Attachment B
WCS- Waste Control Specialists LLC - Nuclear Department
Issue Date 09/03/98
Revision 0
WASTE ACCEPTANCE CRITERIA
Section 1 - Purpose and Scope
These Radioactive Waste Acceptance Criteria establish the basis for acceptance of low-level and mixed radioactive waste materials at the Waste Control Specialists, LLC (WCS) Andrews Facility in Andrews County, Texas. The following types of radioactive waste may be accepted at the WCS facility for processing and interim storage, and, in some cases, disposal at exempt levels:
Low-Level Radioactive Waste (LLRW)
Radioactive waste materiai not classified as high-level
waste, spent nuclear fuel, transuranic (TRU) waste, uranium mill tailings, or mixed waste. LLRW
can include byproduct, source, and special nuclear material, natural occurring and accelerator
produced radioactive material (NARM), or sealed sources.
Mixed Waste (MW)
LLRW containing both radioactive and hazardous or toxic components as
defined by the Atomic Energy Act (AEA), the Resource Conservation and Recovery Act (RCRA),
and the Toxic Substances Control Act (TSCA). Non-AEA radioactive material mixed with RCRA
or TSCA waste can also be accepted at WCS.
Natural Occurring Radioactive Material (NORM)
Radioactive material resulting from natural
sources that contain any nuclide that is radioactive in its natural physical state (i.e. not man-made)
This includes NORM which may have been technologically enhanced (the chemical properties or
physical state of natural sources of radiation have been altered or the potential exposure pathways to humans have been altered)
Source material
Uranium or thorium or any combination thereof, in any physical or chemical
form: or ores that contain by weight 0.05% or more of uranium, thorium, or any combination
thereof.
Special Nuclear Materials (SNM)
Fissionable radioactive material in quantities not sufficient to
form a critical mass as defined in TRCR Part 11.2.
Non-radioactive hazardous waste (regulated under RCRA and TSCA) can also be accepted from
approved generators for processing, storage and disposal at the WCS Facility; however, the criteria and
procedures for acceptance of non radioactive hazardous waste is not within the scope of this document.
Contact the Facility Manager (Richard Grondin) at 1-888-789-9783 for additional information.
For questions regarding this waste acceptance criteria document or any other questions regarding WCS
radioactive waste management capabilities, contact William Dornsife (Vice President - Nuclear Affairs)
at 1-888-193-7553 or 717-540-5920 or other designated WCS staff at 1-888-789-2783.
These criteria have been established to ensure that State of Texas, U.S. Department of Transportation
(DOT). U.S. Nuclear Regulatory Commission (NRC), U.S. Environmental Protection Agency (EPA) and
local government requirements are met, and to satisfy operational requirements at the WCS facility.
Approval:
William Dornsife (signed)
Vice President-Nuclear Affairs
Date: 9/10/98
(Illegible) (signed)
Radition Safety Officer
Date: 9/10/98
Section 2 - Procedures for Shipping Waste to the WCS Andrews Facility
The WCS waste acceptance criteria, characterization, and certification requirements apply to all
generators and waste collectors shipping radioactive waste to the WCS Andrews Facility. All packages
will be evaluated for compliance with the acceptance criteria, and any additional requirements
established by WCS and its regulators. Waste may not be shipped to the WCS Facility until the shipment
has been authorized by WCS. The steps involved in this process include:
1. Contact the WCS Nuclear Department at 1-888-492-7552, or the facility at 1-888-789-2783, to discuss contract and pricing topics.
2. Submit a waste profile sheet to WCS providing information about the generator, the waste to be shipped, and assurances that the requirements in this document will be satisfied. This waste profile (Appendix A attached) must be submitted for WCS approval prior to shipment of waste.
3. WCS will review this information, may conduct generator/ broker site visits as needed to verify
characterization and certification processes, and approve or reject the generator/ collectors radioactive
waste based on the information submitted and provide an authorization to ship letter.
4. Shipment should be scheduled at least 72 hours before arrival at the site with at 1-888-789-2783.
5. Upon approval of the waste profile sheet, and at least 24 hours before waste is due to arrive at WCS, the customer will contact and provide a copy of the completed manifest to WCS Customer Services.
