p.
'DE83-005411 L
tow-Level Radioactive Waste Management Handbook Series Environmental Monitoring.
L For Low-Level Waste-Disposal Sites, Januray 1983 L
00E/ TIC-27601 l.
- Atmospheric Science and Power Production, July 84 DOE-RW-85.159 Optimisation of Radioactive Waste Management Systems Using Weighted Measures of
' Economic and Radiological Impact.
Dalrymple, G.J. and others.
CAP' Scientific Ltd., London (UK).
3 Nov 1985. 87p.
00E/NV/10327 l Limited Risk Assessment and Some Cost /Benifit Considerations for Greater Confinement-Disposal Compared to Shallow Land Burial, September 1984 i
DPST-80-466 Environmental Analysis Burial of Offsite Low-Level Waste AT SRP.
Poe, W.L.;
Moyer, R. A., (Du Pont de Nemours (E.I.) and Co., Aiken, SC (USA).
Savannah RiverLab).
Dec. 1980. 86p.
DPST-85-688 Environmental Infomation Document, Savannah River Laboratory Seepage Basins,
' December 1986.
DPST-85-706 Environmental Information Document, H-Area Seepage Basins, December 1986.
EG&G. Internal #1 Low-Level Waste Disposal Performance Assessment Model Review, July 85 EPA-600/3-83-101 EPA Complex Terrain Model Development Third Milestone Report 1983, November 83 Ih3 11
- [
88/09/06=
EPA-600/3-84-031-MEXAMS--The Metals Exposurv Analysis Modeling System, Battelle PNL, PB84-157155, February 84 -
EPRI EA-3417 Vol 1 - Geohydrochemical Modals, Feb 84 Vol 2 - Geohydrochemical Models for Solute Migration, Nov. 84 Vol 3 - Geohydrochemical Models for Solute Migration, March 86
_EPRI-NPi3680
' Proceedings:
1984 ASME-EPRI Radweste Workshop, Sept. 84 EPRI EA-5342 Groundwater Assessment Modeling Under the Resource Conservation and Recovery Act -.Jan. 88 EPH NP-2664-CCM Low-Level Waste Disposal Site Performance Assessment With the RQ/PQ Computer Program, June B3 EPRI NP-5365M Designs and Cost of Low-Level Waste Disposal Facilities, August 87 EUR 10816 EN
. Radiological Impact of Shallow Land Burial:. Sensitivity to Site Character-istics and Engineered Features of Burial Facilities, Commission of the European Communities (CEC), Nuclear Science and Technology,1986
!CRV Report 34 The Cosimetry of Pulsed Radiation, August 82 lNIS-mf-9040 International Conference on Radioactive Waste Management._ Canadian Nuclear Society, Toronto,-Ontario.
1982. 342p. [ conf.]
INI5-mf-10514 Radweste '86:
Abstracts volume.
Ainslie,L.C.(ed.). Nuclear Development Corp. of South Af rica (Pty.) Ltd., Pelindaba, Pretoria. August 86. 89p.
.[ conf.]'
'LA-9995-MS Solubility Limits on Redionuclide dissolution At a Yucca Mountain Repository, Date?
NCRP Report 51
' Radiation Protection Design Guidelines for 0.1-100 MeV Particle Accelerator
- Facilities. Oct. 79 NCRP Report 59 Operational _ Radiation Safety Program, Nov. 80 NCRP Report 61 Radiation Safety Training Criteria for Industrial Radiography, Nov. 78 12 i
1
88/09/06 NCRP Report 76-
' Radiological' Assessment:
Predicting the Transport, Bioaccumulation, and Uptake by Man of Radionuclides Released to the Environment, May 85 OHWl-465L TRIPM: A Two-Dimensional Finite-Element Model for the Simultaneous Transport of Water and Reacting Solutes Through Saturated and Unsatur6ted Porous' Media, July 83 ORNL/NSF/EATC-17
' A Comprehensive Atmospheric Transport and Diffusion Model, January 78
.ORNL-5970 PREST 0-II:
A low-Level Waste Environmental Transport and Risk Assessment Code, April 86-ORNL/NFW-82/18 Proceecings of the Fourth Annual Participants' Information Meeting.
DOE Low-Level Waste Management Program.
Large, D.E. ; Mezga, L.J., (Oak Ridge
-National Lab, TN (USA)). Oct. 82. 813p.
ORNL-5970 Presto-ll:
A Low-Level Waste Environmental Transport and Risk Assessment Code.
Fields.:D.E.; Emerson, C.J.; Chester, R.O.; Little, C.Aa; Hiromoto, G., (See Also-9514868 OakRidgeNationalLab.,TN(USA)). April 86. 470p.-
ORNL-6001 Unrestricted Disposal of Minimal Activity Levels of Radioactive Wastes:
Exposure and Risk Calculations.
Fields, D.E.; Emerson, C.J., (0ak Ridge National Lab., TN (USA)).
August 84. 95p.
PB-296947
-Low-Level Radioactive Waste Management.
Watson,J.E.(rd.).
(Environmental ProtectionAgency, Washington,DC(USA). Office of Radiation Programs).
Mayl79. 547p.
PB82-244575 Long-Range. Atmospheric Transport & Dispersion Model (User's Guide).
Air Resourced. Labs. May 82. 27p.
PNL Internal #1 Environmental Pathways Analysis of the U. S. Ecology Low-Level Waste Disposal Facility, Richland, Washington, Oct. 87.
-PNL-SAL 1071 Relevance of Biotic Pathways to the Regulation of Nuclear-Waste Disposal, Sept 82.
PNL-2970 GETOUT - A Computer Program for Predicting Radionuclide Decay Chain Transport Through Geologic Media, August 79.
13
'l Ell 1 - '
88/09/06' PNL'-3180-
. Assessment of Effectiveness of Geologic Isolation Systems. ARRRG and FOOD -
j Computer Programs for Calculating Radiation Dose to Man from Radionuclides in the Environment, June 80.
PNL-4722 Allowable Residual-Contamination Levels for Decommissioning Facilities in the-
]j 100 Areas of the Hanford Site, UNI-2522, UC-70A, July 83.
PNL-6396.
I Characterization of Simulated Low-Level' Waste Grout Produced in a Pilot-Scale Test, Feb.-88.
PNL-2850.
' Pacific Northwest Laboratory Annual Report for 1978 to the DOE Assistant Secretary for Environment.
Part 1 - Diomedical Sciences.
Wiley, W. R.
Battelle Pacific Northwest Labs., Richland WA,.Feb. 79, 280p.
Part 2 - Ecological Sciences.
Vanghan, B.E.
Battelle Pacific Northwest l
Labs.
Richland WA, Feb. 79. 166p.
1 Part2(Suppl.),-
Alaskan Environmental Research.
Hanson, W. C.
Eberharot, L. E. Battelle Pacific Northwest Labs.,
Richland WA.
July 79. 31p.
i Part 3 - Atmospheric Sciences.
Battelle Pacific Northwest Labs.
l Richland WA.
Feb. 79. 116p.
Part 4 - Physical Sciences.
Nielson,.J. M. Battelle Pacific Northwest Labs., Richland, WA.
Feb. 79. 121p.
t Part 5 - Environmental Assessment, Control. Health and Safety, Bair, W. J. Battelle Pacific Northwest Lab., Richland, WA.
