Ensure that:

• Members of the Workforce complete the training identified in ESH100.2.ENV.23 prior to performing the indicated work activity or fulfilling the indicated role. Note: See Sandia corporate procedure HR100.2.1, Identify and Complete Sandia Required Training for all Members of the Workforce.
• Primary waste generators within the organization who are responsible for generation and management of radioactive waste are appointed.

• Integrate methods into their daily work operations to minimize the generation of radioactive waste.
• Evaluate the following activities to minimize waste:
  • Minimize material use. Consider processes or material modifications that could eliminate or reduce the generation of waste. These changes can often be justified when the cost of waste management and disposal is considered for the life of the project.
  • Limit the use of material in radioactive waste-generating processes.
  • Minimize the likelihood of other material contacting or mixing with radioactive material.
  • Decontaminate equipment.
  • Physically separate radioactive components from equipment.
  • Re-use radioactive material, such as through the Radioactive Source Control Program.

Notes:

• Primary waste generators should consult the appropriate environmental compliance coordinator or the Pollution Prevention Program contact for ideas about methods of minimizing radioactive waste generation in specific processes and for information on pollution prevention opportunity assessments (PPOAs).

Plan and manage radioactive waste in accordance with PG470228, SNL Radioactive Waste Management Basis, as follows:

• Prepare a technical work document (TWD) that addresses how radioactive waste must be managed. For additional information, see ESH100.2.GEN.3, Develop and Use Technical Work Documents, and MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 1, "Radiological Work Planning and Controls."
• Ensure that the TWD addresses the following at a minimum:
  • Waste characterization, including process knowledge information, and sampling and analysis planning, as applicable (see “Waste Characterization – Process Knowledge” and “Waste Characterization – Sampling and Analysis”).
  • Radioactive waste accumulation area.
  • Waste containers, labeling, and packaging.
  • Segregation and control of radioactive waste to maintain waste traceability.
  • Estimated volume of radioactive waste. Note: As part of the disposal request process, a waste chargeback cost is determined by actual waste volume.
  • Preferred disposal site option.

Notes:

• See the relevant subsection for additional information about the items above. An example of a Waste Management Plan is available on the Waste Management and Pollution Prevention Department (WMPPD) website.
• Reference ESH100.2.ENV.23, Manage Radioactive Waste at SNL, in the TWD and state that the requirements in ESH100.2.ENV.23, Manage Radioactive Waste at SNL, must be followed.
• Meet any other applicable packaging and labeling requirements described in the Nevada National Security Site Waste Acceptance Criteria (NNSSWAC) for disposal of low-level waste at the Nevada National Security Site (NNSS) and in POL 95-01, Programmatic Waste Acceptance Criteria, for an onsite storage facility.
• Consult the waste certification official for assistance in determining other applicable requirements, including local DOE oversight office requirements at SNL remote sites.
• If transuranic waste must be generated, consult the transuranic waste management contact before waste is generated, to determine additional requirements regarding packaging, venting, and prohibited items.
• Primary waste generators should consult the appropriate environmental compliance coordinator before waste is generated, to resolve questions regarding radioactive waste planning, accumulation, packaging, segregation, control, characterization, and disposal pathway.

• Characterize radioactive waste to permit proper segregation, treatment, storage, and disposal.

• Characterize potential radioactive waste to determine whether it is radioactive waste or non-radioactive waste. Requirements in Release of Non-Radioactive Waste must be met before waste can be released as non-radioactive. 

  Note: If you generate waste in an area where there is potential for radiological contamination or activation, then also see MN471016, Radiological Protection Procedures Manual.

• Ensure that physical, chemical, and radiological characteristics of the radioactive waste are documented.

• Document process knowledge for the radioactive waste as the first step in waste characterization. 

