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Regulated under the Atomic Energy Act
◦ Low concentrations of source, byproduct and special nuclear material
◦ Accelerator produced material
◦ Generally exempted materials, products & devices
(e.g. smoke detectors, luminous dials, etc.)
Not Regulated under the Atomic Energy Act
◦ Naturally occurring radioactive material (NORM) except radium & certain other discrete sources
◦ Technologically-enhanced NORM (TENORM)
◦ Pre-UMTRCA uranium and thorium ore processing waste (FUSRAP)

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Waste Specific:
NRC Decommissioning Plan approval
NRC General Exemption
NRC/Agreement State license condition/amendment
NRC/Agreement State approval letter
NRC/Agreement State specific exemption*
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Disposal Facility-Specific:
State law or regulation
RCRA permit condition/amendment
*Policy Note: A 10 CFR 20.2002 alternate disposal authorization is not an exemption. However, NRC policy is to issue an exemption concurrently.

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Select RCRA Subtitle-C Sites are viable options for LARW
Characteristics similar to Part 61 LLRW sites
(‘hybrid’ sites)
◦ Remote location with limited population
◦ Meet performance assessment criteria
◦ Desert environment with low annual rainfall
◦ Deep depth to groundwater
Not all RCRA sites meet these criteria

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Site-specific radiological performance assessment (RESRAD)
Operating Procedures
Emergency Response Plan
Rad Training, Occupational Monitoring, and
Personnel Dosimetry
Environmental Monitoring
Closure/Post-closure Financial Assurance

• Avg 700,000 tons disposed over last 5 years
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~50% radioactive material
Majority FUSRAP &
EPA CERCLA waste
NRC/AS exempt waste volumes increasing

Requests More
Info
Generator Requests
Alternate Disposal
Authorization & Exemption
NRC/AS Conducts
Technical Review
NRC/AS Approves
USE Submits Safety
Assessment to ID
IDEQ Reviews
Rejects
Rejects
Concurs

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General:
NORM up to 1,500 pCi/g
Source material <0.05% by weight
Accelerator produced material <10 mrem/hr
Generally exempt items & devices
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With Specific Exemption:
Source, Byproduct & SNM <3,000 pCi/g, and
NRC/Agreement State exemption based on “less than a few millirem” projected dose per Safety
Analysis

Andrews, TX Site Robstown, TX Site

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All NORM isotopes except radium <150 pCi/gm or less
Radium <30 pCi/g
Uranium & thorium <0.05% by weight
Exempt byproduct material with state approval
Specific Licensed Material: “300-day rule”
Mixed hazardous & radioactive material acceptable
* Applies to both Andrews (WCS) & Robstown (US Ecology) sites

Permittee evaluates waste per TAC
Requests information
Submits concurrence request to TCEQ:
• Reference applicable exemption rule
• Physical description- composition, weight, etc.
• Isotope concentrations
• Generator & waste location
• Must be exempt in state of origin
TCEQ Reviews
TCEQ Issues Written
Concurrence For Disposal
Rejects
Rejects

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Safety Light Corporation, Bloomsburg PA
NRC/PADEP licensed, EPA Superfund Site
Cleanup conducted by USACE
~1,600 cy of soil & debris
50 pCi/g 137 Cs, 180 pCi/g 90 Sr, 50 pCi/g 226 Ra
PADEP exemption granted in Nov 2008
Shipments made via IMC to
ID RCRA Site

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BASF (Former Englehard Chemical Co.),
Plainville, MA
Formerly licensed by AEA (term. in 1963)
123 tons of Natural, Depleted, and Low
Enriched Uranium (~4%)
Approval letter granted by MDPH (Feb 2010)
Idaho concurrence
Disposed at Idaho RCRA site

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PG&E, Humboldt Bay NPP
Undergoing decommissioning
~200,000 ft 3 of soil & debris from Units 1&2
5 pCi/g 137 Cs, 5 pCi/g 60 Co, 1 pCi/g 14 C, more
NRC issued EA with
FONSI and exemption in Nov 2010
Shipments ongoing to
ID RCRA Site

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Former Molycorp source material processing operation in Washington, PA: NRC licensed
~100,000 cy of soil and slag from production of ferro-alloys (Nb amd Mo)
232 Th ~50 pCi/g, 238 U ~15 pCi/g, 226 Ra ~5 pCi/g
Classified as unimportant quantity of source material
(<.05% by weight)
Disposed at Idaho RCRA site

“The Committee should work with the staff to consider and provide advice on what NRC can do to assist in providing greater disposal options for low-level radioactive waste, e.g. use of appropriate Resource Conservation and Recovery Act
(RCRA) Subtitle C hazardous waste facilities.”
U.S. NRC Staff Requirements Memo - 1/16/07