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Title: TECHNICAL BASIS DOCUMENT FOR CRITERIA AND PROCESSES FOR THE CERTIFICATION OF NON-RADIOACTIVE HAZARDOUS AND NON-HAZARDOUS WASTES

Abstract

This Technical Basis Document (TBD) identifies how the values presented in the ''Criteria and Processes for the Certification of Non-Radioactive Hazardous and Non-Hazardous Wastes'' were derived. The original moratorium document (UCRL-AR-109662) applied only to hazardous wastes generated in Radioactive Materials Management Areas (RMMAs) that were destined for off-site Treatment, Storage, and Disposal Facilities (TSDFs) that did not possess a radioactive materials license. Since its inception, the original moratorium document has become the de facto free-release procedure for potentially volumetrically contaminated materials of all varieties. This was promulgated in a February 4, 1992 memo from Jyle Lytle, Deputy Assistant Secretary for Waste Management, entitled ''Update: Moratorium on Shipment of Potentially Radioactive Hazardous and Toxic Wastes''. In this memo, Ms. Lytle states, ''While the moratorium does not apply to non-hazardous/non-TSCA solid wastes and non-waste materials, the same release criteria apply''. Over the past few years, a considerable quantity of data and operating experience has been developed, which has shown the limitations of UCRL-AR-109662. The original Moratorium is out of date, and many of the organizations and procedures that it references are no longer in existence. In addition, the original document lacked sufficient detail to be used as an LLNL-wide procedure for freemore » release, as it only addressed hazardous wastes. The original moratorium document also used highly optimistic ''action limits'', which were based on theoretically achievable minimum detectable activity (MDA) levels for various matrices. Years of operating experience has shown that these action limits are simply not achievable for certain analyses in certain matrices, either due to limitations in sample size, or underestimates of the contribution of naturally-occurring radioactive materials, resulting in the mis-characterization of samples of these matrices as radioactive, when no radioactivity was added by LLNL operations. The new moratorium document updates the organizations involved in Moratorium Declarations, specifically addresses non-hazardous waste matrices, and allows for alternative types of analysis. The new moratorium document formalizes the process of release of potentially volumetrically-contaminated waste materials from radiological controls at LLNL.« less

Authors:
;
Publication Date:
Research Org.:
Lawrence Livermore National Lab. (LLNL), Livermore, CA (United States)
Sponsoring Org.:
USDOE
OSTI Identifier:
902365
Report Number(s):
UCRL-TR-228108
TRN: US0702932
DOE Contract Number:
W-7405-ENG-48
Resource Type:
Technical Report
Country of Publication:
United States
Language:
English
Subject:
38 RADIATION CHEMISTRY, RADIOCHEMISTRY, AND NUCLEAR CHEMISTRY; 12 MANAGEMENT OF RADIOACTIVE WASTES AND NON-RACIOACTIVE WASTER FROM NUCLEAR FACILITIES; 54 ENVIRONMENTAL SCIENCES; LAWRENCE LIVERMORE NATIONAL LABORATORY; MANAGEMENT; MATRICES; RADIOACTIVE MATERIALS; RADIOACTIVITY; SOLID WASTES; STORAGE; WASTE MANAGEMENT; WASTES

