ML20151F335
| ML20151F335 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1988 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bixby W ENERGY, DEPT. OF |
| References | |
| REF-WM-10 NUDOCS 8807270036 | |
| Download: ML20151F335 (14) | |
Text
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LETTER PERSON 5/12/88 MAY 1319g9 Willis W. Bixby, Director West Valley Project Office P.O. Box 191 West Valley, NY 14171
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Dear Mr. Bixby:
The NRC staff has completed prep (aration of comments and questions concerning the draft process control plan PCP) that was sent to the NRC -for coment. contains the consnents and questions that were addressed in the meeting at West Valley on May 3 and 4, 1988.
In addition to those coments',
the staff has, upon further reflection, and taking into consideration some of the information exchanged at the meeting, extended their comments to; include two others, which are enclosed as Enclosure 2.
We appreciate the opportunity to coment on the PCP and look forward to your response.
If we may be of assistance in interpreting these comments please contact me.
Sincerely, p/
Richard L. Bangart, Acting Director Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards Enclosure As stated I)ISTRIBUTION: WM-88-078 Mentral?Eiley NMSS r/f LLTB r/f LPerson, LLTB MTokar, LLTB PLohaus, LLOB JSurmeier, LLTB MBell, LLRB JGreeves, LLWM RBangart, LLWM CCantor, LLWM
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NRC Staff and Consultants Review Comments on Oraft Process Control ~ Plan for Decentaminated Supernatant Cement Solidification - WV0P, April 1988 A.
CHARACTERIZATION OF THE SUPERNATANT 1.
General Comment.
The PCP indicates that the main reason that the original formulation for the solidified waste form was changed is due to the difference in performance of the solidified simuisted supernatant and the l
actual supernatant.
For example, it is believed that a combination of oxalate, citrate, and tartrate is responsible for retarding the hydration of the Portland cement.
Therefore, to determine wnat is the proper amount and allowable variations in the amount of calcium ritrate added -to the mix, the amount of organic material in the supernatant should be determined with batch and time as part of the process control.
If possible, the organic material should be identified regarding their molecular chemistry, (i.e., amounts of oxalate, citrate, and tartrate
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tributyi phosphate, dibutyl phosphate) if the type of organic affects the process and product characteristics. Does the PCP address the fact that the determination of organic constituents in the actual supernatant may significantly affect the amounts of transuranics delivered to product containers?
2.
Page 1. Section 1.0.
A brief chemical and physical description of the waste that is being solidified should be given.
3.
Page 1, Section 1.0.
Compared to low-level waste streams from commercial nuclear reactors, the decontaminated supernatant is well characterized.
Its presumed chemical composition and radiological characteristics are based on actual samling of the liquid in Tank 80-2 as reported.by L. E. Rykken in 00E/NE/44139-14, "High-level Waste Characterization at West Valley," June 2, 1986. However, it is not clear from Rykken's report whether WVNS has conducted a similar characterization of the decontaminated supernatant or has estimated the characteristics from the characteristics of the 80-2 liquid and the presumed Cs-137 decontamination factors of the Zeolite ion-exchange medium. Also, Rykken attributes the homogeneity of suspended solids in the 80-2 liquid to convection currents in the tank due to radioactive self-heating.
Rykken also devises a crude model for the heat balance in Tank'80-2, attributing the heat principally to the Cs-137/Ba-137m decay chain in the supernatant (33.7 kw) and the Sr-90/Y-90 decay chain in the sludge solids (5$.3 kw). As liquid is removed from the tank for decontamination, the temperature of the remaining liquid may change as the heat generating radionuclides in the supernatant are depleted and the heat dissipation properties of the liquid layer change with decreasing quantity of liquid.
It is not clear whether the net effect will be a decrease in temperature because of the decreasa in amount of Cs-137 as the liquid is removed or an increase Decause of poorer heat dissipation properties.