2/79.,146p.
y PNL-3370 i
Development of a Multimedia Radionuclide Model For Low-Level Waste Management.-
'1 (Pacific Northwest Lab., Richland, WA (USA)). March 82. 202p.
i 1
PNL-5356-l 2
Potential Radiological Im Proposed Waste Disposal. pacts of Upper-Bound 0perational Accidents During i
Mishima, J.; Sutter, S.L. (See Also:
- 9500022, Pacific Northwest Labs., Richland, WA (USA)).
Feb. 86. 188p.
RAE-8339/12-2 I
The PATHRAE-T Performance Assessment Code for Analyzing Risks from Radioactive Wastes,_ Rogers & Associates Engineering Corporation, Dec. 85.
L' SAND Internal #1 l
- Draft
Comparison of Strongly Heat-Driven Flow Codes for Unsaturated Media, April 88.
! SAND 79-0299 l
-Sundia Origen User's' Manual.
Bennett, D.E., Oct. 79. 112p.
SAND 86-0530 Risk Assessment and Ranking Methodologies for Hazardous Chemical Defense Waste:
1 A State-of-the-Art Review and Evaluation; Task 1 report, June 86.
i 14 1
a n
s.:
88/09/061
)
. SAND 86 2994 H
SRS: _ Site Ranking System for Hazardous Chemical and Radioactive Waste, May 88.
TR-79-CANADA Environmental and Safety Assess;nent. Wright, J.H. (comp.). '(Atomic Energy of Canada Ltd... Manitoba).- 1981. 295p.
UCRL 15210-I Comparison of One, Two, and Three-Dimensional Models for Mass Transport of
. Radionuclides, Feb. 80.-
-l U. S. Ecology Environmental-Pathways Analysis of' the US Ecology Low-Level Waste Disposal Facility,-Richland, Washington, Oct. 87.
USGS/WRD/WRI-80-041-.
Additional and Revised Thermochemical Data and Computer Code for WATEQ2 - A Computerized Chemical Model for-Trace and Major Element Speciation and Mineral Equilibria-of Natural Waters, Jan. 80.
USGS/WRIR-85-4278
.Three-Dimensional Steady-State Simulation of Flow in the Sand-and-Gravel
- Aquifer, Southern Escambia County, Florida,1986.
USGS/WRIR-86-4095 HST3D:
A Computer _ Code for Simulation of Heat and Solute Transport in Three-
- Dimensional Ground-Water Flow Systems,1987.
l.
t 15
'?
'SnWMHNES'
/
umise STA788 l
NUCLEAR REGULATORY COMMISSION
[
c WASM80eeToes, D. c. 3sses 7
S 1
g 84Y 111963 ATTENTION:
Commission Licensees
SUBJECT:
FINAL WASTE CLASSIFICATION AND WASTE FORM TECHNICAL POSITION PAPERS By Federal Register Notice dated December 27, 1982 (47 FR 57446), NRC amended its regulations to provide specific requirements for licensing facilities for the land disposal of low-level radioactive waste.
The majority of these require-monts are contained in a new-Part 61 to Title 10 of the Code of Federal Regula-tions (10 CFR Part 61) entitled " Licensing Requirements for Land Disposal of -
Radioactive Waste."
Some. additional requirements directed primarily at waste generators and handlers-including certification and use of shipping manifests were concurrently published as a new $ 20.311 of Part 20 (" Standards for Protection Against Radiation").
j As noted in the December 27 Federal' Recister Notice, the effective date of 10 CFR Part 20, 5 20,311 is December 27, 1983, while the effective date of 10 CFR Part 61 and all other amendments is January 26, 1983.
Section 20.311 requires that any licensee who transfers radioactive waste to a land disposal facility or to a licensed waste collector or processor must' classify the waste according_to 6 61.55 of 10 CFR Part 61.
Licensed waste processors who treat or repackage radioactive waste-for disposal into a land disposal facility must also classify their waste according to S 61.55.
This section defines radio-active waste suitable for disposal as falling.into one of three classes-(Class A, Class B,.or Class C), and wa**4 is determ 6ed to fall into one of the classes by comparison.to limiting cw.centrations of some particular listed radionuclides.
Class B and C wastes are subject to waste stability requirements which are set forth in 9 61.56 of the rule.
In addition, S 20.311 also requires.that waste generators record on shipment manifests a description of the transferred waste n well as a certification that the waste is properly classified and that tne wJ fest is filled out correctly.
Licensees must also conduct a quality control propr c. to assure compliance with the waste classification and waste stability
% uirements.
NRC staff recognizes that the new requirements may result in some modifications to existing licensee waste management practices, and furthermore believes that it will be useful to licensees to begin planning for implementation of the new requirements in advance of the December 27, 1983 effective date.
At this time NRC staff is preparing Regulatory Guides on both waste classification and waste form.
To provide immediate guidance to licensees, however, the NRC Low-Level Waste Licensing Branch has prepared technical position papers on waste classifi-cation and waste form.
The waste clasjjfigA11on tecAnj,aLootit. ion pagar describes overall procedures acceptable to NRC staff which may be used by licensees to determine the presence and concentrations of the radionuclides listed in 5 61.55,'and thereby classify
- ing waste for near-surface disposal.
This technical position paper also provides guidance on the types of information which should be included in shipment mani-fests accompanying waste shipments to near-surface disposal facilities.
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. _ ~
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- g.
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Commission Licensees 2
y a
The technical position paper on waste form provides guidance to waste generators on test ~Mstho'ds and results acceptable to NRC staff for implementing the 10 CFR r
Part 61 waste form requirements.
It can be used as an acceptable approach for demonstrating compliance with the 10 CFR Part 61 waste structural' stability criteria.
This technical position paper includes guidance on processing waste
-into an acceptable stable form, designing acceptable high-integrity containers,
. packaging cartridge filters, and minimizing radiation effects on' organic ion-exchange resins.
The guidance in the waste form technical position paper may be used by licensees as the basis for qualifying process control programs to meet the waste form sta-bility requirements including tests which can be.used to demonstrate-resistance to degradation arising'from the effects of compression, moisture. microbial activ-ity, radiation, and chemical changes.
Generic test data (e.g., topical reports prepared by vendors who' market solidification technology) may be used for process control program qualification where such generic data is applicable to the particular-types of waste generated by a licensee.
y While the NRC staff has not formally reviewed or aproved any products,.NRC staff believes.that solidification processes and high-integrity containers currently exist that can be qualified to meet the waste form stability requirements.
Licensees and vendors should continue their efforts to have qualified products available in advance of the December 27, 1983 implementation deadline.
NRC staff will continue to work with licensees and vendors to meet the waste form require-ments and implementation deadline.
NRC staff will also continue.to coordinate
'their work with cognizant representatives of States which currently have licensed low-level waste disposal sites.
-Oraft versions of both technical position papers.have previously been made avail-able to interested members of the public.
Comments received on these drafts have been considered during development of the technical position papers being pub-lished at this time.
Further public comment on these technical positions is welcomed, and any such comment received will be considered during preparation of the waste classification and waste form Regulatory Guides.
Comments on the tecn-nical position papers may be forwarded to myself ( Address:
U.S. Nuclear Regula-tory Commission, Washington, DC, 20555, mailstop 55-623).
Questions on the tecn-nical position papers may be referred to Mr. Paul H. Lohaus (301-427-4500), to Mr. G. W. Roles (301-427-4593), or to Mr. Timothy C. Johnson (301-427-4697) of my staff.
