Conditional Exemption for Storage and Treatment

The EPA conditionally exempts LLMW from some of the RCRA storage and treatment regulations. As mentioned earlier, the radioactive portion of LLMW must be managed as radioactive waste.

For the conditional exemption for storage and treatment of LLMW, the RCRA regulations establish the following:

• The eligibility criteria for the waste
• The conditions that must be met to maintain this exemption
• How a facility could lose the exemption for its waste
• How a facility falls under RCRA when its LLMW is no longer eligible for the exemption
• How a facility may reclaim a lost exemption
• The recordkeeping requirements for this conditional exemption
• The storage unit closure requirements for facilities that have RCRA-exempt waste

If a facility generates and manages LLMW under a single NRC license or under an NRC Agreement State license, then the waste is eligible for this conditional exemption. Note, though, that waste that is shipped to the facility from a facility with a different license number is not eligible for this exemption.

To learn more about RCRA safety standards visit our RCRA Refresher Online Training web page.