ML20153B475
| ML20153B475 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1988 |
| From: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lowenberg H LOWENBERG ASSOCIATES, INC. |
| References | |
| REF-WM-81 NUDOCS 8807130086 | |
| Download: ML20153B475 (1) | |
Text
b p Mr. Homer Lowenberg, President Lowenberg Associates, Inc.
10901 Rosemont Drive Rockville, MD 20852 JUN : 9 1998
Dear Mr. Lowenberg:
This letter is to close out formally in our tracking system an allegation (AllegationNumber.NMSS.88.A-001fromLowenbergAssociates,Inc., received December 22,1987) submitted by you in accordance with 10 CFR Part 21.
It was alleged that NUPAC is marketing Chichibu High Integrity Containers (HICs) for ua.e in compaction of low-level waste (LLW) and that at least one utility may be using these HICs for that purpose. The HIC has not been approved for use in compaction and may not be capable of such use.
NRC staff met with representatives of Chichibu Cement Company and Nuclear Packaging on January 20, 1988 at WFN. The purpose of the meeting was to discuss a change in use of the Chichibu HIC that was not covered in the TopicalReport(TR). Chichibu wants to market the HIC for compaction of LLW.
The NRC staff advised them to submit an amended TR to justify any use of the HIC that is outside the limits of the approved TR. NUPAC assured hRC during the reeting that no compaction of waste in a Chichibu HIC intended for burial has taken place nor has any Chichibu HIC been marketed for that purpose.
The staff considers that this resolves the allegation. A copy of the meeting report is enclosed.
Sincerely, (0%inal.Sipid liv l
-j John J. Surme1I6, Chief Technical Branch Division of Low-Level Waste Management and Decomissioning
Enclosure:
As stated cc: Mr. Osamu Suzuki, Manager Technical Development Department Related Products Div.
Chichibu Cement Co., LTD.
The Head Ottice Nippon Kogyo Club Bldg.
No.4 6, 1.Chome Marunouchi Chiyoda-Ku. Tokyo, Japan
^
DISTRIBUTION:
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MEMORANDUM FOR: John J. Sunneier, Chief Technical Branch
/
Division of Low-level Waste Management and Decomissioning, NMSS t
FROM:
Everett Wick Technical Branch Division of Low-Level Waste Management and Decomissioning, NMSS
SUBJECT:
REPORT OF MEETING WITH CHICHIBU AT WFN1 ON JANUARY 20, 1988 Pqrpose:
To discuss a proposed change in use of the Chichibu High Integrity Container (HIC) not covered by the topical report.
Attendees:
NRC
~
John Greeves, LLWM John Surmeier, LLTB Michael Tokar, LLTB Robert Fonner, 0GC Keith McDaniel, LLTB Leroy Person, LLTB*
Everett Wick, LLTB Chichibu Group Yoshibumi rurusawa, President, Scimarec Co., Ltd.
Osamu Suzuki, Manager Technical Development, Chichibu Cement Co.
Richard Haelsig, Executive Vice Prasident, Pacific Nuclear Systems.
Gary Clark, PICHIC Project Manager, Nuclear Packaging (A Pacific Nuclear Company).
Gordon Epstein, Panager Radiological Issues, Mitsubishi Washington Branch.
- Attended only latter part of meeting due to need to attend another meeting.
(,.
0 JAN I51998 John J. Surmeier 2
Summary 1.
Nuclear Packaging, as U.S. marketing agent for the Chichibu HIC, and Chichibu are considering marketing the HIC for compaction of waste within the container and are looking for guidancs on how to proceed. NRC advised them to submit amendments to justify any intended use that is outside the limitations of the topical report that NRC approved.
2.
NRC told Chichibu that amendments would be treated as new topical reports and would be placed behind other topical reports already.in the review process.
3.
NRC stated that the topical report is not a legal requirement. A user would be taking a risk, however, if a HIC were used in a canner outside the limitations of the topical report approved by NRC. The risk would be that the operator of the burial site would not accept the HIC for burial.
, Discussion whichibu's HIC has been approved by NRC. Chichibu, however, is considering marketing the HIC for compaction of low-level waste after the waste has been placed in the container and is looking for guidance on how to proceed. Diablo Canyon wants to use the HIC for compaction and has done some preliminary development on this. The HIC is approved for compacted waste but Haelsig says the topical report is silent on where the compaction'is to be conducted. NRC stated that compaction of waste in the HIC is outside the scope of the Topical Re' port that NRC app;oved.
Fonner pointed out that the Topical Report is not a legal requirement. Surmeier, however, raised the question of whether the vendor is obligated to notify the user if an intendeo use is outside the limitations of the topical report approved by NRC. Sunneier also pointed out I
that the user would be taking a risk if the HIC were used in such a manner.