The waste classification and waste form technical position papers are included as attachments to this letter.
The information collections contained in these technical positions have been approved under OMB number 3150-0014.
- f)).
j) S E
Leo B. Higg otham, Chief Low-Level Waste Lftensing Branch Division of waste Management l
May 1983 Rev. O m
)
4.
O-LOW-LEVEL WASTE LICENSING BRANCH TECHNICAL POSITION ON RADI0 ACTIVE WASTE CLASSIFICATION 4
A.
-Introduction Section 20.311 (" Transfer for Disposal and Manifests") of 10 CFR Part 20-(" Standards for Protection Against Radiation") requires that any licensee who transfers radioactive waste to a land disposal facility or to a licensed waste collector or processor must classify the waste according to Section 61.55
-(" Waste Classification") of 10 CFR Part 61
(" Licensing Requirements for Land
- Disposal of Radioactive Waste").
Section 20.311 also requires that any licensed weste processor who treats or repackages radioactive waste for disposal into a land' disposal facility also classify their waste according to Section 61.55.
g Section 61.55 defines radioactive waste suitable for land disposal as falling into one of three categories--i.e., Class A waste, Class 8 waste, and Class C L
waste.
Wastes are determined to fall into one of the classes by comparison to i
limiting concentrations of particular radionuclides which are set forth in l
L Table 1 and Table 2 of Section 61.55.
Wastes determined to fall into one of.
1 L
the classes must be labeled as such in accordance with Section 61.57 (" Labeling").
L Waste generators and waste processors must record on shipment manifests a L
description of the transferred waste, and must also carry out a quality control' a
, program to assure that classification of waste is carried out in a proper manner.
All three classes of waste are required to meet certain minimum.
requirements-as set forth in paragraph 61.56(a) of Section 61.56-(" Waste Characteristics") which are intended to facilitate handling of waste at:the
- disposal site and provide protection of public health and safety.
Class B and Class C wastes, however, are required to meet more rigorous requirements on waste stability.
These stability requirements are set forth in paragraph 61.56(b) of Section 61.56.
Class C waste must be also identified to allow for
..1 additional disposal procedures to be carried out at the disposal site to provide protection to a potential inadvertent intruder.
Finally, wastes having concen-trations ofLparticular radionuclides exceeding those allowed for Class C waste are generally considered unacceptable for near-surface disposal.
This technical position describes overall procedures acceptable to the regulatory staff which may be used by licensees to determine the presence and concentrations of radionuclides listed in Section 61.55, and thereby classifying o
waste for near-surface disposal.
The technical position also provides guidance and clarification on the minimum types of information which should be included i
on shipment manifests.
B. ' Discussion Each shipment of radioactive waste by a waste generator to a licensed collector processor, or operator of a land disposal facility must ensure that a_ shipment manifest accompany the waste.
Section 20.311 states that the mani-fest must include information on waste characteristics including (as a minimum)
1
=
i a physica}
b total radioactivity, the principal chemical form, the solidifica-description of the waste, the volume, the radionuclide identity and quantity, W f any), and the waste class.
tien agen the radienus11 des H-3, C-14, Tc 99, and I-129 must be listed.As a minimum, th 1
These radio-nuclides, as well as the other radionuclides listed in Section 61.55, are used to determi.no the classification statui; cir radioactive waste.
Controlled dis-t posal of wastes containing these radionuclides is considered important in i
assuring that the performance objectives of Subpart C of the Part 61 regulation The manifest must also identify waste containing more than 0.1 percent are met.
by weight chelating agents, as well as provide an estimate of the weight per-contage of the chelating agent.
Additional information may be required for shipment to a particular disposal facility depending upon facility-specific license conditions.
To classify waste for disposal and fill out shipment manifests, a licensee must make two basic determinations:
(1) whether the waste is acceptable for near-surface disposal, and (2) if acceptable for near-surface disposal, whether the waste is classified as Class A, Class B, or Class C weste.
Another deter-i mination is whether the waste compiles with any additional waste form, package, or content requirement which may be in place at the particular disposal facility l
to which the waste is to be shipped.
j i
Waste is determined to be generally unacceptable for near-surface disposal if it contains any of the radionuclides listed in Tables 1 and 2 of Section 61.55 in concentrations exceeding the limits established for the radionuclides.
If determined to be acceptable for near-surface disposd. waste is determined to be Class A, Class B, or Class C based upon the listi. (*' radionuclide concen-tration limits set forth in Tables 1 and 2.
C.
Regulatory position i
All licensees must carry out a compliance program to assure proper classification of waste, Licensee programs to determine radionuclide concen-trations and waste classes may, depending upon the particular operations at tne licensee's facility, range from simple programs to more complex ones.
In general, more sopt.isticated programs would be required for licensees generating Class B or Class C waste, for licensees generating waste for which ninor process variations may cause a change in classification, or for licensees generating waste for which there is a reasonable possibility of the waste containing concentrations of radionuclides which exceed limiting concentration limits for near-surface disposal.
The regulatory staff is prepared to be flexible in the adaptation of a particular program to a particular waste generating facility.
A principal consideration for the acceptability of a particular program will be whether a reasonable effort has been made to ensure a realistic representation of the distribution of radionuclides within waste, given physical limitations, and to classify waste in a consistent manner.
Example " physical limitations" can include difficulties in obtaining and measuring representative samples at reasonable costs and acceptable occupational exposures.
The staff considers a reasonable target for determining measured or inferred radionuclide concentra-tions is that the concentrations are accurate to within a factor of 10.
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.a Ites, however, that this target may be difficult to achieve for staff roc some waste s and forms.
A licensee's program should be specific to a particular facility, and should consider the different radiological and other characteristics of the different waste streams generated by the facility.
There are at least four basic methods which may be potentially used either individually or in combina-tion by licensees:
materials accountability; classification by source; gross radioactivity measurements; or direct measurement of individual radionuclides.
The following discussion outlines instances and conditions whereby each basic method or combinations thereof would be acceptable to regulatory staff as a program for demonstrating compliance with the waste classification requirement.
Some licensees, such as nuclear power facilities, are expected to employ a combination of methods.
Appendix A to this technical position outlines enr example program for nuclear power facilities which the regulatory staff would find acceptable.
j 1.
General Criteria Compliance Through Materials Accountability a.
s.
One method which the regulatory staff would find acceptable to determine radionuclide concentrations and demonstrate compliance with the waste classifi-cation requirem d.s is through a program of materials accountability.
That is, a given quantity (and resulting concentration) of radioactive material may be known to be contained within a given waste or may be inferred through deter-mining the difference between the quantity of radioactive material entering and exiting a given process.
This procedure is expected to be most useful for licensees who receive and possess only a limited number of different radio-i isotopes in known concentrations and activities (e.g., holders of source material, special nuclear material, or specific byproduct material licenses).
An example use of this method would be at a biomedical research facility at which known amounts of a radioisotope are injected into research animals, the carcesses of which are ultimately disposed of as radioactive waste.
Another example would be a research or test facility performing activation analysis experiments.
In this case, the quantity of radioactive material within a given waste stream may be inferred through calculation.
A third example would be a a
Dower p3 ant in which the radionuclide content of a particular process vessel (e.g., a resin bed) is determined on the basis of measurements of influent and effluent streams.
This method may also be used to determine the absence of particular radionuclides.
That is, for most licensees, the absence of particular radio-
.nuclide may be determined through a knowledge of the types of radioisotopes received and possessed, as well as the prucess producing the waste.
