ML19345H099
| ML19345H099 | |
| Person / Time | |
|---|---|
| Issue date: | 09/12/1980 |
| From: | Miller V NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19345H095 | List: |
| References | |
| FOIA-81-105 NUDOCS 8104300491 | |
| Download: ML19345H099 (8) | |
Text
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h ['d UNITED STATES NUCLEAR REGULATORY COMMISSION j(i gg WASWNGTON. D. C. 20555 t-
- $g SEP 121980 TO ALL IflDUSTRIAL LICEtiSEES
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There are a number of steps licensees engaged in industrial uses of licensed material can take under tiRC rules to substantially reduce, and in some cases eliminate, the need to send radioactive waste to commercial low-level waste disposal facilities.
By taking advantage of these alternatives and following good waste management practices, licensees can often reduce the risk of having their programs impacted through further curtailment of commercial waste disposal facilities. Some of the more important steps that can be taken are to:
1.
Segregate radioactive waste from non-radioactive waste to reduce unnecessary volume. This simply requires a little time and discipline in use of radioactive materials at a licensee's facility.
2.
Compact radioactive waste to the extent practicable to reduce volume.
3.
Hold waste with short-lived radionuclides in storage for decay to background levels, then dispose of it in the ordinary trash. This procedure requires a license amendment unless your license already contains provision for this method.
(See for information to be submitted with the amendment request).
4.
' Release certain materials into the sanitary sewage system in accordance with 10 CFR Part 20.203. No license amendment is required but 10 CFR Part 20.203 should be carefully reviewed to stay within limits.
5.
Industrial licensees who use relatively long-lived sealed sources in general may only dispose of their sources by transfer to an authorized recipient. However, even in cases where only sealed sources are used, if the half-life of the source is less than 90 days, considerations should be given to holding the source in storage until it decays to background.
Judicious use of these five steps can substantially reduce the volume of waste shipped to burial grounds.
Some industrial licensees using only short-lived radionuclides can eliminate waste shipments.
Waste from industrial licensees involved'in biomedical research or similar activity is generally somewhat more difficult to manage.
Two of the most common problems are disposal of liquid scintillation counting waste (LSCW) and animal carcasses. The most frequently used radioisotopes in both are tritium and carbon-14.
LSCW presents a particularly troublesome problem due to the flammability and toxicity of the solvents.
Disposal of LSCW has been given special consideration by flRC. The staff has investigated alternatives to managing these wastes and the results have been published in HUREG-0656.
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Consideration should be given to disposal by incineration for LSCW and laboratory animals containing small amounts of tritium and carbon-14.
This method requires a license amendment; 10 CFR Part 20.305 contains the provisions for incineration. Enclosure 2 identifies the information to be submitted with an amendment request for incineration.
There are other provisions in the regulations that cover waste disposal.
We have mentioned only the few that are most easily and comonly used.
Other regulatory prov.isions include:
4 1.
Disposal by burial in soil in accordance with.10 CFR 20.304 (A proposed rule change is under consideration to delete this provision.
It will likely be replaced by a prov.ision which requires specific approval by license amendment for burial).
t
'2.
Release as effluents to unrestricted areas pursuant to 10 CFR Part 20.106.
In keeping with the ALARA concept, this method should normally be used only for releases incident to the
.l procedures involved.
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We suggest that you review and consider alternatives to commercial land burial for the management of your low-level radioactive waste.
Implementation of some of these alternatives such as compaction, hold for decay and incineration may require an amendment to your license. Amendment requests should be submitted to the Material Licensing Branch through -the use of normal channels.
If you have any questions concerning what actions require an amendment to your license or any other questions concerning i
NUREG-0656, they should be directed to the Material Licensing Branch (301)427-4228. Copies of the NUREG-0656 may be obtained from the Division of Technical Information and Document Control, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555..
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Sincerely, i
~
b 7'9, 6M Vandy L.
Material;[ Iller,Chiefpdensing Branch o
9 i
Division of Fuel Cycle and i
L Material Safety I
Enclosures:
l.
Information to b'e submitted When Requesting Amendment to Dispose of-Radioactive Waste by Decay-In-Storage.
2.
Information Required for Commission Approval of Treatment or Disposal by Incineration.
s.'
Information to be Submitted When Requesting Amendment to Dispose of Radioactive Waste by Decay-In-Storage Method
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This is in reference to your request for information concerning authorization to dispose of radioactive waste via decay-in-storage.
In order to approve such an amendment request, we need the following information:
1.
Please submit a diagram of the area where the waste will be decayed-in-storage. Show the type, location, and thickness of shielding that you will have available in this area of your diagram.
