ML20235Y472

Advises That DOE Re Site Cement Low Level Waste Form Qualification Provides Resolution of NRC Comments. Summary of 890124 Meeting W/Doe in Rockville,Md Encl

ML20235Y472
Person / Time
Issue date:	03/09/1989
From:	Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Bixby W ENERGY, DEPT. OF
References
REF-PROJ-M-32 NUDOCS 8903140182
Download: ML20235Y472 (15)

Text

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MAR 9 ;989 Dr. W. W. Bixby, Director 3

West Valley Project Office J

-Idaho Operation Office P.O. Box 191 West Valley, NY 14171

Dear Dr. Bixby:

1 Since transmittirig the NRC staff's Technical Evaluation Report (TER) to you on November 29, 1988, we received and completed our review of DOE's November 29; Waste Form Qualification.. West Valley Demonstration Project Cement Low-Level 1989, subr.ittal; subject:

In addition, our respective staffs with consultants met on January 24, 1989, in NRC's Rockville, MD office to discuss the regulatory review items that remained and that had been identified in our

.TER. As noted in.the enclosed summary for the January 24, 1989 meeting, the information provided in DOE's November 29, 1988 submittal and as modified by the agreements reached at the January 24 meeting, has resulted in the acceptable resolution of all NRC review comments on cement solidification of the decontaminated supernatant waste.

NRC considers its consulting role in reviewing the cement solidification of the decontaminated supernatant waste to be completed with the full resolution of previously identified concerns. We look forward to receiving the results of the scheduled short-terin/and long-term test programs and anticipate they will continue to confirm your successful waste cement solidification efforts that are documented in the Topical Report.

Sincerely, (SIGNED) JOHNT.GREEVES John T. Greeves, Acting Director Low-Level Waste Management and Deconsnissioning, NMSS I

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SUMMARY

OF MEETING WITH DOE /WVNS Or, JANUARY 24, 1989 AT OWFN, ROCKVILLE, MD.

A meeting was held on January 24, 1989, at NRC's Rockville, MD office between the U.S. Department of Energy (DOE) and the U.S. Nuclear Regulatory Comission

'(NRC) staff. and their respective consultants. A list of the meeting par'ticipants is attached as Enclosure 2.

The meeting was arranged in response to a DOE request (E. Maestas) to meet with the NRC staff to discuss DOE's preliminary plans for handling the." sludge wash" from the reprocessing liquid waste.in Tank 80-2. The meeting date selected was convenient to DOE and West Valley personnel because of their presence in~ the Washington, D.C. area following DOE's detailed briefing of the ACNW on January 23. 1989 on West Valley activities. While completing the arrangements for the January 24 meeting, the NRC staff had. indicated to DOE that this meeting would also be an appropriate time to discuss the staff's review comments on the November 29, 1988 submittal from DOE (W. Bixby) to NRC (M. Knapp) regarding the remaining review items on cement solidification of the decontaminated supernatant waste.

To begin the discussions at the January 24, 1989 meeting, the NRC staff provided a handout-(Enclosure 3) containing the staff's and consultants review comments on DOE's November 29, 1988 submittal. Enclosure.3 identifies what I

review items related to cement solidification of the decontaminated 1

supernatant waste remained after the staff's evaluetion of the November 29, i

1988 submittal and also identifies the items that had been acceptably resolved.

The major items of discussion at the January 24, 1989 meeting on the November 29 submittal included the following:

(1) No additional effort will be made by DOE to expand the discussion in the Topical Report related to the significance of the organic constituents because the final draft of the Topical Report has been forwarded to the publisher.

. (2) An explanation by DOE was provided for the new column labeled % RSD that was added to Table 1-2 (Page 6) of the Topical Report. The values of percent relative standard deviation (% RSD) were established by dividing the error band by the actual reading for the specific radiochemical constituent.

(3) DOE agreed to accept NRC's suggestions for clarifying the number of preso11dification samples to be taken as indicated in the Process Control i

Plan (PCP), with the exception of the words that have been lined out in item 2 on the first page of Enclosure 3.