  Notes:

  • Contact the appropriate environmental compliance coordinator or the waste characterization project leader for assistance in documenting process knowledge.
  • When process knowledge relies on living memory, the individual's knowledge must be documented and signed by both the interviewer and the interviewee. For telephone interviews, a statement outlining relevant information must be signed by the interviewer (and interviewee if possible).
• Provide waste characterization information as an attachment to SF 2042-TRA, Radioactive or Mixed Waste Disposal Request (DR) Form.
• Ensure that radioactive waste characterization information includes:
  • Applicable radiological process knowledge and/or sampling and analysis documentation for each waste parcel to estimate the activity of each radionuclide contaminant.
  • Determination that the radioactive waste is not regulated by the Resource Conservation and Recovery Act (RCRA) or by state regulations as a mixed waste.
  • Determination that the radioactive waste does not contain other prohibited items (see Segregation and control of radioactive waste).

Notes:

• A Radiological and Mixed Waste Characterization web page is available on the the WMPPD website for use by generators of radioactive waste.
• See Waste Characterization—Process Knowledge in Guidance on Managing Radioactive Waste at SNL.

Manage unknown waste for which there is no characterization information as mixed waste (see ESH100.2.ENV.24, Manage Mixed Waste at SNL), unless process knowledge and/or sampling and analysis can verify that the waste does not contain RCRA-regulated hazardous waste, state-regulated hazardous waste, or radioactive waste.

Notes:

• Contact the appropriate environmental compliance coordinator for assistance in managing unknown waste.
• Contact the waste characterization project leader for assistance in characterizing unknown waste.

• Identify no disposal path (NDP) waste in the planning process by describing the type and quantities of waste likely to be generated from a new project or process.
• If NDP waste is identified, complete an approval request package with assistance from the NDP waste contact.
• Obtain approval from DOE prior to generating any NDP waste, with assistance from the NDP waste contact.
• Take all necessary actions including procurement restrictions to ensure that no materials are procured that may lead to a NDP waste, without receiving prior approval from the DOE/NNSA/Sandia Site Office (SSO).
• Retain the records of approval in accordance with records retention established by the generating organization.

• Review and resubmit the request package for approval each year the waste is generated, unless a disposal path becomes available.

  Note: Progress made in locating a viable disposal path is necessary for renewed approval to continue to generate waste with no identified path to disposal.

Determine appropriate locations for radioactive waste accumulation areas and ensure that areas used for radioactive waste accumulation:

• Meet the requirements for radiological work permits and technical work documents specified in MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 1, “Radiological Work Planning and Controls.”
• Are identified by appropriate radiation protection signs, which are posted clearly and conspicuously. See MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 2, “Posting and Labeling for Radiological Control.” Note: Consult the appropriate Radiation Protection Representative for assistance.
• Are near the point of generation that is under the control of a primary waste generator or at an accumulation area that is under the control of the generator's organization.
• Are separated from areas with any other material or waste.
• Have adequate aisle space around waste containers so that emergency access is preserved (see [[ link | ESH100.2.FP.1]], Manage Fire Protection Requirements).
• For additional information, see Radioactive Waste Accumulation Area in Guidance on Managing Radioactive Waste at SNL.

• Provide secondary containment for radioactive waste containers that contain any free liquid and that are outside, inside near a floor drain, or inside where the possibility exists that spilled liquid could be discharged to a sanitary sewer or to the environment.
• Ensure that secondary containment systems have:
  • Sufficient capacity to contain 10 percent of the total volume of the containers, or the volume of the largest container, whichever is greater.
  • A base that is sufficiently impervious to contain leaks, spills, and precipitation until the accumulated material is removed.
  • A sloped base, elevated shelves, or other design features that prevent the containers from coming into contact with spilled or accumulated liquids.

• Immediately implement the applicable emergency plan. See ESH100.3.1, Prepare for and Manage Emergencies, for specific requirements.
• Comply with MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 11, "Radiological Incidents."
• Consult appropriate environmental compliance coordinator for assistance in complying with ESH100.4.RPT.4, Report Environmental Releases.

Label waste parcels using the appropriate labels and tags:

• Figure 1, Sample Caution Radioactive Material Information Tag.
• Figure 2, Sample Caution Radioactive Material Information Label.
• Figure 3, Sample Caution Radioactive Material Warning Label.
• Figure 4, Sample Tritium Waste Warning Label.
• Figure 5, Sample Danger Contains Asbestos Fibers Label.

