Information Notice No. 90-09: Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555
February 5, 1990
Information Notice No. 90-09: EXTENDED INTERIM STORAGE OF LOW-LEVEL
RADIOACTIVE WASTE BY FUEL CYCLE AND
MATERIALS LICENSEES
Addressees:
All holders of NRC materials licenses.
Purpose:
This information notice provides guidance to fuel cycle and materials
licensees on information needed in license amendment requests to authorize
extended interim storage of low-level radioactive waste (LLW) at licensed
operations. NRC previously provided guidance on storage of LLW at nuclear
power plant sites in Generic Letters 81-38 and 85-14. However, until now
NRC has not provided similar guidance for fuel cycle and materials licensees
who may, for reasons stated below, need to store their LLW for periods
longer than in the past. It is expected that recipients will review this
information notice, distribute it to management and staff involved with
licensed activities, including responsible radiation safety staff, and
consider actions, as appropriate, to assure compliance with NRC
requirements. No specific written response to this information notice is
required.
Description of Circumstances:
The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA)
established a series of milestones, penalties and incentives to ensure that
States or Regional Compacts make adequate progress toward being able to
manage their LLW by 1993. On January 1, 1993, the existing LLW disposal
sites are expected to either close or to stop receiving LLW from outside
their Regional Compacts. What this means to licensees who generate LLW is
that, unless their State or Regional Compact either has a disposal facility
operational on January 1, 1993 or has made other arrangements for storage or
disposal, such licensees may have to store their LLW onsite until disposal
capacity is available. Storage of LLW in accordance with NRC requirements
may be necessary for anywhere from several months to several years.
Discussion:
Not all licensees who will need to store LLW onsite will need amendments to
their licenses to do so. However, if the possession limits specified in a
license need to be increased to allow storage, or if the terms and
conditions of a license
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otherwise need to be modified, a licensee will need to apply for a license
amendment. Attachment 1 to this notice identifies information which
licensees will need to provide to NRC in such amendment requests. This
information may also be useful to licensees who will not need license
amendments to store waste, as well as to persons considering applying for a
license to construct a centralized storage facility to receive waste from
others until State or Regional disposal capacity is available. The
following considerations are central to extended storage, and are the basis
of the information included in Attachment 1.
1. Storage is not a substitute for disposal. Other than storage for
radioactive decay, LLW should be stored only when disposal capacity is
unavailable and for no longer than is necessary. Licensee planning
should consider a specific date by which storage will end and disposal
of the LLW will take place.
2. In general, waste should be processed before storage, packaged in a
form ready for transport and disposal at the end of the storage period,
and clearly labeled in accordance with 10 CFR Subsection 20.203(f) and
Section 20.311. Adequacy of the waste form or package may have to be
reassessed before disposal.
3. To ensure integrity of packaging and maintenance of waste form, stored
waste should be shielded from the elements and from extremes of
temperature and humidity.
4. Waste should be stored in an area which allows for ready visual (direct
or remote) inspection on a routine basis. Licensees should plan to
conduct and document such inspections at least quarterly.
5. Depending on the specific waste involved, licensees may need to have
procedures and equipment in place or readily available to repackage the
waste, should the need arise.
6. Decomposition and chemical reaction of incompatible waste materials
over time can result in gas generation or other reaction products.
Licensees should evaluate what they are planning to store and use
measures to prevent these reactions. Further, licensees should
determine if the need exists for additional ventilation or fire
protection/suppression systems.
7. For most waste forms, storage of waste in containers suitable for
disposal will not represent a significant increment of direct radiation
exposure potential to workers. However, licensees should consider
their specific waste and storage plans and determine if additional
shielding or other actions are warranted to keep exposures as low as is
reasonably achievable (ALARA).
8. Stored waste should be located in a restricted area and secured (e.g.,
in a locked room) against unauthorized removal for the term of storage.
