ML20211K301
| ML20211K301 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/1997 |
| From: | Hauber R NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| To: | Greeves J, Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| NUDOCS 9710090199 | |
| Download: ML20211K301 (3) | |
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NUCLEAR REGULATORY Commission o
1' WASHINGTON, D.C. 80MH001 October 7, 1997 i
'I MEMORANDUM T0:
John T. Greeves, Director l
Division of Waste Management i
Office of Nuclear Material Safety and Safeguards Paul H. Lohaus Deputy Director Office of State Programs FRON:
D auber, Director Nonproliferation, Exports and Multilateral Relations Office of International Programs
SUBJECT:
PROPOSED IMPORT OF RAD 10AC11VE WASTE FROM CANADA Attached is an application from Diversified Scientific Services, Inc. (OSSI),
Kingston Tennessee for the im) ort (IWOO4) of Canadian radioactive waste.
Your advice and assistance in tie review of the application would be appreciated.
The wastes to be imported are from Ontario Hydro Technologies and are typically liquid, used oil and/or other combustible materials containing primarily tritium and carbon-14, mixed fission product radionuclides and other contaminants.
The waste is generated during the normal course of business by the nurlear power utility.
The applicant advised that only waste authorized by their Resource Conservation and Recovery Act Permit, their Radioactive Materials License and U.S. Used Oil Regulations (40 CFR 279) will be imported.
The anticipated maximum quantity of waste requested for import is 5,000,000 kilograms per year. We feel that a license for import of the subject material should not exceed three years.
The waste is to be processed at DS$1's Industrial Boiler facility wht.ein the imported waste will be burned. The resultant residue, in the form of solids, will be returned to Canada for final disposition.
To assist in your revlew, I am also attaching a copy of the export license application (XWOO2) for the re-export of the resultant residue, and a copy of a draft letter to the Tennessee Department of Environment and Conservation.
Please also give us your comments on the draft letter, g ( D)_
The import licensing criteria in 10 CFR 6110.43 are as follows:
(a)
The proposed import is not inimical to the common defense and security, g
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(b)
The proposed import does not constitute an unreasonable risk to the public health and safety.
(c)
Any applicable requirements of subpart A of part 51 of this chapter are satisfied.
(d)
With respect to the im) ort of radioactive waste, an appropriate facility has agreed to accept tie waste for management or disposal,
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J. Greeves 2-I would appreciate your comments, including recommended consultations, if any, with Federal agencies or with interested States, or low-level waste Compacts, t
in addition to the State of Tennessee.
Please note that we would not issue an 1
import license until we are satisfied that a license can be issued for the i
export of the residue.
I Your comments are requested by October 17, 1997.
Please call if you need additional information.
Attachments:
1.
Import Itcense application dated July 23, 1997 (IWOO4) 2.
Draft letter to State of Tennessee 3.
Export license application dated i
July 23, 1997 (XWOO2) 1 cc w/ attach:
T. Rothschild, OGC DISTRIBUTION:
Central files ~f k-3D - 15 PDR DCS/ W P OIP r/f CRStoiber RDHauber BLWright JKennedy, NMSS 1
SSalomon, OSP DOCUMENT NAME:
G:\\ EXPORTS \\lWOO4.MEM
- PREVIOUS CONCURRENCE T3 tusive e copy of this document, indicate in the bes:
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- Copy without enclosuree
'3" a copy with enclosures
'9" a llo copy 0FFICE OlP/NEMRHu(gd OGC*
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l NAME BLWright: tic 0 TRothschild RD!!auber RAA DALE 10/on/97 10/06/97 1C/ 0 797' 10/ /97 10/ /97 (DiffltQWil. IRiiRDRD (RQPr."
J. Greeves 2-I would appreciate your comments, including recommended consultations, if any, with Federal agencies or with interested States, or low-level waste Compacts, in addition to the State of Tennessee.
Please note that we would not issue an import license until we are satisfied that a license can be issued for the export of the residue.
Your comments are requested by October 17, 1997.
Please call if you need additional information.
Attachments:
1.
Import license application dated July 23, 1997 (IW004) 2.
Draft letter to State of Tennessee 3.
Export license application dated July 23, 1997 (XW002) cc w/ attach:
T. Rothschild 0GC 1
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'o Diversified Scientific Services, Inc.
657 GMaher Road
- Kirgston, TN 37763 * (423) 376 0084
- FAX (423) 376 0087 AD0234 97 Sent Via Federal Express No. 3353250644 July 23,1997 yg gg
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X u) OOA Mr. Ronald D. Hauber i
Director for Non Proliferation, Exports & Multilateral Relations Office of International Programs U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20855 Re:
Application for a Specific License to import / Export Radioactive Waste
Dear Mr. Hauber:
Diversified Scientific Services, Inc. (DSSI) requests, under 10 CFR 110.20 (a)(2), the issuance of a specific import license to receive radioactively contaminated waste from Ontario, Canada for processing. Additionally, DSSI requests the issuance of a specific export license to return to the generator the radioactive solids associated with processing the imported material.
DSSI operates an industrial Boiler Facility for the treatment of liquid waste. DSSI is permitted to receive this material and to perform this treatment under RCRA Part B Permit Number TNHW-024 issued by the Tennessee Division of Solid Waste Management and Radioactive Materials License Number R 73014-K98 issued by the Tennessee Division of Radiological Health.
