[Federal Register Volume 60, Number 151 (Monday, August 7, 1995)]
[Notices]
[Pages 40204-40211]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-19359]



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NUCLEAR REGULATORY COMMISSION

Joint Nuclear Regulatory Commission/Environmental Protection 
Agency Guidance on the Storage of Mixed Radioactive and Hazardous Waste

AGENCY: Nuclear Regulatory Commission.

ACTION: Publication of joint guidance and request for public comment.

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SUMMARY: The Nuclear Regulatory Commission and Environmental Protection 
Agency (EPA) are jointly publishing herein a draft guidance document on 
the storage of mixed radioactive and hazardous waste (mixed waste). The 
Agencies are developing this guidance to assist mixed waste generators 
forced to store their mixed waste, pending the development of adequate 
treatment and disposal capacity for commercially generated mixed waste. 
The guidance points out areas of flexibility within NRC and EPA 
regulations that relate to the storage of mixed waste. Further, the 
guidance is consistent with the general approach EPA is undertaking as 
it reviews its current regulatory program. The Agencies are soliciting 
comments from members of the regulated community, the States, and the 
public. Interested individuals may provide the Agencies with their 
comments on the proposed guidance by forwarding their written comments 
to NRC at the address listed in the ADDRESSES section.

 
[[Page 40205]]

DATES: The comment period expires November 6, 1995. Comments received 
after this date may be considered, if it is practical to do so, but the 
Agencies are only able to assure consideration for comments received on 
or before this date.

ADDRESSES: Interested individuals should send their written comments 
to: David L. Meyer, Chief, Regulatory Publications Branch, Division of 
Freedom of Information and Publication Service, Office of 
Administration, U.S. Nuclear Regulatory Commission, Washington, DC 
20555, or hand deliver comments to the Commission's offices at 11545 
Rockville Pike (Room T6-D59), Rockville, MD 20555.

BACKGROUND: Mixed waste is defined in the Federal Facility Compliance 
Act (FFCA) as ``waste that contains both hazardous waste and source, 
special nuclear, or byproduct material subject to the Atomic Energy Act 
of 1954.'' Persons who generate, treat, store or dispose of mixed 
wastes are subject to the requirements of the Atomic Energy Act of 
1954, as amended (AEA) and the Solid Waste Disposal Act (SWDA) as 
amended by the Resource Conservation and Recovery Act (RCRA), and the 
Hazardous and Solid Waste Amendments of 1984 (HSWA). The Federal 
Agencies responsible for ensuring compliance with the implementing 
regulations of these two statutes are the NRC and EPA.
    The Low-Level Radioactive Waste Policy Amendments Act of 1985 
(LLRWPAA) established a series of milestones, penalties and incentives 
to ensure that States or regional compacts provide for the disposal of 
radioactive waste. Although mixed waste was not specifically addressed 
in the LLRWPAA, States must ensure adequate disposal capacity for most 
types of commercially generated low-level radioactive wastes, including 
mixed wastes. To date, progress in meeting the milestones in the 
LLRWPAA has been limited. In addition, uncertainties about the amounts 
and types of mixed waste, along with the complexities in complying with 
the regulations for these wastes, have hindered development of 
treatment and disposal facilities for mixed waste. As a result, 
licensees may be required to store mixed waste on-site until adequate 
treatment and disposal capacity has been established.
    NRC and EPA have developed the draft guidance to assist persons 
currently storing mixed waste to meet the regulatory requirements of 
both the AEA and RCRA. The guidance describes procedures that are 
generally acceptable to both NRC and EPA and that resolve issues of 
concern that have been identified to the Agencies by licensees. It also 
addresses similar storage issues identified by the Department of Energy 
(DOE). The guidance first summarizes the general requirements that 
licensees must meet to store mixed waste in accordance with NRC and EPA 
regulations, then addresses specific storage issues that have been 
brought to the Agencies' attention by mixed waste generators. Finally, 
the guidance discusses EPA's RCRA enforcement policy for mixed waste in 
storage. NRC and EPA will review all comments submitted by interested 
individuals and incorporate appropriate comments into the final 
guidance document.

FOR FURTHER INFORMATION CONTACT: Dominick A. Orlando, Division of Waste 
Management, Office of Nuclear Material Safety and Safeguards, U.S. 
Nuclear Regulatory Commission, Washington, DC 20555, telephone (301) 
415-6749, or Newman Smith, Permits and State Programs Division, Office 
of Solid Waste, U.S. Environmental Protection Agency, Washington DC 
20460, telephone (703) 308-8757.

    Dated at Rockville, MD, this 28th day of July, 1995.

    For the U.S. Nuclear Regulatory Commission.
Michael F. Weber,
Chief, Low-Level Waste and Decommissioning Projects Branch, Division of 
Waste Management, Office of Nuclear Material Safety and Safeguards.
Appendix A--Note to Readers

    The information contained in this guidance is intended for use 
by Nuclear Regulatory Commission licensees who may not be familiar 
with the hazardous waste storage requirements that apply to mixed 
waste. However, much of the document may also be useful for Federal 
facilities that generate mixed waste. The guidance assumes that the 
reader already possesses a valid NRC or Agreement State radioactive 
materials license, but may not possess an Environmental Protection 
Agency or authorized State storage permit.
    EPA and NRC recognize that the radioactive component of mixed 
waste may pose hazards from external radiation and from potential 
internal exposures. Individuals that may be exposed to radiological 
and non-radiological hazards from mixed waste should be trained in 
radiation and chemical safety. In addition, mixed waste generators 
should ensure that the hazards associated with the mixed waste are 
fully evaluated prior to generating the waste.
    This guidance presumes that both radiological and industrial 
hygiene safety programs are in place and will be followed by the 
reader. The Agencies did not consult with the Occupational Safety 
and Health Administration or States agencies responsible for 
workplace safety in developing this guidance. However, nothing in 
this guidance supersedes the OSHA safety requirements. NRC licensees 
are expected to comply with OSHA requirements, as well as all other 
applicable regulations.

Appendix B--Disclaimer

    The policies discussed herein are not final agency actions, but 
are intended solely as guidance. They are not intended, nor can they 
be relied upon, to create any rights enforceable by any party in 
litigation with the United States. Environmental Protection Agency 
or Nuclear Regulatory Commission officials may decide to follow the 
policies provided in this guidance or to act at variance with the 
policies, based on an analysis of specific site circumstances. The 
Agencies also reserve the right to change these policies at any time 
without public notice.

