NRC Generic Letter 80-09, Low Level Radioactive Waste Disposal

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GL80009

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

January 29, 1980

TO ALL POWER REACTOR LICENSEES

Subject: Low Level Radioactive Waste Disposal

Recent developments at commerical low level waste burial sites have substantially impacted waste disposal operations. The license to operate the facility at Barnwell has been recently revised by the State of South Carolina to further limit the volume of waste buried and to upgrade the integrity of the waste form received at the site. Similar requirements to upgrade the integrity of waste forms packaged for the Richland, Washington burial site also have been required by the State of Washington, NRC licensees are required by Commission regulations to assure that wastes prepared for shipment are in a form that the Agreement State licensee is permitted to receive under applicable Agreement State regulations as well as meeting all pertinent NRC and DOT transportation regulations.

The past closure of low-level radioactive waste burial sites in Washington and Nevada and the strict enforcement of license conditions at Barnwell have resulted from the States' dissatisfaction with the events that have occurred involving solid radwastes shipped from waste generators including power reactors, Consequently, improvements will have to be made to comply with the State licenses.

NRC OIE Bulletin No. 79-19, Packaging of Low Level Radioactive Waste for Transport and Burial, has already been sent to you regarding this matter. You should review your system and operating procedures to assure the strict adherence to the revised burial site license conditions and their interpretation by the State authorities.

The enclosed license and accompanying letter from the State of Carolina to the site licensee, Chem-Nuclear Systems, Inc., describes the restrictions to be adhered to for the wastes received at that site. The requirements by the State of Washington on waste form upgrade is similar. The following areas are of particular concern to the States and should be acted upon accordingly.

1) Free Liquids in Wastes Leaving Reactor Site

The objective for solid radioactive wastes leaving the reactor site for burial is that they should contain no detectable free liquids as defined by Appendix 2 of ANSI/ANS 55.1-1979. In no case however, should the amount of free liquid upon arrival at the burial site exceed the burial site license conditions. Free liquid determination should consider the effects of transportation, e.g., vibration, freezing and thawing. This requirement is applicable to both dewatered resins and spent filter media as well as solidified wastes departing the reactor site.The following conditions (items 2 - 4) must be met for the waste to be acceptable by burial sites in the States of Washington and South Carolina.

2) Free Liquids in Wastes on Arrival at the Burial Site

Until December 31, 1980, provide assurance that all wastes do not contain more than 1% liquid by volume upon arrival at the burial site. Any liquids present in waste packages shall be non-corrosive with respect to the container. Non-corrosive means conformance with 10 CFR 71.31, 49 CFR 173 and other DOT regulations such that there should be no significant chemical, galvanic or other reaction with the packaging components.

Tests should be conducted either on simulated or actual waste which demonstrate that wastes to be shipped conform to the above criteria. In addition, operating procedures shall be developed that implement the methods to be used to assure that all wastes arriving at the burial site comply with burial site free liquid licensing conditions.

3) Future Free Liquids Requirements

Effective January 1, 1981, no wastes packages shall contain more than trace quantities of non-corrosive free liquids upon arrival at the burial sites. Trace quantities is defined as no more than 0.5% of, or one gallon in, the container volume, whichever is less. For those waste currently solidified by UF systems, you should prepare to meet this requirement as soon as feasible before January 1, 1981. Present methods of waste solidification by UF systems do not provide assurance that the waste packages on arrival at the burial sitE contain no more than trace quantities of non-corrosive free liquids.

4) Requirements on Spent Resins and Filter Media

Effective July 1981, spent resins and filter media with radioactivity levels above 1 Ci/cc of isotopes must be stabilized by solidification. However, in lieu of solidification, other methods such as packaging dewatered resins in a high integrity container (e.g., reinforced concrete) may be proposed to the NRC and the States licensing the burial sites. Although the South Carolina letter accompanying the license amendment does not discriminate between long and short half-live isotopes, it is our understanding through discussions with the State officials, that only isotopes with half-lives greater than 5 years need to be included in the radioactivity level (i.e., greater or less than 1 Ci/cc) consideration. Consequently, solidification or high integrity containers would then only be required if radioactivity levels exceeded 1 Ci/cc for radioisotopes with half-lives greater than 5 years.

In addition, the revised South Carolina License for Chem-Nuclear Systems, reduces the volume of waste allowed to be buried at Barnwell. This, and possible future burial site problems may result in a shortage of low level waste disposal capacity. Consequently, licensees should take positive steps to minimize the volume of waste produced. To this end, each licensee should implement a program to minimize the generation of radioactive solid wastes (e.g., waste segregation) and implement methods to reduce the Volumes of waste which cannot be eliminated (e.g., use of trash compactors).

.The revised requirements on waste forms may necessitate the use of mobile or temporary solidification systems. Regulations require, that any changes to your solidification systems differing from your FSAR submitted for the issuance of your Operating License be reviewed by you in accordance with 10 CFR Part 50.59. According to this regulation, an internal safety evaluation has to be prepared prior to making the facility modification. With respect to future changes in solidification systems, copies of the safety evaluations along with any addition supporting documentation concerning the safety adequacy of any mobile or temporary solidification system shall be submitted to the NRC. In addition, the appropriate revision to the Process Control Program (PCP) required under the model Radiological Effluent Technical Specifications shall be submitted for review if it has not been previously submitted or if it is being modified. Your PCP should be based on data or tests which demonstrate not only that complete solidification of liquid waste takes place, but that no free standing liquid exists in any waste container leaving your site. The PCP should also be based on data or tests that demonstrate that your waste will have no free standing liquid in excess of the burial ground license requirements at time of the burial and that any trace quantities of liquid are non-corrosive. The submittals (the safety evaluation and the revised PCP; should be made prior to the operation of your modified systems.

Sincerely,

Darrell G. Eisenhut, or Acting Director Division of Operating Reactors Office of Nuclear Reactor Regulation

Enclosure:

Letter and License from State of South Carolina

cc w/enclosure: Short Service List