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HPPOS-291 PDR-9306210267

Waste Volume Reporting Requirements of RG 1.21 and the Need for Waste Classification Documentation

See the memorandum from S. Bahadur and L.J. Cunningham to J.H. Joyner (and others) dated December 7, 1992. The minutes of the April 1992 Reactor Health Physics Counterpart meeting identified two items requiring resolution. The first item involved a question regarding volumes and activity of low-level waste, sent off-site for processing, which should be reported per Regulatory Guide 1.21 in the reactor licensees’ semi-annual (now annual) effluent release reports (i.e., per 50.36a). This question came up again from a contractor involved in decommissioning activities at the Shoreham plant. The second item involved the need for a licensee to provide waste classification documentation for radioactive material shipped to a processor for segregation before subsequent offsite disposal. HPPOS-081 and HPPOS-290 contain related topics.

With respect to the first item, the solid waste information reported in the annual report should be the volume and activity of the low-level waste leaving the reactor site that the licensee believes will be sent directly, or via a processor or collector, to a licensed disposal site. Consistent with this response, and Regulatory Guide 1.21, Table 3, the report should identify the type of waste, the number of shipments, mode of transportation, and destination of the waste shipments leaving the licensee’s facility. If it is known by the licensee that waste shipped to a processor is to be received back following processing, the volume and activity of the processed waste would not be included in the annual reports until the waste again leaves the site for disposal.

With respect to the second item, the current regulations [10 CFR 20.311 (d) or, at present, 10 CFR 20.2006 (d) and Section III.A in Appendix F to 10 CFR Part 20 (••20.1001-20.2401] require the preparation of a manifest for transfers of radioactive waste to a land disposal facility, a licensed waste collector, or a licensed waste processor (see HPPOS-081). The term “radioactive waste,” as used above, applies to the transfer of any radioactive material for which no further use by the license is foreseen (e.g., material sent for compaction prior to disposal is waste; contaminated tools transferred for decontamination before intended reuse is not waste).

On the follow-on question, the regulations do not require a generator to classify waste being sent to a processor. Classification is only required if the generator is shipping lowlevel waste to a collector or directly to the disposal site. Note that the May 1983 Technical Position on Radioactive Waste Classification incorrectly states that transfer of waste to a processor require licensees to classify the waste. A pending revision to this Technical Position incorporates the needed correction (see HPPOS-290).

Regulatory references: 10 CFR 20.311, 10 CFR 20.2006, Regulatory Guide 1.21

Subject codes: 3.5, 9.3, 9.4, 9.6

Applicability: All