Waste Generator Disposal Guide

Summary of Steps for Disposal

Import Petitions

Notification Requirements to Texas

Uniform Low Level Radioactive Waste Manifest Forms

TCEQ Waste Shipment Verification Form

Terminology

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A TCEQ resident inspector must inspect every waste shipment and manifest received at the Compact Waste Disposal Facility for proper classification and characterization prior to waste acceptance. Waste profiles must be established with the Compact Waste Disposal Facility operator, Waste Control Specialists LLC (WCS). For waste intended for disposal at the Compact Waste Disposal Facility, waste acceptance is triggered by the final approval of the specific waste shipment by the executive director’s resident inspector. Waste must be packed in accordance with the WAC contained in Attachment C to the WCS low-level radioactive waste disposal license, R04100.

Each shipment of low-level radioactive waste destined for the Compact Waste Disposal Facility shall meet all regulatory requirements for transportation in Texas Department of State Health Services (DSHS) regulations (25 TAC §289.257) U.S. Department of Transportation (U.S. DOT) regulations (49 CFR Parts 171-180), U.S. Nuclear Regulatory Commission (U.S. NRC) regulations, United States Environmental Protection Agency (U.S. EPA), and the requirements of this license. All waste shippers and transporters wishing to transport low-level radioactive waste to the Compact Waste Disposal Facility will be required to submit a fee, emergency plans, quality assurance programs for packaging, and proof of financial responsibility to DSHS for approval prior to shipment of waste. The DSHS has developed guidance in assisting transporters that describes the process for submission of documentation as well as fee payment entitled Regulatory Guide 2.19 – Low Level Radioactive Waste Shippers and Transporters, Submission of Documents and Fees.

Waste generated outside Texas and Vermont must be specifically authorized through an agreement, to import the waste, between the waste generator and the Texas Low-Level Radioactive Waste Disposal Compact Commission (TLLRWDCC). Waste generated within Texas and Vermont that is destined for a licensed LLRW disposal facility outside the Texas Compact must be specifically authorized through an agreement between the waste generator and the TLLRWDCC. The TLLRWDCC applications for importation and exportation of LLRW can be found at http://www.tllrwdcc.org/.

Summary of Steps for Disposal

1. Confirm that waste intended for shipment meets the requirements found in the disposal license and approved Waste Acceptance Criteria
2. If not a Texas or Vermont waste generator, obtain an approved agreement for import with the TLLRWDCC If Texas or Vermont generator with waste to be disposed outside the Texas Compact, obtain an approved agreement for export with the TLLRWDCC.
3. Waste Generator (Shipper) and Transporter (Carrier) document approval from DSHS
4. Waste profile for planned waste streams established with Disposal Facility Operator, WCS
5. Waste Generator schedules shipment with WCS (link to WCS contact - Pending)
6. Waste Generator provides notification to TCEQ and DSHS of intended shipment (TCEQ Form and Instructions- 20225)
7. Follow-up for confirmation that waste has been successfully received and disposed (WCS)

Import Petitions

31 Texas Administrative Code §675.23 (h)(2) requires an import applicant to deliver a copy of the import application (Annex A)and the proposed import agreement (Annex B) and any supplements or amendments to the Texas Low Level Radioactive Waste Compact Commission, the Compact Facility operator (WCS) and the Texas Commission on Environmental Quality (TCEQ), by electronic mail and by certified mail at the time of filing.

In order to meet this requirement, all import applications (Annex A), proposed agreements (Annex B), any supplements or amendments must be sent by certified mail and electronically submitted by e-mail to the following addresses. Phone contact information is also provided.

Texas Low Level Radioactive Waste Disposal Compact Commission
Mailing Address:
Texas Low Level Radioactive Waste Disposal Compact Commission
333 Guadalupe Street #3-240
Austin, Texas 78701

Email: administration@tllrwdcc.org
Phone: 512-305-8941
Fax: 512-542-9201

Physical Address if necessary:
1307 Marshall Lane
Austin, Texas 78703

Texas Commission on Environmental Quality
Mailing Address:
Radioactive Materials Division
Attn: Radioactive Material Section Manager 
PO Box 13087, MC 233
Austin, TX 78711-3087

Email: RADMAT@tceq.texas.gov
Phone: 512-239-6466
Fax: 512-239-6464

Physical Address if necessary:
Radioactive Materials Division - Section Manager
12100 Park 35 Circle, Bldg F
Austin, TX 78753

Compact Facility operator- Waste Control Specialists LLC
Waste Control Specialists LLC
WCS Import Notification Mailstop
Attn: Vickie Watson
Three Lincoln Centre
5430 LBJ Freeway, Suite 1700
Dallas, TX 75240

Email: DL_WCS_Importation@wcstexas.com
Phone: 972-715-9800
Fax: 972-448-1419

Notification Requirements to Texas

The generators of radioactive waste must provide to the TCEQ completed copies of U.S. NRC’s "Uniform Low Level Radioactive Waste Manifest" and "TCEQ Form - 20225 Waste Shipment Verification Form" for shipments consigned for disposal in Texas no later than five days prior to the date proposed for waste shipment. Fill out forms below and submit to RADMAT@tceq.texas.gov. These forms must be completed after the generator has an approved waste profile certification and has a generator identification number issued by the operator.

The TCEQ requires that generators provide a 5-day advance notification prior to placing waste shipments in transit that includes the associated waste manifests. Due to the nature of certain waste streams and shipment scheduling, the TCEQ understands that the timing of finalizing some parameters may fall within the 5-day period. The TCEQ will allow generators to submit estimated waste manifests and the Waste Shipment Verification Form (WSVF), if necessary, five (5) days prior to shipment and provide the finalized waste manifests and WSVF upon placement of that shipment into transit.

In order to streamline regulatory reporting requirements for generators, the submission of waste information can be provided to the TCEQ as early as possible, but no later than by 5-day advance notice.

Uniform Low Level Radioactive Waste Manifest

• Form 540 (Shipping Paper)
• Form 540A (Shipping Paper-Continuation)
• Form 541 (Container and Waste Description)
• Form 541A (Container and Waste Description-Continuation)
• Form 542 (Manifest Index and Regional Compact Tabulation)
• Form 542A (Manifest Index and Regional Compact Tabulation-Continuation)

Instructions for completing NRC's "Uniform Low-Level Radioactive Waste Manifest"

• NUREG/BR-0204, Rev. 2, July 1998

Texas Commission on Environmental Quality Waste Shipment Verification

• TCEQ Form and Instuctions - 20225 (Waste Shipment Verification)

Terminology

Listed below are commons terms between the license, rules, DSHS guidance and the TLLRWDCC import application.

Contact us if you have any questions at RADMAT.