Identify adjacent unrestricted areas located across the walls from the storage area and chow that adequate steps have been taken to assure that radiation levels do not exceed the limits specified in 10 CFR 20.105 (enclosed).
2.
Describe your security measures for the decay-in-storage area.
3.
Confirm that radiation levels in this area will be surveyed and recorded at least weekly.
4.
Describe your procedures for monitoring the waste to assure that it has decayed to background levels prior to disposal. As a minimum, your de-scription should include these points:
a.
Monitor the waste in a low background area.
b.
Monitor with a low level GM type survey meter as appropriate for contamination surveys.
Use the most sensitive scale.
c.
Remove all shielding prior to monitoring.
i d.
Maintain records of these surveys as required under 10 CFR 20.
Be certain to submit your amendment request in duplicate. Unless your activity is fee exempt, your request should be accompanied by the appropriate l
amendment fee.
Refer to 10 CFR 170.
1 l
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IrlFORMATION REQUIRED FOR C0W11SSION APPROVAL OF TREATMENT OR DISPOSAL BY INCINERATION Revised October 3,1979 1.
State specifically the isotopes you wish to incinerate.
For each isotope listed, you should submit calculations demonstrating that air concentrations of the effluents at the stack are in accordance with the requirements of Section 20.106 of 10 CFR Part 20.
2.
Submit the characteristics of the incinerator such as het iht of the stack, height of and distance to buildings in the surroun-:ing areas, rated airflow of the incinerator in cubic feet per hour or similar units and its proximity to any air intake ducts.
3.
The gaseous effluent from the incinerator stack should not exceed the limits specified for air in Appendix B Table II,10 CFR Part 20, when averaged over a twenty-hour (24) hour period.
4.
In order to be in compliance with the ALARA philosophy stated in Section 20.1(c) of 10 CFR Part 20, the gaseous effluent from the incinerator stack should be a fraction (approximately 10") of the limits specified for air in Appendix B. Table II,10 CFR Part.20, when averaged over a one year period.
5.
Describe the method of measurement or estimation of the concentration of radioactive material appearing in ash residue.
6.
Describe the procedures for handling and disposing of ash from the incinerator.
7.
Describe procedures to be followed to prevent overexposure of personnel during all phases of the operation, including instruction given to personnel handling the combastibles and the ash.
8.
State the maximum number of burns to be_ performed in any one week l
and the maximum number of burns per year.
9.
Submit confirmation that you have complied with all state and local regulations concerning incineration.
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UNITED STATES og NUCLEAR REGULATORY COMMISSION 2
o WASHING TON,0. C. 20555
-E NOVEMBER 1980 k...,*/
INFORMATION NEEDED IN AN APPLICATION FOR BURIAL OF RADI0 ACTIVE WASTE IN SOIL BY INDIVIDUAL LICENSEES The Nuclear Regulatory Commission (NRC) has amended its regulations to delete Section 20.304 of 10 CFR Part 20 which provided for disposal of radioactive material by burial i, soil. The Federal Register Notice dated October 30, The 1980, pertaining to this action is enclosed for your infonnation.
purpose of the deletion of Section 20.304 is to minimize burials by individual licensees because of the uncertainties associated with assessing the risk of burials under Section 20.304 and the need to protect public health by improving data regarding amounts and 1ccations of butied radioactive materials.
The policy of the NRC is that the burial of radioactive waste by licensees be specifically authorized pursuant to Section 20.302 of 10 CFR Part 20.
Any current licensee now burying radioactive waste without such authorization must file an application pursuant to Section 20.302 of 10 CFR Part 20 and receive NRC approval for continued burial by January 28, 1981.
Since the purpose of deletion of Section 20.304 is to minimize waste burials by individual licensees, it is incumbent on the applicant to demonstrate that local land burial is preferable to other disposal alternatives. Convenience and lesser cost than other disposal methods will not, by themselves, be con-sidered acceptable justification for burial of waste pursuant to Section 20.302.
The amendment to delete Section 20.304 does not affect material already buried, material held under general license for which there is an exemption from the requirements of 10 CFR Part 20, and material held under an exemption frca NRC regulatory requirements.
In addition to the demonstration of justification for burial, the following information should be included in the application for burial:
1.
A description of the type and quantity of material to be buried.
Isotopes and estimated quantity of each isotope for any a.
one burial, b.
The nt.mber of burials anticipated annually, The estimated volume of' waste per burial and annually.
c.
d.
The physical form (s) of the waste.
2.
Packaging for the waste.
As a minimum, waste should be packaged in strong, tight containers which would preclude loss of the contents.
