ML20246F347

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Ack Receipt of Re Comments on Cement Stabilization of Low Level Radwaste Workshop.Increase in Operating Personnel Exposures Due to Revised Procedures for Preparing cement-solidified Wastes Insignificant
ML20246F347
Person / Time
Issue date: 08/17/1989
From: Tokar M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Phillips W
STOCK EQUIPMENT CO.
References
REF-WM-3 NUDOCS 8908300266
Download: ML20246F347 (2)


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16490'Chillicothe. Road Chagin Falls, Ohio 44022-4398

Dear Bill:

Thank you'for your letter of June 6, 1989, which contained some Conclusions and recommendations that stemmed from your attendance at the Workshop on Cement Stabilization of Low-Level Radioactive Waste'and your prior background and involvement in that technical area., Your comments were most interesting and appreciated. Due to~the press of business, I have not been able to respond until now, but I have given the matter some thought, and I should like to share my thoughts with you.

ThoughLthe points made in your letter are, in most cases, quite factual, the assertion that "no waste stabilization media in use today has demonstrated NRC 10CFR61 compliance capability with a high confider.ca factor" is not accurate. We have reviewed and.

approved topical reports dealing with specific formulations using bitunen (Waste Chem), vinyl ester styrene (DOW) and vinyl toluene ,

(GE/Nupac). In approving those formulations, NRC staff concluded I

.that there was reasonable assurance that the formulations would satisfy.the Part 61 technical requirements for long-term structural stability. In arriving at this conclusion, the  !

" confidence factor," though subjective, was adequate.  !

I agree with many of the other statements made in your letter, but I believe that I have a somewhat different perspective on their significance. For instance, while operating personnel exposures'may increase as a result of revised procedures for preparing cement-solidified wastes, I do not anticipate that the increases, if any, will be significant. As for the likelihood that the amount of waste in each waste form will decrease as the numbar of waste forms or containers increase, that may well be true, but I do not regard that possibility with alarm. Any increases in transportation volume would be relatively slight (as  ;

noted in your letter, Class B and Class C wastes comprise only l about 5% of the total volume of low-level waste). Increases in j burial volume would be correspondingly small. Moreover, if there i were to be increases in burial volume, this would actually be -

welcome-from a financial standpoint, given the concerns about ,

potential overcapacity due to overproliferation of sites.

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a-William S.'Phillips In short, while I_ understand the basis for your concern'and your recommendation that Class B and Class C low-level radioactive i~

wasteLshould be disposed of by deep burial, I am not convinced that.the' degree of hazard warrants such action or that the:

technical " fixes" we have are inadequate. I do appreciate your concern, however, and the fact that you took the trouble to send me your thoughts,on the matter in writing. I should also like to i- . express my deep appreciation for your participation in the Cement Workshop. 'Your comments were cogent and incisive and were an-invaluable contribution to Working Group 3 and the Workshop as a whole. You very definitely helped to make the Workshop a i success, and I am grateful for your contribution to that and to any efforts we may be involved in regarding cement. solidification' in the future.

Sincerely, Ori6 1ncl Di'gned 37 Michael Tokar, Section Leader ,

Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS Distribution:

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PDR No:/ / Reason: Proprietary / / or CF Only / /

ACNW Yes:/_j(_/ No:/ /

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OFFICIAL RECORD COPY l

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