ML20148J417
| ML20148J417 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1988 |
| From: | Ballard R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-88 NUDOCS 8803300268 | |
| Download: ML20148J417 (6) | |
Text
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WM-88 MEMO FINAL TR-MEMORANDUM FOR:
John J. Surmtier, Chief Technical Branch:
Division of Low-Level Waste Management and Decomissioning -
FROM:-
Ronald L. Ballard, Chief Technical Review Branch Division of_High-Level Waste Management
SUBJECT:
FINAL YERSION OF THE GENERAL ELECTRIC TOPICAL REPORT "TRANSPORTABLE AZTECH PLANT LICENSING TOPICAL REPORT" The subject Topical Report (TR) was approved by the NRC in December 1985, subject among other conditions to preparation of a final TR by the General Electric Company. A version dated August 1986 and designated as NEDE-30878-1 was received and reviewed in 1986 by the Project Manager. While many of the changes requested were made, others were either not made or were not made satisfactorily. New text was also inserted which had not been reviewed previously that also required revision. The. fyrther changes were discussed with GE and marked-up pages are in our files pending receipt of the final version of the TR. Attachment I documents the status of work required on this TR.
This evaluation, as documented in Attachment 1, represents a logical point for turnover of responsibility for this TR to your Branch. Accordingly, with this memo, we are completing the direct work by our Branch on this TR. We will continue to be available on a consulting basis if needed.
If you have any questions, please' call me on x74739 or Chuck Peterson on x74546..
Ronald L. Ballard, Chief Technical Review Branch Division of High-Level Waste Management
Enclosure:
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-WM-88 MEM0' FINAL TR 2
0FFICIAL CONCURRENCE AND DISTRIBUTION RECORD MEMORANDUM FOR:
John.J. Surmeier, Chief Technical Branch Division of Low-Level Waste Management FROM:
Ronald L. Ballard, Chief Technical Review Branch Division of High-Level Waste Management
SUBJECT:
FINAL VERSION OF THE GENERAL ELECTRIC TOPICAL REPORT "TRANSPORTABLE AITECH PLANT LICENSING TOPICAL REPORT" DATE:
87/12/
FEB 4 tre DISTRIBUTION (wattachments) 1
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WM-88 MEMO FINAL TR ATTACHMENT 1 STATUS OF WORK ON THE GENERAL ELECTRIC COMPANY TOPICAL REPORT, "TRANSPORTABLE AZTECH PLANT LICENSING TOPICAL REPORT" 1.
Leach Test Data the stability tests recommended in the NRC Technical Position on Waste Among(TFWF) are 90-day leach tests. The GE Topical Report (TR) included two Form sets of leach data: results obtained in their own laboratories and results obtained under a contract with the Brookhaven National Laboratory (BNL).
However, all that was reportd was the final average values for Leach Index (LI) along with the half-range, which was denoted as the standard deviation.
We have repeatedly requested from GE copies of the actual leach test data in the ANS 10.1 format. The latest version of the TR shows the calculated values of the Leach Indices (LIs) for each of the ten time intervals in each set of test data.
On first reading, this response appeared satisfactory.
However, in another TR (Hittnan Cement Solidification System), Hittman noted that in some cases the leach test data covered less than 10 time intervals because essentially all of the tracer element had been leached out. Hittman was correct in concluding that when leaching began at some finite rate and then trended toward zero, the final near zero values would lead to meaningless LIs.
They were not correct in using less than 10 intervals. The correct action, as we have recommended, would have been to use larger specimens, or possibly higher initial loadings, or both.
We were concerned that the same situation might have occurred in the GE data, especially since GE's own leach data noted that many of the tests did not include 10 tine intervals. Coded footnotes disclosed that these tests had been terminated short of 90 days, and hence must be regarded as unacceptable. The remainder of the GE leach data were acceptable as were all the BNL leach data included in the GE TR since these were specifically described as resulting from 90-day tests.
In the meantime, GE Nas sold the AZTECH Process to Pacific Nuclear. With the permission of the las er, we obtained from Brookhaven National Laboratory a copy of their original leach data. Spot checking these data, we conclude that they are in fact the data surrearized in the GE TR and that BNL did carry out the leach tests as prescribed. Thus the concern identifed in the Hittman case does not exist in the GE case.
There is, however, a minor concern. Many of the results for the amount leached are expressed as less than x ppm. The resulting LIs are therefore really lower bounds.
In no case was the amount of tracer element leached more than about 60% of the original loading. One might contend that the Icach L
- s.
WM-88 MEMO FINAL TR tests should be designed to produce specific values for the element concentrations in the leachate, as by using larger loadings in the test specimens or more sensitive analytical equipment. This appears to be an unnecessarily stringent requirement.
