OSWER DIRECTIVE  ^9487.00-3
       'I         UNITED STATES EN VIRONMEN T AL PROTECTION AGENCY

\55Zrfr*                     WASHINGTON, O.C. 20150
                                                              . '• -c OF
                                                              ••') ••V3.-.-*--NCY RESPONSE
 AUG I 8 )§81


MEMORANDUM


SUBJECT-:-  • Jo-i-n-t-•N-RG-B'PA—Gtti-d«H*c6-o»--a—Corvcep-feual- Design Approach
          tor Commercial Mixed  Low-Level  Radioactive and Hazardous
          Waste Disposal Facilities  — Action Memorandum

FROM:     Marc i a E. Williams, Director p #A-~
          Office of Solid Waste         {

TO:       Waste Management  Division  Directors
          Regions  I-X


     Attached is a guidance document entitled "Joint NRC-EPA
Guidance on a Conceptual Design Approach  for Commercial Mixed
Low-Level Radioactive  and Hazardous  Waste Disposal Facilities."
The document was developed  in concert with the Nuclear Regulatory
Commission  (NRC) primarily  to aid  States  and compacts in designing
mixed waste land disposal facilities that satisfy the regulatory
requirements of both Agencies.   The  document highlights two
requirements often cited by the regulated community as being in
conflict, namely,  EPA's double  liner/leachate collection and.leak
detection systems  and  NRC's requirement that waste not come in
contact with liquids.  The  design  presented in the attached
guidance accommodates  these and other land disposal requirements
in  an above ground tumulus  which with only minor modifications
could be placed below  grade.

     This document constitutes  the last in the series of three
guidance documents originally slated for development by EPA and
NRC addressing mixed waste  issues  of national concern.  However,
both EPA and NRC are committed  to  providing further guidance not
only to the Regional Offices but to States, compacts and other
members of  the regulated community as needed.  Therefore, I
encourage you to bring to our attention those issues which you
believe are generic and  may require additional guidance to
facilitate  implementation of the mixed waste program.

Attachment

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                                          OSWER  DIRECTIVE  #9'487.00-3
                                 AUG -3   I98T
TO THE STATES, COMPACT REGIONS, AND ALL NRC LICENSEES

SUBJECT:  JOINT NRC-EPA GUIDANCE ON A CONCEPTUAL DESIGN APPROACH FOR COMMERCIAL
          MIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS WASTE DISPOSAL FACILITIES


Under the Resource Conservation and Recovery Act (RCRA), the U.S. Environmental
Protection Agency (EPA) has jurisdiction over the management of solid wastes
with the exception of source, byproduct, and special nuclear material, which
are-..r-eguI.a.texiJ3LVt> theOLS^JIucIeajE. Regulatony^CommJs-siorv (NRC) under the Atomic
Energy Act (AEA).  Low-Level Radioactive Wastes (LLW) contain source,
byproduct, or special nuclear materials, but they may also contain chemical
constituents which are hazardous under EPA regulations promulgated under
Subtitle C of RCRA.  Such wastes are commonly referred to as Mixed Low-Level
Radioactive and Hazardous Waste (Mixed LLW).

Applicable NRC regulations control the byproduct, source, and special .nuclear
material components of the Mixed LLW (10 CFR Parts 30, 40, 61, and 70); EPA
regulations control the hazardous component of the Mixed LLW (40 CFR Parts
260-266, 268 and 270).  Thus, all of the individual constituents of Mixed LLW
are subject to either NRC or EPA regulations.  However, when the components are
combined to become Mixed LLW, neither agency has exclusive jurisdiction under
current Federal law.  This has resulted in dual regulation of Mixed LLW where
NRC regulates the radioactive component and EPA regulates the hazardous
component of the same waste.

The attached guidance document provides a conceptual design approach for Mixed
LLW disposal facilities.  It has been developed jointly by the NRC and EPA to
assist commercial LLW disposal site operators and State and Regional Compact
regulatory agencies in designing disposal facilities that satisfy both EPA and
NRC regulations for Mixed LLW facilities.  Although EPA is currently in the
process of promulgating regulations that further define the technical
parameters for the leak detection, leachate collection, and double liner
systems, affected parties may proceed to develop designs for disposal units
that will accept Mixed LLW in accordance with existing regulatory requirements.
Owners and operators should, however, keep abreast of developing EPA.
regulations in this area.  The attached guidance is based on NRC and EPA
regulations in effect on August 1, 1987.

The attached guidance presents a conceptual design approach that meets EPA's
regulations covering minimum technology requirements for liners and leachate
collection systems, and NRC's requirements for minimization of contact of waste
with water, while also assuring long-term stability and avoidance of long-term
maintenance which are required by both agencies.  The concepts proposed in this
document are presented as general guidance; specific design details are
expected to be complementary to particular site conditions, so that a license
application will have to address site characteristics and their relationship to
a proposed design as well as the details of any engineered portion of the
facility.  The application of this guidance will not affect the requirements
for waste disposal facilities to comply with all applicable NRC and EPA
regulations.

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                                          OSWER  DIRECTIVE  #9487.00-8
The attached guidance should permit licensees to develop  safe  and  effective
designs for disposal of Mixed LLW that fully meet the regulatory requirements
of both agencies.  Depending on the particular type of conceptual  design
selected by a licensee, EPA may_ permit variances to the requirements  for  double
liners and leachate collection systems.
                                        Sincerely,
                                        HUj^h/L. Thompson,/r.,/effector
                                        Orfcrce of Nuclear Mats
                                          Safety and Safeguard
                                        U.S. Nuclear Regulatory Commission
                                           Winston Porter
                                         ssistant Administrator
                                        Office of Solid Waste
                                          and Emergency Response
                                        U.S. Environmental
                                          Protection Agency
 Enclosure:
 As  stated

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                                          OSWER  DIRECTIVE  #948/.UU-8
          JOINT NRC-EPA GUIDANCE ON A CONCEPTUAL DESIGN APPROACH FOR
             COMMERCIAL MIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS
                           WASTE DISPOSAL FACILITIES


Introduction

The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA)
requires that the three operating low-level radioactive waste (LLW) disposal
facilities remain available through-1992v  By that time, all states and compact
regions are required to assume complete responsibility for LLW disposal.  Both
existing^and new disposal facilities may.receive commercial mixed low-level
radioactive and hazardous waste (Mixed LLW), which is regulated by the~U.'S.
Nuclear Regulatory Commission (NRC) under the Atomic Energy Act (AEA), and by
the U.S. Environmental Protection Agency (EPA) under the Resource Conservation
and Recovery Act (RCRA).  Mixed LLW is defined as waste that satisfies the
definition of LLW in the LLRWPAA 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 LLW to exhibit any of the hazardous waste characteristics identified in
Subpart C of 40 CFR Part 261.  To assist in applying this definition, NRC and
EPA issued joint guidance entitled "Guidance on the Definition and
Identification of Commercial Mixed Low-Level Radioactive Waste and Answers to
Anticipated Questions" on January 8, 1987.