Section 3 - Radioactive and Mixed Waste Acceptance Criteria
This section identifies acceptance criteria for contaminant levels, waste packaging and form restrictions
for all radioactive and mixed waste accepted at the WCS facility for processing, interim storage, disposal, and for waste resulting from WCS processing operations.
Section 3.1 - General Packaging and Waste Form Acceptance Criteria for All Radioactive and Mixed Waste
1. Waste packages will not be accepted at the WCS facility without the generator and shipper's
certification that the shipment has been packaged, loaded, and transported in accordance with all
applicable provisions of USDOT regulations in 49 CFR Parts 170-178 and USNRC regulations in 10
CFR 71. Applicabie State of Texas regulations for waste receipt, notification, Iabeling and
manifesting include Texas Regulations for Control of Radiation (TRCR) Part 11 and TRCR Part 21,
Appendices D and E.
2. Mixed waste (MW) shall meet applicabie USDOT and USEPA regulatory requirements for the
hazardous and/or toxic components in addition to meeting regulatory requirements for radioactive
materials. Limited quantity MW must be classified according to requirements for hazardous material
as defined by Title 49 CFR 173.2.
3. Waste containing multiple hazards shall be packaged according to the level of hazard as defined in Title 49 CFR 173.2, "Classification of Material Having More than One Hazard." Incompatible MW shall be packaged in accordance with Title 40 CFR 264.177, "Special Requirements for Incompatible Wastes." Incompatible wastes may not be packaged together.
4. Waste packages shall be provided with lifting devices. Acceptable devices include pallets, skids, cleats, offsets, rings, handles, or other auxiliary lifting devices to allow handling by means of
forklifts, cranes, or similar handling equipment. Lifting rings and other auxiliary lifting devices on
the package are permissible, provided they are recessed, offset, or hinged in a manner that does not
inhibit stacking the packages or they may be sheared/destroyed during transfer by WCS. The lifting
devices must be designed to a 5:1 safety factor based on the ultimate strength of the material. All
rigging devices that are not permanently attached to the waste package must have a current load test
based on 125 percent of the safe working load. This does not apply to shipments of bulk material.
5. All DOT packages should include a closure device that is sturdy enough so that it will not be
breached under normal handling conditions and will not serve as a weak point for package failure.
6. All waste packages shall be loaded as efficiently and compactly as practical to maximize utilization
of interior volume. With the agreement of the generator, WCS can consolidate and repackage waste
that is not optimally loaded prior to placing into interim storage.
7. Waste containing pathogens, infectious wastes, explosives, organic peroxide, or other etiologic agents as defined in Title 49 CFR 173.386 will not be accepted.
8. Waste containing greater than 100 nCi/gm of TRU radionuclides will not currently be accepted at the WCS Facility.
9. The generator shall take the following precautions to protect the waste package after closure prior to shipment:
--The preshipment storage environment shall be controlled to avoid adverse influence from
weather or other factors on the containment capability of the waste packaging during
handling. storage, and transport. The generator preparing waste in preshipment storage shall
preclude the accumulation of moisture on or in packages prior to their arrival at thc WCS
facility.
--A form of Tamper Indicating Device (TID) shall be applied to each container once
certification actions have been completed.
--Each waste package shall be prepared for shipment so as to minimize damage during transit.
Damage or contamination incurred during transit will be the responsibility of the generator.
and will have to be suitably repaired prior to acceptance.
--The requirements of Titie 40 CFR 264, Subpart I, "Use and Management of Containers. shall
be met for all MW packages.
Section 3.2 - Radionuclide Acceptance Criteria for Exempt Level Radioactive Material Disposal at
WCS
3.2.1 Exempt level radioactive material (or the radioactive component of mixed waste) which can
be accepted for disposal at WCS, if the material was never licensed under the AEA.
1. Source material (uranium or thorium) in any physical or chemical form. solution or alloy in
which the source material is < 0.05% by weight. This translates to the following
concentrations: Th-232 = 54.5 pCi/g, U-238 = 166.5 pCi/g, U(nat)= 355 pCi/g, Th(nat)=
110 pCi/g, and U(depleted) = 950 pCi/g.
2. Unrefined or unprocessed ores containing source material (U or Th).
3. Rare earth metals, compounds, mixtures, or products containing less than 0.25% by weight
Th or U or any combination thereof.
