ML20126A011
| ML20126A011 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1992 |
| From: | Bradley Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Roy B SCIENTIFIC ECOLOGY GROUP, INC. |
| Shared Package | |
| ML20126A000 | List: |
| References | |
| REF-WM-20, REF-WM-46 NUDOCS 9212170189 | |
| Download: ML20126A011 (5) | |
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^' 3 N NUCLEAR REGULATORY COMMISSION o i W A$HINoToN, D. C. 20$$$
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JAN 071992 Mr. Bryan A. Roy, Manager Engineering and Technical Resources Scientific Ecology Group, Inc.
P.O. Box 23$0 1560 Bear Creek Road Oak Ridge. Tennennee 37831-2530 Dear Mr. Royt Enclosed is the NRC !!equest for Additional Information (RAI) #2, regarding Topical 1992. Report (TB) WM-20, which we discussed in our telecon on January 6, Your prompt attention to this satter would be greatly appreciated, as it would subject TR. help us to co6plete the Interia Technical Evaluation Report on the SE4. Please fax a copy of your responses to Jennifer Davis, Mail Stop Our new fax numbers are (PTS) 964-2259, or (FTS) 964-1137. If you have any questiotis about RAI $2 please call se at (FTS) 964-2697.
Sincerely, (Oilgiul5gnedby -)
B7 Jennfter Davis, Msterials Engineer i Technical and Special Issues Section Low-Level Waste Management Branch Division of Low-Level Waste Managesent ant. Decommissioning Office of Nuclear Material Safety and Safeguards.
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l 9212170189 921208 PDH WASTE.
t' HM-20 PDR '
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Request for Information #2 January 6, 1992 SEG (nee LN Technologies) Topical Report Docket Number VM-20 S911_dif.ication (General)
A. Sample Preparation la.
What technique is used for capping the test specimens prior to compressive strength testing?
lb.
How would the capping process influence compressive strength resulta?
Ic. If ASTM C617 (Standard Practice for Capping Cylindrical Concreto Specimens) was used, which capping saterial was used?
2.
On pages 21 and 22 of the Topical Report (TR), the samples for blodegradation "unspiked". testing and thermal cycling are described as being What does this sean? '
3.
What temperatures were the 28 day cure samples subjected to during curing?
B. Testing Methods 3.
What method was used to ensure that the test specimens subjected to thermal cycling were allowed to cose to thermal equilibrius at the high and low tesperature limits during testing?
- II. Powdered Resin:
Ecodex P203H. Formula A and Ecodex P20i3. Formula D A. Vaste characterisation - Qualification Samples
- 4. Page 34 of the TR states "The Ecodex P202H is a sixture of cation and strong base anion resins in the H':0H' form and a cellulosic fibrous saterial
' (approximately 351 by weight). The Ecodex X203H is composed of the same materials as the P202H, but differs in the cation-to-anion ratio and contains a greater amount of fibrous saterial (up to 501 by weight),
i n 4a. What is the cation-to-anion ratio for each renin type (Ecodex P202H snd Ecodex P203H) used in the manufacture of the qualification test samples?
4b. What is the level of depletion for each resin type (Ecodex P202H and Ecodex P203H) used in the manuf acture of the qualification test samples?
(c. How were the ion exchange resina used in the qualification samples deple.ted?
- 5. What was the pH cf the representative " waste" used for qualification sample sar.uf acture?
P Enclosure (1)
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l 6.
What were the approximate tolerances / ranges for the ingredients used to manufacture the quellfication nasples?
7.
What was the temperature of the representative " waste" used for qualification sample manufacture?
B. Formulations - Qualification Samples j
- 8. ;
In Table D.4.a of the TR (Appendix D), the amount of hydrated line in formulations A-D of the Powdex PCH is 1.5g. The amounts of hydrated line in formulations However, A-D of Ecodex in Enclosure 3 to the P202H Marchare 9.0g, 8.8g, 8.Bg and 8.8g respectively.
23, 1989 Submittal (Responses to .
l Request for Additional Information (RA!) # 1), the amounts of line in formulations A-D of the Powdex PCH are 9.0g, 6.8g, 8.8g and 8.8g, respectively, while the amount of line in each of the formulations A-D of Ecodex P202H is listed as 1.2g. All other component quantities are !
consistent.
Ba.
Which table is correct with regard to the amounts of line in the Ecodex P202H formulations?
Bb. I If Enclosure 3 to the March 23, 1989 Submittal is correct, is the line quantity 1.2g or 1.5g? I i
C. Wante Characterisation - Actual Waste /PCP Program 9.
In the Nov. 15, 1988 Response to RAI #1, the response to RAI Question 25 states in part:
"This will... adjust the water and cement quantities to compensate for corrosion products and other solids present in the waste."
9a.
What are the controls / tolerances on corrosion products and other solids in the waste?
