ML20134P456
| ML20134P456 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1985 |
| From: | Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mcgrath J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20134P447 | List: |
| References | |
| FOIA-85-566 NUDOCS 8509060319 | |
| Download: ML20134P456 (2) | |
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JUL 31 B85 l
MEMORANDUM FOR:
John McGrath, Regional State Agreements Office, Region I FROM:
R. John Starmer, Section Leader Low-Level Waste and Uranium Recovery Projects Branch i
Division of Waste Management
SUBJECT:
COMMENTS ON TESTING PROCEDURES FOR AM-241 WASTES This memorandun is in response to your 11 July 1985 memorandum requesting a review and coments on ENSA's proposed testing procedures for determining the leaching and adsorption potential of AM-241. We have the following coments on ENSA's proposal.
GENERAL:
1.
Proposed use of EP Toxicity Test to detennine leaching potential of AM-241:
Although this procedure appears to provide an acceptable method for detemining the leaching potential of AM-241, we suggest considering a rodification of the original test for the purpose of maintaining site specific conditions, particularly site water composition (see specific coment #1).
2.
Proposed use of Americal Society for Testing and Materials Document 34.02-022R0 (draft 2) Method for 24-Hour Batch-Type Distribution Ratio (Rd) for Contaminant Adsorption by Soils and Sediments, to detennine adsorption potential of AM-241:
Instead, we suggest utilizing ASTM D 4319 Standard Test Method for Distribution Ratios by the Short-Term Batch Method.
It provides more detailed testing procedures than does Document 34.02-022RO (draft 2). A copy of ASTM D4319 may be'obtained from the ASTM (ASTM, 1916 Race Street, Philadelphia, PA 19103).
SPECIFIC:
1.
Nature of the solution used to obtain the leachate sample (EP Toxicity Test):
We suggest modifying the chosen procedure to utilize site specific watert, as the initial sclution to obtain leachate if possible (note:
EP toxicity determination requires a pH 5, per 40 CFR 261 Appendix II).
Use of site specific waters will permit generation of " realistic" data.
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8509060319 850829 PDR FOIA WELDON85-566 PDR
JUL 3 1 955
, 2.
Collection of the soil sample at a depth between 9-10 feet adjacent to borehole SM-12 adjacent to the landfill:
It is unclear why a soil sample that will be obtained at an arbitrary depth in a borehole adjacent to the landfill will be utilized as the sample to detemine the adsorption potential of AM-241 "in native soils beneath the landfill".
Since soil /
fill material composition may vary within a landfill site, we suggest j
obtaining the soil sample from the native soil beneath the landfill.
1 3.
Use of manual agitation in the modified test procedure to detemine i
adsorption potential:
If cost saving measures which alter testing procedure / equipment are invoked, it should be demonstrated that the credibility of the test will not be jeopardized.
For example, a favorable comparison of the modified test results with third party test results (obtained through standard testing procedures) could be considered as demonstrating credible results.
In sumary, the modified testing procedures that are described by Mr. Haas in his letter of 22 May 1985, are deficient as presently submitted.
This deficiency can be rectified by:
- 1) collecting representative samples; 2) adhering to up-to-date test procedures; and, 3) providing elaboration on the intended use of the test results.
b R. John Starmer, Section Leader Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management