NRC Generic Letter 1991-02
{{#Wiki_filter:UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555FC 2 8 1990TO: ALL OPERATORS OF LOW-LEVEL RADIOACTIVE WASTE (LLW) DISPOSAL SITES,WASTE PROCESSORS, AND ALL HOLDERS OF LICENSES FORNUCLEAR FUELS, NUCLEAR MATERIALS AND NUCLEAR POWER REACTORS
SUBJECT: REPORTING MISHAPS INVOLVING LLW FORMS PREPARED FOR DISPOSAL(GENERIC LETTER 91-02)
Purpose
- For the reasons presented below, the Nuclear Regulatory Commission (NRC) hasdecided to rely on voluntary submittal of informational reports by both wasteform generators and processors regarding mishaps to LL forms prepared fordisposal. This Generic Letter is intended to encourage this action on suchmishaps. Licensees are also reminded of their obligation to report defects anddeviations in accordance with NRC requirements in 10 CFR Part 21.Discussion:Background -NRC has incomplete information on mishaps to LLW forms prepared for disposal.Four incidents have been reported in which pressurization resulted fromchemical reactions in LLW shipping containers storing dewatered syntheticorganic materials, such as resins (NRC Information Notices 83-14, "DewateredSpent Ion Exchange Resin Susceptibility to Exothermic Chemical Reaction," March21, 1983; 84-72, "Clarification of Conditions for Waste Shipments Subject toHydrogen Gas Generation," September 10, 1984; 90-50, "Minimization of MethaneGas in Plant Systems and Radwaste Shipping Containers," August 8, 1990).Another incident was reported in which, during solidification of the waste, aviolent reaction occurred between a chemical detergent and a vendor's wastesolidification agent (NRC Information Notice 88-08, 'Chemical Reactions withRadioactive Waste Solidification Agents," March 14, 1988). This reactionresulted in boiling of the mixture so-that it overflowed the liner, thenhardened, and had to be chipped away. Other problems have been encountered inthe use of cement to solidify and stabilize bead resin wastes. Thus, therehave been multiple incidents in which cement-solidified bead resin wastes haveeither not solidified properly or have disintegrated over a period of timeafter solidification. Although mishaps such as these generally have been madeknown to regulatory authorities, mainly through indirect and informal means,there is presently no established method to encourage the reporting of suchevents and the providing of adequate information on them.(00, L ;f Of-s 'L 7CI-Q1_n1 Annul9-- 9i>oI -v ----
\ -{ r -Current Practice -All three currently-sited Agreement States (Nevada, South Carolina, andWashington) have established requirements in the State licenses for thereporting of waste form and container deficiencies identified by the siteoperators in wastes shipped to the sites for disposal. In addition, all threefacilities have on-site State inspectors who inspect the condition of shipmentsreceived by the disposal-facility operators. This information is provided toNRC as part of the NRC/Agreement State exchange of information program. Thestaff further notes, however, that neither the Agreement States nor NRC havespecific regulatory requirements that apply to all licensees for reporting ofwaste form or container deficiencies. Therefore, the States do report whatthey find, but they may not find some of these problems, because they have norequirement to look for all such events at their disposal facilities, and theydo not presently have the means to be informed routinely of mishaps that occurat NRC-licensed facilities.Existing reporting requirements contained in 10 CFR 20.403, 50.72, 50.73 and61.80 do not require reporting of waste form mishap information. Thereporting requirement in 10 CFR Part 21 is associated with safety-significantdefects or noncompliances, and may not be interpreted by some to cover mishapinformation.Classes of Needed Information -The staff has identified three classes of useful information thatinterest NRC and could be reported. These three include:1. The failure of high-integrity containers used to ensure a stable wasteform. Container failure can be evidenced by changed container dimensions,cracking, or damage resulting from mishandling (e.g., dropping orimpacting against another object).2. The misuse of high-integrity containers, evidenced by a quantity of freeliquid greater than 1 percent of container volume, or by an excessivevoid space within the container. Such misuse is prohibited by 10 CFR 61.56.3. The production of a solidified Class B or C waste form that has any ofthe following characteristics:-Contains free liquid in quantities exceeding 0.5 percent of thevolume of the waste.