ML20204B727

Technical Evaluation of VRS-002, 10CFR61 Waste Form Conformance Program for Solidified Process Waste Products by Waste Chem Corp Vol Reduction & Solidification (Vrs) Sys. Rept Acceptable as Ref Document

ML20204B727
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Site:	Hope Creek
Issue date:	10/17/1988
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ENCLOSURE TECHNICAL EVALUATION BY THE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Report Numbert VRS-002 ,

t Report

Title:

10 CFR 61 Waste Fonn Conformance Program for Solidified Process Waste Products Produced by a Waste Chem Corporation Volume Reduction and Solidification (VRS) System.

Originating Organization: Waste Ciiem Corporation, Paramus, NJ .

Reviewed by: Technical Branch Division of Low-Level Waste Management and Decomissioning (NMSS)

INTRODUCTION Compliance with the regulatory requirements and recomenoations for disposal of low-level racioactive waste would nonnally require detailed inspection at each licensee facility. To expedite determination of compliance, NRC has encouraged preparation of a* Topical Report (TR) by each vendor for his particular packag-ing method or system. The TR approarh provides a centralized national level of review with active participation by the States.

On May 30, 1986, WasteChem Corporation submitted (Ref.1) its Topical Report for a fonnal NRC review. On August 5,1986, it submitted (Ref. 2) Supplement No. 1. Biodegradation Test Results. Copies of the TR and Supplement were sub-sequently transmitted (Ref. 3) by NRC to the States of Washington and South Carolina. Consolidated comants and questions from NRC and the States were sent (Ref. 4) to Wastechem on November 5, 1986. Wastechemresponses(Revi-sion 1) were received (Ref. 5) by NRC on September 25, 1987. On December 16, 1987. Wastechem submitted Revision 2 of its Topical Report (Ref. 6).

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This Technical Evaluation Report (TER) contains a detailed evaluation of the extent the generic waste processed by VRS can satisfy regulatory requirements on waste fom.

sum ARY OF TOPICAL REPORT

• The TR documents the results of tests performed to demonstrate compliance with 10 CFR Part 61 criteria for asphalt-encapsulated waste foms produced by Waste-Chem Volume Reduction and Solidification (VRS) Systems. ,

A YRS system was used to prepare the following eight types of waste to simulate generic process wastes produced by coccercial PWR's and BWR't:

$ Bead Resin

$ Precoat Filter Cake with Powdered Resin

$ Precoat Filter Cake with Diatomaceous Earth Evaporator Concentrates - Neutralization Waste

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$ Evaporator Concentrates - Floor Drain

$ Evaporator Concentrates -

$ Decontamination Waste

$ Mixed Resin and Filter Cake Waste

/.ppendix A of this evaluation report contains information on the composition and preparation of the waste streams and the maximum evaluated waste-to-aspnalt ratio.

The VRS system used is a heated extruder-evaporator (53 rm 0). During opera-tion, wet solid waste and ASTM-D-312 Type !!! asphalt (a high-viscosity, oxidized, petroleum based asphalt) are simultaneously fed to the syste i. Free water in the waste stream is evaporated and condensed in the extrucer steam dere coolers and drained by gravity to a liquid waste collecticn system. The remaining waste solids are encapsulated into a molten asphalt matrix and are discharged from the system into waste containers.

The solidified, waste products (listed above) have been tested in accordance with procedures reconwended by hRC's 1983 Technical Position on Waste Fom fcr 2

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compressive strength, radiation stability, biodegradation, therral degradation, leach resistance, issnersion and free liquid content. Test results were com-pared with the acceptance criteria recomended by the Technical Position on Waste form.

REGULATORY REQ 1)IREMENTS .

The basic technical requirements for waste classification and waste character-istics are given in 10 CFR 61 Sect 4n 61.55 and 61.56, respectively (Ref. 7).

The Technical Position papers and Regulatory Guides the NRC has issued provide guidance to aid in implementation of the regulations. The information provided in the Technical Position papers and Regulatory Guides are presented as recom.

mendations. They are not legal requirements and, therefore, a vendor can offer alternatives.

