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Waste Generator Disposal Guide

Generators of commercial low-level radioactive waste (LLRW) seeking to utilize the Texas Compact Waste Disposal Facility (CWF) are required to receive advanced approval prior to placing any shipment of LLRW in transit. No shipment may be accepted for disposal unless advance notification has been provided and the waste shipment has been inspected by the TCEQ. A summary of the steps for disposal have been developed to help guide waste generators through the required documents and approval prior to disposal of commercial LLRW in Texas.

Overview of Disposal

A TCEQ resident inspector must inspect every waste shipment and manifest received at the CWF for proper classification and characterization prior to waste acceptance. Waste profiles must be established and approved by the CWF operator, Waste Control Specialists LLC (WCS). For waste intended for disposal at the CWF, waste acceptance is completed with the final approval of the specific waste shipment by the executive director’s resident inspector. Waste must meet the Waste Acceptance Criteria (WAC) contained in Attachment C to the WCS LLRW disposal license, R04100.

Each shipment of LLRW destined for the CWF 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, and the requirements of the R04100 license. All waste shippers and transporters wishing to transport LLRW to the CWF 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. For additional information, see the DSHS webpage for LLRW Shipper and Transporter RegistrationsExit the TCEQ.

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, to export the waste, between the waste generator and the TLLRWDCC. The TLLRWDCC applications for importation and exportation of LLRW can be found on the TLLRWDCCExit the TCEQ webpage.

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Summary of Steps for Disposal

    1. Confirm that waste intended for shipment meets the requirements found in the R04100 license, including the WAC in Attachment C.
    2. If not a Texas or Vermont waste generator, obtain an approved agreement for import with the TLLRWDCCExit the TCEQ. For waste generated in Texas or Vermont destined for disposal outside the Texas Compact, the generator must obtain an approved agreement for export with the TLLRWDCC.
    3. Receive waste generator (shipper) and transporter (carrier) registration approval from DSHSExit the TCEQ
    4. Approval of waste profile from WCSExit the TCEQ prior to planned shipments to the CWF.
    5. Waste generator schedules shipment with WCS.
    6. Waste generator provides notification to TCEQ and DSHS of intended shipment (TCEQ Form and Instructions-20225)
    7. Waste generator confirms that the waste has been successfully received and disposed.

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Import Applications

Title 31, Texas Administrative Code, Subsection 675.23(f) 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 TLLRWDCC, WCS, and the TCEQ, by electronic mail and by UPS or FedEx to the following addresses. 

Texas Low-Level Radioactive Waste Disposal Compact Commission
Mailing Address:
Texas Low-Level Radioactive Waste Disposal Compact Commission
919 Congress Avenue, Suite 830
Austin, Texas 78701

Email: administration@tllrwdcc.org
Phone: 817-454-3142

Physical Address if necessary:
919 Congress Avenue, Suite 830
Austin, Texas 78701

Texas Commission on Environmental Quality
Mailing Address:
Radioactive Materials Division
Attn: Ashley Forbes, Deputy Director
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
Attn: Ashley Forbes, Deputy Director
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: Kelly Scruggs
17103 Preston Road, Suite 200
Dallas, TX 75248

Email: DL_WCS_Importation@wcstexas.com
Phone: 682-503-0030
Fax: 214-853-5720

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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 (5) days prior to the date proposed for waste shipment. Fill out the forms listed 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 WCS.

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 the 5-day advance notice requirement.

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Uniform Low-Level Radioactive Waste Manifest Forms

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

Instructions for completing NRC's "Uniform Low-Level Radioactive Waste Manifest" can be found in NUREG/BR-0204, Rev. 3, June 2020Exit the TCEQ.

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TCEQ Waste Shipment Verification Form

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Terminology

Listed below are commons terms used interchangeably by TCEQ, DSHS, TLLRWDCC, and the NRC.

TCEQ DSHS TLLRWDCC NRC MANIFEST
Generator Shipper Generator
Small Generator Generator Small Generator Generator
Consignee Disposal Operator Disposal Operator Consignee
Transporter Transporter Shipper Carrier
Host State Texas Host State Texas
Party State Vermont Party State Vermont
Compact Waste Disposal Facility (CWF) Texas Compact Facility Texas Compact Facility Commercial Waste Disposal Facility
Land Disposal Facility Texas Disposal Facility Texas Compact Disposal Facility Disposal Facility
Low-Level Radioactive Waste (LLRW) see R04100 Low-Level Radioactive Waste (LLW) see 10 CFR §62.2 Low-Level Radioactive Waste (LLW) see 10 CFR §62.2

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Contact the Radioactive Materials Division if you have any questions.

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