United States Nuclear Regulatory Commission - Protecting People and the Environment

Storage of Low-level Radioactive Wastes at Power Reactor Sites (Generic Letter 81-38)

                                                          GL 81-38

                                UNITED STATES 
                            WASHINGTON, D.C. 20555

                              November 10, 1981


          SITES (Generic Letter 81-38)


As a result of a reduction in waste disposal availability in the United
States, many nuclear power reactor licensees are taking or are planning to
take steps to provide for additional onsite storage of low-level radioactive
wastes generated onsite.  These steps range from storing packaged wastes in
unused space to construction of new facilities for volume reduction and
extended storage.  The NRC has been considering the variety of plans which are
underway and how they should be reviewed and approved.

Actions on waste storage can influence the development and implementation of
final disposal plans by states, acting individually or on a regional basis, to
establish additional disposal capacity.  Some states have indicated to NRC
that utilization of disposal services by nuclear power plant licensees is
essential if disposal sites are to be developed by states or regional
compacts.  Thus, it is important that the NRC not take deliberate action that
would hinder the establishment of additional disposal capacity by the states
and yet, consistent with NRC regulatory safety requirements, permit necessary
operational flexibility by its licensees.  It is with these points in mind
that the following guidance is provided.

For proposed increases in storage capacity for low-level waste generated by
normal reactor operation and maintenance at power reactor sites, the safety of
the proposal must be evaluated by the licensee under the provisions of 10 CFR
50.59.  If (1) your existing license conditions or technical specifications do
not prohibit increased storage, (2) no unreviewed safety question exists, and
(3) the proposed increased storage capacity does not exceed the generated
waste projected for five years, the licensee may provide the added capacity,
document the 50.59 evaluation and report it to the Commission annually or as
specified in the license.



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Radiological safety guidance has been developed by the staff for the design
and operation of interim contingency low-level waste storage facilities. 
Necessary design features and administrative controls will be dictated by such
factors as the waste form, concentrations of radioactive material in
individual waste containers, total amount of radioactivity to be stored, and
retrievability of waste.  A copy of the guidance document is enclosed with
this letter.  This guidance shall be used in the design, construction and
operation of your storage facility.  In addition, the NRC will judge the
adequacy of your 50.59 evaluation based on your compliance with the guidance. 
Please note also that IE Circular No. 80-19, dated August 22, 1980, provides
information on preparing 50.59 evaluations for changes to radioactive waste
treatment systems. 

If you determine that an unreviewed safety question exists, authority for use
should be requested through application to the Office of Nuclear Material
Safety and Safeguards (NMSS) pursuant to 10 CFR 30, accompanied by an
environmental evaluation that considers the incremental impact as related to
reactor operations.  Such application for a separate Part 30 license is for
the administrative convenience of the Commission and is not intended to be
substantively different than an application for amendment of the facility
operating license.  Application for use should also be accompanied by a
showing that the storage provisions will not impact on the safety of reactor
operations and will not foreclose alternatives for disposal of the wastes.

NMSS will notice the receipt of application in the Federal Register, offer an
opportunity for public hearing if significant public interest is demonstrated,
and will perform an environmental assessment to determine if the proposed
activity will significantly affect the quality of the environment.  Facility
construction prior to the staff's determination would be carried out at the
licensee's risk.  Any license issued will be for a standard five-year term,
renewable if continued need is demonstrated and if safety of continued storage
is established.  NRC licensing jurisdiction will be retained in Agreement
States in accordance with 10 CFR 150.15(a)(1) for storage of low-level waste
generated and stored onsite.  Indemnity agreement with the Commission.

If it is determined that the storage provisions could impact on the safety of
reactor operations or an existing license condition or technical specification
limit on the amount of waste storage, a change in the conditions of the
reactor facility license may be necessary.


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The provisions for added capacity should be used only for interim contingency
storage, and low-level wastes should continue to be shipped to disposal sites
to the extent practicable.  The "Low Level Radioactive Waste Policy Act" of
1980 gives primary responsibility for the disposal of low-level waste to the
states.  Some states have initiated disposal plans, and we believe it is
important that power reactor licensees, as major waste generators, work with
and provide technical assistance and other support to assist individual states
or regions in developing new disposal sites.  You are encouraged to take an
active role in the development of additional disposal sites.

Some licensees are considering the installation of major volume reduction
processes, e.g., incineration, dehydration, or crystallization to
substantially reduce the volume of waste for disposal.  You are encouraged to
examine the costs and benefits of such processes for your operation.  However,
notwithstanding the use of volume reduction, you are also encouraged to take
an active role in the development of additional disposal sites.

