Low Level Radioactive Waste (LLRW)/Disused Sources Toolbox for Materials Users
What Is Low Level Radioactive Waste (LLRW)?
Low-level radioactive waste (LLRW) includes items that have become contaminated with radioactive material or have become radioactive through exposure to neutron radiation. This waste typically consists of contaminated protective shoe covers and clothing, wiping rags, mops, filters, reactor water treatment residues, equipments and tools, medical tubes, swabs, injection needles, syringes, and laboratory animal carcasses and tissues. The radioactivity can range from just above background levels found in nature to very highly radioactive in certain cases such as parts from inside the reactor vessel in a nuclear power plant.
A history of LLRW management can be found in NUREG 1853, "History and Framework of Commercial Low-Level Radioactive Waste Management in the United States."
What are the Classes of LLRW?
The NRC has developed a classification system for LLRW based on its potential hazards. NRC has specified disposal and waste requirements for each of the three classes of waste-Class A, B, and C-that are acceptable for disposal in near-surface facilities. These classes have progressively higher levels of concentrations of radioactive material, with Class A having the lowest and Class C having the highest level. Class A waste accounts for approximately 96 percent of the total volume of low-level radioactive waste. Determination of the classification of waste is a complex process. A fourth class of LLRW, called "greater than Class C," is not generally acceptable for near-surface shallow depth disposal.
Further information about these classifications can be found in 10 CFR 61.55.
Who Generates LLRW?
LLRW is generated by those entities that possess a specific or general license to possess and use radioactive materials. These licenses are issued by either the NRC (Federal) or State regulatory authority depending on the location of the facility. These licenses include authorizations for industrial use, medical use, decommissioning activities, waste processors, research and development activities, manufacturing and distribution of radioactive sources or devices, and radiopharmacies. See Agreement States to determine your regulatory authority for the possession and use of radioactive materials.
Information regarding LLRW shipments received at commercial low-level radioactive waste disposal facilities is maintained by the Office of Environmental Management in the US Department of Energy through their Manifest Information Management System (MIMS).
Who Regulates LLRW?
When licensees temporarily store LLRW on site (at their facility) pending decay-in-storage, pending transfer to an authorized recipient, or pending ultimate disposal to a licensed facility, the licensing agency is the regulator. See Agreement States to determine whether you are located within an Agreement State or an NRC-regulated State.
Regulations That Pertain to LLRW
For more information on how LLRW disposal facilities are regulated, see Low-Level Waste Disposal.
NRC Regulations regarding disposal of radioactive waste can be found in 10 CFR Part 20, Subpart K, "Waste Disposal."
Subpart K--Waste Disposal
20.2001 General requirements.
20.2002 Method for obtaining approval of proposed disposal procedures.
20.2003 Disposal by release into sanitary sewerage.
20.2004 Treatment or disposal by incineration.
20.2005 Disposal of specific wastes.
20.2006 Transfer for disposal and manifests.
20.2007 Compliance with environmental and health protection regulations.
20.2008 Disposal of certain byproduct material.
For Agreement State Regulations, please refer to the regulations of the individual Agreement States.
Where Can I Dispose of LLRW?
LLRW can be disposed of in facilities that are licensed by either the NRC or an Agreement State in accordance with health and safety requirements. Part 61 of Title 10 of the Code of Federal Regulations describes the procedures, criteria, and terms and conditions upon which the NRC issues licenses for the disposal of radioactive wastes containing byproduct, source and special nuclear material received from other persons.
Once a licensee decides to ultimately dispose of LLRW, it must be disposed of at a licensed facility. The Low-Level Radioactive Waste Policy Amendments Act of 1985 gave the states responsibility for low-level radioactive waste disposal. It authorized the states to enter into
compacts that would allow several states to dispose of waste at a joint disposal facility. There are currently four
LLRW disposal facilities in the US. Each of these facilities is licensed by an Agreement State for commercial operation. The facilities have been designed, constructed, and operated to meet safety standards. The operator of the facility must also extensively characterize the site on which the facility is located and analyze how the facility will perform for thousands of years into the future.
How Can Licensees Prevent or Lessen the Generation of LLRW?
The easiest way to prevent generating LLRW is simply that - not generating LLRW. In some cases, comparable non-radiological techniques can be used in place of techniques that utilize radioactive material.
Another method to lessen the generation of LLRW is to only procure and acquire the amounts of radioactive material that are needed to perform the task. As appropriate, you can work with your regulatory agency to lower your possession amounts and amend your license.
Often, LLRW is produced when licensees clean up contaminated areas. NRC has developed some guidance for licensees regarding minimizing radioactive contamination and the generation of associated waste. This guidance can be found in: NRC Regulatory Guide 4.21, "Minimization of Contamination and Radioactive Waste Generation"
What Can I Do With Unwanted/Disused Radioactive Sources?