4. Any finished product, part, or scrap containing metal thorium alloys with Th < 4% by
weight.
5. Depleted U in counterweights installed in aircraft, rockets, projectiles, or missiles or used as
a shieiding material constituting part of any shipping container.
6. Products or materials containing radioactive material not exceeding the concentrations in
Table 1 on page 8.
7. Self luminous products containing H3, Kr85, Pr147 manufactured under a specific license
which authorizes the transfer to exempt persons.
8. Any other specific items exempted from licensing under TRCR Part 40.3 or 40.4.
3.2.2 Exempt level radioactive material (or the radioactive component of mixed waste) which can
be accepted for disposal at WCS.
1. Naturally Occurring Radioactive Materials (NORM) containing any NORM radionuclide
less than 150 pCi/gm (this includes any Uranium and Thorium radionuclides if not licensed
or classified by the generator as source material) or technologically enhanced radium-226 or
radium-228 at less than 30 pCi/gm, averaged over any 100 square meters in the first 15
centimeters of soil below the surface, provided the radon emanation rate is less than
20 picocuries per square meter per second. If containerized, the average concentration for
the shipment must meet these same limits.
3.2.3 Additional packaging and waste form acceptance criteria for disposal of radioactive and
mixed waste at WCS.
In addition to the general acceptance criteria presented in Section 3.1, the following criteria must be
met for radioactive or mixed waste accepted for disposal at WCS.
1. Wastes shall not be packaged for disposal in cardboard or fiberboard boxes.
2. Liquid waste shall be packaged in sufficient absorbent material to absorb twice the volume
of the liquid.
3. Solid waste containing liquid shall contain as little free-standing and non-corrosive liquid as
is reasonably achievable, but in no case shall the liquid exceed 1 percent of the volume.
4. Waste shall not be readily capable of detonation or of explosive decomposition or reaction
at normal pressures and temperatures, or of explosive reaction with water.
5. Waste shall not contain, or be capable of generating, quantities of toxic gases. vapors, or
fumes harmful to persons transporting, handling, or disposing of the waste.
6. Waste must not be pyrophoric. Pyrophoric materials contained in wastes shall be treated,
prepared, and packaged to be nonflammable.
7. Wastes in a gaseous form shall be packaged at an absolute pressure that does not exceed 1.5
atmospheres at 20°C. Total activity shall not exceed 100 curies (3.7 terabecquerels) per
container.
8. Wastes containing biological, pathogenic, or infectious material shall be treated to reduce to
the maximum extent practicable the potential hazard from the non-radiological materials.
9. Waste containing hazardous or toxic substances must be treated in accordance with all
applicable State of Texas and USEPA requirements prior to disposal. WCS can perform
these necessary treatment services as described in Section 3.8.
3.3 Acceptance Criteria for Interim Storage of LLRW at WCS
LLRW classified as Class A, B, C, or greater than C can be accepted for interim storage at WCS.
NORM, TRU, sealed sources, and mixed waste will also be accepted on a case by case basis for
interim storage. All LLRW must meet all other criteria in Section 3.1 and 3.2.3 as well as the
following to be accepted for interim storage at WCS. License inventors limits for various
radionuclides are shown in Table 2.
1. Packages: All waste for interim storage shall be shipped in USDOT approved packages.
Preferred containers include the following: 4 x 4 x 7 ft (1.2 x 1.2 x 2.1m) or 4 x 2 x 7 (1.2
x 0.6 x 2.1m) (WHL) boxes, 55-gallon (208-liter) drums. 85 gallon overpacks, B-25 boxes,
and 195/ 215 liners. Other dimensions may be pre-approved by the WCS Facility Manager.
Cardboard or fiberboard boxes will not be accepted for interim storage.
2. Strength: Except for bulk waste, waste packaged in steel drums, or SEALANDTM
containers, the waste package (packaging and contents) shall be capable of supporting a uniformly distributed load of 4,000 Ibs/ft2 (19528 kg/rn2). This is required to support other
waste packages during stacking operations.
3. LLRW accepted for storage at WCS's Facility shall not exhibit any characteristics of or be
listed as hazardous waste as identified in Title 40 CFR 261 "ldentification and Listing of
Hazardous Waste." For information on hazardous waste storage services. contact the faciIity manager.
