ML20059M876
| ML20059M876 | |
| Person / Time | |
|---|---|
| Issue date: | 09/09/1993 |
| From: | Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Lehman R, Lieberman J, Sharp P HOUSE OF REP., HOUSE OF REP., ENERGY & COMMERCE, SENATE, ENVIRONMENT & PUBLIC WORKS |
| References | |
| RULE-PRM-20-21 CCS, NUDOCS 9311190411 | |
| Download: ML20059M876 (4) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION d'
WASHINGTON, D.C. 20555-0001 j
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Septe:nber 9,1993 l
The Honorable Philip Sharp, Chairman Subcommittee on Energy and Power Committee on Energy and Commerce United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
Enclosed for your information is a copy of a petition for rulemaking (PRM-20-21) requesting that the Nuclear Regulatory Commission (NRC) amend 10 CFR Part 20.
The petition was filed with the NRC by Keith J.
- Schlager, Ph.D.,
et al.
The petition requests that the NRC amend its regulations regarding disposal of certain low-level radioactive wastes.
Also enclosed is a copy of the Federal Register notice that
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contains additional information concerning.the petition.
The notice will be published requesting public comment for a 75-day l
period.
.n Sincerely,
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Dennis K. Rathbun, Director r
Office of Congressional Affairs
Enclosures:
1.
PRM-20-21 2.
Federal Register notice cc:
Representative Michael Bilirakis i
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E UNITED STATES 53 5'" f NUCLEAR REGULATORY COMMISSION Y4 b"
WASHINGTON, D.C. 2055M001 j
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September 9, 1993 The Honorable Richard H.
Lehman, Chairman Subcommittee on Energy and Mineral Resources Committee on Natural Resources United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
Enclosed for your information is a copy of a petition for rulemaking (PRM-20-21) requesting that the Nuclear Regulatory l
Commission (NRC) amend 10 CFR Part 20.
The petition was filed with the NRC by Keith J.
Schlager, Ph.D., et al.
The petition requests that the NRC amend its regulations regarding disposal of certain low-level radioactive wastes.
Also enclosed is a copy of the Federal Register notice that contains additional information concerning the petition.
The notice will be published requesting public comment for a 75-day period.
Sincerely,
~ u. f gt Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosures:
1.
PRM-20-21 2.
Federal Register notice cc:
Representative Barbara Vucanovich 1
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NUCLEAR REGULATORY COMMISSION o,/
WASHINGTON, D.C. 20555-0001 Septalber 9, 1993 The Honorable Joseph Lieberman, Chairman Subcommittee on Clean Air and Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, DC 20510
Dear Mr. Chairman:
Enclosed for your information is a copy of a petition for rulemaking (PRM-20-21) requesting that the Nuclear Regulatory Commission (NRC) amend 10 CFR Part 20.
The petition was filed with the NRC by Keith J.
Schlager, Ph.D.,
et al.
The petition requests that the NRC amend its regulations regarding disposal of certain low-level radioactive wastes.
Also enclosed is a copy of the Federal Register notice that contains additional information concerning the petition.
The notice will be published requesting public comment for a 75-day period.
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Sincerely,
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l' s-Dennis K.
R thbun, Director Office of Congressional Affairs
Enclosures:
1.
PRM-20-21 2.
Federal Register notice cc:
Senator Alan K.
Simpson
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j
September 9, 1993 I
i The Honorable Richard H.
Lehman, Chairman Subcommittee on Energy and Mineral Resources l
Committee on Natural Resources j
United States House of Representatives l
Washington, DC 20515 l
i
Dear Mr. Chairman:
l l
Enclosed for your information is a copy of a petition for rulemaking (PRM-20-21) requesting that the Nuclear Regulatory l
Commission (NRC) amend 10 CFR Part 20.
The petition was filed with the NRC by Keith J.
Schiager, Ph.D., et al.
The petition requests that the NRC amend its regulations l
regarding disposal of certain low-level radioactive wastes.
F Also enclosed is a copy of the Federal Register notice that contains additional information concerning the petition.
The l
notice will be published requesting public comment for a 75-day period.
b Sincerely, l
1 Dennis K. Rathbun, Director I
Office of Congressional Affairs i
Enclosures:
1.
PRM-20-21 2.
