ML20128B580
| ML20128B580 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/15/1985 |
| From: | Butler W Office of Nuclear Reactor Regulation |
| To: | Mittl R Public Service Enterprise Group |
| References | |
| NUDOCS 8505240582 | |
| Download: ML20128B580 (48) | |
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MAY 15 1985 Docket No. 50-354 Mr. R. L. Mitti, General Manager Nuclear Assurance and Regulation Public Service Electric & Gas Ccmpany P.O. Box 570, T22A Newark, New Jersey 07101
Dear fir. liitti:
SUBJECT:
SOLID WASTE PROCESS CONTROL PROGRAM The Hope _ Creek Safety Evaluation Report states that PSE&G needs to submit for NRC approval the solid waste process control program (PCP) before processing any solid waste. By letter dated April 8,1985, you submitted the Hope Creek PCP
'for staff review.
We have conducted a limited review of the PCP and have concluded it is weak in a number of areas.
In particular, it does not adequately address the product c
sample and evaluation program, the prequalification program and the quality assurance and control prograns.
To assist you in preparing a PCP, we have developed the enclosed document entitled " Guidelines for Preparation of a Solid Waste Process Control Progran."
This document is intended to provide a framework for the developnent of a PCP acceptable to the staff. Accordingly, the PCP submitted by your April 8,1985 letter should be revised to incorporate the guidelines discussed in the enc:osed
'dccument. Please call us if you should have any questions.
Sincerely, Orisiaal signea by t Walter R. Butler, Chief Licensing Branch No. 2 Division of Licensing
Enclosure:
As stated cc: See next'page Distribution: ; DoskitTF.ile' NRC PDR Local PDR PRC System NSIC LBi2 Reading-Ellylton DWagner Dewey,0 ELD ACRS (16)
JPartlow BGrimes EJordan RFell Il LST27h PM LB#2/DL/BC DWagner:1b WBut r 05/II/85
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UNITED STATES
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{i NUCLEAR REGULATORY COMMISSION
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% *****y MAY 151985 Docket No. 50-354 Mr. R. L. Mittl, General !!anager Nuclear Assurance and Regulation Public Service' Electric a Ocs Company P.O. Box'570, T22A Newark, New Jersey 07101
Dear Ir. fiitti:
SUBJECT:
SOLID WASTE PRCCESS CONTROL PROGRAM The Hope Creek Safety Evaluation Report states that FSE60 r.eeds to subnit'for flRC approval the solid waste process control program (PCP) before processing any solid wcste. By letter dated April 8, ICEE, you submitted the Hope Creek FCF for staff review.
We have ccr. ducted a limited review of the PCP and have concluded it is weak in a number of areas.
In particular, it does not adequately address th prcduct sample and evaluation program, the prequalification program and the quality assuran.e and control programs; To assist you in preparing a PCP, tee have developed the enclosed dccult.cnt entitled " Guidelines for Preparation of a Sclic Huste Process Control Program."
This document is intended to provide a framework for the develepn.ent of a PCP acceptable to the staff. Accordingly, the PCP submitted by ycur April 8, 1985 letter should be revised to incorporate the guidelines oiscussed in the enclosed
-document. Please call us if you should have any questiens.
Sincerely, a
f
!! alter R. Butler, Chief r
Licensing Branch No. 2 Division of Licensing 7
Enclosure:
j As stated cc: See next page l
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o Er. h. L. hittl Hope Creek Ger.cratirg Station
~ Public Service Electric & Gas Co.
cc: Gregory Minor Susan C. Penis Richard Hubbara Divisicn of Public Interest Advocacy Dale ' Brider.beugh New Jersey State Departr;ent ef HHB Technical Asscciates the Public Acvccate 1723 Hamilton Avente, Suite A Richarc J. huges Justice Ccr2ples Sar. Jcse, Celifornia 95125 CN-850 Trenton, New Jersey CE6' 5 c
Trcy b. Conner, Jr. Esquire Office of Legal Ccun*.el Conner & Wetterhahn Departrent of Natural Resources 1747 Perrsylvania Avenue N.W.
and Environmental Ccntrol Washingtcn, D.C.
20006 65 Kings Highway P.O. Box 1401 Ccycr, Celaware 19903 Richard Fryling, Jr., Esquire Dr. K. h. Burrcwes, Frcject Engineer Associate Genercl Solicitor Bechtel Power Corporaticr.
-Public Service Electric & Gas Co.
50 Beale Street P. O. Box 570 T5E P. C. Cox 3965 flewark, New Jersey 07101 San Frar cisco, California 94119 fir. R. Bicugh Mr. J. ft. Ashley Eesiaent Inspector Senior Licensir.g Engineer U.S.N.R.C. L c/o Public Service Electric h Gas Co.
P. O. Box.241 Bethesda Office Center, Suit 550 Hancocks Bri.dge, hew Jersey 08038 4520 East-Lest Highway Bethesda,11aryland 20814 Richara F. Engel Deputy Attorney Genere.1 Pr. A. E. Giardino Division of Law Hanager - Quality Assurance E&C Environmental Protection Section Public Service Electric & Gas Co.
Richard J. Hughes Justice Complex P. O. Ecx A Ch-112P Hancocks Bridge, i;cw Jersey 08038 Trenten, flew Jersey 08625 Mr. Robert J. Touhey, Mr. Anthony J. Pietrofitta Acting Director General Manager DNREC - Division of Power Prcduction Engineering Environmental Control Atlantic Electric E9 Kings Highway 1199 Black Horse Pike P. O. Box 1401 Pleasantville, hd 06232 Dover, Delaware 19903 Mr. Thcmas E. Furley Mr. R. S. Salvesen U. S. NRC, Region I General Manager-Hope Creek Operation 631 Park Aver.te Public Service Electric & Gas Co.
King of Prussia, Pennsylvania 19406 P.O. Box A Hareccks Bridge, New ' Jersey. CCC2E Hr. B. A. Prestct, Project Licensing Fer.ager Public Service Electric & Gas Co.
P. O. Box 570 T22A Newark, Few Jersey 07101
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of facilities for the land disposal of low-level radioactive waste. The majority of these requirements are contained in 10 CFR Part 61 " Licensing
-Requirements for Land Disposal of Radioactive Waste." Some additional requirements, directed primarily at waste generators and handlers,
-including certification and use of shipping manifests, were concurrently pubitshoc-in 10 CFR Part 20.311, " Transfer for Disposal and Manifests" (Ref. 3).
Section 20.311 of 10 CFR Part 20 requires that any licensee who transfers
. radioactive waste to a land disposal facility or to a licensed waste collector or processor must classify the waste according to 10 CFR Part 61.55, " Waste Classification". Section 61.55 defines low-level radioactive waste suitable for land disposal as falling into one of three categories:
1.e., Class A waste, Class B waste, and Class C waste. The waste class is based on the radionuclide concentration in the final waste form. Wastes hav,ing radionuclide concentrations exceeding those allowed for Class C waste are generally considered unacceptable for near-surface disposal. Wastes determined to fall into one of the classes must be labeled as such in accordance with 10 CFR Part 61.57, " Labeling". Waste generators and waste processors must record on shipping manifests, a description and classification of the waste forms.
All three classes of waste are required to meet certain minimum physical requirements as set forth in 10 CFR Part 61.56(a), " Waste Characteristics", which are intended to facilitate handling of waste at the' disposal site and, provide protection of public health and safety.
Class-B and Class C wastes, however, are reqcired to meet more rigorous requirements on stability. These stability requirements are set forth in l
10 CFR Part 61.56(b). ~ Class C wastes requires additional measures at the disposal facility to protect against inadvertent intrusion.
The NRC prepared a Branch Technical Position (BTP) identifying methods and parameters acceptable to the staff for demonstrating compliance to 10 CFR Part 61 which is contained in this report as Appendix A.
The licensee should be cautioned that the ETP addresses the Federal regulations and does not necessarily address more restrictive State regulations and other requirements governing the disposal of low-level radioactive wastes.
1.3 Ignas 4
- The purpose of the licensee's PCP is to describe the envelope within which processing and packaging of low-level radioactive wastes will be accomplished to provide reasonable assurance of compliance with low-level waste regulations and requirements. The PCP should address requirements imposed by the State or other agencies that are more restrictive than the Federal regulations.
The licensee's PCP_ shall be a manual containing a general description of the methods for controlling the processing and packaging of radioactive waste, specific parameters pertaining to each method, manifest preparation and the quality assurance provided to verify compliance with applicable regulations and requirements.
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DRAFI GUIDELINES FOR PREPARATION OF A SOLID WASTE PROCESS CONTROL PROGRM l
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E.BCC M Changing, modifying, or packaging the commercial nuclear power plant generated radioactive waste into a form that is acceptable by a disposal site.
QUALITY ASSURANCE /CUALITY CONTROL As used in this document, " quality assurance" comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.
Quality assurance includes quality control, which comprises those quality assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means to control the quality of the material, structure, component, or system to predetermined requi rements.
SAMPLING PLAN A sampling program implemented to ensure that representative samples from the feed waste and the final waste form are obtained and tested for agreement to the acceptance criteria.
STABILITY As used in this document, " stability" means structural stability.
Stability requires that the waste form maintain its structural integrity under the expected' disposal conditions.
P VERIFICATION SAMPLE A representative sample obtained from the waste form and tested to demonstrate control of the waste processing. The sample shall be obtained from at least every tenth batch of waste processed or a sample obtained for at least every 5000 gallons of batch waste processed, wichever is more frequent.
MA E Those low-level radioactive wastes containing source, special nuclear, or by-product matertal that are acceptable for disposal in a land disposal facility. For the purposes of this definttfon, low-level waste has the same meaning as in the Low-Level Waste Policy Act, that is, radioactive waste not classified as high-level radioactive waste, transuranic waste, spent nuclear' fuel, or by-product material as defined in section 11e.(2) of the Atomic Energy Act (uranium or thorium tailings and waste).
WASTE CONTAINER A vessel of any shape, size, and composition used to contain the final processed waste for sending to a disposal-site.