4. LLRW shall contain no free-standing or corrosive liquids. Waste containing liquids shall be processed to solidify the liquid using a sufficient quantity of absorbent materials to contain twice the volume of the liquid.
5. LLRW containing discrete radium (> 2 nCi/gm) shall be in the form of sealed sources and packaged in a 2R container, or its equivalent. The 2R container must be immobilized in
concrete in the center of a second container. The second container must be a DOT approved
container.
6. Compressed gases as defined by Title 49 CFR 173.300, including unpunctured aerosol cans will not be accepted for interim storage at the WCS facility.
7. Where practical, LLRW shall be treated to reduce volume and provide a high degree of
physically and chemically stability. Wastes shall not significantly react with the packaging
during normal storage, shipping, and handling. Void spaces within the waste and between
waste and its package shall be minimized to the extent practicable.
8. Waste containing chelating or complexing agents at concentrations greater than eight
percent by weight will not be accepted at the WCS facility without special WCS approval.
9. Waste must be received in a form that meets all acceptance criteria for interim storage or
can be treated by WCS to achieve an acceptable waste form.
3.4 Acceptance criteria for interim storage and disposal of Mixed Waste
The following additional criteria must be met for interim storage or disposal of mixed waste at
WCS. Mixed waste must receive any required treatment prior to shipment, or arrangements made in
advance for treatment at the WCS facility. EPA-approved methods must be used. To be accepted
for disposal, mixed waste must meet the radioactive material requirements of Section 3.2.1.
1. Mixed waste prohibited from land disposal under 40 CFR 268, "Land Disposal
Restrictions," will not be accepted for interim storage unless treated as specified under 40
CFR 268, Subpart D, "Treatment Standards."
2. Wastes must be identified by the most appropriate compatibility group listed in Title 40
CFR 264, Appendix V, "examples of Potentially Incompatible Waste" to ensure that
incompatible wastes are not shipped or stored together. Incompatible MW shall be packaged
in accordance with Title 40 CFR 264.177, "Special Requirements for Incompatible
Wastes."
3. Residual liquids shall be mixed with absorbent or solidified so that free liquids are no
longer observed. To demonstrate the absence of free liquids, the generator may be required
to use EPA Test Method 9095 (Paint Filter Test) as described in "Test Methods for
Evaluating Solid Wastes, Physical/Chemical Methods." (EPA Publication No. SW-846).
4. The requirements of Title 40 CFR 264, Subpart 1, "use and Management of Containers" shall be met for MW packages.
3.5 Acceptance criteria for interim storage or disposal of radioactive waste contaminated with
PCB's
Polychlorinated Biphenyl (PCB) contaminated radioactive waste can be accepted for interim storage
or disposal. (For disposal, it must also meet the requirements of Section 3.2.1.) Acceptance will be
handled on a case-by-case basis to assure compliance with storage and disposal requirements. Refer
to 40 CFR 761.60 and applicable Texas regulations for PCB disposal requirements. Generally.
solids contaminated with any level of PCB's are acceptable for disposal, but liquids must be treated
to less than 500 ppm for disposal at WCS.
3.6 Acceptance Criteria for Bulk Waste
Bulk waste can be accepted for interim storage, processing, or disposal. (For disposal. it must also
meet the requirements of Section 3.2.1.) Bulk waste shipments may be approved by WCS on a case-by-case basis.
3.7 Acceptance Criteria for Interim Storage and Disposal of Radioactive Contaminated Asbestos
Radioactive contaminated asbestos waste may be accepted by WCS on a case-by-case basis.
1. All regulated asbestos that is friable or otherwise capable of giving off friable asbestos dust
must be wetted with a water and surfactant mix and stored in two plastic bags whose combined
thickness equals at least 6 mil. The plastic bags must be overpacked in a leak-resistant
containers that meets applicable shipping requirements for the radioactive content of the
material involved. Sharp edges and corners within the package shall be padded or otherwise
protected to prevent damage to the plastic inner wrap during handling and shipping. Since the
asbestos must be wetted during abatement activities, an absorbent must be added to ensure
compliance with the free liquid criteria for interim storage of LLRW.
2. All LLRW containing regulated asbestos shall be packaged, marked, and labeled in accordance
with the requirements of 40 CFR 61. 150.
