ML20045B922

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Waste Vol Reporting Requirements of RG 1.21 & Need for Waste Classification Documentation
ML20045B922
Person / Time
Issue date: 12/07/1992
From:
Office of Nuclear Reactor Regulation
To:
References
RTR-REGGD-01.021, RTR-REGGD-1.021 HPPOS-291, NUDOCS 9306210267
Download: ML20045B922 (1)


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l RECORD #291 TITLE:

WASTE VOLUME REPORTING REQUIREMENTS OF RG 1.21 AND THE NEED FOR WASTE CLASSIFICATION DOCUMENTATION I

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UNITED STATES NUCLEAR REGULATORY COMMISSION 5

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DEC - 7 g MEMORANDUM FOR: Those on Attached List FROM:

Sher Bahadur, Acting Chief low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Office of Nuclear Reactor Regulation

SUBJECT:

WASTE VOLUME REPORTING REQUIREMENTS OF RG 1.21 AND THE NEED FOR WASTE CLASSIFICATION DOCUMENTATION The minutes of the April 1992 Reactor Health Physics Counterpart meeting identified two items (K-5 and K-6) requiring resolution. The first involved a question regarding the volumes and activity of low-level waste, sent offsite for processing, which should be reported per RG 1.21 in the reactor licensees' semiannual (now annual) effluent release reports (i.e., per 50.36a). This question came up again recently in a telephone conversation with 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 prior to subsequent offsite disposal.

The solid waste information reported in the annual report should be the volume and activity of the low-level waste leaving the reactor site which the licensee believes will be sent directly, or via a processor or collector, to a licensed disposal site. Consistent with this res)onse, 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, current regulations [20.311(d)) 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.

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 di:posal is waste; contaminated tools transferred for decontamination prior to intended reuse is not waste).

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l tt Attached List 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 transfers of waste to a processor require licensees to classify the waste. A pending revision to this Technical Position incorporates the needed correction.

ORiellent sisess gy Sher Bahadur, Acting Chief Low-Level Waste Management Branch Division of low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards E M '33GhlED ev LeMoine.J. Cunningham, Cnief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation Distribution:

(L-256)

Central File NMSS r/f RBangart WBrach JAustin JSurmeier J.rialeg SBahadur JKennedy JThoma Blahs RCooper R-I JStohr R-II CNorelius R-III BMurray R-IV RScarano R-V GGrant EDO RAnderson C-TN JLieberman OE PDR YES

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LCunningham LLWM t/f LLWB r/f-PDR NO Category:

Proprietary or CF Only 7 ACNW YES NO-SUBJECT ABSTRACT: WASTE VOLUME REPORTING REQUIREMENTS OF RG 1.21 AND j

THE NEED FOR WASTE CLASSIFICATI0N' DOCUMENTATION

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C LLWB M Nhd NAME Blahs JKennedy JThoma SBahadur Cundghh '

DATE 12/03/92 12/03/92 12/03/92 (A/4/92 M/ 7/92 G:\\LOHAUS\\L256-2 0FFICIAL RECORD COPY-1 l

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For Those on Attached List dated:

James H. Joyner, Chief, FRSSB, DRSS, Region I William E. Cline, Chief, RPEPB, DRSS, Region II Cynthia D. Pederson, Chief, RPB, DRSS, Region III L. Joseph Callan, Director, DRSS, Region IV James H. Reese, Chief, RRPB, DRSS, Region V Paul H. Lohaus, Acting Chief, RDB, RES, NLS-129 l

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Attached List l On the follow-on question, the regulations do nqt 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 transfers of waste to a processor require licensees to classify the waste. A pending revision to this Technical Position incorporates the needed correction.

Sher Bahadur, Acting Chief Low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety andSafeguards

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nningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation P

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Attached List On the follow-on question, the regulations do agi 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 Classificathn incorrectly states that transfers of waste to a processor-require. licensees to classify the waste. A pending revision to this Technical Position inco ates the needed correction.

Sher Bahadur, Acting Chief Low-level Waste Management Branch Division of low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness ffice of Nuclear Reactor Regulation l

Distribution:

(L-256)

Centra File NMSS r/f RBangart WBrach JAustin JSurmeier SBahadur JXennedy JThoma Blahs RCooper R-I JStohr R-II-CNorelius R-III BMurray R-IV RScarano R-V GGrant EDO RAnderson -TN JLieberman OE PDR YES LCunningham LLWM t/f LLW8 r/f PDR NO Category:

Proprietary or CF Only ACNW YES NO SUBJECT ABSTRACT: WASTE VOLUME REPORTING REQ IREMENTS OF RG 1.21.AND THE NEED FOR WASTE CLASSIFIC TION DOCUMENTATION OCF LLDR LMk0 LLWB C-LLWBk NRR I

NAME Blahs JKbdy Nhlma SBahahr Cunningham_

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G:\\LOHAUS\\L256-2

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OFFICIAL REC 0FD COPY

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GEC -7 E For Those on Attached List dated:

James H. Joyner, Chief, FRSSB, DRSS, Region I William E. Cline, Chief, RPEPB, DRSS, Region II Cynthia D. Pederson, Chief, RPB, DRSS, Region III L. Joseph Callan, Director, DRSS, Region IV James H. Reese, Chief, RRPB, DRSS, Region V Paul H. Lohaus, Acting Chief, RDB, RES, NLS-129

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