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4 ABSTRACT This report provides NRC recommended guidelines to be used by licensees of commercial nuclear power plants to prepare a' solid waste Process Control Program (PCP). The PCP will be a controlled document containing a description of the methods used for processing low-level radioactive waste by the plant into a waste form acceptable for disposal at a licensed land disposal facility.
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(1) Waste must not be packaged for disposal in cardboard or fiberboard boxes (2) Liquid waste must be solidified or packaged in sufficient absorbent material to absorb twice the volume of the liquid.
(3) Solid waste containing liquid shall contain as little free standing and noncorrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 15 of the volume.
(4) Waste must not be readily capable of detonation or of explosive i
decompostion or reaction at normal pressures and temperatures, or of explosive reaction with water.
(5) Waste must n.ot contain, or be capable of generating, quantities of toxic gases, vapors, or fumes harmful to persons transporting, handling, or disposing of the waste. This does not apply to radioactive gaseous waste packaged in accordance with item (7) of this section.
4 (6) Waste must not be pyrophoric. Pyrophoric materials contained in waste shall be treated, prepared, and packaged to be nonflammable.
(7) Waste in a gaseous form must be packaged at a pressure that does not exceed 1.5 atmospheres at 200C. Total activity must not exceed 100 curies per container.
4 (8) Waste containing hazardous, biological, pathogenic, or infectious material must be treated to reduce to the maximum extent practicable the potential hazard from the non-radiological materials.
2.2.2 Stability Requirements In addition to fulfilling the eight minimum requirements, Class B and Class C wastes must fulfill she stability requirements of 10 CFR
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61.56(b). These requirements are clarified in the attached BTP on Waste Form. The following waste processing methods are acceptable to the NRC to satisfy the stability requirements:
o Solidification o
Encapsulation o
High Integrity Container Usage o
Entombment Waste solidification is a process of thoroughly mixing the waste with a solidification agent, whereas waste encapsulation is a pro:ess of surrounding or containing the waste in a solidification agent. As an option to the solidification or encapsulation methods to provide stability, the waste may be packaged in high-integrity containers. Some low-level radioactive wastes may also be entombed at the disposal site.
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TABLE OF CONTENTS ABSTRACT..............................
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INTRODUCTION..........................
1 1.1 Pu rp os e..........................
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1.2 Background
1 1.3 Scope...........................
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1.4 De fi n i ti ons........................
3 2.
2.1 System Description and Operating Procedures........
5 2.2 Radioactive Waste Characteristics.............
.5 2.2.1 Min imum Requi rements.,...............
5 2.2.2 Stab i l i ty Requ i rements...............
6 2.2.2.1 Solidi fication Method............
7 2.2.2.2 Encapsulation Method.............
8 2.2.2.3 High Integrity Container Usage........
9 2.2.2.4 Entombment Method..............
9 2.3 ' Contracted Vendor.....................
9 2.4 Waste Classification 10 2.5 Shipment Manifest.....................
11 2.6 Administrative Controls..................
11 2.6.1 Documentation Controls...............
12 2.5.2 Quality Assurance i................
12 2.6.3 Training......................
12 2.6.4 Record Retention..................
12 3.
REFERENCES...........................
14 APPENDIX A - BRANCH TECHNICAL POSITION...............
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zThe PCP shall require that the production level process parameters be implemented in the seltdtftcation process by including the parameters in operating procedures and having qualified operators to provido assurance the process is performed within the parameters.
.Pricrto solidifying waste, a representative sample of the feed waste from isolated (if possible) and thoroughly mixed tanks shall be analyzed to verify the production process parameters and also processed to assure the sample will solidify.. A new sample must be obtained when the composition of the waste changes. Upon verification of solidification-of the test sample, full-scale processing of the waste may begin. During-p rocessing, the tank (s) shall remain isolated and thoroughly mixed.
Production level sampling of the solidified product for verification of acceptable waste forms should be performed.at no less than 1 sample per 10 batches or 1 sample per 5000 gallons of waste to be processed. The verification test performed on the solidified sample shall be a compression test in accordance with ASTM C39 or ASTM 01074 following a 14-day f amersion.
It must be demonstrated that the sample test results are similar to the prequalification test results. This demonstration shall be provided prior to shipping solidtfied waste forms produced subsequent to the last sample verified.
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The licensee's PCP shall describe their sampling and testing guidelines and provide a sampling schedule. The Itcensee's PCP shall describe the method for providing assurance that the composition of the media used for solidification is equivalent to that used for.the prequaltftcation testing.
2.2.2.2 Encapsulaticn Method Encapsulation is an acceptable-method for providing stability for certain Class B and Class C wastes. If this method is used, a brief description of the waste encapsulation method must be provided in the PCP with the
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processing parameters identified. The processing parameters provide boundary conditions for processing the waste to provide reasonable assurance the final waste form will meet the stability requirements.
- The encapsulating media must satisfy the stability guidelines of Sections B and C of-the BTP on Waste Form contained in Appendix A of this document.
Specifically, the final waste form (waste and encapsulation modta) should be capable of maintaining at least a 50 pst come' assion strength.
Generally, credit for the structural strength of the waste material,
'(e.g., filter cartridges) should not be allowed unless it can be demonstrated that it will not. degrade in 300 years. This prequalification can be demonstrated by analyses or tests. If analyses are used, actual 4
compression strength data for the solidification agent should be referenced. As a condition for PCP approval, the prequalification test data and the resultant process parameters shall be submitted to the NRC.
The use of generic test data to prequalf fy the encapsulating media would be acceptable.
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INTRODUCTION 1.1' E E E.Q11 The purpose of this document is to provide guidance to the licensees of commercial nuclear power plants in preparation of their low-level radioactive waste Process Control Programs (PCP). Standard Technical Specification 3.11.3 in NUREG-0472 (Ref.1) and NUREG-0473 (Ref. 2) calls for the operator of each commercial nuclear power plant to process the low-leve) radioactive wastes in accordance with a PCP.
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Nothing in this report relieves the licensee from complying with appitcable regulations (Federal, State and disposal site) and other requirements governing the disposal of the radioactive waste.
1.2 Backaround i
Low-level radioactive wastes are produced at a nuclear power plant as a result of routine plant operation and maintenance of the plant's systems.
Examples of the systems ares (1) Reactor water clean-up system (2) Spent fuel pool clean-up system
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(3) Condensate clean-up system (4) Liquid radwaste system (5) Gaseous radwaste system (6) Chemical wastes clean-up system (7) Hot shower / laundry waste system These systems or the maintenance of these systems generate low-level radioactively contaminated wastes such ass (1)' Boric acid i
(2) Sodium sulfate (3) Bead resins (4) Powdex (5) Filter sludge (6) Spectfic decontamination wastes (7) Specific organic liquids (8) Charcoal
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(9) HEPA filters In addition to these waste types, there are compactible and non-compactible wastes, (e.g., anti-contamination clothing, tools, etc.)
and radioactively contaminated oils. Waste volumes may be reduced as a result of incineration or calcination resulting in radioactive waste in the form of incinerator ash or calciner bottoms.
The majority of the low-level radioactive wastes generated are processed and packaged for near-surface disposal at a licensed disposal site. By Federal Register Notice dated December 27, 1982 (47 FR 57446), the NRC amended its regulations to provide specific requirements for the licensing 1
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require to a management review of the vendor's topical report to assure vendor operation and requirements are compatible with plant operation and I
plant responsibility. The licensee's PCP shall also contain a description of services and p-lant interfaces required by the vei. dor, for examples (1) Radwaste supply
= (2) Electrical-power (3) Flush water and ' drains (4) Shielding (5) Radioactive effluent controls and monitoring (6) Health physics ' support (7) Fire protection (8) Communication (9) Heating and ventilation system (10) Temporary waste holding tanks The purpose of identifying plant and service interfaces is to ensure all necessary safety precautions have been addressed and considered prior to full-scale processing. For example, a vendor's outside temporary tanks may be limited to 10 curies of liquid waste per tank as required by Standard Technical Specification 3.11.1.4 in References 1 and 2.
The licensee's PCP shall require a verification that the test results of samples obtained from vendor processed waste are similar to the vendor's prequalification test sample results. - The same production level sampling and evaluation methods listed in Section 2.2.2.1 are ap'plicable to service
-vendor production controls.
2.4 waste classiff eation Wastes acceptable for near-surface disposal must be classified as Class A, Class B or Class C for the purpose of segregation at the disposal site.
The waste class is based on the concentration of certain radionuclid'es in the waste form as given in 10 CFR 61.55.
There are four methods suggested for determining the radionuclide concentrations (1) Materials accountability (2) Classification by source (3) Gross Radioactivity measurements (4) Direct measurement of individual radionucifdes Detailed discussions of these methods and the frequency for determining the radionuclide concentrations are included in Sections C.1 and C.2 of the BTP on Waste Classification contained in Appendix A of this document..
The licensee's PCP shall identify the methods and procedures used and the frequency for determining the radionuclide concentrations. Radionuclide concentrations shall' be determined based upon the volume or weight of the final waste form as discussed in Section C.2 of the BTP on Waste J
Classification. The PCP shall also describe the methodology and reference the main procedures for classifying the final waste form.
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c The PCP shall contain a prequalified mixture fonnula, sampling methodology, controlled specimen tests and analysis with acceptance criteria, system description and any other determinations to be made for the processing and packaging of low-level radioactive wastes. Inherent in the PCP will be the quality assurance and quality control for processing and packaging the low-level radioactive wastes.
All commercial nuclear power plants must have an NRC approved PCP even if a contracted vendor is processing and packaging the waste. If the vendor has an NRC approved topical report on waste processing, it shall be referenced in the licensee's PCP. If a vendor does not have an NRC approved topical report, the vendors report must be included with the licensee's PCP for NRC approval and will be reviewed by NRC on a case by case basis. If the waste is processed by a vendor, a description of'the plant-to-vendor equipment interface and the. vendor's service requirements must also be addressed in the licensee's PCP.
1.4 Definitions MT.Cli l
An isolated quantity of food waste to be processed having constant l
physical and chemical characteristics.