It will probably be a decrease since most of the tank heat (82.8 kw) is currently dissipated to the atmosphere
w JKANE/88/04/28
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via the air condensers. However, a change in temperature of.the. liquid will-result in changes in the1 chemical and radionuclide composition as the solubilities of various components in the liquid and tae sludge change with temperature.
If such changes in the composition of the 80-2 liquid (and the resulting decontaminated supernate) should occur as the tank liquid is removed for decontamination, corresponding changes in the recipe for solidification of the decontaminated supernatant-in Portland cement may be necessary to insure the production of an acceptable-solidified waste form product. WVNS should discuss how these changes are treated in the pCP procedures.
4.
Page 2, Section 3.0.
The PCP describes the. solidification proca.2 as beginning with the sampling of decor,taminated supernatant af ter it has been transferred from the Liquid Waste Treatment System (LWTS).
The supernatant is supposed to be a nominal 39 weight percent (w/o). solids and is stored in 15,000 gallon batches in one of two tanks,50-15A or 50-158.
The supernatant sample is analyzed for radiological and chemical.
characteristics, and a small portion is solidified using the solidification recipe d=veloped for the supernatant. As long as the recipe works, full-scale solidification will proceed. What is the expected variation in solids content? What-variation can be tolerated before the solidified waste product quality is affected? For example,
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what are the effects from a change from.8 w/o to 40 w/o?
3 5.
Page 7, Section 3.2,'2nd Paragraph.
Can results of radiochemical analysis be correlated with the waste solution composition?
If not.-how is the analysis of the chemical constituents verified?'
6.
Page 18, Section 4.0.
Sample verification;is based on laboratory-scale solidification of samples taken from the tanks which feed the waste dispensing vessel. While 1t is likely that the recirculation described in Section 3.1.1 will maintain the homogeneity of the waste feed while it is stored within.the waste dispensing vessel, samples for lab-scale.
verification taken from the output of the waste dispensing vessel would be more representative of the feed to the mixers in the event any type of settling or separation of undissolved or precipitated solids were to occur despite the presence of recirculation. We suggest WVNS consider sampling from the output of tne waste dispensing vessel.
7.
Page 19, Section 4.2.2.
Will the various measurements for (4.2.2.1) gross alpha and beta, (4.2.2.2) gamma scan and (4.2.2.6), radiochemical analyses for nuclides listed in 10 CFR 61 be checked for mutual self-consistency?
Comments on Attachment A - Decontaminated Supernatant Waste-Form Development Report
6
.JKANE/88/04/28 i
.i 8.
Page 6, Table.
This table gives data for the simulated supernatant.
To i
determine the appropriateness of the simulated supernatant, the analysis l
of the actual supernatant should be provided.
9.
Page 9.
The discussion on the study of the crystallization temperature measurements raises questions as to where collection tanks50-15A and B.
are located and what are their temperatures.
If crystallization can occur in the supernatant, then the waste will not be homogeneous unless the waste stream is continuously recirculated. Please discuss.
B.
FORMULATION FOR SOLIDIFICATION
- 10. General Comments. As previously stated in our April 13, 1988 letter.
1 (M. Knapp to W. Bixby) the NRC staff and its consultants have indicated that additional qualification testing is needed for the 39 w/o supernatant waste that is to be solidified in Portland cement. We understand based on i
recent telephone communications that the WV0P has already initiated the start of additional testing which 00E had committed to perform to support the new formulation. We anticipate discussing the details of the additional qualification testing at our May 3-4, 1988 meeting that will include the testing proposed in the letter from S. Marchetti to W. Bixby, subject "Confirmatory Testing on WV0p-Cement Waste Form." The letter on confirmatory testing is confusing in that leach testing is to be performed but the testing that is proposed appears in a section of the letter than indicates testing is not planned.
Please clarify.
While a check of the waste feed properties prior to mixing with cement is i
necessary to determine whether the waste feed is within the composition and property parameters necessary to produce a stable final product and j
whether any minor adjustments to the quantities of cement and additives may be necessary, some sampling of the product at the output of the mixing i
vessels might be justified in light of the problems in scaling up to j
high-shear mixing.