Notes:

• When radioactive waste is placed into a labeled waste container, it is defined as a waste parcel.
• For additional information regarding labeling waste parcels, see Waste Containers, Labeling, and Packaging in Guidance on Managing Radioactive Waste at SNL.

• Follow the steps in Process for Labeling and Packaging Containers of Solid Radioactive Waste, when labeling and packaging containers of solid radioactive waste.
• Follow the steps in Process for Labeling and Packaging Containers of Liquid Radioactive Waste, when managing and labeling containers of liquid radioactive waste.

Obtain the following, as appropriate:

• A waste accumulation container (such as a plastic bag). If plastic bags are used, they must be clear or light yellow to allow visual inspection of contents through a double-bagged waste parcel.
• SNL/NM-certified shipping containers, metal box liners, and absorbent through the radioactive and mixed waste operations contact. SNL/NM-certified shipping containers include:
  • 30-gallon metal drums.
  • 55-gallon metal drums.
  • 85-gallon metal drums.
  • 7x4x2-foot metal boxes.
  • 7x4x4-foot metal boxes.
  • Transportainers. Note: Consult the radioactive and mixed waste operations contact to determine the appropriate waste accumulation container or SNL/NM-certified shipping container for the waste.
• Certification of existing shipping containers, as necessary.
• Labels and forms.
• Container-handling equipment.

Perform the following, as applicable:

• Verify that a liner is in drums and boxes.
• Provide documentation demonstrating that the amount of lead used for shielding is not excessive for a specific container of low-level waste. Note: Consult the waste characterization project leader.

Perform the following before use:

• Confirm that shipping containers are SNL/NM-certified by:
  • Verifying that the containers have a bar-coded SNL/NM container number (such as SNL/NM004444).
  • Documenting on an SF 2042-TRA, Radioactive or Mixed Waste Disposal Request Form, whether the container has a bar-coded SNL/NM container number.
• Conduct a pre-use inspection of waste containers and liners immediately before placing waste in the containers. The inspection includes the following.
  • Verifying that containers and liners are in good condition and leak-free (i.e., have no tears, dents, creases, bulges, or corrosion that would compromise the integrity of the container). Minor dents or minor surface corrosion are acceptable.
  • Visually evaluating container integrity and verifying that there is no liquid in the container before it is used.
  • Documenting this pre-use inspection by responding on an SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form. Note: If a nonconforming item has been received from the WMPPD or from a WMPPD-approved vendor, consult the radioactive and mixed waste operations contact.
• Contact the waste certification official if water is found in a container, or if the integrity of a container has been compromised.

Perform the following labeling immediately after waste is placed into the waste parcel:

• Affix a "Caution Radioactive Material" warning label (see Figure 3) or "Danger, Radioactive Material" warning label (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 2, “Posting and Labeling for Radiological Control”).
• Consult the appropriate Radiation Protection Representative for assistance on which label to use.
• Consult the appropriate Radiation Protection Representative to determine whether a radiological survey is required during accumulation and to determine whether a "Caution Radioactive Material" information tag or a "Caution Radioactive Material" information label is required during accumulation (see Figure 1 and Figure 2).
• Fill in the appropriate information on the information tag or label, if it is required to be attached to the waste parcel during accumulation.
• Attach a "Caution Tritium Waste" warning label (see Figure 4) if more than 1 millicurie of tritium is estimated to be present in the waste.
• Record the start date (the date that radioactive waste is first placed in the waste parcel) on the waste parcel.
• Record a tracking number on the waste parcel if it does not already have an SNL/NM barcode number. This waste parcel tracking number must include the six-digit Disposal Request (DR) number followed by a two-digit sequential number (e.g., 081148-01, 081148-02, and so on for multiple parcels on the DR).