-Contains waste with radionuclides in concentrations exceeding thoseconsidered during waste form qualification testing accepted by theregulatory agency, which could lead to errors in assessment of wasteclas Contains a significantly different waste loading than that used inqualification testing accepted by the regulatory agency.-Contains chemical ingredients not present in qualification testingaccepted by the regulatory agency, and those quantities aresufficient to unacceptably degrade the waste product.-Shows instability evidenced by crumbling, cracking, spalling, voids,softening, disintegration, nonhomogeneity, or dimensional changes.-Evidence of processing phenomena that exceed the limiting processingconditions identified in applicable topical reports on processcontrol plans, e.g., foaming, temperature extremes, premature orslow hardening, and production of volatile material.Bases for Needed Information -The voluntary reporting of the three classes of information outlined abovewould allow the staff access to information on field experiences with LLW formsand to determine when modifications to test criteria are necessary. 10 CFRrart 61 establishes certain "minimum"(61.56(a)) and "stability" (61.56(b))requirements for LLW, whereas Part 20 (Section 20.311) requires wastegenerators and processors to certify that the waste satisfied the requirementsof Part 61. The Nuclear Material Safety and Safeguards (NMSS) staff reviewstopical reports and other documents provided by vendors and licensees to ensurethat the waste-form requirements of Part 61 will be met and to provide avehicle with which the certification requirements of Part 20 can be satisfied(by reference). In a parallel effort, the Office of Nuclear Reactor Regulation(NRR) staff reviews information on waste-processing equipment and procedures toensure that 10 CFR Part 50, App. A, "General Design Criteria for Nuclear PowerPlants," is satisfied. The NRC staff findings of acceptability and adequacy ofprocess-control provisions affecting the characteristics of the waste-formproduced may require modification, if subsequent experience in the fieldreveals that the bases for the approvals are being exceeded or are nolonger relevant. Therefore, to make informed decisions on regulatory action,to inform licensees of events that may have generic implications, and to makeinspectors aware of the reported information, the staff needs to havequantitative information on the nature and frequency of occurrence of mishapsregarding waste form and packaging for disposal.It is suggested that the voluntary submittal of information regardingwaste-form mishaps be reported within 30 days of the incident to NRC's Directorof the Division of Low-Level Waste Management a-id Decoiraissioning and to thedesignated State disposal-site regulatory authorit This request is covered by Office of Management and Budget Clearance Number:3150-0156, which expires November 30, 1993. The estimated average burden isapproximately 8 person-hours per licensee response, including visualobservation of the waste form mishap, drafting a description of theobservation, and preparing a final mishap report for submittal to NRC.Comments on the accuracy of this estimate and suggestions to reduce the burdenmay be directed to the Office of the Management and Budget, Room 3208, NewExecutive Office Building, Washington, D.C. 20503, and the U.S. NuclearRegulatory Commission, Information and Records Management Branch, Office ofInformation Resources Management, Washington, D.C. 20555.If you have any questions about this letter, please direct themto the technical contact listed below or to the appropriate regional office.