This jointly developed NRC-EPA guidance document presents a conceptual design
approach that meets the regulatory requirements of both agencies for the safe
disposal of Mixed LLW.  Other designs, or variation of the proposed design
concept may also be acceptable under the requirements of both agencies and will
be reviewed on a case-by-case basis as received.

EPA regulations in 40 CFR Part 264, Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities, Identify the
design and operating requirements for owners and operators that dispose of
hazardous waste in landfills [264.300 to 264.317].  These regulations involve
requirements for the installation of two or more liners and a leachate
collection and removal system (LCRS) above and between the liners to protect
human health and the environment.  Exceptions to the double liner and leachate
collection system requirements are allowed, 1f alternative design and operating
practices, together with location characteristics, are demonstrated to EPA's
Regional Administrator to be equally effective in preventing the migration of
any hazardous constituent into the ground water or surface water.

NRC regulations in 10 CFR Part 61, Licensing Requirements for Land Disposal of
Radioactive Waste, indicate that long-term stability of the waste and the
disposal site require minimization of access of water to the waste [61.7(b)(2)]
and that the disposal site must be designed to minimize, to the extent
practicable, the contact of water with waste during storage, the contact of
standing water with waste during disposal, and the contact of percolating or
standing water with wastes after disposal [61.51(a)(6)j.  The primary objective
of the above NRC regulations is to preclude the possibility of the development
of a "bath-tub" effect  in which the waste could become immersed in liquid

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                                         OSWER DIRECTIVE  #9487.00-8
(e g   from infiltration  of  surface water runoff) within a disposal unit below
grade with a low-permeability  bottom  surface.


document   ll not affect the requirements for licensees  of waste disposal
facilities to comply with all applicable NRC and EPA regulations.

Conceptual Design

Sketches and a brief discussion of the design considerations  for an above grade
disposal unit are provided.  This design concept has been developed Primarily
to  demonstrate the integration of EPA's regulatory requirements for two  or more
l?ners  fndt leachate collection ..system above and /^VnSThe'waste  be
reflations of the NRC that  require the contact of water with tne  waste  oe
minimized?  In addition, the design concept fulfills the need under both
agencies' regulations to assure  long-term stability and minimize  active
maintenance after site closure.

 in +MC annroach the Mixed  LLW  would be placed above the original ground
 suVfSce inPa tSmulus that  would  be blended  into the disposal  site topography.
 IchemSic dltails of some  of the principal  design features of an  above grade
 Mixed LLW disoosal  unit  are  provided  in  the, sketches accompanying this guidance
 document!  F gSre  1 2epi?ts  the  three dimensional overall view of a conceptual
 Mixed ILW disposal  unit; Figure  2 provides  details of the perimeter berm,
 linen,: and leachate collection  system;  Figure  3 presents a cross-sectional
 view of the covered portion of the disposal  unit; and Figure 4 describes the
 final cover system.

 In the overall view of the Mixed LLW  disposal  facility,  the double liners and
  eacSate conection and removal  system are  installed bef "^ yTj—Jft*
 thP Mixed LLW: and the cover system is added at closure.  The  lea* aetecnon
 lank ad leachate collection tank are encircled by  a berm that controls surface
 water  ruUff frw precipitation that would  fall directly on  the waste faciity
 siteT  The drainage pipes in the upper primary collection system  would  co   ect
 anv leachate that could possibly develop above the  top  flexible membrane liner
 tnd telw the emplaSed wastl.  Any leachate collected would  drain through the
 p?pes  tS the pHmaS leachate collection tank where the leachate  would  be
 tested and treated/if required.  Any leachate collected by  the  lower leachate
 collect^ anl  removal system would drain to the ^jj  detection  tank   ^he
 rfpvelonment of  sicmificant  amounts of leachate from the solidified waste aizer
 cl^u?e^s not  lnt?cipSe5.  This is because the closure requirements provide
 that  the cover  must be  designed^ and constructed 1) to  prov de long-term
 minimization of water infiltration Into the closed disposal  facility, £.) to
  funSion wtth minimum maintenance, 3) to promote drainage and minimize  erosion,

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                                          OSWER DIRECTIVE #9487.00-8
and 4) to have a permeability less than or equal to the permeability of any
bottom liner system.  It is anticipated that the area shown on Figure 3 between
the slope of the final cover and the run-on control berm, where the tanks are
located, would be regraded and the tanks removed at the end of the post-closure
care period (normally 30 years) when leachate development and collection is no
longer a problem.

Figure 2 provides the general details required by EPA regulations for the
double liner and. leachate^coJJ.ectioru and renuxv.a.1-.systenu.  The perimeter berm
for leachate runoff control Would assure that all leachate is collected'below
the waste and safely contained and transported through the drainage layers and
pipes to the tanks located outside the final cover slope.  NRC's regulations
requiring minimizing contact of the waste with water are fulfilled by requiring
the waste to be placed above the level of the highest water table fluctuation
and above the drainage layers where leachate would collect.  The bottom
elevation of the solidified Mixed LLW would be required in all instances to be
at elevations above the top of the perimeter berm.

In Figures 3 and 4, the design concepts for the final  cover over the solidified
waste zone and the perimeter berm are presented.  The actual zone for placement
of solidified Mixed LLW may consist of different options, depending on the
licensee's selection.  Options that would be acceptable include use of stable
high integrity waste containers (HICs) that have the spaces between containers
filled with a cohesionless, low compressible fill  material or placement of the
waste in an engineered structure, such as a reinforced concrete vault.  A cover
system over the waste that would be acceptable to the EPA and NRC is shown in
Figure 4.  The cover system would consist of (1) an outer rock or vegetative
layer to minimize erosion and provide for long-term stability, (2) a filter and
drainage layer that transmits infiltrating water off of the underlying low
permeability layers, (3) an impervious flexible membrane liner overlying a
compacted low permeability clay layer, and (4)  a filter and drainage layer
beneath the compacted clay layer.  If the solidified waste zone does not
consist of an engineered vault structure with a top roof,  an additional
compacted clay layer should be placed immediately above the emplaced waste to
direct any water infiltration away from the waste zone.   Mixed LLW that
contains Class  C waste as designated by NRC's regulations  would need to provide
sufficient thickness of cover materials or an engineered intruder barrier to
ensure the required protection against inadvertent intrusion.

Variations on the above described design approach  may  Include placement of the
Mixed LLW in an engineered reinforced concrete vault,  a steel  fiber
polymer-impregnated concrete vault, or double-lined high integrity containers
that are hermetically sealed.  If proposed by license  applicants, these
variations would be reviewed by both the EPA and NRC on a  case-by-case basis to
evaluate their acceptability and conformance with  established Federal
regulations.

