ML20195K162

Provides Supplemental Qualification Data Re Cemented Low Level Waste Form & Reaffirms Project Position on long-term Mgt of Subj Waste

ML20195K162
Person / Time
Site:	West Valley Demonstration Project
Issue date:	11/29/1988
From:	Bixby W ENERGY, DEPT. OF
To:	Knapp M NRC
Shared Package
ML20195K167	List: ML20195K162 ML20195K210
References
REF-PROJ-M-32 NUDOCS 8812050149
Download: ML20195K162 (3)

Text

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k Department of Energy Idaho Operations Office g 'A j; g

West Vaney Propset Office 5

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P.O. Box 191 West Valley, NY 14171 November 29, 1988 Mr. Malcolm Knapp U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

West Valley Demonstration Project (WVDP) Cement Low-Level Waste Form Qualification

REFERENCE:

(A) Letter M. Knapp to W. W. Bixby, dated June 16, 1988 l

(B) Letter M. Knapp to W. W. Bixby, dated August 5, 1988

Dear Mr. Knapp:

The purpose of this letter is to provide supplemental qualification data concerning the cemented low-level waste form and to reaf firm the Project's position on the long-term management of this waste.

The above referenced letters provided the Project with NRC comments and advice regarding a) the qualification testing of the cement waste form for decontaminated supernatant and b) an approach to final waste d'sposal acceptance. The specific review comments of the NRC staff, its consultants from the National Bureau of Standards (now called National Institute for Standards and Testing) and Brockhaven National Laboratory provided valuable insight to the: (1) Topical Report on Waste Qualification, (2) Process Control Plan for operation of the Cement Solidification System, and (3) conceptual short and long-term testing programs for the cemented waste. The Project has evaluated and addressed the NRC observations and the documents have been revised to reflect these observations.

It should be noted that the Process Control Plan has been incorporated as an appendix to the Topical Report, in addition, a statistical analysis of presolidification compressive strength test data has been prepared. The revised documents and the statistical analysis are enclosed for your use and information.

As reflected in the Topical Report on Waste Qualification and supporting product data, the West Valley Demonstration Project cement waste form has been fully characterized. The Project believes the Cement Solidification System l

has been properly configured to produce a waste form which exceeds all performance requirements identified in the NRC 1933 Branch Technical Position i

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Mr. Malcolm Knapp November 29, 1988 To verify the cement product integrity, we have initiated an in-process quality control surveillance program, plus both a short-term and long-term product testing program that will focus on the collection of performance data for the cement waste form package. This information will provide a solid data base to support performance assessment calculations of this waste in the long-term. These calculations and the supporting data will be a key element in the preparation of our impending Closure Environmental Impact Statement (E!S).

In addition, this data should be of generic interest, not only to the Department, but the entire nuclear industry on tha long-term performance of cement matrix waste.

With respect to disposal Public Law 96-368 directs the Secretary to "...

dispose of low-level waste..."

In keeping with that mandate, the long-term cement performance data will be utilized to develop a performance assessment model, as noted above, which will be used to support the design basis of a disposal system as required by NEPA.

The analysit will inclurie a number of alternatives covering a range of disposti designs, includ',ng on and off-site scenarios. To preclude tne foreclosure of any options, the Project has already taken steps to enhance the retrieveability of the wastes (i.e., drum 1

cell design, waste package containment design, etc.) should an off-site disposal option be the prefered option. Any anomolies in the waste form i

package detected between now and the EIS completion would be dealt with promptly. Adjustmcr.ts to the waste form or package would be addressed in the l

context of evaluations conducted in support of the disposal system design j

including additional barriers to the waste form.

Because of the generic benefit of this data, we will continue to keep the NRC i

informed on progress being made during the production campaigns of the Cement j

Solidification System. As interim storage data becomes available, we will provide you with progress letter reports on a yearly basis or earlier if the i

situation warrants. Should the NRC require additional information, please advise me.

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Mr. Malcolm Knapp November 29, 1988 i

This office appreciates the cooperative, constructive approach utilized in reaching a ecmmon understanding on the performance of the Project cemented low-level waste. This should serve as an example of future interactions between our agencies to achieve completion of 6he West Valley Demonstration i

Projec t.

Sincerely,

.4 f1~hl%.

W.W.Bixby, Director)

West Valley Project Office

Enclosures:

(1) Topical Report on Waste Form

'lification (2) Statistical Analysis of Presolidification Compressive Strength Test Data l

(3) Test Plans for Short and Long-Term Testing of Cement Waste Forms cc:

R. D. Hurt, NRC-riQ, w/ene.

i T. N. McIntosh, DOE-HQ, w/ enc, J. E. Soleckt. DOE-ID, w/out enc.

EM:079:88 - 1277:88:10