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Acceptable containers would include, for example, 55-gallon steel drums or steel boxes which would not be readily susceptible to
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corrosion.
Cardboard or wooden boxes would.iot be considered suit-able containers.
If packaging is not contemplated, an explanation bp and justification for not packaging should be submitted.
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i 3.
Burial location.
In general, only burial sites which are located.
on the property of the applicant will be considered acceptable.
The nature of the waste proposed to be buried should be such that i
long-term site control is not necessary for protection of public health and safety. A map or sketch of the applicant's property which shows specifically where on the property burials will be made should be submitted.
4.
Nature of the burial site.
An analysis of the adequacy of the.
site which demonstrates that transport of radioactive material away from the site is highly unlikely to occur must be submitted.
Information which should be included in the analysis is the nature of the environment, including typographical, geological, hydrological, and meteorological characteristics of the site; usage of ground and surface waters in the general area; and the nature and location of other potentially affected facilities. The water table should be a minimum of 10 feet below the depth at which the waste will be buried.
The 10 foot depth should be the high point for the water j
table.
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5.
Depth of burial. The depth at which waste will be buried should
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l be specified. As a minimum, the burial depth should be at least four feet below the surface.
6.
Restriction and sosting of burial sites. The means for assuring i
that access to t1e burial site will be limited to authorized 1
personnel should be described. An acceptable method for access restriction would be an 8 foot chain link fence around the site posted with " CAUTION-RADI0 ACTIVE MATERIAL" signs.
t 7.
Radiation safety procedures.
The specific program for handling j
the waste to be buried including radiation safety precautions to be followed, should be submitted.
I 8.
Recordkeeping.
The program for maintaining records of burial should be described.
9.
Local requirements. The contacts made with local officials to determine the extent to which local laws and requirements could l
affect burial of radioactive waste should.be described.
It is I
the responsibility of the applicant to assure that all local i
requirements are met.
i Section 30.34(f),10 CFR Part 30; Section 40.41(f),10 CFR Part 40; and Section 70.32(b),10 CFR Part 70 require notification in writing when the l
licensee decides to permanently discontinue all activities involving materials.
Therefore, if for some reason a licensee intends to abandon, sell, transfer or otherwise give up control of the burial site, the NRC must be notified.
For further information, you may contact Mr. Vandy L. Miller, Chief, Material Licensing Branch, Division of Fuel Cycle and Material Safety (Telephone (301) 427-4002),
i l
1 Federal Register / Vol. 45. No. 212 / Thursday. October 30, 1980 / Rules and Regulations 71781 NUCLEAR REGULATORY improperly buried or disturbed after not significant!y affect the quahty of the COMMISSION buttal For eaample. I 20 304 a!!aws human enstrenment.
burial of up to one mil!!curte of cobalt.
Public Commer.ts 10 CFR Part 20 eo. As a point source this quantity delivers a dose rate of over 100 In reaching the dectston to delete Standards for Protection Agalnat milhrems per hout at a distance of to l 20.304. the Ccmm!seien considered Radiation; Burial of Ernau QxntJtles of centimeters. If a burial site were public comrnents received on the Radionuclides disturbei and a person carne into propened ru!e change. These comments Ao Ncy: Nuclear Regulatory contact with one mi!!! curie of cobalt.60 and the impact of deletion of I 20 304 Coinmission.
for an extended pertoi an es eremposure are discussed in the value. impact could occur.
assessment, which is asailable for AcTicN: Final rule' The Commission has concluded that if inspection or eepying for a fee at the NRC Pubhc Document Room.1777 H suuuAity: ne Nuclear Regulatory
- s mappropriate to cont:nue genenc Commission is amening its regulations authenratJon of bunale pursuant to Street. Washington. D C. 20553. The to reguire NRC !!censees to obtain i 20 304 without regard to such factors major pubhc comments received are i
discus sed be!ow.
spect.4c approval to bury small as tocation of bunal cencontrations of I
quantities of rad!onuc!Jdes. Curnnt NRC raicactive matettal form of packsamg.
Thirty e!ght sets of public comments regulauens provide that !!censees may and nott!! cation of NRC.Therefore, the were received on the proposed deletion of I 20.JS4 Seventeen commenters bury certain small quantities of Comrn.ssion will require that licensus favored deletion. fourteen opaesed radionuclides without prior approval obtain prior appros allor new bunals of de!etion, and seven took no ciear The amendments w111 provide gnator the type currently allcwed by 1 20 304.
