United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Waste Form Technical Position, Revision 1

HPPOS-290 PDR-9306210270

Title: Waste Form Technical Position, Revision 1

See the letter from P. H. Lohaus to Commission Licensees

dated January 24, 1991. Included with is the extensive

document, "Waste Form Technical Position, Revision 1",

which must be reviewed in its entirety for proper

interpretation. The document was written in the context of

10 CFR 20.311, but it also applies to the "new" 10 CFR Part

20, Section 20.2006 and Appendix F to §§20.1001-20.2401.

HPPOS-289 and HPPOS-291 contain related topics.

The regulation "Licensing Requirements for Land Disposal of

Radioactive Waste," 10 CFR Part 61, establishes a waste

classification system based on the radionuclide

concentrations in the wastes. Class B and C waste are

required to be stabilized. Class A wastes have lower

concentrations and may be segregated without stabilization.

Class A wastes may also be stabilized and disposed of with

class B and C wastes. All Class A liquid wastes, however,

require solidification or absorption to meet the free

liquid requirements. Structural stability is intended to

ensure that the waste does not degrade and (a) promote

slumping, collapse, or other failure of the cap or cover

over a near-surface disposal unit and thereby lead to water

infiltration, or (b) impart a substantial increase in

surface area of the waste form that could lead to an

increase in leach rate. Stability is also a factor in

limiting exposure to an inadvertent intruder since it

provides greater assurance that the waste form will be

recognizable and nondispersable during its hazardous

lifetime. Structural stability of a waste form can be

provided by the waste form itself (as with activated

stainless steel components), by processing the waste to a

stable form (e.g., solidification), or by emplacing the

waste in a container or structure that provides stability

(e.g., high integrity container or engineered structure).

This technical position on waste form was initially

developed in 1983 to provide guidance to both fuel-cycle

and non-fuel-cycle waste generators on waste form test

methods and results acceptable to the NRC staff for

implementing the 10 CFR Part 61 waste form requirements.

It has been used as an acceptable approach for

demonstrating compliance with the 10 CFR Part 61 waste

stability criteria. This position includes guidance on (1)

the processing of wastes into an acceptable, stable waste

form, (2) the design of acceptable high integrity

containers, (3) the packaging of filter cartridges, and (4)

minimization of radiation effects on organic ion-exchange

resins. The regulation, 10 CFR 20.311 (d) (1) [or, at

present, 10 CFR 20.2006 (d) and Section III.A.1 of Appendix

F to §§20.2001-2401], requires waste generators and

processors to prepare wastes that meet the waste

characteristics requirements of Part 61 (including the

requirements for structural stability). The recommendations

and guidance provided in this technical position are an

acceptable method to demonstrate waste stability. One way

of demonstrating conformance with the general

recommendations contained in this technical position is to

reference an approved Topical Report, because such reports

are reviewed and approved by the acceptance criteria

contained in this technical position. However, additional

actions (e.g., plant-specific process control procedures)

by waste generators will be needed to demonstrate that a

stabilized plant-specific waste stream satisfies Part 61

waste form requirements.

Since the initial issuance of the Technical Position, it

has been the intent of the NRC staff to provide additional

guidance on waste form as it became necessary to address

other pertinent waste form issues. One such issue involves

the use of cement to stabilize low level wastes. Field

experience and laboratory testing of cement solidified

low-level radioactive waste has shown that some unique

chemical and physical interactions can occur between the

cement constituents and the chemicals and compounds that

can exist in the waste materials. Therefore, an appendix

(Appendix "A") dealing with the qualification testing,

performance confirmation and reporting of mishaps involving

cement-stabilized waste forms has been included in this

revision to the Technical Position.

To provide more comprehensive guidance and cement

stabilization of low-level radioactive waste, Appendix A

addressed several areas of concern that were not considered

in the May 1983, version of this Technical Position. Thus,

information and guidance on cement waste form specimen

preparation, statistical sampling and analysis, waste

characterization, process control program (PCP) specimen

preparation and examination, surveillance specimens and

reporting of mishaps are provided in Appendix A. The

guidance provided in Appendix A is the culmination of an

extended period of study and information gathering and

exchange between NRC staff and representatives of various

organizations, including government laboratories, the

Advisory Committee on Nuclear Waste (ACNW), cement

processing vendors, other waste form vendors, nuclear

utilities, and state regulatory agencies. Especially

useful in the development of the guidance in Appendix A was

the information exchanged in the Workshop on Cement

Stabilization of Low-Level Radioactive Waste held in June,

1989. The workshop proceedings have been published as an

NRC report, NUREG / CP-0103, which is available from either

the Superintendent of Documents, U.S. Government Printing

Office, P.O. Box 37082, Washington, D.C. 20013-7082, or

National Technical Information Service, Springfield,

Virginia 22161.

Regulatory References: 10 CFR 20.311, 10 CFR 20.2006, 10

CFR 61.55, 10 CFR 61.56

Subject codes: 9.0

Applicability: All

Page Last Reviewed/Updated Thursday, March 29, 2012