ML20127D988

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Forwards Preliminary Comments on Topical Rept for High Integrity Container for Disposal of Low Level Radwastes, Submitted by Chichibu Cement Co,Ltd.Revised Nonproprietary Version of Topical Rept Encl.W/O Rept
ML20127D988
Person / Time
Issue date: 05/02/1985
From: Greeves J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Nussbaumer D
NRC OFFICE OF STATE PROGRAMS (OSP)
References
REF-WM-81 NUDOCS 8505170194
Download: ML20127D988 (5)


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JTGreeves TCJohnson TLJungling HJMiller MEMORANDUM FOR:

Donald A. Nussbaumer J0 Bunting Assistant Director for LBHigginbotham State Agreements Programs PDR Office of State Programs FROM:

John T. Greeves, Acting Chief Engineering Branch Division of Waste Management

SUBJECT:

PRELIMINARY COMMENTS ON THE CHICHIBU CEMENT COMPANY'S HIGH INTEGRITY CONTAINER As stated in your letters of October 5,1984 to N. Kirner and H. Shealy, the Division of Waste Management has been reviewing the topical report entitled,

" Topical. Report for High Integrity Container for Disposal of Low-Level Radioactive Wastes," submitted by the Chichibu Cement Company, LTD.

In accordance with the topical report review procedures, we are submitting our

. initial review comments at this time to provide the disposal site states the

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opportunity for further input. Also enclosed are revised versions of the non-proprietary version of the. topical report submitted by the vendor in February 1985.

If.you have any questions, please contact Tom Jungling at x74540.

John T. Greeves, Acting Chief Engineering Branch Division of Waste Management cc: Kathleen Schneider, OSP

Enclosure:

As stated YlM Record fita WM Praicct _E/

Dacket No.

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LPOR Distribution:

8505170194 850502

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COMMENTS ON CHICHIBU SFPIC HIC (Non-Proprietary-Version) 3 (Revised February 1985) 1.

Chapter 2, page 4, paragraph 3.

The empty weights of the HICs are given as 157 kg for the 200 1 and 324 kg for the 400 1.

Do these figures include the weight of the steel drum?

2.

Chapter 2, page 5, last line.

Chichibu has stated that the proposed HIC will be used for " ion exchange media 'etc."

For what specific wastes does Chichibu intend to qualify the HIC?

3.

. Chapter 3,~ p$ge 11, paragraph 3.

The last sent'ence states that the impregnation with polymer-is expected to extend the life of the concre.e by a factor of three or more over normal t

concrete. What is the basis of this ascertion?

-4.

Chapter 3 page 12, paragraph 3.

Although the dimensional configuration ~of the steel drum is compatible -

with handling equipment, could a fully loaded SFPIC HIC exceed weight limitations for the' equipment?

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5.

Chapter 3, page 13, last bullet.

Note that ASTM C39 is appropriate for compressive strength testing, but r

not fo_r bending strength testing.

6.

Chapter 3, page 14, 2nd bullet.

Could a placing pattern of 45% produce greater stresses and therefore a more critical configuration than the two patterns examined?

j 7.

Chapter 5, page 20, paragraph 2.

If the epoxy resin is applied manually to the HIC excessive worker doses could result. Therefore the remote epoxy application equipment should be an integral component of the process system, both at the generator and the disposal site.

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WM-81/TLJ/12/20/84 8.

Chspter 6, page 23, paragraph 3. (Chemical Attack) l The compressign strength result for the chemical attack test with 2% H SO4 2

was 770 kg/cm. Although this strength is greater than the stress resulting from burial, it shows a significant decrease in strength from the initial values and is also below the 900kg/cm conservative limit described on page 13.

Note that the 50 psi value recommended in the Technical Position on Waste Fonn applies to solidified wastes and is inappropriate as a design value for HICs.

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Chapter 6, page 2'4, paragraph 2..(Mechanical Strength).

