ML20248H288

Forwards Draft Technical Position, Min Info in Low Level Shipment Manifests & Operation of Computer Recordkeeping Sys at Low Level Waste Storage & Disposal Facilities, for Review & Comment

ML20248H288
Person / Time
Issue date:	10/05/1989
From:	Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Lohaus P, Silberberg M, Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
References
FRN-57FR14500, REF-WM-3 AD33-1-120, NUDOCS 8910110252
Download: ML20248H288 (42)

Text

3u 214.3/GWR/9/12/89 DCT 0 5 mg MEMORANDUM FOR: Those on Attached List l FROM: Michael J. Bell, Chief 4 i Regulatory Branch i' Division of Low-Level Waste Management and Decommissioning, NMSS i';

SUBJECT:

REVIEW 0F DRAFT TP: MINIMUM INFORMATION IN LOW-LEVEL WASTE L

SHIPMENT MANIFESTS AND OPERATION OF COMPUTER RECORDKEEPING SYSTEMS AT LOW-LEVEL WASTE STORAGE AND DISPOSAL FACILITIES 1

o We have prepared a draft technical position (TP) on minimum information in <

. low-level waste (LLW) shipment manifests and operation of computer

.re:ordkeeping systems at LLW storage and disposal facilities. We plan to

, ' distribute this draft TP to Compacts and other interested parties for their retriew and comment. Before we do, we would appreciate your review and consnent.

We, have initiated a rulemaking to (1) augment and improve the quality of information contained in LLW shipment manifests, (2) require that operators of LLW disposal facilities store shipment manifest information in computer recordkeeping systems, and (3) require that these operators periodically sabmit, in an electronic form, reports of shipment manifest information. But because this rulemaking will take time to complete, we have agreed to prepare the TP to help Compacts develop criteria for manifesting and computer recordkeeping at new disposal facilities. In the draft TP, we also propose to tddress computer recordkeeping systems at central LLW storage facilities which nay be established by Compacts to meet their commitments under the Amendments Act.

For this TP, we believe that the most significant technical issue is to ensure that the physical and chemical characteristics of shipped waste are adequately described without significantly increasing licensee paperwork. Although existing manifests are large, complex documents, information about specific containers of waste can generally be recorded on a single manifest

" continuation page." We believe that NRC should be cautious about adding information that would increase the number of continuation pages per waste container.

We have purposely included a considerable amount of background information and justification in the draft TP. We have done this to help direct the review of the draf t TP by Compacts and other interested parties. The idea is to help the reviewers focus on the details of what information is needed and how it should be documented. Otherwise, many reviewers may respond by merely questioning why particular data elements are included.

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~ 214.3/GWR/9/12/89' P f OCT 0 51983 Addressees - tiemorandum dated / /89 Paul H. Lohaus, Chief Operations Branch Division of Low-Level Waste Management  !

and Decommissioning, NMSS John J. Surmeier, Chief Technical Branch Division of Low-Level Waste Management 4 and Deconnissioning, NMSS )

i Melvin-Silberberg, Chief Waste Management Branch Division of Engineering, RES Charles E. MacDonald, Chief Transportation Branch Division of Safeguards '

ans Transportation, NMSS Vandy L. Miller,. A/D State Agreements Programs State, Local and Indian Tribe Programs, GPA i

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1

1 - ,. v MANIFEST TP TECHNICAL POSITION ON MINIMUM INFORMATION IN LOW-LEVEL WASTE SHIPMENT MANIFESTS AND OPERATION OF COMPUTER RECORDKEEPING SYSTEMS AT LOW-LEVEL WASTE STORAGE AND DISPOSAL FACILITIES

1.0 INTRODUCTION

1.1 Purpose To assure protection of public health and safety and the environment, operators of all low-level waste (LLW) disposal facilities should maintain computer .

recordkeeping systems for electronic storage and speedy manipulation of information on LLW shipment manifests. When a shipment of LLW arrives at a-disposal facility, operators should perform quality control checks on the shipment end manifest information and transfer needed manifest information into these computer recordkeeping systems. Manifest information should be periodically reported, in an electronic format, to appropriate regulatory agencies. Similar activities should be performed by operators of LLW storage facilities established to meet a Compact's commitment to manage LLW pursuant to the Low-Level Radioactive Waste Policy Amendments Act of 1985 (Amendments Act).

This technical position (TP) delineates and expands upon this regulatory position. In so doing, the TP addresses the need for particular data elements that, as a minimum, should be included on shipment manifest and in computer data. systems. In addition, this TP addresses the need for periodic forwarding of collected information, in an electronic format, to a central location so

.that data on waste disposed at all sites can be used by all that need it.

1.2 Background

Low-level radioactive waste (LLW) may be shipped to a LLW disposal facility in a number of ways. Waste may be received directly from a waste generator.

Waste may be received from a broker, a licensee who typically handles prepackaged waste from hospitals, laboratories, or other licensees generating only small volumes of waste. A shipment from a broker may have been stored for a few days at the broker's facility, and when eventually shipped to a disposal facility, combined with waste containers obtained from several generators.

Waste may be received from a waste processor who has received waste from other generators and in some way has changed its chemical or physical characteristics. The waste processor may have repackaged the waste, compacted or incinerated the waste, or segregated contaminated waste from non- '

. s MANIFEST TP contaminated waste (the latter waste may be disposed by another method). A single package received by a disposal facility operator from a waste processor may contain wastes from a number of different generators.

Finally, waste may be received from a decontamination facility. In this case, contaminated material is delivered to the facility and after processing, two streams are produced. One stream, a product stream, contains material that has been sufficiently decontaminated that it can be reused in some manner. The other stream is a waste stream that is characterized, packaged, and shipped to the disposal facility.

Thus, from its original generation to its final delivery to a disposal facility, LLW'may have changed hands on more than one occasion. Indeed, in 1988 nearly 25% of all LLW delivered to disposal facilities was handled by brokers and processors. (And considering the trend for rising disposal costs, l processing may be even more commonplace in the future.) Any step in the waste' delivery chain -- temporary storage by a broker, processing, or disposal -- may have taken place in a different State than that in which it was generated.

Companies handling, processing, or disposing of the waste may be licensed by the Nuclear Regulatory Commission (NRC) or may licensed by an Agreement State.

Each shipment of LLW must be accompanied by documents, known collectively as shipment manifests, describing the shipment contents. When a shipment or LLW arrives at a disposal facility, operators perform quality control checks on the shipment and manifest information and transfer a portion of the manifest information into computer recordkeeping systems. Disposal facility operators have independently developed their computer systems to answer a variety of needs, such as assisting in business activities and complying with summary reporting requirements pursuant to disposal facility license conditions. The two operators have developed their computer systems as the only practical means to track and evaluate the manifest data. LLW may be generated by thousands of licensees and is extremely heterogeneous; it exists in a variety of chemical and physical forms and contains roughly 200 different radionuclides in concentrations that can range from a few millionths of a curie to several hundred curies per cubic foot.

LLW is currently disposed at three disposal facilities: the Barnwell, SC disposal Richland, facility WA andoperated by facilities Beatty, NY Chem-Nuclear operatedSystems, Inc. (CNSI),(and by U.S. Ecology USE). In the 1988, these three facilities received more than 3,700 shipments of LLW.

In the future, there may be many more disposal facilities. In response to the mandates of the Low-level Radioactive Waste Policy Amendments Act of 1985 (Amendments Act), and of the earlier Low-Level Radioactive Waste Policy Act of 1980, States have organized into regional Compacts to site and operate new disposal facilities. The Amendments Act establishes a series of milestones, penalties, and incentives to assure that the States will be able to manage 1993. While new disposal capacity is waste generated within their Compacts being developed, the three sited States by(Nevada, South Carolina, and k

. e MANIFEST TP Washington) may impose surcharges on waste from outside their compact and to allocate waste from nuclear utilities. After December 31, 1992, the Compacts are responsible for managing their own wastes and can prohibit disposal of waste generated from outside their compacts. (The Barnwell, SC facility will close on this date, and a new site will be developed in the Southeast Compact.)

After this date, and ur.til disposal capacity is created, some States and Compacts may store LLW for several years, either at licensee's sites or at regional storage facilities.

1.3 Principal Waste Manifesting Regulations Each shipment of radioactive material must be accompanied by shipping papers containing documentation required by the Department of Transportation (DOT) in 49 CFR Part 172. This documentation is designed to help ensure safety during transportation. If the material is transported by common carrier engaged in interstate or foreign commerce, the documentation must be accompanied by a bill-of lading pursuant to Interstate Comerce Commission (ICC) regulations in 10 CFR Part 1051. Additionally, if the radioactive material is LLW, it must be accompanied by a shipment manifest that contains information required by NRC in 10 CFR Section 20.311. These Part 20 regulations are intended to ensure that LLW may be tracked and that information is provided that is important for disposal safety. (NRC's Part 20 regulations don't apply to shipments of radioactive material to a decontamination facility, although they do apply to any LLW shipped from the decontamination facility. Thus, the shipper of the radioactive material would have to provide the operator of the decontamination facility with any information needed by the operator to comply with the Part 20 manifesting regulations.) Finally, if the LLW is sent to a LLW disposal facility, facility license conditions may require additional documentation.

Theoretically, individual waste brokers, processors, and disposal facility operators could all use different shipment manifest forms. In practice, however, the designs of the forms are largely dictated by the disposal facility operators, who form the last link in the LLW management chain. To the extent that disposal facility operators require particular information as a condition of waste acceptance, then these information requirements are necessarily imposed on brokers and other persons handling waste farther up the chain.

Manifest forms used by the disposal facility operators are approved by the State agencies regulating the disposal facilities.

The information required by DOT regulations, NRC regulations, and disposal facility license conditions is typically combined into a single document, called a radioactive shipment manifest. (The bill of lading is a separate document.) This manifest consists of a title page, which presents information applicable to the shipment as a whole, and one or more continuation pages, which describe individual containers of waste within the shipment. For some wastes, additional documentation is appended.