This process completely destroys the original waste. The DSSI air pollution control system captures particulate matter and neutralizes the acid forming gasses generated during combustion of the waste. The salts from neutralization and boiler ash associated with this waste will then be returned to the generator.
Prior to making the first shipment of radboctive material to DSSI for processing, Ontario Hydro will provide written assurance from the appropriate Canadian authorities confirming Ontario Hydro's authorization to accept return receipt of their material, processed or unprocessed.
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I Diversified Scientific Services,Inc.
t 657 Gattaher Road
- Kngston, TN 37763 * (423) 376-0084
- FAX (423) 376-0087 AD0234 97, Page 2 l
Mr. Ronald D. Hauber l
July 23,1997 l
l As required by 10 CFR 110.31, the following attachments are enclosed in support of this license application:
Attachment A Information required by 10 CFR 110.32 for an import license Attachment B information required by 10 CFR 110.32 on an NRC Form 7 for an expor1 license Attachment C Initial 55,000.00 application fee in accordance with 10 CFR 170.31 Additionally, a letter from Ontario Hydro concerning their ability to receive solids from DSSI generated from processing their liquid is also attached as follows:
Attachment D Ontario Hydro letter from H. Morrison dated June 27,1997 Thank you for your consideration in this matter, If you have any questions or require any additionalinformation, please do not hesitate to contact me at (423) 376-0712.
Sincerely, m
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imn Selph DSSI Radiation Safety Officer Attachments CC:
Dr. J.P. Kraznia, Ontario Hydro Technologies Mr. Roger Perry, TN DEC, Division of Radiological Health
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i Diversified Scientific Services,Inc.
657 Ga!!aher Road
- Kngston, TN 37763 * (423) 376-0084
- FAX (423) 3 '6 0087 1
l AD0234 97, Page 3 Mr. Ronald D. Hauber July 23,1997 ATTACHMENT A import License Application
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import Ucense Application The following information is provided,~ as required by 10 CFR 110.32, to support
- the application for a specific license to import radioactive waste.
Name and Address of Apolicant Diversified Scientific Services, Inc, (DSSI) 657 Gallaher Road Kingston, Tennessee 37763 TN Radioactive Material License No. R-73014-K98 l
N_gme and Address of Supejjg
- Ontario Hydro Technologies Pickering Nuclear Division P.O. Box 160 -
Pickering, Ontario L1V 2RS Country of Orlal.B
-Canada Name and Address ofIntermediate Consionees There are no intermediate consignees. The waste will be shipped directly to DSSI for processing and the resultant solids will be shipped directly back.
Dates of Proposed First and Last Shloment
' First Shipment - August,1997 -
Last Shipment - Continuous business from date of authorization AD0234-97, Attachment A Page 1 of 2 i
4 Material Description The radioactive wastes to be imported from Ontario Hydro Technologies are typically liquid, used oil and/or other combustible materials containing primarily H-3 and C-14, mixed fission product radionuclides, and other contaminants. The waste is generated during the normal course of business by the nuclear power utility. Only waste authorized by our RCRA Permit, our Radioactive Materials License, and the Used Oil Regulations (40 CFR 279) will be imported.
The anticipated maximum quantity of waste is 5X10' kilograms per year. The anticipated maximum quantity of radioactivity is approximately 1000 Cl of H-3 and C-14 and 10 Cl of mixed fission product radionuclides per year. The wastes to be shipped to DSSI under this license will be destroyed and not disposed.
Therefore the classification described in 10 CFR 61.55 is not applicable.
In accordance with 49 CFR 171.12a, the material shall be transported in accordance with Canadian and U.S. transportation regulations. The material w most likely be transported by exclusive use tractor trailer or taak truck to DSSI as Radioactive LSA or an exempt quantity.
The material was generated during the last 20 years from routine maintenance of machines and machine shop work. The generator has a regulatorily driven yson to dispose of this waste prior to August 31,1997 and there is no permitted outlet for it in Canada.
After the waste has been processed, the resultant solids will be returned to the generator in Canada for storage.
AD0234 97, Attachment A Page 2 of 2 l
Diversified Scientific Services,Inc.
657 Gaflaher Ibad
- Kngston. TN 37763 * (423) 376 0084
- FAX (423) 376 0087 i
AD0234 97, Page 4 Mr. Ronald D. Hauber July 23,1997 ATTACHMENT B Eu K/x/44 2.
NRC Form 7, Export License Application i
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Printed on recy0ted C8De'
Diversified Scientific Services, Inc.
657 Ga!iaher Road
- Kngston TN 37763 * (423) 376-0084
- FAX (423) 376-0087 AD0234 97, Page 5 Mr. Ronald D. Hauber July 23,1997 ATTACHMENT C Application Fee h
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Diversified Scientific Services,Inc.
