RE: Liquid waste tank decommissioning!

["Richards, David" <david.richards@rfets.gov>]

There is a good bit of precedence for using large vessels as their own
shipping containers, e.g. steam generators from decommissioned reactors. I
seem to remember that the SGs from either Shippingport or Yankee were filled
with concrete, welded shut and shipped as the "container". Also, this draft
reg seems somewhat off the wall if one considers the fact that once a drum
is filled with contaminated material, it itself becomes contaminated and
thus could be classified as LSA.

Perhaps the "empty" connotation makes the difference and if filled with
concrete or some other fixative as with the SGs it is found acceptable.
Probably a good discussion point for some of our packaging experts out
there.

DJ Richards
Hazards Assessment & Y2k Emergency Preparedness Lead
Rocky Flats Environmental Technology Site
David.Richards@rfets.gov
djrichards@earthlink.net



> -----Original Message-----
> From:	Joe Christy [SMTP:jchristy%SLAC.Stanford.EDU@inet.rfets.gov]
> Sent:	Wednesday, February 03, 1999 3:38 PM
> To:	Multiple recipients of list
> Subject:	Re: Liquid waste tank decommissioning!
> 
> At 09:10 AM 2/3/99 -0600, you wrote:
> >Hello!
> >
> >What is the procedure for putting liquid radioactive waste tanks out of
> >service? What I mean is if we were to replace an old tank with a new
> tank,
> >how do we go about getting rid of the old one ( if we have some trace
> >amounts of radioactivity still present)
> >Any suggestions or comments are appreciated.
> >
> >Thank you.
> >
> >Latha Vasudevan	
> -------------------
> Latha:
> 		           
> Depending upon the size, configuration, and components of the tank (and
> the
> amount of radioactivity remaining in the tank), some of the options that
> you may want to explore are:
> 
> 1. Decontaminate the tank for free release.
> 2. Use the tank as a "strong tight" container for the transport/disposal
> of
> LSA and/or SCO radioactive material [see 49 CFR 173.427(b)].
> 3. Recycle the tank through metal melting at:
> 	GTS Duratek
> 	Bear Creek Operations
> 	P.O. Box 2530
> 	1560 Bear Creek Rd.
> 	Oak Ridge, TN 37831-2530
> 	Customer Service: 800-663-2966
> 
> (For more info on GTS, visit their website at:
> <http://www.gtsduratek.com/>)
> 
> Joe Christy
> E-mail: jchristy@slac.stanford.edu
> -------------------------------------------------
> Latha:
> 
> Since my first posting, I did some research on option #2 above.  
> 
> According to a joint NRC/DOT draft guidance on LSA and SCO material
> (NUREG-1608), neither LSA or SCO can be used as their own packaging.  So,
> if the "empty" tank meets the definition of LSA or SCO (see 49 CFR
> 173.403)
> than it cannot be used as a "strong tight" container for the
> transport/disposal of other LSA and SCO material.    
> 
> The draft NUREG gives the following example:  A shipper might have
> large-diameter steel pipes that are internally contaminated.  The shipper
> would not be permitted to package LSA radioactive material inside the
> pipes, install ends on the pipes, and present the pipes with contents for
> transportation as LSA.  The reason:  the contaminated pipes are themselves
> considered to be contents requiring categorization and packaging for
> transportation.  This constraint also applies to large process vessels.
> Thus, a large vessel having no external radioactive contamination, but
> having contaminated internal surfaces, even if subsequently filled with
> LSA
> or other SCO, is considered to be radioactive material subject to the
> regulations of DOT and NRC for packaging and transportation. 
> 
> I have heard that this NRC/DOT guidance document has been issued as
> RAMREG-003 (a DOT guidance document) but I have not been able to put my
> hands on it.  The final guidance may be significantly different from that
> presented above from the draft document.  So, option #2 may still be a
> possibility. 
> 
> One final note:  Under certain situations, LSA and/or SCO can be shipped
> in
> bulk packaging with the conveyance serving the function of the "strong
> tight" packaging. Specifically, LSA-I and SCO-I material can be shipped in
> this manner [see 49 CFR 173.427(c)].  So, if the tank were filled with
> solid low-level waste and the filled tank met the definition of LSA-I or
> SCO-I material, then the tank could be used as a receptacle for
> LSA-I/SCO-I
> waste material provided it were shipped on a conveyance that met "strong
> tight" packaging criteria (e.g., in a closed transport vehicle).     
> 
> Sorry for any confusion. 
> 
> Joe
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