Information Notice No. 90-09: Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees

                                UNITED STATES
                           WASHINGTON, D.C.  20555

                              February 5, 1990

                                   RADIOACTIVE WASTE BY FUEL CYCLE AND 
                                   MATERIALS LICENSEES


All holders of NRC materials licenses. 


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 

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. 


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 

                                   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 

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.

                                                            Attachment 1 
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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 

     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 


                                                            Attachment 1
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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 

     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 

     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.


                                                            Attachment 1
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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 

     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 

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.


                                                            Attachment 2
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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 

1. Non-sited Regional Compacts*

Appalachian Compact                     Mark McClellan      
                                        Deputy Secretary for Environmental      
                                        Department of Environmental Resources   
                                        Commonwealth of Pennsylvania
                                        P.O. Box 2063
                                        Harrisburg, PA  17120

                                        (Member States are Pennsylvania [host 
                                        State], Delaware, Maryland and West 

Central Interstate Compact              Ray Peery
                                        Executive Director
                                        Central Interstate Low-Level 
                                          Radioactive Waste Compact 
                                        3384 Peachtree Road NE, Suite 260
                                        Atlanta, GA  30326
                                        (Member States are Nebraska [host 
                                        State], Arkansas, Kansas, Louisiana, 
                                        and Oklahoma.)

Central Midwest Compact                 Clark Bullard
                                        Chair, Central Midwest Compact 
                                        Director, Office of Energy Research 
                                        University of Illinois 
                                        901 South Matthews Urbana, IL 61801 

                                        (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


                                                            Attachment 2
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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
                                        (Member States are Connecticut and 
                                        New Jersey, both of which are host 

Southwestern Compact                    Don Womeldorf
                                        Chief, Environmental Management 
                                        Department of Health Services
                                        State of California
                                        714 P Street, Room 616
                                        Sacramento, CA  95814

                                        (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
                                        (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
                                        (Member States are Nevada [current 
                                        host State], Colorado, New Mexico and 

                                                            Attachment 2
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Southeast Compact                       Kathy Visocki
                                        Executive Director
                                        Southeast Compact Commission
                                        3901 Barrett Drive, Suite 100
                                        Raleigh, NC  27609
                                        (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
                                        Service Facility Regulation
                                        Department of Consumer and 
                                          Regulatory Affairs
                                        District of Columbia
                                        614 H Street, NW, #1014
                                        Washington, D.C.  20001

Maine                                   Matthew Scott
                                        Executive Director
                                        Low-Level Radioactive Waste Siting
                                        State of Maine
                                        99 Western Avenue, Suite 101
                                        Augusta, ME  04330

Massachusetts                           Carol Amick
                                        Executive Director
                                        Low-Level Radioactive Waste
                                          Management Board
                                        Commonwealth of Massachusetts
                                        100 Cambridge, 20th Floor
                                        Boston, MA  02202

New Hampshire                           Bryan Stromh
                                        Deputy Director
                                        Public Health Services Division
                                        Department of Environmental Services
                                        State of New Hampshire
                                        6 Hazen Drive
                                        Concord, NH  03301


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New York                                Jay Dunkelberger
                                        Executive Director
                                        Low-Level Radioactive Waste Siting
                                        State of New York
                                        1215 Western Avenue, Suite 306
                                        Albany, NY  12203

Puerto Rico                             Santos Rohena
                                        Environmental Quality Board
                                        Commonwealth of Puerto Rico
                                        P.O. Box 11488
                                        San Turce, Puerto Rico  00910

Rhode Island                            Victor Bell
                                        Office of Environmental Coordination
                                        Department of Environmental 
                                        State of Rhode Island
                                        9 Hayes Street
                                        Providence, RI  02908

Vermont                                 Jonathan Lash
                                        Agency of Natural Resources
                                        State of Vermont
                                        103 South Main
                                        Waterbury, VT  05676

Texas                                   Lawrence R. Jacobi
                                        General Manager
                                        Low-Level Radioactive Waste Disposal
                                        State of Texas
                                        7701 North Lamar Boulevard, #300
                                        Austin, TX  78752

*  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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