For proposed increases in storage capacity for more than five years
(long-term), the application and review procedures will be pursuant to 10 CFR
30 with consideration of container integrity and retrievability, volume
reduction, influence on state planning for disposal, and implications for de
facto onsite disposal.  Any long-term license issued will be for a five-year,
renewable term.

If you have any questions about these matters, please let us know.


                                   William J. Dircks
                                   Executive Director
                                     for Operations

Guidance Document




I.    Introduction

      The objective of this technical position is to provide guidance to
licensees considering additional onsite low level radioactive waste storage
capabilities.  While it may be prudent and/or necessary to establish
additional onsite storage capability, waste should not be placed in
contingency storage if the ability to dispose of waste at a licensed disposal
site exists.  The shipping of waste at the earliest practicable time minimizes
the need for eventual waste reprocessing due to possibly changing burial
ground requirements, reduces occupational and non-occupational exposures and
potential accident consequences, and in the event of burial ground closure,
maximizes the amount of storage space available for use.

      The duration of the intended storage, the type and form of waste, and
the amount of radioactive material present will dictate the safeguards and the
level of complexity required to assure public health and safety, and minimal
risk to operating personnel.  The longer the intended storage period, the
greater the degree of controls that will be required for radiation protection
and accident prevention.  For purposes of this document, the duration of
temporary waste storage is to be up to five (5) years.  The magnitude of the
onsite storage safety hazard is predicted on the type of waste being stored,
the amount of radionuclides present, and how readily they might be transported
into the environment.  In general, it is preferable to store radioactive
material in solid form.  Under some circumstances, however, temporary storage
in a liquid form may be desirable or required.  The specific design and
operation of any storage facility will be significantly influenced by the
various waste forms, consequently, this document addresses wet waste,
solidified wet waste and dry low level radioactive waste.

      Guidance similar to that provided in this enclosure has been
incorporated in NUREG-0800, NRC/NRR Standard Review Plan, July 1981, as
Appendix 11.4-A to SRP 11.4, Solid Waste Management Systems.

II.   General Information

      Prior to any implementation of additional onsite storage, substantial
safety review and environmental assessments should be conducted to assure
adequate public health and safety and minimal environmental impact.  The
acceptance criteria and performance objectives of any proposed storage
facility, or area, will need to meet minimal requirements in areas of design,
operations, safety considerations and policy 

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considerations.  For purposes of this technical position, the major emphasis
will be on safety considerations in the storing, handling and eventual
disposition of the radioactive waste.  Design and operational acceptability
will be based on minimal requirements which are defined in existing SRPs,
Regulatory Guides, and industry standards for proper management of radioactive
waste.  Considerations for waste minimization and volume reduction will also
have to be incorporated into an overall site waste management plan and the
onsite storage alternative.  Additional waste management considerations for
ALARA, decontamination, and decommissioning of the temporary storage facility,
including disposal, should be performed as early as possible because future
requirements for waste forms may make stored wastes unacceptable for final

      Facility design and operation should assure that radiological
consequences of design basis events (fire, tornado, seismic event, flood)
should not exceed a small fraction (10%) of 10 CFR Part 100, i.e., no more
than a few rem whole body dose.

      The added capacity would typically extend storage to accommodate no more
than an amount of waste generated during a nominal five-year period.  In
addition, waste should not be stored for a duration that exceeds five-years. 
Storage of waste in excess of the quantities and duration described herein
requires Part 30 licensing approval.  The design capacity (ft3, C1) should be
determined from historical waste generation rates for the station, considering
both volume minimization/reduction programs and the need for surge capacity
due to operations which may generate unusually large amounts of waste.

      The five-year period is sufficient to allow licensees to design and
construct additional volume reduction facilities (incinerators, etc.), as
necessary, and than process wastes that may have been stored during
construction.  Regional state compacts to create additional low-level waste
disposal site should also be established within the next five years.

III.  Generally Applicable Guidance

      (a) The quantity of radioactive material allowed and the shielding
configurations will be dictated by the dose rate criteria for both the site
boundary and unrestricted areas onsite.  The 40 CFR 190 limits will restrict
the annual dose from direct radiation and effluent releases from all sources
of uranium fuel cycle and 10 CFR Part 20.105 limits the exposure rates in
unrestricted areas.  Offsite does from onsite storage must be sufficiently low
to account for other uranium fuel cycle sources (e.g., an additional dose of 
� 1 mrem/year is 


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not likely to cause the limits of 40 CFR 190 to be exceeded).  Onsite dose
limits associated with temporary storage will be controlled per 10 CFR Part 20
including the ALARA principal of 10 CFR 20.1.