CHELATING AGENT For the purpose of this document chelating agents are amine polycarboxylic acids (e.g., EDTA, DTPA), hydroxy-carboxylic acids, and polycarboxylic acids (e.g., citric acid, carbolic acid, and glucinic acid) as defined in 10 CFR Part 61.2.
INADVERTENT IMTRUDER A person who might occupy the disposal site after closure and engage in normal activities, such as agriculture, dwelling construction, or other pursuits in which the person might be unknowingly exposed to radiation from the waste.
I OPERAELE A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s),
and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function (s) are also capable of performing their related support function (s).
PRE 31ALIFICATION PROGRAM The testing program implemented to demonstrate that the proposed method of waste processing will result in a waste form acceptable to the land disposal facility.
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t WASTE 3CPN Waste in a final packaged form acceptable for shipment to a licensed near-surface disposal facility.
- 2.. PROCESS CONTROL PROGRAM t
The Itcensee's PCP must address the following areas for processing all t
wastes:
System Description and Operating Procedures o
o Radioactive Waste Characteristics o
Ccatracted Vendor (If applicable) o Radioactive Waste Classiffcation l
o Manifest Preparation o
Administrative Controls 2.1 Svstem. Descrintion and Goeratina Procedures A brief description and block diagram of the flow paths for the processing systems (e.g., compaction system, solidification system, encapsulation system, or dewatering system) shall be provided in the PCP. Components of the system that monitor process parameters should be included, for
-example, flow meters, torque meters, and temperature meters.
Periodically or prior to use, the waste processing equipment must be operated and maintained to assure that the equipment will be cperable within the parametecc established in the PCP. The PCP shall specify a surveillance schedt le to demonstrate operability '. ' tife system. Plant procedures should i ichde this requirement as a pierequisite to processing j
t the waste. In addition, all gennano procedures associated with sampling, classification, solidification and product verification should be
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referenced or included with the PCP.
2.2 Radiometive waste characteristics 2.2.1 Minimum Requirements The eight minimum waste characteristic requirements identified in 1,0 CFR 61.56(a) and listed below shall be satisfied for the three waste classes.
The licensee's PCP must ensure these minimum requirements are satisfied for Class A, Class B and Class C wastes. The following requirements are minimum requirements for all classes of waste and are intended to l
facilitate handling at the disposal site and provide protection of health and safety of personnel at the disposal site.
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2.2.2.1 Solidification Method A brief description of the waste solidification methods used at a plant must be provided in the PCP with the established process parameters identified. The operating process parameters or equipment settings provide boundary conditions for processing the waste to provide reasonable assurance the final waste form will meet the stability requirements.
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These process parameters are influenced by (a) characteristics of the waste prior to processing, (b) qualities of the solidification agent, and (c) the physical process of preparing the waste into a final waste form.
The variables that influence the process parameters include, but are not e
limited to:
(1) Type of waste (e.g., bead resins, powdered resins, boric acid solutions, etc.)
(2) Composition or charact'erization of the waste having influence on the final waste form (e.g., pH, oil content, chelating agents, water content, etc.)
(3) Solidification agent and additives (e.g., coment, water, lime, cement with sodium silicate, asphalt, polyester, etc.)
(4) Physical process parameters (e.g., temperature, mixing times, curing times, etc.)
The production level process parameters are established upon completion of prequalification testing of the waste form.
2.2.2.1.1 Prequalification Tests Prequalification tests must be performe. on a test specimen of the waste form to demonstrate stability compliance to the criteria contained in Sections B and C of the ETP on Waste Form contained in Appendix A of this-document. As a condition for PCP approval, the prequalification test data and the resultant process parameters shall be submitted to the NRC.
Testing may be performed on simulated nonradioactive wastes. However, the leacha0111ty index determination may require radioactive tracers. If testing is performed on laboratory size specimens the PCP should describe the methods used to correlate the test data results to full-scale production waste forms.
l 2.2.2.1.2 Production Level Sampling Once the prequalification test program is completed, processing wastes within the established production level process parameters should provide reasonable assurance that an acceptable waste form will be produced. As a means to assure that the production process is in control and the final L
waste form is acceptable, a production level sampling method and evaluation program must be implemented.
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To on?.ure an acceptable waste form, there must be adequate encapsulating media surrounding the waste to provide stability. The PCP shall describe the method that assures adequate encapsulating material surrounds the i
waste.
Processing wastes by the encaprulation method within established process parameters should provide reas Jnable assurance that'the final waste form will meet the stability criteria. The PCP shall require that the process parameters be implemented in f.he encapsulation process by including the parameters in the operating p.ocedures.
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The licensee's PCP shall des: ribe the method for providing continual assurance that the composition of the media used for encapsulation is equivalent to that accepted during the prequalification testing.
2.2.2.3 High Integrity' Container Usage With approval from the land disposal facility, wastes may be disposed of in approved high-integrity containers (HIC). The HIC must be designed and j
constructed to comply with the acceptance criteria discussed in the BTP Section C.4 on Waste Form contained in Appendix A of this document.
The licensee's PCP shall provides assurance that the HIC is State certified for the land disposal facility; a physical and chemical description of the waste that can be packaged; and assurance that the waste form is compatible with the HIC. The licensee's PCP shall include a j
description of any dewatering process. The licensee's PCP shall describe the methods used and the tests employed to verify less than 15 free standing liquid by volume in the HIC.
2.2.2.4 Entombment Method Licensee's may find entombment as an acceptable alternative for disposal of wastes not compatible with the previously discussed processing methods.
With approval from the land disposal facility, some wastes may be entombed at the disposal site. The licensee's PCP shall identify the type or category of wastes approved for entombment, e.g., structural components, pumps, etc. The licensee's PCP shall include a description of the requirements or a reference to the requirements by the land disposal facility for the preparation and packaging of the waste.
l 2.3 contracted vender The licensee may obtain the services of a contracted vendor to process and package the waste on site. Vendor's documents containing a description of
+he vendor's equipment and waste processing methods and vertf tcation of an acceptable waste form will be, referred to as the vendor's topical report.
i The licensee's PCP shall identify the contracted vendor (s) and include a copy of the vendor's topical report. The vendor's topical report need only be 6eferenced if it has NRC approval. The licensee's PCP shall i
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2.5 shfoment uanffant Each shipment of radioactive waste to a licensed land disposal facility must be accompanied by a shipment manifest as required by 10 CFR 20.311(b) and 10 CFR 20.311(c). The licensee's PCP shall assure the manifest contains the name, address, and telephone number of the person generating i
the waste. The manifest shall also include the name, address, and l
telephone number or the name and EPA hazardous waste identification number of the rerson transporting the waste to the land disposal facility. The I
manifest must also indicate as completely as practicable:
a physical description of the waster the volume; radionuclide identity and quantity; 4.
the total radioactivity; and the principal chemical form. The solidification agent must be identified. Waste containing more than 0.15 chelating agents by weight must be identified and the weight percentage of the chelating agent estimated. Wastes classified as Class A, Class B, or Class C must be clearly identified as such in the manifest. The total U
quantity of the radionuclides H-3, C-14, Tc-99 and I-129 must be shown.
The manifest required by this paragraph may be shipping papers used to 4
meet Department of Transportation or Environmental Protection Agency regulations or requirements of the receiver, provided all the required information is included. Copies of manifests required oy this section may be legible carbon copfes or legible photocopies.
l Each manifest must include a certification by the waste generator that the
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transported materials are properly classified, described, packaged, marked, and labeled and are in proper condition for transportation according to the applicable regulations of the Department of
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Transportation and the Commission. An authorized representative of the waste generator shall sign and date the manifest.
I The licensee's PCP shall identify any additional information required on the manifest by the land disposal fact 11ty.
A manifest recordkeep'ng and tracking system must also be implemented to meet the requirements of 10 CFR 20.311(d). The licensee's PCP shall identify the organizations having responsibilities for fulfilling the tracking system requirements. A copy of the manifest form used by the licensee should be included with the licensee's PCP.
L 2.6 Administrative controln Administrative controls are required to ensure all processing is performed i
in accordance with the approved PCP. The organizations responsible for ensuring compliance with the licensee's PCP shall be clearly designated in the PCP with a clear delineation of their authorities and 4
i responsibilities.
The following areas are of major concern in this sections e
Documentation Control e
Quality Assurance e
Training e
Record Keeping 11
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r 2.6.1 Documentation Control Audits of implementing procedures shall he performed by the responsible organizations at least once every 24 months. Any changes to the procedures shall be reviewed to. ensure continual compliance with the requirements and process parameters of the licensee's PCP. Radioactive wastes not described within the licensee's PCP or wastes that do not fall within previous waste processing experience must be evaluated and approved 4
for inclusion in the PCP by the authorized organizations prior to processing for packaging and disposal. Licensee initiated changes to the PCP shall be submitted to the NRC. This documentation control shall be
~
4 discussed in the licensee's PCP.
2.6.2 Quality Assurance The Itcensee shall establish and maintain a quality assurance (QA) program to assure compliance with the PCP. The licensee's PCP shall also describe the Administrative controls designed to prevent solidified waste forms from being released for shipment prior to test sample verification of acceptability. Charts illustrating the sequence of events of the Ifconsee's PCP shall be provided to the NRC. An example for a solidification process is shown in Figure 1.
The QA program shall be described in the 11eensee's PCP. The QA program shall assure compliance with the waste classification and characterization requirements of 10 CFR Parts 61.55 and 61.56. The programs shall also include audits and management evaluations of such audits to satisfy the requiremer.ts of 10 i
CFR Part 20.311 (d) (3). In addition, the licensee shall establich proper l
controls on manifest preparation and tracking to satisfy the requirements of 10 CFR Part 20.311.
In case of a contracted vendor processing the wastes, the licensee's PCP shall address a quality assurance program requiring a management review of the vendor's topical report. This review will also assure that the vendor's operations and requirements are compatible with the i
(;
responsibilities and operation of the plant. The service vender shculd i;
comply-with all quality assurance steps required by the licensee's PCP.
I 2.6.3 Training A training program shall' be developed and implemented for personnel having responsibilities related to waste processing operations to ensure the waste processing shall be performed within the requirements of the PCP.