WASTE CLASSIFICATION AND WASTE CHARACTERISTICS The waste classification system (10 CFR 61.55) di'vides icw-level wastes accept-able for near-surface disposal into three categories designated as Classes A, B, and C on the basis of the half-lives and concentrations of certain radionu-clides. Class A wastes have the lowest concentrations of radionuclides and are required to meet only minimum waste form requirements. Class B wastes have higher concentrations and must also treet stability recuirements. Class C wastes have even higher concentrations of radionuclides and besidts meeting the requirements of Class B wastes must be disposed of with protection for an inadvertent intruder. The structural stability requirements for Classes B and C wastes currently are achieved by the use of high integrity container (HICs),

by solidification of the waste, or by taking credit for the inherent stability of the waste.

The minimum requirements (10 CFR 61.56(a)) are intended to ensure operator safety during handling of the wastes. The stability requirements are intended to minimize subsidence effects in the disposal facility by maintaining gross physical properties and identity for a minimum of 300 years. Section61.56(b) clarifies the tr;eaning of stability and identifies several expected disposal conditions which the wastes must withstand: external lead, mo'sture, microbial 3

activity, radiation, and chemical attack with respect to Class C waste, barriers against inadvertent intrusion should have an effective life of at least 500 years.

TECHNICAL POSITION ON WASTE CLASSIFICATION Section 61.55 of 10 CFR Part 61 contains two tables listing limiting radionu-clide concentrations for three classes of wastes considerea suitable for near- ,

surface disposal. The classifications take into account the radiological hazard of the nuclides of concern and also provide for wastes containing mix-tures of nuclides. Any licenset who transfers waste either to a land disposal facility or to a waste collector must classdfy the waste transferred. Any licensed waste processor who treats or repackages waste for disposal must also classify those wastes.

t All licensees must carry out a compliance program to assure proper classifica- '

tien of waste. The objective of these programs,is to ensure realistic repre-sentation'of the distribution of radionuclides with the wastes. The program is expected to be more sephisticated for wastes c6ntaining higher concentrations of nuclides, as in waste Classes 8 and C, and for cases in which minor varia-tions in process conditions could result in a change in classification or in which there is a reasonable chance that Class C limits might be exceeded.

In recognition of the difficulties in sampling and measurement, a reasonable target for accuracy is determination of concentrations to within a factor of

10. Concentrations may be detemined by direct measurement, indirectly by correlation f actors, by materials accounting by source, or by gross activity measurements.

TECHNICAL POSITION ON WASTE FORM The 1983 Technical Position on Waste fem (Ref. 8) elaborates on tne provisions of Section 61.56.

Class A wastes, having low concentrations of nuclices, do not have to be stabi-lized, but on disposal must be segregated from Classes B and C wastes. If 4

1 Class A wastes are solidified ano segregated from Class B and Class C wastes, they need only be free-standing monoliths having a free liquid content no more than 0.55 by voltme. If not segregated, such wastes must meet the structural stability requirements of Classes B and C wastes.

e Classes B and i wastes are intended to maintain their gross physical properties and physical identity over a 300-year period. The demonstration of the required structural stability can be done by subjecting samples of the waste fonns to a series of tests. The reconnended tests include initial compressive strength, leach resistance to appropriate aqueous media, compressive strength after innersion in water, resistance to biological attack, radiation resistance and thermal cycling stability.

Stability can also be achieved through use of high integrity containers (HICs). '

These should also have a minimum life-time of 300 years. Tests to which HICs must be subjected include consideration of their mechanical strength, the impact of themal loads, chemical and biological , interactions with both the disposal en"vironment and the contained waste, ganr.a and ultraviolet radiati$n, and the ability to withstand varicus handling tists.

EVALUATION COMPOSITION OF WASTE FORMS TESTED The composition of the eight waste types used by WasteChem are similar to the i waste types for which some test data were developed by BNL (Ref. 10. Appen-dix A). However, waste stream fomulations were provided (in the topical report) without providing any indications as to the range of their character-1 istics, i.e., concentrations of organic chemical constituents, within which acceptable waste foms can still be made. The raximum achievable waste / asphalt f ratio is different for such waste type, and waste characteristics apparently i

depend on both waste feed stream chemistry and waste / asphalt ratio. This review and evaluation, therefore, apply only to the fomulation listed in l Appendix A of this Evaluation Report, ,

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. l The pH's for the formulations were also not provided for most cases. The TR l states that solidification of asphalt containing waste is not sensitive to pH. l l

However, it was also stated that pH must be controlled to minimize corrosion of j the process equipment (pp. 20 and Section A-3.2). It is therefore necessary to include suc,h information and any other waste characteristics important to e process con' trol, equipment protection or waste product acceptability as part of the Process Control Plan (see discussion on page 15). (It is noted that in the revised report, it is stated that waste feed pH must be controlled to a value of 7 or greater to Minimize corrosion of equipment.)