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                                          OSWER  DIRECTIVE  #9487.00-8
For questions related to NRC regulations and design requirements, contact:

Dr. Sher Bahadur, Project Manager
Division of Low-Level Waste Management.
  and Decommissioning
Mail Stop 623-SS           	'
U.S. NucVearHtegtrhartory-'eoinirTSSTcnr---   • •
Washington, DC  20555

Facility specific questions, permitting requirements, variances and other
related concerns should be addressed to either the EPA Regional office or State
agency authorized to administer the mixed waste program as appropriate.  For
general questions related to EPA  regulations and design requirements, contact:

Mr. Kenneth Skahn, Senior Engineer
Waste Management Division
Mail Stop WH-565E
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC  20460

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            OSWER  DIRECTIVE  #9487.00-8
                                         FINAL COVEII
                                                               R&MOVAl
                                                         LEACHATE
                                                           COLLECTION
                 LCACIIATE COLLECTION MANIFOLD
          LEACIIAIE COLLECTION TANK
 fctTECTlOM
- MlXtD  WKSTE.

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                                 OSWER  DIRECTIVE #9487.00-8
                                                  SEPARATIOH TO ASSURE.
                                                  V.EJ\CH/VTE.  FLOW IHTQ LCRS
                SOUDlFltb
                           BOTTOM OF
                                                  HEACMKTE RUNOFF CONTROL
TOP LINER (FLEXIBLE MEMBR/VNE LINER -FML>
              DETECTION, tQUUECTloN ^^ ___
          REMOVE SYSTEM
      BOTTOM LINER (COMPOSITE
           COMP/\CT£D CLKi
                   UNSATURATIO SOIL
                                                      STABLE FOUNDKTION
      compacted claij
 «nr>»n\»n\)in 3 -f «et iv, -H>icKness and Vmve
 o    rlic conducfixlifij Us* ^
FIGURE Z- D6UBUE  UHER
                                             V.EACHKTE  CQLLECTIOH SYSTEM

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                                    OSWER DIRECTIVE #9487.00-8
                     R6GRKDED  FOLLOWING
               POST-CLOSURE  CW?E. PERlOO
                      Sttindords)
                                                                     FINM. COVER
RUN-OH
 COHTBpL
       PERIMtTER
        BERKA fOR
       LEAiCHATE
        RUNOFF
         CONTROL
                                                                                        I
       CONTROL BERM

GROUND WATER
                             3-  CROSS -SECTiOHM. M\E\M ^-^

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                                OSWER  DIRECTIVE #9487.00-
                                                                               FML
      C010FF
 POST-CLOSURE CfSRE
LCfcS  GovxecTiod
  1>*TECTK)O P»PE
                                                                                  TO
                                                                                FLOW INTO LCR
                        F\6URE  4 - V^Stfc COVER  SVSTEM

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                                                              OSWER  DIRECTIVE  #9487.00-8
   24504
   ENVIRONMENTAL PROTECTION
   AGENCY
   (FRl-3041-31

   State Authorization To Regular* the
   Hazardous Components of
   Radioaetlvt Mixed Wastts Under the
   Resource Conservation and Recovery
   Act

   AGINCY: Environment! Protection
   Agency.
  ACTION: N'otice.

  SUMMAMV: The En\ironmental Protection
  Agenc>
Federal Register / Vol. 51. No. 128 / Thursday. July 3. 1986 /  N'ctices
  noi.ce thai in order to obtain and
  maintain authorization to administer
  and enforce a hazardous waste program
  pursuant to Subtitle C of the Resource
  Conservation and Recover} Act
  (RCRA). States must have authority to
  regulaie the hazardous components of
  "radioactive mixed wastes".
  "Radioactive mixed wastes" are wastes
  that contain hazardous wastes subiect
  to RCRA and radioactive wastes subject
  to the Atomic Energy Act (AEA).
  o*Tf : States which have received EPA
  authorization prior to the publicity date
 of this N'otice must, within one year of
 the publication date of this notice (two
 years if a State statutory amendment is
 required) (i.e.. by July 3. 1987 and July 3.
 1988). demonstrate authonty to regulate
 the hazardous components of
 radioactive mixed wastes. States
 initially applying for final authorization
 after July 3. 1987 must incorporate this
 provision in their application for final
 authorization.
 *OW PUHTMfll INPONMATION CONTACT:
 Denise Hawkins. Office of Solid Waste
 (WH-S63-B). U.S. Environmental
 Protection Agency. 401  M Street SW..
 Wdshington. DC 20460. (2021 382-2210.
 SUPM.I MffMTAHY INFOMMAT!OM:

 A. Authorization of State Hazardous
 Waste Programs
  Section 3006(b) of RCRA provides that
 Sidles may apply to EPA for
 authorization to administer and enforce
 a hazardous waste program pursuant to
 Subtitle C of RCRA. Authorized State
 prjgrams are carried out :n lieu of the
 Federal program. However. EPA :s
authorized to implement the Hazardous
                 and Solid Waste Amendments to RCRA
                 (HSWA) (Pub. L 98-618) in autnonzed
                 States until those States revise their
                 programs to incorporate the HSWA
                 requirements and receive EPA
                 authorization to implement HSWA.
                 Requirements for obtaining
                 authorization are set forth m 40 CFR
                 Part 271. To date. 41 States have
                 received final authorization (not
                 including HSWA).

