Update to Reporting H-3, C-14, Tc-99 and I-129 on the Uniform Waste Manifest

NRC RIS 2015-02 Reporting of H-3 c-14 Tc-99 and I-129 on the Uniform Waste Manifest.pdf

The U.S. Nuclear Regulatory Commission (NRC) issued a new regulatory issue summary (RIS 2015-02) to inform all licensees, certificate holders and applicants of the option to use indirect methods to determine the activity of Tritium (H-3), Carbon-14 (C-14), Technetium-99 (Tc-99), and Iodine-129 (I-129) reported on the uniform waste manifest when the radionuclide is present at a concentration less than the lower limit of detection (LLD). The reason for noting this option is because accurately reporting the activities of these radionuclides is important for better decision making regarding the disposal of low-level radioactive waste (LLRW). Overestimation of disposal site inventory could lead to premature loss of disposal system capacity, whereas underestimation of inventory could lead to public health and safety concerns. It is expected that the use of indirect methods will be most appropriate for licensees with well-characterized and consistent waste streams (e.g., nuclear power plants). Regulations in 10 CFR 61.55(a)(8) allow for the use of indirect methods to determine the concentrations of radionuclides in waste for the purpose of waste classification if there is reasonable assurance that the indirect methods can be correlated with actual measurements. However, the instructions for completing the uniform manifest (NUREG/BR-0204) do not include this option for reporting the inventory of H-3, C-14, Tc-99, and I-129. One type of indirect method mentioned in this RIS is the use of scaling factors. Scaling factors are used to calculate the activity of a difficult-to-measure radionuclide from that of an easy-to-measure radionuclide that has been shown to be correlated. Other indirect methods described in this RIS that can be used are material accountability or computer codes that predict the activity of radionuclides if there is reasonable assurance that the results obtained using these methods are correlated with actual measurements. Licensees may voluntarily begin using the methods described in this RIS. Neither a specific action nor any written response is required. The NRC is providing this RIS to the Agreement States for their information and for distribution to their licensees as appropriate.