ML20081G860

Requests Written Concurrence W/Understanding on Confirmation of Compliance W/Land Disposal Restrictions for Storage & Treatment of high-level Radioactive Mixed Waste at West Valley Demonstration Project

ML20081G860
Person / Time
Site:	West Valley Demonstration Project
Issue date:	04/29/1991
From:	Buggy J, Harbison S, Rowland T ENERGY, DEPT. OF, NEW YORK, STATE OF, WEST VALLEY NUCLEAR SERVICES CO., INC.
To:	Counterman P, Gorman J ENVIRONMENTAL PROTECTION AGENCY, NEW YORK, STATE OF
References
REF-PROJ-M-32 NUDOCS 9106130371
Download: ML20081G860 (5)

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Department Of Energy Idaho Operations Office hh

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, c;$ P O. Box 191 West Valley, NY 14171 April 29,1991 Mr. John Gormn, Section 011cf Unitcd States Envi-sital Protection Agency 26 Fcderal Plaza, Roca 1121 New York, New York 10278 Mr. Paul Countermvn, Director ILuardous Substarre Tugulations Ncw York State Department of Environnental Conservation 50 Wolf Rcod Albany, New York 12233 SUanrr: Confirmtion of Carpilance with the Lard Disposal Festrictions (LDRs) for the Storage and TIvatment of High Lavel Raciioactive Mixed Waste (IN) at the West Valley Duuokation Project (WDP)

Dear Sirs:

The purpose of this letter is to provide hackground informtion on the storage and treatment of the WDP's liquid high-level IW, and obtain your formal concurrerca that the WVDP is in acrplianm with the a;plicable Resource Conservation and Recovery Act (RCRA) ILRs. As mndated by the WDP Ict of 1980 (PL 96-368), the U. S. Depart:ent of ErrIgy (DOE) and the New York State Energy Research and Develcir:nnt Authority (NYSGDA) are presently pursuiry their mission of vitrifying the liquid high-level IW at the WDP.

Tw types of liquid high-level IMi are stared or are currently undergoirq treat;nent at the WDP,11DREX waste and FUREX waste. These wastes were generated by the previous site cperator, Nuclear Itel Services. 'Ihe 7110 REX

waste was pMmi frca processirg a c

:all batch of tharium-uranium fuel usirq i

the 710 REX sbcess, ktich involved dic.mlution of spent fuel in nitric acid, l

followed by separation of the uranium and any plutonium. The thorium remained with the fission prcxtacts in the high level radioactive waste stream. The apprcximtely 12,000 gallons of 7110 REX waste were placed in an undergreurd l stainless steel starage tank, in an acidic form to keep the thorium in solution. The TIOREX waste meets the definition of hazardous waste by virtue of exhibitiry the characteristics of corrosivity and toxicity (EPA hazardous I waste rnenhnrs D002, D005, D006, D007, and D010) . In nM ition, it contains the

" California List" constituent nickel, in con:rntrations above the LDR limit.

Ihe PUREX waste was produccd frcn the reprocessiry of uranium fuel usirg the PUREXc p . m (dicelution of spent fuel in nitric acid, followed by solvent I

extraction of uranium and plutoniuc) . This waste was neutralized with sodium l hydroxide before transfer to an urderground carbon steel storage tank. The 1

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4 J. 2tran April 29, 1991 P. C unterrnn ncutralization prteess causcd rost of the fissicrrwu.hrt elmmts, with the exceptian of cosium, to precipitate and fem a sitzkyo at the bottm of the tank. Se sitrkye is overlain by a cxsium laden supermtant. At the enset of the pruject there were appmximtaly 600,000 gallons of PUREX m ste in starage. Die PUREX waste meets the definition of huardous waste by virtue of exhibitirg the toxicity duracteristic (EPA betxbus waste numbers D005, D006, D007, D009, and D010). So IUREX sitdge also contains the " California List" ccnctituent nickel in mmdaations ab.ne the 1DR limit.

Se supermtant fIm the FUREX tank is curIrntly be1In ps-W thrVLgh the Inhgrated Radioactive Waste Treatment Systm (IRPS), which started rr.ciioactive operations in 1988. 'Ihe IRTS consists of an ion exdurgo systs to rmove radioactive oesiten, a liquid waste treatrent systs to cancxmtrate (ard thereby IMm the volume of) the trmtad liquid frcu the icn excharge system, ard a cement solidification system to stabilize the bmrdous ard radioactive w.rients in the mmdauted liquid. 9*rmuent to supermtant treatment, the sitdge remaining in the IUREX tank will be washed to rmove c.u3swits (primarily sulfates) that arc detrimental to the vitrification process. So wash waters, like the superTutant, will be processed thrctyh the IRrs. Se cum.rit product is tested usiry the 2xicity Ouracteristic Imachiry Prmuttre to verify that the waste form ctrplies with the applicable treatment stardards (i.e. ., for D005, D006, D007, D009, and D010 wastes) .