Unused or unwanted radioactive sealed sources or items/devices containing radioactive sealed sources can include portable or fixed nuclear density gauges; radiography cameras used for industrial purposes, sealed radioactive sources used for medical brachytherapy treatments, and sealed sources used for instrument calibrations, etc. These are just a few of the items that can typically be transferred to another authorized licensee for reuse, returned to the item�s vendor or manufacturer, held in storage pending transfer/disposal, or decayed-in-storage.
There are various options available to find a new home for unwanted or unused radioactive material such as individual sealed sources and those in devices. In many cases, this is surplus material that is still in good condition but is unwanted by the licensee authorized to possess it.
Often, these types of sources can be returned to the original vendor or manufacturer of the radioactive source. Some vendors or manufacturers may take the sources back at no cost while others may charge a fee for return. If you are having difficulty locating a vendor or manufacturer, your regulatory agency should be able to provide assistance in this regard Keep in mind that not every vendor or manufacturer will be able to take back radioactive materials because they would need to be licensed or authorized to do so.
Sometimes, another licensee might be interested in receiving the unwanted/unused radioactive material so that they can use it themselves. As they say, one person's trash is another person's treasure. In this case, one licensee can transfer the material to another licensee if that licensee is licensed and authorized to possess the quantity and type of radioactive material being transferred. Your regulatory agency may be able to identify licensees that are in need of or want certain radioactive materials.
There are also some nationwide programs to assist with the removal of unwanted or unused radioactive materials.
It is important to recognize that sometimes, the avenues described above are exhausted, and the material must be disposed of at a licensed LLRW disposal facility. Licensees wishing to dispose of sealed sources to a LLRW disposal facility may be interested in an analysis of the current commercial sealed source disposal landscape (see the table on page 12).
See also information about Orphan Sources.
I Understand That Disposal of LLRW and Sealed Sources Is Expensive. Is This True?
Unfortunately, disposal of LLRW and sealed radioactive sources can be expensive. Often, licensees utilize radioactive material and procure sealed radioactive sources but fail to adequately plan for disposal costs. NRC does not maintain a comprehensive list or table of disposal costs. However, the following report may provide licensees with expected disposal costs.
I Am Going to Sell My Business or My Business Is Going Bankrupt. What Do I Do With My Radioactive Material?
A brief description of licensee responsibilities for bankruptcy/transfer of control can be found in the Spring 2009 edition of the FSME newsletter.
Further guidance regarding changes of control and bankruptcy can be found in NUREG-1556, Volume 15, "Consolidated Guidance About Materials Licenses: Guidance About Changes of Control and About Bankruptcy Involving Byproduct, Source, or Special Nuclear Materials Licenses."
I Need Help Disposing of My LLRW. What Can I Do?
Often, licensees that need help regarding the process of disposing of LLRW elect to obtain the services of a waste collector or waste broker. A waste collector or waste broker is licensed by the NRC or an Agreement State to collect and consolidate waste generated by others, and to transfer this waste, without processing or repackaging the collected waste, to another licensed waste collector, licensed waste processor, or licensed land disposal facility. In some cases, the waste collector or waste broker may provide guidance and assistance to the licensee regarding packaging and transportation requirements; however, the licensee is ultimately responsible for ensuring compliance with all applicable regulatory requirements.
NRC cannot endorse the services of any particular waste collector or waste broker.
What Are the Common Methods of LLRW Storage and Disposal?
The most common methods of low-level radioactive waste storage and disposal are:
I Am Ready to Ship My LLRW for Disposal. What Do I Need to Do?
Waste intended for disposal at a low-level radioactive waste facility must be packaged in approved containers for shipment, and each container must identify the radionuclide and the amounts contained in the waste. Additionally, packages must comply with the requirements of the particular disposal facility's license, as well as applicable State, NRC, and DOT requirements.
The shipper must provide all information required in NRC s Uniform Low-Level Radioactive Waste Manifest and other associated documents (NRC Form 540 and NRC form 541)
These requirements can be found in 10 CFR Part 20, Appendix G .
Stephen Poy
US Nuclear Regulatory Commission
Office of Nuclear Material Safety and Safeguards
Division of Materials Safety, Security, State, and Tribal Programs
State Agreement and Liaison Programs Branch
Phone: 301-415-7135
Email: Stephen.Poy@nrc.gov
Kristen Schwab
Washington State Department of Health
Office of Radiation Protection
Waste Management Section
Phone: 360-236-3244
Email: kristen.schwab@doh.wa.gov