657 Gal!aher Road
- Kngston, TN 37763 * (423) 376-0084
- FAX (423) 376-0087 AD0234-97, Page 6 Mr. Ronald D. Hauber July 23,1997 ATTACHMENT D Ontario Hydro letter dated June 27,1997 6
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MEMORANDUM J, KRASZNAl 97 06 27 Principle Research Engineer / Scientist Technology Services Division KKR 230 FILE: WO 03463 (T5)
Ash from the Destruction of Radioactive Liould at DSSI We were asked if we would accept ash from the destruction of radioactively contaminated liquid if that material was destroyed at a U.S. facility such as that operated by DSSI, Our facility is licensed to accept radioactive materials ' produced at nuclear.
generating stations or other facilities currently or previously operated by Ontario Hydro". It is therefore essential that you are able to demonstrate that the ash we receive is the ash which arose from the radioactive matsrtals generated at Ontario Hydro facilities, if this can be demonstrated,-
i and if the ash meets our Waste Acceptance Criteria (attached), then we can accept if for storage at Radioactive Waste operations $lte #2.
if the ash is sent to us we would prefer to receive it in a 825 box, although new carbon steel drums are an acceptable attemative if quantitles do not warrant the use of B25's.
I H. Morrison Manager Waste Management Services Dept.
KMombourquette/pb Nuclear Waste & Environment Services Div.
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goa3 WASTE ACCEPTANCE CRITERIA REV 5
y WASTE ACCEPTANCE CRITERIA WAC-01 BNPD RADIOACTIVE WASTE OPERATIONS SITE 2 V
ABSTRACT OF REVISION:
New format.
Definitions expanded.
Ganeral information expanded.
Added waste classification and packaging criteria.
Reorganized specific criteria into 'Normar and 'Non-standard" wastes.
Reorganized criteria for standard low and intermediate level waste.
Revised packaging criteria for contaminated oil.
Revised by:
VerHied by-Authorized by:
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G. Cleland K Momboorquette H. Morrison Date:
Date:
Date:
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WASTE ACCEPTANCE CRITERIA REV. 5 9.4.5 Tritium Control Packaging must be selected to control tritium during handling (loading, transport and unloading).
9.4.6 Free-Standing Liquid Waste packages / containers shall not contain any free standing water. (e.g.,
interstitial water in dewatered IX resin is acceptable, flooded resin is not acceptable).
Re-usable waste packages must be free of loose contamination and liquids inside and outside.
9.5 Waste Trackina Waste tracking is an important element of lifecycle management of low and intermediate level waste. Shippers must have the capability to track waste from point of origin (station pid-up point) until placement into shipping packages. If bar coding technology is used, it should be compatible with Intermec technology.
9.6 Transoortation Additional restrictions based on transport regulations may apply to the packaging and shipment of waste from the generator's site to the RWOS.
The Transport Co ordinator at each facility should be consulted to assist the waste generator.
9.7 Documentation All waste shipments received at the RWOS must be accompanied by complete documentation. For all shipments, this inciudes, as a minimum an approved Radioactive Materials Shipment Advice form (OH form # 820459 -
external to BNPD site) or Transfer Permit (Conditional or Standing, from within BNPD site). Additional documentation is listed, where required, under the specific requirements for each waste type.
10.0 ACCEPTANCE OF NORMAL. WASTES 10.1 Procedure Normal procedure is to apply these acceptance criteria and make arrangements through WMSD Planning, v
06/27/97,00:08 Q
WASTE ACCEPTANCE CRITERIA REV 5
10.2 Criteria for Exempt Waste Reserved for future criteria.
10.3 Criteria for low Level Waste 10.3.1 LLW Incinerable incinerable wastes shall have a maximum dose rate of 60 mrern/h on contact with the unshielded bag.
Incinerable waste shall be packaged in clear radioactive waste bags unless otherwise specified. The bags shall be closed with tape. Bags with holes, or that contain sharp objects, shall be double bagged. Bagged waste must weigh less than 40 lbs.
Bags shall not contain visible liquids (oils, water, paint).
Bags shall have a maximum tritium level of 100 MPCa.
Dry inc.inerable wastes may be packaged in cardboard boxes with overall dimensions of less than 2 fi x 2 ft x 2 ft (60 cm x 60 cm x 60 cm). The box must weigh less than 40 lbs. and be labelled as to contents.
Large incinerable items (such as scaffolding planks and plywood) must be cut into pieces with a maximum dimension of 2 ft (60 cm) and bagged.
10.3.2 LLW Compactible Compactible wastes shall have a maximum dose rate of 200 mrem /h on contact with the unshielded bag.
Compactible waste shall be packaged in clear radioactive waste bags unless otherwise specified. The bags shall be closed with tape. Bags with holes, or that contain sharp objects, shall be double bagged. Bagged waste must weigh less than 40 lbs.
Bags shall not contain visible liquids (oils, water, paint).
Bags shall have a maximum tritium level of 100 MPCa.
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10.3.3 LLW Non-Processible Low level non processible waste is all low level waste that is neither incinerable nor comptaible.
Low level non processible waste shall have a maximum contact dose rate of 1 R/h.
Low level non-processible waste shall be packaged in clear radioactive waste bags unless otherwise specified. The bags shall be closed with tape.
Bags with holes, or that contain sharp objects, shall be double begged Bagged waste must weigh less than 40 lbs.
Bags shall not contain visible liquids (oils, water, paint).
Bags shall have a maximum tritium level of 100 MPCa.
Large non-processible items may be packaged in WMSD supplied non-processible waste containers (' blue bins"). In such cases, the waste and/or container shall be sealed to prevent the spread of contamination. The exterior of the container shall be free of any loose contamination. The rated weight capacity cf the ' blue bin" shall not be exceeded.