Federal Register notice cc:
Representative Barbara Vucanovich IDENTICAL LETTER SENT TO:
The Honorable Joseph Lieberman cc:
Senator Alan Simpson j
The Honorable Philip Sharp cc:
Representative Michael Bilirakis DISTRIBUTION:
RDG MHARRISON DLMEYER OCA (3)
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i 18 May 1993 1
P U S. Nuclear Regulatory Commission J
Attention:' Chief
.j Docketing and Service Branch Office of the Secretary Washincton. DC 20555
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PETITION FOR RULD1AKING Reason for the Petition Each of the undersigned individuals is responsible t'or radioactive and mixed waste management at an institution with extensive biomedical research activities, but is writing as an l
individual citizen and not as a representative of his.or her institution. Current restrictions on low-level radioactive waste disposal have jeopardized the ability of our institutions to pursue certain kinds of research that cannot be conducted effectively without the use of radioactive
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materials. The petitioners seek to obtain partial relief,from this intolerable situation by proposing safe alternatives for disposal oflimited categories of wastes. We are concemed that l
there has been no action on a previous, similar petition for rulemaking (PRM 20-14, 49 FR 3667-3669, January 30, 1984).
Mixed Wastes Containine H-3 or C-14 P
Current NRC regulations (10 CFR 20 306) allow the disposal of liquid scintillation' fluid i
containing no more than 0.05 microcurie of hydrogen-3 or carbon-14 per gram to be disposed of as if it were not radioactive. This provision is both rational and practical, since it allows i
disposal of flammable solvents by the preferred method of incineration; it will be continued after 1 January 1994 under the provisions of s20.2005. However, procedures other than liquid.
scintillation counting generate similar flammable or combustible liquid wastes containing low concentrations of H-3 and C-14.
Including these materials under the disposal criteria 'for specific wastes would provide a cost-effective disposal option with essentially no impact on public health or environmental quality.
Wastes Containine Short-Lived Radionnelides Much of the radioactive waste generated by research and medical institutions contains only short-lived radionuclides, with the radioactivity decreasing rapidly through the normal decay process. At present, such wastes are stored for a prescribed period of time, usually 10 half-lives, allowing 99.9% of the activity to decsy. The wastes are then surveyed and, if no residual radioactivity is detected, they are disposed of as nonradioactive. Most NRC licensees are allowed to use this method for materials with half-lives ofless than 65 days, but it could safely be used for materials with longer half-lives, e.g. up to one year.
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9 Schiager. ci al - Petition for Rulemakinn 18 May 1993 10 CFR 20.2005 - Disposal of SpeciEc Wastes Page 2 The intent of the prescribed storage time for decay before disposal is to assure decay of the radioactivity to harmless levels. Regardless of the initial activity. the same fractional decay occurs in 10 half-lives. leaving 0.1% of the original. For example. a waste package containing i millicurie would decay to 1 microcurie in 10 half-lives, whereas a package initially containing I curie would still contain 1 millicurie after the same storace time. Thus, an arbitrary number of half-lives is not equally protective in all situations.
r For materials with half-lives of one year or less. regardless of the initial activity, there is no significant risk that materials would leach from a landfill before they decay. Consequently, there is no reason rciated to protection of health or the environment that the radioactive decay should not occur after the waste is buried rather than in a licensee-controlled storage facility.
The limit on activity in the waste at the time it is sent for burial is intended for the protection of the handlers und transponers of the waste, as well as for the general public in the event of a transportation accident enroute to the burial site.. A limit on exposure rate from the waste container or transport vehicle would adequately serve the same purpose. We recommend essentially the same criterion that is currently included ip specific licenses. i.e. that the deep-dose equivalent exposure rate be indistinguishable from background with typical low-level laboratory survey instruments. This would allow for immediate disposal of wastes containing low-energy beta emitters; the storage time required for high-energy beta emitters or photon emitters would depend on both the energies of the emissions and the total activity in the waste.
Proposed Revisions (Ddetis ns :ndieeted by strikeout, additions indicated by shidihg.)
i 20.2005 Disposal of specific wastes.