Perform the following when segregating and placing radioactive waste into a waste parcel:

• Add absorbent to waste parcels, if there is potential for condensation or moisture. Example waste parcels include waste excavated from the ground, or potentially damp personal protective equipment, such as Tyvek® coveralls. Consult the radioactive and mixed waste operations contact to obtain absorbent, and for assistance on how much absorbent to use.
• Load SNL/NM-certified shipping containers efficiently to minimize void space.
• Ensure that the gross weight of the waste parcel does not exceed the maximum allowable gross weight, as stamped on the waste container or according to DOT regulations. Consult the radioactive and mixed waste operations contact for assistance with this determination.
• Wrap and seal the waste item in plastic, if it is too large to containerize. Contact the radioactive and mixed waste operations contact for assistance.
• Determine a packaging option for radioactive waste, if the radioactive waste generated has a dose equivalent rate greater than 200 millirem per hour (mrem/hr) at the surface of the waste container. Consult the radioactive and mixed waste operations contact for assistance.

Note: Contact the Radiation Protection Representative to determine if the waste parcel should be closed at all times except for when adding or removing waste. There are radiation protection requirements to control the spread of contamination that might necessitate waste parcels be kept closed.

• Use one of the following methods to double-contain parcels of solid radioactive waste to prepare for pick-up by the Waste Management and Pollution Prevention Department (WMPPD):
• • Place compactable waste, such as Tyvek® coveralls or latex gloves, in a transparent, labeled plastic bag, and double-bag the waste parcel once full.
  • Use a liner in a metal drum or metal box.
  • Place radioactively contaminated metal debris in a lined, labeled, SNL/NM-certified metal drum or metal box. Ensure that sharps are well taped or boxed before they are double-contained. Note: Consult the appropriate environmental compliance coordinator or the radioactive and mixed waste operations contact for assistance in determining appropriate packaging for radioactive waste.
• Ensure that the outer container is labeled appropriately for waste parcels, as described in Step 4.

• Request a radiological survey by the appropriate Radiation Protection Representative when the waste parcel is full and double-contained (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 8, "Monitoring Areas and Material") to facilitate pick-up of the waste parcel by the WMPPD.
• Consult the appropriate Radiation Protection Representative for assistance in completing a "Caution Radioactive Material" information tag or a "Caution Radioactive Material" information label to be placed on the waste parcel (see Figure 1 and Figure 2).

Collect liquid radioactive waste in an appropriate rigid container (plastic, glass, or metal) that has a screw-cap lid, such as a carboy, or collect it in an approved drum. Before the container is used:

• Consult the radioactive and mixed waste operations contact for assistance on the appropriate container for the liquid waste.
• Ensure that the container is compatible with the liquid waste.
• Visually evaluate container integrity and respond appropriately on SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form.

Note: Keep the waste container closed at all times, except when waste is being added or removed.

Perform the following immediately after liquid radioactive waste is placed in the waste parcel:

• Affix a "Caution Radioactive Material" warning label (see Figure 3) or "Danger, Radioactive Material" warning label (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 2, “Posting and Labeling for Radiological Control”). Consult the appropriate Radiation Protection Representative for assistance on which label to use.
• Consult the appropriate Radiation Protection Representative to determine whether a radiological survey is required during accumulation and to determine whether a "Caution Radioactive Material" information tag or, "Caution Radioactive Material" information label is required during accumulation (see Figure 1 and Figure 2).
• Fill in the appropriate information on the information tag or label, if required to be attached to the waste parcel during accumulation.
• Affix a "Caution Tritium Waste" warning label (Figure 4) to the waste parcel if more than 1 millicurie of tritium is estimated to be present in the waste.
• Record the start date (the date that radioactive waste is first placed in the parcel) on the waste parcel.
• Record a tracking number on the waste parcel. This waste parcel tracking number must include the six-digit Disposal Request (DR) number followed by a two-digit sequential number (e.g., 081148-01, 081148-02, and so on for multiple parcels on the DR).

• Ensure that the gross weight of the waste parcel does not exceed the maximum allowable gross weight, as stamped on the container or according to DOT regulations. Note: Consult the radioactive and mixed waste operations contact for assistance with this determination.
• Allow adequate headspace in a container of liquid waste such that pressure buildup does not cause leakage from the container.
• If liquid radioactive waste requires solidification and/or other treatment, then fill the container no more than 50 percent full to allow sufficient space for WMPPD Treatment Team operations. Note: Consult the radioactive and mixed waste treatment contact to determine if solidification or other treatment is required.