Appendix C--Joint Guidance on the Storage of Mixed Low-Level 
Radioactive and Hazardous Waste

August 1995.

I. Introduction

    Mixed low-level radioactive and hazardous waste (mixed waste) is 
waste that satisfies the definition of low-level radioactive waste 
in the Low-Level Radioactive Waste Policy Amendments Act of 1985 
(LLRWPAA)1 and contains hazardous waste that either: (1) Is 
listed as a hazardous waste in Subpart D of 40 CFR Part 261; or (2) 
causes the waste to exhibit any of the hazardous waste 
characteristics identified in Subpart C of 40 CFR Part 261. Persons 
who generate, treat, store or dispose of mixed wastes are subject to 
the requirements of the Atomic Energy Act of 1954, as amended (AEA) 
and the Solid Waste Disposal Act (SWDA) as amended by the Resource 
Conservation and Recovery Act (RCRA), and the Hazardous and Solid 
Waste Amendments of 1984 (HSWA). The Federal agencies responsible 
for ensuring compliance with the implementing regulations of these 
two statutes are the Nuclear Regulatory Commission (NRC) and the 
Environmental Protection Agency (EPA).\2\ In October 1992, Congress 
enacted the Federal Facilities Compliance Act (FFCA) which, among 
other things, added a definition of mixed waste to RCRA. Mixed waste 
is defined in the FFCA as ``waste that contains both hazardous waste 
and source, special nuclear, or byproduct material subject to the 
Atomic Energy Act of 1954'' (RCRA Section 1004(41), 42 USC 
6903(41)).

    \1\ The LLRWPAA defines low-level radioactive waste as 
``radioactive material that (A) is not high-level radioactive waste, 
spent nuclear fuel, or byproduct material as defined in section 
11e.2 of the Atomic Energy Act of 1954 and; (B) the Nuclear 
Regulatory Commission, consistent with existing law and in 
accordance with paragraph (A), classifies as low-level radioactive 
waste.''
    \2\ Note that most radioactive material under the control of the 
Department of Energy is not regulated by NRC.
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    The LLRWPAA established a series of milestones, penalties and 
incentives to ensure that States or Regional Compacts provide for 
the disposal of radioactive waste. Although mixed waste was not 
specifically 

[[Page 40206]]
addressed in the LLRWPAA, States must ensure adequate disposal capacity 
for all low-level radioactive wastes, including mixed wastes. To 
date, progress in meeting the milestones in the LLRWPAA has been 
limited. In addition, uncertainties about the amounts and types of 
mixed waste, along with the complexities in complying with the 
regulations for these wastes, have hindered development of treatment 
and disposal facilities for mixed waste. As a result, licensees may 
be required to store mixed waste on-site until adequate treatment 
and disposal capacity has been established.
    This guidance is designed to assist persons currently storing 
mixed waste to meet the regulatory requirements of both the AEA and 
RCRA. However, many of the requirements and procedures discussed in 
this guidance may not be applicable to nuclear power reactor 
facilities. The guidance describes procedures that are generally 
acceptable to both NRC and EPA that resolve issues of concern which 
have been identified to the agencies by licensees. It also addresses 
similar storage issues identified by the Department of Energy (DOE). 
The guidance first summarizes the general requirements that 
licensees must meet to store mixed waste in accordance with NRC and 
EPA regulations, then addresses specific storage issues that have 
been brought to the Agencies' attention by mixed waste generators. 
Finally, the guidance discusses EPA's RCRA enforcement policy for 
mixed waste in storage.
II. Background

a. Regulatory Authority

    In general, NRC or Agreement State licensed facilities that 
manage mixed waste are subject to the RCRA Subtitle C requirements 
for hazardous waste in 40 CFR part 124 and parts 260-270 implemented 
by EPA, or to comparable regulations implemented by States or 
Territories that are authorized to implement RCRA mixed waste 
authority. EPA asserted its regulatory authority over the hazardous 
portion of mixed waste in Federal Register Notices on July 3, 1986 
and September 23, 1988 (see 51 FR 24504 and 53 FR 37045).
    The RCRA Subtitle C program was primarily developed for 
implementation by the States, and oversight by EPA. As of April 
1995, EPA regulates mixed waste in Alaska, Hawaii, Iowa, Wyoming and 
all U.S. Trust Territories except Guam. Thirty-eight states and one 
territory (Guam) have been authorized to implement the base RCRA 
hazardous waste program (i.e., authorized States), and to regulate 
mixed waste activities (see 51 FR 24504, July 3, 1986). Nine states 
are authorized for the RCRA base hazardous waste program, but have 
not been authorized to regulate mixed waste.3 In these 9 States 
mixed waste is not regulated by EPA but may be regulated by States 
under the authority of State law. To understand the roles of EPA and 
the States in regulating the hazardous portion of mixed waste, the 
following categories of States or Territories are discussed below:

    \3\ The RCRA base hazardous waste program is the RCRA program 
initially made available for final authorization, and includes 
Federal regulations up to July 26, 1982. Authorized States revise 
their programs to keep pace with Federal program changes that have 
taken place after 1982 as required by 40 CFR 271.21(e).
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     States and Territories whose hazardous waste program 
has not been authorized under RCRA to act ``in lieu of'' the federal 
RCRA program; these are called ``unauthorized States or 
Territories'';
     States and Territories with RCRA authorization that 
have adopted mixed waste authority; and
     States and Territories with RCRA authorization that 
have not adopted mixed waste authority.
    As a subset of hazardous waste, mixed waste is regulated by EPA 
in unauthorized States and Territories (i.e., States and Territories 
that have not been authorized to implement the RCRA Subtitle C 
program). Where States and Territories are RCRA authorized and have 
adopted mixed waste authority, mixed waste is subject to the State's 
or Territory's authorized hazardous waste program (which may contain 
regulations more stringent than those in the Federal RCRA program). 
See Table 1 for a list of States with mixed waste authority as of 
June 30, 1995. In States or Territories with RCRA authorization that 
have not yet adopted mixed waste as part of the base RCRA program, 
mixed waste may be regulated under State or Territorial regulation, 
but not as a hazardous waste under an authorized RCRA program.
    Facilities in RCRA authorized States (whether the State has 
mixed waste authority or not) should contact their respective State 
agency to ascertain what State regulations may apply to mixed waste. 
In addition, facilities in RCRA authorized States should be aware 
that EPA Regions may share responsibility for implementing the RCRA 
program with the State, particularly with respect to certain 
requirements promulgated under the Hazardous and Solid Waste 
Amendments of 1984 (e.g., corrective action and land disposal 
restriction requirements), for which the State may not yet be 
authorized to implement.4