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NRC does not advocate extended storage of LLW, as long as disposal capacity
is available to licensees. However, NRC recognizes that storage is allowed
for, as an interim measure, in the framework of the LLRWPAA, and this
guidance is being issued in recognition of that fact. NRC continues to
believe that, whenever possible, storage should only be an interim step
between activities that generate waste and ultimate disposal of that waste.
In the interest of public health and safety, as well as maintaining
exposures ALARA, the length of time LLW is placed in storage should be kept
to a minimum. Accordingly, NRC's approval of requests by materials and fuel
cycle licensees for interim extended storage will generally be for a period
of time no greater than five years.
Some licensees will need to store LLW which also contains hazardous waste as
specified under the Resource Conservation and Recovery Act, as amended
(RCRA). These mixed wastes, as they are called, are regulated both by NRC -
for the radioactive component of the waste - and the U.S. Environmental
Protection Agency (EPA) - for the hazardous component of the waste. The
information and guidance contained in this notice apply to NRC's regulations
only. For information on permitting of storage by EPA, licensees should
contact the appropriate EPA regional office or, in those States with
approved mixed waste programs, the appropriate State regulatory authority.
If you have questions about your State or Regional Compact, a list of
contact persons is provided in Attachment 2 of this notice.
Questions on your specific license or general procedures for license
amendments and reviews related to extended interim storage should be
addressed to the appropriate NRC regional office or, in the case of fuel
cycle licensees, to the Division of Industrial and Medical Nuclear Safety in
NMSS.
Richard E. Cunningham, Director
Division of Industrial and Medical
Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
Technical Contact: George Pangburn, NMSS
(301) 492-0628
Attachments:
1. Information Needed in an Amendment Request
to Authorize Extended Interim Storage of LLW.
2. Regional Compacts and Unaffiliated States.
3. List of Recently Issued NMSS Information Notices.
4. List of Recently Issued NRC Information Notices.
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Attachment 1
IN 90-09
February 5, 1990
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INFORMATION NEEDED IN AN AMENDMENT REQUEST TO AUTHORIZE
EXTENDED INTERIM STORAGE OF LOW-LEVEL RADIOACTIVE WASTE
The following paragraphs identify the information which NRC considers
necessary in an amendment request from a materials or fuel cycle licensee to
authorize extended interim storage of low-level radioactive waste (LLW).
1. Identification of Waste to be Stored
a. Specify any possession limit increases needed for extended interim
storage of LLW.
b. Identify the estimated maximum amount of LLW to be stored, both in
terms of volume and activity, by radionuclide.
c. Characterize the LLW to be stored:
(1) Volume of waste by Class (A, B, or C)
(2) Physical form of the waste: solid, liquid or gas
(3) Waste processing: volume reduction, solidification
or other treatment.
(4) Additional non-radiological properties of LLW (if any):
hazardous, biologic/pathogenic, corrosive, flammable, etc.
d. Describe the amount and type of LLW currently being stored or
processed.
e. Identify any additional permits or approvals necessary for storage
(i.e., EPA hazardous waste permit, State or local approvals, etc.)
and the status of each required approval.
2. Plans for Final Disposal
a. Specify when disposal capacity will no longer be available to you
and onsite storage will begin.
b. Specify the State/Regional disposal facility to be used for ultimate
disposal of your LLW and when that facility is scheduled to begin
accepting LLW. Your Regional Compact or State LLW authority should
be able to provide this information if you do not have it.
c. Specify when you will begin shipping LLW to that facility and how
long it will take for your estimated storage inventory to be moved
out.