For example, if a licensee receives, possM$es, and uses only tritium, there is no need to measure the wast.c stream for other isotopes such as iodine-129 or N sium-137.
3
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b.
C9Eksification by Source 4
This method is similar to the above method of materials accountability and involves determining the radionuclide content and classification of waste througn knowledge and control of the source of the waste.- This method is expected to be useful for occasions when the radionuclide concentrations within waste generated by a particular process are relatively constant and unaffected by minor variations in the process.
This method is also expected to be frequently useful for determining the absense of particular radionuclides from a given waste stream.
For example, within a given licensed facility there may be a number of separate controlled areas within which only a limited number of radioisotopes are possessed and used (e.g., Cs-137 may be used in one area and tritium in another).
As long as facility operations are conducted so that transfer of radioactive material from one controlled area to another cannot occur, waste generated from a particular area may be readily :lassified by source.
An example of a licensee for which this method is expected to be useful is a large university which holds a broad license for byproduct material.
c.
Gross Radioactivity Measurements Measurement of gross radioactivity is an acceptable method for all classes l
of waste provided that:
I t
the gross radioactivity measurements are correlated on a consistent basis with the distribution of radionuclides within the particular waste stream analyzed, and the radionuclide distributions are initially determined and periodically verified by direct measurement techniques.
Licensees carrying out gross radioactivity measurements to assure compliance with the waste classification requirement must establish a program to correlate and calibrate measured radioactivity levels with radionuclide concentrations in wastes prepared for shipment.
This program must at a minimum take into account waste package and detector geometry, shielding and attenuatic-effects, the effective gamma energies of the emitted photons,'ard the number of photons per decay.
The accuracy of the correlation must be initially estab-lished by and periodically checked through more detailed sample analysis involving measurement of specific radionuclides.
The accuracy of the correla-tion should also be checked whenever there is reason to believe that process changes may have significantly altered previously determined correlations.
E d.
Measurement of Specific Radionuclides Another method acceptable to the regulatory staff for determining radionuclide concentrations in waste is by direct measurement.
In using this method, licensees may directly measure individual radionuclides or may estab-lish an inferential measurement program whereby concentrations of radioisotopes which cannot be readily measured (through techniques such as gamma-spectral analysis) are projected through ratioing,to concentrations of radioisotopes which can be readily measured.
An example would be the practice of scaling 4
i transurani.c concentrations to concentrations of the isotope Ce-144 Scaling l
factors should be developed on a facility and waste stream specific basis, and 4
should be initially determined and periodically confirmed through direct measurements.
2.
Determination and verification of Radionuclide Concentrations and Corrslations Radionuclide concentrations should be determined based upon the volume or weight of the final waste form.
Samples may be taken for analysis either from the final waste form or from the waste prior to processing into a final waste form (e.g., from any intermediate process step).
Samples taken prior to final processing should enable the results of the sample analysis to be directly translated to the final waste form.
The lower limit of detection of a measurement technique for direct measure-ment of a particular radionuclide should be no more than 0.01 times the concentra-tion for that radionuclide listed in Table 1, and 0.01 times the smallest concentration for that radionuclide listed in Table 2.
For this technical position, the lower limit of detection for a particular measurement may be assumed by licensees to be consistent with the definitions for lower limit of detection (LLD) provided in references 1 and 2.
The radionuclides listed in Section.61.55 may be roughly organized into two groups:
(1) those that are amenable to routine quantification by direct measurement techniques (e.g., gamma spectral analysis of isotopes such as Co-60 or Cs-137), and (2) those that require more costly and time consuming analysis frequently recoved from the waste generator's facility (e.g., alpha / beta analysis).
For the first group of radionuclides, measurements to identify and quantify specific radionuclides within final waste forms should be performed:
routinely for Class B and Class C wastes; and l
L routinely for wastes for which minor process variations could cause an upward change in waste classification.
In this case, " routine" measurements would involve a limited number (e.g., one or two) of samples out of a batch.
If radionuclide distributions are shown to be reasonably consistent from one batch to the next, however, consideration will be given to decreasi3g the frequency of routine measurements.
A more detailed analysis for the second group of radionuclides should be i.
l performed:
periodically to confirm the correlation of measurements made from gross radioactivity measurements; and whenever there is reason to believe that facility or process changes may have significantly altered (e.g., by a factor of 10) previously determined correlations of gross radioactivity mbasurements.
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The staff g ieves that for most facilities and for most Class 8 and C waste I
types, thmsonfirmatory analysis should be performed on at least an annual basis.
Ces(3rmatory analyses for Class A wastes should be performed on at least a biannual basis.
However, these frequencies may be raised or lowered based upon. consideration of particular facility, waste stream, or radionuclide characteristics.
Factors which would influence this consideration include the frequency of process vessel changeout or waste shipment, the difficulty (e.g.,
costs, occupational exposures) in obtaining a representative sample of a particular waste stream, the variability of the radionuclidt distribution within the waste stream over time, and the availability of analytical capability for particular radionuclides.
It is recognized that it is sometimes difficult to obtain a truly representative sample of some waste streams and that some judgment will be necessary to determine sampling adequacy and representative radionuclide distributions.
One example could include Class A dry active waste such as L
miscellaneous trash.
In this case, an estimate of the radionuclide distribution within the waste could be made based upon distributions determined from other waste streams associated with generation of the trash waste.
Alternatively, radionuclide distributions could be potentially estimated from smear samples obtained from locations in which the waste is generated.
Another example could I
include activated metals.
In many cases, radionuclide concentrations within activated metals will be difficult to directly measure, and NRC staff will in such cases accept estimates based on consideration of activation analysis calculations for similar material types.
3.
Concentration Volumes and Masses I
Paragraph 61.55(a)(8) states that the concentration of a radionuclide may be a traged over the volume of the waste, or the weight of the waste if the concentration units are expressed as nanocuries per gram.
This requirement needs to be interpreted in terms of the variety of different types and forms of low-level waste.
Principal considerations include:
(1) whether the distri-bution of radionuclides within the waste can be considered to be reasonably homogeneous, and (2) whether the volume of the waste container is significantly larger than the volume of the waste itself, and the differential volume consists largely of void space.
Most waste streams may be considered to be homogeneous for purposes of waste classification.
Such waste streams would include, for example, spent ion-exchange resins, filter media, solidified liquids, or contaminated dirt.
Contaminated trasn waste streams, which are composed of a variety of miscel-laneous materials, may be considered homogeneous for purposes of waste classi-fication when placed and compacted within shipping containers.
The activity of small concentrated sources within the trash, such as small check sources or gauges, may be generally averaged over the trash volume.
4 In many cases the volume used for waste classification purposes may be considered to correspond to the volume of the waste container.
This would be the case, for example, for trash waste streams which are compacted into shipping containers.
The waste classification volume of large unpackaged components such as contaminated pumps, heat exchangers, or other machlnery may be taken to be the overall volume of the component. -
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b Ce to be taken, however, to differentiate between the volume of the was and 'the volume of the waste container if the latter is signifi-cantly 1 (e.g., greater than 10%).
For example, for wastes such as ion-exchange resins or filter media contained within a disposable domineralizer or liner, the volume used for waste classification should be the volume of the contained waste rather than the gross volume of the container.