3. Regulated asbestos waste must be segregated and packaged separately.
4. For disposal, it must also meet the requirements of Section 3.2.1
3.8 Acceptance Criteria for Waste Accepted for Processing
LLRW and MW received for processing may be exempted from certain characterization and
certification criteria required for waste destined for interim storage or disposal since the waste
characteristics will be altered during processing. For waste processed at WCS, compliance with
appilicable Texas Department of Health (TDH), Texas Natural Resources Conservation Commission
(TNRCC) and USDOT regulations will be the primary controlling acceptance criteria. Radioactive
waste material processed by WCS will be certified as meeting waste acceptance criteria stated in
this document prior to storage or disposal at the WCS facility, or prior to return to the generator or
other authorized recipient. All waste accepted for processing will be approved on a case by case
basis.
Section 4 - Waste Classification
All waste received for processing. storage, or disposal must be classified in accordance with the
requirements in TRCR Part 21 Appendix E. Waste containing PCB material and/or asbestos shall be
properly identified Hazardous waste components shall be classified according to criteria in 40 CFR
761.13 and 268.
Section 5 - Requirements for Characterization of Waste
All radioactive waste shipped to the WCS facility shall have its radioactivity content determined prior to
shipment. The radionuclides present and the radioactivity levels shall be determined from nuclear assay,
direct measurement, process knowledge, or any other approved method. (See NRC Low-Level Waste
Licensing Branch Technical Position on Radioactive Waste Classification dated 5/83) This information is required to maintain WCS facility radioactive material inventory levels within Radioactive Material
License limits issued by the TDH, Bureau of Radiation Control and to insure it meets the TNRCC perrnit
requirements.
The concentration of a radionuclide may be determined by indirect methods such as use of scaling
factors, which relate the inferred concentration of one radionuclide to another that is measured, or
radionuclide material accountability, if there is reasonable assurance that the indirect methods can be
correlated with actual measurements. The concentration of a radionuclide may be averaged over the
volume of the waste, or weight of the waste if the units are expressed as picocurie (becquerel) per gram.
Table 1 - Acceptable radionuclide concentration, for disposal of materials and products
| Nuclide | Halflife years | Concentration (pCi/gm) |
| Ba-133 | 10.7 | 2000 |
| Ba-140 | 0.035 | 300 |
| Be-7 | 0.146 | 20,000 |
| C-14 | 5730 | 8000 |
| Ca-45 | 0.447 | 90 |
| Ce-141 | 0.089 | 900 |
| Ce-144 | 0.778 | 100 |
| Co-57 | 0.742 | 5000 |
| Co-58 | 1.96 | 1000 |
| Co-60 | 5.258 | 500 |
| Cr-51 | 0.0762 | 20,000 |
| Cs-134 | 2.06 | 90 |
| Eu-152 | 13.4 | 600 |
| Eu-155 | 5 | 2000 |
| Fe-55 | 2.7 | 8000 |
| Fe-59 | 0.1233 | 600 |
| Gd-153 | 0.66 | 2000 |
| H-3 | 12.33 | 30,000 |
| Hf-181 | 0.116 | 700 |
| I-131 | 0.0221 | 20 |
| Ir-192 | 0.203 | 400 |
| Mn-54 | 0.8575 | 1000 |
| Nb-95 | 0.962 | 1000 |
| P-32 | 0.0391 | 200 |
| Pm-147 | 2.623 | 2000 |
| Po-210 | 0.38 | 7 |
| Ru-103 | 0.108 | 700 |
| Ru- 106 | 1.008 | 100 |
| S-35 | 0.239 | 600 |
| Sc-46 | 0.229 | 400 |
| Se-75 | 0.329 | 3000 |
| Sr-85 | 0.179 | 1000 |
| Sr-89 | 0.1392 | 100 |
| Ta-182 | 0.315 | 400 |
| Te-125m | 0.1589 | 2000 |
| Zn-65 | 0.6677 | 1000 |
| Zr-95 | 0.175 | 600 |
For a combination of isotopes, the limit for the combination should be derived as follows. Determine for each
isotope in the product the ratio between the concentration present in the product and the concentration established in
Table 1 for the specific isotope when not in combination. The sum of such ratios may not exceed "1" (i.e., unity).