A summary of the principal regulations governing preparation of LLW shipment documentation is provided below.

i 1 %

MANIFEST TP 1.3.1 10 CFR Section 20.311 The Section 20.311 regulations were written to accomplish two tasks. First, the regulations specify the minimum information, important to waste disposal, to be included in LLW shipment manifests. These information requirements are written broadly and generally don't distinguish information to be provided on a shipment basis from information to be provided on a waste container basis.

Second, the regulations address tracking of LLW from generation to disposal.

Regarding information requirements, each shipment of waste to a licensed land

' disposal facility must be accompanied by a shipment manifest that contains the name, address, and telephone number or the name and Environmental Protection Agency (EPA) hazardous waste identification number of the person transporting the waste to the land disposal facility. The manifest must include a physical description of the waste, the volume, the radionuclides identity and quantity, the total radioactivity, and the principal chemical form. The solidification -

agent must be specified. Waste containing more than 0.1% chelating agents must be identified and the weight percentage of the chelating agent estimated. The classification status of the waste must be specified, as must the total quantities of the radionuclides H-3, C-14, Tc-99, and I-129. Each manifest must include a certification by the waste generator that the transported materials are properly classified, described, packaged, marked, and labeled, and are in proper condition for transportation. The required manifest may be shipping papers used to meet DOT or EPA regulations or requirements of the receiver, provided that all the required information is included.

Regarding waste tracking, Part 20 establishes a system whereby, when LLW changes hands, a copy of the manifest must be sent from the person shipping the waste to the person receiving the waste. The person receiving the waste must acknowledge receipt of the waste, within one week, by notifying the shipper.

Both the shipper and receiver of the waste must maintain records of the LLW transfer, and must trace lost or missing shipments or parts of shipments.

Although these records must be available for regulatory inspection, there are no reporting requirements, unless lost or missing shipments or parts of shipments can't be traced within a specified time.

Part 20 imposes different tracking requirements for LLW collectors from LLW processors. For waste handled by waste collectors, the identity of the generator must be preserved when the waste is shipped to a LLW disposal facility or to a LLW processor. The manifest must indicate which generator is  !

responsible for which container of waste. But for processed waste, there currently are no requirements in Part 20 to report the original generator when the processed waste is shipped for disposal.

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MANIFEST TP 1.3.2.'49 CFR Part 172 DOT's requirements for preparation of shipping papers for radioactive and other j hazardous materials are contained in 49 CFR 172.200 through 172.206. Unless 'i specifically authorized ~or required, the required shipping description must not contain any code or _ abbreviation. Shipping. papers must contain a certification-by the shipper. Shipping papers may contain additional information as long as the.information'is not inconsistent with the required information. . Shipping papers for shipments by water must contain the names of the shippers.

Pursuant to Section 172.202, the shipping paper must contain a description of the hazardous material, namely: (1)itspropershippingname;(2)itshazard class; and (3),its identification number (preceded by UN or NA as appropriate).

This basic description must be shown in sequence (e.g... Radioactive Material, n.o.s. -- Radioactive Material, UN2982). Except for empty packages, shipping papers must provide the total quantity (by weight, volume, or otherwise .

appropriate) of the hazardous material covered by the basic description.

In addition, if the shi

" reportable quantity"'(pment contains radioactive material in excess of aRQ),

papers either before or after the basic description required by Section 172.202. -For example, either "RQ, Radioactive Material, n.o.s. -- Radioactive Material. UN2982" or " Radioactive Material, n.o.s. -- Radioactive Material, UN2982, RQ" would be acceptable. The concept of RQ derives from the EPA regulation, 40 CFR Part 302, that requires that persons in charge of vessels or-facilities from which a hazardous substance has been released-in a 24-hour period in a quantity equal to or greater than an RQ innediately notify the National Response. Center. DOT therefore requires that persons shipping a quantity of hazardous material equal to or greater than an RQ indicate this on shipment manifests. In May 1989. EPA changed the RQ for radionuclides from one pound to a variable curie quantity established as a function of individual radionuclides. DOT is undertaking a rulemaking to adopt the new EPA radionuclides limits; a final rule is expected in 1989.

Shipping papers for radioactive material must contain the following additional information(Section 172.203):

1. The name of each radionuclides (abbreviations are authorized).

2. The physical and chemical form, if the material is not in special form.

The generic chemical description is acceptable for the chemical form.

3. The activity contained in each shipment package in terms of curies, millicuries, or microcuries (abbreviations are authorized). For shipment of a package containing a highway route controlled quantity of radioactive materials, the words " Highway route controlled quantity" must be entered in association with the basic description.

4. The package label: Three categories of labels are specified, based on --

(a) the designated Transport Index for the waste package, (b) the radiation level (in mrem /hr) at the package surface, and (c) the Fissile

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'NANIFESTTP a Class of the waste package. -The three labels are RADIOACTIVE WHITE - I, RADI0 ACTIVE YELLOW --II AND RADI0 ACTIVE YELLOW - III.

^

5. The transport.index (TI) assigned to each package labeled RADI0 ACTIVE YELLOW .II or.RADI0 ACTIVE. YELLOW - III. The TI is determined in.two ways: (a) the maximum radiation level.in millirem /hr. measured at one meter from the external surface of the package, and (b) for Fissile Class

1. .II packages or packages in a Fissile Class III shipment, the number

. expressing the maximum radiation level at one meter from the external surface of-the package, or the number obtained by dividing 50 by the allowable number of packages which may be transported together, whichever

-is larger.

6. For a package approved by DOE or NRC (a package containing radioactive material in excess of Type A quantities), the package identification number as~ prescribed in the applicable DOE or NRC approval. ,

7. For an export shipment or a shipment in a foreign made package, the package. identification. marking as prescribed in the applicable International Atomic Energy Agency (IAEA) Certification of Competent Authority issued for the package.

For shipments of fissile materials, shipping papers must either indicate that the shipped package is " fissile exempt" or, if not exempt, identify the fissile class of each package of the shipment, where the fissile class is determined pursuant to 49 CFR 173.455. . Additional shipping paper notations must be made for Fissile Class III packages.

Finally, Section 172.205 requires use of the national uniform manifest form specified by EPA in 40 CFR Part 262 whenever hazardous waste is offered,

-transported, transferred, or delivered. Section 172.205 also imposes a number of requirements on persons generating, transporting, treating, or disposing the waste, in an effort to ensure that the chain of custo(y of the waste is known "from cradle to grave." Hazardous waste, regulated by EPA under the Resource Conservation and Recovery Act (RCRA), is solid waste that is specifically listed by EPA pursuant to a rulemaking, is hazardous by characteristic (ignitability, corrosivity, reactivity, or extraction procedure toxicity), is a mixture of a solid and hazardous waste, or is derived from treating, storing, or disposing a listed waste. Section 172,205, the EPA uniform manifest, and the hazardous waste tracking requirements, are applicable to all licensees

' transporting mixed waste, which is waste containing hazardous waste as well as radioactive waste regulated by NRC or the States under the Atomic Energy Act of 1954, as amended.

1.3.3 49 CFR Part 1051 These ICC regulations contain requirements for bills of lading. Every comanon carrier by motor vehicle must show on the face of each and every receipt or bill of lading issued for the transportation of property by such carrier in interstate or foreign comunerce, information which includes the names of the

l.

l MANIFEST TP consignor and consignee; the points of origin and destination; the number of packages; the description of the articles; and the weight, volume, or measurement (if the lawfully applicable rates or charges are published to apply per unit of weight volume or measurement) of the property received. (For l transportation of LLW, bills of lading are usually separate documents from shipping papers required by DOT.)

l 1.3.4 Other Requirements Other documentation frequently accompanies waste shipments. For example, licensees shipping Class C waste to the Barnwell, SC disposal facility must include, as part of the shipment manifest, a more complete description of the waste and a discussion of how classification was performed.

1.3 Waste Receipt and Disposal Disposal sites operating in the future will be licensed pursuant to 10 CFR Part 20 and 61 or compatible Agreement State regulations. (Existing disposal sites have been licensed pursuant to Parts 20, 30, 40, and 70, or compatible Agreement State regulations.) An-application for a disposal facility license will be reviewed by regulatory staff to assess the potential impacts of the proposed activities on public health and safety and the environment. Pursuant to Subpart B of Part 61, an application for a disposal site license must include general information, specific technical information and analyses, and institutional and financial information as set forth in Sections 61.11 through 61.16. An environmental report must accompany the application.

Standards for issuance of a license are provided in Section 61.23. A license may be issued if, among other requirements, there is reasonable assurance that the management of waste will be performed in a manner to meet the performance objectives of 10 CFR 61.41 through 61.44, to meet technical requirements of Subpart D of Part 61, and to meet criticality requirements as described in Section61.23(j).

Part of the license acceptance review consists of review of the applicant's receipt and inspection procedures and waste acceptance criteria. Waste entering the site must Ae checked to provide reasonable assurance that waste characteristics are accarately recorded on the shipment manifest in accordance with NRC and DOT regulations and disposal site license conditions. This waste receipt and acceptance program is part of the operator's quality control program which must be established pursuant to paragraph 61.12(j). Consnission acceptance of the applicant's procedures for the receipt and insptction of waste is based on the applicant meeting the requirements of 10 CFR 61.55, 61.56, 61.81, 71.87, and 20.311, and 49 CFR 173.441 and 173.443 and the performance objectives of Part 61 (Ref. 1).