(a) A licensee may dispose of the following licensed material as ifit were not radioactive:
(1) 0.05 microcurie (1.85 kBq), or less, of hydrogen-3 or carbon-14 per gram of medium used for liquid scimi!!ation counting flsmmhbip@r]combustibiflif oid; and l
(2) 0.05 microcurie (1.85 kBq), or less, of hydrogen-3 or carbon-14 per gram of enimal.
biological tissue, animal bedding;tnaterialiof:nnimhliexsietid averaged over the weight of the entire animal tissde; bedding material or exegeta.
Existing subparagraph (b) should be retained as it is; (c) should be retained but relabeled as subparagraph (g).
(c) ?Anyflicenkeimaf? disp 6scibff0.05{iEiEfo"diliiRI!85!kB4)R6r~ileissTBfl116siisEdiiiiiEEihl consisting'of unfjmixtuisMf. hydrogen 13ncarbonkl4)and!radi6ntidlides%ith half:liW6f;16ss than one year;perIgram]Sf(incineratosssh%ndnhal#abidjirail$eraieNove2[thEs$ish$f the ashior tmshighnsratedidirectlytin!theutili2stioh?bf thElradiehuclides?ptesch@byb6itist?iit a landfillWpproved byfthegU.SAEnvifoninenthQProtection@iency@rfappf6pristEgstate regulatory agenhy.
i Schiager. ci al. - Petition for Rulemaking 18 May 1993 10 CFR 20.2005 - Disposal of Specific Wastes Page 3 1
(d) The deep-dose equivalent dose rate at the surfacefof containers;and vehicles usedffor tansporting wastes disposed 'of under the provisions of paragraph ~(c) of this section shall'he indistinguishable from background __with typical low-level:laboratOfy stirvey instruments; l
_ (c) All " radioactive! materials" Jabels shall be removed or bbliterated prior to disposal?iisdir 1
the provisions of paragraph (c) of this section, and the containers and the transport vehlblehof these waste materials shall lnot.be labeled as contaihing radioactive [ materials unless so $qdited i
by the.U. S. DepartmentLof Transportation."
(f) Wastes.disposedforimder'the provisions of paragraph (c) of this section att notisubject to the' requirements of section 20.2006e t
Mditional Interpretation
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It is recognized that proposed paragraphs (c) and (c) introduce a potential conDict between regulations of the NRC and the U. S. Department of Transportation (DOT), which regulates i
as radioactive any material with a specinc activity greater, than 0.002 microcurie per gram. If j
this petition results in favorable action by the NRC, a petition will be submitted to the DOT to revise 49 CFR 173.403(y) to accommodate this method of disposal.
t The types of waste speciGed in proposed paragraph (c) are incinerator ash and nonsalvable i
trash. The intent is to exclude discarded laboratory apparatus, equipment or furniture that might invite unanticipated or unauthorized salvage of contaminated items. Although incinerator
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ash is included in the proposal, the incineration process is not included, since it is addressed in section 20.2004.
Adoption of this proposed revision would not increase risks to the health of the public or to the environment, but would substantially reduce the costs and complexity of low-level j
radioactive waste management by research institutions.
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Petitioners 1
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d Keith f. Schlager, PfiD, CHP Donald E. Carlson, PhD ( i i
f Director, Radiological Health Environmental Health & Safety 100 Orson Spencer Hall U of Texas Southwest Med Center I
University of Utah 5323 Harry Hines Blvd.
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Salt Lake City, UT 84112 Dallas, TX 75235-9053 l
Schiager, et c!. - Petition for Rulemaking 18 May 1993 10 CFR 20.2005 - Disposal of SpeciEc Wastes Page 4 V h f /.,e P W n y&w 4dwed A Ch!is:::an, PhD, CHP Martha M. Malter Environ:rentd Heal:h & Safety Columbia University
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Environmental Health & Safety Univ. of Califemia, San Diego
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630 West 16E:h S:rcer La Jolla, CA 92093 New York, NY 10032
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Elan J. G::c =r.n. PED F Mda Pery Director, O!Ece of University Safety Radicion Safety Officer ia!e Univenity ne p_ermr,. University 135 College Street
.S?n<fb Romas R. Hicks Jc;p6 ~ 6
- c n t' Environ. Hed:h r.nd Safe:y Ji'ahhPhyci" t
Univenity of Oregca Envirnere +1 N1th & Safety 1230 Fr :k! n Blvd.