The training program shall be repeated and the personnel requalified on an acceptable periodic schedule. The individual's training records shall be maintained for audit and inspection. The itcensee's PCP shall specify the use of qualified and trained operators.
i 2.6.4 Record Retention It shall be stated in the Itcensee's PCP that records of all processing data, test and analysis results, documents on manifest preparation and tracking, and.results of training, inspection and audits etc. will be retained in accordance with the plant standard quality assurance procedures for record retention.
12
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Figure 1.
Example flow chart illustrating the sequence of events for a waste solidification process.
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3.
REFERENCES 1.
U.S. Nuclear Regulatory Commission, " Radiological Effluent Technical Specifications for PWR's,r NUREG-0472 Oraft Revision 3, Septemoer 1982.
2.
U.S. Nuclear Regulatory Commission, " Radiological Effluent Technical Specifications for BWR's," NUREG-0473 Draft Revision 3, September 1982.
3.
10 CFR Parts 20, S0 and 61, " Energy," Office of the Federal Register, U.S. Government Printing Office, Washington, January 1,1984 e
14
APPENDIX A BRANCH TECHNICAL POSITION This appendix is a reproduction of the NRC's Low-level Waste Licensing Branch's Technical Position papers on the Waste Classification and the Branch Technical Position on the Waste Form.
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UNITED STATts NUCLEAR REGULATCRY CCMMISSION I
wasmestom.m. c.zoess f
%,W/
MAY 11283 nw l
ATTENTICN:
Commission Licensees SUEJECT:
FINAL WASTE CLASSIFICATION AND WASTE FORM TECHNICAL POSITION PAPERS r
By Federal Recister Notice dated December 27, 1982 (47 FR 57446), NRC amended its regulations to provide specific requirements for licensing facilities for the land disposal of low-level radioactive wasta.
The majority of these require-ments are contained in a new Part 61 to Title 10 of the Code of Federal Regula-tions (10 CFR Part 61) er) titled "Licensi~ng Requirements for Land Cisposal of Radioactive Waste." Some additional requirements directed primarily at waste
]
generators and handlers including certification and use of shipping manifests were concurrently published as a new 5 20.311 of Part 20 (" Standards for i
Protaction Against Radiation").
1 As noted in the December 27 Federal Recister Notice, the effective data of 10 CFR Part 20, 5 20.311 is Decameer 27, 1983, while the effective date of 10 CFR Part 61 and all other amendments is January 26, 1983.
Section 20.311 l
requires that any licensee who transfers radioactive waste to a land disposal facility or to a Itcensed wasta collector or processor must classify the waste according to 5 61.55 of 10 CFR Part 61.
Licensed wasta processors who treat or repackage radioactive wasta for disposal into a land disposal facility must also classify their wasta according to 5 61.55.
This section defines radio-active waste suitable for disposal as falling into one of three classes (Class A, Class B, or Class C), and wasta is determined to fall into one of the classes by comparison to limiting concentrations of some particular listed radionuclides.
Class B and C wastes are subject to wasta stability requirements which are set forth in 5 61.56 of the rule.
In addition, 5 20.311 also requires that wasta generators record on shipment manifests a description of the transferred wasta as well as a certification that the waste is properly classified and that the sanifest is filled out correctly.
Licensees must also conduct a quality control program to assure compliance with the wasta classification and waste stability 1
requirements.
~
NRC staff recognizes that the new requirements may result in some modifications
]
to existing licensee wasta management practices, and furthermore believes that it will be useful to licensees to begin planning for implementation of the new requirements in advance of the December 27, 1983 effective data.
At this time NRC staff is preparing Regulatory Guides on both wasta classification and waste form.
To provide immediata guidance to licensees, however, the NRC Low-Level Wasta Licensing Branch has prepared technical pos'ition papers on wasta classifi-cation and wasta form.
1 Thj wasta classification technical position paper describes overall procedures acceptable to NRC staff which may be used by licensees to determine tne presence i
and concentrations of the radionuclides listed in 5 61.55, and thereby classify-ing wasta for near-surface disposal.
This technical position paper also provides guidaace on the types of information which should be included in shipment mani-fests accompanying waste shipments to near-surface disposal facilities.
1
, -. _ _. _. _ _. _, _ ~. _ _ _..
I
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Commission Licensees The tecnnical position paper on waste form provides guidance to waste generators i
on test methods and results acceptable to NRC staff for implementing the 10 CFR Part 61 waste form requirements.
It can be used as an acceptable approach for demonstrating comoliance with th 10 CFR Part 61 waste structural stability l.
criteria.
This technical position paper includes guidance on processing waste into an acceptable stable fom, designing acceptable high-integrity containers, packaging cartridge filters, and minimizing radiation effects on organic fon-exchange resins.
The guidance in the waste form technical position paper may be used by licensees as the basis for qualifying process control programs to meet the waste fem sta-bility requirmnents, including tests which can be used to demonstrate resistance to degradation arising from the effects of compression, moisture, microbial activ-1 l
ity, radiation, and chemical changes.
Generic test data (e.g., topicaT reports prepared by vendors who market solidification technology) may be used for process i
control program qualification where such generic data is applicable to the particular types of waste generated by a licensee.
While the NRC staff has not formally reviewed or aproved any products, NRC staff believes that solidification processes and high-integrity containers currently
.. exist that can be qualified to meet the waste form stability requirements.
Licensees and vendors should continue their efforts to have qualified products available in advance of the December 27, 1983 implementation deadline.
NRC staff will continue to work with licensees and vendors to meet the waste form require-ments and implementation deadline.
NRC staff will also continue to coordinate their work with cognizant representatives of States which currently have licensed low-level waste disposal sites.
Oraft versions of both technical position papers have previously been made avail-able to interested members of the public.
Comments received on these drafts have been considered during development of the technical position papers being pub-lished at this time.
Further public comment on these technical positions is i
welcomed, and any such comment received will be considered during preparation of the waste classification and waste form Regulatory Guides.
Comments on the tech-nical position papers may be forwarded to myself (Address:
U.S. Nuclear Regula-tory Commission, Washington, DC, 20555, mailstop 55-623).
Questions on the tech-nical position papers may be referred to Mr. Paul H. Lohaus (301-427-4500), to Mr. G. W. Roles (301-427-4593), or to Mr. Timothy C. Johnson (301-427-4697) of my
+
staff.
The wasta classification and waste form technical position papers are included as attachments to this letter.
The information collections contained in these technical positions have been approved under OMB number 3150-0014.
0A.
Leo B. Hig ham, Chief Low-Level Weste Licensing Branch Division of Waste Management J
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May 1983 i
Rev. 0 I
f I'
LOW-LEVEL WASTE LICENSING BRANCH l
TECHNICAL POSITION ON j
RADICACTIVE WASTE CLASSI.:ICATION A.
Introduction j
Section 20.311 (" Transfer for Disposal and Manifests") of 10 CFR Part 20
(" Standards for Protection Against Radiation") requires that any licensee who l
transfers radioactive waste to a land disposal facility or to a licensed wasta collector or processor must classify the wasta according to Section 61.55
("Wasta Classification") of 10 CFR Part 61
(" Licensing Requirements for Land Disposal of Radioactive Waste").
Section 20.311 also requires that any licensed waste processor who treats or repackages radioactive waste for disposal into a f
land disposal facility'also classify their waste according to Section 61.55.
t Section 61.55 defines radioactive wasta suitable for land disposal as falling i
into one of three categories--i.e., Class A wasta, Class 8 waste, and Class C wasta. Wastes r.e determined to fall into one of the classes by comparison to limiting conc a trations of particular radionuclides which are set forth in Tacle 1 N.a Table 2 of Section 61.55.
Wastes determined to fall into one of the classes must be labeled as such in accordance with Section 61.57 (" Labeling").
Waste generators and wasta processors must record on shipment manifests a description of-the transferred waste, and must also carry out a quality control program to assure that classification of waste is carried out in a proper manner.
All three classes of waste are required to meet certa'in minimum i
i requirements as set forth in paragraph 61.56(a) of Section 61.56 ("Wasta Characteristics") which are intended to facilitate handling of waste at the disposal site and provida protection of pubite health and safety.
Class 8 and i
Class C wastes, however, are required to meet more rigorous reqJirements on l
waste stability.
These stability requirements are set forth in paragraph i
61.56(b) of Section 61.56.
Class C waste must be also identified to allow for additional disposal procedures to be carried out at the disposal site to provide t
f protection te a potential inadvertent intruder.
Finally, wastes having concen-trations of particular radionuclides exceeding those allowed for Class C waste j
are generally considered unacceptable for near-surface disposal.
This technical position describes overall procedures acceptable to the regulatory staff which may be used by licensees to determine the presence and concentrations of radionuclides listed in Section 61.55, and thereby classifying l
waste for near-surface disposal. The technical position also provides guidance and clarification on the minimum types of information which should be included on shipment manifests.
i 8.
Discussion l
Each shipment of radioactive waste by a waste generator to a licensed j
collector, processor, or operator of a land disposal facility must ensure that a shipment manifest accompany the waste.
Section 20.311 states that the mani-fest must include information on waste characteristics including (as a minimum) l 1 8 a
v i
, ~,
-l a physical description of the waste, the volume, the radionuclide identity and quantity, the total radioactivity, the principal chemical form, the solidifica-tion agent (if any), and the pasta class.
As a minimum, the total quantity of the radionuclides 14-3, C-14, Tc-99, and I-129 must be listad.
These radio-i nuclides, as well as the other radionuclides listad in Section 61.55, are used t
to determine the classification status of radioactive wasta.
Controlled dis-posal of wastas containing these radionuclides is considered important in assuring that the performance objectives of Subpart C of the Part 61 regulation i
are met.
The manifest must also identify wasta containing more than 0.1 percent by weight chelating agents, as well as provide an estimate of the weight per-contage of the chelating agent.
Additional information may be required for shipment to a particular disposal facility depending upon facility-specific license conditions.
To classify wasta for disposal and fill out shipment manifests, a licensee must make two basic detartinations:
(1) whether the waste is acceptabl.e for near-surface disposal, and (2) if acceptable for near-surface disposal, whether the wasta is classified as Class A, Class 8, or Class C wasta.
