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