Re: Sealed sources

[LIPTONW@detroitedison.com]

You stated: 
 
The NRC has published guidelines for decay in storage in an  
     Information Notice issued a couple of years ago that should answer all  
     your questions.  If I remember correctly, it provides information on  
     the number of half-lives that material must be held to be considered  
     no longer of concern. I don't remember the number right off.  Perhaps  
     a visit to their home page would help or one of the NRC types on here  
     could be of assistance. 
      
     Jim Reese 
     Defense Logistics Agency 
 
 
 
I'm not familiar with the Information Notice, but the NRC did issue "Health 
Physics Position Statement 278", which recommends a minimum decay time of 10 
half lives, with some qualifications.  This statement is reproduced, below. 
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com 
 
 
Technical Assistance Request, Department of the Interior, 
Salt Lake City, U T; Apparent Request to Store Low-Level 
Waste for Decay for a Time in Excess of Five Years 
HPPOS-278                                     PDR-9306140198 
 
Title:  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 
 
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