One constituent of particular concern is lubricating oil, present in simulated evaporator concentrates (PWR) and decontamination waste (BWR/FWR). Oils and organic solvents will generally soften asphalt waste forms, hence, some upper limit to oil and organic concentrations in the waste stream should exist to achieve an acceptable waste fonn product. The waste strearrs listed as approved in Table 1 of Appendix A of this report should not contain oils in greater concentrations than thuse listed for the respe.ctive waste streams tested in Appendi$A.

MINIMUM REQUIREMENTS FOR WASTES, 10 CFR 61.56(a)

This secticn of the evaluation examines the adequacy of VRS products' waste characteristics.

Section 61.56(a) of 10 CFR Part 61 contains the minimum requirements for all classes of waste and are intended to facilitate handling at the disposal site and provide protection of health and safety of personnel at the disposal sito.

(a) Packaging ,

l As indicated in 10 CFR 61.56(a)(1), waste must not be packaged for disposal in cardboard or fiberboard boxes. The waste form is packaged in suitable waste containers (55 gallon steel drums) and thus satisfies the requirement.

(b) Liquid Vaste l

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s As required by 10 CFR 61.56(a)(2), liquid waste must be solidified or packaged in sufficient absorbent material to absorb twice the volume of the liquid. ,

Liquid wastes are completely solidified in nonnal operation.

(c) Free Ljquid e As indicated in 10 CFR 6't.56(a)(3), free standing liquid in the solid waste shall not exceed 15 of the volume of the solid waste.

Free liquid content was determined in accordance with the method prescribed by ANS 55.1 "American National Standard for Solid Radioactive Waste Processing System for Light Water Cooled Reactor Plants," Appendix 2. No free liquid was found in any o' the samples tested. This satisfies the requirement of no more than 1 percent by volume of free standing liquid.

(d) Reactivity of Product As indicated in 10 CFR 61.86 hi(4), the waste must not be readily capable of ,

detonation or of explosive decomposition or reaction at norsal pressures arid temperatures, or of explosive reaction with water.

The waste asphalt matrix produced does not appear to contain any substance capable of detonation or explosive decompositiun or reaction at normal pres-sures and temperatures, or of explosive reaction with water.

(e) Gas Generation 1

Thewasteasphaltmatrixsatisfiestherequirementstatedin10CFR61.56(a)(5) because it does not contain or appear to be capable of generating quantities of toxic gases, vapors, or fures hamful to persons transporting, handling or dis-  ;

posing of the waste form.

(f) Pyrophoricity 7

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The waste asphalt matrix satisfies the requirement stated in 10 CFR 61(a)(6) because it does not contain materials which are pyrophoric as defired in 20 CFR 61.2.

e (g) Gaseous Wastes ,

This provision (10 CFR 61(a)(7)) is not applicable to WasteChem's waste fonn which is either solid or solid containing less than the 11 by volume of free standing liquid.

(h) Hazardous Waste ,

Under the Resource Conservation and Recovery Act (RCRA), the U.S.

Environmental Protection Agency (EPA) has jurisdiction over the management of solid hazardous wastes with the exception of source, byproduct, and special nuclear material, which are regulated by the NRC under the Atomic Energy Act (AEA). Low-level radioactive wastes (LLW) contain source, byproduct, or special nuclear raterials, but tney maj also tontain chemical constituents which are hazardous under EPA regulations promulgated under Subtitle C of RCRA.

Such wastes are coitoonly referred to as Mixed low-level Radioactive and HazardousWaste(MixedWaste).