Citation Formats

Dominick, J, and Gaylord, R. TECHNICAL BASIS DOCUMENT FOR CRITERIA AND PROCESSES FOR THE CERTIFICATION OF NON-RADIOACTIVE HAZARDOUS AND NON-HAZARDOUS WASTES. United States: N. p., 2007. Web. doi:10.2172/902365.
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Dominick, J, & Gaylord, R. TECHNICAL BASIS DOCUMENT FOR CRITERIA AND PROCESSES FOR THE CERTIFICATION OF NON-RADIOACTIVE HAZARDOUS AND NON-HAZARDOUS WASTES. United States. doi:10.2172/902365.
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Dominick, J, and Gaylord, R. Tue . "TECHNICAL BASIS DOCUMENT FOR CRITERIA AND PROCESSES FOR THE CERTIFICATION OF NON-RADIOACTIVE HAZARDOUS AND NON-HAZARDOUS WASTES". United States. doi:10.2172/902365. https://www.osti.gov/servlets/purl/902365.
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@article{osti_902365,
title = {TECHNICAL BASIS DOCUMENT FOR CRITERIA AND PROCESSES FOR THE CERTIFICATION OF NON-RADIOACTIVE HAZARDOUS AND NON-HAZARDOUS WASTES},
author = {Dominick, J and Gaylord, R},
abstractNote = {This Technical Basis Document (TBD) identifies how the values presented in the ''Criteria and Processes for the Certification of Non-Radioactive Hazardous and Non-Hazardous Wastes'' were derived. The original moratorium document (UCRL-AR-109662) applied only to hazardous wastes generated in Radioactive Materials Management Areas (RMMAs) that were destined for off-site Treatment, Storage, and Disposal Facilities (TSDFs) that did not possess a radioactive materials license. Since its inception, the original moratorium document has become the de facto free-release procedure for potentially volumetrically contaminated materials of all varieties. This was promulgated in a February 4, 1992 memo from Jyle Lytle, Deputy Assistant Secretary for Waste Management, entitled ''Update: Moratorium on Shipment of Potentially Radioactive Hazardous and Toxic Wastes''. In this memo, Ms. Lytle states, ''While the moratorium does not apply to non-hazardous/non-TSCA solid wastes and non-waste materials, the same release criteria apply''. Over the past few years, a considerable quantity of data and operating experience has been developed, which has shown the limitations of UCRL-AR-109662. The original Moratorium is out of date, and many of the organizations and procedures that it references are no longer in existence. In addition, the original document lacked sufficient detail to be used as an LLNL-wide procedure for free release, as it only addressed hazardous wastes. The original moratorium document also used highly optimistic ''action limits'', which were based on theoretically achievable minimum detectable activity (MDA) levels for various matrices. Years of operating experience has shown that these action limits are simply not achievable for certain analyses in certain matrices, either due to limitations in sample size, or underestimates of the contribution of naturally-occurring radioactive materials, resulting in the mis-characterization of samples of these matrices as radioactive, when no radioactivity was added by LLNL operations. The new moratorium document updates the organizations involved in Moratorium Declarations, specifically addresses non-hazardous waste matrices, and allows for alternative types of analysis. The new moratorium document formalizes the process of release of potentially volumetrically-contaminated waste materials from radiological controls at LLNL.},
doi = {10.2172/902365},
journal = {},
number = ,
volume = ,
place = {United States},
year = {Tue Feb 13 00:00:00 EST 2007},
month = {Tue Feb 13 00:00:00 EST 2007}
}
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DOI:  10.2172/902365
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  • ;

  • This document details Lawrence Livermore National Laboratory's (LLNL) criteria and processes for determining if potentially volumetrically contaminated or potentially surface contaminated wastes are to be managed as material containing residual radioactivity or as non-radioactive. This document updates and replaces UCRL-AR-109662, Criteria and Procedures for the Certification of Nonradioactive Hazardous Waste (Reference 1), also known as 'The Moratorium', and follows the guidance found in the U.S. Department of Energy (DOE) document, Performance Objective for Certification of Non-Radioactive Hazardous Waste (Reference 2). The 1992 Moratorium document (UCRL-AR-109662) is three volumes and 703 pages. The first volume provides an overview of the certificationmore » process and lists the key radioanalytical methods and their associated Limits of Sensitivities. Volumes Two and Three contain supporting documents and include over 30 operating procedures, QA plans, training documents and organizational charts that describe the hazardous and radioactive waste management system in place in 1992. This current document is intended to update the previous Moratorium documents and to serve as the top-tier LLNL institutional Moratorium document. The 1992 Moratorium document was restricted to certification of Resource Conservation and Recovery Act (RCRA), State and Toxic Substances Control Act (TSCA) hazardous waste from Radioactive Material Management Areas (RMMA). This still remains the primary focus of the Moratorium; however, this document increases the scope to allow use of this methodology to certify other LLNL wastes and materials destined for off-site disposal, transfer, and re-use including non-hazardous wastes and wastes generated outside of RMMAs with the potential for DOE added radioactivity. The LLNL organization that authorizes off-site transfer/disposal of a material or waste stream is responsible for implementing the requirements of this document. The LLNL Radioactive and Hazardous Waste Management (RHWM) organization is responsible for the review and maintenance of this document. It should be noted that the DOE metal recycling moratorium is still in effect and is implemented as outlined in reference 17 when metals are being dispositioned for disposal/re-use/recycling off-site. This document follows the same methodology as described in the previously approved 1992 Moratorium document. Generator knowledge and certification are the primary means of characterization. Sampling and analysis are used when there is insufficient knowledge of a waste to determine if it contains added radioactivity. Table 1 (page 12) presents a list of LLNL's analytical methods for evaluating volumetrically contaminated waste and updates the reasonably achievable analytical-method-specific Minimum Detectable Concentrations (MDCs) for various matrices. Results from sampling and analysis are compared against the maximum MDCs for the given analytical method and the sample specific MDC to determine if the sample contains DOE added volumetric radioactivity. The evaluation of an item that has a physical form, and history of use, such that accessible surfaces may be potentially contaminated, is based on DOE Order 5400.5 (Reference 3), and its associated implementation guidance document DOE G 441.1-XX, Control and Release of Property with Residual Radioactive Material (Reference 4). The guidance document was made available for use via DOE Memorandum (Reference 5). Waste and materials containing residual radioactivity transferred off-site must meet the receiving facilities Waste Acceptance Criteria (if applicable) and be in compliance with other applicable federal or state requirements.« less

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