During operations, the disposal site operator receives, inspects, and disposes of waste based on approved procedures and a disposal site license issued by NRC or an Agreement State. Waste may be received from an NRC or an Agreement State

L

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. MANIFEST TP licensee, and frequently from a licensee located in a different. state. The disposal facility licensee complies with regulations including Section 61.80 (Maintenance of records,)

land disposal facilities . reports, and-transfers)'and Section 61.81 (Tests.atThe radionuclides inventories as may be imposed as discussed in paragraph 61.7(b)(2). Periodically,.the license is renewed. .The licensee submits an application for renewal pursuant to Section 61.27 and a decision on the renewal application is made pursuant to Section 61.23. . Eventually, the licensee.

submits an application for closure pursuant to Section 61.28.

1.4 Approach to Technical Position The remainder of this TP is divided into three chapters: ' Chapter 2 presents a discussion of the need for and uses of a computer data base on LLW manifest information. Chapter 3. presents the staff regulatory position. In this -

chapter, the. staff addresses the need for specific data elements on shipment manifests and in computer data systems, as well as the staff's position on -

design, use, and maintenance of disposal facility computer recordkeeping systems. Chapter 4 addresses implementation of this.TP.

2.0 DISCUSSION This chapter. presents the need for, and uses of, computer systems used to store and manipulate LLW shipment manifest information. It discusses these computer systems on two levels. First, it discusses the need for and uses of a LLW computer data base at individual LLW disposal facilities. Second, it discusses the need for and uses of. a LLW. computer data base on a national level. This national LLW computer data base would contain manifest information about LLW disposed at all LLW disposal facilities.

2.1 Need for and Uses of a LLW Computer Data Base at an Individual Disposal Facility Important site-specific needs and uses of a LLW computer data base include:

o Day-to-day compliance with requirements at LLW disposal facilities; o Safei;y and environmental assessments at LLW disposal facilities; o Tracking inventories of specific radionuclides; o Recordkeeping and reporting; o Assessing the health and safety implications of possible problems.

2.1.1 Day-to-Day Compliance with Regulations As part of an a) plication for a LLW disposal facility, NRC staff believes that the applicant siould ". . . describe the procedures or contracts in place that will ensure that arriving shipments comply with applicable Federal regulations and waste acceptance criteria" (Ref. 2). These procedures are to include those l

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' MANIFEST TP

-9 for verifying the accuracy of the waste class reported on the waste manifest and for verifying that waste characteristics and waste form requirements are met (Ref. 2). Staff expects that an applicant's procedures will include computer analyses based on waste characteristics reported on shipment manifests.  !

Human skill and common sense are of primary importance in determining j compliance. Nonetheless, use of computer technology provides a tool that can i help make decisions. The most significant attribute of this tool is its ability to store information for quick retrieval and manipulation and to quickly perform numerical calculations. Computer technology facilitates a quicker, more detailed, review of shipment inanifests.

Using computer technology, for example, the following types of analyses could be quickly performed:

o Using the reported package radionuclides inventories, waste and package description, and waste volume and weight, verify the classification status of the waste.

o Confirm classification of waste according to DOT transportation regulations (LSA, T.m A, Type B).

o Identify waste packages containing radionuclides distributions that, based on consideration of other, similar, types of waste, are reported in unexpected isotopic ratios.

o Identify waste packages in which the reported radionuclides distributions and quantities are not appropriate to measured radiation levels.

o Screen manifests for nonexistent radionuclides or stable isotopes.

o By suming the volume and activity of individual containers, confirm that the results match those for the totals printed on the manifest title page.

There may be other analyses that could be performed. The point, however, is that a disposal site manifest recordkeeping system will be needed to help carry out the waste verification procedures required at a disposal site licensed under Part 61.

2.1.2 Safety and. Environmental Assessments at LLW Disposal Facilities Upon receipt of an application for a disposal facility license, the regulatory staff must assure the protection of public health and safety and the environment by assessing the potential impacts from disposal facility activities. Once a disposal facility is licensed, the staff must confirm that the disposal facility is operating in compliance with regulations and disposal site license conditions. Safety and environmental analyses similar to those performed during disposal site licensing would be performed as part of license renewal and closure assessments.

I

MAtlIFEST Tp The starting point of all safety and environmental aniums is the radioactive waste source term. For this reason, license applications must not only provide an assessment of safety and environmental impacts, but must include a projection of the quantities and physical, chemical, and radiological characteristics of the LLW to be disposed. (For license renewals and closure assessments, projected waste characteristics would be replaced to the appropriate extent by information obtained from actual waste receipts.) In References 1 and 2, the staff note that waste projections should be made on a waste stream specific basis. For each waste stream, the followin is needed at a minimum: (a) annual volumes; (b) waste class; (c)g information average concentrations of the principal radionuclides constituting the waste stream (including those listed in 10 CFR 61.55); (d) the chemical and pnysical form; (e) the presence of chelating agents; (f) packaging characteristics (e.

whether the waste will be disposed in a high-integrity container); and solidification agent. ,

Typical release and transport scenarios to be considered in : safety assessments are described in References 1 and 2. Five basic pathways, each involving one or more radioactivity release scenarios, are described for ncmal conditions, and additional release scenarios are recognized for abnormi (accident) conditions. Typical scenarios that could be considered as part of an environmental assessment are listed in Reference 3. Environmental analyses are generally similar to health and safety analyses.

Although there may be a number of scenarios for radionuclides release and transfer, there are far fewer release mechanisms. This is because similar release mechanisms may be the starting point for a number of scenarios. (For example, leaching by water is the starting point for such scenarios as release through groundwater pathways, release through surface water, and uptake by plant roots.) These release mechanisms appear to principally consist of the following:

Release by water contact .

- Leaching of solid waste

- Washing of surface contamination

- Release of free liquid Dispersion into air

- Mobilization of surface contamination

- Mobilization of friable waste forms

- Combustion

- Significant chemical reaction <'

- Release of free liquid Surface radiation levels Releases due to radioactivity leaching and migration typically involve the following waste-specific parameters (Ref. 4):

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'u MANIFEST TP -

1. Waste radiological characteristics (radionuclides and activities);

2.- Waste. physical and chemical characteristics (e.g.. waste exists as

-activated metal; waste exists as porous material such as trash cr cement, waste contains chelating agents, etc.);

3. Waste surface-to-volume ratio;

4. Waste packaging (different' waste containers provide different abilities to retain radionuclides); and-

5. Contact by water.

Information applicable to the first four parameters is either alrea# on or should be included on shipment manifests. The last parameter, contact by

- water, is a function of many variables, including the potential for disposal cell subsidence. Subsidence, in turn, can be influenced by the vaste physical

.and chemical characteristics. -

Waste container surface contamination levels are alrea # estimated (generally

-over-estimated)forweW.,containersonexistingshipmentmanifests. Transport vehicles are checked for contamination upon arrival at disposal sites and the results of this. screening process is documented. Free liquid content, however, is not explicitly listed on shipment manifests, although it can be estimated based on a knowledge of the waste physical and chemical characteristics, the solidification media, the waste packaging, and the waste class.

Release mechanisms such as dispersion of friable wastes, fires, and chemical reactivity can be estimated by a knowledge of the physical and chemical characteristics of the waste and waste containers. For example, wastes containing significant quantities of paper are obviously more flammable than

~ inert materials such'as contaminated soil.

Surface radiation levels of waste containers and transport vehicles are used in a number of applications, including an analysis of impacts of wastes transported to the disposal site. Regardin transportation, a review of one reference Ref. (g impacts that

4) indicates dueLLW to waste transportation assessments typically involve the following parameters:

1.. Number of waste shipments;

~ Waste container types and sizes;

- Radiation levels at container surfaces (determines shielding i.

requirements, which influences vehicle types and overpacks);

- Vehicletypesandoverpacks(needforcasks);

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2. Shipment distance and time; and

3. Radiation levels at vehicle surface.

j All parameters correspond to information that could be taken or deduced from information on shipment manifests.

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MANIFEST TP Needed Data Elements 1

The computer data base should provide a detailed description of the physical, chemical, and radiological characteristics of LLW. The waste description should be on a container, as opposed to a shipment, basis.

2.1.3 Tracking Inventories of Specific Radionuclides i As stated in paragraph 61.7(b)(2), in licensing a LLW disposal facility,'"For certain radionuclides prone to migration, a maximum disposal site inventory based on the characteristics of the disposal site may be established [as license conditions) to limit potential exposure." These inventory limitations may depend on waste packaging and waste pvsical and chemical characteristics, since the rates at which radionuclides will be released from disposed waste will depend upon these factors. For example, release of radionuclides from '

disposed waste would be inhibited if the waste was in a corrosion-resistant waste form, as are most activated metals, or packaged in a high integrity container, and would be enhanced for wastes containing chelating agents.

To comply with any license conditions restricting radionuclides inventories, staff believe that an onsite. computer recordkeeping system will be needed. The computer system will allow the operator to keep a running track of radionuclides inventories to determine the proximity of these inventories to the site Ifmits.

To allow regulatory agencies to monitor compliance, inventories should be periodically reported.

2.1.4 Records and Reports Requirements for record maintenance and reporting at a LLW disposal facility are provided in 10 CFR Section 61.80. Paragraph 61.80(a) is a general requirement that a licensee keep any records and make any reports as required by license conditions or by the rules, regulations, or orders of the Commission. Paragraph 61.80(e) requires that each licensee, upon receipt and acceptance of a LLW shipment, record the following: the date of disposal; the disposal location; the condition of the waste packages as received; any discrepancies between materials listed on the manifest and those received; evidence of leaking or damaged packages or radiation or contamination in excess of regulatory limits; a description of any repackaging operations; and any other information required as a license condition.

Paragraphs 61.80(g), 61.80(1), and 61.80(j) address reporting requirements.

Paragraph 61.80(g) addresses safeguard reporting requirements by referencing Sections 30.55, 40.64, 70.53, and 70.54. Section 30.55 requires a report to NRC describing any incident or attempt of theft of tritium exceeding 10 curies at any one time, or more than 100 curies in any year. Section 40.64 contains a similar reporting requirement for source material, except that the specified quantities are 15 pounds at any one time or 150 pounds in a year. Section 40.64 also imposes requirements for reporting receipt or transfer of source material and for reporting inventories. Sections 70.53 and 70.54 reference

MANIFEST TP other sections of the NRC regulations imposing a similar reporting requirement for receipt, transfer, and possession of special nuclear material. Receipt or transfer of source and special nuclear material is reported on Form DOE /NRC-741; inventories are reported on Form DOE /NRC-742.

