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Information Notice No. 89-27: Limitations on the Use of Waste Forms and High Integrity Containers for the Disposal of Low-Level Radioactive Waste
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, D.C. 20555 March 8, 1989 Information Notice No. 89-27: LIMITATIONS ON THE USE OF WASTE FORMS AND HIGH INTEGRITY CONTAINERS FOR THE DISPOSAL OF LOW-LEVEL RADIOACTIVE WASTE Addressees: All holders of operating licenses or construction permits for nuclear power reactors, fuel cycle licenses and certain by-product materials licenses. Purpose: This information notice is being provided to inform addressees of recent actions taken by the NRC concerning the stability of waste forms (WFs) that contain Class B and/or Class C low-level waste. The actions pertain to completion by the NRC Office of Nuclear Material Safety and Safeguards (NMSS) of reviews of vendor topical reports (TRs) on waste forms containing stabilized low level wastes or on high integrity containers (HICs) for burial at low-level waste disposal sites. It is expected that addressees will review the actions listed in the attached status summary for applicability to their activities and consider actions, as appropriate, to avoid problems in disposing of certain waste streams. Addressees are also expected to distribute the notice to responsible radiological staff and waste handling personnel. However, suggestions contained in this information notice do not constitute any new NRC requirements; therefore, no specific action or written response is required. Description of Circumstances: This information notice applies to TRs that characterize solidified waste forms or high integrity containers that contain Class B and Class C low-level waste from reactor waste streams, from fuel cycle facilities or from certain by-product materials waste streams. The solidification media for the waste forms typically have consisted of cement, cement/gypsum, polymer or bitumen. The HIC materials are typically iron-chromium-nickel alloys (i.e.; ferralium or austenitic stainless steels), polyethylene-impregnated concrete, polyethylene, fiberglass/polyethylene or coated carbon steel (please refer to the status summary in Attachment 1). NRC reviews of vendor topical reports on solidified low-level waste forms and on high integrity containers are issued as Technical Evaluation Reports (TERs). A copy of each TER and the letter of transmittal to the vendor applicant is sent to the Agreement States in which the current LLW disposal sites are located. 8903020165 . IN 89-27 March 8, 1989 Page 2 of 6 Approvals of stabilization media and HICs are limited to certain waste concen- trations or to certain waste streams which are stated in the TER and the letter of transmittal. Thus, not all waste concentrations or waste streams in the original TRs have been approved. These restrictions or limitations could affect the ability of licensees to dispose of certain wastes. An example of an approved stabilization medium (i.e., waste form) is presented in Attachment 2. The TER and the TR it covers are not legal requirements. However, a user risks rejection of waste shipments by burial site operators if waste forms or HICs are generated outside the limitations of topical reports approved by the NRC. Waste generating licensees who desire to transfer low-level radioactive waste to a land disposal facility or to a licensed collector and any licensed waste processor who treats or repackages wastes are reminded that they must comply with the requirements of paragraphs (d) and (f), respectively, of 10 CFR 20.311. NRC regulation 10 CFR 20.311 requires the waste generator and/or processor, as pertinent, to certify, through the preparation of shipping manifests, that the transported materials are properly classified, described, packaged, and labeled and are in proper condition for transportation. For the purposes of this infor- mation notice, particular attention should be paid to paragraphs (d)(1) and (f)(3), respectively, of 10 CFR 20.311, where it is indicated that a licensee shall prepare all wastes so that the waste is classified according to 10 CFR 61.55 and meets waste characteristics requirements in 10 CFR 61.56. One way for a waste generator or processor to ensure compliance with the Class B and Class C waste stability requirements of 10 CFR 61.56(b) is to process the waste in ac-cordance with the provisions and limitations of the NRC-approved topical reports on waste form stability. Discussion: Background - The Agreement States* have the licensing authority for the disposal sites with respect to whether specific HICs or WFs would be acceptable for disposal at their sites. An agreement, however, was reached in 1983 between NRC and the States that NRC would provide a "central" review of TRs that would be applicable for all the disposal sites. Before the 1983 agreement, the State of South Carolina had issued ten Certificates of Compliance (Cs of C) and had under review two additional requests for approval of HICs. The State of Washington had two requests for approval. It was decided that South Carolina (Nevada and Washington had not yet issued any HIC approvals) would continue to accept the use of HICs that had already been issued a C of C. For such HICs, revocation of a C of C would take place only if a problem were identified or if new information indicated that the HICs would not meet the ________________________________ *"Agreement State" means any state with which the NRC has entered into an effective agreement under subsection 274b of the Atomic Energy Act of 1954. . IN 89-27 March 8, 1989 Page 3 of 6 acceptance criteria. For new HICs that were described in TRs submitted to the NRC, the States would not issue Cs of C until the review had been completed by the NRC; it should be noted, however, that periodic temporary approvals or "variances" for limited quantities of certain types of HICs have been granted by the State of Washington. For solidification processes, those processors who submitted information to NRC in TRs submitted before June 30, 1984 would be acceptable under a grandfathering arrangement pending completion of the NRC review. A list of HICs and solidification media that are currently accepted at Barnwell, Hanford, and Beatty can be found in Attachments 3, 4, and 5, respec- tively. Solidification media and high integrity containers shown in Attachment 1 as "discontinued", "not approved" or "withdrawn" are not acceptable for disposal unless special provisions have been arranged with the disposal site(s). A case where the NRC staff has concluded that a stabilization product is not capable of meeting 10 CFR Part 61 requirements for waste form stability, unless special provisions are provided at the disposal site, involves the use of high density polyethylene (HDPE) high integrity containers. As indicated in Attach- ment 1, such containers, as described in topical reports submitted by three vendors (Docket Nos. WM-18, WM-76, & WM-80), were not approved by the NRC. In the list (Attachment 4) of stabilization media and containers approved by the State of South Carolina, however, it is shown that (beginning in 1981) several HDPE containers have been issued Certificates of Compliance. Those containers continue to be accepted for disposal at the Barnwell site "on an interim basis" while South Carolina implements special provisions for disposal beginning April 1, 1989. NRC-licensed waste generators who wish to use polyethylene containers for the disposal of Class B and Class C wastes and who must comply with the provisions of 10 CFR 20.311(d) should either (1) place and ship the polyethylene container in an approved high integrity container (see Attachment 1 for a list of NRC-approved HICs) or (2) obtain assurance and documentation from the disposal site operator that structural stability consistent with Part 61 requirements will be provided at the site. For example, stability requirements may be met by placing the waste in an approved concrete container or structure that provides stability after disposal. The State of South Carolina has author-ized the Barnwell Disposal Site Operator to receive class B & C waste in HDPE/HICS for disposal in concrete overpacks. Waste generators desiring to pursue any of these options should contact the facility operator for procedural details. Accepted Stabilization Procedures - Licensees can ensure that Class B and/or Class C low-level wastes will be accepted for burial at a disposal site by doing one of the following: a. solidifying the waste into a form that is shown in the table in Attachment 1 as "approved" or "under review" by the NRC and which is accepted for disposal on an interim or final basis by the sited State; . IN 89-27 March 8, 1989 Page 4 of 6 b. placing the waste in a high integrity container (HIC) that is shown in the table in Attachment 1 as "approved" by the NRC and for which a Certificate of Compliance or other State Approval document, as appropriate, has been issued; c. solidifying