Sincerely,Richard L. Bangart, Directd'Division of Low-Level Waste Managementand Decommissioning, NMSS
Technical Contact:
Michael Tokar, NMSS(301) 492-0590
Enclosure:
List of Recently Issued Generic Letters4 LIST OF RECENTLY ISSUED GENERIC LETTERSGenericLetter No.Date ofSubject IssuanceIssued To91-0190-0989-10SUPP. 390-0890-0789-10SUPP. 288-20SUPP. 390-06REMOVAL OF THE SCHEDULE FORTHE WITHDRAWAL OF REACTORVESSEL MATERIAL SPECIMENSFROM TECHNICAL SPECIFICATIONSALTERNATIVE REQUIREMENTS FORSNUBBER VISUAL INSPECTIONINTERVALS AND CORRECTIVEACTIONSCONSIDERATION OF THE RESULTSOF NRC-SPONSORED TESTS OFMOTOR-OPERATED VALVESSIMULATION FACILITYEXEMPTIONSOPERATOR LICENSING NATIONALEXAMINATION SCHEDULEAVAILABILITY OF PROGRAMDESCRIPTIONSCOMPLETION OF CONTAINMENTPERFORMANCE IMPROVEMENTPROGRAM AND FORWARDING OFINSIGHTS FOR USE IN THEINDIVIDUAL PLANT EXAMINA-TION FOR SEVERE ACCIDENTVULNERABILITIESRESOLUTION OF GI 70, "POWER-OPERATED RELIEF VALVE ANDBLOCK VALVE RELIABILITY,"AND GI 94, "ADDITIONAL LOW-TEMPERATURE OVERPRESSUREPROTECTION FOR LIGHT-WATERREACTORS," PURSUANT TO1OCFR50.54(f)01/04/9112/11/9010/25/9008/10/9008/10/9008/03/9007/06/9006/28/90ALL HOLDERS OF OLsOR CPs FOR NUCLEARPOWER PLANTSALL LIGHT-WATERREACTOR LICENSEESAND APPLICANTSALL LICENSEES OFOPERATING NUCLEARPOWER PLANTS ANDHOLDERS OF CONSTRUC-TION PERMITS FORNUCLEAR POWER PLANTSALL HOLDERS OFOPERATING LICENSESOR CONSTRUCTIONPERMITS FOR NUCLEARPOWER REACTORSALL POWER REACTORLICENSEES ANDAPPLICANTS FOR ANOPERATING LICENSEALL LICENSEES OFOPERATING NPPs ANDHOLDERS OF CPs FORNPPsALL LICENSEES HOLD-ING OLs AND CPsFOR NPP FACILITIESEXCEPT LICENSEESFOR BWRs WITH MARK ICONTAINMENTSALL PRESSURIZEDWATER REACTORLICENSEES ANDCONSTRUCTIONPERMIT HOLDERS This request is covered by Office of Management and Budget Clearance Number:3150-0156, which expires November 30, 1993. The estimated average burden isapproximately 8 person-hours per licensee response, including visualobservation of the waste form mishap, drafting a description of theobservation, and preparing a final mishap report for submittal to NRC.Comments on the accuracy of this estimate and suggestions to reduce the burdenmay be directed to the Office of the Management and Budget, Room 3208, NewExecutive Office Building, Washington, D.C. 20503, and the U.S. NuclearRegulatory Commission, Information and Records Management Branch, Office ofInformation Resources Management, Washington, D.C. 20555.If you have any questions about this letter, please direct themto the technical contact listed below or to the appropriate regional office.
Sincerely,ONGI'IA1 SiGRichard L. Bangart, DirectorDivision of Low-Level Waste Managementand Decommissioning, NMSSTechnical Contract: Michael Tokar, NMSS(301) 492-0590
Enclosure:
List of Recently Issued Generic LettersEDO #90-229 (EDO WIDistribution: CentMraus RECuJGreeves RBanCJenkinsPDR YESACNW YESABSTRACT SUBRRCT:TS NO. 9000ral File#nninghamcartNMSS r/f LLWM r/fCERossi MTokarPLohaus R.O'ConnellLLWD t/f LLUR r/fEWickJSurmeierDMorris ,EDOEDO r/fNO _ Category: Proprietary _ or u- unlyNOREPORTING MISHAPS INVOLVING LLW FORMS PREPARED FORDISPOSAL (GENERIC LETTER 91-02)*SEE PREVIOUS CONCURRENCEOFC :LLWM* :TEDITOR* :IMNS* :LLWM* :LLWM* :LLWD* :LLWD*-____________________________________________________________________________________NAME:EWick* :EKraus* :RCunningham*:MTokar :JSurmeier :JGreeves :RBangart-____________________________________________________________________________________DATE:10/19/90 :10/22/90 :10/31/90 :12/27/90 :12/28/90 :12/28/90 :12/28/90a.I.,sITA nrrfnln rfinvGENERIC LIK 91-UZUrrLUIAL KLUUKU Wrl4 This request is covered by Office of Management and Budget Clearance Number:3150-0156, which expires November 30, 1993. The estimated average burden isapproximately 8 person-hours per licensee response, including visualobservation of the waste form mishap, drafting a description of theobservation, and preparing a final mishap report for submittal to NRC.Comments on the accuracy of this estimate and suggestions to reduce the burdenmay be directed to the Office of the Management and Budget, Room 3208, NewExecutive Office Building, Washington, D.C. 20503, and the U.S. NuclearRegulatory Commission, Information and Records Management Branch, Office ofInformation Resources Management, Washington, D.C. 20555.If you have any questions about this letter, please direct themto the technical contact listed below or to the appropriate regional office.
