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# Technical Assistance Request, Department of the Interior, Salt Lake City, UT; Apparent Request to Store Low-Level Waste for Decay for a Time in Excess of Five Years

## HPPOS-278 PDR-9306140198

See the memorandum from J. E. Glenn to L. J. Callan dated October 22, 1991.

This memo responds to a technical assistance request from Region IV, dated June 26, 1991, regarding the Department of the Interior, Salt Lake City Research Center's apparent request to store for decay for a time in excess of five years (enclosure). The respond to the TAR was coordinated with the Division of Low-Level Waste Management and Decommissioning (LLWM). HPPOS-239 and HPPOS-264 contain related topics.

The licensee stated in the amendment request: "... that shipping will not be done if the radioactive decay renders the waste low enough in activity to be disposed of as regular waste." This statement makes it unclear whether it is for interim storage pending availability of a waste broker for disposal in a licensed site, or for decay-in-storage. At the time of storage, waste must be identified as interim storage or decay-in-storage, and segregated as such.

Waste designated as interim storage must be disposed of at an NRC authorized low-level waste disposal site or transferred to a licensee authorized to receive the waste. The commission has said that it will not look favorably upon long term on-site storage beyond January 1, 1996, for waste destined to a licensed disposal site. Therefore, if the licensee states that it is intending to eventually send the waste to a licensed disposal site, it should be asked to justify a storage period that exceeds January 1, 1996. It should be noted that Utah is a member of the Northwest Compact region. The licensee has a disposal site available to it. We assume that the motivation for the request is the lack of a broker (see Item 11, Paragraph 3.b.1. of the licensee's submittal).

Waste designated for decay-in-storage should be held for a minimum of ten half-lives or longer, depending on the isotope and total activity, before disposal in regular trash. Requests for decay-in-storage that extend beyond a five-year period are not looked upon favorably.

Before the request can be approved, the licensee must specify more clearly how its waste will be identified, segregated, and what it intends for disposal. The license amendment request will not require an environmental assessment according to 10 CFR 20.301 (B), 10 CFR 30.41 (b) (7), and 10 CFR 51.22 (c) (14) (v).

Approval was recommended provided four conditions were followed. First, the licensee specified how waste will be identified, segregated, and disposed. The licensee should also show that the waste would not be held greater than a five-year period. Second, that guidelines outlined in Policy and Guidance Directive FC 90-03; "Licensing of low-level Radioactive Waste Storage of Materials and Fuel Cycle Licensees" were followed as appropriate (e.g., were current possession limits adequate for the waste to be stored up to five years?). Third, survey procedures and instrumentation used for monitoring waste before disposal were reviewed and approved. Finally, specific isotopes with half-lives between 65 and 120 days must be listed on the license. If sulfur-35 is the only radioactive material with a half-life greater than 65 days to be held for decay-in-storage, then it would be appropriate to revise the standard license condition to specify 90 days, rather than 120 days.

**Regulatory references:** 10 CFR 30, 10 CFR 40, 10 CFR 70

**Subject codes:** 3.4, 9.0, 9.6

**Applicability:** Byproduct, Source, and Special Nuclear Materials 

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