(4) There was considerable discussion related to the establishment of the lower compressive strength limit to be used in process control based on the statistical analysis of the presolidification compressive strength

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, test data. Ultimately an agreement was reached between DOE and the NRC that will result in revisions to the PCP and Operational Safety Requirements (OSR) to identify the lower compressive strength limit as 500 psi. As agreed to at an earlier September 20, 1988 meetir.g at West Valley, if the 500 psi limit is approached, DOE will begin analysis to establish the cause of the change in the cement solidification process.

This effort will include analyzing for any change in the constituents of the waste, evaluating the adeouacy of the testing procedures, and examination of the actual solidification process. DOE indicated that on the basis of the limited presolidification data available at this time,-it will continue to identify the limit of 186 psi in its Technical Requirements. The Technical Requirement limit of 186 psi is an internal control established by DOE independent of past review comments by NRC.

DOE expressed a desire to reexamine both the 500 psi and 186 psi limits after additional data becomes available in future solidification campaigns. Notification of the NRC would only be necessary if a limit lower than the 500 psi would be proposed by DOE.

(5) Since the November 29, 1989 submittal, DOE had completed testing all three cure specimens following the leach testing. The compression strengths from these tests ranged from 500 to 800 psi with an average strength of 654 psi.

Based on the results of the above discussions between the NRC and DOE, all review items on the cement solidification of the decontaminated supernatant waste have been acceptably resolved. As noted in NRC's Technical Evaluation Report of November 29, 1988, the results from the scheduled short-term and long-term testing programs are to be provided by DOE when available for the infomation of the NRC, but these results are considered to be a confirmation of the qualification test results that were provided in the Topical Report, and are not considered remaining review items.

The last topic of discussion at the January 24, 1989 meeting dealt with DOE's plans for handling the sludge wash. The DOE presented to the NRC staff the engineering strategy and schedule for the treatment of high-level waste sludge in Tank 80-2. provides the handouts that were discussed in the meeting. DOE noted that sludge samples collected in 1989 will be used to l

l determine the sludge wash frequency wastes which will determine the radionuclides and chemical composition of the wash water.

From this infomation, recipes will be developed using a cement based matrix for the resulting low-level waste fom.

To the extent possible, the DOE will utilize the qualification documentation prepared for the decontaminated supernatant to supplement the cemented sludge wash waste documentation submittals to the NRC.

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Encicw e3 JK/04 NRC STAFF AND CONSULTANTS REYlEW COMENTS ON NOVEMBER 29, 1988-TRANSMITTAL (W. BIXBY, DOE LETTER WITH ENCLOSURE TO M. KNAPP, NRC)

RELATED TO WVDP CEMENT LOW-LEVEL WASTE FORM QUALIFICATIO

Reference:

Summary of Agreements Reached at September 20, 1988'

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Meet.ing at West Valley ENCLOSURE 1 - Topical Report on Waste Fore Qualification DOE has acceptably responded to the first and third items that were recorNd in the Summary of Agreements (above identified reference) for the Topical Report The second iten reisted to including a discussion on the results and signi/*cance of the supernatant analysis for organic components by Oak Ridge was not adequately addressed in the Topical Report. Although there is a brief mention of the Oak Ridge analysis for and detection of 150 ppe total organic carbon' in the Executive Summary (page IX), this detection and its significance are not discussed in the Topical Report. The point of NRC's comment is to highlight the surprising finding for the benefit of others, that such a very l

small percentage of the waste constituents could have such a large effect on the cement u ste form properties. Additionally, the Topical Report does not mention thu ihe organics were not specifically identified by O'ak Ridge as citrate, tartrate and oxalate.

DOE has provided new information in Table 1-2 (page 6) of the Topical Report in response to NRC's past request for a discussion on the sample analysis error bands and the variation of results with depth. An explanation by DOE is now requested to understand the dennopment and significance of the new column labeled 1 RSD, that was added to Tau e 1-2.

APPENDIX 8 - Process Control Plan There is still a need to clarify the number of presolidification samples to be taken in the sample verification procedures. Although a revision was made in the last paragraph of Section 1 (page 1) of the PCP, there remains an implication that only 2 presolioification samples will be prepared in the last paragraph of Section 3.2 (page 6) and Section 4.4.3.2 (pages 22.-23).