                 B. Regulation of Radioactive Wastes
                  Section 1004(27) of RCRA excludes
                from thejiefinition of "solid .waste.'.'...'..
              ' ''""source, "special nuclear or byproduct
                material as defined by the Atomic
                Energy Act of 1954. as amended (AEA)
                (68 Slat. 923)." Since "hazardous waste"
                is defined by section 1004(5) as a subset
                of "solid waste", "source, special
                nuclear and byproduct material" are
                exempt from the definition of hazardous
                waste and thus from the Subtitle C
                program.
                  W'hile source, special nuclear and
                byproduct material are clearly exempt
                from RCRA. the extent of the statute's
                applicability to wastes containing both
                hazardous waste and source, special
                nuclear or byproduct material has been
                les evident. The question of which
                wastes are encompassed by the term
                "byproduct material" has a'lso been the
                subjecu of some controversy. We note
                that the definition of byproduct material
                is currently the subject" of-rulemaking by
                the Department of Energy (DOE). (50 FR
               45738. November 1,1985).  '
                 Given the lack of clant'yo'ii this issue.
               EPA did not previously require as a
               condition of State authorization that the
               State have regulatory authority over the
               hazardous components of radioactive
               m;xed wastes. In authorizing States.
               EPA did not inquire inwSfate authonty
               over the hazardous components of
               radioactive mixed wastes and made no
               determination of whether States had
               authority over such wastes.
               Accordingly, the Agency has taken the
               position that currently authorized State
               programs do not apply to Tadioictive
               mixed wastes.
                 Thus, radioactive mixed wastes are
              not currently subject to.Subtitle C
              regulations in authorized States.' EPA
              has now determined that wastes
   containing both hazardous was'n a--
   radioactive waste are jubtec; to •--'"
   RCRA regulation.
     Today, we are hereby pub.ish.ra
   notice that, pursuant to 40 CFR :::  9
   (which requires State programs V
   regulate all wastes controlled ur.za- 40
   CER Part 261). Radioactive mixed w »«•
   are to be part of authorized State
   programs. States that already hav»
   authorized programs must revise t^-r
   programs (if necessary) and must a?"!-
  for authorization for hazardous
  components of radioactive mixed
  wastes. Slates-must demonsrratrro  the
  appropriate EPA Regional Admin-st-i'-i
  tnat their program applies to all
  hazardous waste even if mixed with
  radioactive waste. This demonstrate
  must be made within one year of the
  publication date of this notice.1 States
   1 Th« exception to ihu n ,r i!.» .Jje 3f cpA 4
 HSWA authorities m author-iea Suits EPA c*.i
 use itt HSWA authorities 10 supplement in
 authorized Suit s authority ov«r RCRA-renla—i
t units. Undtr f MMIuJ. EPA cm laimiy issue *
 permit with the State tnd impost corrective t:r-"t
 requirements on hazardous waste management
 units snd solid wastt nunaftmtm um'i ;iwmi »• „•
 facilities th«t eomnn units subteet to RCRA
 Although hazardous eompontms if Mdio«e:u*
 miztd wants art not RCRA-rtfui«tcd under
 authonstd Statt RCRA programs, mdioau.ti
 mtitd waste will bt eonsidtrtd to bt a soi;.i
 wastt" for purposes of corrective tenon t- «u.'. J
 waste management units. Tht Federal deftn.-t.'.- .«
 "solid wastt" is to bt ustd in dtttrmmmf »h.--
 units art swmu's. because Suit definitions »«-<
 not seniimixtd. Therefore, in ordtr >o obtain
 authorization for eorrtetivt tenon Sutti T.JI
 obtain'authorization for thttr definition of iu' •.'
 watit. which may not exclude hazardous
 components of radioactive mi»«d »4n#t Btti.i*
radtotetive mixed waste is considered a soiu »«,-,.
under tht Ftdtral RCRA proiram jn-.is tar.-* .- -a
radioactive mixed wattes are iwmu t and «.-e
subitci to corrective tenon .'there u «no-k«» -j- •
requirni a RCRA permit at the f*c:ni>  RCR.A
enforcement activities also ippl>
  1 EPA is not promuifating a refuUnon :o » ores.oui a-. >
we believe n n appropriate to provide the tirr» '
allowed by 40 CFR ir\ ::;e»:i for S-are srot-.m
modifications to conform to regulafon ch*.-j-«
Note that EPA has propoicd  to a.-rend W CFS
271.21 to allow States am:l |ulv 1 of «
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                                                     OSWER  DIRECTIVE  #9487.00-3
                       Federal Register / Vol. SI. No. 128 / Thursday July 3. 1986 / Notices
                                                                      24302
initially applying for f"nt' authorization
one year after the publication date of
this nonce must make this
demonstration in (heir initial'
application.
  In most cases, this will reqxre aniy an
interpretse statement BV the 5sa:e
Attorney General, since most Stares
have the same exception to the
definition of "solid waste" as that
contained in section 1004(2"] of RCRA.
Some States, however, may require
stattuozy amendments~m.ocdex.to-., •
regulate*the hazardous components of
radioactive mixed wastes. Such States.
if already authorized, must revise tneir
programs within two years of fW.e
publication date of this not;:e Sta'es
miitalh applying that need a statutory
amendment w:!l have to obtdin the
amendment before subrouting an
application for final authorization
  In order to demonstrate recuia'ion of
the hazardous components of
radioactive mixed wastes. States should
submit to the appropriate Regional
Administrator a copy of all applicable
statutory and regulatory provisions. pi-.s
a statement by the State Attorney
General to the effect that the Slate s
hazardous waste program applies to
wastes containing both hazardous v\as'e
and radioactive waste as defined b>  :ne
AEA. If an agency other than the
authorized hazardous waste agencv v\,i;
implement the radioactive mixed wastes
prosramrthe-authorrzatfon' application
must include a description of tnc
agency's functions (see 40 Cr'R Z"1 6ibM
                                    ' ' '
between that agency and the authorized
hazardous waste agency, describing the
roies and responsibilities of each.
  The DOE has proposed an ir.terprfve
det'.nmon of the t»rm "byproduct
masenal" (53 FR 4S"3o. Nove-rr.er l.
1983). and :s now evaluating ;>ubiic
comment Pending clarification of tnis
issue, this matter will be aaaressed on a
case-by-case basis.
  Y\ e disc note that section 1006 of
RCRA precludes any regulation bv EPA
or a Sldie which :s inconsistent wi»n the
requirements of the  Atomic Eneigy Act.
 EPA and 'he S-afe mav. -ra-. ''j.-fe  :n ny gr;mt of access to cLss. ;".«•.]
 tnforr.-.ation under the provision* of
 RCRA.
   D*:e JO. !38C
 | Winston Porttr.
 •IU.INO COOC (MO-10-M

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                                                I
                              OSWER DIRECTIVE #9487.00-8
                        ATTACHMENT 2
              UNITED STATES ENVIRONMENTAL PROTECTION
                        WASHINGTON O C 2
                                             AGENCY
 MEMORANDUM


 SUBJECT:fV


FROM:


TO:
                         JUN 2 9 '937
                                            ,._ .
                                            5	
                      rter
           Assistant nfaministrator
                    .
         Regions I -  '<
      This memorandum is i
 surrounding the  i
                             cr,
                                     any unce^tainty
 (51
                                 Cinai
                                                rule
           the             u=sn
 be  considered byproduct maerlal " -h. ^f ,w«"»
 pretative rule^aking  is that all    '"
 contain a Us
                                           »trean» »m
                                            h-his int:er-
                                             "h    ei
                                                   :his
 conm"ssi'r^i%c°^£ni=Jfp^
 -.«. t..u.i .^i.i,^:-™™£ £sr&l.c%;lxiL&2
                                         n '/19W o
                                                " £?A for
                                               .
                                                S contention
byproduct rule.  AS you know
excluding high-level and tran.ura:
diction.  The proposed exclusion ;
that tr.eir waste .nanagesient o-
to those mandated by RCRA and r»-  ' r*-< =,  i^=7 a             	
regulatory duplication was inconsistent?  Jc-or^nn ^iM l™tilat
tas< force was commissioned in Nov^ber  1986 ^^^' Cn'  MEWS
information on the merits of DOE 's'aslert ion   v  ^ac^e^ technical
however, that past p-actic«s wer«  ^ *  t J?^ °U  shou1^ note,
nor were they ?eviewe"cI  by the JHk^r Ci"d?d ln the DOE -Dr°P°
visits to select D^E facilities        S dUri"g Subsequent  si?e

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                                  OSWER DIRECTIVE #9487.00-8


                               -  2 -
                           I

     In March of this year, the  MEWS  task  force  issued  its  final
r^oort which indicated that to a Large  extent,  DOE  manager?eat  of
hiah-level and transuranic :mixed wastes were  equivalent:  or  superior
to RCRA requirements.  Certain areas  of their waste m.anageTient
operations, however, such as ground-water  monitoring  and chemical
analysis of wastes were clearly  deficient.  To  date,  no  category
of DOE mixed waste has been. exempt.ed....f rom  RCRA  regulation as  a
result of the findings of the MEWS task force.