9b. What are the "other solids" likely to consist of? .
9c. How were these lapurities accounted for in the qualification progran?
- 10. Are there any controls /llmits for the level of depletion for the resins that can be solidified?
- 11. What is the allowed temperature range for PCP samples /solidifications?
D. l'CP Instructions
- 12. In the Nov. 15, 1988 Submittal (Response to RAI #1).- the response to RAI Question 39 states in part: "The water content is then adjusted by adding or removing water to match the water content of the laboratory test data presented in the topical report."
If the waste water content (already in the solidification liner) is higher than the final desired water content, what process is used to remove the excess?
3 Enclosure (1) 0 e
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- . - .. .. . - - = . - . - - - . . - - _ . . . . - _ . . . - _ .
13.
In the most recent (Nov. 27, 1991) Response to RAI #1, the response to RA1 Question 36 is incomplete. Please provide the full response.
4
!!!. Filter _Encaosulation A. Formulation 14.
In Enclosure (3) to the March 23, 1989 Response to RAI #1, the forsulas for the concrete and the cement grout used for the filter encapsulation liner are listed as shovn below:
Water (al) Stone (g) Cesent(g) Sand (g)
Concrete 9.6 41.6 20.1 28.7 Cement Grout ---
170 ---
100 ;
In Enclosure (3) of the August 18, 1989 Submittal (Response to RAI #1), the formulas for the concrete and the cement grout used for filter encapsulatten '
are listed as shown below:
~
Water (al) Stone (g) CementIg) Sand (g) '
Concrete 9.6 41.6 20.1 28.7 Cement Grout 100 ---
170 ---
!s 100ml grout? of water and 270g of cement the correct formulation for the cesent '
B. Material to be Encapsulated 15.
The " Procedure for Using the SEG Filter Encapsulation Liner at Diablo Canyon" (SS-034. Rev. K), and the " Design Analysis Report for the LN Filter Encapsulation Liner" (LN-87-003) both indicate that the liner may be used to encapsulate "any acceptable waste in accordance with 10 CFR 61 and disposal site requirements, i.e. ion exchange resins and filter utdia" in addition to contaminated mechanical filters. What is the rationale for permitting these other types of wastes to be encapsulated?
- 16. What controla are in place to ensure that the contents of the FE Liner do not weigh more than 2300 lbs as specified in paragraph 2.3.1 of docusent LN-87-0037 P
4 Enclosure (1)
Bryan Roy f'3he interia approvals will allow SEG to use the six waste / binder formulations for twelve months. J
'TuaTITTestion.. test _lngand_WilLLeviac_the PCP documents in ac
' _the revised Technical Position on Waste Form.
and the revised _ PCP documents to NRC for evaluatio_n, before the end {
12- of\ theSE
{ month Deriod. RC wtil_tasue tanat ajIpViWals f or those~ rY61 pes ~f6F1hich the ~ ~
j additional
~
tes ing is successful, meaning that the data confirm that the waste forms will meet the criteria described in Appendix A of the Technical Position.
forms will not If the additional meet these criteria, test data indicate that the cementitious waste
" disapproved" status. the formulations will be changed to i l
In this time period, SEG will also have the opportunity to execute the full series of Appendix A qualification testing on tha "not-approved" waste forms listed in Table 111, to update the applicable PCP documents, and to devise and qualify a design for filter encapsulation In grout. These formulations will "then be evaluated by the NRC, and will be classified as either " approved" or disapproved." i i
The topical report should be revised to include all appropriate information that was developed during the technical review. Proprietary and non-proprietary interia approved versions of the topical report should be submitted to che NRC within 60 days of this letter. They should be titled with the designations "P-IA" and "NP-!A,"_ indicating proprietary-interim '
l approved, and non-proprietary interim approved, respectively. The topical '
report should not include information on the "not-approved" formulations at this time. Applicable information should be submitted in the final version.
Final approval of the topical report is based on submission and approval of a final resised topical report (proprietary and non-proprietary versions) to include all appropriate information that was developed during the technical
- review and confirmatory testing.
Final approval of the interim approved and "not-approved" waste / binder formulations are subject to the following additional conditions, as set forth in the TER:
4 (1) During the period of interim approval, SEG will perfors additional qualification testing on the six interia approved waste streams,-as described in Section 5.3 of the TER.
(2) SEG will revise the PCP documents in accordance with the conditions in t
Sectiona 4.7.1 and 5.4 of the TER. '
(3) For the low-PE powdered resin, the filter sludge, and the sodlus sulfate with mixed solids formulations, SEG-will prepare, store and test surveillance speclaens in accordance with Section 5.5 of the TER. .
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(4) For final approval of the "not-approved" formulations, SEG shall comply with (2) and-(3) above, and shall perform additional qualification .
testing in accordance with Section 5.3 of the TER.
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