ML20045E019
| ML20045E019 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1993 |
| From: | Robert Lewis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Thoma J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9306300327 | |
| Download: ML20045E019 (6) | |
Text
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M 2 41993
' MEMORANDUM FOR:
File FROM:
Robert Lewis Technical and Special Issues Section Low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards THROUGH:
John Thoma, Section Leader Technical and Special Issues Section Low-Level Waste Managemerf Branch Divison of Low-Level Waste Management and Decommissioning Office Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF 6/14/93 MEETING WITH SCIENTIFIC ECOLOGY GROUP Enclosed you will find a summary of the subject meeting between Brian Roy of Scientific Ecology Group (SEG) and Low-Level Waste Management (LLWM)
Staff.
The discussion centered on four main topics:
the organization and functions of SEG and the Nuclear Regulatory Commission, waste form issues, waste container issues, and the topical report process. There are action items that resulted from the discussions, and we can anticipate that SEG may submit some topicals in the near future.
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MEMORANDUM FOR:
File FROM:
Robert Lewis Technical and Special Issues Section Low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards T HROU'GH:
John Thoma, Section Leader Te hnical and Special Issues Section Low-Level Waste Management Branch Divison of Low-Level Waste Management and Decommissioning Office Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF 6/14/93 MEETING WITH SCIENTIFIC ECOLOGY GROUP Enclosed you will find a summary of the subject meeting between Brian Roy of Scientific Ecology Group (SEG) and low-Level Waste Management (LLWM)
Staff. The discussion 3 centered on four main topics:
the organization and functions of SEG and the Nuclear Regulatory Commission, waste form issues, waste container issues, and the topical report process. There are action items that resulted from the discussions, and we can anticipate that SEG may
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SUMMARY
OF MEETING BETWEEN SCIENTIFIC ECOLOGY GROUP AND NRC STAFF by Robert Lewis On June 14, 1993, Mssrs. Lohaus, Thoma, Lewis, and Shewmaker met with Mr.
Brian Roy'of Scientific Ecology Group (SEG) at the U.S. Nuclear Regulatory Commission headquarters in Rockville, Maryland.
SEG asked for the meeting to establish dialogue with NRC staff and to discuss several waste form and container issues.
Topics included (1) an overview of SEG operations, (2) SEG; epoxy as a solidification ~ media-for Class A waste, (3) qualification of polyethylene (HDPE) containers on all HIC guidance criteria except stability, 1
and (4) NRC organization and policy regarding topical report submissions, review, and revisions.
A summary of each of the discussions follows.
SEG operations Mr. Roy presented a brief introduction and video which provided an overview of the various facilities and systems that comprise SEG's radwaste processing programs.
SEG is a wholly owned subsidiary of Westinghouse, and _has been such since 1986.
SEG owns and operates a radwaste incinerator,,a supercompactor, and is heavily involved in low-level waste transportation technologies.
He noted that many nuclear power plants ship Class A wastes to SEG's-central processing facility in Oak Ridge, Tennessee for incineration and/or compaction.
Mr. Roy said that SEG has been, and continues to be, dedicated to new ideas and innovative processing techniques. Mr. Roy noted that SEG is closely watching the needed increased reliance on storage in order to forecast future actions.
Both SEG's amount of customers and-the volume of processed wastes have increased in each o# the last eight years. Other than activities at the central facility, SEG works at utilities and Department of Energy Labs. _
Presently, about 14% of SEG's activity is'done~at reactor sites, and this number has been decreasing. About 20% of SEG's activities involve decontamination / decommissioning, and this number has been increasing.
Waste Form issues SEG has developed a new processing technique for the solidification of incinerator ashes and bead resins. The process involves in-situ injection of an epoxy (similar in properties to Vinyl Ester Styrene (VES)). that _
encapsulates the dried waste into a monolithic form. Mr. Roy indicated that the waste form demonstrated good stability (i.e., compressive strength.(>1000 psi), thermal, radiation, and biodegradation resistance), but that the waste.
form was not tested against the stability requirements of the_ Branch' Technical Position on Waste Form (BTP).
The loading limit was not a function of l
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Mr. Roy indicated SEG was exploring submission of a topical report to NRC for approval of this process as a Class A waste solidification technique.
In SEG's opinion, the requirements for solidified Class A waste would be somewhat less than the Class B and C stability requirements in the BTP.
(Note that as-stated here, solidified Class A waste does not imply Class A waste that meets the requirements of, or can be disposed with, Class B and C stabilized waste).
In the future, however, Mr. Roy noted that SEG might wish to qualify this technique for Class B and C solidification per-the BTP.
's NRC sta noted that there was no precedent for review and approval of a topical report for solidification media for Class A waste.