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3. Physical Description of Storage Area
a. Identify the location and provide a diagram of the LLW storage area
which demonstrates where packages will be stored and how packages
will be accessible for inspection purposes. Include the locations
of waste processing equipment (if applicable), air sampling
stations, effluent filters and any sources of flammable or explosive
material.
b. Specify the maximum volume of LLW that can be stored in the proposed
waste storage area and relate this to annual volume of waste
generated.
c. Specify the type of building/structure in which the waste will be
stored and demonstrate that the waste will be protected from weather
at all times.
d. Describe the measures to control access to the LLW storage area and
thereby ensure security of the waste.
e. Describe the ventilation system and how it will assure adequate
ventilation of the storage area.
f. Describe the fire protection and suppression system to minimize the
likelihood and extent of fire.
g. Describe how the adverse effects of extremes of temperature and
humidity on waste and waste containers will be avoided.
h. Describe vulnerability to other hazards such as tornado, hurricane,
flood, industrial accident, etc.
4. Packaging and Container Integrity
a. Describe the packages or containers to be used for storage of LLW,
any hazards the waste may pose to their integrity, and the projected
storage life of the packages or containers.
b. Describe your program for periodic inspections of LLW packages to
ensure that they retain their integrity and containment of LLW.
c. Describe your program and equipment (if applicable) for remote
handling and/or repackaging damaged or leaking waste containers.
5. Radiation Protection
a. Describe your program for safe placement and inspection of waste in
storage and maintaining occupational exposures as low as is
reasonably achievable (ALARA). This program should include periodic
radiation and contamination surveys of individual packages and the
storage area in general, as well as posting the storage area in
accordance with 10 CFR Section 20.203.
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b. Describe projected exposure rates, needs for shielding (if any) and
any changes in personnel monitoring which will be required as a
result of waste storage.
c. Describe your procedures for responding to emergencies, including
notification of and coordination with local fire, police and medical
departments.
d. Describe your system for maintaining accurate records of waste in
storage (including any waste receipts or transfers from or to other
licensees) to assure accountability.
6. Training
a. Describe your program for training personnel in procedures for
packaging, handling, placement, inspection, surveying and emergency
response for LLW storage.
7. Financial Assurance
a. Review the relevant sections of Parts 30, 40 and 70 regarding
financial assurance for decommissioning. If your proposed maximum
possession limits exceed the limits specified in Sections 30.35,
40.36 or 70.25, submit with your amendment request a decommissioning
funding plan or certification of financial assurance, as
appropriate. In either case, this submittal should demonstrate that
financial resources are or will be in place not only to decommission
the licensed operation, but also to provide for the estimated costs
of handling, transport and ultimate disposal of all LLW stored
onsite.
8. Emergency Preparedness
a. Review the relevant sections of Parts 30, 40 and 70 regarding
emergency preparedness. If your proposed maximum possession limits
exceed the limits specified in Subsections 30.32 (i)(1), 40.31(j)(1)
or 70.22 (i)(3), you will be required to either demonstrate that an
emergency plan is not needed or to develop and maintain a plan that
meets the requirements of the aforementioned sections.
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Attachment 2
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February 5, 1990
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REGIONAL COMPACTS AND UNAFFILIATED STATES
The following is a list of the existing Regional LLW Compacts and
unaffiliated States. The list includes a contact person at either the
Compact or State level, if you have questions about LLW disposal. In
addition, each Regional Compact is further divided to show its member
States.
1. Non-sited Regional Compacts*
Appalachian Compact Mark McClellan
Deputy Secretary for Environmental
Protection
Department of Environmental Resources
Commonwealth of Pennsylvania
P.O. Box 2063
Harrisburg, PA 17120
717/787-5028
(Member States are Pennsylvania [host
State], Delaware, Maryland and West
Virginia.)
Central Interstate Compact Ray Peery
Executive Director
Central Interstate Low-Level
Radioactive Waste Compact
3384 Peachtree Road NE, Suite 260
Atlanta, GA 30326
404/261-7114
(Member States are Nebraska [host
State], Arkansas, Kansas, Louisiana,
and Oklahoma.)
Central Midwest Compact Clark Bullard
Chair, Central Midwest Compact
Commission
Director, Office of Energy Research
University of Illinois
901 South Matthews Urbana, IL 61801
217/333-7734
(Member States are Illinois [host
State] and Kentucky.)