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'IC# CO**'"I' DEE* *"I assurer.ca that buried radioactive and accoringly 120.304 is being EC'#**'are:("1) Burials pursuant to j
deletion material will not present z henjth deleted from NRC regulations. Pnor i 20 304 do not represent a pub!!c heahh hazard review of proposed burtais will result in prob!em. (2) dapesal of wastes at erncTNE Daft: January 28.1981.
improved records regating amounts commercial buttal grounds is not a good Note-The Nuclear Regulatory and locations of future banals of ahernauw becaun H 18 too upensM.
Comm!ssion hu submitted tMa rule to the radioactive matertal and provide H cah He cwn %. and the Ccmptro'ler General for sach rmew as meF grestor assurance that burted material commercial sites are overburdened and u appregnate under the rederal Reports wtli not present a health harard at a (3) NRC has not adeqwstely out!!ned Act, as amended, a4 UAC.3512. na date on which the toporting requirement of tha rule later date,.Thus, the risk of exposure of requirements for obtaming spectfic individua.s accidentally isturbing approvals for bunals.
becorns effective, unlus advtaad to the buned radioactive wsste would be 1.Pubhc hechh risA. Several contrary.ref'ects inclusion of the 4s-day period which that statute a!1ows for euch reduced comments from institutiona performing revtew (44 UAC. sstztcl(2D.
The Commission staff estimates that buttals pursuant to i 20.304 provided i
ren runTwas mrosuarsoes coartAcTt fewer than 100 ticensees (out of about infctmation on their cperations, Mr. John W. N. Hickey. Office of 20.000 NRC and Agreement State Indicating that thee buttal sites are safe j
Standards Development. U.S. Nuclear heensees) are performing buttale because they are owned by the licensee.
Regulatory Commissiott, Washington, a!!cwed by 120.304. NRC licensees will fenced and markeilocated in areas of D C. 20553 (phone: 301-44S4006).
have 90 days to halt bunals and epplY low risk of ground wster contamination, sWPMastENTAnY IMf0AMAfsoec On for specific approval to resame bunals or contain short. lived radionuc!! des in i
December 4.1978. the Nuclear pursuant to to CFR 2a302, or usf waste withlow specif!c activt y.
Regulatory Commission (NRC or afternatfve disposal methods such as Nevertheless. as discussed previously.
Cemm!ssion) proposed to delete 1 20.304 transfer of waste to licensed commercial the radionuc!!de quantattes invohed are of 10 CTR Part 20. *$tandards for burial grounds. The NRC staff will potentf ally large enough to cause Protection Against Radiation"(43 FR provideJnformation to Lcensees as significant raiatten exposures,if they 56677). Section 20.304 allows !!censees appropriate related to obtainin8 are concectrated point sources, and the to bury certain einall quantities of approval for burials. Deletion of to CFR Commission has decided that case.by-i radionuclides without prior NRC 20 304 will not affect material already case review of proposed burials is
- roval buried. genera!!y licensed and exempt appropriate.
I a;As discussed in the notice of proposed
- material orlicensees who have already
- 2. CJmretc/olbuciolgreur da. Many rulemaking, several State obtained specific approval to perform commenters incorrectly mterpreted the representatives have suggested that the bunals pursuant to to CFR 20.3c2.
proposed rule to mean that local burtal risk from burials of radioactive waste Agreement State licensees will not be would be prohibited and that all waste allowed by 120.304 may be directly affected by the !!nal rule.-
would have to be shipped to con.mercial I
unacceptable. The qur ntities of because they are subject to tedividual burial grounds. The Commission is not.
a raionuc!! des allowed to be buried State regulations rather than NRC requtring that all radioactive waste pursuant to i 20.304 are 1.000 times regulations.However. Agreement Stste affected by deletion of I 20,304 be greater than exempt quantities. Such offtetals have cons!stently supported shipped to commeref al burial grounds quantitles pose a small risk if they are deletion of I 20.304, and the Commission Licensee proposals for waste dispcsal j
preperly buried and left undisturbed anticipates that those States which have will be reviewed on a case by. case particu!stly if they are dispersed not already done so will make changes basis, including consideration of risk through a large volume of waste in their regu!stions compatible with and economic costs. This is consistent rnatenal. However, t 20.304 imposas no deletion of I 20.304.
with 1201(c) which provides that concentration limits. and the quantitles As discussed in the notice of propcsed hcensees shcu!d make every reasonable
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as concentrated " point sources" are rulemaking. the Commission has effort to mamteln raiation expcsures as potentially large enough to cause determined that an envirentnental low as is reasonably achievable. where excessive radiation expoeures if the impact statement need not be prepared "as low as is reasonab!y achfevable" q
. radioacnve matertal ls mishandled, because deletion of to CFR 20 304 will includes taking into account economics y
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D-71762 Federal Register / Vol. 45. No. 212 / Thursday. October 30. 1980 / Rules and Regulations of improsement m relation to benefais to demakins Until new regu!ations are the public health and safety.
