Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
SSINS No.: 6835
IN 83-05
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
February 24, 1983
Information Notice No. 83-05: OBTAINING APPROVAL FOR DISPOSING OF
VERY-LOW-LEVEL RADIOACTIVE WASTE - 10 CFR
SECTION 20.302
Addressees:
All production and utilization facilities, including nuclear power reactors
and research and test reactors, holding an operating license.
Purpose:
Modern radiation-detection equipment makes possible the detection of very
low concentrations of radionuclides in materials, including very low levels
of radioactive contamination in materials such as soils. A number of
licensees have expressed concern over the perceived need to package and ship
large quantities of such materials to low-level waste burial sites. Such
shipments are expensive and use the limited space available in burial sites.
The purpose of this information notice is to call attention to a little-used
section of NRC regulations [10 CFR 20.302(a)] that provides a method for
obtaining approval of proposed procedures for disposing of licensed material
and any other radioactive material involved, in a manner not otherwise
authorized in the regulations. This section of the regulations may be used
to obtain approval of proposed procedures for disposal of, among other
things, large volumes of material contaminated at very low levels, such as
contaminated soil, oil, or tools and equipment. It is expected that
recipients will review this information notice for applicability to their
facilities. No specific action or response is required.
Description of Circumstances:
In its Policy Statement on Low-Level Waste Volume Reduction (46FR 51100,
October 16, 1981) the NRC recognized the need to minimize the quantity of
waste generated and shipped to commercial waste-disposal sites. With one
exception, existing NRC regulations provide no minimum level of
radioactivity in waste from a licensee's facility that may be disposed of in
a manner other than as normal radioactive waste. That exception is the
provision, in 10 CFR 20.306, that licensees may dispose of certain levels of
tritium and carbon-14 in liquid-scintillation and animal-carcass waste
without regard to its radioactivity. In publishing its proposed licensing
requirements for land disposal of radioactive waste, the Commission
recognized the need for similar provisions for other radionuclides and other
wastes, wastes that would be exempt from the
*10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive
Waste," 46FR 38081, July 24, 1981.
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IN 83-05
February 24, 1983
Page 2 of 3
proposed 10 CFR Part 61* and would be of no regulatory concern. In the
notice of proposed rulemaking, the Commission stated that it believed that
such exemptions should be determined on a specific waste basis. Over
one-fourth of the commenters on the draft Environmental Impact Statement for
Part 61 endorsed the need for such provisions. The fundamental concern of
practically all commenters appeared to be not whether a generic or a
case-by-case approach should be taken, but rather that some action be taken
as soon as possible. The NRC staff believes that the current policy of
examining waste streams on a case-by-case basis will result in the quickest
and best results.
The NRC staff recognizes that setting generic limits is a desirable goal and
plans to work toward this goal over the next few years. The NRC staff also
believes that the process of examining a few specific waste streams will
facilitate the development of generic requirements and is accelerating its
efforts on setting standards for disposal of very-low-level wastes by less
restrictive means. Toward this end, the NRC's Office of Nuclear Regulatory
Research has initiated research to provide a technical basis for a
regulatory provision for disposal of specific wastes from nuclear power
reactors.
In the interim, before specific or generic provisions for disposing of very-
low-level radioactive wastes are adopted through rulemaking, licensees have
another alternative for obtaining approval to dispose of large volumes of
materials contaminated with very low levels of radioactivity. That
alternative is provided in 10 CFR 20.302(a), "Method for obtaining approval
of proposed disposal procedures." For example, a licensee recently proposed
to relocate 17,000 cubic feet of very-low-level contaminated soil from the
restricted area to the parking lot area. The very-low-level contaminated
soil was to be covered with a minimum of 6 inches of clean soil and possibly
paved over with asphalt in the future. In another ,case, a licensee proposed
that very-low-level contaminated oil be burned in its oil fired boilers and
proposed a technical specification change to limit the amount of
radioactivity released through the boiler exhaust. In both cases, the NRC's
evaluations concluded that the estimated doses were negligibly small from
the standpoint of occupational exposure limits and acceptably small for
potential non-occupational exposures. The licensees' proposals were
approved.
The purpose of this information notice is to bring the provisions of 10 CFR
20.302a) to the attention of licensees. The NRC staff believes that
submittals and approvals in accordance with 10 CFR 20.302(a) can provide a
reasonable alternative to high cost disposals by shallow land burial at
waste repositories of large volumes of material contaminated at low levels.
Such submittals could also provide a data base for further development of
regulatory provisions for disposing of specific wastes below some activity
level without regard to their radioactivity similar to the provisions of 10
CFR 20.306 for disposing of certain licensed materials containing low levels
of carbon-14 and tritium.
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IN 83-05
February 24, 1983
Page 3 of 3
Applications pursuant to 10 CFR 20.302(a) should be submitted to the Office
of Nuclear Reactor Regulation (NRR). The Office of Inspection and
Enforcement and NRC Regional Offices have no authority to approve such
requests. NRR has indicated that such requests for disposal pursuant to 10
CFR 20.302(a) will be handled in a timely manner.
Edward L. Jordan Director
Division of Emergency Preparedness
and Engineering Response
Office of Inspection and Enforcement
Technical Contacts: L. J. Cunningham, IE
301-492-8073
Attachment:
List of Recently Issued IE Information Notices