It is stated that, d...the Modulus of Elasticity and the Poisson's ratio indicate that the material has a low rate of deformation." Since these properties dd not reflect time responses of materials, they should not be used to draw conclusions about strain rates.

10. Chapter 6, page 26, paragraph 1.

(Creep Characteristjes). -

It is not clear from the discussion provided, as to how compressive strength and modulus of elasticity values are obtained from a creep test performed with a constant load.

11. Chapter 6, page 26, paragraph 3.

('FatigueTest).

The third sentence should be clarified.

It is not clear what limit is used to obtain a load of between 12% and 80%.

Is the limit value that of.

the compressive strength and if so, what is that value?

12. Chapter 6, page 27, paragraph 1.

(Thermal Cycling).

Has consideration been given to the differences in the coefficients of thermal expansion.between the carbon steel drum and the SFPIC? Could stresscs build-up in the SFPIC (e.g., hoop stresses)?

13. Chapter 6, page 28.

(RadiationResistance)

The NRC limit of flammability is indicated in the discussion of gas generation. The reference for this limit should be stated.

In addition, it is unclear how the gas generation rate at 100 days was obtained from Figure 6-2-b.

The units of g-moles /ft" do not represent a generation b

f.

WM-81/TLJ/12/20/84 rate. Does this value correspond ~to the volume of PIC.or' total drum volume?

3 In the absence of a passive vent.ing system,-it is necessary to evaluate-the gas pressure increase resulting from the contained Waste in addition to,that from the PIC material. That is, some wastes which may be proposed for disposal in the SFPIC HIC may generate substantial quantities of gas, which combined with the gas generated by the PIC material may, in 300 years, produce an internal pressure which exceeds the pressure reported in the leak tightness test, therefore, resulting in failure of the HIC.

14. Table 7-1, page 34,' footnote.

It is unclear as to.which Section 3 calculations are being references in the footnote.

15.

Chapter 7,~page 36, paragraph 2.

(FreeDropTest).

The State of South Carolina (Barnwell site) has recently instituted a

- requirement for a free drop test similar to the State of Washington.

(See a

attachment). The South Carolina test requires a drop at four orientations (full bottom, sides, bottom corner and top corner) only the last three have been performed. The full bottom and top orientation should also be tested, or justification should be presented-to indicate that the previously performed tests are the more critical..

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16. Chapter 7, page 37,1st full par'agraph

.What was the basis for stating that the 400 1 container appeared to have

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less resistance to the corner drop tests?

It is suggested that minor word l.~

changes be made which explicitly indicate that the 34* drop angle corresponds to the center of gravity and that this represents the most conservative drop test.

17. Chapter 7, page 37, last paragraph.

a Did the cracking of the SFPIC liner as a result of the drop testing penetrate the SFPIC liner? What were the sizes of these cracks? The water leak tests following drop testing should be explained in more detail.

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18. Chapter 7, page 39, last paragraph.

s What were the sizes of the cracks observed in the fir'e test? Did they penetrate the SFPIC liner?

19. Chapter 9, page 41, paragraph 1.

The intrusion of carbonic gases is mentioned as a possible degradation process for plain concrete. What is the origin of carbonic gases?

20. Chapter 9, page 45 BTP C.4.a.

A description of the dewatering system to include test results should be included.

21. Chapter 9, page 46, BTP C.4.b.

Chemical compatibility regarding wastes and the trench environment should be discussed. We suggest addressing the chemical compositions in trench sump liquids provided in NUREG/CR-1289 and NUREG/CR-3993. _

22. Chapter 9, page 49 BTP C.4.k.

It states that the HIC lid can be filled with mortar after sealing to eliminate the accumulation of water A procedure to accomplish this should be described in Chapter 5 or another appropriate location.

23. Chapter 9, page 50, BTP C.4.1.

The inspection procedure should be provided for our review.

24. Chapter 9, page 51, BTP C.4.n.

The quality assurance program should be provided for our review.

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