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IMPLEMENTATION GUIDE for Use with DOE M 435.1-1

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IMPLEMENTATION GUIDE for Use with DOE M 435.1-1 IMPLEMENTATION GUIDE for use with DOE M 435.1-1 Chapter III Transuranic Waste Requirements (This page intentionally left blank.) DOE G 435.1-1 III-1 7-09-99 III. A. Definition of Transuranic Waste. Transuranic waste is radioactive waste containing more than 100 nanocuries (3700 becquerels) of alpha-emitting transuranic isotopes per gram of waste, with half-lives greater than 20 years, except for: (1) High-level radioactive waste; (2) Waste that the Secretary of Energy has determined, with the concurrence of the Administrator of the Environmental Protection Agency, does not need the degree of isolation required by the 40 CFR Part 191 disposal regulations; or (3) Waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with 10 CFR Part 61. Objective: The objective of this requirement is to provide the criteria for determining if a waste is to be managed in accordance with DOE M 435.1-1, Chapter III, Transuranic Waste Requirements. Additionally, it is necessary to determine if a waste meets the definition of transuranic waste to enable the Department of Energy to comply with provisions in the Waste Isolation Pilot Plant Land Withdrawal Act of 1992, as amended. Discussion: Basis. This definition of transuranic waste is the definition used in the Waste Isolation Pilot Plant (WIPP) Land Withdrawal Act of 1992, as amended. This definition is functionally equivalent to that in 40 CFR Part 191, Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes. The WIPP Land Withdrawal Act of 1992, as amended, defines transuranic waste and limits disposal at WIPP to transuranic waste resulting from atomic energy defense activities which meets this definition. Interpretation and Application. In order to ensure consistent application, various terms used in the definition need to be clarified. First, the limit above which a waste is determined to be transuranic waste is based on an activity of 100 nanocuries (nCi) (3700 becquerels (Bq)) per gram of waste. The activity to be counted in making this determination is only that from the isotopes that would qualify a waste as transuranic waste as described in the following paragraphs. In other words, one would not include the activity from short-lived fission products (i.e., non-alpha emitters with half-lives less than 20 years) in calculating the concentration. The mass over which Chapter III - Transuranic Waste Requirements III-2 DOE G 435.1-1 7-09-99 the activity is divided in making the waste determination is the waste matrix. This includes the waste material itself as well as any stabilization media that must be added to meet waste acceptance criteria for mobility, physical form, structural stability or free liquids. The mass of added shielding, the container, or any rigid liners is not included in the calculation. The term transuranic means those elements with an atomic number greater than that of uranium (i.e., atomic number >92). Therefore, uranium wastes do not qualify as transuranic waste by virtue of their uranium concentration. The transuranic radionuclides that are to be considered in making a transuranic waste determination must decay by emission of alpha particles and also must have a half-life greater than 20 years. Consistent with this portion of the definition, there are radionuclides with atomic numbers greater than 92 that would not cause a waste to be called transuranic waste. Example: A waste is contaminated with americium-242 which predominantly decays by emission of a beta particle and has a 16-hour half-life. Even though americium-242 has an atomic number greater than 92, it cannot be considered in determining the waste type because it is not an alpha emitter and does not have a 20-year half life. Given the definition provided in the public law and its application pursuant to DOE M 435.1-1, the determination of transuranic waste should be made at the time of waste certification, that is, each time the waste is transferred to another person or facility (see guidance for DOE M 435.1-1, Section III.J). Example 1: A waste is contaminated with curium-244 which is an alpha-emitter and has an atomic number greater than 92. Over a period of about 200 years, a sufficient inventory of curium-244 will decay to greater than 100 nCi/g of plutonium-240, an alpha emitter with a 6,750-year half-life. Regardless of the decay product, the curium-244 content of the waste is not relevant to the determination of whether the waste is transuranic because the curium has an 18.11-year half-life and the determination is made at the time the waste is certified as meeting a facility’s waste acceptance criteria. However, even if the waste is determined to be a low-level waste, the method of disposal must be commensurate with the