Tritium Safeguards and Security

DOE-HDBK-1129-99

Reactivity [40 CFR 261.23] Reactive wastes are solid wastes that exhibit any of the following

properties: (1) they are normally unstable and readily undergo violent change without

detonating; (2) they react violently with water; (3) they form potentially explosive mixtures with

water; (4) when mixed with water, they generate toxic gases, vapors, or fumes in a quantity

sufficient to present a danger to human health or the environment; (5) they are a cyanide or

sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate

toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the

environment; (6) they are capable of detonation or explosive reaction if subjected to a strong

initiating source or if heated under confinement; (7) they are readily capable of detonation or

explosive decomposition or reaction at standard temperature and pressure; (8) they are a

forbidden explosive as defined in 49 CFR 173.51, or a Class A explosive as defined in 49 CFR

173.53 or a Class B explosive as defined in 49 CFR 173.88.

The discussion in Section 2.5.1.c provides a qualitative argument for the determination that for

waste, the characteristic of corrosivity typically are not exhibited. However, little data are currently

available to confirm whether or not the vapor space of some tritium containers (e.g. tritium oxide

adsorbed on molecular sieves) would exhibit the hazardous characteristic of ignitability or reactivity

over time due to radiolytic decay. As explained above, reactor-generated tritium waste streams

that do not contain a hazardous waste component may be excluded from the RCRA hazardous

waste regulations pursuant to 40 CFR 261.4(a)(4). This may be the case even if sufficient

quantities of both hydrogen and oxygen are present to exhibit characteristics of ignitability or

reactivity. This is based on a regulatory policy that EPA has applied in certain cases whereby

residuals derived from the management of exempt or excluded waste retain the exemption or

exclusion. [13-17] However (as indicated above), if a tritium waste (reactor- or accelerator-

produced) also contains a distinct hazardous waste component, the waste stream should be

managed as a radioactive mixed waste under the AEA and RCRA.

The application of RCRA to certain tritium waste streams may be subject to regulatory

interpretation and enforcement discretion. With this in mind, it is recommended that

determinations as to whether or not certain tritium wastes constitute RCRA hazardous waste be

discussed and validated with the appropriate regulatory agency (i.e., the EPA Region or RCRA-

authorized State agency). Section 8.2.2 provides a flow diagram and expanded discussion on this

issue, in addition to the definitions and options for tritium recovery and disposal.

3.2 Tritium Safeguards and Security

Tritium is a nuclear material of strategic importance and must be safeguarded from theft or

diversion. Safeguard requirements are based on the category of the nuclear material as specified

in Figure I-2, "Nuclear Material Safeguards Categories," of DOE Order 5633.3B; i.e., Category I

through Category IV, and the attractiveness level; i.e., Attractiveness Level A through E. Tritium is

either a Category III or Category IV material depending upon the following:

Category III Weapons or test components containing reportable quantities of tritium.

Deuterium-tritium mixtures or metal tritides that can be easily decomposed to tritium gas,

containing greater than 50 grams of tritium (isotope) with a tritium isotopic fraction of 20

percent or greater.

Category IV All other reportable quantities, isotopic fractions, types, and forms of tritium.