Waste classi-fication volumes of cartridge filters stabilized by emplacement within high integrity containers should be determined as calculated over the volume of the cartridge filter itself rather than the gross volume of the container.
Simi-larly, the volume and mass considered for purposes of waste classification of dewatered ion-exchange resins and filter media placed into high integrity
}
containers should be the volume and mass of the contained waste.
Classification of absorbed liquids should be based on the volume and mass of the liquids prior to absorption.
An exception to the above would be a situation in which a particular waste type is stabilized within a waste container ~using a solidification media.
For example, assume that a cartridge filter or large sealed source is solidified with a 55 gallon drum using a binder such as cement or bitumen.
In this case, the waste and binder forms a solid mass within the container and the waste classification volume may be considered to be the volume of the solidified mass.
Similarly, classification of solidified liquids would be based on the volume and mass of the solidified waste mass.
4 Reporting on Manifests Section 20.311 of 10 CFR Part 20 requires that each shipment of radioactive waste to a land disposal facility be accompanied by a manifest which describes 1
l the shipment contents.
This manifest may be shipping papers used to meet regulations promulgated by the Department of Transportation or the Environmental L
Protection Agency, provided that the information required by Section 20.311 is l
included.
The waste shipment receiver (e.g., the disposal facility operator) may also require specific additional information.
In addition to shipper i
identification requirements and a certification, the manif"its required by Section 20.311 must include the following information as a minimum:
the waste class.
a radiological description; and a physical and chemical description.
Waste class Identifying the waste class of the shipped waste is required, since certain disposal requirements are imposed for each waste class and the waste disposal facility operator must be able to identify the waste in order to carry out these disposal requirements.
The individual waste containers must be labeled as being Class A. Class B, or Clash C, and the waste class of each container must also be indicated on the manifest.
The format of the shipment labels (or martings) is at the discretion of the disposal facility operator.
Unpackaged Class A waste (e.Q.. bulk shipments of contaminated dirt) do not need to be labeled provided t t the waste class is recorded on the manifest.
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i ys The shipment manifest should also record the date for which the classification determination is valid.
This can be, for example, the date of transfer of the waste package from the site of generation to the disposal site.
In no case should the date chosen for decay correction be beyond the date on j
which the waste is transported to the disposal site.
Radiological description
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The requirements in Section 20.311 include a general requirement to list radionuclide identities and quantities, a general requirement to list the total radioactivity in the waste, and a specific requirement to list four individual l
l radionuclides:
These requirements need some further guidance, however, since a wide range of radionuclides over a wide range of concentrations may be contained in a particular waste package.
The regulatory staff has determined three criteria for determining specific radionuclides which should be listed in manifests:
1.
any radionuclide specifically required to be listed by Section 20.311, or by license conditions at the disposal facility to which the waste i
is shipped; 2.
any radionuclide which is listed in Section 61.55 and forms a significant part of the total activity which determines the waste class; and 3.
any radionuclide which is contained in significant quantities within a waste container or shipment.
Currently, only the isotooes H-3, C-14, Tc-99, and I-129 are required in Section 20,311 to be specifically identified and their quantities listed.in manifests.
In the manifests, if a particular one of these four radioisotopes is known to be not present within a waste stream (e.g., through material accountability), the quantity of the radionuclide should be recorded as "not present."
If the radionuclide is determined through material accountability, direct measurement, or inference through direct measurement or gross radio-activity measurement, this quantity should be reported as determined.
If.the radionuclide is known or suspected to be contained within the waste but is in quantities less_than the lower limit of detection for the analp ed sample, the quantity of the radionuclide should be recorded as being less than the minimum detectable,~with the minimum detectable amount included alongside in parentheses.
The total quantities of these four nuclides may be reported on a waste shipment
+
rather than an individual waste container basis.
In the case of Tc-99, care should be taken to distinguish between this nuclide and its short-lived precursor, Tc-99m.
Other radionuclides listed in Section 61.55 should be specifically identified and the quantities reported if they are significant for purposes of classification.
A radionuclide shall be determined to be "significant for purposes of classification" if it is contained in waste in concentrations greater than 0.01 times the concentration of that nuclide listed in Table 1 or 0.01 times the smallest concentration of that nuclide listed in Table 2.
This criterion does not include isotopes i.dentified in Table 2 as having half-lives M
l o
less than years.
An isotope (other than Cm-242) having a half life less than 5 years i sidered significant for the purposes of waste classification if i
it is con in the waste in concentrations greater than 7 pCi/cm3 (0.01 times the le 2, Column 1 value).
Radionuclides not listed in Section 61.55 should also be specifically identified and the quantities reported if they~are contained in significant quantities within a waste container or shipment.
In general, a radionuclide shall be deemed to be " contained in significant quantity" if it is in concen-trations greater than 7 pC1/cm3 In addition, the total quantity of source or special nuclear material should be reported, if the waste contains such material.
Otherwise, radionuclides should be iisted in shipment manifests in compliance with Department of Transportation requirements in 49 CFR Part 172, Section 172.203.
Physical and chemical description Items to be included in the physical and chemical description include, as a minimum, the following:
a physical description of the waste; the volume; the principal chemical form; and the solidification agent used (if any).
Wasta containing more than 0.1% chelating agents by weight must be identified, and the weight percentage of the chelating agent estimated.
Amplification of NRC's intent regarding these requirements is provided below, i
A physical description of the waste is needed in order to facilitate safe handling at the disposal facility and to better predict long-term environmental impacts.
The description need only be a few words but should be as specific as possible.
For example, a description such as " solidified resins" or " solidified evaporator bottoms" should be used rather than the description " solidified radwaste."
Similarly, the description " scintillation vials" is preferable to l
the description " laboratory waste."
The volume listed in the manifest should be the volume of the waste container, if any, or the volume of the waste itself if shipped unpackaged (e.g., a bulk quantity of contaminated soil).
The principal chemical form of the waste also needs to be provided as an aid to waste handling safety and to improve prediction of long-term environ-mental impacts.
This should be the principal chemical form in which the i
radioactivity is contained (e.g., calcium fluoride, toluene, ate ).
There is no need to list trace chemical contaminants, however.
l The solidification agent need only be provided in general terms (e.g.,
cement, esphalt, vinyl ester styrene).
The type of solidification agent usEd may be combined with the physical description of the waste (e.g., " resins l
solidified in cement").
The intent of the requirement to identify waste containing chelating agents in quantities greater than 0.1% is to identify waste containing large quantities of such agents.
Large quantities of such agents may be segregated from other waste at a disposal facility and/or disposed through some special 9
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i; il disposal method.
Disposal facility operators need to have such waste identi-'
i fled in order for them to perform these additional disposal-operations, For 4
nurposes of.this requirement, chelating agents include the following:
amine polycarboxylic acids-(e.g., EDTA, OTPA), hydroxy cartcxy11e acids, and polycarboxylic acids (e.g., citric acid, carbolic acid, and glucinic acid).
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a, APPENDIX A GENERAL PROGRAM FOR CLASSIFYING WASTES AT NUCLEAR POWER FACILITIE5 In order to meet the requirements in 10 CFR Part 61 to ' classify radioactive wastes at nuclear power plants, NRC staff has prepared a general program for implementing the waste classification system.
This implementation program consists of r three-tiered approach which includes:
1.
-periedic analysis for all nuclides listed in Table 1 of Section 61.55; 2.
gamma spectroscopy of certain nuclides from which waste classification nuclideo are correlated; and 3.
gross rad 5oactivity measurements which correlate activity levels of wastes fron similar batches to the gamma spectroscopy measurements.
