Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
GL80009
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
January 29, 1980
TO ALL POWER REACTOR LICENSEES
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
accordingly.
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
site.
8002140005
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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
Carolina.
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
components.
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).
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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.
Sincerely,
Darrell G. Eisenhut, or Acting Director
Division of Operating Reactors
Office of Nuclear Reactor Regulation
Enclosure:
Letter and License from
State of South Carolina
cc w/enclosure: Short Service List