HEPA filters may be packaged in suitable cardboard boxes (such as the ones which contained the replacement filters). Where the potential for loose contamination exists, the filter and/or box shall be sealed in a suitable plast.'0 bag.
Large non-processible items may be packaged in ' blue bins", provided that
- the unshielded dose rate on the container does not exceed 1 rem /h on contact with any surface of the container. " Blue bins" containing C-14, elemental tritium or Fe-55 wastes shall be colour coded with a tape stripe accoroing to 9.4.1.
Some nonessible wastes, such as solidified liquids and wastes with a high potential for loose contamination, may be packaged in 205 L non-processible radioactive waste drums (' black drums" such as OH MatCode # 223A4625 or 223A1790). The drums shall be sealed and the contents of the drum shall be clearly marked on the side of the drum. Where six or more drums are to be shipped, the drums shall be shipped on WMSD supplied drum racks (' bale racks"- OH MatCode # 599A6700), six per rack.
If scrap (previously used) drums are used, they must be in good condition
- (e.g., leak tight, rust free), in addition, any old markings which are not appropriate for the new waste form shall be completely covered over with opaque paint. (e.g., do not leave words like ' Waste Oil" stencilled on a drum which actually contains metal shavings.)
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The use of dnsns for routine non-processible waste is severely discouraged due to inefficient storage. (A rack of six drums -
with a capacity of 1.2 m' of waste occupies 3.4 m' of storage space).
10.3.6 Iron 55 Contaminated Iron 55 (Fe 55) contamination is 'present'to varying degrees during Bruce A fuel channel maintenance. When Fe-55 is identified by Bruce A as being a hazard in low level waste, the following is required:
' Contact the Operations Co ordinator (3201) PRIOR to transferring the Fe-55 contaminated waste.
Unless agreed to otherwise by the Operations Co-ordinator, Fe-55 waste is to be transferred to RWOb on weekdays during dayworker hours.
Incinerable Fe-55 waste must be double bagged, marked with brown tape (T1,1) and shipped in 1 cubic meter containers clearly marked "FE 55 INCINERABLE WASTE",
Fe-55 contaminated compactible waste is treated as non-processible.
Nonpocessible Fe-55 waste must be packaged as follows:
caulk alljoints of a ' blue bin"with silicone caulking compound line the bin with plastic sheeting and cover and seal the plastic with duct tape cover the blue bin by strapping on a 1/2 inch thick plywood sheet mark the bin "FE 55 NON-PROCESSIBLE WASTE" 10.3.7 Reject Drums All reject drums shall be free of liquids and sludge inside and free of loose contamination on the outside.
The maximum contact dose rate on any surface of the drum shall be less than 1 rem /h. If the dose rate exceeds this limit, the drum must be decontaminated prior to shipment to the RWOS.
Reject drums which may contain loose contamination on the inside, and cannot be sealed (for example due to deformation of the drum) shall be sealed in a suitable plastic bag.
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WASTE ACCEPTANCE CRITERIA REV 6
10.3.8 HT Contaminated TRF Waste v
Metallic waste with high levels of surface elemental tritium shall be packaged as follows:
a) double bag components in polyethylene, minimise the void volume, b) heat seal in a metallic foil bag, and place into a steel drum, c) backfill void space with moist vermiculite, or other absorbent, d) contain in a 1 cm thick sealed high density polyethylene salvage overpack (Enpac) labelled "TRF ELEMENTAL TRITIUM WASTE.
Tritiated oils, limited to ? 000 Ci per package, shall be packaged as follows:
a) absorbed on sawdust (or other oil absorbent),
b) place in a steel drum, c) contain in a 1 cm thick, sealed high densi*y polyethylene salvage overpack(Enpac)
The HDPE salvage overpack might have to be further contained in a qualified container for transportation purposes, 10.4 Criteria for Intermediate Level Waste All waste with greater than i rem /h gamma contact shall be considered Intermediate Level Waste. All filters and IX columns used for cleanup of systems with long half life radionuclides or with the potential for alpha and/or high activity particles, are considered to be intermediate level waste. For example, fuel bay filters are considered to be intermediate level waste at low dose rates, i
10.4.1 Small Filters and IX Columns f
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- All waste containers for Type 3 wastes (such as filter drip cans, disposable filter vessels and shutoff rod liners) shall be designed for storage in an IC-18 or equivalent storage structure. Except for 3 m' IX resin liners (see Section 10.4.3) and similar packages, the maximum OD for the waste containers is 20 inches (51 cm). Oversized wastes with OD up to 22 inches (56 cm) can be accepted as non-standard waste for tilehole storage (11.0).
All waste packages must be designed for bottom unloading into IC-18's in a manner that controls the descent of the waste, contains loose contamination, and limits dose rates to less than 300 mremlh during storage operations.
IX columns must be sealed. Small filters must be contained in a sealed container or a competent drip can.
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_10.4.2 Core CsTponents All waste packages must be designed for bottom un_ loading ir to IC-18's in a manner that controls the descent of the waste, contains looso contamination, and limits dose rates to less than'300 mromM during storage operations.
Full length core components can be stored in specially ada'>ted IC-18's.
Such operations generally require long Isad times ard spe ciel equipment.