    \4\ For more information on RCRA State authorization and the 
authorization status of particular States, contact the RCRA/
Superfund Hotline at 1-800-424-9346.
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    Twenty-nine States have signed agreements with NRC enabling the 
various ``Agreement States'' to regulate source, byproduct, and 
small quantities of special nuclear material within their 
boundaries. (see Table 2). Most facilities located in Agreement 
States are subject to regulatory requirements for radioactive 
material under State law. This applies to all source, special 
nuclear, and byproduct material except that from nuclear utilities 
and fuel cycle facilities, which are subject to NRC's requirements 
and DOE facilities, which are subject to DOE Orders. While States 
are required to adopt programs that are comparable with the NRC 
program, States may have requirements that are more stringent, or 
are in addition to those from the Federal program. Facility managers 
should determine whether their State is an NRC Agreement State and 
determine the scope of the program that has been relinquished by NRC 
to the State.
    In addition to NRC regulated facilities, many DOE facilities may 
store mixed waste. These facilities are subject to the RCRA Subtitle 
C requirements or comparable State regulations. DOE Order 5820.2A, 
``Radioactive Waste Management,'' and DOE Order 5400.3, ``Hazardous 
and Radioactive Mixed Waste Program,'' establish policies, 
guidelines, and minimum requirements under which DOE facilities must 
manage their radioactive and mixed waste and contaminated 
facilities. DOE Order 5400.3 excludes byproduct material unless it 
is mixed with RCRA hazardous waste. Because the storage issues 
discussed in this document may arise at either NRC-licensed or DOE 
facilities, this guidance may be useful in addressing mixed waste 
storage at DOE facilities. However, the primary focus of this 
guidance is a discussion of the requirements for the storage of 
mixed waste at NRC-licensed and RCRA-regulated facilities. As 
summarized in Table 3, regulation of mixed waste may be the 
responsibility of the State in which a facility is located. To 
ensure compliance, licensees and permittees should contact their 
State agencies in RCRA authorized or NRC Agreement States to 
determine if this or other guidance is applicable.

b. Applicability of RCRA Storage Requirements

    NRC licensees who store mixed waste must comply with the 
requirements of RCRA. Under RCRA regulations, storage is defined as 
``the holding of hazardous waste for a temporary period at the end 
of which the hazardous waste is treated, disposed of, or stored 
elsewhere''. The specific RCRA storage requirements that apply to 
licensees are determined by the quantity of hazardous waste 
generated, how long the licensee stores hazardous waste (including 
mixed waste) on-site,5 and the type of unit in which the waste 
is stored. Licensed facilities are considered RCRA storage 
facilities that require a RCRA permit 6 (40 CFR 262.34) if they 
store the waste for:

    \5\ ``On-site'' defined by RCRA means ``the same or 
geographically contiguous property which may be divided by public or 
private right-of-way, provided the entrance and exit between the 
properties is at a cross-roads intersection, and access is by 
crossing as opposed to going along, the right-of-way. Non-contiguous 
properties owned by the same person but connected by a right-of-way 
which he controls and to which the public does not have access, is 
also considered on-site property.'' 40 CFR 260.10
    \6\ Note that facility generation rates must be made on a per 
month basis for all hazardous wastes generated on-site. Waste 
averaging (i.e., determining the total amount of waste generated in 
a year and dividing by 12) is not permitted in calculating monthly 
generation rates. Likewise, mixed waste cannot be treated separately 
from other hazardous waste in terms of the generation and 
accumulation limits.
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     More than 90 days, and if the facility's generation 
rate (both hazardous and mixed waste) is greater than 1000 kilograms 
per month (or greater than 1 kilogram of acutely hazardous waste/
month; 7 or

    \7\ Acutely hazardous wastes are defined in 40 CFR 261.11(a)(2) 
and listed in 40 CFR 261.31-33).
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     More than 180 days, and if the facility's waste 
generation rate (both hazardous and 

[[Page 40207]]
mixed waste) is between 100 and 1000 kilograms/month (in addition, the 
on-site waste accumulation can not exceed 6000 kilograms); or
     Longer than 270 days, if the facility's waste 
generation rate (both hazardous and mixed waste) is between 100 and 
1000 kilograms/month, and if the hazardous waste management facility 
to which the waste must be shipped is over 200 miles from the 
licensee's facility.
    Licensees have asked questions about the applicability of RCRA 
regulated quantities. If a facility generates a quantity of low-
level mixed waste that, combined with on-site RCRA non-mixed 
hazardous waste generation, does not exceed 100 kg/mo (or one 
kilogram of acutely hazardous waste as defined in 40 CFR 
261.11(a)(2) and listed in 40 CFR 261.31-33), it qualifies as a 
conditionally exempt small quantity generator (SQG). As a result, it 
can dispose of the low-level mixed waste as low-level radioactive 
waste, if these materials meet the disposal site's waste acceptance 
criteria (40 CFR 261.5).
    RCRA permit requirements are unit-specific and are described in 
40 CFR part 264 for permitted facilities and 40 CFR part 265 for 
interim status facilities. Interim status requirements are self-
implementing waste management requirements which are limited to 
facilities that were already in existence on the date that a new 
regulation or statutory requirement took effect and which subjected 
the facility to RCRA. For mixed waste facilities in authorized 
States, this date generally corresponds to the date that the State 
received authorization for a mixed waste program, although State 
requirements may differ.
    Under RCRA, persons who store the prescribed quantities of 
hazardous wastes for less than the times outlined above are 
considered generators only and need not obtain a storage permit. 
However, such generators are still subject to the storage 
requirements of 40 CFR 262.34 (a) or (d),8 unless they qualify 
for the conditionally exempt small quantity generator (SQG) 
exemption in 40 CFR 261.5. A generator qualifies for this exemption 
if he generates no more than 100 kilograms of hazardous waste 
(including mixed waste) per month or 1 kilogram of acutely hazardous 
waste/month. Conditionally exempt SQGs are generally not subject to 
RCRA regulation as long as they meet the generation and accumulation 
limits, properly characterize their waste and ensure its proper 
management. If a SQG accumulates more than 1000 kilograms on-site or 
if its generation rate exceeds 100 kilograms in any given month, 
that SQG is no longer conditionally exempt and is subject to 
RCRA.9