Sincerely,(6e, OM1 L 9AKRichard L. Bangart, DirectorDivision of Low-Level Waste Managementand Decommissioning, NMSSTechnical Conta Michael Tokar, NMSS01) 492-0590
Enclosure:
List of Recently Issued Ge ic LettersDistribution: Central File# NMSS r/f LLRB r/f EWickEKraus RECunningham ossi MTokar JSurmeierJGreeves RBangart PLo s R.O'ConnellPDR YES NO Category: Prop tary or CF OnlyACNW YES NO =_\*SEE PREVIOUS CONCURRENCEOFC :LLTB C I :IN :L L :LL :LN---- --- --- ---- --- --- ---- --- --- ---NAME:EWick* :EKraus* :RCunningham*:MToka :JSur er e .aDATE:10/19/90 :10/22/90 :10/31/90 :12/,.1/90 :12/26/90 :12/,p/90 :12/ 0(as attacimt to doc CRGR' FFICIAL RECRD COPY4*01k It is requested that waste-form mishaps be reported within 30 days of knowledgeof the incident to NRC's Director of the Division of Low-Level WasteManagement and Decommissioning and to the designated State disposal-siteregulatory authority.This request is covered by Office of Management and Budget Clearance Number:_ which expires .The estimated average burden isapproximately 8 person-hours per licensee response, including visualobservation of the waste form mishap, drafting a description of theobservation, and preparing a final mishap report for submittal to NRC.Comments on the accuracy of this estimate and suggestions to reduce the burdenmay be directed to the Office of the Management and Budget, Room 3208, NewExecutive Office Building, Washington, D.C. 20503, and the U.S. NuclearRegulatory Commission, Information and Records Management Branch, Office ofInformation Resources Management, Washington, D.C. 20555.If you have any questions about this letter, please direct themto the technical contact listed below or to the Regional Administrator of theappropriate regional office.
Sincerely,Richard L. Bangart, DirectorDivision of Low-Level Waste Managementand Decommissioning, NMSSTechnical Contract: Michael Tokar, NMSS(301) 492-0590
Enclosure:
List of Recently Issued Generic LettersDistribution: Central File# NMSS r/f LLRB r/f EWickEKraus RECunningham CERossi MTokar JSurmeierJGreeves RBangart PLohausPDR YES NO Category: Proprietary _ or CF OnlyACNW YES NOSUBJECT ABSTRXCT:OFC :LLTB E5H &kT :IM v :NRR/DOEA:LLTB :LLTB :LLWM :LLWM__-----------------------------------------------------NAME:EWick EKraus 'lfRC nningham:CERossi :MTokar :JSurmeier:JGreeves:RBangartDATE:10/i./90 10/szio :10/3//90 :10/ /90:10/ /90:10/ /90 :10/ /90:10/ /90aE~ RE* OFFICIAL RECORD COPYbeflrhec I2se 04}}