Staff noted that Part 61 contained no specific requirements for solidification of Class A waste but recognized that a number of states required that Class A waste be solidified (e.g., CA, TX, IL).
Staff noted a possible benefit in having NRC conduct a single coordinated review of such a Class A solidification technique-through a topical report review process similar to that performed by NRC for Class B and C wastes.
Staff noted two possible options for SEG's consideration.
Under one option, SEG could evaluate their process against a defined set of waste form criteria (i.e., specific criteria established by SEG) and then NRC would conduct an independent review of the process against those criteria.
Under the second option, SEG would evaluate their process against individual State requirements for solidification of Class A waste.
This option would require a high degree of coordination with Agreement States and other States having requirements' for solidification of Class A waste. Staff noted the second option would likely be preferable but noted that all States have not yet established detailed waste acceptance requirements.
Assuming NRC were to agree to review such a topical report, NRC's review would be closely coordinated with the Agreement i
States, both from the standpoint of what criteria to apply as well as to acceptability of the solidification process.
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As an action item on this issue, NRC staff agreed to hold further internal discussions, and will continue dialog with SEG. NRC staff and SEG also noted the benefit of exploring the concept with other entities such as individual States, the LLW Forum, the Technical Coordination Committee, the E-5 Committee, and/or the ASME Waste Management Committee.
On a separate waste form issue, SEG would like to re-open a cement topical report for which interim approval expired in 1992. The topical, Docket number WM-46, involved several cement recipes.
SEG would like to re-open the docket for only the grout formulation (grout encapsulation method for filter media),
as it is the only one of economic use to them.
SEG wondered if there is precedent for approving grouted materials.
As an action item for this issue, NRC will find correspondence in its files to determine if there are any outstanding responses regarding this docket NRC will await a letter requesting that the topical be re-opened.
NRC will 2
a provide SEG with a copy of the waste classification guidance regarding sealed sources for their information.
Waste Container Igg e._t SEG has performed preliminary work on a container named "Enduropak," which is a 0.8 inch thick, linear HDPE, cylindrical container. Mr. Roy postulated the idea that this container could be approved through NRC review with the proviso that it bear no load.
That is, that a condition of approval be that the structural stability be provided by some other means (overpack or vault wall s ). The focus on maintaining structural load for 300 years has impeded the approval of HDPE High-Integrity Con 1ainers (HIC) in past NRC reviews.
SEG has interest in qualifying the HDPE container without an overpack to address storage concerns and generator needs relating to LLW storage.
In terms of the Enduropak, SEG would like to qualify the container based on properties such as chemical compatibility, freeze / thaw, vibration, irradiation, and drop tests performance.
SEG indicated that the Enduropak model was designed for and will probably be accepted for use on the K-25 drums at Martin Marrietta/0ak Ridge National Lab. Mr. Roy also indicated that.they had requested South Carolina approval for disposal with overpacks at Barnwell.
NRC explained to SEG that the review of past HDPE HICs concentrated solely on.
structural load concerns. Once it was determined that long-term stability _
could not be provided by HDPE materials, the review was terminated. NRC staff offered several comments in this area.
First, will void space minimization requirements imply that the unused container volume (including the space between conta-iner and overpack) be backfilled or possibly grouted? Second, in a situation where the vault is to provide stability, there would likely be a load on the HDPE HIC (at the minimum, the backfill materials will create a load that could cause long-term creep).
Finally, NRC review and approval for r
all facets of container design except stability would be difficult for the NRC since most of the performance testing guidance'is based on and derived from structural stability requirements.
Since only structural stability is mentioned as a requirement in 10 CFR 61, would the overpacks/ vaults also need to be analyzed simultaneously with the HDPE containers?
As an action item on this issue, NRC staff agreed to examine the concept of HIC review against NRC BTP guidance where stability would be provided by the disposal facility design.
NRC Topical Report Reviews Mr. Lohaus reviewed the organization and responsibilities of the Low-Level Waste Management Branch and Division. He noted that the division has lead responsibility for reviewing those aspects of topical reports that deal with acceptability of waste forms, and that.NRR has the lead responsibility for reviewing those aspects of topicals involving plant systems. The two NRC offices are responsible for coordination of their respective review efforts.
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. George Hubbard from Plant Systems Branch of NRR dicussed NRR's position on -
topical, report submissions and revisions. NRR's position is that generic topical reports. from a vendor get assigned a low review. priority-and may never get reviewed unless the. review is tied to a lead plant need and submittal.
Mr. Hubbard pointed out that in the' case.of revisions to topical ~ reports that it might be possible for a licensee to: Justify the use of the revision if. he can determine that anLunreviewed safety. question does not exist per.the criteria of 10 CFR 50.59.
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