Hr.rve.rd Univasity Eugene, OR 97403 46 Oxford S:reet Ca=iridge, MA 02138 L Todd Lema reumm W. Scalowic Office of Pcea:ch Safe:y Mr.nr.ger of Safe:y Northwe::an Universi:y 303 E. Chiutgo Avenne Calif. Ins:. of Technology" t
Chicago, IL 60611 2039 Empress Avenna.
Sou:h Pm+"a, CA 91030 Ob -(!
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Jose A [
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p naineir afe:y Manager Univ opTexns Southwestern Med Center
_ A?*6e Safe:y Officer Hr.nwd Universi:y
$323 Ha:Ty Hines Blvd.
6 Shagbark F.ond Dallas, TX 75235-9053 Concord, MA 01742 i
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Schiager. a al. - Petition for Rulemaking 18 May 1993 i
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10 CFR 20.2005 - Disposal of Specific Wastes Page 5
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I Sheets containing the original signatures of the petitioners that were photo-copied to the
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preceding page are appended to the original copy of the petition submitted to the NRC.
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[7590-01-P)
I NUCLEAR REGULATORY COMMISSION 10 CFR Part 20
[ Docket No. PRM-20-21]
l Keith J. Schlager, Ph.D., et :!1 Receipt of 3,
a Petition for RulemaXing i
AGENCY:
Nuclear Regulatory Commission.
t ACTION:
Petition for rulemaking; Notice of receipt.
The Nuclear Regulatory Commission (NRC) has received
SUMMARY
and requests public comment on a petition for rulemaking filed by.
Keith J. Schlager, Ph.D.,
et al.
The petition has been docketed PRM-20-21.
by the Commission and has been assigned Docket No.
)
The petitioners request that the NRC amend its regulations governing the disposal of certain low-level radioactive wastes to provide additional options for the disposal of very low concentrations of short-lived racionuclides.
The petitioners believe such an amendment would permit more cost-effective j
radioactive waste management by research institutions and would-l not adversely affect public health and safety.
Submit comments by (75 days following publication in.the DATE:
Federal Reaister).
Comments received after this date-will be considered if it is practical to do so, but assurance of-consideration cannot be given except as to comments received on or before this date.
J t
ADDRESSES:
Submit comments to:
Secretary, U.S.-Nuclear Attention:
Regulatory Commission, Washington, DC 20555.
l Docketing and Service Branch.
Deliver comments to 11555 Rockville Pike, Rockville, I
i Maryland, between 7:45 am and 4:15 pm on Federal workdays.
For a copy of the petition, write:
Rules Review Section, l
Rules Review and Directives Branch, Division.of Freedom of i
information and Publications Services, Office of Adminiatration, 20555.
U.S. Nuclear Regulatory Commission, Washington, DC FOR FURTHER INFORMATION CONTACT:
Michael T.
Lesar, Office of i
Administration,"U.S. Nuclear Regulatory Commission, Washington, DC 20555.
Telephone:
301-492-7758 or Toll Free:
800-368-5642.
SUPPLEMENTARY INFORMATION:
Background
The Nuclear Regulatory Commission (NRC) received a petition for rulemaking submitted by Keith J. Schlager, Ph.D., et al.,
i 2
dated May 18, 1993.
The petition was docketed as PRM-20-21 on 4
July 6, 1993.
The petitioners requested that the NRC amend its a
l regulations in 10 CFR Part 20 that will become mandatory for all l
licensees on January 1, 1994, to permit additional methods for i
The l
disposal of certain low-level radioactive wastes.
petitioners note that current NRC regulations on low-level j
radioactive waste disposal (10 CFR 20.306) permit tla disposal of i
liquid scintillation fluid that contains no more than 0.05
)
microcurie of hydrogen-3 (H-3) or carbon-14 (C-14) per gram.
The petitioners believe this provision is appropriate j
i because it allows disposal of flammable solvents by incineration I
l but claim that procedures other than liquid scintillation counting generate similar flammable or combustible liquid wastes that contain low concentrations of H-3 and C-14.
On May 21, 1991 i
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r (50 FR 23360, 23391), the NRC published a final rule that added f
revised standards fo." protection agatnst radiation to the regulations in 10 CFR Part 20.
