Who is regulated by R313-26 and will need a permit to transport waste to the State of Utah for disposal?
Anyone sending radioactive waste to EnergySolutions needs a permit to access the site for eventual disposal of waste.
What materials transported for disposal are regulated by R313-26?
All radioactive waste categories or types are regulated by the Generator Site Access Permit and all radioactive waste generators, waste processors and waste collectors will require a permit to access the EnergySolutions facility.
Can I use a project name or acronym as the Permittee or organization on the application form?
No, the Permittee should be the legal entity (whether a corporate entity or a governmental agency) that is responsible for compliance with the Generator Site Access Rules for waste shipments destined for disposal in the State of Utah, regardless of whether the Permittee is the actual generator of the waste. The identity of the Permittee should match the “SHIPPER” name that is to be listed on the standard radioactive waste manifest form.
If I am a private contractor using a GSA permit to ship DOE waste can I consider myself a federal agency?
No, if you are contracted to be responsible for compliance with the Generator Site Access Rules, you are the “corporate entity” and should fill in the state of incorporation or formation field on the application form.
Can the permit be transferred to a new owner?
Depends, any request for a permit transfer is reviewed on a case by case basis. The Director may allow transfer of a Generator Site Access Permit in accordance with new ownership (R313-26-3-(8).
If a waste processor or waste collector has a “site access permit,” will this eliminate the generator’s need to have a “site access permit”?
Yes, if the generator is using a permitted broker (e.g. waste processor’s or waste collector’s services), the generator will not need to obtain a “site access permit.”
Is there a prescribed format for the permitting process? Is a memo sufficient?
Yes, the Generator Site Access Permit Application is the prescribed format for the process. No, a memo will not be sufficient.
Is it 30 working days or 30 calendar days prior to waste shipment that applications must be received by the Director?
It is 30 calendar days.
Is an approval letter required prior to shipment, or can shipment occur 30 days after the Director’s receipt of application without approval?
Yes, an approval letter is required. EnergySolutions cannot accept waste without a generator site access permit number.
Are permit fees the same for waste generators, waste processors and waste collectors? Is the permit based on actual or estimated quantities?
No, permit fees are different for Waste Processors, Waste Collectors and Generators. Waste Processors and Waste Collectors are assessed $7,500 annually. Generators are assessed $2,500 annually. Neither, it is a flat fee.
Will waste generators who are also waste processors or waste collectors have to obtain two permits?
Yes, persons who both generate and are either a Waste Processor or Waste Collector need separate “Site Access Permits”.
Does a generator with facilities located in different states need separate Generator Site Access Permits?
Yes, Facilities which are owned by the same generator and located in different states need separate Generator Site Access permits.
Does the permit number need to be listed in the shipping documents? Is a copy of the permit required to accompany the waste shipments?
Yes, the permit number needs to be listed in the shipping documents. No, while the permit number must accompany the waste shipments, a copy of the permit is not required to accompany the waste shipments.
Will the waste processor, waste collector or generator receive an approval number or letter?
Yes, both a permit number and approval letter will be issued to those who are approved.
Where can generators and brokers go to get permit status reports and what organization is responsible to maintain and provide this information.
Permit status information can be obtained by contacting the Division of Waste Management and Radiation Control. An Email as well as a letter will be sent to the contact person listed in the Division’s system approximately 60-days prior to expiration. The Division’s Generator Site Access Program maintains the permitting process and has access to program information.
Does a generator, waste processor or waste collector have any recourse if the Division of Waste Management and Radiation Control does not respond within a 30-day time-frame?
No, however, the Division makes every effort to respond within 30 days.
Can online renewal be used to apply for the generator site access permit?
No, there is not an online renewal system at this time.
Are there different fees for out-of-state generators, waste processors and waste collectors?
No, the permit fees are the same and applicable to everyone regardless of geographic location.
Will the Federal Government be considered in violation, if a carrier used by the Federal Government is in violation?
No, it is the organization that is permitted that is responsible for any violations.