DOE may want to consider the following suggestions for clarifying this ites.

1 1.

After the first paragraph of Section 4.0 (page 20) add "presolidification compressive strength to the list for samples to be analyzed.

2.

Revise Section 4.2.1 (page 20) to read " Representative samples of the decontaminated supernatant, W:: : ; h: p. Leuh = one sample per 2.!!

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o samples are obtained from 5-D-15A1, one when the tank is full and one at half capacity, and one sample is obtained from 5-D-15A2 when it is full, after the tanks have been sufficiently mixed to ensure a homogeneous mixture."

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In Section 4.4.3.4 (page 23) at the end of the first line, change to "---

samples used for three 2-inch cube specimens are representative of the homogeneous waste samples obtained -- ".

ENCLOSURE 2 - Statistical Analysis of Preso11dification Compressive Strength Test Data The NRC staff and its consultants have technical ccncerns with the wide scatter of data and low values of compressive strength that are listed on Table 1 of Enclosure 2.

Some of the reported strengths are significantly lower than values reported from the qualification testing program and accordingly, result in an uncomfortable, lower strength limit that would be used in process control.

(While completing arrangements with DOE (E. Maestas andWVNS(C.McKay)for meeting at OWFN, NRC (J. Kane))was informed that 2 or 3 the January 24, 1989 additional production runs to solidify the actual decontaminated supernatant have been completed since the development of Table 1 in Enclosure 2.

The results from these latest runs indicated compressive strengths in excess of 700 psi ai.d were not limited by an upper test equipment capacity that was inherent in the development of Table 1 data.

WVDP has separately analyzed this more favorable data c:1 compressive strengths in their trending statistical study and will bring the results of this effort to the January 24, 1989 meeting.

DOE and WVNS representatives indicated a willingness to use this new information to establish the lower compressive strength limit in the PCP).

Sections 4.3.3 (page 22), 5.9.1 and 5.14 (page 27) need to be revised to identify the lower limit that will result from the statistical analysis, instead of the currently listed 60 psi compressive strength. The note following Section 5.14 (page 27) would appear to be the logical PCP location where the actions to be taken should be inserted, if the limits are approached. The actions to be taken by DOE in the event the lower ifmit is approached are recorded in Reference 1 above.

ENCLOSURE 3 - Test Plans for Short Term Testing of Cement Waste form and Long Term Testing of Cement Waste Form In Section 4.3 (page 2) of the WVHS Short Term Testing Program, it is indicated that compressive testing shall be performed on one core following leach testing. This testing of only one core needs to be discussed with DOE since it was the NRC's staff and its consultants understanding that testing would be performed on all three core specimens following leach testing.

(Refer to NRC's Technical Evaluation of November 29, 1988, page 5 and the last ite;m listed in Reference 1 above).

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5 80-2-SLUDGE COMPOSITION

• ELEMENT PNL PNL B/W AESD UNWASHED WASHED WASHED WASHED Al 6.85 6.82 6.74 5.90 B

3.27 3.25 Ba 1.88 1.88 Ca 3.80 3.80 4.76-3.40 Ca 0.85 0.84 Cr 0.23 0.12

<.5 0.08 Cu 0.65 Fe 100.00 100.00 100.00 100.00 Kg 0.06' E

1.84 0.88

<.7 La 0.39 0.39 Li 0.06 0.06.

Mg 0.45 0.45 0.65 0.63 Mn 8.73 8.73 10.78 7.73 Mo 0.02 0.00 Na 50.77 16.48 5.71 Nd 1.19 1.18 N1 1.83 1.83 2.32 1.86 P

1.71 S

4 0.2 Si 3.73 3.71 1.67 Sr 0.26 0.26 0.31 T1 0.23 0.23 En 0.38 0.38 0.62 0.22 Zr.

0.60 0.60 3.06 0.34 U

1.60 1.60 4.97 0.89 Pu 0.08 0.09 NO2 28.41 0.00

<0.5 NO3 31.86 0.00 3.13 F

0.04 0.00 0.96 Cl 0.24 0.03 0.00 PO4 0.87 0.10 1.93 504 7.24 0.00 0.48

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'257.62 153.98 135.98 135.78

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