     Thus-»-all--DOS- wrxer?~wa'sfg5-.are''subject to  RCRA regu-laticms-
independent of the nature of the radioactive  component.   Therefore,
Regions which are administering  RCRA  programs in unauthorized
States should, in accordance with priorities  established in the
RCRA Implementation Plan, be implementing  the program at DOE
facilities.  Secondly, those Regions  where States have  been
delegated mixed waste authority  should  make it  clear  that their
authorization includes all 'DOE mixed  wastes.  These mixed wastes
may contain high-level, low-level, or transuranic radioactive
constituents.  Third, you should continue  to  encourage  States  to
apply for -nixed waste authorization especially  in those  States
with major DOE facilities.

     Headauarters is committed to providing technical;  legal  and
policy assistance to the States  and Regions in  support of efforts
to effect mixed waste reaulation at DOE facilities.   Accordingly,
I will keep you apprised of: any  initiatives taken by  either DQE
and/or EPA Headquarters affecting mixed waste regulation as soon
as they develop.  Specific 'questions  concerr.i-ng mixed wastes
should be-directed to 3etzy Shackleford, OS;;  on  (FTS) 475-9656.

Attachment                         *

cc:  Ken Shuster, OSW
     Chris Grundler, OSWER
     Ray Berubev DOE"

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                                                       OSWER  DIRECTIVE  #94ff7.00-8
Rules and Regulations
                                                                       F«d«Ml

                                                                       Vol. 3i No. 34

                                                                       Friday. May 1. 19
                                 DEPARTMENT OF ENERGY

                                 10 CFR Part 9«2

                                 H»dk»ctlv« WML, Byproduct Mat.**

                                 AOCNCY: Department of Energy.
                                 *cnoic Final rule.
                                 fnn,    DeP*rtm«nt °f Energy ~
                                 (DOE) today is issuing a final
                                 interpretative rule under section leip. Of
                                 the Atomic Energy Act of 1954 (42 U.S C
                                 ..Oil et sec..- hereinafter "the AEA") for
                                 the purpose of clarifying DOFs
                                 obligations under the Resource
                                 n •
                                substances which are also "hazardous
                                waste • within tht meaning of RCRA
                                The effect of this rule is that ail DOE
                                "l10*^8 WMt8 which «• hazardous
                                under RCRA will be subject to

                                m13-^" un,der both 8CRA "«* «h«   -
                                AEA Th,, rule daes not affect materials
                                that are defined as byproduct matenal
                                under s-ction He(2) of the Atomic
                               Energy Act
                                        OATK June 1. 1987.
                               Henry K. Carson. Esq., Assistant

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                                                                                 1

                                                  OSWER  DIRECTIVE  #9*8*7.00-8
    General Counsel for Environment. GC-
    11. Department of Energy. :ooo
    Independence Avenue SW
    Washington. DC 20585. Telephone (202)
           .
    Raymond P. Berube. Acting Director
     Office of Environmental Guidance and
     Compliance. EH-23. Department of
     Ir»r?£ I00° '"dependence Avenue
     SW.. Washington DC 20S85.
     Telephone (202) 586-3680.
   3UPWJMIMTAHY INFORMATION:
   Background

     RCRA establishes a comprehensive.
   regulatory scheme, administered by the
   Environmental Protection Agency (EPA)
   and EPA-authonzed States, governing
   the gener«wn.^raraportatttJnV
   treatment, storage and disposal of
   hazardous waste. Federal agencies are
   required by section 6001 of RCRA (42
   U.S.C. 6961) to comply with the
   requirements of that regulatory scheme
   in the same manner, and to the same
   extent, as any private person or entity.
   L'nder section 1004 of RCRA (42 U.S.C.
  6903). the "hazardous waste" governed
  by RCRA is a subset of the statute's  .
  definition of "solid waste." The
  definition of "solid waste." however
  expressly excludes "source, special'
  nuclear, or byproduct material as
  defined by the Atomic Energy Act."
  Those materials, instead, continue to be
  regulated under the AEA either by the
  Nuclear Regulatory Commission (NRQ

  M The AEA's definitions of the terms
   source material" and "special nuclear
  material * are specific in nature, and
  present no particular difficulty of
  interpretation. The AEA's definition of
  byproduct material." in contest.
  speaks only generally of "any
  radioactive material (except special
  nuclear material) yielded in or made
 radioactive by exposure to the radiation
 incident to the process of producing or
 utilizing special nuclear material." AEA
 section lle(l). 42 U.S.C. 2014(e)(l). The
 lack of specificity in thi« definition.
 coupled with RCRA's exclusion of
 byproduct material from its hazardous
 waste regulatory scheme, has raised a
 question concerning which DOE
 radioactive waste streams, if any.
 should bt considered byproduct
 m"'e"al not subject to regulation under
    between "direct process" radioactive
    waste (i.e. waste directly yielded in. or
    necessary to. the process of producing
    and utilizing special nuclear material)
    and other radioactive waste less
    proximate to the physical process of
    producing or utilizing special nuclear
    material. Under the proposed rule, direct
    process waste, even if it contained
    hazardous material, would have been
    regarded as byproduct material and
    thus would be regulated exclusively
    under the AEA. Any radioactive waste
    other than direct process waste, if it
   contained hazardous material would
   have been considered "mixed waste-
   subject to regulation under both RCRA
   JHrt th a.—A-CA.1...--.. ......
      SuchT'dei,dlspersed in the medit
      such a result, m DOE'rview
    presented substantul legal questions