This sampling of the high-shear mfxer output is
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separate.from the full-scale drum testing which is the subject of the comment on Section 3.1.7.
Please disucss.
Admittedly, considerations of occupational exposure, cost, and time required for any necessary modifications may militate against sampling from the output of the mixing vess91s.
The next best course of action, may be a thorough study of the correlations between the properties of laboratory-scale verification samples and full-scale process samples using actual decontaminated supernatant, if practicable, or a simulated decontaminated supernatant as close as practicable in chemical composition to the actual decontaminated supernatant.
11.
Page 4, Section 3.1.3.
The CSS - Flow Diagram (Orawing 9000-2198, Rev. O, Sheet 1 of 2) shows additive pumps (70-G-110, 70-G-111) at location 3.1 and sodium silicate pumps (70-G-113, 70-G-114) at location 3.3.
Presumably, the antifoam is added at 3.1, this should be made explicit if
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correct. Otherwise identify the correct location. Also, WVNS seems to be
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assuming that there will be no need to vary the ccncentration of the 1
antifoaming agent.
Considering the known effects in the solidification process resulting from' minor constituents in the waste (i.e., the set R
retarding effect of the organics and chromate) and from scale-up to full-scale testing (i.e., the air entrainment, foaming, and rapid
~ hydration noted in the high-shear mixer product), the PCP should indicate how toe necessary variations in antifoaming agent concentrations, etc.,
are to be established.
The PCP does not state whether to reduce or increase sodium silicate, nor for what circumstances, e.g., excess bleed water.
Will sodium silicate be changed by. increasing or decreasing the volume of solution used, or by changing the sodium silicate concentration of the
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solution present in the mixer?
12.
Page 4, Section 3.1.3.
How sensitive is the cement waste product to small variations (e.g., min. 4 - max 7 w/o) in calcium nitrate concentration in the cement? What~is the acceptable variation in the "nominal"_5 w/o of j
calcium nitrate?
Is there any check by WVNS on the w/o of calcium nitrate in the cemen+? As with the concentration of antifoaming agent considered i
in the preceding comment, WVNS seems to be assuming that there will be no need to vary the w/o of calcium nitrate in the cement.
Can this assumption be justified?
If changes.in the w/o of calcium ritrate prove to be necessary, how quickly can the composition of the dry cement / calcium nitrate blend be changed? Does the cement / calcium nitrate mixture stay homogeneous during transfer operations?
1 I
13.
Page 5, Section 3.1.3.
What amount of antifoam is added and how is the amount determined?
14.
Pages 10 to 10F. Tables 1 through Table 1F.
The proper units should be j
i specified for each item.
There should be a discussion on how Tables 1A through IF were developed. How is the specific gravity of the solution I
used in checking the proper formulation? How have the MIN and MAX valLes
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for WASTE, CEMENT, RATIO and FILL been arrived at and what is the explanation for the row labelled TIMER? The specific manner that the I
tables will be used to verify the proper formulation should be provided in the PCP.
15.
Page 11, Section 3.5.
Is mixer speed monitored directly? How long does sodium silicate addition take? Is this included in cement mixing' time, that is, is sodium silicate added during cement mix time?
Is the sodium silicate completely dissolved?
- 16. Page 11, Section 3.6.
It is important to specify the process of making the solidified supernatant for the proper procedures to be followed.
For example, the last paragraph on this page should specify the cement mix.
time with limits.
s JKANE/88/04/28 Comments on Attachment A - Decontaminated Supernatant Waste Form Development Report
- 17. Page 14, Line 10.
This discussion indicates that a 30-second mix time is optimum, but the timer setting in Table 1 cf the PCP is around 15 seconds.
Please clarify.
C.
DOCUMENTATION OF TEST DATA
- 18. General Comment.
In many sections of the report statements are mede J
regarding the homogeneity of supernatant and. test results but confirmation i
data.are not present nor are references given to reports containing the data.