    \8\ 40 CFR 262.34(a) addresses the accumulation time and the 
containment of wastes in containers, tanks, or on drip pads as well 
as the labelling of these units. 40 CFR 262.34(d) discusses storage 
requirements for persons generating between 100 and 1000 kilograms 
of hazardous waste per month.
    \9\ State regulations pertaining to small quantity generators 
may vary. Generators should contact the appropriate State hazardous 
waste regulatory authority to determine the status of SQGs in their 
State.
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    Generators may also store up to 55 gallons of hazardous waste 
(or 1 quart of acutely hazardous waste) in containers at or near the 
site of generation without a RCRA permit and without regard to the 
storage time limits. This is known as ``satellite accumulation'' and 
is governed by 40 CFR 262.34(c)(1). However, any waste in excess of 
the 55 gallons (or 1 quart of acutely hazardous waste) must be 
removed from this area within three days of the date that these 
volumes were exceeded to a central storage area at which time the 
accumulation times mentioned above take effect. For example, a 
facility that generates over 1000 kg of hazardous waste per month 
has up to three days to remove any waste that exceeds the satellite 
accumulation limit of 55 gallons from the satellite accumulation 
container and, following that three day period (or after waste is 
moved to the generator storage area), may store the waste for up to 
90 days in accordance with the generator storage provisions of 40 
CFR Part 262.34(a). If the waste is stored longer than 90 days, RCRA 
interim status or a RCRA storage permit is required.
    Secondary materials that are stored or accumulated prior to 
being recycled (used, reused, or reclaimed) may be considered 
``accumulated speculatively'' (see 40 CFR sections 261.1(c)(7), 
261.1(c)(8), and 261.2(c) and (e)) and thus may be identified as 
hazardous waste unless the generator or facility accumulating the 
material can demonstrate that:
     The material is potentially recyclable;
     The material has a feasible means of being recycled; 
and
     At least 75 percent by weight or volume is recycled or 
transferred to a different site for recycling during the calendar 
year.
    The EPA Regional Administrator or State Director has authority 
to approve accumulation that does not meet these limits, upon 
request for a variance (see 40 CFR 260.31(a)).
    These restrictions on speculative accumulation may bring 
materials into the hazardous waste universe that have in the past 
been considered recyclable (see 40 CFR 261.2(d) and 261.2(e)). The 
intent of having such a requirement is to prevent the long term 
storage and mismanagement of hazardous materials under the guise 
that they may have some potential for being reused or recycled. 
Readers are encouraged to review 40 CFR 261.2 and 261.6 for further 
information on accumulation.

c. Storage Time Limitations Under the Land Disposal Restrictions and 
Variances

    EPA's Land Disposal Restriction (LDR) regulations (i.e., the 
requirements in 40 CFR 268.50 that prohibit the land disposal of 
hazardous wastes without prior treatment) prohibit the storage of 
LDR restricted hazardous wastes (including mixed wastes) except when 
storage is ``solely for the purpose of accumulation of such 
quantities of hazardous waste as necessary to facilitate proper 
recovery, treatment, or disposal''. Wastes that satisfy this 
accumulation requirement, may be stored in tanks, containers, or 
containment buildings on-site.10 Waste may be stored without 
regard to the storage prohibition if it has been treated to meet EPA 
treatment standards or if the waste is not subject to, or is exempt 
from, the LDRs because of an extension or a specific exemption from 
the LDRs (e.g., conditionally exempt small quantity generator 
wastes). In addition, wastes that have been placed into storage 
prior to an applicable LDR effective date are not subject to the 
prohibitions on storage. However, once such wastes are removed from 
storage, these wastes are subject to treatment standards and other 
applicable LDR requirements (51 FR 40577, November 7, 1986).

    \10\  Containment buildings (defined as hazardous waste 
management units where waste is stored or treated) are not 
considered land disposal units and wastes may be stored in 
containment buildings without first meeting a treatment standard. 
Please see 57 FR 37194, August 18, 1992 for more detailed 
information.
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    The storage prohibition also is not in effect for waste subject 
to a variance from the Land Disposal Restrictions. EPA grants three 
general types of variances from the LDRs: (1) variances that delay 
the effective date of a prohibition (e.g., a variance based on the 
lack of capacity to treat, recover or dispose hazardous waste); (2) 
variances from the prohibition based on a ``no-migration'' 
determination; and (3) a treatability variance from a specific 
treatment standard. For more information on these variances, please 
consult the EPA guidance document entitled ``Guidance on the Land 
Disposal Restrictions' Effects on Storage and Disposal of Commercial 
Mixed Waste'' (OSWER Directive 9555.00-01, September 28, 1990) 
available from NRC or EPA.

d. RCRA Permits and NRC License Amendments

    Storage of all radioactive waste, including mixed waste, should 
be carried out in such a manner that ensures that the stored waste 
does not create a radiological hazard to surrounding areas, increase 
the potential for a release of radioactive materials to unrestricted 
areas, or pose an increased hazard to facility personnel. The 
physical, chemical, and radiological characteristics of the waste, 
as well as any other characteristics that could pose a potential 
health and safety problem in the storage area should be identified 
and evaluated by the licensee prior to developing the NRC license 
application or amendment request. Provisions for material security 
and inventory, fire protection, effluent controls, effluent 
monitoring, shielding and area radiological controls should be 
included in the NRC license application or amendment request. This 
application or request should include written procedures for 
radiological surveys, periodic audits, and inspections, as well as 
an effective contingency plan to address the repackaging of damaged 
or deteriorating containers. The elements of the plan should take 
into account the isotopes, waste forms, and quantities to be stored.
    In order to remain in compliance with all regulatory 
requirements for mixed waste storage, some licensees may need to 
obtain an EPA (or authorized State) storage permit and/or amend 
their NRC (or Agreement State) 

[[Page 40208]]
licenses. Examples of instances where an NRC license amendment may be 
needed include:
     If the total activity of the radioactive material at 
the facility (both in use, storage, or in waste) would exceed the 
activity authorized by the facility license;
     If the licensee intends to store the waste in a portion 
of the facility not authorized by the license;
     If the chemical or physical form of the waste is not 
authorized by the license; or
     If the storage program is not specifically included 
within the scope of the authorization.
    If a licensee is required to amend its radioactive materials 
license, NRC will require the licensee to provide sufficient 
information to evaluate the request and determine if the proposed 
amendment impacts on the level of protection afforded by the 
existing license.