    ifSHrfe
    a±" SL?!^radiation h«»S,
The Proposed Rule

  On November 1.1985. DOE published
«™,°f of Pr°P°«d rulemaking (SO FR
45708, in which it proposed to adopt an
interpretative rule clarifying RCRA's
applicability to DOE radioactive waste.
Briefly summarized, that proposed rule
would hav« established a distinction
     As DOE noted the Federal Register
   preamble to the proposed rule, the
   legislative history of the AEA provides
   little guidance in interpreting the
   statutory definition of byproduct
   material, and application of the
   definition has not been clarified by
   judicial interpretation. Because the plain
   words of the definition are keyed to the
   process for producing and utilizing
   special nuclear material however! it
   seemed that process must be regarded
   as a critical factor in determining
  fcii8Su .particula,r radioactive material*
  fell within the definition. Accordingly.
  one significant feature of the "direct
  process" approach, as discussed in the
  preamble to the proposed rule, was its
  congeniality with the bare text of the
  statutory definition of byproduct
  material.
   A major consequence of the "direct
  process" approach was the fact that it
  would result in the exclusive regulation
  of all direct process waste under the
  AEA. Just as the legislative history of
  the AEA provides little help in
  interpreting the statutory definition of
  byproduct material the legislative
 history of RCRA is silent on the
 intended effect of RCRA's exclusion
 from its coverage of source, special
 nuclear and byproduct material
 Nevertheless. DOE assumed that that
 exclusion was intended by the Congress
 to be applied to radioactive wastes in
 their real-world configuration. Virtually
 all radioactive waste substances are
 contained, dissolved or suspended in a
 nonradioactive medium from which
 their physical separation is
 impracticable. Accordingly, DOE noted
 m proposing the "direct process-
 approach that unless some radioactive
 waste streams were considered to be
 byproduct material in their mtinty.
 RCRA s exclusion of byproduct material
 might reasonably be perceived to have
httle effect, because RCRA'a application
to a nuclear waste's nonradioactive
medium would appear to entail at least
       ni       rce- •P**a.
    and byproduct material, and general!*
    preempts the State, from SJffiS "J
    hose materials.' It had also been helc
    that when tha radiation and
    nowadiation hazards of a wast»
    containing byproduct material are
    inseparable, regulatory action under tf
  - AEA-preempts the incompatible  '
   exercise of general state nuisanca
   authority over th* waste.* Thes«
   deciiions. read in conjunction wsth
   RCRA s affirmation of state regulation
   as an acceptable, indeed a favored
   alternative to EPA regulation, were
   I1*™9*** °°E " suggesting that an :
   appropriate interpretation of bynreduci
   material would, like tha proposed    1
    direct process" approach, exclude   :
   certain radioactive wasta streams, in
   their entirety, from regulation under
  Development of tha Final Rula
    At thettoie of its publication of the
  f1?°P0i*f "d* °°E made available to
  «•«» public reports provisionally
  identifying which of th* waste streams
  generated at its facilities would bo     ]
  considered "direct process waste"     1
  subject only to AEA regulation under   1
  the proposed rule, and which of those   1
  waste streams would be considered    ''•
  "mixed waste" subject to regulation    :
  under both RCRA and the AEA. DOE
  sought and received public comments on
  those reports, and on the proposed rule

   During the period since the proposal
 was made. -DOE has had the opportunity
 further to review the pertinent legal
 authorities, as well aa to consider the
 comments received, the provisional     '
 waste stream identifications. DOE's
 additional operating experience, and
 related actions taken by other federal
 agencies. Baaed on the  review. DOE is
 today publishing a final rule that adopt*
 a narrower interpretation of byproduct
 material than the "direct process"
 approach that was originally proposed.
 For the reasons set forth below, the final
 rule provides that only tha actual
 radionuclidee in DOE wast* streams
  1 Sw Northwn sum Pomtt Co. ». MHUMMM.
*w r.M imj (MX or. wn». a/jf* «os us, uaT
lian). Stt alto Tula v. Colcindo Pfck. (at*mi
**tt«*di Oou»t 
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                                                                                     [
                                                     OSWER  DIRECTIVE  #9487.00-8

                 Federal Renter /  Vol.  52. No. 84 /Friday. May i.  i987 / Rules and  Regulations
  will be considered byproduct material.
  The nonradioactive components of those
  waste streams, under the final rule, will
  be subject to regulation under RCRA to
  the extent that they contain hazardous
  components.
  Discussion
    The overriding question raised by the
  public comments on the proposed rule
  was whether RCRA's exclusion of
  source, special nuclear and byproduct
  material from regulation under that Act
  was intended by the Congress to exempt
  entire waste streams, rather than
  exempting only the radionuclides
  dispersed or suspended in a waste
  streatnrAj-discussed'above". the" ''" '
  proposed rule woud have treated any
  "direct process" waste as byproduct
  material in its entirety, even if the waste
  contained a nonradioactive chemically
  hazardous component  that would
  otherwise have been subject to
  regulation under RCRA. Thus, the
  characterization of a waste stream as
  "direct process" waste would have
  foreclosed the application of RCRA to
  that stream irrespective of whether the
 associated non-radiological
 environmental hazard was significant.
 In the opinion of many commenters.  this
 was a significant disadvantage to the
 "direct process" approach. In view of
 this concern, some commenters
 suggested that DOE instead adopt an
 alternative interpretative approach that
 would permit the application of each
 regulatory regime to the type of hazard
 that it was designed to  control, i.e. that
 would apply the AEA to ensure
 protection against the radiological
 hazard of this waste, and apply RCRA
 to ensure protection against any
 associated chemical hazard.
  DOE'S operational experience since
 the publication of the proposed rule
 lends support to the concern expressed
 by these commenters. In its efforts	
 provisionally to apply the "direct
 process" approach. DOE found a
 number of instances in which otherwise
 identical wastes were sometimes found
 subject to RCRA. end other times were
 found subject only to the AEA. due
 solely to the wastes' different proximity
 to the physical process of producing and
 utilizing special nuclear material. While
 distinctions of this type are not entirely
 incompatible with the process-oriented
 language employed by the Congress in
 the AEA to define byproducts material.
 DOE has concluded after further
 analysis that the better view of the (aw
 is one that avoids such artificial
 distinctions and that affords the greatest
 scope to the RCRA regulatory scheme.
 consistent with the requirements of the
AEA. SM Legal Envtl. Assistance Found
  v. Hqd$l. 586 F.Supp. 1183 (E.D. Tenn.
  1984J. :>      '::.-"
    As noted in (he foregoing discussion
  and in the preamble to the proposed
  rule, the legislative histories of both
  RCRA and the AEA provide little
  assistance in interpreting either the
  meaning of the term byproduc* material
  or the intended effect of RCRA's
  exclusion of byproduct material from the
  hazardous waste regulatory program.
  The House Committee on Interstate and
  Foreign Commerce, in reporting its
  version of the bill that;ultimately was
  enacted as RCRA. alluded to a 1973 leak
  of radioactive waste from a DOE under-
 .gBMiod. «tocaaa.tank' at Rrehiandr-	
  Washington as an "actual instance {} of
  damage caused by current hazardous
  waste disposal practices." H.R. Rep. No.
  1491. 94th Cong.. 2d Sess.. pt 1. at 17-19.
  feprtntedia 1978 U.S. Code Cong. A
  Admin. News 6238.8254-57. This
  reference is a less than certain
  indication that the Congress viewed
  such radioactive waste at "hazardous
  waste" subject to  RCRA. Unlike RCRA
  as finally enacted, the bill » which this
  House Report accompanied contained
 no provision excluding source, special
 nuclear and byproduct material, thereby
 minimizing the probative value  of the
 Committee's Richland reference in
 construing the statute that was
 ultimately enacted. Nevertheless, the
 Committee's reference should not be
 entirely discounted as evidence :hat the
 Congress in considering RCRA was
 concerned with unregulated hazards
 presented by radioactive waste, even
 though the AEA already provided
 sufficient jegula^ry control over the'
 radiological hazards associated  with
 such waste.
  No court has addressed  the specific
 question whether the entirety of a
 nuclear waste, or only its radioactive
 component is byproduct material.4 The
 decision in Brown v. Kerr-McGee Chem.
 Corp.. supra note 2. clearly holds that
 the States cannot employ their general
 authority to abate nuisances to regulate
 even the nonradiation hazard of a waste
 incompatibly with regulation done under
 the AEA where the radiation and
 nonradiation hazards an inseparable.
 Nothing in that decision, however, is
 incompatible with concurrent regulation.
  > H.R. 14498.94(li Con*. Id SMS. (1979).
  * Two decuioiu havt upheld the authority of ih«
NRCi pr*dK*i«or tftncy. the Atomic Energy
Ccmmmion. to UetaM low level radioactive waete
i« byproduct material. Kama Gammy v. United
Stoin. 02 F 2d 370 {sih Cir. 1981): City of New
Britain v. Atomic Energy Comrn n. MS f.2d MS (O.C
Or. 1S02). In neither cue. however, did the conn
ranch the ipecific queetion whether the tnnraty of
the wane, or only its radioactive component. i«
byproduct material
  by the States or EPA. of the
  nonradioactive component of a nucieai
  waste, subject to paramount
  requirements of the AEA.4
    In this context. DOE notes that at the
  time trie Congress was considering
  RCRA. the Supreme Court very recent!'
  had published  its decision in Tram v   '
  «,°J:°,T,**° Pub>  Inter"« Research Croup
  428 U.S. 1 (1978). That case decided
  whether the Federal Water Pollution
  Control Act.  as amended in 1972,
  applied to source, special nuclear and
  byproduct material discharged into
  navigable waters by govemment-ownec
  production facilities and commercial
  power reactort-regulatetf by tfie'AEA.
  After concluding that the Federal Watei
  Pollution Control Act properly
  construed, did not authorize EPA or the
  States to regulate source, special nuclea
  and byproduct material the Court
  rejected the contention that the Water
  Act contemplated joint regulation of
  source, special nuclear or byproduct
  material effluents. 428 U.S. at 15. Th«
  practical effect of the Court's decision.
  however, was a regime of concurrent
  regulation, by different authorities, of   :
  effluent streams containing both       '
  radioactive and nonradioactive        i
  components. Specifically, tha decision  j
  left EPA and tha States free to regulate. I
  under tha Water Act tha nonradioactiv*
  component of liquid effluents from      ;
 nuclear facilities, while reserving to the '
 NRC and DOE'S predecessor agency all :.
 regulatory authority over the source.   i
 special nuclear and byproduct materials]
 contained in those same effluent       j
 streams.                             <
  The legislative history of RCRA      i
 contains no mention of the Train
 decision. However, the Congress is
 presumed to be aware of decisions of
 the Supreme Court* and in fact
 employed in RCRA the same AEA
 terms, including byproduct material that
 the Court had extracted from the  Water
 Act's legislative history to emphasize in
 its analysis in Train. Thus it is at  least
 equally logical to infer that tha          -
 Congress,  in selecting the AEA terms   1
 emphasized in Train, anticipated a
 similar result under RCRA aa it is to
 posit—as did the proposed rule—that
 RCRA's exclusion of byproduct material
 must have bean intended to exclude in
 their entirety some waste streams from
 regulation under  RCRA.
  In short while  the specific legal
 authorities relied upon by DOE in
 developing the proposed rule appeared
 consistent with the "direct process"
  * Sew dueuMMa of RCHA Mctioo 1008UI. U-SC
MOOtai, infra
  • Gary ». Curtia. 44 UA (3 How. | as, 240 (184SI.