Paragraph 61.80(i) requires an annual report containing information such as a waste class-specific summary of waste received, a per nuclide description of any environmental releases, the results of the environmental monitoring program, and so forth. Paragraph 61.80(j) references Section 70.52 addressing repor% of accidental criticality or loss or thef t or attempted thef t of special nuclear material.

Section 20.311 of Part 20 is applicable to disposal facilities licensed under Part 61, as well as to existing disposal facilities. Among other provisions, Section 20.311 requires that a disposal facility operator maintain copies of all completed manifests or equivalent documentation until the Commission ,

authorizes their disposition.

Although paragraph 61.80(c) permits paper or microfiche copies of records maintained pursuant to Section 61.80, operators at all existing LLW disposal facilities have installed computer recordkeeping systems. The NRC staff believes that future disposal facilities should also install computer recordkeeping systems to facilitate storage and management of the manifest data base and to make reports as required by regulations and disposal facility license conditions.

2.1.5 Assessing Possible Problems A computer data base would help regulatory agencies and disposal facility operators to identify and assess the significance of possible problems Lt the disposal facility. For example, to comply with NRC regulations in Section 61.56 for waste structural stability, many licensees either solidify wastes or package wastes inside high-integrity containers (HIC). If a problem was observed with either a solidification media or a HIC design, a computer data base would enable an estimate of the implications of the problem with respect to public health and safety.

2.2 Need For and Uses of a National LLW Computer Data Base Significant needs and uses from an overall, national basis include:

o NRC's national regulatory oversight responsibility; o Inspection of waste generators for compliance with regulations; o Accountability and control of radioactive material; and o Miscellaneous technical studies and analyses.

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' MANIFEST TP 2.2.1 NRC's National Regulatory Oversight Responsibility NRC has responsibility for regulating and licensing the commercial and nondefense use, transfer, and disposal of source, byproduct, and special

. nuclear material. In discharging this responsibility, NRC is empowered to relinquish part of its regulatory authority to the States. This ir.cludes the authority to license commercial disposal of LLW in licensed facilities.

Despite the strong role of the States in LLW disposal, NRC retains the overall responsibility to develop and issue regulations, perform generic safety and environmental assessments, and prepare guidance for the safe management of radioactive material. This is a national responsibility, independent of the licensing of any specific facility.

To meet this responsibility, NRC must perform diverse activittas such as the .

following: (1) monitoring the adequacy of LLW disposal regulations, (2) preparingassessmentsfordevelopmentofregulationsandguidance,and(3) performing other regulatory activities. .

Monitoring the Adequacy of LLW Disposal Regulations One important NRC responsibility is to monitor the adequacy of the existing regulatory structure for LLH disposal. It is impossible to do this without a detailed knowledge of the radiological, physical, and chemical characteristics of LLW.

NRC's LLW disposal regulations, established in 1982 as a new 10 CFR Part 61 and as amendments to 10 CFR Part 20, were developed based on NRC's understanding of the chemical, physical, radiological characteristics of LLW. NRC developed several performance objectives and technical criteria, and tied these separate requirements together using a radioactive waste classification system. The greater the " hazard" of the LLW to be disposed, as determined by the concentrations of specific radionuclides within the LLW, the more stringent the disposal requirements.

Since the Part 61 rule was promulgated, there have been indications that the physical, chemical, and radiological characteristics of LLW are changing.

Licensees have significantly reduced waste volumes, either by administrative procedures or by physical processing. This trend tends to increase the radionuclides concentrations in particular waste streams. Another trend is licensees' increased use of chemical decontamination processes; wastes from these processes contain chelating agents that can increase the mobility of radioactivity from disposed waste. Changes in technology tend to change the radionuclides distributions in waste.

To the extent that waste characteristics significantly change, questions arise regarding the completeness of the Part 61 regulations. A computer data base'of LLW information would help NRC to monitor trends, and to assess the need for

MANIFEST TP i

regulatory amendments or for additional guidance. It would help NRC to identify where additional research is needed.

A computer data base would help NRC identify the significance of potential problems. Section 2.1.5 addressed use of a computer data base to help assess the implications of a possible problem at an individual disposal facility. A computer data base, on a national level, would help NRC address problems on a national level.

Assessments for Development of Regulations and Guidance Analyses performed on a generic level, to establish regulations and guidance or to perform generic environmental assessments, are similar to those performed for licensing a disposal facility. Examples of past impact analyses are given in the Draft and Final Environmental Impact Statements for the Part 61 regulation (Refs. 5, 6). To perform these analyses, NRC must generally compare alternatives in terms of impacts and costs.

A detailed data base on the LLW source term is needed to determine the health and safety implications from possible exposures by such pathways as I radioactivity migration, waste transportation, and so forth. In addition, and  !

i in accordance with the Regulatory Flexibility Act of 1980, such a source term is needed to determine the costs of implementing alternative requirements. i (The Regulatory Flexibility Act requires that each Federal agency consider the economic effects of an agency action on small entities.) This point can be illustrated by an example.

Consider a proposal to impose a solidification requirement for a particular waste stream -- say, fon-exchange resins -- exceeding a certain radionuclides concentration. To determine costs and radiological impacts, the staff would need to know the fraction of all ion-exchange resins, prior to solidification, that would exceed alternative concentrations. To do this, staff would need to know the distribution of radionuclides within the wastes and the fractional distribution of volumes of ion-exchange resins over a series of concentration ranges. To assess impacts, staff would also need to quantify the presence of chelating agents within the resins.

Existing ton-exchange resins contain a broad spectrum of radionuclides and are delivered to LLW disposal sites in a variety of containers and in a range of concentrations. Some resins are solidified. For accurate analyses, staff must i analyze the existing, "as-disposed," waste data to obtain the volume and other waste characteristics prior to solidification and packaging. Factors to be considered in this calculation include the void (or freeboard) space in the container, the fraction of ion-exchange resins that have been solidified, and the solidification loading. Container radiation levels must be know to assess I the potential for occupational exposures arising from additional waste handling activities.

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. MANIFEST TP Once this is known, alternatives can be considered on an common basis. To the extent that a proposed requirement causes the disposed ion-exchange volume to

. increase, costs would increase. Among other reasons, there would be a need for

' additional waste containers and additional shipments to disposal sites. The types of containers used, and the need for particular types of transport vehicles, each able to carry different amounts of waste, depend on factors such as'the radiation levels. To the extent that a proposed requirement results in additional waste handling, occupational exposures would increase.

At the disposal facility, one would assess the difference in potential impacts resulting from imposing alternative requirements. Each alternative requirement could change the projected radiological, chemical, and physical characteristics of the waste. In addition, factors such as change in waste volume, types of containers, radiation levels, and waste classes influence site operations, affect disposal efficiency, and bear upon the disposal rate structure. ,

Other Regulatory Activities NRC performs a number of other regulatory activities. One of these activities is the review of packaging and shipping procedures for fissile materials and for other licensed materials in excess of Type A quantities (as defined by DOT regulations). NRC isssues. certificates of compliance (CoC) for approved packages and renews these certificates of compliance every five years.

Reusable packages (" casks") are frequently used to transport LLW containing radionuclides in quantities exceeding DOT Type A limits. A computer data base on historical use of approved packages would help NRC set priorities for review of CoC renewals. In addition, if a problem was known or suspected about a particular package, 'a computer data base would help NRC to understand the extent of the problem and its health and safety implications.

2.2.2 Inspection of Waste Generators A computer LLW data system would help the staff inspect licensees for compliance with Part 61 requirements for waste classification and characterization. It would augment staff inspections for compliance with Part 20 requirements for describing wastes in manifests, and with DOT I requirements for preparing waste shipments for safe transport to a disposal

. facility.

Use of Computer System for Inspection Ecch NRC Regional Office could be provided access to the LLW computer data system. As part of an inspection, NRC staff could obtain historical waste I shipment information for a specific licensee. This information would be used to help identify possible problems with a licensee's waste management program, or at least identify areas of concern.

MANIFEST TP Using a computer data system, inspectors could quickly check shipment records to determine if the waste has been accurately characterized and classified for pur

61) poses.of safe This would be transportation done through use(49of CFR Part 172) classification and disposal subroutines (10 CFR Part available through the computer system. As another application, inspectors could compare radionuclides scaling factors among different waste streams to help determine if

'licenseet-have' expended reasonable effort to develop these scaling factors on a facility and waste stream basis as called for in the " Technical Position on Radioactive Waste Classification" (Ref. 7).

As another application, the radionuclides distribution within a waste stream could be examined. The regulatory staff have occasionally observed questionable descriptions of wastes on shipment manifests. Examples are listed below:-

1. Shipment manifests that report stable or nonexistent isotopes.

2. Radionuclides distributions that, based on consideration of other, similar,'

types of waste, are reported in unexpected isotopic ratios.

3. Shipment manifests indicating the radiation levels at a container surface that are not appropriate to the listed radionuclides types and quantities.

A computer data system would allow easier identification and investigation of questionable manifest citations.

There are other applications of a computer data base. For example, licensees for which shipment discrepancies are observed could be given higher priority

-for inspection ~of waste management programs. Higher priority could also be given to licensees who have recently significantly changed the volume or activity of waste shipped to a disposal site, as a significant change suggests a change in facility operations.

Needed Data Elements Needed data elements include the identity of the shipper, the volumes, 4 radionuclides, activities, and chemical characteristics of specific shipments and containers of waste, plus past instances of manifest and shipment discrepancies.