Another deter-mination is whether the wasta complies with any additional waste form, package, or contant requirement which may be in place at the particular disposal facility to which the wasta is to be shipped.
Waste is determined to be generally unacceptable for near-surface disposal if it contains any of the radionuclides listed in Tables 1 and 2 of Section 61.55 in concentrations exceeding the limits established for the radionuclides.
If determined to be acceptable for near-surface disposal, wasta is determined to be Class A, Class 8, or Class C based upon the lists of radionuclide concen-tration limits set forth in Tables 1 and 2.
C.
Reculatory Position All licensees must carry out a compliance program to assure proper -
classification of wasta.' Licensee programs to determine radionuclide concen-trations and wasta classes say, depending upon the particular operations at the In licensee's facility,' range from simple programs to more complex ones.
general, more sophisticated programs would be required for licensees generating Class 8 or Class C waste, for licensees generating waste for which minor process variations may cause a change in classification, or for licensees generating waste for which there is a reasonable possibility of the waste containing concentrations of radionuclides which exceed limiting concentration Ifmits for i
near-surface disposal.
- The regulatory staff is prepared to be flexible in the adaptation of a A principal particular program to a particular wasta generating facility.
consideration for the acceptability of a particular program will be whether a reasonable effort has been made to ensure a realistic representation of the i
~
distribution of radionuclides within waste, given physical limitations, and to Example " physical limitations" can classify wasta in a consistent manner.
i include difficulties in obtaining and measuring representative samples at The staff considers a reasonable costs and acceptable occupational exposures.
reasonable target for determining measured or inferred radionuclide concentra-The tions is that the concentrations are accurate to within a factor of 10.
1 1
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l staff rec:gnizes, however, that this target may be difficult to achieve for i
some wasta types and forms.
A licensae's program should be specific to a particular facility, and should consider the different radiological 'and othe'r characteristics of the different waste streams generatau by the facility.
There are at least four basic methods which may be potentially used either individually or in combina-tion by licensees:
satarials accountability; classification by sourca; gross radioactivity measurements; or direct seasurement of individual radionuclides.
4 The following discussion outlines instances and conditions whereby each basic method or combinations thereof would be acceptable to regulatory staff as a program for demonstrating compliance with the waste classification requirement.
Scae licensees, such as nuclear power facilities, are expected to employ a combination of methods. Appendix A to this technical position outlines an example program for nuclear power facilities which the regulatory staff would find acceptable.
1.
General Criteria 4
a.
Comoliance Throuch Materials Accountability b
One method which the regulatory staff would find acceptable to determine radionuclide concentrations and demonstrata compliance with the waste classifi-cation requirements is through a program of materials accountability. That is, l
a given quantity (and resulting concentration) of radioactive material may be known to be contained within a given waste or may be inferred through deter-mining the difference between the quantity of radioactive material enterbg and exiting a given process. This procedure is expected to be most useful for licensees who receive and possess only a limited number of different radio-isotopes in known concentrations and activities (e.g., holders of source material, special nuclear material, or specific byproduct material licenses).
An example use of this method wou14 be at a biomedical research facility at which known amounts of a radioisotope are injected into research animals, the carcasses of which are ultimately disposed of as radioactive wasta.
Another example would be a research or test facility performing activation analysis experiments.
Ia this case, the quantity of radioactive material within a given wasta stream may be inferred through calculation.
A third example would be a l
power plant in which the radionuclide content of a particular process vessel (e.g., a resin bed) is determined on the basis of sensurements of influent and l
effluent stromes.
I This method may also be used to determine the absence of particular radionuclides. That is, for most licensees, the absence of particular radio-nuclide may be determined through a knowledge of the types of radioisotopes received and possessed, as well as the process producing the wasta.
For example, if a licensee receives, possesses, and uses only tritium, there is no need to measure the waste stream for other isotopes such as iodine-129 or casium-137.
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b.
Classification by Source This method is similar to the above method of materials accountability and involves determining the radionuclide content and classification 'of waste through knowledge and control of the source of the wasta.
This method is expected to be useful for occasions when the radionuclide concentrations within waste generated by a particular process are relatively constant and unaffected by minor variations in the process.
This method is also expected to be frequently useful for determining the acsense of particular radionuclides frcm a given wasta stream.
For example, within a given licansed facility there may be a number of separata controlled areas within which only a limited numoer of radioisotopes are possessed and used (e.g., C4-137 may be used in one area and tritium in another).
As long as facility operations are conducted so that. transfer of radioactive material from one controlled area to another cannot occur, waste generated from a particular area may be readily classified by source.
An example of a licensee for which this method is expected to be useful is a large university which holds a broad license for byproduct material.
c.
Gross Radioactivity Measurements Measurement of gross radioactivity is an acceptable method for all classes of waste provided that:
the gross radioactivity measurements are' correlated on a consistant basis with the distribution of radionuclides within the particular waste stream analyzed, and the radionuclide distributions an initially determined and periodically verified by direct measurement techniques.
Licensees carrying out gross radioactivity measurements to assure compliance with the waste classification mquirement must establish a program to correlate and calibrate measured radioactivity levels with radionuclide concentrations in wastes prepared for shipment.
This program must at a minimum take into account waste package and detector geometry, shielding and attenuation effects, the_sffective gamma energies of the emitted photons, and the number of photons per decay.
The accuracy of the correlation must be initially estab-11shed by and periodically checked through more detailed sample analysis involving measurement of specific radionuclides.
The accuracy of the correla-tion should also be checked whenever there is reason to believe that process changes may have significantly altered previously determined correlations, d.
Measurement of Specific Radionuclides Another method acceptable to the regulatory staff for determining radionuclide concentrations in waste is by direct measurement.
In using this method, licensees may directly measure individual radionuclides or may estan-lish an inferential measurement program whereby concentrations of radioisotopes which cannot be readily measured (through techniques such as gamma-spectral analysis) are projected through ratioing to concentrations of radioisotopes which can be readily measured.
An example would be the practice of scaling 21
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r transuranic concentrations to concentrations of the isotope Ca-144.
Scaling factors should be developed on a facility and wasta stream specific basis, and should be in)qf ally datamined and periodically confirmed through direct measurements.
2.
Determination and Verification of Radionuclide Concentrations and Ccrrelations Radionuclide concentrations should be detarmined based uoan the volume or weight of the final wasta fom.
Samples may be taken for analysis either from the final wasta form or from the wasta prior to processing into a final waste form (e.g., from any intermediata process step).
Samples taken prior to final processing should enable the results of the sample analysis to be directly translated to the final waste form.
The lower limit of detection of a measurement technique for direct measure-ment of a particular radionuclide should be no more than 0.01 times the concentra-tion for that radionuclide listad in Table 1, and 0.01 times the smallest concentration for that radionuclide listed in Table 2.
For this technical position, the lower limit of detection for a particular measurement may be assumed by licensees to be consistant with the definitions for lower limit of detection (LLD) provided in references 1 and 2.
The radionuclides listed in Section 61.55 may be roughly organized into two groups:
(1) those that are amenable to routine quantification by direct measurement techniques (e.g., gamma spectral analysis of isotopes such as Co-60 or Cs-137), and (2) those that require more costly and time consuming analysis frequently removed from the wasta generator's facility (e.g., alpha / beta analysis).
For the first group of radionuclides, measurements to identify and quantify specific radionuclides within final wasta forms should be performed:
routinely for Class B and Class C wastas; and routinely for wastes for which minor process variations could cause an upward change in wasta classification.
In this case, " routine" measurements would involve a limited number (e.g., one or two) of samples out of a batch.
If radionuclide distributions are shown to be nasonably consistant from one batch to the next, however, consideration will be given to decreasing the frequency of routine measurements.
A more detailed analysis for the second group of radionuclides should be performed:
periodically to confirm the correlation of measurements made from gross radioactivity measurements; and whenever there is reason to believe that faci.11ty or process changes may have significantly altered (e.g., by a factor of 10) previously determined correlations of gross radioactivity measurements.
. 88
e.-
The staff believes that for most facilities and for most Class B and C waste types, this confirmatory analysis should be performed on at least an annual basis.
Confirmatory analyses for Class A wastes should be performed on at least a biannual basis.
However, these frequencies may be raised or icwered based upon censideration of particular facility, waste stream, or radionuclide characteristics.
Factors which would influence this consideration include the frequency of process vessel changecut or waste shipment, the difficulty (e.g.,
costs, occupational exposures) in obtaining a representative samole of a particular waste stream, the variability of the radionuclide distribution within tne wasta stream over time, and the availability of analytical capability for particular radionuclides.
It is recognized that it is sometimes difficult to obtain a truly representative sample of some wasta streams and that some judgment will be necessary to determine sampling adequacy and. representative radionuclide distributions.
One example could include Class A dry active vaste such as miscellaneous trash.
In this case, an estimate of the radionuclide distribution within the wasta could be made based upon distributions determined from other 1
wasta streams associated with generation of the trash wasta.
Alternatively, radionuclide distributions could be potentially estimated from smear samples obtained from locations in which the wasta is generated.
Another example could include activated metals.
In many cases, radionuclide concentrations within activated metals will be difficult to directly measure, and NRC staff will in such cases accept estimates based on consideration of activation analysis i
calculations for similar material types.
3.
Concentration Volumes and Masses
~
Paragraph 61.55(a)(8) states that the conce'ntratio'n of a radionuclide may be averaged over the volume of the waste, or the weight of the waste if the concentration units are expressed as nanocuries per gram.
This requirement needs to be interpreted in terms of the variety of different types arid forms of low-level waste.
Principal considerations include:
(1) whether the distri-bution of-radionuclides within the wasta can be considered to be reasonably homogeneous, and (2) whether the volume of the wasta container is significantly larger than the volume of the waste itself, and the differential volume consists 4
largely of void space.
Most wasta streams may be considered to be homogeneous for purposes of waste classification.
Such wasta streams would include, for example, spent ion-exchange resins, filter media, solidified liquids, or contaminated dirt.
Contaminated trash wasta streams, which are composed of a variety of miscal-
'laneous materials, may be considered homogeneous for purposes of wasta classi-fication when placed and compacted within shipping containers.