the waste into a form (i.e., using a Stabilization Medium) that has been approved by the States of Nevada, South Carolina, or Washington for burial at the Beatty, Barnwell, or Hanford sites, as appropriate (see Attachments 3, 4 and 5); d. placing the waste in a HIC that has been approved by the State of Nevada or for which a Certificate of Compliance has been issued by the States of South Carolina or Washington for burial at the Beatty, Barnwell, and Hanford sites, as appropriate (see Attachments 3, 4 and 5). The following paragraphs discuss specific issues related to the stability of waste forms and process control procedures. Process Control Programs - Many reactor licensees are required to process wastes only in accordance with the plant-specific process control program (PCP). Generic (not plant-specific) process control procedures or programs are addressed in TRs that are also reviewed by NRC's Office of Nuclear Reactor Regulation (NRR), except as noted in Attachment 6. A summary of topical reports for radwaste volume reduction systems that NRR has approved or has under review is presented in Attachment 6. Variances in Processing Parameters - Some mixtures of wastes and solidification agents may react adversely with one another. These reactions may not be noticeable during the specimen tests per- formed before the actual solidification occurs; therefore, it is important to be alert to variances in solidification parameters specified by PCPs, such as increasing temperature of the mixture and reduced amount of solidification agent required to fill the liner or other container. An example of a situation where a licensee either operated outside the bounds of the technical evaluation report (TER) or mixed waste streams of questionable or unknown compatibility is described in Information Notice No. 88-08, "Chemical Reactions with Radioactive Waste Solidification Agents", March 14, 1988. Cement-Solidified Waste Problems - The problem identified in Information Notice No. 88-08 is symptomatic of a number of mishaps that have been observed in the field and in laboratory testing of . IN 89-27 March 8, 1989 Page 5 of 6 cement-solidified low-level waste. Such mishaps include but are not limited to waste forms that failed to solidify completely and that swelled and/or disintegrated over relatively short times after solidification. Waste streams that have caused the most concern involve bead resin, decontamination solutions, borates, sulfates, and oils. As illustrated in the example discussed in Infor-mation Notice No. 88-08, small amounts of secondary ingredients that were not anticipated to be a problem, and which may not have been known to be present in the waste at the time of processing, were later identified to be the cause of the difficulties encountered. This is a major reason why waste generators and processors should endeavor to store, handle, and process Class B and C low-level radioactive wastes within the boundary conditions, established in the qualification test programs, that are addressed in the vendor topical reports. It will be noted (see Attachment 1) that NMSS has not yet approved any topical reports dealing with 10 CFR Part 61 stability qualification testing of cement- solidified Class B or Class C wastes. This is a result of the complexity of the issues involving cement-solidified wastes. The NMSS staff plans to host in 1989 a Workshop on Cement-Stabilization of Low-Level Waste. Cement stabi- lization medium vendors, waste generators, laboratory researchers and industry consultants are expected to participate in the workshop, which is intended to provide an improved understanding of the technical concerns and which would lead to both short-term and long-term regulatory resolution. Interested persons and potential participants may contact Dr. Michael Tokar at (301) 492-0590 for further information. Suggestions regarding the workshop agenda and format are welcome. Status of Reviews - As may be seen from Attachment 1, the status of topical report reviews is subject to change as reviews are completed and as new TRs or revisions to existing TRs are submitted for review. Thus, the lists of solidification media or HICs that have been reviewed and approved by NRC and those that are acceptable at Agreement State sites may change. Waste generators should remain aware of the status of TRs reviewed by NRC so as to be informed of any limitations or change in limitations on use of solidified media and HICs. To assist the waste generators and