U.S. Nuclear Regulatory Commission
Waste Volume Reporting Requirements of RG 1.21 and the Need for Waste Classification Documentation
Title: 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 low-level 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