NRC License Amendments

    While EPA regulations concerning the storage of hazardous waste 
(40 CFR Part 264, Subpart I and J) are fairly prescriptive, NRC 
regulations regarding the storage of radioactive waste, other than 
spent fuel, are more performance based. NRC licenses incorporate 
conditions specific to a facility or licensee that prescribe 
acceptable practices for the storage of radioactive material. 
Typically, licensees propose materials management practices to NRC 
and an evaluation of the proposed practice is performed by NRC prior 
to approving (or disapproving) the request. These license conditions 
are then enforceable conditions under which the licensee must 
conduct his operations.
    Those facilities already possessing a radioactive materials 
license may need to amend their license to store mixed waste. 
Currently, NRC guidance on LLW storage is contained in several 
Generic Letters and Information Notices. Appendix A lists these 
Generic Letters and Information Notices. Licensees contemplating 
storing mixed waste should review the NRC guidance and contact NRC 
to determine the information that should be included in a request to 
store mixed waste at their facility.

[In a memorandum to the Commission dated August 1, 1994 (SECY 94-
198), NRC staff provided the Commission with revisions to the 
existing guidance for on-site storage of low-level radioactive 
waste. NRC staff expects to finalize the guidance in late 1995. 
Until the revised guidance is finalized licensees should refer to 
the guidance discussed in Appendix A. NRC staff expects to include 
the revised LLW storage guidance in the final joint guidance on 
mixed waste storage].

    If licensees store mixed waste containing special nuclear 
material, they must address the special properties of the fissile 
radioisotopes in this waste. Their mixed-waste storage program must 
address the spatial distribution, geometry, volume, and the 
concentration of this waste at the storage facility. Strict controls 
are to be implemented and documented that assure the safe storage of 
mixed waste containing special nuclear material. Appropriate 
security measures are to be taken, and documented, to ensure the 
physical security of special nuclear material at the storage 
facility. The licensee must comply with all requirements stipulated 
in their license and with the requirements in 10 CFR Part 70, 
``Domestic Licensing of Special Nuclear Material.''

RCRA Permits

    Licensees who require a RCRA permit for storage must submit an 
EPA permit application. The application, which is described in 40 
CFR Part 270, consists of two parts (Parts A and B). Part A consists 
of pages 1 and 3 of the Consolidated Permit Applications Form. There 
is no form for a Part B application. Rather, the Part B application 
is submitted in narrative form and should contain the information 
set forth in the applicable sections of 40 CFR 270.14 through 
270.29. For new facilities, Parts A and B of the permit must be 
submitted at least 180 days before physical construction of any new 
facility is expected to commence.
    For existing facilities (i.e., existing on the date that RCRA 
applicability is established), timely submission of the Notification 
of Hazardous Materials Activity and a Part A application qualifies 
the facility for interim status under RCRA section 3005(e). 
Facilities with interim status are treated as having been issued a 
RCRA permit until EPA, or a State, makes a final determination on 
the permit application.
    Facilities with interim status still must comply with the 
interim status regulations set forth in 40 CFR Part 265 or with 
their State's regulations if it is an EPA authorized State. For such 
existing facilities the EPA Regional Administrator shall set a date, 
giving the facility at least six months notice, for submission of 
the Part B application.

III. Specific Storage Issues

    Most mixed waste at operating facilities will be stored in 
containers or, less frequently, in tanks. EPA requirements for waste 
stored in tanks and containers are outlined in RCRA Subparts J and 
I, respectively. In addition, 40 CFR 268.50 addresses the storage of 
hazardous wastes restricted from land disposal under Subpart C of 
RCRA. Unlike EPA regulations, NRC's requirements for waste storage 
are not specific with respect to the type of storage unit (i.e., 
container, tank, waste pile, etc.), except for tanks at nuclear 
power reactors, but are based on the type of waste (i.e, wet or dry) 
and are outlined in 10 CFR Parts 20, 30, 40, 50, 70, and 73. 
Licensees will be required to comply with container and tank 
requirements of both EPA and NRC.
    Licensees have identified a variety of issues associated with 
the storage of mixed waste that have caused them concern. Licensees 
have indicated to both NRC and EPA that they believe strict 
adherence to the regulations of both agencies may not be possible 
because of perceived inconsistencies between the two sets of 
regulatory requirements.11 Where radioactive wastes (or wastes 
suspected of being radioactive) are involved in storage, it has been 
suggested that the NRC's storage requirements may run counter to the 
aims of RCRA. Neither EPA nor NRC is aware of any specific instances 
where RCRA compliance has been inconsistent with the AEA. However, 
both agencies acknowledge that an inconsistency may occur. A 
licensee or applicant who suspects that an inconsistency may exist 
should contact both NRC, EPA, or any other AEA and RCRA regulatory 
agencies. These regulatory agencies should deliberate and consult on 
whether there is an unresolvable inconsistency and, if one exists, 
they should attempt to fashion the necessary relief from the 
particular RCRA provision that gives rise to the inconsistency. 
However, all other RCRA regulatory requirements would apply. That 
is, a finding by the regulatory agencies that an inconsistency 
exists does not relieve a hazardous waste facility owner/operator of 
the responsibility to ensure that the mixed waste is managed in 
accordance with all other applicable RCRA regulatory requirements. 
Owners/operators of mixed waste facilities are encouraged to address 
and document this potential situation and its resolution in the RCRA 
facility waste analysis plan which must be submitted with the Part B 
permit application, or addressed in a permit modification.

