Tritium Disposition Options

DOE-HDBK-1129-99

The documentation should be constructed in such a way that independent review would result in

consistent characterization conclusions. The collection, review, management, and dissemination

of the information should be standardized and documented to ensure data integrity and that the

information is defensible during future assessments.

The use of waste knowledge to characterize wastes may be applicable in a number of situations,

including:

Waste stream is difficult to sample because of the physical form.

Sampling analysis would result in unacceptable risks of radiation exposure.

Waste is too heterogeneous in composition.

Waste sampling and analysis is not feasible or necessary.

Waste stream results from well-documented specific processes, such as with standard

laboratory operations.

8.2.2 Tritium Disposition Options

Tritium exists in various concentrations and forms throughout the complex. The tritium contained

in waste streams could be stored, released to the environment (i.e., in compliance with applicable

regulatory limits or permitted levels), or recovered for reuse. This section provides an overview of

a process to help make an informed decision on tritium disposition.

The diagram depicted on Figure 8-1 provides a simplified flow path for ultimate disposition of

tritiated material. The first fork is associated with the production source of the tritium. As

discussed in Section 3.1.3, the RCRA regulations include an exclusion from the hazardous waste

management requirements for source, special nuclear and byproduct material as defined by the

AEA [40 CFR 261.4(a)(4)]. Reactor-produced tritium wastes meet this definition of "byproduct"

material, and, as such, are excluded from the RCRA requirements applicable to solid waste and

hazardous waste. Additionally, EPA has applied a regulatory policy in certain cases [Ref. 13-17]

by which residuals, derived from the management of RCRA exempt or excluded waste, retain the

exemption or exclusion (even if they subsequently exhibit hazardous characteristics). These

considerations provide the basis for not including a hazardous waste determination step, relative to

assessing the tritium itself, in the reactor-produced tritium fork presented in Figure 8-1.

Accelerator-produced tritium waste does not qualify for the RCRA source, special nuclear, and

byproduct material exclusion. As such, any accelerator-produced tritium waste stream that

exhibits one or more of the characteristics of hazardous waste (e.g., ignitability, corrosivity) would

be subject to the RCRA hazardous waste provisions. For this reason, the accelerator-produced

tritium fork in Figure 8-1 includes a determination of whether the material (i.e., the accelerator-

produced tritium waste itself) is hazardous. The authors believe that it is unlikely that forms of

tritiated materials in container configurations, used in the DOE complex, would exhibit any of the

four characteristics of hazardous waste. This pathway, while unlikely to exist, is still possible (e.g.,

compressed tritium gas in a container configuration satisfies the characteristic of ignitability) and is

illustrated in Figure 8-1.

Both the accelerator and reactor forks include a mixed waste determination. Specifically, this

determination step considers whether the tritiated material also contains a RCRA hazardous waste

component (i.e., in addition to the tritium/radioactive component). If a reactor-produced or

accelerator-produced tritium waste stream also contains a hazardous waste component, the waste