ML20128A118
| ML20128A118 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/28/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NE-85-0720, NE-85-720, NUDOCS 8507020570 | |
| Download: ML20128A118 (2) | |
Text
_ __ _ _ _ - _ _ _ _ - _ _ _ _
l b
W e n2 Nuclear Operahons Formi-2 6400 Noch Owe Edison mwHignway ga.
June 28, 1985 UE-85-0720 Hr. L. B. Higginbotham Chief, Low-Level Uaste & Uranium Recovery Projects Branch Division of Haste Management U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Mr. Higginbotham:
Reference:
NRC License No. NPF-33 NRC Docket no. 50-341
Subject:
Performance of non-Brittle Uaste Forim at Burial Sites Detroit Edison Company is currently engaged in a 10CFR61 vaste form conformance program to qualify Class B and C solidified vaste to the stability requirements imposed by the Branch Technical Position on Waste Form.
The simulated wastes under investigation are asphalt-encapsulated liquids and resins generated at the Fermi 2 Uuclear Station.
A meeting was recently held with the Low-Level Uaste Licensing Branch to obtain comment on our conformance test program plan.
During this meeting, disturbing news was given by the Branch.
It-appears that the Branch intends to single out asphalt (and other non-brittle vaste forms) so as to require special administrative controls for backfilling at the burial site i
irrespective of performance in the tests specified in the Branch Technical position on waste form.
These controls might be imposed by way of a qualifier to the Branch's approval of our waste form test results.
It is a well recognized fact that non-brittle vaste forms I
exhibit plastic deformation or viscoelastic creep under compressive load.
This was acknowledged by the NRC and others during the public comment period for 10CFR61 and was viewed as a property which is not detrimental to stability if void spaces
]
are minimized according to law [(10CFR61.52(a) (4) and (5)].
j opsto "8" pf' f46'g 8507020570 850628 TO ADOCK 05000341 CfMM
/sh PDR p
i'
s G
Iir.
L.
D.
Higginbotham June 28, 1985 NC-85-0720 Page 2 The Low-Level Uaste Granch nov postulates that non-brittle vaste forms (minus their container) may creep into void spaces left adjacent to the vaste form.
Thus, in an improperly filled trench, if the vaste form deforms and fills the first void, another void of equal volume is created.
The Branch presumes that creation of this second void will cause trench subsidence.
The additional administrative controls for backfilling non-brittle vaste forms are, according to the Branch, designed to prevent this occurrence.
Detroit Edison strongly objects to the Branch's new position for tuo reasons.
First, the exchange of equal volume void spaces within the trench due to viscoelastic creep of the vaste form contributes nothing to trench subsidence.
The total void volume in the trench remains the same.
If the trench is improperly backfilled, this void space vill exist regardless of the vaste form that is placed in the trench.
- Hence, application of special administrative controls to one vaste form is inappropriate.
Second, and more importantly, 10CFR61 already stipulates that filling of void spaces between containers (regardless of the vaste form they contain) is required.
Redundant regulation in the form of administrative controls and their associated higher costs are not needed to assure burial site integrity.
All that is required is enforcement of the regulations that already exist.
Sincerely, f
/
s cc:
fir.
P. :1. Byron Mr.
M. David Lynch USHRC Document Control Desk Washington, D.
C.
20555