United States Nuclear Regulatory Commission - Protecting People and the Environment

Low Level Radioactive Waste Disposal (Generic Letter 80-09)


                               UNITED STATES 
                          WASHINGTON, D. C. 20555 

                             January 29, 1980 


Subject: Low Level Radioactive Waste Disposal 

Recent developments at commerical low level waste burial sites have 
substantially impacted waste disposal operations. The license to operate the
facility at Barnwell has been recently revised by the State of South 
Carolina to further limit the volume of waste buried and to upgrade the 
integrity of the waste form received at the site. Similar requirements to 
upgrade the integrity of waste forms packaged for the Richland, Washington 
burial site also have been required by the State of Washington, NRC 
licensees are required by Commission regulations to assure that wastes 
prepared for shipment are in a form that the Agreement State licensee is 
permitted to receive under applicable Agreement State regulations as well as 
meeting all pertinent NRC and DOT transportation regulations. 

The past closure of low-level radioactive waste burial sites in Washington 
and Nevada and the strict enforcement of license conditions at Barnwell have
resulted from the States' dissatisfaction with the events that have occurred
involving solid radwastes shipped from waste generators including power 
reactors, Consequently, improvements will have to be made to comply with the
State licenses. 

NRC OIE Bulletin No. 79-19, Packaging of Low Level Radioactive Waste for 
Transport and Burial, has already been sent to you regarding this matter. 
You should review your system and operating procedures to assure the strict 
adherence to the revised burial site license conditions and their 
interpretation by the State authorities. 

The enclosed license and accompanying letter from the State of Carolina to 
the site licensee, Chem-Nuclear Systems, Inc., describes the restrictions to
be adhered to for the wastes received at that site. The requirements by the 
State of Washington on waste form upgrade is similar. The following areas 
are of particular concern to the States and should be acted upon 

1)   Free Liquids in Wastes Leaving Reactor Site 

     The objective for solid radioactive wastes leaving the reactor site for
     burial is that they should contain no detectable free liquids as 
     defined by Appendix 2 of ANSI/ANS 55.1-1979. In no case however, should 
     the amount of free liquid upon arrival at the burial site exceed the 
     burial site license conditions. Free liquid determination should 
     consider the effects of transportation, e.g., vibration, freezing and 
     thawing. This requirement is applicable to both dewatered resins and 
     spent filter media as well as solidified wastes departing the reactor 

                                  - 2 -

     The following conditions (items 2 - 4) must be met for the waste to be 
     acceptable by burial sites in the States of Washington and South 

2)   Free Liquids in Wastes on Arrival at the Burial Site 

     Until December 31, 1980, provide assurance that all wastes do not 
     contain more than 1% liquid by volume upon arrival at the burial site. 
     Any liquids present in waste packages shall be non-corrosive with 
     respect to the container. Non-corrosive means conformance with 10 CFR 
     71.31, 49 CFR 173 and other DOT regulations such that there should be 
     no significant chemical, galvanic or other reaction with the packaging 

     Tests should be conducted either on simulated or actual waste which 
     demonstrate that wastes to be shipped conform to the above criteria. In
     addition, operating procedures shall be developed that implement the 
     methods to be used to assure that all wastes arriving at the burial 
     site comply with burial site free liquid licensing conditions. 

3)   Future Free Liquids Requirements 

     Effective January 1, 1981, no wastes packages shall contain more than 
     trace quantities of non-corrosive free liquids upon arrival at the 
     burial sites. Trace quantities is defined as no more than 0.5% of, or 
     one gallon in, the container volume, whichever is less. For those waste
     currently solidified by UF systems, you should prepare to meet this 
     requirement as soon as feasible before January 1, 1981. Present methods
     of waste solidification by UF systems do not provide assurance that the
     waste packages on arrival at the burial sitE contain no more than trace
     quantities of non-corrosive free liquids. 

4)   Requirements on Spent Resins and Filter Media 

     Effective July 1981, spent resins and filter media with radioactivity 
     levels above 1 Ci/cc of isotopes must be stabilized by solidification. 
     However, in lieu of solidification, other methods such as packaging 
     dewatered resins in a high integrity container (e.g., reinforced 
     concrete) may be proposed to the NRC and the States licensing the 
     burial sites. Although the South Carolina letter accompanying the 
     license amendment does not discriminate between long and short 
     half-live isotopes, it is our understanding through discussions with 
     the State officials, that only isotopes with half-lives greater than 5 
     years need to be included in the radioactivity level (i.e., greater or 
     less than 1 Ci/cc) consideration. Consequently, solidification or high 
     integrity containers would then only be required if radioactivity 
     levels exceeded 1 Ci/cc for radioisotopes with half-lives greater than 
     5 years. 
In addition, the revised South Carolina License for Chem-Nuclear Systems, 
reduces the volume of waste allowed to be buried at Barnwell. This, and 
possible future burial site problems may result in a shortage of low level 
waste disposal capacity. Consequently, licensees should take positive steps 
to minimize the volume of waste produced. To this end, each licensee should 
implement a program to minimize the generation of radioactive solid wastes 
(e.g., waste segregation) and implement methods to reduce the Volumes of 
waste which cannot be eliminated (e.g., use of trash compactors). 

                                  - 3 -

The revised requirements on waste forms may necessitate the use of mobile or
temporary solidification systems. Regulations require, that any changes to 
your solidification systems differing from your FSAR submitted for the 
issuance of your Operating License be reviewed by you in accordance with 10 
CFR Part 50.59. According to this regulation, an internal safety evaluation 
has to be prepared prior to making the facility modification. With respect 
to future changes in solidification systems, copies of the safety 
evaluations along with any addition supporting documentation concerning the 
safety adequacy of any mobile or temporary solidification system shall be 
submitted to the NRC. In addition, the appropriate revision to the Process 
Control Program (PCP) required under the model Radiological Effluent 
Technical Specifications shall be submitted for review if it has not been 
previously submitted or if it is being modified. Your PCP should be based on 
data or tests which demonstrate not only that complete solidification of 
liquid waste takes place, but that no free standing liquid exists in any 
waste container leaving your site. The PCP should also be based on data or 
tests that demonstrate that your waste will have no free standing liquid in 
excess of the burial ground license requirements at time of the burial and 
that any trace quantities of liquid are non-corrosive. The submittals (the 
safety evaluation and the revised PCP; should be made prior to the operation 
of your modified systems. 


                                   Darrell G. Eisenhut, or Acting Director 
                                   Division of Operating Reactors 
                                   Office of Nuclear Reactor Regulation 

  Letter and License from 
    State of South Carolina 

cc w/enclosure: Short Service List 

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