Fbilowirg IUREX supermtant treatment and sludge washirg, the IUREX sitdge, alorg with the spent ion exdunge nnh used in the supermtant treatment

2use of IRTS ard the 310 REX waste, vi11 be cmbined in the HREX waste tank for vitrification in barosilicate glass. As statnd in the mi2i mird Rulemgirg, vitrification is the establiched IIR treatment sta.Jard for the high-level fractions of the IUP.EX ard MOREX wastes. (Note

AlthcLgh the spent ion excharge raiia is rot expected to exhibit the duracta-istics of cerrosivity or toxicity for metals, DDE has determined that the waste stream should urdergo vitrification due to its cosium content.)

S e above aMeicns pertainity to treatment of the WVDP high-level RH dersmi.2 ate that the waste will be treated to root the IDR stardards and any continued storage of high-level RH at tne site, now ard in the future, serves to facilitate proper treatrnnt. Se following acklrosses additional issues regardirq storage of the WVDP high-level RM ard ccr:pliance with the IDRs.

2e UCREX waste was placed in its present storage tank prior to 1973, well before the effective dates of the applicable IDR rcquiations. So DDREX waste will remain isolated in the storage tank until the WVDP is ready to cxrmence operations at the Vitrification Facility, ard thus the storage prohibitions do not apply (see 55 FR 22525, which states "he land d%41 restd tions apply prospectively to the affected wastes.")

J. Gormn April 29, 1991 J P. Ctunterman 1

The PUREX waste, like the DDREX vaste, was placed in stcrage prict to 1973.

The tank containity the EUREX waste can be viewed frun two pr.spdves - (1) that it is a a-tarage vessel for waste that remains in the tank ard (2) that it is part of the IRrs. If the tank is considered a storage vw.al, then wastes reminirq in the tank are not subject to the storage prthibitions unless newly-generated, restricted vastes are ahri to the tank. While the substances identified in Attachnmt A are occasionally ^%vi to the tank, these substances are not newly-generated, restricted wastes. If the PUREX tank is cmsidered part of the IRTS as spM by the seccrid pergdve, the waste is not beirg starod ard thus is not subject to the storage prrhibitions.

Once the DDREX waste and the spmt ion exctiange nvvila are ctrabined with the sludge in the PUREX tank, treatment of these wastes is underway ard the PUREX waste tank is part of the vitrification process. Radicactive cperaticn of the Vitrification Pacility (currently in huoction) is expected to occinence by fiscal year 1996. The anticipated lcrgth of timo for ocr:pletion of high-level RW vitrification is abatt 24 months frun the onset of radioactive operations.

In light of the abcn,'e, the WDP annerts ccrpliance with the IDRs for storage ard treatrent of its high-level Rs. Your written cancurrence with this understarxiing is requested.

Very truly yours, 8 M T.

T. J. Rowlard, Actirq Director U. S. DOE West Valley Project Offico MM J. j. M, Presidiant*'drd General Manager West Valley tbclear Services Cb., Inc.

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&&.I S. G. Harbison, F w gam Manager ikN York State Energy Research ard Develegnent Authority Enclocure ETE:068:91 - 0731:91:01 ETM/sl

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ATTACl[ MENT A Substances Added to West Valley Demonstration Project PUREX Waste Tank l

Substances added to the PUREX waste tank are limited to:

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i o closed-looped recirculated streams from the Integrated '

Radioactive Waste Treatment System (IRTS) and o transfers from a waste storage tank designated "7D-2", which receives:

- radioactive waste waters collected in sumps in the Main Process Build.4ng and

- radioactive waste waters from the Analytical Chemistry Laboratory.

{ It is possible that the recirculated waste streams from the IRTS l could meet the definition of " hazardous waste." However, this would only be due to the hazardous characteristic (toxicity) exhibited by the PUREX waste, itself, and therefore these streams are not considered " newly-generated."

Based on analytical data e,d our knowledge of the processes contributing waste streams, the waste in tank 7D-2 does not meet the definition of hazardous waste, and therefore is not restricted.

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. . s bac: J. E. Solocki, DOE-ID (w/cnc)

D. B. Dyolavi, DOE-ID (w/ enc)

T. W. McIntmh, DOE-HQ (w/crr)

C. LjtueL=ug, DOE-ID (w/ enc)

B. R. Datun, DOE-ID (w/cnc)

G. G. Baker, WNS (w/cnc)

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