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                                                             OSWER  DIRECTIVE  #9487.00-8
  15940        Fadtral gagiater / Vd. S2. No. 84  /  Friday.  May 1. lOff / Rules mi
  approach, those authorities an equally
  consistent with ma narrower
  Interpretation nrTijpmrinrt ••tin !•! that
  was suggested bf the majority of the
  commenten on  the propped rule, Ufere
 Tmpcrtanlly, DOB is now persuaded
  after farther analysis that the "direct
 process" approach does not reflect the
 betterTiew of tkia law.
   RCRA is a remedial statute. and as
 •uch must b« UbaraHy eaastnad to
 effectuate Out renedial purpose for
 which 51 was scactad.7 Tie m>«»>^
 comprehanaiveaess of RCRA'*
 regulatory schema is evident from the
 Act's legislative history. The principal , ,
 sponsor ofthe legislation in the Senate
 emphasized •hatitTcpresenaed "a major
 commitment of federal assistance to
 state and local .government efforts to
 meet {hazardous and solid waste)
 problems in a comprehensive and
 effective manner." * The House
 Committee on Interstate and Foreign
 Commerce regarded the legislation as
 closing the "last remaining loophole" •
 in a framework of national
 environmental lnws that already
 included the dear Air Amendments of
 1970. the Federal Water Pollution
 Control Act Amendments of 1972. and
 the Safe Drimkinij Water Act
  Moreover, interpretation of RCRA's
 exclusion of byproduct material must
 not focus solely 
  •dual ra4cm*dides in the waste as
  betna «x»tno< from RCRA. Today's final
  rule adopts the same approach for all
  DOE radioactive and chemically
  hazardous waste.
    Accordingly, for purposes of RCRA.
  DOE interprets the teem byproduct
  material to refer only te the radioactive
  component of a nuclear waste. The
  mnradioaetiwe chemically hazardous
  component of the waste will be subject
  to regulation under RCRA.

  Precriuni Mftttari

  -4. Executive On/or 12291

   This rule ba< been reviewed in
  accordance wrA Executive Order 12291.
  The rufo is not classified as a major rule
  because it does not meet the criteria for
  major rules established by that Order.

  B. National Environmental Policy Act

   This rule is an interpretative rate
  intended only to clarify the meaning-of a
  statutory definition. Issuance of the rule
  will have no eBwonmentai impact

  C Regulatory Flexibility Act
  Certification

•   Tho rule will not nave • significant
  impact on a  substantial number of small
  entitle*.

  D. Paperwork Reduction Act of 29OO

   There are  no information collection
  reqniremento in the rule.

  List of Subjocte ia M CFR Part 982

.   Nuclear materials. Byproduct
  material.
   Issued m Washington. DC. April 27.19H?
 I Michaul FuraU.
 Cer,eral Counsml

   In consideration of the foregoing. Part
 962  is added to 10 CFR Chapter III. to
 read as follows:

 PART 982—OYPflOOUCT MATERIAL

 Sec.
 962.1 Scop*.
 962.2 Purpose.
 962.3 Byproduct material.
   Authority: Th« Atomic-Energy Act ui" 19S4
 (42 C'.S C. 2011 et seq.): Energy '
 ReorBdmzation Act of 1974 (42 L'.S.C. SSOl et
sfu I: Department of Energy Organization Act
 [42 C S.C 7t01 et «7.): Nuclesr W^sse Policy
Act | Pub. L. 9r-4zs. 90 Stat. 22011.