Please contact the WMSD Waste Operations Technical Supt. during the -
early planning stages for the job for detailed requirements on a case by. case basis.
10.4.3 Bulk lon Exchange Rosin Bulk lon exchange (IX) resins must be packaged in containers approved by WMSD. The standard containers for resins are "4 m' Low Level Rosin Container"(OH MatCode # 599AS735 for storage of resins with a contact dose rate af less than 1 remM in Low Level Storage Buildings) and "3 m' 4
Resin Liner" (OH MatCode # 59986406 for storage of resins in the IC-18's).
Bulk resin containers are normally obtained by contacting the WMSD j
Operations Coerdinator.
All penetrations on the resin containers must be sealed with suitable threaded metal plugs.
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The resin containers must be de-watered to less than 1% free standing water prior to shipment to the RWOS.
i The 3 m* resin liner must be loaded into the transportation flask using approved procedures to ensure that the lifting lug remains accessible.
The 3 m* resin liner must be free of loose ::ontamination and water on the outside.
10.4.4 Large Heat Exchangers for in-Grour.d Container IC-HX Storage j
b These criteria apply to large heat exchangers only. Contact WMSD to i
discuss the suitability and preparation of individual heat exchangers for -
storage as inground heat exchangers (IC-HX) as follows:
All heat exchangers shall be dry on both the tube side and shell side, and free of loose contamination on the exterior of the shell.
i All heat exchangers shall have a minimum wall thickness of 3/8"(1 cm). All j
penetrations in the outer shell shall be sealed with welded caps with a minimum thickness of 3/8".
NWESD WAC-01 Page 15 of 21 WASTE ACCEPTANCE CRITERIA REV 6
All heat exchangers shall be coated with a suitable corrosion protection V
coating (such as coal tar epoxy, or equivalent approved by the WMSD Operations Co ordinator).
All heat exchangers shall be vacuum leak tested to 4 psig ( 42 kPag) and holding the vacuum for a minimum W 30 m'riutes, as indicated on a vacuum gauge connected to both the shell side and tube side. The leak test is to be done before the coating is applied. All leaks must be located and repaired using welded caps. After a successful vaaJum test, the heat exchangers are to be backfilled with nitrogen.
All heat exchangers shall have the weight and maximum dose rate stencilled on the side.
All heat exchangers shall have suitably designed lifting lugs to allow lifting and rotation from horizontal to vertical.
A quality %pection check sheet must accompany the shipment describing weld quality control, leak testing and corrosion protection.
All heat exchangws destined for IC-HX storage shall be provided with a leak l
test port consisting of a 3/4" NPS pipe which penetrates both the shell and j
tube side, and extends approximately 4 ft (1.2 m) above the top of the heat exchanger when raised to a vertical orientation. The leak test line shall be provided with a ball valve at the upper end. The ball valve shall be capped with a suitable pipe plug. A similar vent line, open at both the top and bottom (no valve) is to be attached to the exterior of the heat exchanger shell and protrude to the same height as the leak test line. The vent line shall be fitted
- with a U berid at the upper end in prevent the ingress of precipitation.
An inspection / test report (OH form 241547) must be completed and forwarded to WMSD Technical.
10.4.5 Miscellaneous Bulky items The existing storage facility at RWOS are designed for specific waste form geometries. Miscellaneous bulky items are treated as non-standard wastes (11.0).
10.4.6 High Activity particles Waste containing known high activity particles are considered non-standard (11.0).
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06/27097 84 :(1)
O WASTE ACCEPTANCE CRITERIA
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10.5 Other Hazardous Waste 10.S.1 Scintillation Fluids Liquid scintillation fluid vials must'be packaged in a manner suitable for incineration. The currently recommended method is to put the vials in a 20 L (S gal) white polyethylene pail (OH MatCode # 22320704). The lid of the pail must be sealed in place with duct tape. The pali must be clearly marked as containing liquid scintillation vials, such as with OH MatCode # 822C4276 radioactive liquid scintillation fluid labels. Waxed cardboard boxes may also be used, subject to the size and weight restrictions given in T1.6.
10.S.2
' Animal Carcasses Biological wastes (such as animal carcasses from OH Technologies) shall be sealed in air tight incinerable containers, such as 20 L (5 gal) polyethylene pails (OH MatCode # 22320704). The pail fids shall be sealed with duct tape and the containers shall be clearly marked as containing biological wastes for immediate incineration.
11.0 ACCEPTANCE OF NON-STANDARD WASTES 11.1 Procedure Radioactive waste types not specifically mentioned in this document shall only be shipped to the RWOS with prior approval from the WMSD Operations Co ordinator or authorised designate. This is accomplished by completing OH Form 821032 ' Notification of Non-Routine Radioactive Waste Shipment". An approved copy of the form must accompany the shipment.
11.2 Criteria for Liould With prior approval and prior notification, absorbed liquids that are suitably packaged, may be accepted for immediate incineration. Other criteria for LLW Incinerable (10.3) may also apply.
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WASTE ACCEPTANCE CRITERIA REV 11,3 Criteria for interim Storaos of Oil Radioactive waste oil is accepted for interim storage only. The l
generator is responsible for the full costs once a suitable -
processing technique is implemented..