The periodic sampling for listed nuclides would be performed on various waste streams in the plant.
These periodic analyses should be the basis for estabitshing correlation factors between the waste classification nuclides and
~
nuclides which can be more easily measured using gamma spectroscopy techniques.
Samples should be taken nominally on an annual basis from individual waste streams such as boric acid evaporator bottoms, primary system cleanup resins, chemical regenerative evaporator bottoms, etc., which are likely to be Class B or C wastes.
If unit operations or plant conditions-are modified such that the t -
radionuclide distribution for any of the-individual waste streams changes by a factor of 10, a reanalysis should be performed.
Plant operational changes would include changes in the failed fuel fraction or a crud burst.
If operations i.
remain consistent, consideration can be given to performing reanalysis on a L
less frequent basis.
In addition, consideration should be given to increasing the frequency of analysis depending upon individual facility, waste stream, and radionuclide characteristics.
Factors which would influence this consideration include the frequency of process vessel changeout or waste shipment, the diffi-culty in obtaining a representative sample of a particular waste stream, the variability of the radionuclide distribution within the waste stream, and the l
available analytical capacity for particular radionuclides, h
The gamma spectroscopy measurements should be performed on a limited number of samples obtained from individual waste batches.
This can be performed by analyzing waste samples prior to or after volume reduction and/or solidifi-cation, analyzing waste drums or liners by any of the commercial devices designed for this task, or by analyzing influent and effluent samples from the l
process stream.
Other methods which provide reasonable analysis will also be l
considered.
Efforts should be made to obtain reasonably representative samples for analysis.
The results of the gamma spectroscopy measurements should be applied with the correlation factors to obtain concentrations for those nuclides listed in the waste classification table.
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Gro eactivity measurements may also be performed on individual waste packages steiler waste batches for which gamma-spectroscopy results are available se radioactivity measurements should include corrections for attenuati container size and configuration.
The gross activity measure-ments should be used to scale the nuclide concentrations obtained from the gamma spectroscopy data and correlations.
For Class A wastes such as contaminated trash, gross radioactivity measurements may be performed as the basis for waste classification provided that these measurements can be correlated to the concentrations df the radio-nuclides listed in Section 61.55.
Confirmatory reanalysis of the correlation factors should be performed on at least a biannual basis.
The NRC staff believes that the abcVe approach presents a workable and enforceable program for implementing the waste classification system.
This approach should minimize the administrative and operational burdens on plant personnel, but still provide reasonably accurate data for use in quantifying disposal site nuclide concentrations and inventories.
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REFERENCES < _
2.
.(1)
U.S. lhelear Regulatory Commission, " Radiological Ef fluent Technical Specifications for PWR's," NUREG-0472 (as revised), July 1979.
(2)
U.S. Nuclear Regulatory Commission, " Radiological Effluent Technical Specifications for BWR's," NUREG-0473 (as revised), July 1979.
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May 1983 i
Rev. O
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Tecnnical Position on Waste Form A.
Introduction The reguletion " Licensing Requirements for Land Disposal of Radicactive Waste." 10 CFR Part 61, establishes a waste classification system bassa on the radionuclide concentrations in the wastes.
Class 8 and C waste are required to be stabilized.
Class A waste have lower concentrations, and may be segregated without stabilization. Class A wastes may also be stabilized and disposed of with the Class B wastes. All Class A liquid wastes, however, require solidification or absorption to meet the free liquid requirements.
Structural stability is intended to ensure that the {
waste does not degrade and promote slumping, collapse, or other failurg 1
of the cap or cover over the disposal trench and thereby lead to water infil tration.
Stability is also a factor in limiting exposure to an inadvertent intruder since it provides greater assurance that the waste form will be recognizable and nondispersable during its hazardous lifetime.
Structural stability of a waste form can be provided by the waste form itself (as witn large activated stainless steel components),
by' processing the waste to a stable form (e.g., solidification), or by empiacing tne waste in a container or structure that provides stability (e.g., high integrity container),
i This technical position on waste form has oeen developed to provide t
t-guidance tu both fuel-cycle and non-fuel-cycle waste generators on waste form test methods and results acceptoble to the NRC staff for implementing the 10 CfR Part 61 waste form requirements.
It can be useo as an acceptable apprmn for demonstrating compliance with the 10 CFR Part 61 waste stability criteria.
This pasition includes guidence on the processing of wastes into an acceptable, stable waste form, the design of acceptable h6th integrit/ containers, the packaging of filter cartridges, and ministesap-the radiation effects on organic ion-exchar.ge resins, it is the intent of the kRC stdtf to add other guidance on waste form in additional technical positions as is necessar/ to address other pertinent waste form issues.
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M B.
Background
Historically, waste form and container properties were considered of secondary importance to good site selection; the combination of a properly operated site having good geologic and hydrologic characteristics were considered the only barriers necessary 'to isolate low-level radioactive wastes from the environment.
Experience in operating low-level waste disposal sites indicated that the waste form
+
should play a major role in the overall plan for managing these wastes.
The regulation for near-surface disposal of radioactive wastes,10 CFR Part 61, includes requirements which must be met by a weste form to be acceptable for near-surface disposal.
The regulation includes a waste classification system which div1aes waste into three general classes:
A, B, and C.
The classification system is based on the overall disposal hazards of the 2 wastes.
Certain minimum requirements must be met by all wastes.
These minimum requirements are presented in Section 61.56(a) and involve basic packaging criteria, prohibitions against the disposal of pyrophoric, explosive, toxii and infectious materials, and requirements to solidify or aosorb liquits.
In addition to the idnimum requirements, Class B and C wastas are required to have staoittt,y.
As definea in Section 61.56(b) of the rule, stability requires tnat tne waste furm maintain its structural integrity under the expected disposal conoitions.
Structural stability is necessary to inh 1Dit slumping, collapse, or other failure of the disposal trench resulting from degraded wastes which could lead to water infiltration, racionuclide migration, and costly remedial care programs.
Stability is also considered in the intruder pathways where it is assumed that af ter the active control period wastes are recognizable and, i
i therefore, continued inadvertent intrusion is unlikely. To the extent practical Class 8 and C waste forms should maintain gross physical properties and identity over a 300 year period.
In order to ensure that Class 8 and C waste or its container will maintain its stability, the following conditions need to be met:
Tho'weste should be a solid form or in a container or structure a.
that provides stability af ter disposal.
e b
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b.
The weste should not contain free standing and corrosive liquids.
That is, the wastes should contain only trace amounts of-drainable liquid, and in no case may the volure of free liquid exceed one percent of the waste volune when wastes are disposed of in containers designed to provide stability, or 0.5 percent of the waste volume for solidified wastes.
The waste or container should be resistant to degradation c.
caused by radiation effects.
d.
The waste or container should be resistant to biodegradation, The waste or container should remain stable under the e.
compressive loads inherent in the disposal environment.
f.
The waste or container should remain stable if exposed to moisture or water af ter disposal, g.
The as-generated waste should be compatible with the solidification nwdia or container.
A large portion of the w6ste produced in the nuclear industry is in a form which is either liquid or in a wet solid form (e.g., resins, filter sludge, etc.) and requires processing to achieve an acceptable solid, I
monolithic form for burial.
The liquid wastes, irregardless of its classification, ore required to be either absorbed or solidified.