    \11\ The Agencies consider an inconsistency to occur when 
compliance with one statute or set of implementing regulations would 
necessarily cause non-compliance with the other.
---------------------------------------------------------------------------

    Licensees have identified four issues where compliance with both 
agencies' regulations has caused concern or confusion. These issues 
are:
    (1) Decay-in-storage of mixed waste;
    (2) Inspection/surveillance requirements for mixed waste in 
storage;
    (3) Allowable storage practices for stored mixed waste; and
    (4) Waste compatibility, segregation and spacing requirements.
Decay-in-Storage of Mixed Waste

    A large portion of the radioactive waste (and mixed waste) 
generated by medical and biomedical research institutions contains 
radionuclides with relatively short half-lives. These short lived 
radionuclides are especially prevalent in the combustible dry waste, 
aqueous wastes, and animal carcass wastes generated by medical and 
academic institutions. NRC generally allows medical facilities to 
store waste containing radionuclides with half-lives of less than 65 
days until 10 half-lives have elapsed and the radiation emitted from 
the unshielded surface of the waste, as measured with an appropriate 
survey instrument, is indistinguishable from background levels. The 
waste may then be disposed of as non-radioactive waste after 
ensuring that all radioactive material labels are rendered 
unrecognizable (see 10 CFR 35.92). Radioactive waste may also be 
stored for decay under certain circumstances in accordance with 10 
CFR 20.2001. For mixed waste, storage for decay is particularly 
advantageous, since the waste may be managed solely as a hazardous 
waste after the radionuclides decay to background levels. Thus, the 
management and regulation of these mixed wastes are greatly 
simplified by the availability of storage for decay.
    Before disposing of the waste after decay, the licensee must 
survey the waste using an appropriate survey instrument, and 

[[Page 40209]]
technique, and demonstrate that the radiation emitted from the waste is 
indistinguishable from representative background levels. Licensees, 
not already authorized to hold wastes for decay-in-storage, that 
wish to hold mixed waste for decay-in-storage may need to obtain a 
license amendment from NRC prior to storing the mixed waste. Many 
licensees in possession of mixed waste and who use decay-in-storage 
will be required to obtain an amendment to store the mixed waste for 
decay prior to disposal as hazardous waste. The following should be 
included in a license amendment request to NRC:
     A description of the survey procedures to be used 
during storage and prior to release of the waste to a hazardous 
waste-only facility,
     A description of the procedures for segregating and 
tracking waste from placement in storage to release to a hazardous 
waste-only facility,
     A commitment that waste will be held for a minimum of 
ten half-lives prior to performing the final radiation survey before 
release to a hazardous waste-only facility and
     A statement that the decayed radioactive waste will not 
be released to a hazardous waste-only facility unless the radiation 
emitted from the waste is indistinguishable from background 
radiation.
    While NRC licensing amendments address the management of the 
radioactive component of these wastes, they generally have no effect 
on the applicable RCRA storage provisions. Storage requirements 
under RCRA should ideally be implemented in a manner that provides 
appropriate protection of health and the environment, without 
setting up undue impediments to well conducted decay programs.
    Under RCRA, a storage permit (or interim status) is generally 
required to manage the wastes during the decay period if this 
storage period exceeds 90 days. However, even with such a permit, a 
question has been raised as to whether accumulation of mixed wastes 
during the decay period violates the Land Disposal Restrictions 
(LDR) storage prohibition in RCRA section 3004(j). This latter 
provision, and regulations at 40 CFR 268.50, generally prohibit 
generators and owner/operators of hazardous waste treatment, 
storage, or disposal facilities from storing hazardous wastes that 
are restricted from land disposal under the LDR program, except when 
storage is ``solely for the purpose of accumulation of such 
quantities of hazardous waste as necessary to facilitate proper 
recovery, treatment, or disposal''. Exceptions are recognized for 
hazardous wastes that have been treated to LDR treatment 
specifications, and for wastes exempted by virtue of one of the LDR 
variance authorities, i.e., a capacity variance, a no migration 
variance, or a case-by-case extension. In addition, RCRA and 
regulations at 40 CFR 268.50(a) define a conditional exception for 
on-site storage in tanks or containers, where the generator complies 
with the regulations at 40 CFR 262.34 requirements, and the storage 
is solely for the purpose of the accumulation of such quantities of 
hazardous waste as are necessary to facilitate proper recovery, 
treatment, or disposal.
    EPA believes that the limited periods of approved decay-in-
storage of mixed waste do not violate the RCRA section 3004(j) 
storage prohibition. EPA believes this interpretation is supported 
by the following consideration.
    EPA considers decay-in-storage a necessary and useful part of 
the best demonstrated available technology (BDAT) treatment process. 
``Decay-in-storage'' meets the definition of ``treatment'' in 40 CFR 
260.10, insofar as it is a method or technique designed to change 
the physical character or composition (amount of radioactivity) in 
the mixed wastes. Decay-in-storage subsequently makes the treatment 
of the hazardous constituents safer, and renders them safer for 
transport.
    As a result, the LDR storage prohibition does not apply to mixed 
waste held pursuant to an NRC approved decay-in-storage program 
during the period of decay. EPA emphasizes that the inapplicability 
of the storage prohibition is coincident with the period of decay; 
once the waste has decayed to levels that are indistinguishable from 
background levels, the RCRA 3004(j) and 40 CFR 268.50 provisions 
apply fully to any additional storage that occurs prior to 
completing the required BDAT treatment.

Inspection/Surveillance Requirements for Stored Mixed Waste

    Under RCRA, waste storage containers must be inspected on a 
weekly basis (40 CFR 264.174) and certain above-ground portions of 
waste storage tanks on a daily basis (40 CFR 264.195(b)(1)). The 
purpose of these inspections is to detect leakage from or 
deterioration of containers. NRC recommends that waste in storage be 
inspected on at least a quarterly basis. Licensees have expressed 
concerns that daily or weekly ``walk-through'' inspections of high-
activity mixed waste may result in increased exposures to workers at 
their facilities and thus violate their As Low as Reasonably 
Achievable (ALARA) programs.
    The RCRA regulations and permit guidance do not require that 
inspections of mixed waste in storage must be ``walk-through'' 
inspections. NRC and EPA recognize that increased exposures to 
workers may result from daily or weekly ``walk through'' inspections 
and suggest that licensees consider using methods other than walk-
through inspections as a means to inspect high-activity mixed waste 
in storage. Alternative methods for inspection could include the use 
of remote monitoring devices to determine if a waste container is 
leaking or television monitors, or other means that are capable of 
detecting leakage or deterioration. Such alternative methods would 
comply with the RCRA regulation and would avoid the additional 
exposures of walk-through inspections. However, these measures 
should be coupled with a means to promptly locate and segregate or 
remediate leaking containers.
    Flexibility does exist in the RCRA regulations to allow use of 
such alternative inspection procedures at frequencies specified in 
the hazardous waste regulations and in the facility's waste analysis 
plan. Once a facility receives a RCRA permit, these procedures and 
frequencies are included in the permit. Facilities with existing 
RCRA permits may have to request a permit modification to change 
stated inspection procedures (40 CFR 270.42).
    NRC licensees that have incorporated specific inspection 
procedures in their radioactive materials licenses or procedures 
referred to in license conditions should contact the appropriate NRC 
or State office to determine if the alternative inspection procedure 
will require the license to be amended.

