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Radiologic Health branch

  ​​LLRW Tracking Program FAQs


Background: The CDPH plays an important role in the State's oversight of low-level radioactive waste (LLRW), which includes licensing and inspecting those that possess sources of radiation and generate radioactive waste. The Department's Radiologic Health Branch (RHB) performs many of the oversight activities for radioactive materials or radiation-emitting machines, which includes tracking LLRW.  Health and Safety Code (HSC) section 115000.1 requires the CDPH to track LLRW that is shipped and stored within the State.  LLRW generators must submit specific information to the CDPH for tracking purposes. The purpose of this data collection is to understand the burden of LLRW generated, stored, and transferred by California generators in order to assess the need for alternative disposal options in the future.  An annual report is available to the public by request to LLRWtracking@cdph.ca.gov. The following FAQs provide guidance and clarification on these reporting requirements.

Basic Information

1.    What is Low-Level Radioactive Waste?

LLRW is defined in California HSC section 115255 as follows:

"Low-level radioactive waste" means regulated radioactive material that meets all of the following requirements: 

  1. The waste 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 (42 U.S.C. Sec. 2014(e)(2))).
  2. The waste is not uranium mining or mill tailings.
  3. The waste is not any waste for which the federal government is responsible pursuant to subdivision (b) of Section 3 of the Low-Level Radioactive Waste Policy Amendments Act of 1985 (42 U.S.C. Sec. 2021c(b)).
  4. The waste is not an alpha emitting transuranic nuclide with a half-life greater than five years and with a concentration greater than 100 nanocuries per gram, or Plutonium-241 with a concentration greater than 3,500 nanocuries per gram, or Curium-242 with a concentration greater than 20,000 nanocuries per gram.

2.    What are the waste classifications for LLRW?

The waste classifications for LLRW disposed in near-surface disposal facilities are:

  • Class A
  • Class B
  • Class C

The waste classifications are defined in federal regulation 10 CFR 61.55, which may be accessed through the U.S. Nuclear Regulatory Commission website at http://www.nrc.gov/.

3.    Who must comply with HSC section 115000.1?

If you answer YES to either of the following questions, you must comply, and report, in accordance with HSC section 115000.1(h):

  • Have you, directly or indirectly, through a broker or a manufacturer, shipped LLRW to a licensed LLRW disposal site? This includes LLRW shipped to the licensed LLRW disposal site after treatment at a waste processor facility.
  • Do you have LLRW in your possession as of December 31, whether for purposes of decay-in-storage, storage for later transfer to a licensed disposal facility, or storage due to a lack of disposal option?


Reporting Requirements

4.    What must LLRW generators do?

Generators are required to provide both of the following via the CDPH online LLRW reporting system:

  • For each shipment of LLRW, the generator must submit to the CDPH the information included on the Nuclear Regulatory Commission's (NRC) Uniform Low-Level Radioactive Waste Manifest Forms 540, 540A, 541, and 541A; AND
  • Annually submit to the CDPH specific information summarizing the LLRW stored as of December 31.

Please see FAQ #7 for specific reporting scenarios.

5.    What is the online LLRW reporting system?

The online LLRW reporting system is a single application that consists of two modules.  The first module is a questionnaire into which storage data should be entered, and the second module is a data-entry template that replicates the format of the NRC 540, 540A, 541, and 541A forms.

Please use the following link register and/or gain access to the system:

 LLRW ONLINE REPORTING SYSTEM

6.    When should the generators and/or brokers submit the required information for the LLRW stored and/or shipped for disposal at the licensed LLRW disposal sites?

HSC section 115000.1(h) requires generators of LLRW to submit information to the department annually concerning LLRW shipped and stored; however, a submittal date for the annual reports is not specified in law.   RHB will consider the annual reporting requirement to have been met if the information is submitted by June 30 of the year following the reporting calendar year.

If special circumstances do not allow submittal of the annual report by June 30, contact the RHB in writing with the reason for the delay and the anticipated submittal date.  Please send an email to LLRWtracking@cdph.ca.gov to report delays.

7.    Specific licensed waste management operations reporting scenarios.

Scenario A.    I am a medical licensee (e.g., hospital, nuclear medicine clinic or office) authorized to use and dispose of radioisotopes, with half-lives less than 120 days, by decay in storage for later disposal as regular trash. I DO NOT ship LLRW, either directly or indirectly by a licensed LLRW broker, for disposal at the licensed disposal facilities. Would I have to file an annual report?

 Yes, but only for the LLRW stored for decay as of December 31 of the reporting year.

 Scenario B.    I am a cardiologist licensed for nuclear cardiology procedures provided by a mobile service and all the LLRW generated during patient treatments are transferred to the mobile service for disposal. Would I be required to file an annual report?

No, you are not required to file an annual report.

 Scenario C.    I have a small nuclear medicine program. I return all unused radioactive dosages and contaminated materials to the nuclear pharmacy. I do not ship LLRW or hold radioactive material for decay in storage. Would I be required to file and annual report?

No, you are not required to file an annual report.

 Scenario D.    I operate a clinical laboratory using RadioImmuno-Assay kits containing iodine-125 and/or 131 and I am authorized to dispose of the kits by decay in storage for later disposal as regular trash. In addition, I DO NOT ship LLRW, either directly or indirectly by a licensed LLRW broker, for disposal at the licensed disposal facilities. Would I be required to file an annual report?

Yes, but only for the LLRW stored for decay as of December 31 of the reporting year.

Scenario E.    I am a licensee who is authorized to use portable gauges containing radioactive sealed sources. I ONLY transfer the sealed sources to the licensed gauge manufacturers for re-sourcing without shipping the sealed sources, as LLRW, either directly or indirectly by a licensed LLRW broker, for disposal at the licensed disposal facilities. Would I be required to file an annual report?

No, you are not required to file an annual report.
 

Scenario F.     I am licensed to use radioactive sealed sources in industrial radiographic devices for non-destructive testing. I ONLY transfer the sealed sources to a licensed industrial radiographic device radioactive source manufacturer for re-sourcing, without shipping the sealed sources as LLRW, either directly or indirectly by a licensed LLRW broker, for disposal at the licensed disposal facilities. Would I be required to file an annual report?
No, you are not required to file an annual report.

Scenario G.    I am a research laboratory and/or a biotech firm that is authorized for radioisotopes with half-lives less than 120 days to use and dispose of radioactive material by decay in storage for later disposal as regular trash. I DO NOT ship LLRW, either directly or indirectly by a licensed LLRW broker, for disposal at the licensed disposal facilities. Would I have to file an annual report?

Yes, but only for the LLRW stored for decay as of December 31 of the reporting year.


8.    What are the annual reporting requirements for generators who have LLRW in storage that has not been characterized sufficiently to provide the required information?

Licensees are required to maintain an understanding of the radioactive materials under their control.  If the stored LLRW is not sufficiently characterized, please email LLRWtracking@cdph.ca.gov to explain the delay in reporting.

 

Additional Questions

9.    Who may a generator contact to request clarification regarding the Health and Safety Code section 115000.1 requirements?

Generators may either email questions to LLRWtracking@cdph.ca.gov; contact Eric Pulley at 916-440-7966; or contact your local State or County inspection office, as shown below:

OfficeContact NumberContact
RHB ICE South(714) 524-1203Donald Oesterle
RHB ICE North(510) 620-3417Nika Hewadikaram
RHB Sacramento(916) 440-7902Rajiv Mishra
LA County(213) 351-7387Jeff Day
San Diego County(858) 694-3616Ron Yonemitsu
LLRW Tracking Program(916) 440-7966Eric Pulley

 


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