Economic Discard Limit for Tritiated Water

DOE-HDBK-1129-99

stream would need to be managed as a radioactive mixed waste in accordance with the AEA and

RCRA. The determination that a mixed waste exists will result in the more stringent disposition

option depicted. Note that even though naturally-occurring and accelerator-produced radioactive

materials do not constitute a source, special nuclear or byproduct material, all DOE waste

containing naturally-occurring and accelerator-produced radioactive materials mixed with a

hazardous component must be managed as hazardous waste under RCRA [pursuant to Order

DOE 5820.2A]. The disposition options for non-hazardous, non-mixed tritium from both the

accelerator and reactor sources is similar with the biggest difference resulting from the storage

requirements for RCRA solid material. These disposition options are a function of the form (solid,

liquid, or gas).

8.2.3 Economic Discard Limit for Tritiated Water

EPA uses the economic discard limit (EDL) to evaluate whether a hazardous material or residue

should be classified as a waste. If it has sufficiently high economic value, the material should be

considered for recovery and reuse. The intent is not to allow facility operations (both at

Government Owned and Commercially Owned) to define material as not being waste and thereby

not be required to meet the current federal statutes on permitting of hazardous waste material for

treatment, storage, and disposal (TSD). In a simplistic form, the EDL is the threshold value in

determining when a materials economic value ($/unit weight or volume) exceeds the associated

cost for the materials treatment, storage, and disposal. If the economic value, based on current

market value or replacement value, is determined to be of greater value than the cost of TSD, the

material can be considered non-waste. The governing statues and requirements for non-waste are

less extensive, and the disposition times are less severe.

There have been increasing discussions and studies of the feasibility of recovering the current

oxide inventory (~200 grams) and continuing additions (~100 grams/year) in the DOE complex [35-

36]. Even though the reports referenced originated at LANL, there are conflicting burial costs. For

example, one states that LANL burial costs are on the order of $1,000-$3,000 per Ci and the other

stating that the LANL costs possess "negligible local burial costs" and "interim storage incurs no

significant space or other charges;" therefore, a much higher value of $1,250 per Ci from Mound

(Mound personnel contacted believe that this value is far too high for Mound costs) was used

instead for illustrative purpose.