Allowable Storage Practices--Dense Packing Practices

    NRC currently allows containers with low exposure rates to be 
used to provide radiation shielding for containers with higher 
exposure rates. Licensees have expressed concerns that RCRA 
inspection requirements (40 CFR 264.174, 264.195(b)(1), 265.174, and 
265.195(a)(1)) may restrict this use of low exposure rate containers 
and that such a restriction could cause an increase in worker 
exposures.
    The agencies agree that using low-exposure rate containers for 
radiation shielding is a reasonable practice. However, concerns 
about the potential consequences of a container leaking liquid high-
activity mixed waste must also be addressed. Containers may be used 
for radiation shielding, so long as a licensee is capable of 
detecting, locating the source, and responding to a release within 
24 hours of detection to mitigate any significant release. An 
example of such a capability might include a remote monitoring 
capability coupled with a means for promptly locating and responding 
to such a release. So long as the container configuration does not 
compromise the ability to detect or respond to container leakage or 
deterioration, the configuration complies with RCRA requirements.

Waste Compatibility, Segregation and Spacing Requirements

    In general, any facility that treats, stores or disposes of RCRA 
hazardous wastes (including mixed waste) must take special measures 
in handling ignitable, reactive, and potentially incompatible 
wastes. These measures are outlined in 40 CFR 264.17, including 
placing ``No smoking'' signs in areas where ignitable or reactive 
wastes present hazards, separating or protecting wastes from sources 
of ignition or reaction, and taking special precautions to avoid 
explosive, heat or gas generating reactions. Facilities must 
document their compliance with these measures (40 CFR 264.17(c)).
    Additional requirements for ignitable, reactive, and 
incompatible wastes managed in tanks and containers are found in 
Subparts I and J of 40 CFR Parts 264 and 265. For example, 40 CFR 
264.177 and 265.177 require that wastes managed in containers that 
are stored close to incompatible wastes or other materials ``must be 
separated from the other materials or protected from them by means 
of a dike, berm, wall, or other device'' to prevent ignition or 
reaction. This separation, however, can occur in the same storage 
facility and does not necessitate the construction of an entirely 
separate storage unit. Hazardous wastes also may not be placed in 
unwashed or contaminated units that previously contained 
incompatible 

[[Page 40210]]
wastes or materials (40 CFR 264.177(b)). Appendix V of 40 CFR Part 264 
contains examples of potentially incompatible wastes.
    RCRA storage facilities must also maintain sufficient aisle 
space in waste storage areas ``to allow the unobstructed movement of 
personnel, fire protection equipment, spill control equipment, and 
decontamination equipment to any area of the facility operation in 
an emergency, unless it can be demonstrated to the EPA Regional 
Administrator that aisle space is not needed for these purposes'' 
(40 CFR 264.35). In situations where high activity mixed wastes are 
monitored by remote means and/or stored using dense packing, a new 
facility has the flexibility to make such a demonstration to the 
Regional Administrator based (or authorized State) on the need to 
control the radiation hazard (40 CFR 264.35). Facilities with 
interim status have the same opportunity to justify why aisle space 
is not required (40 CFR 265.35). In either case, alternative systems 
or plans to contain spills, prevent fire and decontaminate equipment 
may be required by the Regional Administrator. The determination to 
waive or alter the aisle space requirement will be made on a case-
by-case basis and be incorporated into the facility's RCRA permit.

IV. EPA RCRA Enforcement Policy for Mixed Waste in Storage

    EPA has recognized that a shortage of adequate treatment and 
disposal capacity for mixed waste has existed for some time, and 
that the LDRs present a problem for generators that are unable to 
treat or dispose of this waste. Accordingly, on August 29, 1991 EPA 
announced, in the Federal Register (56 FR 42730) a policy of giving 
a reduced priority to civil enforcement of the storage prohibition 
in section 3004 (j) of RCRA at facilities which generate mixed 
waste. The policy was limited to civil enforcement and 
administrative actions resulting solely from the act of storing 
mixed waste in violation of RCRA section 3004 (j) and to those waste 
streams for which adequate treatment is not available. The policy 
was limited in duration and expired on December 31, 1993. On April 
20, 1994, EPA announced a two year extension of this policy (59 FR 
18813).
    This policy applies to facilities which generate less than 1,000 
cubic feet per year of land disposal restricted mixed waste and are 
operated in an environmentally responsible manner. EPA will consider 
a variety of factors in determining if a facility is conducting its 
operations in an environmentally responsible manner including:
     Whether the facility can demonstrate that its mixed 
waste storage areas are in compliance with all applicable RCRA 
storage facility standards found in 40 CFR 264.73/265.73 and 
inspection standards found in 40 CFR 264.15/265.15;
     Whether the facility has identified and kept records of 
its mixed wastes in accordance with 40 CFR 264.73(b)/265.73(b), 
including sources, waste codes, generation rates and volumes in 
storage;
     Whether the facility has developed a mixed waste 
minimization plan (see 58 FR 31114, May 28, 1993) and;
     Whether the facility is prepared to demonstrate the 
good faith efforts it has undertaken to ascertain the availability 
of treatment capacity for its wastes.
    Licensees are encouraged to review this policy as presented in 
the Federal Register to determine if the flexibility contained in 
the policy may be appropriate for the operations at their 
facilities.