The docu=entation of such test data is vital in determining the adequacy of testing and of the process control plan.
i 19.
Page 21, Section 4.4.3.2.
What evidence is available for the statement i
"solidified test specimen is considered representative of tank contents?"
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- 20. Pace 21, Section 4.4.3.4 How was it determined that a 2-inch cube specimen was representative of homogeneous waste sample?
- 21. Page 25, Section 6.1, Lines 6 to 8.
Where is the data to support the l
statement on homogeneity?
- 22. P2ge 26, Section 6.2 The results of the proposed additional qualification testing need to be assessed to support the conclusion that is stated in the first paragraph of this section, i
23.
Page 27, Section 7.0, 3rd Paragraph, Line 11. What are the' limits of the "slight variation" that are discussed?
Comments on Attachment A - Decontaminated Supernatant Waste Form Development Report
- 24. Page 1, Section 1.0, Last Paragraph. Where is the data on the entrained air, density and compressive strength?
- 25. Page 5, Section 1.0, Line 22. What leach testing has been carried out on the new formulation?
- 26. Page 6, last paragraph.
The Westinghouse R&D reports recommended w/c =
0.70 for 39 w/o supsenatant and w/c = 0.66 for 53 w/o supernatant.
These were used to make samples for TP qualification tests..There was no mention of an acceptable range for w/c from 0.54 to 0.70 with a recommended 0.61, as suggested in \\ttachment A.
Please clarify.
i; JKANE/88/04/28 27.
Page 9', last Paragraph, Line'4.
How was the "simulated accurately the densities" determined?
28.
Page 10, 2nd Paragraph, Line 6. How was the density measured and where is the data on the density, air entrainment, and compressive strength?
29.
Page 19, 2nd Paragraph, Line 12. Will water that is not absorbed withir two hours (the time between filling a drum and transporting it to the storage facility) still be reabsorbed completely after the drum has been placed on its side?
30.
Page 21, Line 3.
Provide the data that is available on porosity, density and compressive strength to support the indicated conclusion.
31.
Table II.
The listed compressive strengths are considerably lower than the strengths reported for the 39 w/o supernatant solidified with the "original" recipe at Westinghouse R&D.
Please explain.
O.
CORRELATION OF LABORATORY AND FIELD TESTING
- 32. General Comments, Sections 4 and 5.
One small sample (150 mL) is obtained from the 15,000 gal collection tanks.
From this sample, radiological characteristics are determined and the solidification recipe is verified by preparing one 2-inch cube.
The small sample may be representative of the contents of a 15,000 gal tank if the tank has the capability for recirculation. All that is mentioned in the PCP is sparging in this tank.
If this is the case, then some confirmation of the homogeneity of the waste af ter it is in the tank should be 'provided.
One 2-inch cube.is not likely to be representative of the solidification of 375 drums of waste (750 batches in the cement mixer).
It is reasonable that more samples should be made and tested so that some indication of the variability in properties, particularly ccmpressive strength, is available.
There is no description of what to do if the solidification recipe fails to provide an acceptable cube.
If changes are required in the recipe, who will decide whether the changes are large enough to require additional qualification testing?
- 33. Page 20, Section 4.3.3.
ASTM C-39 is entitled "Standard Test Method for Compressive Strength of Cylindrical Concrete Soecimens." WVNS needs to demonstrate equivalency of verification testing of the 2-inch cube samples with testing of moi ed cylinders or drilled cores representative of the final stabilized product by correlating compressive strength with sample size and geometry as well as with mixing parameters.
Furthermore, WVNS should justify the selection of a 14-day cure period.
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JKANE/88/04/28'
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-Results' summarized 'ini a draf t' report from Westinghouse R&D, "Cement.
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Encapsulation and Waste Form Qualification Testing of LWTS Organic Resin,"'
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by D. C. Grant and E.~ E. Smeltzer, indicate:that the size of the. sample as well as.the speed of_the mixer which combines the waste-form ingredients can have an effect the compressive. strength of the final product.