The activity of small concentrated sources within the trash, such as small check sources or gauges, may be generally averaged over the trash volume.
In many cases the volume ~used for wasta classification purposes may be considered to correspond to the volume of the waste container.
This would be the case, for example, for trash wasta streams which are compacted into shipping containers. The wasta classification volume of large unpackaged components such as contaminated pumps, heat exchangers, or other machinery may be taken to be the overall volume of the component.
23
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Care needs to be taken, however, to differentiate between the volume of the wasta form and the volume of the waste container if the latter is signifi-cantly larger (e.g.,' greater-than 10%).
For example, for wastes such as ion exchange resins or filtar media contained within a disposable dominera11zer or. liner, the volume used for wasta classification should be the volume of the contained wasta rather than the gross volume of the container.
Wasta classi-fication volumes of cartridge filters stabilized by emplacement within high integrity containers should be determined as calculated over the volume of the Simi-cartridge filter itself rather than the gross volume of the container.
larly, the volume and mass considered for purposes of wasta classification of dewatered ion-exchange resins and filter media placed into high integrity centainers should be the volume and mass of the contained wasta.
Classification of absorbed liquids should be based on the volume and mass of the liquids prior to absorption.
An exception to the above wo'uld be a situation in which a particular waste For type is' stabilized within a waste container using a solidification media.
i example, assume that a cartridge filter or large sealed source is solidified with a 55 gallon drum using a binder such as cement or bitumen.
In this case, l
the waste and binder forms a solid mass within the container and the waste l
classification volume may be considered to be the volume of the solidified mass.
Similarly, classification of solidified liquids would be based on the volume and mass of the solidified waste mass.
i 4.
Recortina on Manifests Section 20.311 of 10 CFR Part 20 requires that each shipment of radioactive wasta to a land disposal facility be accompanied by a manifest which describes This manifest may be shipping papers used to. meet the s.hipment contents.
regulations promulgated by the Department of Transportation or the Environmental Protection Agency, provided that the information required by Section 20.311 is included. The waste shipment receiver (e.g., the disposal facility operator) may also require specific additional information.
In addition to shipper identification requirements and a certification, the manifests required by Section 20.311 must include the following information as a minimus:
the wasta class; a radiological description; and a physical and chemical description.
Waste class t
Identifying the wasta class of the shipped wasta is required, since certain disposal requirements are imposed for each wasta class and the waste disposal facility operator must be able to identify the waste in order to carry out these disposal requirements. The individual waste containers must be labeled as being Class A, Class B, or Class C, and the wasta class of each container must also be indicated on the manifest.
The format of the shipment I
labels (or markings) is at the discret. ion of the disposal facility operator.
Unpackaged Class A wasta (e.g., bulk shipments of contaminated dirt) do not need to be labeled provided that the waste class is recorded on the manifest.
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The shipment manifest should also record the date for which the classificatien determination is valid.
This can be, for example, the date of transfer of the waste package frem the site of generation to the disposal sita.
In no case snould the date chosen for decay correction be beyond the date on which the waste is transported to the disposal site.
Radiolecical description The requirements in Section 20.311 include a general requirement to list radionuclide identities and quantities, a general requirement to list the total radioactivity in the waste, and a specific requirement to list four individual radionuclides:
These requirements need some further guidanca, however, since a wide range of radionuclides over a wide i
range of concentrations may be contained in a particular warte package.
The regulatory staff has determined three criteria for determining specific radionuclides which should be listed in manifests:
1.
any radionuclide specifically required to be listed by Section 20.311, or by license conditions at the disposal facility to which the waste i
is shipped; i
2.
any radionuclide which is listed in Section 61.55 and forms a significant part of the total activity which determines the waste class; and 3.
any radionuclide which is contained in significant quantities within a waste container or shipment.
1 Currently, only the isotopes H-3, C-14, Tc-99, and I-129 are required in Section 20.311 to be specifically identified and their quantities listed in manifests.
In the manifests, if a particular one of these four radioisotopes is known to be not present within a waste stream (e.g., through material i
accountability), the quantity of the radionuclide should be recorded as "not l
present."
If the radionuclide is determined through material accountability, direct measurement, or inference through direct measurement or gross radio-activity measurement, this quantity should be reported as determined.
If the I
radionuclide is known or suspected to be contained within the waste but is in j
quantities less than the lower limit of detection for the analyzed sample, the quantity of the radionuclide should be recorded as being less than the minimum detectable, with the minimum detectable amount included alongside in parentheses.
The total quantities of these four nuclides may be reported on a waste shipment l
rather than an individual waste container basis.
In the case of Tc-99, care should be taken to distinguish between this nuclide and its'short-lived precursor, Tc-99m.
Other radionuclides listed-in Section 61.55 should be specifically i
identified and the quantities reported if they are significant for purposes of classification.
A radionuclide shall be determined to be "significant for purposes of classification" if it is contained in waste in concentrations greater than 0.01 times the concentration of that nuclide listed in Table 1 or 0.01 times the smallest concentration of that nuclide listed in Table 2.
This criterion does not include isotopes identified in Table 2 as having half-lives 25
=
i a
less than 5 years.
An isotope (other than Cm-242) having a half-life less than 5 years is considered significant for the purposes of wasta classification if 3 (0.01 it is contained in the wasta in concentrations greater than 7 pCf/cm times the Table 2, Column 1 value).
Radionuclides nct listed in Section 6L55 should also be specifically identified and the quantities reported if they are contained in significant quantities within a waste container or shipment.
In general, a radionuclide shall be deemed to be " contained in significant quantity" if it is in concen-trations greater than 7 pCi/cm3 In addition, the total quantity of source or special nuclear material should be reported, if the waste contains such material.
Otherwise, radionuclides should be listed in shipment manifests in compliance with Department of Transportation requirements in 49 CFR Part 172, Section 172.203.
Physical and chemical description Items to be included in the physical and chemical description include, as a minimum, the following:
a physical description of the waste; the volume; the Wasta principal chemical form; and the solidification agent used (if any).
containing more than 0.1% chelating agents by weight must be identified, and the weight percentage of the chelating agent estimated.
Amplification of NRC's intent regarding these requirements is provided below.
A physical description of the waste is needed in order to facilitate safe handling at the disposal facility and to better predict long-term environmental impacts. The description need only be a few words but should be as specific as possible.
For example, a description such as " solidified resins" or " solidified evaporator bottoms" should be used rather than the description " solidified radwaste." Similarly, the description " scintillation vials" is preferable to the description " laboratory wasta."
i The volume listed in the manifest should be the volume of the wasta container, if any, or the volume of the waste itself if shipped unpackaged (e.g., a bulk quantity of contaminated soil).
The principal chemical form of the waste also needs to be provided as an j
aid to waste handling safety and to improve prediction of long-term environ-mental impacts.
This should be the principal chemical fann in which the radioactivity is contained (e.g., calcium fluoride, toluene, etc.).
There is no need to list trace chemical contaminants, however.
The solidification agent need only be provided in general terms (e.g.,
cement, asphalt, vinyl ester styrene).
The type of solidification egent used i
may be combined with the physical description of the waste (e.g., " resins solidified in cement").
The intent of the requirement to identify waste containing chelating agents in quantities greater than 0.1% is to identify weste containing large quantities of such agents.
Large quantities of such Agents. may be segregated l
from other waste at a disposal facility and/or disposed th?ough some special 26
disposal method.
Disposal facility operators need to have such waste identi-fied in order for them to perform these additional disposal operations.
For purposes of this requirement, chelating agents include the following:
amine polycarooxylic acids (e.g., EDTA, OTPA), hydroxy-carboxylic acids, and polycartexylic acids (e.g., citric acid, carcolie acid, and glucinic acid).
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'l APPENDIX A GENERAL PROGRAM FOR CLASSIFYING WASTES AT NUCLEAR POWER FACILITIES In order to meet the requirements in 10 CFR Part 61 to classify radioactive wastas at nuclear power plants, NRC staff has prepared a general program for implementing the wasta classification system.
This implementation program consists of a three-tiered approach which includes:
periodic analysis for all nuclides listed in Table 1 of Section 61.55; 1.
gamma spectroscopy of certain nuclides from which waste classification 2.
nuclides are correlated; and gross radioactivity measurements which correlata activity levels of 3.
wastes from similar batches to the gamma-spectroscopy measurements.
The periodic sampling for listed nuclides would be performed on various These periodic analyses should be the basis for wasta streams in the plant.
establishing correlation factors between the wasta classification nuclides and nuclides which can be more easily measured using gamma soectroscopy techniques.
Samples should be taken nominally on an annual basis from individual waste
~
stnams such as boric acid evaporator bottoms, primary system cleanup resins, chemical regenerative evaporator bottoms, etc., which are likely to be Class 8 If unit operations or plant conditions are modified such that the or C westes.
radionuclide distribution for any of the individual waste streams changes by a factor of 10, a reanalysis should be performed.
Plant operational changes would include changes in the failed fuel fraction or a crud burst.
If operations remain consistant, consideration can be given to performing manalysis on a less frequent basis.
In addition, consideration should be given to increasing the fnquency of analysis depending upon individual facility, wasta stream, and Factors which would influence this consideration radionuclide characteristics.
include the frequency of process vessel changeout or waste shipment, the diffi-culty in obtaining a representative sample of a particular waste stnam, the variability of the radionuclida distribution within the wasta stream, and the available analytical capacity for particular radionuclides.
The gamma spectroscopy measurements should be perfomed en a limited This can be performed number of samples obtained from individual waste batches.
by analyzing wasta samples prior to or after volume reduction and/or solidiff-cation, analyzing wasta drums or liners by any of the commercial devices designed for this taskt or by analyzing influent and effluent samples from the Other methods which provide reasonable analysis will also be process stream.Efforts should be made to obtain reasonably representative samples considered.
The nsults of the gamma spectroscopy measurements should be for analysis.
applied with the correlation factors to catain concentrations for those nuclides listed in the waste classification table.
28
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Gross radioactivity measurements may also be pe 'onned on individual waste packages from similar waste batches for which gam =a-t iectroscopy results are avail able.