Although the final rule became effective Jute 20, 1991, licansees are not required to implement i
the provisions of the final rule until January 1, 1994. The petitioners contend that the regulations that become mandatory for all licensees on January 1, 1994, are too restrictive and I
prevent many research institutions from pursuing certain types of research that cannot be conducted effectively without the use of j
radioactive materials.
on January 30, 1984 (49 FR 3667), the NRC published a petition for rulemaking submitted by Keith J.
Schlager, Ph.D., on behalf of the University of Utah (PRM-20-14).
The petitioner requested that NRC amend its regulations in 10 CFR Part 20 to provide for additional options for the disposal of very low j
concentrations of short-lived radionuclides.
In a letter dated June 1, 1993, Dr. Schlager requested, on l
behalf of the University of Utah, that this petition be withdrawn j
because of changes in legislation and operational requirements l
since.the date his original petJtion was published in January 1984.
Dr. Schlager also indicated that a revised petition for rulemaking, which will propose amendments to provisions for l
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disposal of wastes containing low-level radionuclides in 10 CFR i
Part 20 that become mandatory for all licensees on January 1, I
1994, would be filed in the near future.
On July 22, 1993 (58 FR 39173), the NRC published a notice of withdrawal of the 3
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University of Utah's petition for rulemaking.
The NRC is soliciting public comment on the petition submitted by Keith J. Schlager, Ph.D.,
et-a]. that requests the changes as discussed below to the regulations in 10 CFR Part 20 that will become mandatory for all licensees on January 1, 1994.
The Petitioners The petitioners are a group of individuals responsible for radioactive waste management at various educational and medical institutions with extensive biomedical research activities.
The petitioners indicate they are submitting this petition for rulemaking only as individual citizenc, not as authorized representatives of the institutions that possess NRC licenses at which they are currently employed.
Adverse Effects on the Petitioners The petitioners have submitted this. petition for rulemaking because they believe they have been adversely affected by the current regulations that restrict low-level radioactive waste disposal.
The petitioners' primary concern is that these restrictions will prevent them from pursuing certain types of research which they believe cannot be effectively performed without the use of radioactive materials.
The petitioners state that while the current regulations are appropriate in permitting disposal of liquid scintillation fluid that contains no more than 0.05 microcurie of H-3 or C-14 as if it were not radioactive, they indicate that other procedures also generate similar combustible liquid wastes.
The petitioners
'4
4 believe that these materials could be included under the disposal criteria for specific wastes that contain very low levels of radionuclides.
The petitioners also assert'that proposed j
disposal criteria would result in a cost-effective option that j
i would not adversely affect public health or environmental 3
l
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quality.
1 The petitioners state that under the current industry practice, wastes containing low-level radionuclides are usually.
f stored for 10 half-lives, then are monitored for levels of
- i i
radioactivity.
If no residual radioactivity is discovered, the material can be treated as nonradioactive for disposal purposes.
The petitioners state that wastes stored for the prescribed j
timeframe will lose 99.9 percent of their radioactive content.
The petitioners note that under the current regulations most 1
NRC licensees are permitted to use this disposal method for materials that have half-lives of less than 65 days, but also
]
I assert that this disposal practice is appropriate for materials l
with half-lives of up to 1 year.
The petitioners also believe that an arbitrary number of half-lives is not equally protective
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in all situations.
As an example, the petitioners state that waate material containing one millicurie of. radioactivity would
-decay to one microcurie in 10 half-lives, while waste containing-one curie of radioactivity will still contain one millicurie j
l after the same storage time.
The petitioners believe that, regardless of the initial i
radioactivity present in waste material, there is no significant 5
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I risk that materials with a half-life of 1 year or less would
^l leach from a-landfill before they decay.
The petitioners state l
1 that the intent of the required storage time of low-level radioactive waste material before disposal is to.make certain I
i that all radioactivjty has decayed to harmless levels.
The j
petitioners assert that radioactive decay associated with buried i
I wastes containing low levels of radionuclides will have no more l
t adverse effect on public health and the environment than if the j
i wastes are stored in a licensee-controlled facility.
The petitioners also assert that the current regulatory limits on radioactivity in buried waste materials are intended to protect not only individuals who transport and handle the waste, l
but also to protect the general public if a transportation 8
accident enroute to the burial site results in a release.