ApplicableNhtCregulationscontrolthebyproduct, source,andspecialnuclear materialcomponentsoftheMixedLLW(10CFRParts 30,40,61,and70); EPA regulations control the hazardous component of the Mixed LLW (40 CFR Parts 260-266,268and270). Thus, all of the individual constituents of Mixed LLW are subject to either NRC or EPA regulations. However, when the components are combined to become Mixed LLW, neither agency has exclusive jurisdicticn under current Federal law. This has resulted in dual regulation of Mixed LLW where NRC regulates the radioactive component and EPA regulates the hazardous component of the same waste.

UncerSection10CFR61.56(a)(8)wastecontaininghazardous, biological, pathegenic,,or infectious material must be treated to reduce to the Nximum extent practicable the potential hazard from the non radiological materials.

The waste fonn consisting of ASTN 0-312 Type III asphalt plus the waste stream 8

s materials listed in Appendix A of this evaluation does not contain biological, pathegenic or infectious material, and thus satisfies these requirements of 10 CFR Part 61.

It should by noted, however, that the NRC Topical Report review of the Waste Chem VRS-002 bitimunization process asphalt did not address any applicable EPA requirements relating to hazardous solid waste for which the vendor or waste generator using the Waste Chem VRS-002 bitimuninization process for LLW may be legally responsible under RCRA.

STABILITY REQUIREMENTS OF 10 CFR 61.56(b) .

The requirements in 10 CFR 61.56(b) are intended to provide stability of the waste. Stability is intended to ensure that the waste does not structurally degrade and affect overall stability of the site through slumping, collapse, or other failure of the disposal unit and thereby lead to water infiltration.

Stability is also a factor in limiting exposure to an inadvertent intruder, since it provides a recognizable and nondispersible waste.

(a) Structural Stability According to 10 CFR 61.56(b)(1), the waste forin rust maintain its physical dimensions and its form, under the expected disposal conditions such as weight or overburden and compaction equipment, the presents of moisture, and microbial activity, and internal factors such as radiation effects and chemical changes.

The hasteChem product will be packaged in suitable containers, but no credit for stability will be taken for the containers. The evaluation for structural stability is presented below under reconinendations of the 1983 Technical Post-tiononWasteForm(Ref.8and9).

(b) Free Liquid During operation of the VRS system, free liquid in the waste stream is essen-tially ccep1,etely removed. The requirerent that free liquid be no more than 0.5% of the volume of the waste is satisfied.

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(c) Void Spaces Section61.56(b)(3)of10CFR61statesthatvoidspaceswithinthewasteand between the waste and its package must be reduced to the extent practicable.

e Containers holding the processed waste form will be filled to 90% or more of capacity while the waste form is still fluid. Care is taken not to overfill the container or spill the waste. Void spaces within the waste and between the waste and the containers are, therefore, reduced to the exte;.t practicable.

F.ECOMMENDATIONS OF THE 1983 TECHNICAL POSITION ON WASTE F0PJ4 The general applicability of the 1983 Technical Position on Waste Form is dis-cussed on page 3 of this evaluation report.

(a) Compressive Strength For bituminous products, the 1983 Technical Position on Waste Forn recomends that solicified specirens shoulo have compressive strengths of at least 50 psi when tested in accordance with ASTM 01074. However, the State of Washington has since rotified hRC that due to the State's,(U.S. Ecology) plan on placing accitional soil over completed trenches, review criteria fer stability require-ment for the State of Washington need to be rodified to accomodate maximum bu al depths of 55 feet, not 45 feet as was the previous criterion (Ref.12).

I a result of this change, the previous compressive test strength criterion of 50 ps, has been changed to 60 psi.

Duplicate sarples of each waste form were prepared from cylindrical, thin-wall aluminum sample molds nominally two inches in diameter by five and a half inches in length. The samples were chilled to reduce the adhesive bond between the specimen mold and the sample tolds. After the molds were stripped away, test samples were cut to length by a high speed saw to yield a length-to-diareter ratio of approximately 2. Compressive strength tests for the sarple products war,e performed in acccreance with ASTN 01074 as recomended by the

Technical Position on Waste Fortn.