Gross radioactivity measurements should 1 -;1ude corrections for attanuation and container si:e and configur,ation.
The gross activity measi re-ments should be used to scale the nuclide concentratic s obtained from the gamma spectroscopy data and correlations.
For Ciass A wastes sucn as contaminated trash, gross radioactivity measurements may be performed as the basis for wasta classification provided that these measurements can be correlated to the concentrations of the radio-
- nuclides listad in Section 61.55.
Confirmatory reanalysis of the correlation factors should be performed on at least a biannual basis.
The NRC staff believes that the aoove approach presents a workable and This enforceable program for implementing the waste classification system.
approach should minimize the administrative and operational burdens on plant personnel, but still provide reasonably accurate data for use in quantifying disposal site nuclide concentrations and inventories.
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REFERENCES (1)
U.S. Nuclear Regulatory Commission, " Radiological Effluent Technical Specifications for PWR's," NUREG-0472 (as revisad), July 1979.
(2)
U.S. Nuclear Regulatory Ccmmission, " Radiological Effluent Technical Specifications for SWR's," NUREG-0473 (as revised), July 1979.
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May 1983 Rev. 0 Technical Position on Waste Form j
A.
Introduction The regulation, " Licensing Requirements for Land Disposal of Radioactive Waste," 10 CFR Part 61, establishes a waste classificaticn system cased on the radionuclide concentrations in the wastes.
Class B and C waste are required to be stabilized. Class A waste have lower concentrations, and may be segregated without stabilization. Class A wastes may also be stabilized and disposed of with the Class B wastes. All Class A liquid wastes, however, require solidification or absorption to meet the free liquid requirements.
Structural stability is intended to ensure that tne waste does not degrade and promote slumping, collapse, or other failure of the cap or cover over the disposal trench and thereby lead t: water infiltration.
Stability is also a factor in limiting exposure to an inadvertent intruder since it provides greater assurance that the waste form will be recognizable and nondispersable during its hazardous lifetime.
Structural stability of a waste form can be provided by the waste form itself (as with large activated stainless steel components),
by processing the waste to a stable form (e.g., solidification), or by emplacing the waste in a container or structure that provides stability (e.g., high integrity container).
This technical position'on waste form has been developed to provide guidance to both fuelscycle and non-fuel-cycle waste generators on waste form test methods and results acceptable to the NRC staff for implementing the 10 CFR Part 61 waste form requirements; It can be used as an acceptable approach for demonstrating compliance with the 10 CFR 1
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Part 61 waste stability criteria. This position includes guidance on the processing of wastes into an acceptable, stable waste form, the design of acceptable high integrity containers, the packaging of filter cartridges, and minimizing the radiation effects on organic ion-exchange resins.
l' It is the intent of the NRC staff to add other guidance on waste form in additional technical positions as is necessary to address other pertinent weste form issues.
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j S.
Background
Historically, waste fem and container procerties were considered of secondary importance to good site selection; the comcination of a properly operated site having good geologic an:1 hydrologic characteristics were considered the only barriers necessary to isolate lew-level radioactive wastes from tne environment.
Experienca in operating low-level waste af sposal sites indicated th&t the weste form should play a major role in the overall plan for managing these wastes.
l The regulation for near-surface disposal of radiosctive wastes,10 CFR Part 61, includes requirements which must be met by a waste fem to be acceptable for near.,urface disposal. The regulation includes a wasts' classification system which divices waste into three general classes:
A, 8, and C.
Tha classification system is based on the overall disposal hazards of the wastes. Cartain minimum requirements mur.t be met by all wastes. These minimum requirements are prssented in Section 61.36(a) and involve basic packaging criteria, prohibiticas against the dispotal of pyrophoric, explosive, toxic and infectious materials, and requirements to solidify or absord liquids.
In addition to the minimum requirements, Class 8 and C wastes are required to have,stabil.ity.
As defined in Section 61.56(b) of the rule, stability requiroslnat the waste fum maintain its structural integrity under the expected disposal conaitions.
Structural stability is necessary to inhibit slumping, collapse, or other failure of the dispcsal trench resulting from degraded wastes which could lead to water infiltration, radionuclide migration, and costly remedial care programs.
Stability is also considered in the intruder pathways where it is assu.1ed i
that after the active control period wastes are recognizable and, therefore, continued inadvertent intrusion is unitkely. To the extent i
practical Class B and C waste forms should maintain gross physical properties and identity over a 300 year period.
[
In order to ensure that Class 8 and C waste or its container will i
i maintain its stability, the following conditicns need to be met:
(
I a.
The waste should be a solid form or in a container or structure t
that provides stability after disposal.
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t b.
The wasta should not contain free standing and corrosive liquids. That is, the wastes should contain only trace amounts of drainable liquid, and in no case may the volume of free liquid exceed one percent of the wasta volume when wastes are disposed of in containers designed to provide stability, or 0.5 percent of the wasta volume for solidified wastes.
The waste or container should be resistant to degradation c.
caused by radiation effects.
d.
The waste or container should be resistant to biodegradation.
i The waste or container should remain stable under the e.
compressive loads inherent in the disposal environment.
f.
The weste or container should remain stable if exposed to moisture or water after disposal.
The as-generated waste should be compatible with the g.
solidification media or container.
A large portion of the waste produced in the nuclear industry is in 'a fom which is either liquid or in a wet solid fem (e.g., resins, filter sludge, etc.) and requires processing to achieve asi acceptable solid, monolithic forse for burial. The liquid wastes, irregardless of its classification, are required to be either absorbed or solidified.
In order to assure that the solidification process will consistently produce a product which is acceptable for disposal and will meet disposal site license conditions a process control program should be used. General requirements for process control programs are provided in the NRC StandardReyiewPlan11.4,"SolidWasteManagementSystems,"(N
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" Design Guidance for Solid Waste Management Systems Installed in.
l Light-Water-Cooled Nuclear Power Reactor Plants " (revised in July 1961).
i These documents may also be used as the basis for individual se' 'iification process control programs by other fuel-cycle and oy i
nor.. fuel-cycle waste generators who would solidify wastes. The guidance in this technical position should be the basis for qualifying process control programs for Class 5 and C wastes. The use of applicable generic test data (e.g., topical reports) may be used for process control program qualification. Process control programs for solidified Class A wasta products, which are segregated from Class 6 and C wastes, need only ll l
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demonstrate that the product is a free standing monolith with no more cnan 0.5 percent of the waste volume as free liquid.
An alternative to processing some Class 3 and C waste streams, particularly ion exchange resins and filter sludges, is the use of a hign integrity container.
The high integrit/ container would be used to provide the long-term stacility requireo to meet the stability 2
recuirements in 10 CFR Part 61.
The design of the high integrity i
container should be based on its specific intended use in order to ensure that the wasta contents, as well as interim storage and ultimate disposal environments, will not compromise its integrity over the long-term. As with wasta solidification, a process control program for dewatering wet solids should be developed and utilized to ensure that the free liquid requirements in 10 CFR Part 61 are being met.
C.
Recu14 tory Position l
1.
Soitdified Class A Wasta Products a.
Solidified Class A waste products which are segregated from l
Class B and C wastes should be free standing monoliths and have measuredusingthemethoddescribed'inANS~55.1.{reeItquidsas no more than 0.5 percent of the wasta volume as l
b.
Solidified Class A waste products which are not segregated from l
Class B and C wastes should meet the stability guidance for Class B and C wastes provided below.
i
- 2.,. Stability Guidance for Processed (i.e., Solidified) Class B and C Wastes
- d
)
4.
The stability guidance in this technical position for processed westes should be implemented through the qualification of the individual licensee's process control program. Generic test data may be used for qualifying process control programs.
4 Through the use of a well designed and implemented process control program, frequent requalification to demonstrate stability is expected to be unnecessary. However, process control programs should include provisions to periodically demonstrate that the solidification system is functioning T
properly and waste products continue to meet the 10 CFR Part 61 f
stability requirements. Weste specimens should be prepared I
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based'on the proposed wasta streams to be solidified and based on the range of wasta stream chemistries expected. The tests identified may be perfonned on radioactive or non-radioactive samples.
b.
Solidified waste s?acimens should have compressive strengths of at least 50 psi when tested in accordance with ASTM C39.
Comoressive strength tests for bitumino products should be performed in accordance with ASTM 01074 Many solidification agents will be easily capable of meeting the 50 psi li,mit for properly solidified wastes.
For these cases, process control parameters should be developed to achieve the maximum practical comoressive strengths, not simply to achieve the minimum acceptable compressive strength, f,
c.
The specimens for each proposed waste stream fonnulation should remain stable after being exposed in a radiation field equivalent to the maximum level of exposure expected from the proposed wastes to be solidified.
Specimens for each proposeg waste stream fonsulation should be exposed to a minimum of 10 Rads in a gasus irradiator or equivajent.
If the maximum level of exposure is expected to exceed 10 Rads, testing should be perfor'ned at the expected maximum adcumulated dose. The irradiated specimens should have a miaircum compressive strength of 50 psi following irradiation as tested in accordance with ASTM C3g or ASTM 01074.
d.
Specimens for each proposed waste stream formulation shou', be tested fgr resistance p biodegradation in accordance with both ASTM G21 and ASTM G22. No indication of culture growth should be visible. Specimens should be suitable for compression testing in accordance with ASTM C3g or ASTM D1074. Fe' lowing the biodegradation testing, specimens should have compressive strengths greater than 50 psi as tested using ASTM C3g or ASTM D1074.
For polymeric er bitumen products, r.no visible culture growth from contamination, additives or blodegradable comconents on the specimen surface which do not relate to overall substrate integrity may be present.
