Waste Characterization

DOE-HDBK-1129-99

8.1.4.b(4) Release to the Sanitary Sewer

Very-low-level tritium-contaminated water, which is generated by hand washing, showering, and

normal facility water use, may be stored and analyzed to see that it meets state and Federal

release criteria. If the water meets the regulations, it may be released to the local sanitary sewer.

The NRC release limit for tritium as defined in 10 CFR 20 Appendix B, Table 3, for release to

sanitary sewers is 1.0E-2 Ci/mL. This release limit is based on the monthly average (total

quantity of tritium divided by the average monthly volume of water released to the sanitary sewer).

If more than one radionuclide is released, the sum of the fractions rule applies. Also Draft

10 CFR 834 specifies less than a 5 Ci annual tritium release to sanitary sewers.

Regulations regarding the packaging for disposal and disposal of tritium-contaminated water are

complex. The available choices for disposal are dependent on the tritium content of the water and

the equipment available. Facility planning must include provisions for disposal of tritium-

contaminated water at all levels of contamination down to a level that may be released to the local

sanitary sewer system.

8.2 Waste Characterization

The purpose of hazardous waste characterization is to determine the applicability of the RCRA

hazardous waste management requirements and to demonstrate compliance with these

requirements (in accordance with 40 CFR Parts 261 through 268). Radioactive waste

characterization must satisfy requirements in DOE Order 5820.2A. Mixed waste characterization

must satisfy both. Waste characterization is the process used to determine the physical, chemical,

and radiological properties of the LLW. As a general rule, if a hazardous waste component is

reasonably expected to be present in a radioactive waste stream, it is advisable to manage the

waste as mixed waste until the waste is characterized by chemical analysis or process knowledge

to document that the waste contains no hazardous wastes as identified in 40 CFR 261.

Waste characterization is the process of identifying, assessing, and documenting the physical,

chemical, and radiological properties of process wastes and wastes generated from cleanup and

removal activities. The waste profile created during characterization is the foundation for waste

segregation, management, and certification operations. Characterization programs must be

developed to address waste certification requirements dictated by the waste management,

disposal, or treatment option selected for each waste stream, in addition to the applicable

regulatory requirements. The primary characterization determinations to be considered for tritium-

contaminated waste are the low-level and hazardous waste determinations.

Defining process waste streams is one of the most overlooked aspects of waste characterization.

Many generators believe characterization involves the assessment of inventory containers.

Effective waste management must begin at the point of waste generation. The generator must first

identify all of the waste-generating processes. Information such as process inputs, sub processes,

equipment, and chemical use must be reviewed to generate an adequate profile for each waste

stream.

Documenting the waste stream assessments is also an important part of the characterization

process. It is critical that the personnel generating waste be provided with the information required

to properly manage waste generated in their area. Additionally, an auditable record must be

created that allows for review of the characterization process and determinations. Waste-

generating processes must be reviewed periodically to identify changes that could result in the