ML20195J172
| ML20195J172 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1988 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bixby W ENERGY, DEPT. OF, IDAHO OPERATIONS OFFICE |
| References | |
| REF-PROJ-M-32 NUDOCS 8806290069 | |
| Download: ML20195J172 (3) | |
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- JUN l 61988 Dr. W. W. Bixby, Director West Valley Project Office Idaho Operations-Office P. O. Box 191 West Valley,llY 14171
Dear Dr. Bixby:
This letter is in response to your May 16, 1988, letter to Dr. Malcolm R.
Knapp, regarding (1) the on-going supplementary qualification testing of the formulation for solidifying the decottaminated supernatant waste at the West Valley site and (2) your proposed thrte-step approach to final waste qualification.
From your letter we understand that the three steps are as follows:
Step A - "Hot Checkout Testing," i.e., limited production-scale operations using actual decontaminated supernatant waste, to verify integrated system operations and to demonstrhte suitability of product by testing.
Step B -- Upon completion of supplementary qualification testing, conduct full production operations to solidify the remaining decontaminated supernatant.
Step C -- Assuming all nonwaste form issues are resolved and following completion of long-term testing, complete final disposal.
Based on the information and data that you have provided to the NRC prior to the May Iti,1988 submittal regarding the revised formulation for solidification of the decontaminated supernatant and our brie' review of the more recent results from the supplementary qualification itsting that were provided in Attachment A to your May 16, 1988 letter, we conclude that there is a good technical basis for proceeding with the next step (Step A) of limited production operations, as you have proposed. The results to date indicate that it is likely that a stable waste form will be produced by the new formulation, but it is recognized that our endorsement of your proposal to proceed with full-scale production must await the completion of the qualification testing, which is now scheduled for late July 1988. We plan to respond to DOE on the recent data provided in Attachment A and to your responses in Attachment B on the Process Control Plan 'PCP) by mid-August 1988, following our review of the remaining test results to be provided by WVDP in July 1988.
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1 BIXBY LTR As we have discussed in the past, there are certain conditions that we suggest should be completed before proceeding with Step B (full production operations to. solidify the 39 weight parcent supernatant). These conditions would include the following: '
1.
Successful completion of all remaining qualification testing with results-that indicate that there is reasonable assurance that 10 CFR Part 61 regulatory requirements on waste form stability will be met.
2.
Satisfactory revision of the Process Control Plan (PCP) that addresses and resolves past comments by the NRC staff and its consultants.
3.
Testing of the full-scale solidified waste form (e.g., at INEL as
? discussed at May 3,1988, meeting at West Valley) that confirms the achievement of adequate homogeneity and compressive strength in the final weste product. Additional core samples could also be obtained to provide specimens for testing and development of data as part of the long-term test program.
4.
Attainment _of an agreement in principle between DOE and the NRC staff on a suitable long-term (5 year' test program for the solidified supernatant waste that covers the specific curing cor itions to be imposed, the procedures for evaluating compressive strength results over time allowing for normal variations in test results and the identification of criteria for deternining when surface degradation (spalling and cracking) is excessive and unacceptable.
Also, before proceeding with Step B, DOE should provide written statements on positions that have been verbally given in the past to the NRC. These statements would include DOE's acknowledgment that proceeding with full scale waste solidification efforts for the supernatant and placement in the drum cell will not foreclose the undertaking and completion of practicable alternative methods of disposal of the LLW. The statements should also describe DOE's alternate. disposal plans (e.g., overpacking the cement solidified supernatant waste in HICs or removal of the solidified waste from the West Valley site),
with sufficient details to demonstrate the viability of the alternatives.
At this time the staff chooses not to comment on Step C 3roposed by DOE for the "1993 Qualification for Disposal" because many issue otler than solidification of the supernatant are involved.
It would be helpful if DOE were to provide,
BIXBY LTR prior to the start of. Step B, a plan and schedule that identifies the important milestones (e.g., submittal of the technical information and data that demonstrates the acceptability of the siting, design and construction of the proposed tumulus; resolution of the limit on transuranic waste, etc.) to be addressed to demonsteata that 10 CFR Part 61 requirements could be met.
Sincerely, ORIGINAL $GNED By Richard L. Bangart, Acting Director Division of Low-Level Waste Management and Decommissioning DISTRIBUTION:
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