For these cases, additional testing should be perfonned. If culture growth is observed upon 6
35
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completion of the biodegradation test for polymeric or bitumen products, remove the test specimens from the culture, wash tnum free of all culture and growth with water and only light scrubbing. An organic solvent compatible with the substrate may be used to extract surface contaminants. Air dry the specimen at room temperature and repeat the test. Specimens i
should have observed culture growths rated no greater than 1 in the repeated ASTM G21 test, and compressive strengths greater than 50 psi. The specimens should have no observed growth in the repeated ASTM G22 test, and a c:mpressive strength greater
^
1 than 50 psi. Compression testing should be perfomed in accordance with ASTM C39 or ASTM 01074 If growth is observed following the extraction procedure, longer term testing of at least six months should be perforgd to determine biudegradation rates. The Bartha-Pramer Method is acceptable for this testing. Soils used should be representative of those at burial grounds. 81odegradation,
extrapolated for full-size waste forms to 300 years should produce less than a 10 percent loss of the total carbon in the waste form.
i Leach testing should be performed for a ajnimum of go days tn e.
accordance with the procedure in MS 16.1.- Specimen sues should be consistent with the samples prepared for the A!TM C3g or ASTM 01074 compressive strength tests.
In addition to toe.
domineralized water test specified in M516.1, additional 1
testing using other leachants specified in MS 16.1 should also be perfomed to confim the solidification agents teach resistance in other leachant media.
It is preferred that the l
synthesized sea water leachant also be tested. In addition, it J
is preferable that radioactive tracers be utilized in performing the leach tests. The leachantlity index, as calculated in accordance with MS 16.1, should be greater than 6.
Waste specimens should maintain a minimum compressive strength l
f.
of 50 psi as tested using ASTM C3g or ASTM 01074, following i
ilumersion for a minimum period of go days.
Immersion testing may be performed in conjunction with the teach testing.
Weste specimens should be resistant to thermal degradation.
g.
The heating and cooling chambers used for the thermal 36
_ __ _ _ _ _ _ ~ _ _ - _ _. _ _ _ _ _ _ _ _ _ _ _ _
detradation testing shculd confom to the description given in ASTM 8553, Section 3.
Samples suitaole for performing compressive strength tests in accordance with ASTM C3g or ASTM 01074 shoulo be used.
Samples should be placed in the test chammer and a series of 30 thermal cycles carried out in l
accordance with Section 5.4.1 througn 5.4.4 of ASTM 8553. The hign temperature limit snould be 60C and the low temperature s
i limit -40C.
Following testing the waste specimens should have compressive strengths greater than 50 psi as tested using ASTM C3g or ASTM 01074 h.
Weste specimens should have less than C.5 percent by volume of l
the wasta specimen as free liquids as measured using the method described in ANS 55.1. Free liquids should have a pH between 4 I
and 11.
1.
If ses11, simulated laboratory size specimens are used for the test data from sections or cores of the 4
above testing,ll-scale products should be obtained to correlate anticipated fu the characteristics of actual size products with those of l
simulated laboratory stae specimens. This testing may be perfomed on non-radioactive specimens. The full-scale specimens should be fabricated using actual or comparable l
solidification equipm. ent.
j.
Wasta samples from full-scale specimens should be destructively l
analysed to ensure that the product produced is homogeneous to
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the entent that all regions in the product can expect to have compressive strengtns of at least 50 psi. Full-scale specimens may be fabricated using simulated non radioactive products, but i
should be fabricated using actual solidification equipment.
3.
Radiation Stability of Organic ten-tachange Resins 4
In order to ensure that organic ton exchans resins will not produce adverse radiation degradat' on effects, res ns should got be generated i
i that have loadings which will produce greater than 10 Rads total g
accumulated dose.
For Cs-137 and Sr-go a tota 1 accumulated dose of 10 3
Rads is approximately equivalent to an 10 C1/ft concentration.
This i
position is applicable to resins in the unselidified, as-generated form.
[
In the event that the wasta generator considers it necessary to load resins higher than 10 Rads, it should be demonstrated that the specific 8
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n resin will not undergo radiation degradation at the proposed higher loading. The test method should adequately simulate the enemical and A ganus irradiator or equivalent should raciologic conditions expected.There should be no aaverse swelling, acid be utilized for these tests.
formation or gas generation which will be detrimental en the proposed final waste product.
4.
High Integrity Containers The maximum allowable free liquid in a high integrity container a.
should be less than one percent of the waste volume as measured using the method described in ANS 55.1. A process control program should be developed and qualified to ensure that the free liquid requirements in 10 CFR Part 61 will be met upon delivery of the wet solid material to the disposal facility.
This process control program qualification should consider the effects'of transportattun on the amount of drainable liquid which might se present.
High integrity containers should have as a design goal a b.
minimum 1<fetime of 300 years. The high integetty container should be designed to maintain its structural integrity over this period.
The high integrity container design should consider the corrosive and chemical effects of both the waste contents and c.
Corrosion and chemical tests the disposal trench environment.
shouls be performed to confirm the suitability of the proposed container materials to meet the design lifetime goal.
The high integrity container should be designed to have d.
sufficient mechanical strength to withstand horisontal arid vertical loads on the container equivalent to the depth of propesp burial assuming a cover material density of 12 lbs/ft.
to withstand the routine loads and effects from the waste contents, waste preparation, transportation, hane11ng and disposal site operations, such as trench compaction proceduru This mechanical design strength should be justified by conservative design analyses.
design mechanical strengths should be For polymeric material conservatively extrapolated from creep test data.
e.
34
f.
The oesign should consider the themal loads from processing, storage, transportation and burial. Proposed container materials should be tasted in accordance with ASTM B553 in the of this technical position.
manner described in Section C2(g)l design properties should No significant changes in materia result from this thennel cycling.
The high integrity container destgn should consider the g.
radiat' on stability of the proposed container materials as well as the radiation degradation effects of the wastes.
Radiation degradation testing should be performed on proposed container materials using a ganna irradiator or equivalent.
No significant changes in material desifin properties shguld result fo lowing uposure to a total accumu' ated dose of 10 Rads.
If it is proposed to design the hiflh integrity container to greater accumulated doses, test < ng should be perfomed to confirm the adequacy of the proposed materials. Test specimens should be prepared using the proposed fabrication techniques.
polymeric high integrity container designs should also consider the effects of ultra-violet radiation. Testing should be perfonned on proposed materials to show that no sifinificant changes in material design properties occur follow' ng espected ultra-violet radiation exposure.
The high integrity container design should consider the h.
biodegradation properties of the proposed materials and any biodegradation of wastes and disposal moeia.
Biodegradation testing should be performed on proposed container materials in accordance with ASTM $21 and ASTM G22. No indication of, culture growth should be visible. The entraction procedure described in Section C2(d) of this technical position may be performed where indications of visible culture growth can be attributable to contamination, additives, or biodegradable components on the specimen surface that do not affect the It is also acceptable to overall integrity of the substrate.
determine blodegradation rates us.ing the Bathta Premer Mnthod described in Section C2 (d). The rate of biodegradation should produce less than a 10 percent loss of the tota' carton in the container material after 300 years. Test specimens should be prepared using the proposed material fabrication techniques.
3g
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The high integrity container should be capable of meeting the requirements for a Type A package as specified in 49 CFR 173.398(b).
The free drop test may be perfonned in accordance with 10 CFR 71, Appendix A. Section 6.
j.
The high integrity container and the associated lifting oevices should be designeo to witastand the forces applied during Itfting operations. As a minimum the container snould be designed to withstand a 3g vertical lifting load.
k.
The high integrity container should be designed to avoid the collection or retention of water on its top surfaces in order to minimite accumulation of trench liquids which could result in corrosive or degrading chemical effects.
1.
High integrity container closures should be designed to provide a positive seal for the design lifetime of the container. The closure should also be designed to allow inspections of the contents to be conducted witnout damaging the integrity of the container.
passive vent designs may be utilized if needed to relieve internal pressure.
passive vent systems should be designed to minimize the entry of moisture and the passage of waste materials from the container.
prototype testing should be perforged on high integrity m.
container designs to demonstrate the container's ability to withstand the proposed conditions of waste preparation, handling, transportation and disposal.
High integrity containers should be fabricated, tasted, n.
inspected, prepared for use, filled, stored, handled, transported and disposed of in accordance with a quality The quality assurance preilram should also assurance program.
address how westes which are detrimental to h'gh integrity container materials will be precluded from being placed into the container. Special emphasis should be placed on fabrication process control for these high integrity containers which utilize fabrication techniques such as polymer molding processes.
5.
Filter Cartridge Wastes 4
40
For Class 3 and C westes in the form of filter cartridges, the waste generator should demonstrate tnat tae. selected approach for providing stability will meet the requirements in 10 CFR Part 61.
Encapsulation of the filter cartridge in a solidification binder or the use of 4 high intag.*ity container are acceptable options for providing stability. When high integrity containers are used, waste generators shoulo demonstrate that protective means are previoed to preclude container camage during packaging handling and transportation.
D.
Imolementation This :achnical position reflects the current fiRC staff position on acceptable means for meeting the 10 CFR Part.61 waste stability requirements.
Therefore, except in those cases in which the waste generator proposes an acceptable alternative method for complying with the stab;11ty requirements of 10 CFR Part 61, the guidance described herein will be used in the evaluation of the acceptability of waste fo es r
for disposal at near surface disposal facilities.
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References:
1.
NUREG-OSCO, Standard Review Plan ANS 55.1, "American National standard for Solid Radioactive Wasta 2.Processing System for Light Water Cooled Reactor Plants.* American Nuclear $cciety,1979 ASTM C39, "Comoressive Strength of Cylindrical Concrete Specimens,"
3.American Society for Testing and Materials,1979 ASTM 01074, " Compression Strength of 8ttuminous Mixtures," American 4.Society for Testing and Materials,1980 ASTM G21, " Determining Resistance of Synthetic Polymeric Materials to 5.Fungi," American Society for Testing and Materials,1970 ASTM G22. " Determining Resistance of Plastics to sectaria," American 6.Society for Testing and Materials,1976 R. 8 artha, D. Pramer, " Features of a Flask and Method for Measuring 7.the Persistance and 81ological Effects of Pesticides in soils,"
SoilScience100(1),pp-44-70,1945 ANS 16.1, " Measurement of the Leachability of Solidified Low-Level 8.Radioactive Wastes," American Nuclear Society Draf t Standard, April 1981 ASTM 8553, " Thermal Cycling of Electroplated Plastics," American 9.Society for Testing and Materials,1979 0
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