It is unrealistic in the case of a waste form from which no leaching occurs. We recommend acceptance of the BNL results as being in accord with ANS 16.1, although the tables in the TR and the text should make clear where the average LIs represent lower bounds rather than specific values.
2.
Decontamination Solution The Safety Evaluation Report sent by the Office of Nuclear Reactor Regulation (NRR) to GE did include restrictions on what wastes were approved for solidification by the AZTECH Process. However, a question has been raised with respect to decon solution. The language in the SER appears to say that the Process applies to all decon solutions, and only in the last page or so do explicit statements appear that limit use of the process to only those wastes for which data were presented in the TR. Thus, only the decon solution actually tested is approved.
The Project Manager has reconfirmed with GE that only one decon solution was tested and that was specifically CANDECON. We have granted GE a 10% tolerance on composition: 1.e., a 40% solids content in the case of CANDECON means up to 44% is acceptable. GE has already agreed to revise the statement on page 9-44 in the TR so that "chemically similar" is explained as "chemical composition within 10% of CANDECON. We repeat that chemically similar decontamination agents are not approved, although this may appear plausible. The reason is that we have no basis for supporting this "plausible" conclusion.
GE, or its successor, should obtain the necessary data.
However, GE did not delete the second statement in id, p 9-44, to the effect that (other) decontamination solutions are also qualified. This should be checked when the final TR is received for review. NRR should also be requested to issue an amendment to the SER making the foregoing restriction on decon solutions clear, j
3.
Mixed wastes l
One of the minimum requirements of 10 CFR Section 61.56(a) is that the waste form does not contain hazardous wastes. The TR was approved under existing regulations and recommendations (of the TPWF). At that time, the question of f
jurisdiction over wastes containing both radioactive materials and chemically hazardous materials had not been resolved between the NRC and the EPA. Pending l
such resolution, a rationale, as summarized below, was presented in the SER for L
c-WM-88 MEMO FINAL. TR finding that the waste forms from the AZTECH Process do not contain hazardous substances, A substance may be designated as hazardous by EPA if (1) it has a.
certain characteristics or (2) it is listed in Subpart 0 of 40 CFR Part 261.
(1) The wastes themselves are normal nuclear power plant wastes and are not hazardous under (a) or (b), above.
(2) The feed materials to the AZTECH Process, however, either are or could be listed by EPA as hazardous, b.
Sections 40 CFR 261.30 - 261.33 provide that the presence of any amount of a listed substance in a waste renders the waste hazardous, Section 40 CFR 261.11 specifies certain considerations under which the c.
finding in b., above, would not be made: the quantities of waste involved, low concentration of listed constituents, migration potential, plausible types of management, and previous damage to human health and the environment due to improper management of the listed constituents.
(1) By actual test, the wastes themselves are held in a solid that is very resistant to leaching under expected conditions.
(2) The feed materials to the AZTECH Process are polymerized to a high degree during the solidification reaction, so the total amount of unreacted feed materials is expected to be very small.
d.
Section 10 CFR 61.56(a)(8) provides that waste containing hazardous material must be treated to reduce to the maximum extent practicable the potential hazard from non-radiological materials. We concluded that polymerization constitutes such a step.
The foregoing rationale was the basis for the finding that AZTECH waste forms do not contain hazardous materials.
GE has since provided some leach data for total carbon, inorganic carbon and organic carbon to be included as a new Table 9.5-21.
Organic carbon is determined as the difference between total and inorganic carbon. While the largest value shown is only 31 ppm, no interpretation is possible.
The brief text included states that the values are for the 90-day leachates.
If so, the values are only for the amounts leached in the last 43 days. What are the values for the first 9 leachates? Second, the sample numbers do not correspond E
WM-88 MEMO FINAL TR to any of those in the TR. Third, we have no criteria for deciding whether an acceptable concentration is 1 ppm, 100 ppm, or some larger figure.
We recommend that the question of leaching of organics from the AZTECH waste forms be treated as a new subject for regulation by more specific requirements than have been formulated to date.
It would appear that coordination with EPA will be required.
4.
Review of the Final TR In view of the fact that agreed upon revisions to the TR are available as marked up pages, review of the final TR when received would probably be expedited if done by the personnel familiar with these agreements. Schedules should be reviewed when the final version is received to determine how best to perform this final review.
5.
Transmittal of Test Data Copies of the BNL leach test data recently received should be sent to the States of Washington and South Carolina for their files. A copy should also be sent to Pacific Nuclear, the present owner of the process.
The document containing the leach data is available for copying from the CCC, It was received under a cover letter from P. Colombo dated 11/19/87 and is entitled "Stability Testing of GE AZTECH Waste Froms (in Accordance with NRC 10 CFR 61 Waste Stability Criteria), Program Final Report, July 1985".
It is marked proprietary and should be handled accordingly.
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