In L
order to assure that the solidification process will consistently produce a product which is accepteble for disposal and will meet disposal site license conditions a process control program should be used.
General e
requirements for process control programs are provided in the NRC Standard Reyiew Plan 11.4, " Solid Waste Management Systems,"
(NUREG-0800 ) ano its accompanying Branch Technical Position ETSB 11-3,
" Design Guidance for 50110 haste Management Systems Installeo in Light-Water-Cooled Nuclear Power Reactor Plants," (revised in July 1981),
i These documents may also be used as the basis for individual solidification process control programs by other fuel-cycle and by non-fuel-Sycle waste generators who would solidify wastes. The guidance in this technical position should be the basis for qualifying process control programs for Class B dnd C wastes.
The use of applicable generic test data (e.g., topical reports) may be used fur prccess control program qualification. Process cuntrol programs for solidified Class A waste products, which are segregated from Class B ano C wastes, need only O
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i demonstrate that the product is a free standing inonolith with no more than 0.5 percent of the waste volume as free liquid.
An_ alternative to processing some Class B and C waste streams, particularly ion exchange resins and filter sludges, is the use of a high integrity container.
The high integrity container would be 'used'to provide the long-term stability required to meet the stability requirements in 10 CFR Part 61.
The design of the high integrity container should be based on its specific intended use in order to ensure that the waste contents, as well as interim storage and ultimate disposal environments, will not compromise its integrity over the long-term.
As with waste solidification, a process control program for dewatering wet solids should be developed and utilized to ensure that the free liquid requirements in 10 CFR Part 61 are being met.
C.
Regulatory position e
1.
Solidified Class A Waste Products l
a.
Solidified Class A waste products which are segregated from Class B and C wastes should be free standing monoliths and have no more than 0.5 percent of the waste volume as measuredusingtnemethoddescribedinANS55.1.{reeliquiosas b.
Solidified Class A waste products which are not segregated from Class B and C wastes snould meet the stability guidance for Class B anc C wastes provided Delow.
l 2.
Stability Guidance for Processed (i.e., Solidified) Class 8 and C Westes l
a.
The stability guidance in this technical position for processed wastes should be implemented through the qualification of tne individual licensee's process control program.
Generic test data may be used for qualifying process control programs.
Through the use of a well designed and implemented process control program, frequent requalification to demonstrate stability is expected to be unnecessary.
However, process control programs should include provisions to periodically demonstrate that the solidification system is functioning properly and waste products continue to meet the 10 CFR Part 61 stability requirements. Waste specimens should be prepared 4
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based on the proposed waste streams to be solidified and based on the range of waste stream chemistries expected. The tests identified may be performed on radioactive or non-radioactive smples.
b.
Solidifiedwastespecimensshouldhavecompressivestreggthsof C
et least 50 psi when tested in accordance with ASTM C39.
Compressive strength tests for bitumino products should be performed in accordance with ASTM 01074 Many solidification agents will be easily capable of meeting the 50 psi limit for properly solidifiea westes.
For these cases, process control parameters should be developed to e
achieve the maximum practical compressive strengths, not simply to achieve the minimum acceptable compressive strength, The specimens for each proposed waste stream formulation should.
c.
remain stable after being exposed in a radiation field v
equivalent to the maximum level of exposure expected from the proposed wastes to be solidified.
Specimens for each proposeg waste stream formulation should.be exposed to a minimum of 10 Radsinagammatrradiatororequivojent.
If the maximum level of exposure is expected to exceed 10 Rads, testing shoulo oe performed at tne expected maximum accumulated dose..The irradiated spec 1niens should have a minimum compressive strength of 50 psi following irradiation as tested in accordance with ASTM C39 or ASTM 01074, d.
Specimens for each proposed waste stream formulation should oe testedfgrresistancegobiodegradationinaccordancewithboth r
l ASTM G21 and ?STM G22. No indication of culture growth shoult be visible.
Specimens should be suitable for compression l
testing in accordance with ASTM C39 or ASTM 01074 Following the blodegradation testing, specimens should have compressive L
strengths greater than 50 psi as tested using ASTM C39 or ASTM D1074.
l For polymeric or bitumen products, some vis1b!e culture growth from contamination, additives or biodegradable components on the specimen Surface which do not relate to overall substrate integrity may be present.
For these cases, additional testing should De performed. If culture growth is observed upon l
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completion of the biodegradation test for polymeric or bitumen products, remove the test specimens from the culture, wash them free of 411 culture and growth with water and only light scrubbing.
An organic solvent compatible with the substrate may be used to extract surface contaminants. Air dry the specimen at room temperature ano repeat the test. $pecimens should have observed culture growths rated no greater than 1 in the repeated ASTM G21 test, and compressive strengths greater than 50 psi.
The specimens should have no observed growth in the repeated ASTM G22 test, and a compressive strength greater than 50 psi Compression testing should be performed in accordance with ASTM C39 or ASTM 01074 If growth is observed following the extraction procedure, longer term testing of at least six months should be perform 9d to determine bludegradation rates.
The Bartha Pramer Method 4
is acceptable for this testing. Soils used should be representative of those at burial grounds. Biodegradation extrapolated for full-size waste forms to 300 years should produce less than a 10 percent. loss of the total carbon in the l
waste form.
l 1
Leach testing should be performed for a mjnimum of 90 cays in e.
accordance with the procedure in ANS 16.1.
Specimen sizes should be consistent with the samples preparea for the ASTM C39 or ASTM 01074 compressive strength tests.
In addition to the cemineralized water test specified in ANS 16.1, additional o
testing using other leachants specified in ANS 16.1 should also be performed to confirm the solidification agents leach resistance in other leachant mecia.
It is preferred that the synthesized sea water leachant ;lso be tested. In addition, it is preferable that radioactive tracers be utilized in performing the leach tests.
The leachaD111ty index, as calculated in accordance with ANS 16.1, should be greater than 6.
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f.
Waste specimens should maintain a minimum compressive strength of 50 psi as tested using ASTM C39 or ASTM 01074, following immersion for a minimum period of 90 days.
Immersion testing l
may be performed in conjunction with the leach testing.
9 Waste specimens should De resistant to thermal degradation.
The heatinu eno cooling chambers used for the thermal i
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degradation testing should conform to the description given in ASTM B553, Section 3.
Samples suitable for performing compressive strength tests in accordance with ASTM C39 or ASTM
[
01074 shoulo be used.
Samples should be placed in the test chamber ena a series of 30 thermal Cycles carried out in accordance with Section 5.4.1 through 5.4.4 of ASTN 8553.
The high temperature limit should be 60C and the low temperature limit -40C.
Following testing the waste specimens should have compressive strengths greater than 50 psi as tested using ASTM l
C39 or ASTM D1074.
h.
Waste specimens should have less than 0.5 percent by volume of the waste specimen as free liquids as measured using the method i
described in ANS 55.1.
Free liquids should have a pH between 4 and 11.
i.
If small, simulated laboratory size specimens are used for the above testing, test data from sections or cores of the anticipated full-scale products should be obtained to correlate the characteristics of actual size products with those of simulated laboratory size specimens.
This testing may be 4
performed on non radioactive specimens.
The full-scale specimens should be fabricated using actual or comparable i
solidification equipment.
J.
Waste samples from full-scale specimens should be destructively analyzed to ensure that the product produced is homogeneous to the extent that all regions in the product can expect to have compressive strengtns of at least 50 psi.