All shipments of radioadive oils requke the PRIOR approval of the WMSD j
Operations Co ordinator. The shipper.must send a copy of the radiological
- and chemical analyses to the RWOS Operations Co-ordinator prior to the -
shipment. The analyses must confirm that the oil meets the criteria listed in RO.2.
The oil shall meet the following chemical and radiological criteria:
no decantible water total PCB
< 50 ppm total Chlorine
< 20000 ppm total Lead
< 300 ppm (see also RO.4) total Cadmium
< 0.5 ppm Flash point
> 61' C Tritium < 9.59 x 10 CL/L d
Gross beta / gamma
< 3.14 x 10 Ci/L The oil must also be non49losive, non-flammable, non-corrosive and s,
non-toxic. It may, however, be combustible. Oil which falls to meet one or more of the above criteria is NOT acceptable for storage.
Drums of oil with a lead concentration greater than 5 ppm must be labelled with:
LEACHATE TOXIC - LEAD Oil must be contained in new, leak free drums with a ' bung" type closure (such as OH MatCode # 223A3190). The drums shall be stencilled with:
RADIOACTIVE WASTE OlL Each drum shall also be stencilled with a serial nurnber corresponding to the radiological and chemical analysis sample numbers used for RO.3.
Where six or more drums of oil are to be shipped, the drums shall be shipped on drum racks (" bale racks"- OH MatCode # 599A6700), six per rack. Empty racks are available from the Operations Co-ordinator.
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S 024 WASTE ACCEPTANCE CRITERIA REV 5
i 11.4 Criteria for Solidified Liouids Liquids wastes must be solidified by a method approved by WMSD.
Requests for approval of a new (or non standard) solidification method must I
be made to the WMSD Operatioris Co ordinator in writing PRIOR to the performing of the solidification operation.
All shipments of solidified liquids mu# h weTipanied by an approved "Sclidified Liquid Waste Record" (OH form #820939), along with detailed chemical and radiological analyses of the solidified liquid. The form must be approved by the WMSD Operations Co ordinator PRIOR to shipment of the solidified liquid waste to the RWOS.
The liquids shall be completely solidified, with no free standing liquid.
l The solidified liquid must be in a container approved by WMSD. Requests for approval of a new (or non-standard) container must be made to the WMSD Operations Co ordinator in writing PRIOR to the performing of the solidification operation. All containers shall be provided by the waste generator.
11.5 Criteria for Interim Storaos of Contaminated Toolino ISO marine freight containers (cargo containers) are used for interim storage of slightly contaminated tooling, not for storage of wastes as follows:
Standard 20 ft ISO marine freight containers are normally used, however other similar containers can be used with PRIOR approval by WMSD. The containers are stored outdoors, so temperature sensitive equipment should not be included in such containers.
The shipper provides the container, loads it, inventories it, locks it and arranges for it to be shipped to the RWOS.
All loads in the container shall be suitably constrained against shifting under transpost or lifting conditions.
The maximum external radiation field for storage is 2.5 mrem /h @ 1 m. All materials inside the container shall be decontaminated to a level of less than 5000 cpm of ioose contaminatiort The shipper must include a completed " Storage of Cargo Containers" form (BNPD form # BF-743) showing the load distribution along with a detailed inventory listing with the shipping documents.
1
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.08/27/s7 14:07 O
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19 of 21 WASTE ACCEPTANCE CRITERIA REV 5-WMSD will periodically require the owners of contaminated tooling to justify v
its continued interim storage. A charge will be applied at that time.
11.6 Criteria for Fuel Fles Contamination Wastes contaminated with fuel liwas are acceptable only with prior approval by WMSD.
12.0 EXCLUSIONS (UNACCEPTABLE WASTE)
Wastes shall not contain any recognisable fuel fragments.
12.1 Waste Oriain Wastes are unacceptable if procasd in a location other than in a nuclear generating station and other facilit.y marrently or previously operated by Ontario Hydro.
12.2 Waste Form 12.2.1 Liquids Liquid wastes other than scintillation fluids (10.5.1), contaminated oil (11.3) and absorbed liquids (11.2) are unacceptable.
Aqueous liquid wastes are not accepted for storage at the RWOS. All aqueous liquids must be solidified at the generating site by an approved method prior to shipment to the RWOS, Waste packages / containers shall not contain any f ee standing water. (e.g.,
interstitial water in dewatered IX resin is acceptable, flooded resin is not acceptable).
12.2.2 Gases Compressed gases are unacceptable.
Gaseous waste is unacceptable.
12.3 Radioloaical Content 12.3.1 Recognizable Used Fuel Fragments
/
"E.01 H 8 'I G
ton
.-e WASTE ACCEPTANCE CRITERLA REV 12.4 Non-Radioloalcal Content Reserved forfuture criteria.
13.0 NON-COMPLIANT WASTES
+
Whenever waste is received at RWOS that unexpectedly does not meet the WAC, then, in order of preference:-
i a) the waste will be held in its existing form or pedage awaiting l
special tooling and / or handling procedures, or b) the waste will be held and the shipper will be requested to supply 1
advisor (s) who are familiar with the waste form and its package, or 4
c) the waste will be returned to the shipper to be made into an 1
acceptable form and/or packaged acceptably.
Surcharges may be applied in these situations as per service level agreements or negotiations between WMSD and the shipper.
