U.S. Nuclear Regulatory Commission

Policy and Guidance Directive FC 86-10, "Onsite Burial by Material Licensees"

HPPOS-258 PDR-9306070112

Title: Policy and Guidance Directive FC 86-10, "Onsite

Burial by Material Licensees"

See the memorandum from R. E. Cunningham to Regional

Administrators (and Branch Chiefs, Division of Fuel Cycle

and Material Safety) dated October 9, 1986, and the

enclosed memorandum from V. Stello, Jr., to Addressees

dated September 23, 1986. Policy and Guidance Directive FC

86-10 provides updated guidance for reviewing applications

requesting authorization for licensees to bury their own

radioactive waste onsite. Applications for such

authorizations are made pursuant to 10 CFR 20.302. This

health physics position also applies to "new" 10 CFR Part

20.2002.

Since the deletion of 10 CFR 20.304, "Disposal by Burial in

Soil" (January 28, 1981), and the issuance of IEIN 83-05,

"Obtaining Approval for Disposal of Very-Low-Level

Radioactive Waste - 10 CFR 20.302" (February 24, 1983), a

number of medical, academic, industrial, and reactor

licensees have applied to the NRC for approval pursuant to

10 CFR 20.302 to dispose of licensed material by onsite

burial or disposal in offsite landfills or hazardous waste

disposal sites. The number of such licensee requests has

increased in the past few years, and because of waste

volume limitations imposed on existing sites by the

recently enacted Low-Level Radioactive Waste Policy

Amendments Act of 1985, the NRC anticipates a continuation

of this tend over the next five years.

Several Divisions within more than one office at NRC

Headquarters, as well as the Regional Offices and the

Agreement States, have within their respective regulatory

purview the responsibility for performing reviews and

technical evaluations of proposed waste disposal activities

by licensees. Consequently, it is important that a

centralized cognizance within the NRC for waste disposal

actions under 10 CFR 20.302 [or 10 CFR 20.2002] be

maintained and that NRC reviews and decisions relative to

these activities be internally consistent and uniformly

applied. Examples of areas where agency policy and action

should be consistent are as follows: the disposal of wastes

which are both radioactive and chemically hazardous, the

notification of State and local authorities of

licensee-proposed burials, the authorization of disposal of

low-activity waste offsite in the public domain, and the

authorization of disposal of potentially recyclable

materials contaminated with radioactivity.

To ensure consistency and uniformity in NRC reviews and

evaluations, the Division of Waste Management, NMSS, is

assigned responsibility to monitor all 10 CFR 20.302 [or 10

CFR 20.2002] actions. Discussions and coordination between

offices should take place for the purpose of developing

consistent criteria for acceptable waste disposal

practices. Recent guidance to non-reactor licensees

seeking authorizations pursuant to this regulation has been

published in NUREG-1101, Vol. 1. Additional guidance for

other applications which are not covered in NUREG-1101 will

be completed in the near future. Guidance for reviews of

applications from utilities for disposal of

reactor-generated waste, pursuant to 10 CFR 20.302 [or 10

CFR 20.2002], is in preparation for incorporation into the

Standard Review Plan (NUREG-0800).

NUREG-1101, Vol. 1, "Onsite Disposal of Radioactive Waste,"

March 1986, provides guidance for non-commercial disposal

by subsurface burial. It specifies information to be

provided by the licensee so that an adequate evaluation of

the application can be performed by NRC staff. In

addition, this guidance provides site parameters,

radionuclide limits, and disposal methods normally

acceptable to the NRC staff. Limiting conditions are

described for different categories of radionuclides with

respect to total radioactivity, waste packaging, burial

frequency, and other conditions normally acceptable for

burial.

Licensees applying for onsite burial authorization should

be referred to NUREG-1101 for guidance in preparing their

requests. If an application meets the guidelines of

NUREG-1101, the appropriate Region can issue an amendment

without referring the request to NRC Headquarters. A copy

of the final licensing actions plus any assessment of the

burial request should be sent to the Director, Division of

Waste Management. Any questions or special cases should be

referred directly to the Director, Division of Waste

Management.

Policy and Guidance Directive FC 84-12, Rev. 1, is being

revised to reflect the fact that burial cases do not always

need to be referred to Headquarters. Policy and Guidance

Directive FC 84-7, Rev. 1, pertaining to management of

sites containing material already buried pursuant to 10 CFR

20.304, remains unchanged.

Regulatory references: 10 CFR 20.302, 10 CFR 20.2002,

NUREG-1101

Subject codes: 9.0, 9.4, 9.7

Applicability: All