RE:Applicability of Regs to D-I-S

["Jim Center" <james.center@wmich.edu>]

Throughout this discussion on Decay In Storage, I have not read
anyone referencing NUREG 1556 Vol.11, "Consolidated Guidance About
Material Licenses Programs - Specific guidance About Licenses of
Broad Scope" published April 1999.

I have been working on an application for a Broad Scope license for
our University and have become familiar with this NUREG.  DIS is
discussed in Item 11: Waste Management Programs and Appendix V:
Model Waste Management Procedures.  DIS is allowed for material with
a physical half-life of less than or equal 120 days.  Waste may be
disposed of as ordinary waste IF it has been stored for decay a
minimum of 10 half-lives and a radiation survey performed in a low
background area without any interposed shielding indicates the
material's levels are indistinguishable from the background.   It
also has additional requirements about defacing/removing labels and
such.

NUREG 1556, Vol. 11, Item 11 provides applicant response guidance. 
It states the applicant should "provide procedures for waste
collection, storage, and the disposal by any of the authorized
methods described in this section."   This section did not allow the
applicant to simply state they were adopting the model procedures as
it did for surveys, leak test, instrument calibrations, and other
radiation safety program requirements.  Therefore, your waste
management procedures should be in your license with whatever DIS
criteria you were able to justify.  


Jim Center
RSO,  Western Michigan University
james.center@wmich.edu

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