Midwest Compact Gregg Larson
Executive Director
Midwest Low-Level Radioactive Waste
Compact Commission
350 North Robert, Room 588
St. Paul, MN 55101
612/293-0126
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(Member States are Michigan [host
State], Iowa, Indiana, Minnesota,
Missouri, Ohio and Wisconsin.)
Northeast Compact Denise Drace
Executive Director
Northeast Interstate Radioactive
Waste Compact Commission
195 Nassau Street, 2nd Floor
Princeton, NJ 08540
609/497-1447
(Member States are Connecticut and
New Jersey, both of which are host
States.)
Southwestern Compact Don Womeldorf
Chief, Environmental Management
Branch
Department of Health Services
State of California
714 P Street, Room 616
Sacramento, CA 95814
916/445-0498
(Member States are California [host
State], Arizona, North Dakota and
South Dakota.)
2. Sited Regional Compacts**
Northwest Compact Elaine Carlin
Executive Director
Northwest Compact Commission
Department of Ecology
State of Washington
Mail Stop PV-11
Olympia, WA 98504
206/459-6244
(Member States are Washington [host
State], Alaska, Hawaii, Idaho,
Montana, Oregon and Utah.)
Rocky Mountain Compact Leonard Slosky
Executive Director
Rocky Mountain Compact Commission
1675 Broadway, Suite 1400
Denver, CO 80202
303/825-1912
(Member States are Nevada [current
host State], Colorado, New Mexico and
Wyoming.)
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Southeast Compact Kathy Visocki
Executive Director
Southeast Compact Commission
3901 Barrett Drive, Suite 100
Raleigh, NC 27609
919/781-7152
(Member States are South Carolina
[current host State], Alabama,
Florida, Georgia, Mississippi, North
Carolina, Tennessee and Virginia.)
3. Unaffiliated States***
District of Columbia Frances Bowie
Administrator
Service Facility Regulation
Administration
Department of Consumer and
Regulatory Affairs
District of Columbia
614 H Street, NW, #1014
Washington, D.C. 20001
202/727-7190
Maine Matthew Scott
Executive Director
Low-Level Radioactive Waste Siting
Authority
State of Maine
99 Western Avenue, Suite 101
Augusta, ME 04330
207/626-3249
Massachusetts Carol Amick
Executive Director
Low-Level Radioactive Waste
Management Board
Commonwealth of Massachusetts
100 Cambridge, 20th Floor
Boston, MA 02202
617/727-9800
New Hampshire Bryan Stromh
Deputy Director
Public Health Services Division
Department of Environmental Services
State of New Hampshire
6 Hazen Drive
Concord, NH 03301
603/271-3503
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New York Jay Dunkelberger
Executive Director
Low-Level Radioactive Waste Siting
Commission
State of New York
1215 Western Avenue, Suite 306
Albany, NY 12203
518/438-6130
Puerto Rico Santos Rohena
Chair
Environmental Quality Board
Commonwealth of Puerto Rico
P.O. Box 11488
San Turce, Puerto Rico 00910
809/725-5140
Rhode Island Victor Bell
Chief
Office of Environmental Coordination
Department of Environmental
Management
State of Rhode Island
9 Hayes Street
Providence, RI 02908
401/277-3434
Vermont Jonathan Lash
Secretary
Agency of Natural Resources
State of Vermont
103 South Main
Waterbury, VT 05676
802/244-7347
Texas Lawrence R. Jacobi
General Manager
Low-Level Radioactive Waste Disposal
Authority
State of Texas
7701 North Lamar Boulevard, #300
Austin, TX 78752
512/451-5292
__________________________
* Non-sited Regional Compacts are those Compacts of States approved by
Congress that do not currently have an operational LLW disposal facility.
** Sited Regional Compacts are those Compacts of States approved by
Congress that do have an operational LLW disposal facility.
*** Unaffiliated States are those States that are not a member of a Regional
Compact and that are pursuing LLW disposal capacity or other LLW disposal
arrangements independently.
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