United States Nuclear Regulatory Commission - Protecting People and the Environment

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
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                                                            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;

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                                                            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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