U.S. Nuclear Regulatory Commission

Waste Volume Reporting Requirements of RG 1.21 and the Need for Waste Classification Documentation

HPPOS-291 PDR-9306210267

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

Applicability: All