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The compressive force applied to each sample was recorded at 10% sample defor-mation, and the corresponding strength of each was calculated based upon the original cross sectional area. The compressive strengths at 10% deformation ranged from 108 psi to 262 psi., all greater than the 60 psi strength currently specified for all waste from samples tested. It is noted that they are d l higher than the 75.0 to 97.9 psi for samples of pure ASTM-D-712 Type III asphalt.

(b) Radiation Resistance Duplicate samples of each waste fonn in their sample molds were exposed in cobalt-60 irradiator to a gama field in two batches averaging 0.96 megarads per hour and 0.'/3 megarads per hour and cumulating 100.13 and 100.35 megarads, respectively. The compressive strength after irradiation ranged from 55.6 psi ,

for 50% loaded Evaporator Concentrates (PWR) to 124 psi for 45% loaded Mixed ResinandFilterCakeWaste(BWR). The compressive strength of 55.6 psi for Evaporator' Concentrates is less than the 60 ps1 requirement. Tests for com-pressive strength after irradiation exposure,of 108 rads over a 239.9 hour1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> perico were repeated on December 10, 1987, for a garra field of 0.418 x 106 rad /hr which was less intense than those reported in the May 30, 1986 report.

post irradiation compressive strengths of 220 and 270 psi were obtained for the two samples t,ested. This derenstrated that the 60 psi minimum ccepressive strengths could be maintained after irradiation.

(c) Biccegradability The Technical Position on Waste Form (TPWF) recorrends three levels of testing.

The first two levels are primarily screening tests to deteruine resistance to biodegradation. If no fungal (as defined in ASTM G21) or bacterial (as defined in ASTM G22) culture growth is visible, the spectren waste forms are considered j to have passed biodegradation resistance at the first level of the then recom-eended tests. No further testing for biodegrability is then required. On the other hand, if the waste forms fail the first level tests, the second level of test must be performed. This consists of washing the failed specimens with water and light scrubbing, extraction of surface contaminants with an appro-priate organic solvent if necessary; air drying at rocm temperature, and l

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repeating the G21 and G22 procedure. Waste forms are considered to have passed at the second level tests provided culture growth does not exceed a rating of 1 i in G21 and no growth is visible in G22. In both cases, the specimen must show a compressive strength greater than 60 psi following the tests.

If failure at the second lavel occurs, the TPWP recorsnends that the biodegrada-tion rates be determined by longer M rm testing using the Bartha-Pramer method.

(Ref. 13 ano 14). Soils used in U.14 test should be representative of those at burial grounds. Degradation rates detemined from this level of testing are to be extrapolated for full-size wa',te form to 300 years. Waste foms pass this test if the extrapolation indicates that biodegradation will c,avse less than a 10 percent loss of the total carbon in the waste fom. The minimum time recomended for the Bartha-Prarer testing is six months. No compression tests are required following this test.

Some G21 ano G22 tests were conducted by Brookhaven National Laboratory on generic-type bituminized waste materials. Results from those tests (Ref. 9) indicated that bituminized waste foms were s,usceptible to fungal and bacterial growth.

Based on the BNL test results, and in accordance with the option defined in the 1983 Technical Posittens, Wastechem elected to have Bartha-Pramer bio-degradation rate tests performed on specimens in place of the ASTM G21 and G22 tests. Duplicate samples of each waste fonn were tested over a 26-week period with Hanford soil and with simulated Banvell soil. The test results were extrapolated to predict perfomance of 55 gallon drum waste forms af ter 300 years of burial. Total carbon loss over 300 years was projected to be from not reasurable to .0291 for Hanford soil and not measurable to .025% for Barwell soil. This was less than a 10 percent loss of the carbon in the waste fenn. Therefore, the recorrendations for the TFWF on biodegradability were satisfied.

Wastechem did not perform post biedegradation compre.sion tests on the specirnen i

because no G21 and G22 tests were perforved and because *.'e specimens prepared for Bartha-Prarer tests were not cut for dimensions suitable for compression tests. However, degradation in compressive strength due to biodegradation is 12

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Judged to be negligible since the projected total carb a loss was less than

.0291, a much smaller loss than the 10% maximum alloweit fer by the iPWF.

(d) Leachaoility Index The TPWF recomends that' leach indices be determined in accordance wf th the procedure in AES 16.1 (Ref. 15) for a minimum of 90 days and that the teach indices so determined should be greater tha. 6.

