United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Technical Assistance Request, Department of the Interior, Salt Lake City, U T; Apparent Request to Store Low-Level Waste for Decay for a Time in Excess of Five Years

HPPOS-278 PDR-9306140198

Title: Technical Assistance Request, Department of the

Interior, Salt Lake City, UT; Apparent Request to Store

Low-Level Waste for Decay for a Time in Excess of Five Years

See the memorandum from J. E. Glenn to L. J. Callan dated

October 22, 1991. This memo responds to a technical

assistance request from Region IV, dated June 26, 1991,

regarding the Department of the Interior, Salt Lake City

Research Center's apparent request to store for decay for a

time in excess of five years (enclosure). The respond to

the TAR was coordinated with the Division of Low-Level

Waste Management and Decommissioning (LLWM). HPPOS-239 and

HPPOS-264 contain related topics.

The licensee stated in the amendment request: "... that

shipping will not be done if the radioactive decay renders

the waste low enough in activity to be disposed of as

regular waste." This statement makes it unclear whether it

is for interim storage pending availability of a waste

broker for disposal in a licensed site, or for

decay-in-storage. At the time of storage, waste must be

identified as interim storage or decay-in-storage, and

segregated as such.

Waste designated as interim storage must be disposed of at

an NRC authorized low-level waste disposal site or

transferred to a licensee authorized to receive the waste.

The commission has said that it will not look favorably

upon long term on-site storage beyond January 1, 1996, for

waste destined to a licensed disposal site. Therefore, if

the licensee states that it is intending to eventually send

the waste to a licensed disposal site, it should be asked

to justify a storage period that exceeds January 1, 1996.

It should be noted that Utah is a member of the Northwest

Compact region. The licensee has a disposal site available

to it. We assume that the motivation for the request is

the lack of a broker (see Item 11, Paragraph 3.b.1. of the

licensee's submittal).

Waste designated for decay-in-storage should be held for a

minimum of ten half-lives or longer, depending on the

isotope and total activity, before disposal in regular

trash. Requests for decay-in-storage that extend beyond a

five-year period are not looked upon favorably.

Before the request can be approved, the licensee must

specify more clearly how its waste will be identified,

segregated, and what it intends for disposal. The license

amendment request will not require an environmental

assessment according to 10 CFR 20.301 (B), 10 CFR 30.41 (b)

(7), and 10 CFR 51.22 (c) (14) (v).

Approval was recommended provided four conditions were

followed. First, the licensee specified how waste will be

identified, segregated, and disposed. The licensee should

also show that the waste would not be held greater than a

five-year period. Second, that guidelines outlined in

Policy and Guidance Directive FC 90-03; "Licensing of

low-level Radioactive Waste Storage of Materials and Fuel

Cycle Licensees" were followed as appropriate (e.g., were

current possession limits adequate for the waste to be

stored up to five years?). Third, survey procedures and

instrumentation used for monitoring waste before disposal

were reviewed and approved. Finally, specific isotopes

with half-lives between 65 and 120 days must be listed on

the license. If sulfur-35 is the only radioactive material

with a half-life greater than 65 days to be held for

decay-in-storage, then it would be appropriate to revise

the standard license condition to specify 90 days, rather

than 120 days.

Regulatory references: 10 CFR 30, 10 CFR 40, 10 CFR 70

Subject codes: 3.4, 9.0, 9.6

Applicability: Byproduct, Source, and Special Nuclear


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