ML20059L855

Responds to Requesting Evaluation of Process Control Program Proposed by Adtechs Corp for Solidification of Class a low-level Radwaste

ML20059L855
Person / Time
Issue date:	11/08/1993
From:	Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Muntzing L AFFILIATION NOT ASSIGNED
References
REF-WM-102 WM-102, NUDOCS 9311170454
Download: ML20059L855 (4)

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j WASHINGTON. D C. 20555-0001 Docket No. WM-102 Mr. L. Manning Muntzing President and Chief Executive Officer ADTECHS Corporation 2411 Dulles Corner Park, Suite 520 Herndon, Virginia 22071

SUBJECT:

EVALUATION OF A PROCESS CONTROL PROGRAM FOR BITUMEN SOLIDIFICATION OF CLASS A LOW-LEVEL RADIOACTIVE WASTE This is in response to your October 21, 1993, letter that requested an evaluation by the Nuclear Regulatory Commission of the process control program (PCP) that ADTECHS Corporation is proposing for the solidification of Class A low-level radioactive waste.

Solidification is one option for proce s ing and packaging Class A low-level radioactive waste; however 10 CFR Part 61 does not require solidification.

The Technical Positi n on Waste Form, Revision 1, January 1991, does provide guidance on the characteristics that are expected in a waste form if solidification is the chosen method of processing and packaging.

The guidance states that, " 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 free liquids as measured using the method described in ANS 55.1."

Providing the bitimunization process you described in your letter satisfies the two guidelines, NRC concerns about the solidification of Class A waste are satisfied. However, individual Agreement States have the authority to develop in h Hent regulations er requirements

cor, ning the solidification of Class A m, as long as these requirements satisfy 10 CFR 61.56.

For example,10 CFR 61. 5(a)(4) states " Solid waste containing liquid shall contain as littla free standing and noncorrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 1%

of the volume." However, the Tcchnical Position on Waste Form has a maximum guideline limit of 0.5% because all of the existing disposal sites have established this more restrictive limit.

If the Class A waste is to be disposed of with Class B and/or Class C waste, then the Class A waste must be stabilized as described in 10 CFR Part 61.7 and 10 CFR Part 61.56. Additional guidance on the characteristics that are expected in a stable waste form are also provided in the Technical Position on Waste form.

Topical Report ADTECHS/VSE-61-002-P(A) (WM-102), " Stability of low-Level Radioactive Waste Solidification with High Strength Asphalt", is an NRC approved topical for the stabilization of radioactive waste. Any Class A waste stabilized in accordance with the boundary conditions of the topical is acceptable to the NRC and will satisfy the solidification requirements.

However, in your October 21, 1993 letter, you desire to modify the boundary i 0 conditions of the approved topical to produce a solidification process for I

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Class A waste that does net meet the stabilization requirements. At a minimum, you have expanded the the pH range and increased the waste loading to 65%.

You requested NRC agreement that the proposed boundary conditions are acceptable.

In general, the NRC agrees that high strength asphalt could be qualified for the solidification of Class A waste. However, concerning the specific PCP presented in your letter, the NRC will not devote resources to the review and evaluation of a PCP solely designed for the solidification of Class A waste.

First, the NRC does not have a requirement to solidify mis waste.

Second, some of the disposal sites under regulatory control of ine various states have, or will have, their own requirements relating to solidification.

From the regulatory perspective, there is no advantage to review solidification processes at the Federal level.

In fact, recent inquiries to several of the states developing or currently possessing low-level radioactive waste disposal facilities have indicated they have no interest in the NRC reviewing solidification processes.

Therefore, we recommend that ADTECHS discuss the proposed solidification PCP with the individual state's authority for the states that would be receiving the waste that has been solidified with your bitumen process.

In this way, any current or new future solidification requirements can be identified and the PCP evaluated accordingly.

Of greatest importance to NRC relative to solidified Class A waste is the concern that solidified Class A and stabilized Class A waste do not get mislabelled or disposed of incorrectly, and that radioactive waste that would be processed by your proposed treatment not be identified as stable waste.

That is, a quality control system is needed that will make certain that no Class A solidified waste is disposed of with Class B and/or Class C wastes that require stabilization.

If there are any questions relative to this issue, please contact me at (301) 504-3785.

Sincerely, {0dd:a'stad ty

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Michael J. Bell, Chief Low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning l

Office Of Nuclear Material Safety and Safegua;ds cc: Mr. Virgil Autry, Director Div. of Radioactive Waste Mgt.

Bureau of Solid & Hazardous Waste So. Carolina Dept. of Health & Environment 2600 Bull Street Columbia, S.C. 29201 TICKET: LlWM2129 l

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Mr. L. Manning Muntzing l Class A waste that doer. not meet the stabilization requirements.

At a

, minimum, you have expanded the the pH range and increased the waste loading to 65%.

You requested NRC agreement that the proposed bcundary conditions are acceptable.

In general, the NRC agrees that high strength asphalt could be qualified for the solidification of Class A waste. However, as far as the specific PCP presented in your letter, the NRC will not devote resources to the review and evaluation of a PCP solely designed for the solidification of Class A waste.

First, the NRC does not have a requirement"to solidify this waste.

Second, some of the disposal sites under regulatory control of the various states have, or will have, their own requirements relating to solidification.

From the regulatory perspective, there is no advantage to review solidification processes at the Federal level'.

In fact, recent inquiries to several of the states developing or currently possessing low-level radioactive waste disposal facilities have indicated they have no interest in the NRC reviewing solidification processes.

Therefore, we recommend that ADTECHS discuss the proposed solidification PCP with the individual state's authority for the states that would be rec 3iving the waste that has been solidified with your bitumen process.

In this way, any current or new future solidification requirements can be identified and the PCP evaluated accordingly.

Of greatest importance to NRC relative to solidified Class A waste is the concern that solidified Class A and stabilized Class A waste do not get mislabelled or disposed of incorrectly,'and that radioactive waste that would be processed by your proposed treatment not be identified as stable waste.

That is, a quality control system is needed that will make certain that no Class A solidified waste is disposed of with Class B and/or Class C wastes that require stabilization.

If there are any questions relative to this issue, please contact me at (301) 504-3785.

Sincerely, Michael J. Bell, Chief Low-level Waste Management Branch Division of Low-Level Waste Management and Decommissioning Office Of Nuclear Material Safety and Safeguards cc: Mr. Virgil Autry, Director Div. of Radioactive Waste Mgt.

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. Mr.'L. Manning Huntzing l any current or new fature solidification requirements can be identified and the PCP evaluated accordingly.

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Of greatest importance to NRC relative to solidified Class A was'te is the concern that solidified Class A and stabilized Class A waste mislabelled or disposed of incorrectly and that radioacti[v aste that would i

be processed by your proposed treatment, not be identifie as stable waste.

That is, a quality control system that will make certain/that no Class A solidified waste is disposed of with Class B and/or Clps C wastes that require stabilization.

If there are any questions relative to this issue,/hlease contact me at (301) 504-3785.

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Sincerely,/

Michael ~J.

Bell, Chief Low-Level Waste Management Branch Divi.sion of Low-level Waste Management and Decommissioning l

Office Of Nuclear Material Safety and Safeguards cc: Mr. Virgil Autry, Director l

Div. of Radioactive Waste Mgt.

Bureau of Solid & Hazardous Waste So. Carolina Dept. of Health & Environment 2600 Bull Street Columbia, S.C. 29201 TICKET: LLWM-l?9 DISTRIBUTION: Central File LLWM r/f JGreeves PLohaus JAustin JHolonich NMSS r/f JKennedy LLWM t/f j

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