This document provides the technical justification for an Exemption from the WIR requirements contained in DOE's Manual 435.1-1 Radioactive Waste Mgmt
Office of Environmental Management
August 5, 2020
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Executive Summary
This document provides the technical justification for an Exemption from the Waste Incidental to Reprocessing (WIR) requirements contained in the Department of Energy’s (DOE) Manual 435.1-1, Radioactive Waste Management Manual, Chapter II, Section B.1,2 The Exemption applies to a small quantity (up to eight gallons) of Savannah River Site Defense Waste Processing Facility (DWPF) recycle wastewater.3 The DWPF recycle wastewater is classified as Class B low-level radioactive waste (LLW) in accordance with DOE’s interpretation of the statutory definition of high-level radioactive waste (HLW).
The Office of Environmental Management (EM) is a technical organization with a strong safety-conscious culture. As part of this safety culture, EM continuously evaluates established practices and procedures to assess whether better processes and practices could enhance safety and improve environmental remediation. This practice of constant process improvement has led EM to analyze the application of the HLW interpretation to the DWPF recycle wastewater. The HLW interpretation allows for the classification of reprocessing waste to be based on the radiological contents of a specific waste form and not solely the source of the waste. EM has analyzed the DWPF recycle wastewater under the HLW interpretation. Both the technical analyses as well as the potential safety and environmental benefits associated with the HLW interpretation approach support an Exemption.
The express criteria for granting an Exemption from the WIR requirements contained in Chapter II, Section B of DOE Manual 435.1-1 are set forth in DOE Manual 435.1–1, paragraph 4, and DOE Order 251.1D, Departmental Directives Program, Appendix E. Consistent with these established criteria for granting an Exemption from DOE Manual 435.1-1, EM has determined that the classification of the small quantity (up to eight gallons) of DWPF recycle wastewater as Class B LLW under the HLW interpretation is: (1) is fully protective of public health, safety, and the environment; (2) commensurate with the level of protection required by DOE Manual 435.1-1, Chapter II, Section B; and (3) does not conflict with existing federal laws and regulations. In short, the safety and environmental benefits associated with applying the HLW interpretation to this waste support the requested Exemption.
1 Refer to the Table B in Section 4.1(c) for specific details of the Exemption from the WIR requirements contained in Chapter II, Section B of DOE Manual 435.1-1.
2 DOE M 435.1-1 Chapter II, Section B(2)(b) does not apply as the DWPF recycle wastewater is not transuranic waste.
3 This document provides the technical analysis to support an Exemption; the decision to grant the Exemption is documented in an Action Memo signed by the Under Secretary for Science, dated July 15, 2020.