      (b) Compatibility of the container materials with the waste forms and
with environmental conditions external to the containers is necessary to
prevent significant container corrosion.  Container selection should be based
on data which demonstrates minimal corrosion from the anticipated internal and
external environment for a period well in excess of the planned storage
duration.  Container integrity after the period of storage should be
sufficient to allow handling during transportation and disposal without
container breach.

          Gas generation from organic materials in waste containers can also
lead to container breach and potentially flammable/explosive conditions.  To
minimize the number of potential problems, the waste form gas generation rates
from radiolysis, biodegradation, or chemical reaction should be evaluated with
respect to container breach and the creation of flammable/explosive
conditions.  Unless storage containers are equipped with special vent designs
which allow depressurization and do not permit the migration of radioactive
materials, resins highly loaded with radioactive material, such as BWR reactor
water cleanup system resins, should not be stored for a period in excess of
approximately one year.

          A program of at least periodic (quarterly) visual inspection of
container integrity (swelling, corrosion products, breach) should be
performed.  Inspection can be accomplished by use of TV monitors; by
walk-throughs if storage facility layout, shielding, and the container storage
array permit; or by selecting waste and containers stored in the facility and
placing them in a location specifically designed for inspection purposes.  All
inspection procedures developed should minimize occupational exposure.  The
use of high integrity containers (300 year lifetime design) would permit an
inspection program of reduced scope.

      (c) If possible, the preferred location of the additional storage
facility is inside the plant protected area.  If adequate space in the
protected area is not available, the storage facility should be placed on the
plant site and both a physical security program (fence, locked and alarmed
gates/doors, periodic patrols) and a restricted area for radiation protection
purposes should be established.  The facility should not be placed in a
location that 


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requires transportation of the waste over public roads unless no other
feasible alternatives exist.  Any transportation over public roads must be
conducted in accordance with NRC and DOT regulations.

      (d) For low level dry waste and solidified waste storage:

          1.  Potential release pathways of all radionuclides present in the
solidified waste form shall be monitored as per 10 CFR 50, Appendix A.
Surveillance programs shall incorporate adequate methods for detecting failure
of container integrity and measuring releases to the environment.  For outside
storage, periodic direct radiation and surface contamination monitoring shall
be conducted to insure that levels are below limits specified in 10 CFR
20.202, 20.205, and 49 CFR 173.397.  All containers should be decontaminated
to these levels or below before storage.

          2.  Provisions should be incorporated for collecting liquid drainage
including provisions for sampling all collected liquids.  Routing of the
collected liquids should be to radwaste systems if contamination is detected
or to normal discharge pathways if the water ingress is from external sources
and remains uncontaminated.

          3.  Waste stored in outside areas should be held securely by
installed hold down systems.  The hold down system should secure all
containers during severe environmental conditions up to and including the
design severe environmental conditions up to all including the design basis
event for this waste storage facility.

          4.  Container integrity should be assured against corrosion from the
external environment; external weather protection should be included where
necessary and practical.  Storage containers should be raised off storage pads
where water accumulation can be expected to cause external corrosion and
possible degradation of container integrity.

          5.  Total curie limits should be established based on the design of
the storage area and the safety measures provided.

          6.  Inventory records of waste types, contents, dates of storage,
shipment, etc., should be maintained.

IV.   Wet Radioactive Waste Storage

      (a) Wet radioactive waste will be defined as any liquid or liquid/solid
slurry.  For storage considerations, wet waste is further defined 


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as any waste which contains free liquid in amounts which exceed the
requirements for burial as established by the burial ground licensing

      (b) The facility supporting structure and tanks should be designed to
prevent uncontrolled releases of radioactive materials due to spillage or
accident conditions.

      (c) The following design objectives and criteria are applicable for wet
radioactive waste storage facilities:

          1.  Structures that house liquid radwaste storage tanks should be
designed to seismic criteria as defined in Standard Review Plant (Section
11.2).  Foundations and walls shall also be designed and fabricated to contain
the liquid inventory which might be released during a container/tank failure.

          2.  All tanks or containers should be designed to withstand the
corrosive nature of the wet waste stored.  The duration of storage under which
the corrosive conditions exist shall also be considered in the design.

          3.  All storage structures should have curbs or elevated thresholds
with floor drains and sumps to safely collect wet waste assuming the failure
of all tanks or containers.  Provisions should be incorporated to remove
spilled wet waste to the radwaste treatment systems.