~Although-this report addresses. ion-exchange resin waste rather than~
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decontaminated supernatant,.such effects cannot.a priori be._ ruled out for' the latter waste, stream. ' Interestingly enough, the' cited report states the following i
The implicacion of this (higher compressive strength in cube' samples]
is that waste forms which.have shown marginally unacceptable
. compressive strengths could meet the stability guidelines by testing
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smaller samples.
It would be worthwhile... to develop correlations
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between sample size and compressive' strength.
The compressive strength could then be related to actual waste' form (e.g., 210L~ (55 gal) drum)."
Does Westinghouse R&D agree that the correlations among lab-scale samples of various sizes and geometries as well as between. lab-scale and i
full-scale samples are desirable?'
34 Page 22, Sections'5.3. What is the ratio method? What data are used in the method? How is the carbonate / bicarbonate measured?
35 Page 24' Sections 5.6 through 5.14 The above comment numbers 32 and 33 on_need for correlation of. compressive strength test results for a 2-inch cube with larger size samples and the basis.for selection of cure ported is applicable to these sections as well. A related concern'is the correlation of "penetrameter" results with compressive test results-i obtained by means of ASTM C-39.
In addition,. the selection _of a total curing' time of seven days need: to be explained, the curirig temperature or i
curing-temperature-vs-time relationship needs to be specified, and.the:use of a higher-then-near-ambient cure -- if applicable -- needs to be justified.
Comments on Attachment A - Decontaminated Supernatant Waste Form Development Report R
l' 36.
Page 1, Section 1.
The statements in this-section reinforce the need for full-scale tests with the waste form recipes simul _ating the' actual waste
-form ingredients to the extent practicable in. order to ascertain the effect of scale-up on the processes as well ason the properties of the final solidified waste form.
In some cases there will be unknown or unexpected constituents, e.g., the' organic set _ retardants wFich were discovered in the actual tank 80-2 supernatant, but.as the cited observations of WVNS regarding air entrainment, foaming, and accelerated V
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'JKANE/88/04/28 hydration indicate, potential problems with the scale-up to full' scale proccssing and waste forms may become evident even with a simulated waste.
Will test data be taken from samples from solidified full-scale specimens to correlate the characteristics of actual size products with those of the -
laboratory-scale ' specimens and to ascertain homogeneity of the full-scale product?
37.
Page 2, Section 1.
It is not clear whether the PCP is using the terms "foaming" and "air-entrainment" synonymously.
Please clarify. Have the problems with air entrainment, foaming, and enhanced hydration been observed previously with mixing of Portland cement in high shear mixers?
The enhanced hydration of the cement, in particular, would not be expected to be limited only to high-salt mixtures.
E.
COMPOSITION AND CHARACTERIZATION OF SOLIDIFIED PRODUCT
- 38. Page 3, Section 3.1.2.
How certain is it that the cement / waste mixture will not harden insice the mixing vessel during the course of an operating day? What procedures would be followed if the mixture were to harden?
Even if the cement does not completely harden inside the mixing vessel, is it possible that a residual' cement / waste mixture of higher viscosity could remain from earlier batches and potentially contaminate later batches with "slugs" of lower water-to-cement-ratio material? What has been the operating experience with the uniformity and homogeneity of the solidified products based on Portland cements which have been prepared using such i
high-shear mixers?
l 39.
Page 4, Section 3.1.2 What is the basis and composition of the l
water / cement mix for t.he. drum half-full of residue? It is not clear from either this section or section 3.3 how the contents will be characterized, in terms of either raciological proprties or structural stability.
40.
Page 6, Section 3.1.6.
Tables 1A through 1F in the PCP document present saste stream formulations from 84.72% to 95.46%.
It is not clear from the PCP document how accurately and how precisely the % fill of the drum can be controlled. What centrols exist for ensuring filling of the drum?
41.
Page 7, Section 3.1.7, Last line of section.
Compressive strength is.
indicated to be periodically tested for test drum.
Is compressive strength being tested or is it penetration resistance?
