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