 §962.1  Scepv.

   This Part applies only to radioactive
waste sttfaatancas which are owned or
produced by the Department of Energy
at facilities owned or operated by or for

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                                                          OSWER  DIRECTIVE  #9487.00-8
              Federal Refuier / Vol. 52. No. 84  /  Friday.  May 1. 1987 / Rules and  Regulationa
                                                                     15941
the Department of Energy under the
Atomic Energy Act of 1954 (42 U.S.C
2011 tt aeq}. This Part doe* not apply to
substances which an not owned of
produced by the Department of Energy.
  The purpose of this Part is to clarify
the meaning of the term "byproduct
material- under section lle(l) of th«
Atomic Energy Act of 19S4 (42 U.S.C
2014(e)(l)) for use only in determining
the Department  of Energy's obligations
under the Resource Conservation and
Recovery Act (42 U.S.C. 6901 at teg.}
with regard to radioactive waste
substances owned-or produced- by (he**-—
Department of Energy pursuant to the
exercise of its responsibilities under the
Atomic Energy Act of 1954. This Part
does not affect materials defined as
byproduct material under  section lle(2)
of the Atomic Energy Act of 1954 (42
U.S.C 2014(eH2)).

19614 Byproduct material
   (a) For purposes of this Part, the term
"byproduct material*4 means any
radioactive material (except special
nuclear material) yielded in or mado
radioactive by exposure to the radiation
incident to the process of producing or
utilizing special nuclear material.
   (b) For purposes of determining the
applicability of  the Resource
Conservation and Recovery Act (42
U.S.C 0901 et teg.) to any radioactive
waste substance owned or produced  by
the Department of Energy pursuant to
the exercise of its atomic energy
research, development testing and
production responsibilities under the
Atomic Energy Act of 1954 (42 U.S.C.
2011 et seq.]. the words "any radioactive
material." as  used in subsection (a).
refer only to the actual radionuclides
dispersed or suspended in the waste
substance. The  nonradioactive
hazardous component of the waste
substance will be subject to regulation
under the Resource Conservation and
Recovery Act
(FR Doc 87-9883  Filed 4-30-97; 8:48 am]
SUMauuty; The Ust of Marginable OTC
Stocks is -comprised of stocks traded
over-the-counter (OTC) that have been
determined by the Board of Governors
of the Federal Reserve System to be
subject to the margin requirements
under certain Federal Reserve
regulations. The List is published four
times a year by the Board as a guide for
lenders subject to the regulations and
the general public. This document sets
forth additions to or deletions from the
previously published List effective
February 10, 1987 and will serve to give
notice to the public about the changed
status of certain stocks.
 FEDERAL RESERVE SYSTEM

 12 CFR Parts 207,220,221 and 224

 Regulation* a T, U and X; Securities
 Credit Transactions; Ust of Marglnabto
 OTC Stocks

 AOIMCY: Board of Governors of the
 Federal Reserve System.
 ACTION: Final rulr. determination of
 applicability of regulations.
                       19877
ran puff™** INFORMATION CONTACT:
Peggy Wolffnim, Research Assistant
Division of Banking Supervision and
Regulation. (202H4S2-2781. For the
hearing impaired only. Earnestine Hill or
Dorothea Thompson.
Telecommunications Device for the Deaf
(TDD) (202HS2-3544. Board of
Governors of the Federal Reserve
System. Washington. DC 20551.
supetlMCNTANY INRMWATIONS Set forth
below are stocks representing additions
to or deletions from the Board's List of  '
Marginable OTC Stocks. A copy of the
complete List incorporating these
additions and deletions is available
from the Federal Reserve Bankv This
List supersedes the last complete List
which was effective February 10. 1987.
(Additions and deletions for that List
were published at 52 FR 3217.' February
3. 1987). The current LisMncludes those
stocks that meet the criteria specified by
the Board of Governors in Regulations
G. T. U and X (12 CFR Parts 207. 220. 221
and 224. respectively). These stocks
have the degree of national investor
interest the depth and breadth of
market and the availability of
information respecting the  stock and its
iiisuar to warrant regulation in the same
fashion as exchange-traded securities.
The List also includes any  stock
designated under an SEC rule as
qualified for trading in the  national
market system (NMS Security).
Additional OTC stocks may be
designated as  NMS securities in the
interim between the Board's quarterly
publications. They will become
automatically  marginable at broker-
dealers upon the effective date of their
NMS designation. The names ot these
stocks are available at the Board and
 the Securities  and Exchange
Commission and will be incorporated
 into the Board's next quarterly Ust.
   The requirements of 5 U.S.C 553 with
 respect to notice and public
 participation were not followed in
 connection with the issuance of this
amendment due to the objective
character of the criteria for inclusion
and continued inclusion on (he List
specified in 12 CFR 207.8 (a) and (b).
220.17 (a) and (b). and 221.7 (a) and (b).
No additional useful information would
be gained by public participation. The •
full requirements of 5 U.S.C. section 553
with respect to deferred effective date
have not been followed in connection
with the issuance of this amendment
because the .Board finds that it is in the
public interest to facilitate investment
and credit decisions based in whole or
in part upon the composition of this List
as soon as possible. The Board has
responded to a request fey the public and
allowed a two-week delay before the
List is effective.

List of Subjects

12 CFR Part 207

  Banks. Banking. Credit.  Federal
Reserve System. Margin. Margin
requirements. National Market System
(NMS Security). Reporting and
recordkeeping requirements. Securities.

12CFRPart220

  Banks. Banking. Broken. Credit
Federal Reserve System. Margin. Margin
requirements. Investments. National
Market System (NMS Security).
Reporting and recordkeeping
requirements. Securities.

12 CFR Part 221
  Banks. Banking. Credit Federal
Reserve System. Margin. Margin
requirements. Securities. National
Market System (NMS Security),
Reporting and recordkeeping
requirements.

12 CFR Part 224
  Banks. Banking. Borrowers. Credit.
Federal Reserve System. Margin. Margin
requirements. Reporting and
recordkeeping requirements.  Securities.

  Accordingly, pursuant to the authority
of sections 7 and 23 of the Securities
Exchange Act of 1934. as  amended (IS
U.S.C. 78g and 78w), and  in accordance
with 12 CFR 207.21 k) and  207.6(c)
(Regulation Gl 12 CFR 220.2(s| and
220.17(c} (Regulation T). and 12 CFR
221.2(j) and 221.7(c) (Regulation U).
there is set forth below a  listing of
deletions from and additions to the
Board's List:
 Deletions From List

Stocks Removed for Failing  Continued
Listing Requirements
 American Aggregates Corporation
  No par common
 Bio-Mtdicus. Inc.
  Warrants (expire 08-31-88)

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