ML20195K397
| ML20195K397 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1988 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bixby W ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 24431, NUDOCS 8806290415 | |
| Download: ML20195K397 (3) | |
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Dear Dr. Bixby:
N This letter is in response to your May 16, 1988, letter to Dr. Malcolm R.
Anapp, regarding (1) the on-going supplementary qualification testing of the formulation for solidifying the decontaminated supernatant waste at the West Valley site and (?) y.. t proposed tk.ree-step approach to final waste qualification.
From pur letter we understand that the three steps are as follows:
Step A - "Hot Checkout Testing," i.e., limited production-scale operations usin3 actual decontaminated supernetant wasp, to verify integrated system operations and to demonstrate suitability of pron ct by testing.
Step B -- Upon completion of supplementary qualifica+ ion testing, conduct tull production operations to solidify tne remaining deccntaminated supernatant.
Step C -- Assumig all'nonwaste form issues are resolved and following
.cmpletion of long-term testing, complete final disposal.
Based cn the information and data that you have provided to the NRC prior to the M y 15, 1988 submittal regarding the revised formulation for solidification of the decc"taminated supernatant and our brief review of the more recent results frou the supplementary qualification testing that were provideo in Attachr.4nt 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 thr.t our endorsement of your oroposal to proceed with full-scale production must await the completion of the qualifu.ation testing, wnic' is now scheduled for '",e July 1988, We plan to respond to DOE on the recent data provided in Att.
wn+ - ?.nc' to vour responses in Attachmer.: B on the Process Control Plan (P b;,.-August 1788, following our review of the remaining test results to te r:
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'n 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 percent supernstant). 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 b1 regulatory requirements on waste form stability will be met.
2.
Satisfactory revision of the Process Control Plan (PCP) thac addresses and resolves past comments by the NRC staff and its consultants.
3.
Testing of the full-3cale solidified waste form (e.g., at INEL as discussed at May 3,1988, meeting at West Valley) that confirms the achievement of acequate homogeneity and compressive strength in the finai waste product. Additional core samples could also be obtained to provide i
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 conditions to be imposed, the procedures for evcluating compressive strength results over time allowing for normal variations in test results and the '.dentification of criteria for determining when surface degradation (spalling and cracking) is excessive and unacceptable.
Also, before proceeding with Step B, DOE should provide written statenents on positions that have been verbally given in the past to the NRC. These statements would include DOE's acknowledgrent that proceeding with full scale waste solidification efforts for the supernatant and placement in the drum cell will not foreciose 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 solicified waste from tne West Yalley site),
with sufficient details to demonstrate the viability of the alternati/es.
At this time the staff chooses not to comment on Step C 3roposed by DOE for the "1993 Qualification for 0-osal" because many issues otler than solidification of n upernatunt are involved, it would be helpful if DOE were to provide, J
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BIXBY LTR d 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 i
den.Grstrates the acceptability of the siting, design and construction of the proposed tumulus; resolution of the limit on transuranic waste, etc.) to be addressed to demonstrate that 10 CFR Part 61 requirements could be met.
Sincerely, ORf9NAL SIGNED 8?
Richard L. Bangart, Acting Director Division of low-Level Waste Management and Decommissioning DISTRIBUTION:
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OFFICIAL RECORD COPY
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