L 14.0 WASTE AUDITS WMSD performs waste audits on a regular basis. When access is required -
[
to the stations, arrangements will be made in advance with approval of the station involved. Some audits will be conducted at RWOS on incoming j-waste. All audits will be conducted according to approved WMSD procedure.
l All norH:Onformances and findings will be reported to the shipper.
15.0 REFERENCES
BNPD Radioactive Waste Operations Site 2 Operating Licence AECB-WFOL-314 and current reference documents i
BNPD Radioactive Waste Operations Site 2 Safety Report 4
Ontario Hydro Radiation Protection Regulations, Part 1 Radioactive Weste Operations: Operating Policies & Principles, 01911.1.
NWESD Radiation Protecbon Procedures,09071 i
j Waste Acceptance at BNPD Radioactive Waste Operations Site, NWESD Policy WMSD 1.57 ~sevision 0, August 1996
[
Waste Accepbnce at BNPD Radioactive Waste Operations Site, NWESD Procedure WMSP-03460-1, Reviskm 0,~ August 1996 i
.N N
V 2027 o
~
NWESD WAC-01 Page 21 ef 21 WASTE ACCEPTANCE CRITERIA REV 5
Packaging of Low & Intermediate level Waste Catalogue of WMSD
'v Supplied Packages, NWESD WAC 02, Rev.1, February 1997 9
+
h -
(6v27/07 04:00 y
- ^ - ~ ~
M2a
'^
l NWESD WAC41 Pcg3 A1 of1 WASTE ACCEPTANCE CRITERIA REV 4
$f.EEIEEL8 v.
LOW LEVEL WASTE
~~
INCINERABLE COf#ACTIBLE NON PROCES$1BLE Maximum Dose Rate:
Maximum Does Rate:
Maximum Dose Rate:
60 mrom/hr contad 200 mromhr conted i rem /hr at 30 an Paper & Paper Towel Comfo Respirator Filters Hoa Gauge MetalI.e. l.tw:ams i
Tyvek Coveralls, Booties, Ught Gauge Metals ang iron, plate metal, etc.
I and Hoods Welding Rods MetalComponents i.e. pipe Plastic Booties MetalCans flanges, valves, etc.
Plastic Bottles insulation Concrete and Cemet'.W l
1 Wood (2Wx2')
Ventilation Filters Floorsweepings,r evs.
j i
Cardboard Air Hoses Stay Dry, etc.
l l
Mop Heads. dry and damp Mop Buckets and Presses Tools j
smearsfilter Paper Elodric Cable (<1/4*)
Eledric Cable yIv' j
Cloths t.athe Tumings Wire Cabir atr &,3 Rope and Nylon slings Metal Filings Floor Buffing Pads Glass 1
Safety Shoes Plastic Suits (Mark til/IV) j Browns Rubbers Cotton Gloves Vereft Hoods J
Rubber Gloves
.1 NOTES:
(1) All weste is to be begged / wrapped sud) that the size and weight do not exceed the followkg:
Maxirnum Weight:
25 lbs or 11.5 kg Maximum Stre:
2'x2W or 60cm x 60cm (2) No liquids are to be present,i.e. oils, water, paint, etc. Special precautions should be taken to avoid sending paint cans and similar type containers which are partially full.
(3) For Cid, Fe55, and TRF waste, the following should be performed.
identify the individual bags by using different colour tape C14 Blue tape Fe55 Brown tape RF Red tape segregate the weste into two categories. Incinerable and non processible.
All compadible waste to be treated as non-processible.
L',
[(
p* Cthqk yyy y-UNITED STATES NUCLEAR REGULATORY COMMISSION
)
e t
- t WASHINGTON, D.C. 300NWo01 v....
Mr. Michael H. Mobley, Director Division of Radiological Health Department of Environment and Conservation L & C Annex, 3rd Floor 401 Church Street Nashville, TN 37243-1532
SUBJECT:
IMPORT OF LOW-LEVEL RADI0 ACTIVE WASTE FROM CANADA
Dear Mr. Mobley:
Enclosed is a July 23, 1997 letter to the NRC from Jimmy R. Selph, Diversified Scientific Services, Inc. (DSSI), requesting a specific license to import radioactive waste from Canada. DSSI holds Tennessee Radioactive License No.
R-73014-K98.
The wastes to be imported are from Ontario Hydro Technologies and are typically liquid, used oil and/or other combustible materials containing primarily tritium and carbon-14, mixed fission product radionuclides and other contaminants. The waste is generated during the normal course of business by the nuclear power utility. Only waste authorized by DSSI's Resource Conservation and Recovery Act Permit, their Radioactive Materials License and U.S. Used Oil Regulations (40 CFR 279) will be imported. The anticipated i
maximum quantity of waste requested for import is 5,000,000 kilograms per year. We feel that the initial license for import of the subject material should not exceed three years.
The waste will be processed at DSSI's Industrial Boiler Facility wherein the imported waste will be burned. The resultant residue, in the form of solids, will be returned to an authorized facility in Canada for final disposition.
Until recent changes in NRC's 10 CFP,110 export / import regulations, low-level radioactive waste could be imported into the US by persons licensed to receive and possess radioactive materials under NRC general license authority or a specific license issued by an Agreement State.