deseloped. apphcations for weste II,,,
Seieret bcensees performmg bunals disposal will be reviewed accordmg to pursuant to i 00 304 comrnented that it i 20 302. which requires hsensees to (3) Records of disposal oflicensed woud be too espensae to ship was'es
'd*d 'nformation describing the waste matertal made pursuant to il M302.
to commercial bunal sites and 1 i48 in matenal. the lesels of radioactivity 20 303. and deleted i 20.3048are to be 5
any c.ne the sites are al ready msohed, the proposed conditions of maintained until the Commf ssion overburdened Estimates of the entra daposal, the enuronment of the authorizes their dispositjorL costs and volumes of waste insohed disposal site. and procedares to be rinued from $400 to $21.000 and *0 to obscrsed to m nimize the nsk of
's.o.on m me pr.md.d toe tmnet et sman w d he.<l miemte is smL Nonce of tie bM10 t ubic feel per year !! should be unespected or harardous esposures detewn enem in the F. del Regiss.e of Odober noted that (1)The staff estimates that Pursuant to the Ato nic Energy Act of sa tee (as nt g frwer than 100licen*ees am performiras IM4 as amended, the Energy burials purs94nt to i 20 304. (21 untal Reorganizat;on Act of 1974. as amende
- 4. The note following Appendix C of to CTR Part 20 is amended to read as recently about 3 0u0 0n0 cubic feet of and section 553 of title 5 of the Unned gg0*','
radioactne waste were be:ng shspred Siates Code. the fo!!cwmg amendments annually to r.ommercial sites. and (3)
'o Title 10. Chapter 1. Code of Feder41 App.nds C ment mstitutmns s.mdar to those usine Regulanons. Part 20. are pubbshed as.
document sub ect to codshcation.
l Note.-For purposes of I mat, when I 20 304 are usar a comtr.crcial dispos.1 sites Therefere. while certam hcensees i 20 30a (Remoyed) there is involsed a combmation ofisPopes in 94v wnh to dispose of high4olume.
known amounts, the limit for the ccamation
- 1. Sech n Disposal by bunal n should be densed as follows: Determine for sl#t!v con ammated waste b) Incal but:al'fnr justifiable eennamic reason'.
. paragraph (c)le revised each is tope in the combination. the ratio be: ween the quenoty present in the n man) e ases I.censees could ship icw to read as goggows:
s clume waste to ccmmercial sites at combination and the Lmit otherwise reasonable cost without adding l 20.301 Generat roquireenent.
'bbshed for the specific isotcpe when not sianifwantly to the total solume in combinatiorL The sum of sach ratios for all d
h the isotopes in the combmetion may not
[he Co n ecognizes prublems (c) As provided in I m303, applicable,se,,a y gi.e, uruty l.
rn.ss associated with closses or reduced to the disposal oflicensed material by rapacey of commete al burtal grounds release into sardtary sewerage systema. (Sec.161. b. and L Pub. L 83-703. os Stat. 944g This insar afferts all Lcensees disposme or in i m106 (Radioactivity in effluents
,ec. :01. Pub. L 93-438, as Stat.1243 (42 of tow.lesel radioactne waste. not sust to unrestricted areas).
U.S C. : 01. sa411) burials pursuant to i 20.304.The
- 3. In i 2401. paragraphs (b) and (c)(3)
Dated et W.stungeon. DC this :4th day of Commisuon staff wdl of course. take are revised to read as follows:
October tano.
mto acrount :he status of commercial For the Nuclear Regulatory Commisuon.
g bunal sites m making any bcensmg
$4muel l. Chilk.
decmons reptd.ng d.sposal of mon to% W mpoest.
Secretary of the Commission.
radioactne waste.
3 Cr;tena for dwesol. As d.scussed (b) Each licensee shall maintam d"** ** "'28 N " * *s.q in the not. e of proposed rulemakmg ncords in the sarne umts used in this.
'" CCC" ""
the Commission is reuewing custmg part. showmg the results of surveys oolics on disposal of10w-lesel required by 5 20.301(b). monitonng radioactne waste and deselopi.,g new required by { { m205(b) and 20.205(c).
regalat.ons These wdi be pubhshed in and disposals made under il 20.302.
separaste notices of proposed 20.303, and deleted i m304.s,
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