2.2.3- Accountability and Control of Radioactive Material A LLW computer data system would enhance public health and safety by providing a means to monitor the chain of custo(y of LLW as it is generated, processed, transported, and eventually disposed.

As noted in Section 1.2, there has been an increasing trend whereby, from its original generation to its final delivery to a disposal facility, LLW passes through a number of hands. In 1988, nearly 25% of all LLW delivered to disposal facilities was handled by brokers and processors. Any step in the waste delivery chain -- temporary storage by a broker, processing, or disposal

i MANIFEST TP

-- could have taken place in a different State than that in which it was generated. Companies handling, processing, or disposing of the waste may be licensed by the NRC or may be licensed by an Agreement State. Given the rising cost of waste disposal, in the future this trend is likely to be even more significant.

Without a LLW computer data base of LLW manifest information, it may be  !

difficult to monitor the chain of custody of LLW as it passes from generation to disposal. As an example, consider a situation in which the regulatory agency within State A needs to check statements made by a licensee in that State about the disposition of waste material. (Persons terminating a specific license for byproduct material must, among other requirements in 10 CFR Section 30.36, properly transfer or dispose of byproduct material and submit a completed Certificate of Disposition of Materials (form NRC-314). On the Certificate, the licensee must identify his name, address, license number, and ~

license expiration date. The licensee must describe the specific disposal procedures. )

The licensee claims to have sent the material to a processor located in State B. But the regulatory agency in State A has no authority to inspect the records of the waste processor, Upon request, the regulatory agency in State B might do so as a favor to State A. But such an action would likely be time consuming and disruptive to State B's inspection schedule, and in any case, probably wouldn't be normally done as part of a routine inspection. Thus, unless the regulatory agency in State A was aware of specific, suspicious information, it is unlikely that much would be done to confirm the licensee's statements.

The concern for loss of accountability and control has been heightened by a number of incidents involving lost or abandoned radioactive material or occurrences of unexplained radioactive contamination. In 1987, for example, a lost Brazilian teletherapy source resulted in fatalities and extensive contamination. In 1986, the J. C. Haynes Company reported to NRC that waste containing americium-241 had been properly disposed. Instead, the waste had been illegally transferred to Wright-Patterson Air Force Base, where persons unaware of the nature of the waste accidentally contaminated a storage building.

Needed Data Elements The identity of the waste generator should be included as a data element. The identity of the waste generator should furthermore be tracked back through possible waste collectors and processors, who should also be identified as data elements.

The data base should describe the waste sufficiently to provide reasonable assurance that the licensee's certification is correct. If questions arise, i staff needs to know enough about the waste to be able to communicate with the licensee and others on an informed basis. This infers the need for waste-

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MANIFEST TP container-specific information. Hence, data elements should include a description of the waste physical' and chemical characteristics, the waste

. packaging,'the_ waste volume, the total activity and activity of component radionuclides, the contained amounts of source and special nuclear material, and the waste. shipment and disposal dates. Other information includes the name of the transporter and_the package radiation levels.

2.2.4 Miscellaneous Technical Studies and Analyses There are a number of needs for and uses of a LLW computer data base in the-area of technical studies and analyses. The need for a particular study may be purely technical -- that is, to increase staff knowledge of LLW characteristics to improve disposal safety. The need for a particular study may result from an allegation of impropriety filed and investigated per NRC procedures, or from a request filed' pursuant to 10 CFR 2.206 to institute a proceeding on a license.

The need may arise because of a petition for rulemaking.. ,

The need for a particular study is difficult to predict;. therefore, the LLW computer data. base should be as complete and as flexible as practical. Uses of the computer data base may include identifying generators producing specific

. types of wastes or generators producing particular radionuclides in specific quantities. There may be a need to identify specific categories of generators in particular. regions of the country. There may be a need to study the radiological or chemical characteristics of particular types of_ wastes such as activated metals or ion-exchange resins.

3.0 REGULATORY POSITION This chapter is divided into two sections. Section 3.1 addresses the minimum information that should be included on LLW shipment nanifests. Section 3.2 addresses the design, use, and maintenance of a disposal facility computer recordkeeping system, plus the minimum information to be transferred to the computer system, including documentation that would be provided by the disposal facility operator rather than the waste shipper. Section 3.2 also addresses storage of manifest information at a LLW storage facility established by a Compact to meet the provisions of the Amendments Act.

3.1 Minimum Data Elements in Shipment Manifests This section addresses the minimum information,.important for waste disposal, that should be included in LLW shipment manifests. Specific data elements are summarized in Table 1 and discussed individually in Sections 3.1.1 through 3.1.5. These sections address general information, shipment information, container information, uncontainerized waste information, and multi-generator waste information. This discussion doesn't consider information to be provided pursuant to 49 CFR Part 172 or to disposal facility license conditions.

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' MANIFEST TP

, 3.1.1 General Information -

L Identity of Waste Generator The identity of the waste generator is required by Section 20.311, as is the generator address'and the telephone number. .The generator address should indicate the facility generating the waste, as opposed to a corporate headquarters. The telephone number is needed to provide a contact in case that there are questions about the shipment.

The identity of the waste generator is needed for a variety of reasons. The identity is necessary to conduct compliance inspections of waste received at disposal sites, to assist in regulatory agency inspection of waste generators, and to help assure accountability and control of radioactive material.

The identity of the generator is needed to help ensure that possible releases of radioactive material from the disposal site are within regulatory limits.

Knowing the waste generator, the processes generating the waste can be determined,' and the physical and chemical attributes of the waste (which are factors influencing environmental release) are better understood.

Waste generators should be distinguished from site customers. For example, waste shipped from some licensees is handled and processed by a vendor such~as a company providing a range of waste management services. Such vendors may process and package waste using mobile solidification equipment.and deliver the waste to the disposal facility. Such vendors, although they may be billed for disposal services by the disposal facility operator, are not the actual generators of the waste.

The identity of the generators should be tracked through waste brokers and processors on its progress from generation to disposal. For waste handled by brokers, manifests should indicate which centainers have been contributed by which. generators. Minimum information to be tracked for processed waste, in which more than one generator contributed waste to a single waste container, is addressed in Section 3.1.5.

Generator Type This refers to the general industry generating the waste. Example industries include utilities, government, colleges and universities, hospitals and medical services, and other industries.

The information is needed so that particular kinds and quantities of wastes can be associated with particular industries. For example, there may be a need to know whether generation of quantities of particular radionuclides or waste forms is dominated by particular industries. A need to know may arise because of an allegation or a petition for rulemaking.

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MANIFEST TP Broker Name, Address, and Telephone Nunber The identity of the waste broker is needed to conduct compliance inspections of waste received at disposal sites, to assist in regulatory agency inspection of waste generators, to help assure accountability and control of radioactive material. A telephone number is needed to provide a contact in the event that there are questions about the shipment. l Waste Processor Name, Address, and Telphone Number The identity of the waste processor is needed for similar reasons. The processor identity is necessary to conduct compliance inspections of waste received at disposal sites, to assist in regulatory agency inspection of waste generators, to help augment accountability and control of radioactive material.

A telephone number is needed to provide a contact in the event there are questions about the shipment. .

Identity of Waste Carrier The identity of the waste carrier is basic information needed to track shipments of LLW to disposal sites.f If there wts a problem with a particular shipment, the identity of the waste carrier is needed to recreate events.

Information about the waste carrier must be included on shipment manifests pursuant to Section 20.311; this regulation mandates provision of either the name, address, and telephone number or the name and EPA hazardous waste identification number of the pers'on transporting the waste.

3.1.2 Shipment Information The data elements described in this section, which should be provided for each waste shipment, are applicable to the waste shipment as a complete entity.

Total Quantities of H-3, C-14 Tc-99, and 1-129 Part 20. requires that shippers indicate the total quantities of these four isotopes on shipment manifests. All of these isotopes are mobile and, within the exception of tritium, are long-lived. They are specifically highlighted on manifests because, at the time of the rulemaking promulgating Section 20.311, NRC staff felt that these radionuclides would be the most likely candidates for disposal facility inventory limits pursuant to section 61.7.

Shipment Date The date when the waste shipment left the shippers facility should be included.

The shipment date is basic information needed to help regulatory agencies track shipments of LLW; thus, it helps assure accountability and control of radioactive material. If there was a problem with a particular shipment, a regulator would need the shipment date, plus other informa;. ion, to recreate events.

MANIFEST TP Waste shipment dates, coupled with dates when shipments are received at disposal sites, can be used to estimate the travel times between waste generators and the disposal facility. The shipment travel time is one of a number of parameters used to determine the environmental impacts associated with waste transportation to a disposal site.

Shipment Waste Volume The shipment waste volume is one of the basic descriptive elements of a shipment. Thus, knowledge of the shipment waste volume enhances accountability and control of radioactive material.

Knowledge of the shipment volume is needed for some environmental assessments.

For example, the amount of waste that can be delivered per vehicle is a parameter in assessments of the radiological impacts of transport of waste to a disposal site. Aillowable shipment volumes depend on such factors as waste form, radionuclides activity, radiation levels, and weight. The shipment volume is a parameter used to plan operational aspects such as the need for equipment and personnel. All considerations equal, for example, a greater nu2er of smaller shipments implies a need for additional personnel and equipment.

Finally, DOT regulations in 49 CFR 172.202(a)(4) require that "except for empty packages, the total quantity (by weight, volume, or otherwise appropriate) of the hazardous material . . ." The total shipment volume would satisfy this requirement, as would the total activity, and is included on existing shipment manifests.

Shipment Waste Activity Like shipment volumes, the total activity is one of the basic descriptive elements of a shipment. Thus, knowledge of this information enhances accountability and control of radioactive material. In addition, knowledge of the shipment activity, along with other information, facilitates operator and i regulatory agency verification of operator compliance with any license condition regarding site activity possession limits. Furthermore, knowledge of the shipment activity facilitates verification of compliance with DOT requirements for identifying highway would controlled quantities.