The
' j petitioners believe that-a regulatory limit on the exposure rate from the waste container or the transport vehicle would accomplish the same result.
The petitioners _ recommend that the identical requirement i
currently in place for specific licenses, which requires that the j
i Jeep-dose equivalent exposure rate be indistinguishable from b
background levels as measured by low-level laboratory survey i
instruments, would also be adequate to protect public health and i
i the environment from adverse radiological effects from buried low-level biological wastes.
The petitioners believe that such a i
provision would allow for immediate disposal of wastes containing low levels of radionuclides and would permit more cost-effective t
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i waste disposal practices for biological research activities.
The Petitioners' Proposals The petitioners request that 10 CFR Part 20 be amended to overcome che problems the petitioners have itemized and recommend the following revision to the regulations:
t The petitioners propose that S20.2005 be amended by revising paragraph (a); redesignating paragraph (c) as paragraph (g); and r
t adding new paragraphs (c), (d), (e), and (f) to read as follows:
Proposed Revision:
I S20,2005 Disposal of specific wastes.
(a)
A licensee may dispose of the following licensed material i
as if it were not radioactive:
j (1) 0.05 microcurie (1.85 kBq), or less, of hydrogen-3 or carbon-14 per gram of flammable or combustible liquid; and (2) 0.05 microcurie (1.85 kBq), or less, of hydrogen-3 or j
i I
carbon-14 per gram of biological tissue, animal bedding material i
or animal excreta, averaged over the weight of the entire tissue, i
bedding material or excreta.
(c)
Any licensee may dispose of 0.05 microcurie (1.85 kBq), or
)
less, of licensed material consisting of any' mixture of hydrogen-i 3, carbon-14, and radionuclides with half-lives of less than 1 I
year, per gram of incinerator ash or nonsalvable trash, averaged j
over the weight of the ash or trash generated directly in the
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l utilization of the radionuclides present, by burial in a landfill approved by the U.S. Environmental Protection Agency or 7
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appropriate State regulatory agency.
(d)
The deep-dose equivalent dose rate at the surface of r
containers and vehicles uaed for transporting wastes disposed of under the provisions of paragraph (c) of this section shall be indistinguishable from background with typical low-level t
laboratory survey instruments.
(e)
All " radioactive materials" labels shall be removed or obliterated prior to disposal under the provisions of paragraph (c) of this section, and the containers and the transport vehicles of these waste materials shall not be labeled as containing radioactive materials unless so required by the U.S.
Department of Transportation.
(f)
Wastes disposed of under the provisions of paragraph (c) of this section are not subject to the requirements of S20.2006.
i The petitioners admit that proposed S20.2005(c) and (e) i f
would result in a potential conflict between NRC requirements and i
l U.S. Department of Transportation (DOT) regulations that specify i
that any material with a specific gravity greater than 0.002 microcurie per gram must be treated as radioactive.
The petitioners indicate that if the petition for rulemaking before the NRC results in favorable action, they will submit a petition for rulemaking to DOT to revise the relevant regulation (49 CFR
+
173.403(y)) to permit an identical method for disposal of waste-material that contains low levels of radionuclides.
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The petitioners also recognize that the types of waste specified in proposed S20.2005(c) are incinerator ash and j
t nonsalvable trash, and that the incineration process is covered l
in S20.2004.
The petitioners emphasize that the regulatory intent is to exclude discarded laboratory apparatus, equipment, l
or furniture that could result in unintended or unauthorized retrieval of contaminated items.
The Petitioners' Conclusion i
The petitioners have concluded that the current restrictions j
on low-level radioactive waste disposal have hindered certain I
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types of research that they believe cannot be effectively i
performed without the use of radioactive materials.
The j
petitioners have proposed revisions and additions to the current regulations in 10 CFR Part 20 that they believe will permit more
~
cost-effective disposal of wastes containing very low levels of l
radionuclides without adversely affecting public health or the j
environment.
The petitioners request that the NRC consider its l
proposals to amend the rules in 10 CFR Part 20.
l Dated at Rockville, Maryland, this day of e
i 1993.
For the Nuclear Regulatory Commission.
i s
Samuel J. Chilk, Secretary of the_ Commission.
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