Data and analysis for imersion tests using deionized water and three nonradio-

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active tracersi cesium, strontium and cobalt were reported. All samples tested satisfied the TPWF reconenendation. The leach index range was B.07 to 13.76.

The TPWF recocinendation is therefore satisfied.

(e) Imersion Resistance The TPWF, as modified by Ref. 9 letter to amount for an increase in burial depth at Hanford, recomends that solidified waste forms must maintain a mininum compressive strength of 60 psi as tested using ASTM C39 or ASTM 01074 following imersion in water for a minimum period of 90 days.

Data for imersion resistance of duplicate samples of waste forms tested by '

WasteChem indicate that samples from all waste streams have compressive strength exceeding 60 psi (range 73.9 - 250 psi)exceptforsamplesmadewith simulated Evaporator Concentrates - Neutralization Wastes (BWR). Testing for the latter samples, loaded between 30% and 605 solids was terminated due to

< product swelling and subsecuent loss of compressive strength. The tests were repeated with samples loaded with 25% and 151 solids. The resulting compressive strength varied from 98 psi to 108 psi, which exceeds the 60 psi require ent, l

i If swelling occurs during the leach test, the calculation of a leach index is l questionable. However, it is noted that original values of dimensions were f used in calculating the leach index. Therefore, the leach index so obtained is conservative.

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In sumary, samples of all waste stra .>

ied imersion resistance requirements. It is noted that for 'wle m Evaporator

- Concentrates-Neutralization Wastes (BWR) saste loading must be equal or less than 251 to satisfy the compressive strength requirement for post i m ersion compression testing. t (f) Thermal Cycle Resistance Solidified waste forms should retain a minimum compressive strength greater than 60 psi af ter 30 themal cycles between 60 Celsius and -40 Celsius as per ASTM B553. The post-thermal compressive strength of the samples tested ranges from 81.2 psi to 276 psi. The current criterion for thermal cycling resistance is therefore satisfied, j (g) Free Liquid No free liquids were observed upon removal of the small scale waste forms from the sample acids. Furthemore, during destructive examination of a 55 gallon drum containing a bead resin waste fom, no f,ree liquids were detected. This den.onstrates that the recontrendation that waste specimens should have less that.

0,5 percent by volute of the specimen as free liquids was satisfied.

(h) Full-Scale Specimen Tests Results The 1983 TPWF recomends that test data from sections or cores of the full-scale products be correlated with test data from laboratory scale specimens. The full-scale Wasteches waste form is a 55-gallon drum containing a bead resin waste form.

A full size waste form (55 gallen drum) was produceo f rom a bead resin feed to demonstrat,e that waste form properties are independent of waste form scale.

Correlation was demonstrated to the extent that all compressive strength values are well above the 60 psi minim a No leaching index data for cut samples from a full-scale specimen were pre. s.ed. However, the NRC staff do not anticipate 14

that change in values of the leach index, if any, would be significant enough to have resulted in values below 6.

(1) Homogeneity e

Data from four cut semples taken from different locations of the full-size 55-gallon drum containing bead resin showed compressive strengths ranging from 191 to 192 psi. Af ter 90 .1ay imersion in de-ionized water, the range was 172 - 182 psi. Homogeneity, therefore, was demonstrated in that all compres-sive strengths were well above the 60 psi minimum. [

(j) Process Control Program The report reconsnends that implementation of the stability guidance be achieved through a qualified process control program. Periodic demonstrations that the VRS system is functioning properly are recomended. The generic process con-  ;

I trol progr'am provided by WasteChem appeared satisfactory except as noted below.

Instrument calibration should be perfonned periodically and at frequencies te be deterinined by WasteChem ano the waste producer, and, based on actual experi-l ence, Calibration inay then be reduced to a less frequent basis.

J The waste fortn has been qualified on the basis of maximum permissible waste loading. To ensure compliance with the stability requirements, the waste pro-ducer should provide accurate solids content data for each batch of waste based on the actual characteristics of each batch.

It is, therefore, necessary that a separate plant-specific Process Control [

Program be established for each waste producer. The plant-specific Process  !

Control Program should bc tailcred to the characteristics of the producer's waste streams.