long-term hazard associated with the plutonium-240 decay product. Example 2: A waste is generated and placed in bags within 55-gallon drums. The waste has been characterized and certified as transuranic waste in accordance with the waste acceptance criteria of the facility receiving the waste. This same waste, if required to undergo solidification to enable shipment and disposal, could be re-certified after treatment by the treating facility as low-level waste, in the event that radioassay found Chapter III - Transuranic Waste Requirements DOE G 435.1-1 III-3 7-09-99 that the solidification process reduced the concentration of relevant radioisotopes to less than 100 nCi (3700 Bq) per gram of waste matrix. In the previous example, the waste form would be altered by the addition of solidifying agents that would be considered in the radioassay. In either of the two cases in the previous example, the determination would not consider the waste container or its rigid liner. Even if a waste container fails and has to be overpacked, the mass of the failed container does not need to be included in the transuranic waste determination. Example: A 55-gallon drum is damaged, has leaked, and requires overpacking. The concentration determination would include the weights of the original waste matrix and interior bags, but not the weight of the failed drum. It is also conceivable that a low-level waste could become sufficiently concentrated that it becomes a transuranic waste. Example: A waste with a relatively high concentration of transuranic radionuclides (but less than 100 nCi (3700 Bq) per gram) is transferred to a treatment facility as low-level waste. The thermal treatment of the waste reduces the mass of the waste matrix enough that the resulting transuranic concentration exceeds 100 nCi (3700 Bq) per gram. If no additional treatment (e.g., stabilization) were necessary, the resulting waste would be categorized as transuranic waste. Determining whether waste exceeds the 100 nCi/g (3700 Bq/g) shall be in accordance with the requirements and guidance issued by the Carlsbad Area Office in the Transuranic Waste Characterization Quality Assurance Program Plan, Waste Acceptance Criteria for the Waste Isolation Pilot Plant, and/or other controlling documents. Waste which does not exceed the 100 nCi/g limit is to be managed in accordance with the low-level waste requirements of DOE M 435.1-1. Dilution of a transuranic waste stream to reclassify the waste as low-level waste (i.e., reducing the concentration to less than or equal to 100 nCi (3700 Bq) per gram) is not permitted by the Department. While it is recognized that in the course of stabilizing a waste stream some changes in waste concentration may occur, actions to dilute a waste stream below the concentration limits for transuranic waste are prohibited. It is also recognized that actions taken to process a waste stream for safety or technological reasons that are justified, may result in the waste being reclassified after processing as low-level waste. Example: Due to the moisture content of a transuranic waste sludge, the waste does not meet the WIPP WAC. The site evaluates several treatment options taking into consideration factors such as worker exposure, waste minimization, cost and complexity Chapter III - Transuranic Waste Requirements III-4 DOE G 435.1-1 7-09-99 of the treatment process and disposal facility waste acceptance requirements. The treatment process selected involves adding grout to the transuranic waste sludge to eliminate free liquids resulting in a solidified waste form that contains transuranic radionuclides in concentrations less than 100 nCi (3700 Bq) per gram and meets the waste acceptance criteria for a low-level waste disposal facility. There are three exceptions to the definition of transuranic waste: the high-level waste exception; the degree of isolation exception; and the NRC-approved disposal exception. High-Level Waste Exception. The definition of transuranic waste includes exceptions for some wastes that would otherwise be considered transuranic waste. The first exception to the definition of transuranic waste is waste that meets the definition of high-level waste (see Definition of High- Level Waste guidance). Because high-level waste is generated by reprocessing spent nuclear fuel, much high-level waste contains concentrations of greater than 100 nCi (3700 Bq) per gram alpha- emitting radionuclides with half-lives greater than 20 years. Separate requirements apply to management of high-level waste, both within and external to DOE. This exception serves to distinguish high-level waste, as defined in DOE M 435.1-1, Chapter II, from transuranic waste. Example: Waste in underground storage tanks at the Hanford Site contains long-lived, alpha-emitting plutonium and neptunium isotopes in excess of 100 nCi (3700 Bq) per gram.
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