others in this regard, updates of the status of NRC TR reviews will be issued at least annually. Licensees may obtain copies of non-proprietary versions of the TERs and non-proprietary versions of the applicable TRs from NRC Headquarters or from the appropriate NRC regional office. . IN 89-27 March 8, 1989 Page 6 of 6 No specific action or written response is required by this information notice. A summary of topical report reviews is presented in Attachment 1. If you have any questions regarding this information notice, please contact the technical contacts listed below or the Regional Administrator of the appropriate regional office. A list of recent information notices is shown in Attachment 7 for background information. John T. Greeves, Acting Director Division of Low-Level Waste Management and Decommissioning, NMSS Technical Contacts: Michael Tokar, NMSS (301) 492-0590 Charles Nichols, NRR (301) 492-0854 Attachments: 1. Topical Report Review Status Summary, Solidified Waste Form and High Integrity Containers (HICs) 2. Example of Approved Stabilization Medium and Limitations on Approved Waste Streams 3. List of HICs and Stabilization Media Currently Accepted at Beatty 4. List of HICs and Stabilization Media Currently Accepted at Barnwell 5. List of HICs and Stabilization Media Currently Accepted at Hanford 6. Topical Report Review Status Summary for Radwaste Volume Reduction Systems 7. List of Recently Issued NRC Information Notices . Attachment 1 IN 89-27 March 8, 1989 Page 1 of 1 topICAL REPORT REVIEW STATUS SUMMARY SOLIDIFIED WASTE FORM AND HIGH INTEGRITY CONTAINERS (HICs) JANUARY 5, 1989 Office of Nuclear Material Safety and Safeguards Vendor Docket No. Type Disposition Waste Chem WM-90** Solidification (bitumen) Approved. General Electric WM-88 Solidification (polymer) Approved. DOW WM-82** Solidification (polymer) Approved. Chichibu WM-81 HIC (poly impreg/concrete) Approved. Nuclear Packaging WM-45 HIC (ferralium/FL-50) Approved. Nuclear Packaging WM-85** HIC (ferralium/family) Approved. LN Technologies WM-93** HIC (stainless/poly) Approved. Chem-Nuclear WM-18** HIC (polyethylene) Not Approved. Hittman WM-80** HIC (polyethylene) Not Approved. TFC Nuclear WM-76** HIC (polyethylene) Not Approved. U.S. Gypsum WM-51** Solidification (gypsum)* Not Approved. ATI (U.S.Ecology) WM-91** Solidification (bitumen) Discontinued. VIKEM WM-13 Solidification/oil (cement) Discontinued. Stock WM-92** Solidification (cement) Discontinued. Nuclear Packaging WM-71 Solid/Encap (cement/gypsum) Withdrawn. Chem-Nuclear WM-19** Solidification (cement) Withdrawn. Chem-Nuclear WM-96** Solidification (cement) Withdrawn. Hittman WM-79** Solidification (SG-95) Withdrawn. Nuclear Packaging WM-87** HIC (316-stainless/SDS) Withdrawn. LN Technologies WM-57 HIC (polyethylene) Withdrawn. Chem-Nuclear WM-47 HIC (fiberglass/poly) Withdrawn. Chem-Nuclear WM-101 Solidification (cement #1) Under review. Chem-Nuclear WM-97 Solidification (cement #2) Under review. Chem-Nuclear WM-98 Solidification (cement #3) Under review. LN Technologies WM-20 Solidification (cement) Under review. LN Technologies WM-99 Solidification (cement/decon) Under review. Hittman WM-46 Solidification (cement) Under review. ATI (U.S. Ecology) WM-100 Solidification (bitumen) Under review. Bondico WM-94 HIC (fiberglass/poly) Under review. Babcock & Wilcox WM-95 HIC (coated carbon steel) Under review. * Had been approved for single waste stream for one year ending March 3, 1989. ** Actions completed in Calendar Year 1988. . Attachment 2 IN 89-27 March 8, 1989 Page 1 of 1 EXAMPLE OF APPROVED STABILIZATION MEDIUM AND LIMITATIONS ON APPROVED WASTE STREAMS VENDOR TYPE Waste Chem Corporation Solidification Media (ASTM-D-312 Type III oxidized bitumen) DOCKET WM-90 Approved For: WASTE STREAM(s) LIMITATION (s) Bead Resin Waste Forms must Precoat Filter Cake with Powdered Resin be prepared in Precoat Filter Cake with Diatomaceous Earth Accordance with Evaporator Concentrates - Neutralization Waste Process Control Evaporator Concentrates - Floor Drain Program (PCP) Evaporator Concentrates Decontamination Waste Waste Form in Mixed Resin and Filter Cake Waste 55-Gallon Drum or approved HIC CONCENTRATION Maximum waste loadings are as stated in Section A-3.3 of the WasteChem Topical Report, VRS-002, dated August 1987 or in Table I of Appendix A of the NRC TER dated January 22, 1988. . Attachment 4 IN 89-27 March 8, 1989 Page 1 of 1 LIST OF HICs AND STABILIZATION MEDIA CURRENTLY ACCEPTED AT BARNWELL HIC Certificates of Compliance