Table 2-
License inventory limits for interim storage at WCS for selected radionuclides
| Nuclide | Halflife years | License Possession Limit (Ci) |
| Ag-110M | 0.69 | 20,000 |
| Am-241 | 433 | 200 |
| Am-243 | 7370 | 200 |
| Ba-133 | 10.7 | 2000 |
| Ba-140 | 0.035 | 20,000 |
| Be-7 | 0.146 | 200,000 |
| C-14 | 5730 | 200,000 |
| Ca-5 | 0.447 | 200,000 |
| Cd-109 | 1.24 | 200,000 |
| Ce-139 | 0.377 | 20,000 |
| Ce-141 | 0.089 | 200,000 |
| Ce-144 | 0.778 | 20,000 |
| Cf-252 | 2.65 | 200 |
| Cl-36 | 307,000 | 20,000 |
| Cm-242 | 0.446 | 200 |
| Cm-243 | 32 | 200 |
| Cm-244 | 18.1 | 200 |
| Co-57 | 0.742 | 200,000 |
| Co-58 | 1.96 | 200,000 |
| Co-60 | 5.258 | 20,000 |
| Cr-51 | 0.0762 | 200,000 |
| Cs-134 | 2.06 | 20,000 |
| Cs-137 | 30.2 | 20,000 |
| Eu-152 | 13.4 | 20,000 |
| Eu-154 | 8.2 | 2000 |
| Eu-155 | 5 | 200,000 |
| Fe-55 | 2.7 | 200,000 |
| Fe-59 | 0.1233 | 200,000 |
| Gd-153 | 0.66 | 200,000 |
| Ge-68 | 0.786 | 20,000 |
| H-3 | 12.33 | 200,000 |
| Hf-181 | 0.116 | 200,000 |
| I-125 | 0.1636 | 20,000 |
| I-129 | 1.6 E+O7 | 20,000 |
| I-131 | 0.0221 | 20,000 |
| Ir-192 | 0.203 | 20,000 |
| Mn-54 | 0.8575 | 200,000 |
| Na-22 | 2.601 | 200,000 |
| Nb-94 | 20,000 | 2000 |
| Nb-95 | 0.962 | 200,000 |
| Ni-59 | 80,000 | 200,000 |
| Ni-63 | 92 | 200,000 |
| Np-237 | 2,140,000 | 200 |
| P-32 | 0.0391 | 20,000 |
| P-33 | 0.069 | 20,000 |
| Pb-210 | 22 | 2000 |
| Pm-147 | 2.623 | 200,000 |
| Po-210 | 0.38 | 200 |
| Pu-238 | 87.4 | 200 |
| Pu-239 | 24,390 | 200 |
| Pu-240 | 6600 | 200 |
| Pu-241 | 14.3 | 200 |
| Pu-242 | 376,000 | 200 |
| Ra-226 | 1602 | 200 |
| Rb-86 | 0.05 | 200,000 |
| Ru-103 | 0.108 | 200,000 |
| Ru-106 | 1.008 | 20,000 |
| S-35 | 0.239 | 200,000 |
| Sb-124 | 0.165 | 20,000 |
| Sb-125 | 2.73 | 20,000 |
| Sc-46 | 0.229 | 20,000 |
| Se-75 | 0.329 | 200,000 |
| Sn-113 | 0.315 | 20,000 |
| Sr-85 | 0.179 | 200,000 |
| Sr-89 | 0.1392 | 20,000 |
| Sr-90 | 28.9 | 2000 |
| Ta-182 | 0.315 | 20,000 |
| Tc-99 | 213,000 | 200,000 |
| Te-125m | 0.1589 | 200,000 |
| Th-228 | 1.913 | 200 |
| Th-230 | 78,000 | 200 |
| Th-232 | 1.4 E+10 | 20,000 |
| Th-234 | 0.066 | 2000 |
| U (Nat) | 4.5 E+09 | 20,000 |
| U-232 | 72 | 200 |
| U-233 | 159,000 | 2000 |
| U-234 | 247,000 | 2000 |
| U-235 | 7.1 E+08 | 20,000 |
| U-236 | 2.4 E+07 | 2000 |
| U-238 | 4.5 E+09 | 20,000 |
| Y-88 | 0.292 | 20,000 |
| Zn-65 | 0.6677 | 200,000 |
| Zr-95 | 0.175 | 20,000 |