RH-TRAMPAC - Waste Isolation Pilot Plant - U.S. Department of ...

RH-TRAMPAC Document Rev. 0, June 20063.1.2 Methods of Compliance and VerificationCompliance with the Pu-239 FGE or U-235 FEM limits, as applicable, involves the followingsteps:• Determination of the isotopic composition• Determination of the quantity of radionuclides• Calculation of Pu-239 FGE or U-235 FEM, as applicable, and compliance evaluation.Each of these steps is discussed in detail below.Isotopic CompositionThe isotopic composition of the waste may be determined from direct measurements taken on theproduct material during the processing or post-process certification at each site, analysis of thewaste, or from existing records. The isotopic composition of the waste need not be determinedby direct analysis or measurement of the waste unless process information is not available.RH-TRU wastes from DOE sites can be divided into the following categories:• Solid and solidified wastes from the examination of special reactor fuels, research anddevelopment activities, decontamination and cleanup, and other hot cell operations• Contaminated metals• Sludges processed into a solidified waste form from inorganic liquid wastes, originatingfrom water treatment facilities, research and development activities, and decontaminationoperations.These wastes can be referenced to processes requiring the knowledge of the radioisotopiccomposition and quantity for material accountability and tracking in support of the criticalityhazard controls at each site.Facilities that examine special reactor fuels have the most detailed and traceable data regardingthe isotopic composition of the waste. Incoming radioactive materials originally generated bynuclear reactors have a well-known and documented history. The initial isotopic composition ofthe fuel, neutron flux, irradiation time, and cooldown time are measured and documented. Fromthis information, the fissile material and the generation of fission and activation products can becalculated.Mechanical subdivision of the reactor fuels for purposes of examination is required. Thedistribution of the isotopic inventories due to subdividing is measured and/or calculated.Generated waste items and their subdivided parts are identified and tracked by administrativesystems at the sites. Items placed in the waste stream are documented with sufficient detail topermit an assignment of isotopic content. Items, such as cell equipment or decontaminationmaterials that have been contaminated, are documented and the isotopic composition of thecontamination is determined by referencing materials handled in the cell.The isotopic composition of the irradiated fuel is calculated based on the data mentioned above,or the isotopic composition of the irradiated fuel may be confirmed by radiochemical analysis.The isotopic composition of the resulting RH-TRU waste from the examination procedures shallbe determined by referencing the irradiated fuel analysis.3.1-3