Process Control Program Addendum

[Charles Willis <CAW@nrc.gov>]

Good Morning,

In discussing the PCP, I should have mentioned the topical report review
program.  When Part 61 was new, numerous solidification systems
were being offered by various vendors.  It was not clear, however, that
all (or any) had the required data to demonstrate meeting the criteria of
the NMSS paper on waste form.  The NRC undertook a program of
reviewing topical reports on these systems.  Both the demonstration of
compliance and the review of the reports proved to be formidable tasks.
 
Some 22 topical reports on solidification methods were received and
some were revised several times.  Eventually, five solidification topical
reports were approved (two used polymer and two used bitumin).  No
solidification  system based on concrete was ever approved.  A few
years ago the NRC program for the review of topical reports was
discontinued for lack of resources.

This leaves the licensees with the burden of proof that the solidification
data requirements are met.  The data and associated limitations on the
process need not be in the PCP but should be referenced there.  

The PCP and wet waste solidification issues are on the back burner at
the moment, but I believe there is a high probability that something will
happen in the next few years to change that.  It seems likely that, when
caught in the spotlight, the licensee with the  more complete PCP will
suffer least.

These are my recollections and opinions, of course; nothing official.

Charlie Willis
caw@nrc.gov