If it is penetration resistance, which is a measure of hardness, what empirical correlation exists to estimate compressive strength.as identified in the Branch Technical Position?
42.
Page 7, Section 3.1.7.
Tais section indicates "A remotely operable
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conveyor system is instalied at CSS to (among other things] periodically i
test drums for fill, free vater and compressive strengtn." The PCP~
J document provides no detai's on how these tests are to be done other than i
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JKANE/88/04/28
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to state in Section 8.0, FULL-SCALE ORUM TESTING, and in Attachment 8.
CSS Run Plan, that one drum will be randomly selected per production week, allowed to cure for 7 days, and then tested for fill, free water, and compressive strength.
The CSS Run Plan refers to a Standard Operating.
Procedures document, S0P 70-40, Full Size Testing of Solidified Product, that does not provide more details. WVNS should provide a description of the full-scale drum testing and also provide justification for selecting a 7-day cure period.
43.
Page 8, Section 3.3.
How will the flush drums be classified as Class A or greater than Class A? The description it. Section 3.3 of the handling of the flush drums makes no mention of either sampling or gamma-radiation measurements for the purpose of estimating radionuclide activities.
How many flush drums will be produced? Also, under what circumstances does WVNS consider it necessary to transfer flush drums into a high-integrity container (HIC)? For example, if the drum is found to be greater than Class A or if the drum is greater than Class A and also fails the stability criteria of Part 61.
Please clarify.
If stability criteria enter into the decision to use HICs, now will WVNS ascertain whether a particular solidified flush drum meets these criteria?
Will the "suspect" drums be separately stored from the permanent facility?
What procedures define the storing of "suspect" drums?
44.
Page 25, Section 5.14 Are there reasons in the PCP document other than compressive strengths ( 60 psi) for a waste drum to be-considered an out-of-specification drum?
Comments on Attachment B -' Cement Solidification System Run Plan 45.
Page 5, Section 7.1.2.
What part of the drums will be tested for smearable surface contamination?
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46.
Page 10, Section 10.2.
The table listing the calibration frequency for i
instruments does not identify the instruments or frequency for testing compressive strength.
Please clarify.
F.
ACCEPTANCE CRITERIA AND ACTION LEVELS 47.
Page 6, Section 3.1.7.
Where in the PCP document is the expected or desired pH of the waste stream feed to the high shear mixer addressed?
(Section 4.0 notes that the WVNS Analytical Laboratory will analyze the waste feed tank contents for pH.)
48.
Page 22, Section 5.2. -What action would be taken if such undissolved substances are found? How will slow crudding up of the hold tanks or feed tanks with such solids be dealt with and how will these solids be characterized?
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JKANE/88/04/28 49.
Page 22, Section'5.2.
The referenced Analytical Chemistry Methods.(e.g.,
ACM-Gamma-3101) are not recognized standards. Are these ACM designations similar to published standards (e.g., ASTM) or to methods specified in internal WVNS documents? Please clarify.
50.
Page.24, Section 5.8.
The compressive strength criteria must be' greater than 60 psi. See previous,NRC comment numbers 32 and 33 relative to the 2-inch cube samples.
G.
EDITORIAL COMMENTS
- 51. General. The PCP report should stand by itself, with its objective and background information described in sufficient detail so that it can be clearly understood. ~The purpose of the PCP report (which could form an outline for the construction of the report)'is not given. Also, pertinent results given in other reports should be, at least, summarized so that it is not necessary to be constantly searching other reports.
52.
Page 1, Section 1.0.
The meaning of CSS should be given where it initially appears in the PCP.
53.
Page 1, Section 1.0.
The material for the 71 gallon square drum should be identified.
54.
Page 3.
Incorrect spelling of "following" on fourth line.
55.
Page 3, Section 3.1.1.
The location of 5-0-158 is not located on the CSS-Flow Diagram (Orawing 9000-2198).
56.
Page 4, Section 3.1.2, 4th line.
What amount (range) of utility water is j
to be transferred?
57.