Number of Waste Containers The number of waste containers in a shipment is basic information needed to regulate LLW management and disposal. This information is needed for a nuder of environmental and safety assessments. For a given volume of waste, for example, a greater number of smaller waste containers implies additional waste shipments. All things being equal, more containers means that the waste surface area is larger. The waste surface area is one parameter inportant for determining the quantity of radioactive material leached from waste. t I

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MANIFEST TP The number of waste containers needed for a given volume of waste is information used for planning disposal operations. All things being equal, the more waste containers per given volume of waste, the less efficient is space' used in a disposal cell. Similarly, the personnel and equipment requirements would be larger.

The number of waste containers within a shipment serves as one of the basic descriptive elements of the shipment; hence, the information helps to ensure accountfoility and control of radioactive material.

Identification Number of Shipment Cask Transport packages (" casks"), designed to convey radioactive materials in quantities exceeding DOT Type A quantities, are reviewed and approved by NRC, as well as by DOE and DOT. Each design is assigned a unique international identification number. An example identification number is as follows: .

USA /xxxx/B()

where the first three letters denote the country issuing the identification number. The following four-digit number identifies the package design and the particular Federal agency approving the design. The last letter denotes the I type of packaging.

The shipment cask identification number should be included on manifests and in the computer data base. There are two basic needs. First, in the event that there was concern on the safety of a particular cask design, a data base on cask use will help State and Federal regulatory agencies assess the magnitude of the concern. Second, a data base on casks most often used will help NRC set priorities for regulatory review of renewals of certificates of compliance.

Designs used more often could receive a higher priority.

Total Amount of Special Nuclear Material in Shipment Along with waste receipt and disposal dates, this information can be used to i verify compliance with site license conditions regarding site possession limits for special nuclear material. The information is needed to complete forms DOE /NRC-741 and DOE /NRC-742.

Total Amount of Source Material in Shipment Along with waste receipt and disposal dates, this information can be used to verify compliance with site license conditions regarding site possession limits for source material. The information is needed to complete forms NRC/ DOE-741 and NRC/ DOE-742.

I MANIFEST TP

.3.1.3 Container Information The data elements described in this section should be provided for each waste container in each waste shipment.

Container Identification Number Waste containers in a shipment should be identified individually.

' Identification numbers marked on waste containers should correspond with identification numbers provided on shipment manifests.

Container Description A physical description of the waste container should be provided. The description should be concise yet sufficient to identify the container (e.g., -

metaldrum,woodenbox). Vague descriptions such as " strong tight container" should not be used. The description should specifically indicate if the

-container-is a high integrity container HIC. Container descriptions should be

! indicated on manifests using an index list. An example container list is e provided below:

Wooden box or crate Fiberglass tank or liner Metal box Demineralized

. Plastic drum or pail Gas cylinder Metal drum or pail Bulk, upackaged (may not be allowsd Metal tank or liner atsomesites)

Concrete tank or liner Unpacka

' Polyethylene tank or liner Other (ged components or equipmentspecify o A physical description of the waste container is needed for a number of reasons. It is needed to estimate the potential for radiological release from l 'a disposal facility. It is needed to help assure accountability and control of the radioactive waste, as it serves as a basic descriptive element of the waste.

Information about containers is needed to estimate impacts from transport of LLW to disposal sites. The number of waste shipments depend, in part, on the l:

E I transport efficiency and operations provided also depend bythe upon different waste types of packages.

containers used. Disp (osalefficiency Depending upon the distribution of waste by type of container, different mixes of site personnel and equipment would be needed.)

Information about waste containers can be used to estimate the weight of the waste _ form, a needed data element. Weights currently listed on shipment manifests correspond to the waste of the waste plus the container. Une approach would be to provide on shipment manifests the weight of the waste plus container as well as-the weight of the waste itself. But this alternative

' MANIFEST TP requires use of additional space on shipraent manifests. On the other hand, if an acceptable container description was provided, and from another source on the manifest the container envelope volume was known then the weight of the container could be estimated with acceptable accuracy,. The weight of the container would then be subtracted from the gross weight to arrive at the weight of the waste form.

The mass of the waste form is needed for a number of reasons. First, to accurately check the classification status of waste as it arrives at a disposal site, site o waste form. perators Second,must know, of knowledge forthe transuranic radionuclides, waste mass the aids technical mass ofofthe analyses waste characteristics. To study waste characteristics -- for example, the distribution of activity within a particular waste stream -- one needs to focus on the waste devoid of the packaging. Third, the waste mass is needed, in conjunction with information on the fraction of the waste mass that contains chelating agents, to determine the total quantity of chelating agents disposed .

at a disposal facility.

High Integrity Container Vendor The manufacturer of the HIC should be indicated. This information should be indicated on manifests using an index list.

HICs are cosunonly used to stabilize Class B and C low-level wastes. A concern could arise regarding waste disposed using a particular HIC design. A data base of HIC volumes, disposed activities, and manufacturers would allow

-licensees and regulators to assess the magnitude of the potential problem.

Container Gross Volume The overall (envelope) volume of the waste container is basic information used for a variety of applications.,

The container gross volume, as opposed to the volume of waste within the container. is the actual waste volume that is disposed. The overall container volume is used to check disposal site allocations and to assess disposal charges. The container size, along with other parameters such as activity, weste physical description, and the container description, foms a basic descriptive element of the shipped waste. This information enhances accountability and control of radioactive material.

The container volume is a parameter used in environmental and safety assessments. For example, by knowing the distribution of volumes of containers used to dispose of a waste stream, plus other information such as container and waste descriptions, one can generally estimate the surface-to-volume ratio of the wsste within the container. The surface-to-volume ratio is used as a parameter in estimating release of radioactivity by leaching.

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MANIFEST TP Gross Mass of Waste and Container The computer data base should include the gross mass of the waste and container. This information can be used, along with other information, to help verify the classification of waste delivered to the disposal site. Along with the wasts volume and other information, it can be used to determine the density of the waste. The overall mass of the waste will be needed to fill out forms DOE /NRC-741 and DOE /NRC-742 for receipt, transfer, and inventories of source and special nuclear material.

This information helps to assure accountability and control of radioactive

. material, as it serves as a descriptive element of the waste.

Waste Physical and Chemical Description An understanding of the physical and chemical form of the waste is very -

important for safety and environmental assessments. This is because the release of radioactivity from waste depends on the waste physical and chemical characteristics. For this reason, NRC regulations in 10 CFR Section 20.311

. require that shipment manifests provide a physical description of the waste as.

well as the principal chemical fonn. DOT regulations in 49 CFR 172.203(d)(ii) require a " description of the physical and chemical form of the material, if the material is not in special form (generic chemical description is acceptable for chemical form)."

- For computer processing of data, the waste physical and chemical descriptions should be keyed to a series of index codes. This leads to some conflicts, however.

DOT regulations require that the description of the physical and chemical form of' shipped radioactive material not contain any code or abbreviation. Another ,

problem is that LLW is heterogeneous. Assuming that an index list is used, one has the question of specificity. If the index list is too short, the information.is of little use. Much waste would be lumped into meaningless  ;

categories such as " dry solid," a description that greatly reduces ones ability to predict radioactivity release under disposal or accident conditions. If the index list is too lon between waste forms,the g, data and licensees base will be have difficultySome inaccurate. making fine distinctions wastes are unique,

. generated by only one or a few licensees. Waste containers frequently contain mixtures of waste streams; for example, excess space in liners nominally containing ion-exchange resins is often filled with trash.

The staff believe that an acceptable approach would be to use a waste description index code list but to complement this index code with a written description of the chemical form. (This approach enables com l of significant waste streams yet satisfies DOT requirements.)puter manipulation The waste I

description index code would be used for identification of the basic type of waste; the chemical description would provide additional information. For example, the waste description code might indicate ion-exchange resins, while L

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MANIFEST TP the chemical form descri cation, mixed bed, etc.)ption

. Or thedescribes the type waste description of ion-exchange code might indicate resin (anion, activated reactor components, while the chemical form description describes the i type of component (control rod blades, burnable poison assemblies, etc.) {

An example waste description list is provided below.

Solidified liquid Mechanical filter Filter media Sealed source Dewatered ion-exchange media Absorbed aqueous liquid Solidified ion-exchange media Absorbed organic liquid Compactible trash (mostly paper Animal carcasses orplastic) Other biological material Noncompactible trash Foils or absorbed gas Charcoal Wire Contaminated equipment Paint or plating -

Incinerator ash Demolition rubble Soil Neutron activated metal

-Glassware or labware Other (specify material)

If two or more waste forms are contained in a single container, an acceptable approach would be to list the most prevalent waste forms.using an appropriate number (e.g., up to three) of index codes. In this case, the index codes should be ordered by waste form volume.

Additional information should be provided on manifests for unique or high activity waste streams, perhaps as an attachment to the manifest. Staff believe that this can best be done on a site-specific basis, considering the most significant wastes delivered to the disposal site. " Significance" for a particular site may be determined on the basis of activity, for example, or specific radionuclides of importance for a limiting impact assessment pathway.

Che hting Agent Content  ;

Information on the quantity of chelating agents within LLW is needed to perform environmental assessments of LLW disposal. Chelating agents affect the release of radionuclides from waste forms, as well as the migration of radionuclides through groundwater.

Section 20.311 requires that manifests indicate -- (1) specific waste containers containing chelating agents in quantities exceeding 0.1% by weight, and (2) the percent of the waste that consists of chelating agents. This information should be transferred to the computer data base. The former requirement is included to allow operators to identify wastes containing significant quantities of chelating agents. Paragraph 61.12(f) requires that applicants for a disposal facility license specifically describe the methods to be used in the handling and disposal of wastes containing chelating agents.

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r MANIFEST TP i

Staff expects these methods will include disposal in disposal cells segregated from waste not containing chelating agents. The latter requirement is included to aid in environmental assessments, as the chelating agent percent can be used,'along with the mass of the waste ferm, to determine the total amount of chelating agent within a disposal cell.

