United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 88-16: Identifying Waste Generators in Shipments of Low-Level Waste to Land Disposal Facilities

                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                             WASHINGTON, D.C.  20555

                                 April 22, 1988

                                   OF LOW-LEVEL WASTE TO LAND DISPOSAL 


Radioactive waste collection and service company licensees handling 
prepackaged waste, and licensees operating low-level waste disposal 


This notice clarifies 10 CFR Section 20.311 regarding requirements for 
identifying persons shipping low-level waste to land disposal facilities.  The 
clarifications and suggestions contained in this notice do not constitute new 
NRC requirements, and no written response is required. 


A new Section 20.311 ("Transfer for disposal and manifests") was added to 
10 CFR Part 20 in December 1982.  Section 20.311 states that each shipment of 
radioactive waste to a land disposal facility must be accompanied by a 
manifest that describes the waste shipment.  Among other requirements, this 
description must include the name, address, and telephone number of the waste 
generator.  The purpose of identifying the waste generator is twofold:  It 
provides a source of information about the waste if questions or problems 
arise.  It enables development of a representative data base showing factors 
such as actual generators, type of licensee, and state where generated, rather 
than data skewed by large volumes from brokers or waste collectors.

For waste collector licensees who handle only prepackaged waste, Paragraph 
20.311(e) provides two options for shipment manifest preparation.  The first 
option allows the waste collector to prepare a new manifest to reflect conso-
lidated shipments.  The new manifest serves as a listing or an index for the 
detailed generator manifests, which must be attached to the new manifest.  The 
second option allows the waste collector to prepare a new manifest without at-
taching the generator manifests, provided the new manifest contains for each 
package the information contained in Paragraph 20.311(b).

Licensed waste processors who treat or repackage waste are considered in 
Paragraph 20.311(f) to be the waste generators.  Waste processors must prepare 
a new manifest reflecting this responsibility.  

.                                                            IN 88-16
                                                            April 22, 1988
                                                            Page 2 of 2

Description of Circumstances:

Contrary to Paragraph 20.311(e)(2), waste collectors who prepare new manifests 
for shipping prepackaged low-level waste to land disposal facilities have 
sometimes failed to either consistently identify the original waste generators 
or consistently provide sufficient information to maintain the identity of the 
waste generators for each specific waste container.  


The intent of Section 20.311 is to ensure that each waste container delivered 
to a land disposal facility is traceable to a specific waste generator.  Waste 
collector licensees should ensure that disposal facility shipment manifests 
identify, for each container of prepackaged waste, the name, address, and 
telephone number of the person generating the waste.  Similarly, land disposal 
operators accepting prepackaged waste from collectors should ensure that 
container-specific waste generator information is included.

One acceptable approach would be to provide, for each container, a simple 
generator code (e.g., A, B, C), and refer to an attached list for the name, 
address, and telephone number of the generator corresponding to the code.  
Another acceptable approach would be to print the names, addresses, and 
telephone numbers of the generators directly on the manifest continuation 
sheets.  Other approaches are acceptable provided the required waste generator 
information corresponds to individual waste containers.  

No written response is required by this information notice.  If you have 
questions, please contact this office or the appropriate NRC regional office.

                                   Malcolm R. Knapp, Director
                                   Division of Low-Level Waste Management
                                     and Decommissioning
                                   Office of Nuclear Material Safety
                                     and Safeguards

Technical Contact:  G. W. Roles, NMSS

Attachment:  List of Recently Issued NRC Information Notices
.                                                            Attachment
                                                            IN 88-16 
                                                            April 22, 1988 
                                                            Page 1 of 1

                             LIST OF RECENTLY ISSUED
                            NRC INFORMATION NOTICES 
Information                                  Date of 
Notice No._____Subject_______________________Issuance_______Issued to________

88-15          Availability of U.S. Food     4/18/88        Medical, Academic,
               and Drug Administration                      and Commercial 
               (FDA)-Approved Potassium                     licensees who 
               Iodide for Use in Emergencies                possess 
               Involving Radioactive Iodine                 radioactive 

88-14          Potential Problems with       4/18/88        All holders of OLs
               Electrical Relays                            or CPs for nuclear
                                                            power reactors. 

88-13          Water Hammer and Possible     4/18/88        All holders of OLs
               Piping Damage Caused by                      or CPs for nuclear
               Misapplication of Kerotest                   power reactors. 
               Packless Metal Diaphragm 
               Globe Valves 

88-12          Overgreasing of Electric      4/12/88        All holders of OLs
               Motor Bearings                               or CPs for nuclear
                                                            power reactors. 

88-11          Potential Loss of Motor       4/7/88         All holders of OLs
               Control Center and/or                        or CPs for nuclear
               Switchboard Function Due                     power reactors. 
               to Faulty Tie Bolts 

88-10          Materials Licensees:  Lack    3/28/88        All NRC licensees 
               of Management Controls Over                  authorized to use 
               Licensed Programs                            byproduct 

87-44,         Thimble Tube Thinning in      3/28/88        All holders of OLs
Supp. 1        Westinghouse Reactors                        or CPs for nuclear
                                                            power reactors 
                                                            that employ a 
                                                            Westinghouse NSSS.

88-09          Reduced Reliability of        3/18/88        All holders of OLs
               Steam-Driven Auxiliary                       or CPs for nuclear
               Feedwater Pumps Caused                       power reactors. 
               by Instability of Woodward 
               PG-PL Governors 
OL = Operating License
CP = Construction Permit 
Page Last Reviewed/Updated Friday, May 22, 2015