          4.  All tanks and containers shall have provisions to monitor liquid
levels and to alarm potential overflow conditions.

          5.  All potential release pathways of radionuclides (e.g., evolved
gases, breach of container, etc.) shall be controlled, if feasible, and
monitored as per 10 CFR 50, Appendix A (General Design Criteria 60 and 4). 
Surveillance programs should incorporate adequate methods for monitoring
breach of container integrity or accidental releases.

          6.  All temporarily stored wet waste will require additional
reprocessing prior to shipment offsite; therefore, provisions should be
established to integrate the required treatment with the waste processing and
solidification systems.  The interface and associated systems should be
designed and tested in accordance with the codes and standards described in
Standard Review Plan Section 11.

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V.    Solidified Radioactive Waste Storage

      (a) Solidified radwaste for storage purposes shall be defined as that
waste which meets burial site solidified waste criteria.  For purposes of this
document, resins or filter sludges dewatered to the above criteria will be
defined under this waste classification/criteria.

      (b) Any storage plans should address container protection as well as any
reprocessing requirements for eventual shipment and burial.

      (c) Casks, tanks, and liners containing solidified radioactive waste
should be designed with good engineering judgment to preclude or reduce the
probability of occurrence of uncontrolled releases of radioactive materials
due to handling, transportation or storage.  Accident mitigation and control
for design basis events (e.g., fire, flooding, tornadoes, etc.) must be
evaluated and protected against unless otherwise justified.

      (d) The following design objectives and criteria are applicable for
solidified waste storage containers and facilities:

          1.  All solidified radwaste should be located in restricted areas
where effective material control and accountability can be maintained.  While
structures are not required to meet seismic criteria, protection should be
afforded to insure the radioactivity is contained safely by use of good
engineering judgment, such as the use of curbs and drains to contain spills of
dewatered resins or sludges.

          2.  If liquids exist which are corrosive, proven provisions should
be made to protect the container (i.e., special liners or coatings) and/or
neutralize the excess liquids.  If deemed appropriate and necessary, highly
non-corrosive materials (e.g., stainless steel) should be used.  Potential
corrosion between the solid waste forms and the container should also be
considered.  In the case of dewatered resins, highly corrosive acids and bases
can be generated which will significantly reduce the longevity of the
container.  The Process Control Program (PCP) should implement steps to assure
the above does not occur; provisions on container material selection and
precoating should be made to insure that container breach does not occur
during temporary storage periods.

          3.  Provision should be made for additional reprocessing or
repackaging due to container failure and/or, as required for 


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final transporting and burial as per DOT and burial site criteria. 
Contamination isolation and decontamination capabilities should be developed. 
When significant handling and personnel exposure can be anticipated, ALARA
methodology should be incorporated as per Regulatory Guides 8.8 and 8.10.

          4.  Procedures should be developed and implemented for early
detection, prevention and mitigation of accidents (e.g., fires).  Storage
areas and facility designs should incorporate good engineering features and
capabilities for contingencies so as to handle accidents and provide safeguard
systems such as fire detectors and suppression systems, (e.g., smoke detector
and sprinklers).  Personnel training and administrative procedures should be
established to insure both control of radioactive materials and minimum
personnel exposures.  Fire suppression devices may not be necessary if
combustible materials are minimal in the area.

VI.   Low Level Dry Waste Storage

      (a) Low level dry waste is classified as contaminated material (e.g.,
paper, trash, air filters) which contains radioactive material dispersed in
small concentrations throughout large volumes of inert material and contains
no free water.  Generally, this consists of dry material such as rags,
clothing, paper and small equipment (i.e., tools and instruments) which cannot
be easily decontaminated.

      (b) Licensees should implement controls to segregate and minimize the
generation of low level dry waste to lessen the impact on waste storage. 
Integration of Volume Reduction (VR) hardware should be considered to minimize
the need for additional waste storage facilities.

      (c) The following design objectives and criteria are applicable for low
level dry waste storage containers and facilities.

          1.  All dry or compacted radwaste should be located in restricted
areas where effective material control and accountability can be maintained. 
While structures are not required to meet seismic criteria, protection should
be afforded to insure the radioactivity is contained safely by use of good
engineering judgment.


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          2.  The waste container should be designed to insure radioactive
material containment during normal and abnormal occurrences.  The waste
container materials should not support combustion.  The packaged material
should not cause fires through spontaneous chemical reactions, retained heat,

          3.  Containers should generally comply with the criteria of 10 CFR
71 and 49 CFR 170 to minimize the need for repackaging for shipment.

          4.  Increased container handling and personnel exposure can be
anticipated, consequently, all ALARA methodology should be incorporated per
Regulatory Guides 8.8 and 8.10.

Page Last Reviewed/Updated Friday, May 22, 2015