Waste and Stability Class Waste class refers to the classification of the waste per Section 61.55; it is information specifically required in manifests by Section 20.311. Stability class refers to the structural stability of the waste pursuant to Section.

61.56. The two concepts can possibly be combined, assuming that Class B and C wastes must be delivered to the disposal facility in a stable form: Class A (Unstable) waste, Class A (Stable) waste, Class S waste, and Class C waste.

(Combining the two concepts would not be appropriate, however, if Class B or C wastes were delivered to the disposal facility in a structurally unstable form,'

as might be the case if structural stability is to be provided not by the waste itself, but by disposing the waste in a structure that provides stability.)

The waste and stability class should both be included in LLW shipment manifests. Both are needed for environmental assessments of waste disposal and for other technical studies and analyses. This is because pursuant to paragraph 61.52(a)(1), Class B and C wastes must be segregated during disposal from unstable Class A waste. Stable Class A waste, however, may be disposed mixed with Class B and C wastes. The waste class is needed to prepare reports pursuanttoparagraph61.80(1).

Solidification Agej L

l The solidification agent is an item specifically identified in Section 20.311 1 l 'for inclusion in shipment manifests. This information is needed to help l

determine the rates of release of radionuclides from disposed waste. Leaching of radionuclides from different solidification agents occurs at different j- rates. For example, for cement waste forms, it has been experisontally shown that cesium leaches faster from cement than strontium, and that strontium leaches faster from cement than cobalt (Ref. 8). This relationship does not hold for bitumen and vinyl ester styrene waste forms.

(- Staff has also considered whether additional information about solidified wastes should be included on shipment manifests. Such information could include the the curing time, the waste loading, and the ratio of the waste form surface area to the solution volume. Brookhaven National Laboratory has indicateed that leaching from cement waste forms is dependent on these factors (Ref.8). 1 Staff is not at this time recommending that this additional information be included on all shipment manifests. To include such information would increase ;

the size and complexity of the shipment manifest, and staff is not sure whether this would be justified on a generic basis. In 1987, solidified liquids and I

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MANIFEST TP ion-exchange resins constituted .nly about 10% of the LLW volume and about 15%

of the LLW activity. It doesn't seem reasonable to impose detailed reporting requirements on waste streams that may not be significant in terms of potential environmental releases from a LLW disposal facility. Additional information is needed about the content of critical radionuclides within solidified wastes, and the fraction this content represents in terms of all LLW.

Staff believes that a better approach is to obtain detailed information on solidified waste characteristics on an as-needed basis, depending upon specific disposal facility site characteristics and on the waste streams and radionuclides inventories projected for disposal at that facility.

Solidification Vendor The name of the solidification vendor should be provided along with the type of solidification agent. Different vendors use different chemical formulations. .

If'a problem with an approved solidification medium was detected, a data base

! on the solidification media most connonly used would help regulatory agencies

( and disposal site operators determine the possible extent of the problem.

Activity by Specific Radionuclides L This information is basic to all environmental and safety assessments on LLW i

transport and disposal. The information is needed to verify compliance with NRC and DOT regulations, to enhance accountability and control of radioactive material, and to perform a variety of technical analyses and health, safety, and environmental assessments.

Total Activity in Container The total activity in a waste container should be included in the data base.

The information is important for certain technical analyses. For example, one analysis could involve determining the distribution of activity in a given waste stream. The total activity forms a basic descriptive element of the waste; therefore, knowledge of this information aids accountability and control of radioactive material.

The total activity is obviously the sum of the activities of individual radionuclides. Staff, however, believe that the total container activity should be separately indicated on the manifest, in addition to the activities of individual radionuclides. It is information frequently used and it aids quality control activities. The total activity in individual waste containers must be included on shipment manifests pursuant to DOT regulations in 49 CFR l 172.203(d)(ii).

Special Nuclear Material Content l The mass of special nuclear material (SNM) is needed to verify compliance with site license conditions limiting special nuclear material quantities or

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g MANIFEST TP concentrations in individual waste ~ containers. In addition, the SNM mass within a waste package forms a basic descriptive element of the waste package; knowledge of this information aids accounta)1lity and control of radioactive

. material. Knowledge of the SNM mass in individual waste containers helps site operators confirm that the SNM content in a shipment or other accumulation of packages is in compliance with regulations and disposal facility. license conditions.

Source Material Content The source material mass within a waste container forms a basic descriptive element of the waste; knowledge of this information aids accountability and control of radioactive material. In addition, knowledge of the source material mass in individual containers helps to ensure quality control of the source material content within a shipment. The latter information is needed to verify

• compliance with limits imposed as disposal facility license conditions for possession of source material, and to file reports about source material receipt and inventory.

Container Radiatio'n Levels

' Container radiation levels should be included on LLW shipment manifests and in the LLW computer data base. First, knowledge of the radiation levels --

recorded by the: generators and confirmed by the operators -- provides a common sense check on the accuracy of the radionuclides information on the manifest.

As a perhaps trivial example, if the manifest states that the waste only contains tritium.and carbon-14, and the radiation levels are higher than background, then it is' apparent that the package has not been characterized correctly.

Second, container radiation levels' dictate the amount of shielding required

'during waste transportation, which in turn dictates the types of transport vehicles and overpacks (casks) which must be used. These considerations influence the number of waste shipments to the LLW disposal site. All these considerations influence safety and environmental assessments of waste transport.

Third, if an information data base is available on the distribution of container radiation levels, then certain economic analyses could be more accurately made. Such economic analyses could be performed by Compacts establishing site disposal charges or by regulators perfoming cost / benefit calculations for rulemaking and other applications. The higher the package radiation levels, the more care is required in handling the waste. This translates to additional personnel, additional time, additional provisions for shielding, and additional costs.

'In current manifests, container radiation levels are recorded for measurements made at the container surface as well as at a one-meter distance. Both

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MANIFEST TP measurements should be included on LLW shipment manifests and in the LLW computer data system.

Hazardous Material Content Mixed waste is LLW containing source, byproduct, or special nuclear material regulated by NRC or the States under the Atomic Energy Act of 1954, as amended,

' as well as hazardous material regulated by EPA. No LLW disposal facility currently. accepts mixed waste for disposal, although NRC expects this situation to eventually change. When disposal capacity is established, persons shipping

. mixed waste to a treatment, storage, or disposal facility will have to address EPA's requirements for hazardous waste tracking, including use of a uniform hazardous waste manifest form.

Among'other requirements, the manifest instructs the generator to provide the following information about the waste: (a) DOT description (including proper .

shipping name, hazard class, and identification number), (b) number of containers,- (c) type of- container, (d) the total ' quantity of the waste, and (e) the unit '(weight or volume) applied to the total quantity.

Use of the EPA manifest to describe mixed waste presents some' drawbacks.

First, the assumption in the design of the EPA manifest is that the hazardous waste entatis the bulk of- the shipmen.t.. This'is likely not the case for most mixed waste; more likely, the hazardous material constitutes only a small fraction of the total contents of a'few containers. Second, the container type descriptions' aren't a good match with the types of containers used to dispose of LLW. Third, LLW container volumes are usually given in units of cubic feet, a unit not allowable on the EPA manifest forms. Fourth, there is no specific

-space on the EPA manifest form by which particular containers of waste can be identified. Fifth, the form would be awkward to use when waste shipments are made by brokers and processors, in which a number of generators may contribute waste to a shipment.

As a saving quality, however, the EPA uniform manifest form allows States to require that shippers provide additional infomation. Areas where additional information may be included are identified on the manifest by gray shading.

NRC staff believe that an acceptable approach would be to include, on LLW manifest continuation pages, a space to indicate for each container whether it contains mixed waste. -Such containers should be identified so that operators can. segregate such containers at the disposal facility and dispose them in disposal units specifically designed for mixed waste. The LLW manifest would then refer to the EPA uniform manifest for further details.

On the EPA manifest, the hazardous content of the waste would be identified according to the manifest instructions. In the shaded areas, however, two additional items of information would be added. First, a container identification number should be included to key the container back to the specific container described on the LLW manifest. Second, the weight

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i MANIFEST TP 1

percentage of hazardous material within the container should be provided separately for each description indicated. The quan' ty of hazardous material should be provided to characterize the hazard presented by the waste.

3.1.4 Uncontainerized Waste Information In the great majority of cases, waste will be delivered to disposal facilities in containers. But not always, as might be the case with loads of contaminated soil or large components such as a heat exchanger from a nuclear power plant.

(Delivery of uncontainerized waste may be prohibited at some disposal facilities.) For such wastes, the NRC staff believe that, at a minimum, the following information should be provided:

1. The weight of the waste;

2. A physical and chemical description of the waste; this description need only constitute a few words but must be sufficient to enable a reasonable estimate of release of the waste under disposal or accident conditions;

3. The weight percentage of chelating agent if the chelating agent exceeds 0.1% by weight;

4. The identities and activities of individual radionuclides;

5. The total activity;

6. The mass of special nuclear material;

7. The mass of source material;

8. The maximum radiation levels at the surface of the waste and at one meter; and

9. The identities and weight percentages of materials considered hazardous pursuant to EPA regulations in 40 CFR Part 261; this information should be provided on the EPA uniform manifest form, which should accompany the manifest required by 10 CFR Part 20.

3.1.5 Multi-Generator Waste Information This section is included to consider additional, container-specific information to be provided for waste containers which enclose mixtures of LLW originating from different LLW disposal facilities. That is, it would be applied to each container of waste in addition to that information addressed in Section 3.1.3.

It would also generally apply to those very unusual situations in which wastes are shipped to the disposal facility in an uncontainerized form, and for a given shipment portions of the uncontainerized wastes are contributed by different generators.

MANIFEST-TP NRC staff believe that there are two general cases that must be considered.