Page 4, Section 3.1.2, 8th line.
The actual "high speed" should be given.
58.
Page 8, Section 3.3, 6th line. The duplicated words "specified in a flush recipe" should be deleted.
i 59.
Page 12, 6th line from bottom.
Is the word "terminated" a clearer description of the action taken rather than "inhibited"?
I 60.
Page 16, 3rd line.
Even if small, there must be some variance.
61.
Page 18, Section 4.1.1.
To understand what safety precautions are outlined in Analytical Chemistry Procedure-(ACP) 7.2, "Laboratory Safety,"
and ACP 7.4, the NRC staff would need to be provided copies of these l
procedures.
62.
Page 20, Section 4.3.3.
The 50 psi should be changed to 60 psi.
(Also applies to Page 25, line 4.)
.I JKANE/88/04/28,
63.
Page 27, Section 7.0, :13th line.
Either describe or provide reference for the Analytical Quality Assurance Program.
Comments on Attachment A - Decontaminated Supernatant Waste Form Development Report-64 Page 1, Section 1, Line 6.
What is_the meaning of PUREX?.
65.
Page 1, Section 1, Line 8.
Reference 18 is identified but only 14 references are listed at the end of Attachment A.
Please clarify.
66.
Page 1, last line.
The reference'for the R&D reports should be given.
67.
Page 2, 2nd Paragraph, Line 4.
The meaning of STS should be given.
- 68. Page 5, 1st Paragraph, Last Sentence.
How were the crushed samples inspected for density and porosity? (microscopically, visually (not consideredaccuratemethod],orother?)
69.
Page 6, Line 1.
How was the "significantly reduced porosity" determined (visual method weald only be a crude estimate)?
70.
Page 7, Section 2.1, Line 14.
Provide the RPM for the "lowest speed."
71.
Page 11, Section 2.3, 2nd Paragraph, Line 8.
Please clarify.whether "sharp edges" refer to solid particles.
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- 72. Page 13, 2nd Paragraph, Line 1.
Provide the AkiMl type for the fly ash.
73 Page 13, 2nd Paragraph, last Sentence.
There is a statement'about the amount of antifoam being dependent on the amount of supernatant and not on the solids.
Is this correct?
Is not the amount of added solids dependent j
i on the amount of supernatant?
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74.
Page 13 Line 4 from bottom. Explain why there was a "higher total solids."
- 75. Page 15, 1st. Paragraph, Line 4 Consider replacing "many" with "some."
Many organic chemicals are at the worst mild retarders.
- 76. Page 16, 2nd item under Results.
Please define the term "adhesive" in the way that it is used.
77.
Page 18, 2nd Paragraph from Bottom, Line 3. Provide the range.
- 78. Page 18, 2nd Paragraph From Bottom.
Explain the increase in the volume of cement.
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-JKANE/88/04/28 1.
- 79. Page.19,.Line 3.
'The set retardants ~do-not. appear to have'been unequivocally identified.
- 80. Table 3-(no page-listed). Reference;16 is not identified in the list of.
references. Are the recipes based on the simulated supernatant?
- 81. Graphs 1 and 2.
Provide the units for' density, watts, set time and for antifoam.
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1 Additional Coninents on Draf t PCP A.
Comment No. 6 in Enclosure 1 concerns sample verification sampling.
It is suggested that sampling for total organic carbon from the cutput of the waste dispensing vessel be considered as part of that lab-scale sample verification process.
B.
In regard to verification sampling in general, the NRC staff has prepared draft guidelir.es for preparation of a solid waste process control program, and the WVDP has those draft guidelines, which were discussed in part at the llay 3 and 4,1988 meeting at West Valley. As noted on Page 4, in the paragraph titled "Verification Sampling" it is indicated that the verification sample should be obtained from at least every tenth batch of waste processed or a sample obtained for at least every 5000 gallon!, of batch waste processed, whichever is more frecuent.
The PCP should address how the intent of the PCP guidance document will be satisfied with regard to sampling frequency.
I