Reactor- Versus Accelerator-Produced Tritium

DOE-HDBK-1129-99

TABLE 3-1. EPA maximum contaminant level for tritium

Rule

DOE Effects

MCL

Source

20,000 pCi/L

NBS Handbook 69

1976 Final Rule

4 mrem/year Total

(41 FR 28404)

Body or Organ Dose

Equivalent

60,900 pCi/L

RADRISK (ICRP 30)

1991 Proposed Rule

4 mrem/ year

(56 FR 33050)

Effective Dose

Equivalent

86,000 pCi/L

Federal Guidance

1997 Direct Final Rule

4 mrem/year

Report #11

(Never Issued)

Effective Dose

Equivalent

3.1.3 Reactor- Versus Accelerator-Produced Tritium

Under the implementing regulations of the Resource Conservation and Recovery Act (RCRA)

[specifically at 40 CFR 261.4(a)(4)], source, special nuclear and byproduct material as defined by

the Atomic Energy Act of 1954 (AEA) is excluded from the definition of solid waste (and thus, from

the RCRA hazardous waste management requirements). The AEA definition of byproduct material

includes "any radioactive material (except special nuclear material) yielded in or made radioactive

by exposure to the radiation incident to the process of producing or utilizing special nuclear

material." Tritium produced in a reactor (i.e., through the use of special nuclear or source

materials) meets the definition of "by-product" material; and, therefore, the waste streams derived

from reactor-produced tritium are excluded from RCRA regulation (provided such waste streams

do not also contain a RCRA hazardous waste component in addition to the by-product material

component). Accelerator-produced tritium, on the other hand, does not qualify for this exclusion

(since the tritium is produced by a linear accelerator, and does not involve the production or

utilization of special nuclear materials or the extraction or concentration of source material).

Thus, for reactor-generated tritium waste to be considered hazardous waste, the waste stream

also would have to contain a RCRA listed or non-tritium derived characteristic hazardous waste

component. For accelerator-produced tritium waste streams (with only tritium, or tritium and other

non-hazardous waste components), the waste stream would not be excluded from RCRA.

However, unless such tritium wastes exhibit one of the characteristics of RCRA hazardous waste

[ignitability, corrosivity, reactivity, or toxicity (40 CFR 261.21 - .24)], the waste streams would not

need to be managed as a RCRA hazardous/mixed waste. Pursuant to the RCRA regulations, it is

the responsibility of the generator of a waste to determine if that waste is subject to the hazardous

waste requirements [40 CFR 262.11]. Categories of characteristic hazardous waste (and

associated properties) that appear to have some potential to apply to certain accelerator-produced

tritium wastes are as follows:

Ignitability [40 CFR 261.21] Ignitable wastes are solid wastes that exhibit any of the following

properties: liquids with a flash point of less than 60C (140F); solids that are capable of

causing fires through friction, absorption of moisture, or spontaneous chemical changes;

ignitable compressed gases as defined in 49 CFR 173.300; or oxidizers as defined in

49 CFR 173.151.

Corrosivity [40 CFR 261.22] Corrosive wastes are solid wastes that exhibit any of the

following properties: an aqueous material with pH <2 or >12.5; or a liquid that corrodes steel at

a rate greater than inch per year at a temperature of 55C (130F).