ML20217A265
| ML20217A265 | |
| Person / Time | |
|---|---|
| Issue date: | 10/25/1990 |
| From: | Tokar M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jensen C DIVERSIFIED TECHNOLOGIES |
| Shared Package | |
| ML20217A151 | List: |
| References | |
| REF-WM-105 NUDOCS 9011200258 | |
| Download: ML20217A265 (2) | |
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'7 UNITsD sTATss
.f NUCLEAR REGULATORY COMMISSION
.g wasHmoTow, o. c.:oses OCT t 51990 Mr. Charles E. Jensen Vice President, Operations Diversified Technologies 103 Dikon Drive Chestertown, MD 21620
Dear Mr. Jenser:
This is in response.to your letters of September 10, 1990, and October l 1990.
g Your Se tomber 10, 1990 letter requested clarification as to whether NRC s Technic 1 Evaluation Report (for Topical Report DNS-RSS-200NP-A, "The Dow Waste L
Solidification Process for Low-Level Radioactive Waste" - Docket Number WM-82) i L
places any specific limit on NS-1 wastes other than a waste loading ratio up to
.1.5/1.0, or 60 weight percent. Your letter of October 1,1990, also addresses L
-this issue and provides information obtained from archived Dow documents and conversations with current or former Dow employees..This information was provided to support your contention that solids content was never identified as 1
a controlling or limiting factor that would affect successful solidification and stabilization of the NS-1 solution, I
The NS-1 decontamination solutions-that were addressed in the Dow qualification program were reported to contain 6 to 40 percent solids.
It is our understanding
- that " solids" here refers to total dissolved solids.
It is also our understanding i
that'the limitation on. total dissolved solids resulted from excessive viscosity of-the spent NS-1 solution.- This occurred if the solution was-evaporated to less l
than one seventh-or one eighth of=its original volume. The excessive viscosity made the decontamination waste dift'icult to transfer from one tank to another.
Thus, since you seek to solidify spent NS-1 solutions that are even more j
lan to use a different process from that covered concentrated, we wonder if you p{TR).
in the approved topical report 1
~ Another consideration is that the actual spent decontamination waste-solutions may contain radioactive wastes that were not in the solidified simulated waste samples that were tested.in the Dow qualification program. That is a possibility that:is inherent in approving the TR. The Dresden NS-1 decontamination wastes, however, contain even more solids than the simulated waste samples that 4
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were tested. This may increase the possibility of reaction between the-emulsified particles of waste and the vinyl-ester-styrene matrix. Therefore, the total solids content should not= exceed that in the waste samples that were tesced under the Dow qualification program and documented in the TR.-
We acknowledge'that the level of total-solids is not listed as a significant variableinSection3.0(ProcessControlFactors)oftheTR;however, paragraph 6.1.2 of the TER (page 18) states that the waste forms produced shall
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be limited to those made from the reactants specifically identified in.the TR l
as those used to prepare the test' specimens on which the data were obtained.
Taking into account the above considerations, we suggest the following l
alternatives. One, under the approved TR, is to dilute the spent NS-1 l
decontamination waste solution to meet the maximum total dissolved solids that fy12
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2 were reported in the TR, i.e., 40 weight percent. A second option is to perfom qualification tests on simulated samples of this waste and submit these test results to NRC for approval in a revision to the TR. A third option consists of solidifying the waste under the provisions of a surveillance test i
. program.
If you elect this option, however, the details of the program would have to be developed.
l I trust this answers your questions.
If you have any.further questions on this r
matter,pleasecallmeon.(301)492-0590 or Everett Wick on (301)492-0546.
l Sincerely,
/
S Michael Tokar, Section Leader Engineerin Section Technical ranch 1
Division of Low-Level Waste Management
'I and Decommissioning, IMSS r
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