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Question 389: The revised 10 CFR 20 includes a new
provision that allows disposal of licensed material "...by
decay in storage..." What criteria should be used in
implementing this provision? Is the NRC planning to
develop generic guidance for "decay in storage"?
Answer: See the answer to Question 376 for a discussion
of "decay in storage." As indicated in that answer, "decay
in storage" is not a practical means of disposal of
licensed material at nuclear power plants (and at some
other facilities). Therefore, the NRC is providing no
criteria to be used in implementing this provision at
nuclear power plants and is not planning to develop
(additional) generic guidance for "decay in storage" at
nuclear power plants. As noted in the statement of
considerations for revised Part 20 (56 FR 23380, third
column, and 23381, first column), technically, the "decay
in storage" option has always been available to licensees
as an allowed waste disposal option. This option was
formally included in the proposed and final rules because
the list of disposal options is exclusive and there had
been questions as to whether this option is allowed under
§§20.1-20.601 (in old Part 20). It should be noted that
this option does not allow material that has "decayed in
storage" to be released to an unrestricted area unless it
meets the requirements of one of the other allowed forms of
waste disposal in part 20, or the requirements of §35.92,
"Decay in Storage," of 10 CFR Part 35, or the specific
requirements given in any NRC or Agreement State license.
(References: 10 CFR 20.2001).