Full-scale specimens may be fabricated using simulated non-radioactive products, but' should be fabricated using actual solidification equipment.
3.
Radiation Stability of Organic lon-Exchange Resins In order to ensure that organic ion exchange resins will not produce adverse radiation degradation effects, resins should got be generated that have loadings which will produce greater than 10 Reds total accumulated dose.
For Cs-137 end 9-90 a total accumulated dose of 10g 3
Rads is approximately equivalent to an 10 Ci/ft concentration.
This position is applicable to resins in the unsolidified, as-generated fonn, in the event that the waste generator considers it necessary to load 0
resins higher tnen 10 Rads, it should be demonstrated that the specific e
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resin will not undergo radiation degradation at the proposed higher loading.
the test method should adequately simulate the chemical and i
radiologic conditions expected. A gamma irradiator or equivalent should be utilized for these tests.
There should be no adverse swelling, acid formation or gas generation which will be detrimental to the, proposed final waste product.
4 High Integrity Containers The maximum allowable free liquid in a high integrity container a.
'should be less than one percent of the waste volume as measured using the method described in ANS 55.1. A process control program should be developed and qualified to ensure that the free liquid requirements in 10 CFR Part 61 will be met upon delivery of the wet solid material to the disposal facility.
This process control program qualification should consider the effects of transportation on the amount of drainable liquid which might ce present.
b.
High integrity containers should have as a design goal a minimum lifetime of 300 years.
The high integrity container t
should be designed to maintain its structural integrity over this period.
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c.
The high integrity container design should consider the l
l' corrosive and chemical effects of both the waste contents and the disposal trench environment.
Corrosion and chemical tests should be performed to confirm the suitability of the proposed container materials to meet the cesign lifetime goal.
d.
The high integrity container should be designed to have sufficient mechanical strength to withstand horizontal and vertical loads on the container equivalent to the depth of proposgd burial assuming a cover material density of 120 lbs/ft.
The high integrity container should also be designed to withstand the routine loads and effects from the waste contents, waste preparation, transportation, hanoling and disposal site operations, such as trench compaction procedures.
This mechanical oesign strength should be justified by conservative design analyses, For polymeric material, design mechanical strengths should be e.
conservatively extrapolated from. creep test data.
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f.
The design should consider the thermal loads from processing, storage, transportation and burial.
Proposed container materials should be tested in accordance with ASTM B553 in the manner described in Section C2(g) of this technical position.
No significant changes in material design properties should result from this thermal cycling, g.
The high integrity container design should consider the radiation stability of the proposed container materials as well as the radiation cegradation effects of the wastes.
Radiation degradation testing should be performed on proposed container materials using a game irradiator or equivalent.
No significant changes in material design properties shguld result following exposure to a total accumulated dose of 10 Rads.
If it is proposed to design the high integrity container to greater accumulated doses, testing should be perfomed to I
confirm the adequecy of the proposed materials.
Test specinens should be prepared using the proposed fabrication techniques.
Polymeric high integrity container designs should also consider the effects of ultra-violet radiation.
Testing should be performed on proposed materials to show that no significant changes in material design properties occur following expected ultra-violet radiation exposure, j
h.
The high integrity container design should consider the i
biodegradation properties of the proposed materials and any biodegradation of wastes and disposal mecia.
Biodegradation testing should be performed on proposed container materials in accordance with ASTM G21'and ASTM G22.
No indication of l
culture growth should be visible.
The extraction procedure described in Secticn C2(d) of this technical position may be performed where indications of visible culture growth can be attributable to contamination, additives, or biodegradable components on the specimen surface that do not affect the j
overall integrity of the substrate.
It is also acceptable to 2
determine blodegradation rates using the Bathta-Pramer Method described in Section C2 (d).
The rate of biodegradation should p
produce less than a 10 percent loss of the total carbon in the-container material after 300 years. Test specimens should be E
prepared using the proposed material faDrication techniques.
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The high integrity container should be capable of meeting the i
requirements for a Type A package as specified in 49 CFR
+
173.398(b).
The free drop test may be performed in accordance with 10 CFR 71, Appendix A. Section 6.
J.
The high integrity container and the associated lilting'oevices 1
should be designea to withstand the forces applied during lifting operations. As a minimum the container should be designec to withstand a 3g vertical lifting load.
k.
The high integrity container should be designed to avoid the collection or retention of water on its top surfaces in order to minimize accumulation of trench liquids which could result in corrosive or degrading chemical effects.
1.
High integrity container closures should be designed to provide ;
a positive seal for the design lifetime of the container.
The 3 closure should also be designed to allow' inspections of the
- f, contents to be conducted without damaging the Integrity of the container.
Passive vent designs may be utilized if needed to relieve internal pressure.
Passive vent systems should be designed to minimize the entry of moisture and the passage of 1
waste materials from the container, Prototype testing should be performed on high integrity m.
container designs to demonstrate the container's ability to withstand the proposed concitions of waste preparation, handling, transportatica and disposal, n.
High integrity containers should be fabricated, tested, inspected, prepared for use, filled, stored, handled, transported and disposed of in accordance with a quality i
assurance program.
Tne quality assurance program should also adoress how wastes which are detrimental to high integrity container materials will be precluded from being placed into the container.
Special emphasis should be placed on fabrication process control for those high integrity containers which utilize fabrication techniques such as polymer molding processes.
5.
Filter Cartridge Wastes c
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For Class 8 and C wastes in the form of filter cartridges, the waste generator should demonstrate that the selected approach for providing stability will meet the requirements in 10 CFR Part 61.
Encapsulation of the filter cartridge in a solidification binder or the use of-a high integrity container are acceptable options for providing sta>ility. When high integrity containers are used, waste generators shoulo demonstrate that protective means are provided.to preclude conta1ner canage during packaging handling and transportation.
D.
Implementation This technical position reflects the current NRC staff position on acceptable means for meeting the 10 CFR Part 61 waste stability requirements.
Therefore, except in those cases in which the waste L
generator proposes an acceptable alternative method for complying with g
the stability requirements of 10 CFR Part 61, the guidance described herein will be used in the evaluation of the acceptability of waste forms {:.
for disposal at near-surface disposal facilities.
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References:
t i
1.
NUREG 0800, Standard Review Plan 2.
ANS 55.1, "American National Standard for Solid Radioactive Weste Processing System for Light Water Cooled Reactor Plants," American Nuclear Society,1979 3.
ASTM C39 " Compressive Strength of Cylindrical Concrete Specimens,"
l American Society for Testing and Materials,1979 4.
ASTM 01074, " Compression Strength of Bituminous Mixtures " American f
Society for Testing and Materials,1980 5.
ASTM G21
" Determining Resistance of Synthetic Polymeric Materials to Fungi," American Society for Testing and Materials,1970
(
- 1 l.
6.
ASTM G22. " Determining Resistance of Plastics to Bacteria," American
(-
l Society for Testing and Materials,1976 7.
R. Bartha, D. Pramer, " Features of a Flask and Method for Measuring the Persistance and Biological Effects of Pesticides in Soils."
Soil Science 100 (1), pp-68-70, 1965 8.
ANS 16.1, " Measurement of the Leachability of Solidified Low-Level Radioactive Wastes," American Nuclear Society Draf t Standard, April 1981
~
9.
ASTM B553, " Thermal Cycling of Electroplated Plastics," American Society for Testing and Materials,1979 s
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