Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
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
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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
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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
..