The first case involves homogeneous mixtures of wastes, such as would be

! typically the case for incinerator ash. In this case, one is considering an  ;

essentially uniform waste form, radically different from the waste originally j delivered to the processor. All that is required is to identify the generators and'the fraction of the waste mass (or volume) contributed by each generator.

The second, more complex, case involves heterogeneous mixtures of wastes. An example would be a container filled with a half-dozen " hockey pucks," the products of a high pressure compactor. In this case, each container may contain more than one waste form. The various waste forms, moreover, are largely unchanged from those wastes delivered to the processor's facility, except for obvious differences in waste dimensions and density.

-In this case, NRC staff believe that additional information is needed to track the physical, chemical, and radiological characteristics of the individual .

hockey pucks along with the identities of the waste generator. This is needed for more than one reason. For one reason, the specified characteristics serve to identify the radioactive material so that its chain of custody can be readily tracked._ Second, the specified characteristics are needed so that possible releases from the radioactive material can be predicted.

Thus, for heterogeneous mixtures of waste, such as the combined products from a large compactor, the manifest should identify each waste generator contributing waste to the waste container. For each generator, provide --

a. A physical and chemical description of the waste, including the solidification agent, if any;

b. The masses of source and special nuclear material;

c. Radionuclides and activities;

d. Total activity; and

e. The waste mass or fraction of the total waste mass within the container (or the waste volume or fraction of the total waste volume within the container).

3.2 Disposal _or Storage Facility Computer System This section is divided into two subsections. Section 3.2.1 addresses the staff's position on establishment of a computer recordkeeping system at a LLW disposal facility. It also addresses the staff position on establishment of a computer recordkeeping system at a LLW disposal facility established by a Compact pursuant to the Amendments Act. Section 3.2.2 addresses the staff's position on the minimum information to be stored in and processed using this system.

MANIFEST TP 3.2.1 Computer System The operator should maintain access to a computer system for electronic storage and manipulation of infonnation transcribed from manifests accompanying shipments of radioactive waste to the disposal or storage facility. The operator should develop and use this computer system in accordance with a quality assurance program that at a minimum addresses system development, verification, operation, maintenance, and codification. The operator should impose controls (e.g., backup data storage, access controls) to ensure that the stored data is protected against loss or unauthorized modification.

Manifest information should be transferred to and stored in the computer system as waste is received, inspected, and disposed. Information should be entered into the system according to quality control procedures to ensure accurate transcription of data. ,

Information may be transferred to and stored in the computer system before receipt of waste, provided that the accuracy of the transferred information is confirmed when the shipment actually arrives and is inspected. Temporary disablement of or loss of access to the computer system need not preclude waste receipt and inspection, provided that the information is transferred within a reasonable period following receipt and inspection.

The computer system should be capable of tracking the origin, transport, disposition, and enaracteristics of individual containers of waste. The system should also be capable of performing a variety of information sorts and analyses, as required to make reports as specified by regulations or by license conditions. At a minimum, the system should be able to determine parameters such as waste volume, radionuclides inventories, radiation levels, or chelating agent content as a function of other parameters such as the waste stream, the solidification agent, the waste or stability class, the waste generator, or groups of waste generators (e.g., nuclear utilities, hospitals).

3.2.2 Information Stored The information to be stored and manipulated within the computer system should be that contained in the shipment manifest as described in Sections 3.1.1 through 3.1.5. In addition, information should be stored that is not part of the shipment manifest but is recorded by the facility operator when waste is received, inspected,anddisposed(orstored). This additional information addresses the location of the waste within the facility, the dates of waste receipt and disposal (or storage), a unique shipment manifest identification number, the maximum surface radiation level of the waste shipment, and the volumes of waste materials generated as part of facility operation.

Manifest Identification Number A manifest identification number should be provided. The manifest identification number is needed so that the user of the computer system can

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MANIFEST TP reference the particular manifest. The manifest forms the legal record of the waste shipment, and contains information in addition to that of highest

. priority for inclusion in the computer data base.

Shipment Receipt Date The date when the waste shipment arrives at the disposal facility should be provided. The information is needed for the same reaso..s as those given for

" Shipment Date" in Section 3.1.2.

Waste Disposal (Storage) Date

.This date is needed in the computer data base because it assists in ensuring accountability and control of radioactive material. Disposal facility operators must in any case record the date of waste disposal pursuant to paragraph 61.80(f). The disposal date can be used to check for compliance with-disposal facility possession limits.

Identity of Disposal Unit The disposal unit identity should be included for a number of reasons. The information helps to ensure accountability and control of radioactive material, and helps regulators and operators ensure compliance with the requirements in 10 CFR Part 61 to segregate structurally stable waste from structurally unstable waste. The disposal unit identity must in any case be recorded pursuanttoparagraph61.80(f).

The disposal unit identity provides information needed to estimate impacts from waste disposal. For example, factors such as the distance from a disposal unit to the site boundary affect impacts associated with release of radionuclides and transport by groundwater. Staff expects that different disposal units will contain significantly different quantities of radionuclides. Within a given disposal facility, there may be more than one disposal unit design.

Storage Location As applicable, the location of the waste within the storage facility should be identified. This is needed to enable recovery of waste for eventual disposal, and to maintain' accountability.

" Pallet" Volume The reference is-to pallets, bracing, or other materials that is included with waste shipments and is disposed (or stored pending disposal) as material  ;

suspected of contamination. Pallets and similar materials do not add activity to the disposal site but do take up space in disposal units. The result is that the volume of waste actually disposed is greater than the volume of waste shipped.

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MANIFEST TP The computer data base should include this information to ensure proper bookkeeping and material accountability.

Similarly, the computer data base should track the volume of material generated onsiteanddisposed(orstored)aswaste. Such waste material could be generated, for example, as part of decontaminating a vehicle. One way to track this volume would be to include it as part of the pallet volume, assuming that generated waste can be attributed to a particular generator or customer.

Another approach would be to prepare and record a " shipment" manifest listing the facility operator as the generator.

Shipment Maximum Surface Radiation Level The information is used as part of environmental assessments of transportation of waste to disposal facilities. .

4.0 IMPLEMENTATION

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Staff will implement this TP at new disposal facilities licensed pursuant to 10 CFR Part 61. For existing disposal facilities, staff will implement the TP on a case basis, considering such factors as the expectation of continued disposal facility operation.

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MANIFEST TP Table 1. Minimsm Data Elements General Information Identity of. Waste Generator Identity of Waste Processor Waste Generator Type Identity of Waste Carrier

. Identity of waste Broker

j. Shipment Information

.H-3, C-14,.Tc-99, and I-129 Content Number of Waste Containers Shipment Date Identification Number of Shipment Cask Shipment Waste Volume Special Nuclear Material Content.

Shipment Waste Activity Source Material Content Shipment Waste Activity ,

j Container Information Container Physical Description Container ID Number High Integrity Container Vendor Solidification Agent Hazardous Material Content Solidification Vendor Container Gross Volume Activity by Specific Radionuclides Mass of Waste and Container. Total Activity in Container Physical and Chemical Description Mass of Special Nuclear Material Chelating Agent Content Mass of Source Material Weste and Stability Class Container Radiation Levels Disposal Information Manifest Identification Number Shipment Receipt Date Storage or Disposal Date Pallet Volume Identity of Disposal Shipment Maximum Surface Radiation or Storage Unit Level

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Uncontainerized Waste Information (as applicable)

Waste mass Mass of Special Nuclear Material Physical and Chemical Description Mass of Source Material Chelating Agent Content Waste Radiation Levels Activity by Specific Radionuclides Hazardous Material Content Total Activity Multi-Generator Waste Information (as applicable)

Identity of haste Generator Activity by Specific Radionuclides Mass of Source Material Total Activity Mass of Special Nuclear Material Fraction of Waste Within Container

w=o; MANIFEST TP

5.0 REFERENCES

1. U.S. Nuclear Regulatory Comission, " Standard Review Plan for the Review of a License Application for a Low-Level Radioactive Waste Otsposal X Facility: Safety Analysis Report, NUREG-1200, Rev.1,.0f fica of Nuclear Material Safety and Safeguards, January 1988.

2. U.S. Nuclear Regulatory Commission, " Standard Format and Content of a License Application for a Low-Level Radioactive Waste Disposal Facility:

Safety Analysis Report," NUREG-1199, Office of Nuclear Material Safaty and Safeguards, January 1987.

3. U.S. Nuclear Regulatory Commission, " Environmental Standard Resiew Plan for the Review of a License Application for a Low-Level Radioactive Waste Disposal Facility: Environmental Report," NUREG-1300, Office of Nuclear Material Safety and Safeguards, April 1987. -

4. U.S. Nuclear Regulatory Commission, " Final Environmental Ir. pact Statement f on 10 CFR Part 61: Licensing Requirements for Land DispJst.1 of Radioactive Waste," NUREG-0945, Office of Nuclear Material Safety and Safeguards, November 1982.

5. U.S. Nuclear Regulatory Commission, " Draft Environmental Impact Statement on 10 CFR Part 61: Licensing Requirements for Land Disposal of Radioactive Waste," NUREG-0782, Office of Nuclear Material Safety and Safeguards, September 1981.

6. U.S. Nuclear Regulatory Commission, " Final Environmental Impact Statement on 10 CFR Part 61: Licensing Requirements for Land Disposal of Radioactive Waste," NUREG-0945, Office of Nuclear Material Safety and Safeguards, November 1982.

7. U.S. Nuclear Regulatory Commission, " Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification," May 1983.

8. Sullivan, T. and C.R. Kempf, " Low-Level Waste Source Term Evaluation:

Review of Published Modeling and Experimental Work and Presentation of Low-Level Waste Source Term Modeling Framework and Preliminary Model Development," NUREG/CR-4897, Brookhaven National Laboratory for U.S.

Nuclear Regulatory Commission, February 1987.

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