Specific import license requirements were added to 10 CFR 110 in August 1995 to conform US radioactive waste practices with the International-Atomic Energy Agency (IAEA) Code of Practice on the International Transboundary Movement of Radioactive Waste.
d%
Mr. M. Mobley NRC requests confirmation that DSSI is the holder of an active license issued by the State of Tennessee which authorizes DSSI to receive the radioactive waste in the context described in its July 23 letter for processing and that you do not object to the proposed imports for the purpose described.
Your assistance in providing this information is appreciated.
If you have any questions, please call Betty Wright or me at (301)415-2344.
Sincerely, Ronald D. Hauber. Director Division of Non-Proliferation Fxports and Multilateral Relations Office of International Programs
Enclosure:
Letter dated 07/23/97 from DSSI (IWOO4) i t
1 i
a
- i:
CFORM7 U.s Nuclear Regulatory Commisa60n AP*movEgcga Eccv 10 CO 110 APPLICATION FOR LICENSE TO EXPORT
!OUS."M.","M'A Of?M E*! ** L"'O,*tWM,"
NUCLEAR MATERIAL AND EQUIPMENT
- '=#,'.0% 7,L'%7,% WEE *'*L'J".*JL'*fAU'7."
- FJen*=OOOJ.LareW,'C'J#rn.'.
e (See Instructions on Reverse)
- 1. APPLCANT's a DATE OF APPLC# TION
- b. APPLCANT1 REFERENCE
- 2. N1C "e'DOOYEt NUMD9R -
b,1,1CE.ed&E NuMaER <
USE --'
7/23/97 AD0234 97 USE- +
[ ((gGQg
- Wg 3 APPLICANT's NAME AND ADDRESS Ris '
RIS* '
sNAME 4 $UPPLIER'S NAME AND ADDRESS Diversified Scientific Services, Inc.
(Complete sr eees ta not suppler of the materian
- b. STREET ADDRESS (Facility sde) a NAME 657 Gallaher Road Same as Number 3
- c. CITY d STATE
- e. ZIP CODE
- b. STREET ADDRESS Kingston Tennessee 37763
- f. TELEPHONE NUMBER (Area Code Number Extensson)
- c. CITY d STATE
- e. ZIP CODE 423 376 0084 5 F 5i $NA4NT
- 4. FINAL $HiPMENT 7, APPLCANT'S CONTRACTUAL 4 PROPOSED LCENSE 9 U $ DEPARIMENT OF ENERDY SCHEDULED SCHEDULED DELNERY DATE EXPlRATION DATE CONTRACT NO (N Known) 8/97 On Going before August 31,1997 Maximum iengtn a86 owed N/A 10 ULTIMATE FOREIGN CONslGNEE R64
- 11. ULTaAATE END U$E
[ USE C000 <
aNAME (include pieni of facilg name)
Ontario Hydro Technologies Retum solid material from processing liquids from b STREET ADDRESS (Factity sde)
Ontario H dro to Pickering Nuclear Station for storage,
/
Pickering Nuclear Station
- c. CITY d COUNTRY Pickering Ontario Canada 11s DATE REQUIREo August 31,1997 12 INTERMEDLATE FOREGN CONSGNEE RE-
- 13. INTERMEDaTE END USE l USE CODE aNAME N/A N/A b STREET ADDRESS (Facildy sde) c, CITY d COUNTRY 13e DATE REQUIRED 14 INTERMEDaTE FORECN CONSGNEE Rl8 :
- 16. INTERMEQaTE END USE l USE CODE >
4 a NAME N/A N/A b STREET ADOREss(Facitny sde)
- c. CITY
- d. COUNTRY 15e. DATE REQUIRED 16 COM
- 17. DESCRIPTION
- 18. 8AAX ELEMENT 19 W X.
- 20. EX ISOTOPE 21.
CODE (include chemical and phys. cal form of nuclear matenal; gin WECHT WT. %
WECHT UNIT dollar value of nuclear equipment and components) c DSSl's combustion process completely destroys 0
Ly."
the original waste liquids The DSSI air pollution N/A N/A N/A ~4; 5
Control system Captures particulate matter and g
'.y/A neutralizes the acid forming gasses generated n
during Combustion of the waste. The salts from U
i neutralization and boiler ash associated with this 1
waste will be the material retumed to the 2
O generator. The radionuclides returned will be primarily mixed fission products with an annual activity of less ten (10) curies. The waste does 5
p~ g not contain Source Material or Special Nuclear Material.
22 COUNTRY OF ORIGIN -
23 COUNTRY OF ORIGIN sNM
- 24. COUNTRIES WHICH ATTACH SOURCE MATERIAL M
WHERE ENRICHED OR PRODUCED SAFEoVARDS (If known)
N/A N/A N/A 25 ADDIT 60NAL INFORMATCN ON CONDIGNEEs. END USES, AND PRODUCT DESCRIPTIONN (Use seperale sheet W necessary)
See DSSI Letter AD0234-97 dated July 23,1997 to the U.S. NRC regarding an application for a specific license to import / export radioactive waste.
26 The app 4 cant certir.es that tNs application is prepared in conformay with Title 10, Code of Federal Regulations, and that all information in tNs applicaten h correct to the best of his/her knowtedge M,
- 27. AUTHORIZED OFFICIAL a slGNATURE
- b. TITLE DSSI Radiation Safety Officer f4RC FORM ? (3 s4)
/ /
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