The risk would be that the operator of the burial facility would not accept the HIC for burial if its use were outside the limitations of the topical report approved by NRC.
l l
Maelsig said that his company is seeking markets for the Chichibu HIC and i
expects that a number of potential uses will arise. This is likely to result in a number of requests for amendment to the Topical Report. He asked how long it would take to review a submittal for an amendment.
NRC replied that it could not estimate when review of a submittal for amendment could be completed because of factors outside NRC's control. NRC advised that each a;nendment would be treated as a new topical report and would take its place behind other topical reports that were already in NRC's review process.
Fonner explained that NRC's charges for reviewing submittals for amendment would also be handled as submittals for new topical reports, i.e.,
the time of the technical reviewer would be charged up to a maximum of
$20,000.
. a..
s.
1 JAN 2 51988 John J. Surmeier 3
v.
Haelsig and Clark asked what kind of information should be submitted in an amendment to provide for compaction after the waste is placed in the HIC.
Tokar advised them to provide whatever information they feel is necessary to demonstrate that the HIC can sustain the compaction process and still meet its intended function.
Person pointed out the need to demonstrate that there is less than one percent free liquid in the compacted material.
When questioned Haelsig assured NRC that no compaction of waste in a Chichibu HIC intended for burial has taken place nor has any Chichibu HIC been marketed for that ourpose. Diablo Canyon has done preliminary development on compaction of waste in a reject HIC that Chichibu sent them.
Y/
Everett Wick Technical Branch Division of low-level Waste Management and Decomissioning, NMSS cc:
M. Knapp-J. Grceves l
l I
l l
8 ALLEGATION MANAGEMENT' SYrTEM ALLEGATION NUMBER - NMSS-88-A-0001 RUN DATE: 880809 DOCKET / FACILITY / UNIT:
/ NUCLEAR PACKAGING, INC. (NUPAC)
/
DOCKET / FACILITY / UNIT:
/
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DOCKET / FACILITY / UNIT:
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DOCKET / FACILITY / UNIT:
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ACTIVITY TYPES - VENDOR MATERIALS OTHER LOW-LEVEL WASTE MATERIAL LICENSES -
FUNCTIONAL AREAS -
OPERATIONS ONSITE HEALTH AND SAFETY OFFSITE HEALTH AND SAFETY DESCRIPTION - IT 'S ALLEGED THAT NUPAC IS MARKETING CHICHIBU HIGH INTEGRITY CONTAINERS (HICS) FOR USE IN COMPACTION OF LOW-LFVEL WASTE AND THAT AT LEAST ONE UTILITY MAY BE USING CONCERNS -
THESE HICS FOR THAT PURPOSE THOUGH THE HIC HAS NOT BEEN 1
APPROVED FOR THIS AMD MAY NOT BE CAPABLE OF USE FOR COMPACTION.
SOURCE - LOWLNBERG ASSOCIATES CONFIDENT - NO RECEIVED - 871222 BY - M TOKAR
/ NMSS ACTION OFFICE CONTACT - JJ SURMEIER
- (3011492-3441 SAFETY SIGNIFICANCE - UNKNOWN BOARD NOTIFICATION - NO STATUS - CLOSED SCHED COMPLETION - 880630 DATE CLOSED - 880321 ALLEGATION SUBSTANTIATED - NO ALLEGER NOTIFIED - YES DI ACTION - NO OI REPORT NUMBER -
REMARKS - STAFF FROM LLWM AND OGC MET WITH CHICHIBU ON 20 JAN 88 AT WFN TO DISCUSS CHANGE IN USE OF HIC NOT COVERED IN TOPICAL REPORT.
CHICHIBU WANTS TO MARKET HIC FOR COMPACTION OF LLW.
STAFF ADVISED THEM TO SUBMIT AMENDMENTS TO JUSTIFY INTENDED USE THAT IS OUTSIDE LIMITS OF APPROVED TOPICAL REPORT.
NUPAC ASSURED NRC DURING THE 1/20/88 MEETING THAT NO COMPACTION OF WASTE IN A CHICHIBU HIC INTENDED FOR SURIAL HAS TAKEN PLACE MOR HAS ANY CHICHIBU HIC BEEN MARKETED FOR THAT PURPOSE.
LLWM STAFF CONSIDERS THAT THIS RESOLVES THE ALLEGATION. REPORT OF 1/20/88 MEETING CONTAINED IN MEMO FROM E. WICK TO J. SURMEIER 1/25/88 IN ALLEGATION FILE.
ENTERED SYSTEM - 880316 CLOSED SYSTEM - 880511 RECORD CHANGED - 880511 O
e
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