U.S. Nuclear Regulatory Commission

10 CFR 20.311, "Transfer for Disposal and Manifests"

HPPOS-220 PDR-9111220108

Title: 10 CFR 20.311, "Transfer for Disposal and Manifests"

See NRC Information Notice No. 88-16 entitled as above and

dated April 22, 1988. The manifest accompanying low-level

waste shipments must provide enough information to allow

traceability to the original generator. One acceptable

approach would be to provide, for each container, a simple

generator code (e.g., A, B, C), and refer to an attached

list for the name, address, and telephone number of the

generator corresponding to the code. The health physics

position was written in the context of 10 CFR 20.311, but

it also applies to "new" 10 CFR 20.2006.

10 CFR 20.311 [or 10 CFR 20.2006] states that each shipment

of radioactive waste to a land disposal facility must be

accompanied by a manifest that describes the waste

shipment. Among other requirements, this description must

include the name, address, and telephone number of the

waste generator. The purpose of identifying the waste

generator is twofold. It provides a source of information

about the waste if questions or problems arise, and it

enables development of a representative data base showing

factors such as actual generators, type of licensee, and

state where generated, rather than data skewed by large

volumes from brokers or waste collectors.

For waste collector licensees who handle only packaged

waste, Paragraph 20.311 (e) [or Paragraph 20.2006 (d) and

Section III.B in Appendix F to 10 CFR Part 20

(§§20.1001-20.2401)] provides two options for shipment

manifest preparation. The first option allows the waste

collector to prepare a new manifest to reflect consolidated

shipments. The new manifest serves as a listing or an

index for the detailed generator manifests, which must be

attached to the new manifest. The second option allows the

waste collector to prepare a new manifest without attaching

the generator manifests, provided the new manifest contains

for each package the information contained in 10 CFR 20.311

(b) [or Section I in Appendix F to 10 CFR Part 20

(§§20.1001-20.1401)]. Licensed waste processors who treat

or repackage waste are considered in Paragraph 20.311 (f)

[or Section III.C in Appendix F to 10 CFR Part 20

(§§20.1001-20.2401)] to be the waste generators. Waste

processors must prepare a new manifest reflecting this

responsibility.

Contrary to Paragraph 20.311 (e) (2) [or Section III.B.2 in

Appendix F to 10 CFR Part 20 (§§20.1001-20.2401)], waste

collectors who prepare new manifests for shipping

prepackaged low-level waste to land disposal facilities

have sometimes failed to either consistently identify the

original waste generators or consistently provide

sufficient information to maintain the identity of the

waste generators for each specific waste container. The

intent of 10 CFR 20.311 [or 10 CFR 20.2006] is to ensure

that each waste container delivered to a land disposal

facility is traceable to a specific waste generator. Waste

collector licensees should ensure that disposal facility

shipment manifests identify, for each container of

prepackaged waste, the name, address, and telephone number

of the person generating the waste. Similarly, land

disposal operators accepting prepackaged waste from

collectors should ensure that container-specific waste

generator information is included.

One acceptable approach would be to provide for each

container a simple generator code (e.g., A, B, C), and

refer to an attached list for the name, address, and

telephone number of the generator corresponding to the

code. Another acceptable approach would be to print the

names, addresses, and telephone numbers of the generators

directly on the manifest continuation sheets. Other

approaches are acceptable provided the required waste

generator information corresponds to individual waste

containers.

Regulatory references: 10 CFR 20.311, 10 CFR 20.2006

Subject codes: 2.1, 3.5, 9.6

Applicability: All