ML20246H525
| ML20246H525 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1989 |
| From: | Tokar M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Boyce T DOW CHEMICAL CO. |
| References | |
| REF-WM-82 NUDOCS 8907170128 | |
| Download: ML20246H525 (2) | |
Text
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.e Mr. Thomas D. Boyce Technical Services and Development Willard H. Dow Center, 2040 Building DOW Chemical, U.S.A.
Midland, MI 48674
SUBJECT:
FINAL T0pICAL REPORT DNS-RSS-200 NP-A: THE DOW WASTE SOLIDIFICATION !
PROCESS FOR LOW-LEVEL RADI0 ACTIVE WASTE (DOCKET NUMBER WM-82)
Dear Mr.Boyce:
'We have examined the subject Final Topical Report (TR), received in March 1989, as it was formulated and amended to incorporate information that was developed during the course of NRC's technical review. Our examination revealed several discrepancies or omissions between NRC's June 1,1988 Technical Evaluation Report (TER) and the Final TR and some editorial corrections. These are discussed below.
Discrepancies or Omissions Between NRC's TER and DOW's TR
- 1. The Process Control Plan (PCP) Recipe for all waste streams should be revised to be consistent with this TR and should be included as an appendix to this TR.
I
- 2. NRC's TER (Section 5.2, " Process Limits", page 15) points out that the solids concentrations in BWR Eva) orator Bottoms Waste as approved by NRC's Office of Nuclear Reactor legulation (reference 5 of NRC's June 1, 1988 TER) in the process TR (reference 4 of NRC's TER) are substantially lower (7-12 weight percent) than those of the corresponding waste form described in the subject TR (25.5 weight percent). The TER goes on to state that the process TR therefore should be revised to show a maximum solids concentration of 25.5 weight percent in the formulation for solidification of BWR Evaporator Bottoms.
The PCP Recipe shcald be revised to be consistent with the TR, i.e., show a maximum solids concentration of 25.5 weight percent in the formulation for solidification of BWR Evaporator Bottoms.
- 3. Section 5.3.C (page 16) of NRC's June 1,1988 TER states that users must be made aware that relatively small amounts of materials such as copper and iron could interfere with satisfactory operation of the process. The TER further states that this must be made clear in the revised version of the TR and in any sales literature used by DOW. The TER also states that upper limits chould be specified in the PCP.
The final .2 should state that any sales literature will state that relatively small amounts of materials such as copper and iron in other //
l than metallic form could interfere with satisfactory operation of the t pro:ess. The PCP Recipe should be revised to specify the upper limits of (
T.per and iron in non-metallic form (i.e., copper and iron with valences j ditferent from that in metallic form).
8907170128 890623 pfDFfd, PDR WASTE wn-e2 FDC
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+
c ~ LTR TBOYCE EW.
/ '2 4 4b S;ction 6.4 of the TER states that full-scale waste fcrms larger than-50 cubic fcet cannot b3 apprcycd b:caus2 correlation testing is
~
1 incomplete.
Therefore.
forms larger that 50 cubic feetithave must be made not been approved. clear in.the final TR that
- Waste forms larger than 50 cubic feet could be addressed in a revision #
. to this TR and submitted to NRC for approval.
- 5. . Section 6.1.5 of the TER (Limitations) states that the DOW process for solidifying filter-aid sludge should not be anoroved pending further action by DOW because of surface cracks in th e Mb-scule specimens. The further action is to examine large-scale waste forms with this waste stream and demonstrate that cracking is minimei and only superficial in extent.
The Final TR does not indicate that DOW has taken the further action called for in the TER. Therefore, it should be made clear in the Final TR that solidified filter-aid' sludge is not an approved waste form.
Editorial 1.c The last sentence on page 81 says that " wastes containing at least 10% of' l metallic-form (copper and iron) could be solidified." This implies that ;
. wastas with less than 10% of metallic form could not be solidified. This !
4 should be clarified.-
g 2.- The radioactivity units on pages 15, 82 and 83 should be "microc6 ies" rather than " curies."
i A copy of the marked-up pages is enclosed.
> -Please submit your revised Final TR within 60 days after receipt of this' letter.
Sincerely, Original Signed By Michael Tokar, Section Leader Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS Distribution: TCsn Wal File 1 202.2 ,
JGreeves, LLWM HBell,'LLRB' # JAustin, LLRB JSurmeier, LLTB Ptchaus, LLOB MTokar, LLT3 EWick, LLTB JCraig, NRR/SPLB LJahandari,LLTB rf JJones, LLOB rf HMSS rf PDR N0 T 7 Category: Proprietary / / or CF Only / / ;
ACNW YES /T7 NO/ /
fTRAL TR DNS-RSS-200 NP-A: DOW WASTE SOLIDIFICATION SUBJECT AB3 TRACT:
.j . !..[. ....[ .. ..[ f......[ f .......
l NAME:EWicVfTj :MTokar :JSur$eier: : : :
DATE:s //g/89 :( /}f/89 :/ /96/89 : / /89: / /89 : / /89 : / /89
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