V. Conclusion

    NRC and EPA recognize that until adequate treatment and disposal 
capacity is developed, mixed waste generators will face difficulties 
when storing their mixed waste. Compliance with both agencies' 
regulatory requirements will require that mixed waste generators 
become familiar with and take advantage of the flexibility in the 
existing regulations. Methods to ensure compliance with these 
regulations may include the use of remote monitoring equipment and 
shielding high exposure rate containers with low exposure rate 
containers. Generators that manage land disposal restricted waste 
and that are unable to find treatment and disposal capacity are 
likely to meet the conditions for the lower enforcement priority 
policy described above. If a generator locates adequate treatment 
and disposal capacity, this capacity should be used rather than 
engaging in unnecessary storage.
    Generators should make every effort to determine if treatment or 
disposal capacity currently exists for their mixed waste. In order 
to provide mixed waste generators with information on commercial 
treatment and disposal capacity, the agencies published NUREG/CR-
5938, the National Profile on Commercially Generated Low-Level 
Radioactive Mixed Waste in December 1992. This NUREG presents 
information on the volumes, characteristics, and treatability of 
commercially generated mixed waste and provides valuable information 
on facilities that currently offer treatment services for mixed 
waste. Finally, generators should minimize, to the maximum extent 
practicable, the amount of mixed waste being generated at their 
facilities. EPA's Risk Reduction Engineering Laboratory (RREL), in 
coordination with DOE, is currently conducting research in waste 
minimization techniques that should provide generators with general 
strategies to minimize their hazardous and mixed waste generation. 
Mixed waste generators should contact RREL at (513) 569-7391 to 
obtain information on these general waste minimization techniques. 
(For additional guidance, refer to 58 FR 31114, May 28, 1993, 
Guidance to Hazardous Waste Generators on the Elements of a Waste 
Minimization Program, or NRC Information Notice 94-23, Guidance to 
Hazardous, Radioactive and Mixed Waste Generators on the Elements of 
a Waste Minimization Program, March 25, 1994).
    NRC and EPA believe that through cooperation with the regulatory 
authorities, the use of innovative storage practices, minimizing 
mixed waste generation, and treating mixed waste to the maximum 
extent possible, mixed waste generators will be able to manage their 
mixed waste in a manner that protects the public and the environment 
until adequate disposal capacity is developed.

                                             Table 1.--States With Mixed Waste Authority as of June 30, 1995                                            
                                                                                                                                                        
                                                                                                                                                        
Alabama                                Illinois                               Nebraska                              Oregon.                             
Arizona                                Indiana                                Nevada                                South Carolina.                     
Arkansas                               Kansas                                 New Hampshire                         South Dakota.                       
California                             Kentucky                               New Mexico                            Tennessee.                          
Colorado                               Louisiana                              New York                              Texas.                              
Connecticut                            Michigan                               North Carolina                        Utah.                               
Florida                                Minnesota                              North Dakota                          Vermont.                            
Georgia                                Mississippi                            Ohio                                  Washington.                         
Guam                                   Missouri                               Oklahoma                              Wisconsin.                          
Idaho                                  Montana                                                                                                          


                               Table 2.--NRC Agreement States, as of June 30, 1995                              
                                                                                                                
                                                                                                                
Alabama                               Kansas                                New York.                           
Arizona                               Kentucky                              North Carolina.                     
Arkansas                              Louisiana                             North Dakota.                       
California                            Maine                                 Oregon.                             
Colorado                              Maryland                              Rhode Island.                       
Florida                               Mississippi                           South Carolina.                     
Georgia                               Nebraska                              Tennessee.                          

[[Page 40211]]
                                                                                                                
Illinois                              Nevada                                Texas.                              
Iowa                                  New Hampshire                         Utah.                               
                                      New Mexico                            Washington.                         



         Table 3.--RCRA Regulatory Requirements for Mixed Waste         
------------------------------------------------------------------------
   Facility located in                Applicable requirements           
------------------------------------------------------------------------
State not authorized for   Mixed waste is subject to Federal RCRA       
 base RCRA Program.         Subtitle C requirements. State may impose   
                            additional requirements.                    
State authorized for base  Mixed waste is not subject to RCRA Subtitle C
 RCRA program but not for   requirements. State may impose non-RCRA     
 mixed waste.               mixed waste requirements.                   
State authorized for base  Mixed waste is subject to authorized State   
 RCRA program and mixed     RCRA requirements.*                         
 waste (mixed waste                                                     
 authorized State).                                                     
------------------------------------------------------------------------
* Under Sec.  3008(a)(2) of the SWDA, EPA retains enforcement authority 
  in authorized States.                                                 

References

    40 CFR Part 260, Hazardous Waste Management System: General 
Title 40, Code of Federal Regulations, Sec. 260.10.
    U.S. Environmental Protection Agency and U.S. Nuclear Regulatory 
Commission, 1989, ``Guidance on the Definition and Identification of 
Commercial Mixed Low-Level Radioactive and Hazardous Waste and 
Answers to Anticipated Questions.''
    National Profile on Commercially Generated Low-level Radioactive 
Mixed Waste, NUREG/CR-5938, December 1992.
List of Regulations
    Environmental Protection Agency General Regulations for 
Hazardous Waste Management, 40 CFR Part 260.
    Environmental Protection Agency Regulations for Identifying 
Hazardous Waste, 40 CFR Part 261.
    Environmental Protection Agency Regulations for Hazardous Waste 
Generators, 40 CFR Part 262.
    Environmental Protection Agency Standards for Owners and 
Operators of Hazardous Waste Treatment, Storage and Disposal 
Facilities, 40 CFR Part 264.
    Environmental Protection Agency Interim Status Standards for 
Owners and Operators of Hazardous Waste Facilities, 40 CFR Part 265.
    Environmental Protection Agency Regulations on Land Disposal 
Restrictions, 40 CFR Part 268.
    Nuclear Regulatory Commission Regulations--Standards for 
Protection Against Radiation, 10 CFR Part 20.
    Nuclear Regulatory Commission Regulations--Rules of General 
Applicability to Domestic Licensing of Byproduct Material, 10 CFR 
Part 30.
    Nuclear Regulatory Commission Regulation--Domestic Licensing of 
Source Material, 10 CFR Part 40.
    Nuclear Regulatory Commission Regulations--Domestic Licensing of 
Production and Utilization Facilities, 10 CFR Part 50.
    Nuclear Regulatory Commission Regulations--Licensing 
Requirements for Land Disposal of Radioactive Waste, 10 CFR Part 61.

Appendix A

NRC Guidance Documents on the Storage of Radioactive Waste

    1. NRC Generic Letter 81-38, Storage of Low-Level Radioactive 
Wastes at Power Reactor Sites.
    2. NRC Generic Letter 85-14, Commercial Storage at Power Reactor 
Sites of Low-Level Radioactive Waste Not Generated by the Utility.
    3. NRC Information Notice No. 89-13, Alternative Waste 
Management Procedures in Case of Denial of Access to Low-Level Waste 
Disposal Sites.
    4. NRC Information Notice 90-09, Extended Interim Storage of 
Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees.

[FR Doc. 95-19359 Filed 8-4-95; 8:45 am]
BILLING CODE 7590-01-P