4 REGULATORY POSITION

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In the evaluation of this Wastechem Topical Report, the NRC staff reviewed the waste form qualification test cata for eight simulated waste streams to 15

determine the waste forms' compliance with 10 CFR Part 61 criteria. This Topical Report dated August, 1986 is acceptable as a reference document for licensing asphalt-encapsulated waste foms produced by Wastechem's VRS systems subject to the following conditions:

1. Thewaiteformsproducedarelimitedtothosewastespreparedfromthe reactants from which the test specimens were prepared and tested and specifically identified in this Topical Report.

2. The maximum waste loadings are as stated in Section A-3.3 of the Topical Report dated August,1987 and in Table 1 Appendix A of this Evaluation Report.

3. Bitumen can exhibit creep flow under an applied load, thereby increasing the potential for trench instability if not sufficiently confined. The -

NRC recomenos an administrative backfill procedure to ensure adequate confihement and to prevent creepflow. However, if the bitumen waste form is* housed in high integrity containers (H'ICs) which by themselves can sustain the applied load in the disposal trench, the additional admin-istrative backfill procedure will not be necessary.

4. The wast,e form shall be contained in 55 - gt'lon steel drums (if not con-tainedinapprovedHICs).

5. The waste forms should be prepared using the procedures specified in the PCP. With the above limitations, asphalt-encapsulated waste foms produced by Wastechem's VRS system should be capable of meeting the waste form requirements of 10 CFR Part 61. Because waste streams produced at variour nuclear power facilities vary, the licensee M1oying the VRS system must demonstrate that it is capable of following waste elements Process Control Program (above equivalent) and provide NRC with test results of solidified wastes which are representative of wastes produced by the system used.

REFERENCES .

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1. WastechenlettertoUSNRC(DavidN.EnegessofWastechemtoMalcolmR.

KnappofNMSS,USNRC)May 30, 1985.

2. Wastechem letter to USNRC (David N. Enegess of WasteChem to Malcolm R.

Knapp of HMSS, USNRC) August 5, 1986. e

3. USNRC letters to Department of Social and Heaith Services Washington State ,

and to H. Shealy of South Carolina State June 26, 1986.

4 USNRC letter to WasteChem (K. Chang of USNRC to David N. Enegess of Waste-Chem) November 5,1986. .

5. WasteChem letter to USNRC (William J. Klein of Wastechem to M. Tokar of USNRC) September 24, 1987. ,

6. WasteChem letter to USNRC (William J. Klein of WasteChem to Michael Tokar of hMSS, USNRC) December 16, 1987. .

7. Licensing Requf*tments for Land Disposal'of Radioactive Waste, 10 CFR Part 61, Revised as of January 1, 1987.

8. Technical Position on Waste Form. Rev. 0. May 1983; Low-level Waste Licensing Branch, Division of Waste Management, Nuclear Regulatory Comission, Washington, D.C.

Boweman B.S. , Swyler K.J., Dougherty D.R., Davis R.E. Siskind B., and 9.

Barletta R.E., An Evaluation of the Stability Tests Recomended in the Branch Technical Position on Waste Foms and Container Materials, NUREG/

CR-2829. Brookhaven National Laboratory, March 1985.

10. Columbo, P. and Neilson, R.M. Properties of Radioactive Wastes and Waste Containers - First Topical Report BNL-NUREG/CR-0619 Brookhaven National Laboratory, August, 1979.

11. Identif'ication and Listing of Hazardous Waste, 40 CFR Part 261, Revised as of July 1,1983.

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12. LetterStateofWashington(NancyP.Keiner,DepartmentofSocialand Health Services) to USNRC (Donald A. Nusshammer) December 9,1985.

13. R. Bartha, D. Pramer, "Features of a Flask and Method for Measuring the Persistance tnd Biological Effects of Pesticides in Soils. Soil Science ,

100(1)',pp-68-70,1965

14. Piciulo P.L., Shea C.E., and Barletta R.E., Biodegradation Testing of Solidified Lcw Level Waste Streams NUREG/CR-4200, Brookhaven National Laboratory, March 1985.

15. Measurement of the Leachability of Solidified Low-Level R&dioactive Wastes ANS 16.1, American Nuclear Society Draft Standards, April 1981.

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