Issued to Issued what Issued when Adwin Equipment Company 55-gallon HIC 05/29/84 Chem-Nuclear HDPE HICs (x 14) 05/28/81 Chem-Nuclear FRP HIC 02/23/82 Chem-Nuclear Overpack HICs (x3) 04/08/83 Philadelphia Electric Comp. PECO-HIC-1 09/28/81 Hittman Radlok-55 HIC 06/17/82 Hittman Radlok-100 HIC 06/17/82 Hittman Radlok-200 HIC 05/05/83 Hittman Radlok-500 HIC 09/31/85 LN Technologies Barrier-55 HIC 09/01/83 TFC NUHIC-120 HIC 11/01/83 NUPAC HDPE 142 HIC 08/20/84 NUPAC FL-50 HIC 09/26/85 Chichibu Concrete HICs (x2) 08/12/86 Vermont Yankee HDPE HIC 10/10/83 Approved Stabilization Media* Vinyl Ester Styrene Cement ** Bitumen * Processes shall meet and have been evaluated in accordance with the NRC "Technical Position on Waste Form" or other evaluation criteria specif- ically approved by the NRC. Other stabilization media shall be accept- able for which a topical Report has been prepared and approval received from the NRC and the State. ** Administrative controls at the Barnwell Site are necessary for the disposal of this waste form. . Attachment 5 IN 89-27 March 8, 1989 Page 1 of 2 LIST OF HICs AND STABILIZATION MEDIA CURRENTLY ACCEPTED AT HANFORD HIC Certificates Of Compliance (C of C) Package Identification C of C Number Manufacturer Number WN-HIC-01 Pacific Nuclear DSHS-HIC-TMI-01 WN-HIC-02 Nuclear Packaging DSHS-HIC-EA-50 WN-HIC-03 Chichibu Cement DSHS-HIC-SFPIC 200L WN-HIC-04 Chichibu Cement DSHS-HIC-SFPIC 400L WN-HIC-05 Nuclear Packaging DSHS-HIC-EA 142A WN-HIC-06 Nuclear Packaging DSHS-HIC-EA 50A WN-HIC-07 Nuclear Packaging DSHS-HIC-EA 140A WN-HIC-08 Nuclear Packaging DSHS-HIC-EA 190A WN-HIC-09 Nuclear Packaging DSHS-HIC-EA 210A WN-HIC-10 Nuclear Packaging DSHS-HIC-EA 50C WN-HIC-11 Nuclear Packaging DSHS-HIC-EA 140C WN-HIC-12 Nuclear Packaging DSHS-HIC-EA 142C WN-HIC-13 Nuclear Packaging DSHS-HIC-EA 190C WN-HIC-14 Nuclear Packaging DSHS-HIC-EA 210C Other High Integrity Containers which have been approved by the State . Attachment 3 IN 89-27 March 8, 1989 Page 1 of 1 LIST OF HICs AND STABILIZATION MEDIA CURRENTLY ACCEPTED AT BEATTY HICs Package Identification Manufacturer Number Pacific Nuclear DSHS-HIC-TMI-01 Nuclear Packaging DSHS-HIC-EA-50 Chichibu Cement DSHS-HIC-SFPIC200L Chichibu Cement DSHS-HIC-SFPIC400L Stabilization Media 1. Aztech (General Electric) 2. Bitumen* (Waste Chem and ATI) 3. Chem-Nuclear Cement 4. Concrete** 5. Dow Media (Vinyl Ester Styrene) 6. Envirostone (U.S. Gypsum Cement) 7. Westinghouse-LN Technologies Cement 8. Stock Equipment Cement 9. Hittman Grout 10. Other solidification media and processes which have been approved by U. S. Nuclear Regulatory Commission and/or the State as meeting waste form stability criteria. * Note: Oxidized Bitumen Only ** Note: Concrete when used as an encapsulation medium around a small volume of radioactive material, e.g., a sealed source centered in a fifty-five gallon drum containing concrete, shall have a formulated compressive strength equal to or greater than 2500 psi. . Attachment 7 IN 89-27 March 8, 1989 Page 1 of 1 LIST OF RECENTLY ISSUED NRC INFORMATION NOTICES _____________________________________________________________________________ Information Date of Notice No._____Subject_______________________Issuance_______Issued to________ 89-26 Instrument Air Supply to 3/7/89 All holders of OLs Safety-Related Equipment or CPs for nuclear power reactors. 89-25 Unauthorized Transfer of 3/7/89 All U.S. NRC source, Ownership or Control of byproduct, and Licensed Activities special nuclear material licensees. 89-24 Nuclear Criticality Safety 3/6/89 All fuel cycle licensees and other licensees possessing more than critical mass quantities of special nuclear material. 89-23 Environmental Qualification 3/3/89 All holders of OLs of Litton-Veam CIR Series or CPs for nuclear Electrical Connectors power reactors. 89-22 Questionable Certification 3/3/89 All holders of OLs of Fasteners or CPs for nuclear power reactors. 89-21 Changes in Performance 2/27/89 All holders of OLs Characteristics of Molded- or CPs for nuclear Case Circuit Breakers power reactors. 88-73, Direction-Dependent Leak 2/27/89 All holders of OLs Supplement 1 Characteristics of Contain- or CPs for nuclear ment Purge Valves power reactors. 89-20 Weld Failures in a Pump 2/24/89 All holders of OLs of Byron-Jackson Design or CPs for nuclear power reactors. __________________________________________________________________________________ OL = Operating License CP = Construction Permit ..
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