Prepare the liquid waste parcel for pick-up as follows:

• If the liquid waste accumulation container is glass, pack it into a sealable metal can with vermiculite or other appropriate material that holds the liquid container upright and prevents breakage.
• Place the liquid waste parcel into a bag for double-containment, unless the container is a carboy, a sealable metal can, or a drum.

• Request a radiological survey by the appropriate Radiation Protection Representative to facilitate pick-up of the waste parcel by the WMPPD (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 8, "Monitoring Areas and Material").
• Consult the appropriate Radiation Protection Representative for assistance in completing a "Caution Radioactive Material" information tag or a "Caution Radioactive Material" information label to be placed on the waste parcel (see Figure 1 and Figure 2).

• Segregate and control mixed waste to meet applicable RCRA requirements, state requirements, and treatment or disposal site waste acceptance criteria. Lack of appropriate segregation could severely impact waste disposal options.
• See the topic Hazardous Waste Determination in ESH100.2.ENV.22, Manage Hazardous Waste at SNL, for additional information for SNL sites, other than SNL/CA, on segregation of potential RCRA-regulated waste.
• Contact the SNL/CA waste management program lead, for additional information for SNL/CA, on segregation and characterization of potential RCRA-regulated and state-regulated waste (also, see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA).
• Segregate radioactive waste by physical form into separate waste parcels (for example, metal debris, soil, soft waste, liquid, filters), unless otherwise documented in a technical work document. Note: Consult the waste characterization project leader for assistance.
• Segregate classified radioactive waste from non-classified radioactive waste.
• Manage accountable nuclear material appropriately.

Note: For additional information see “Radioactive & Mixed Waste Management Waste Segregation Requirements.”

Ensure that the following prohibited waste types are not present in low-level waste to be disposed at the Nevada National Security Site (NNSS):

• Transuranic waste.
• Hazardous waste regulated under RCRA or state-of-generation (California or New Mexico) regulations.
• Free liquids.
• Compressed gases (unpunctured aerosol cans included).
• Etiologic agents (such as pathogens or infectious waste).
• Chelating agents (greater than 1 percent by weight).
• Polychlorinated biphenyls (PCBs) that do not meet the standards for disposal in solid waste or permitted landfills under 40 CFR 761, “Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions.”  See ESH100.2.ENV.3, Manage PCBs, PCB Containers, and PCB Sources Safely, for additional information.
• Explosives.
• Pyrophorics.
• Animal carcasses that are preserved in formaldehyde.
• Waste that exceeds radionuclide limits for disposal provided in the Nevada National Security Site Waste Acceptance Criteria (NNSSWAC), unless approved by NNSS.

Note: Consult the waste certification official for assistance with managing the above wastes. See form RF 2042-NCI, NNSS Non-Conforming Items, and see Section 3.1 of the NNSSWAC for more information on NNSS requirements related to these prohibited waste types.

Ensure that the following special wastes are segregated, packaged, and labeled appropriately when present in low-level waste to be disposed at the NNSS:

• Beryllium greater than 0.1 percent that might be released as an airborne particulate must be packaged and labeled appropriately in sealed, impermeable 6‑mil bags or containers. Notes:
  • For SNL/NM, see ESH100.2.IH.24, Manage and Control Beryllium Exposures, under “Forms, Links, and Tools,” for a sample beryllium waste label for SNL/NM.
  • For SNL/CA, beryllium-contaminated radioactive waste is regulated as mixed waste. For additional requirements regarding management and labeling, see ESH100.2.ENV.24, Manage Mixed Waste at SNL. Also, see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA, and contact the SNL/CA waste management program lead.
• Sealed sources that have an activity of 100 microcuries or greater must be segregated from other waste.
• Low-level waste that contains regulated asbestos must be packaged, marked, and labeled in accordance with applicable requirements. Notes:
  • For SNL/NM, see Figure 5, Sample Danger Contains Asbestos Fibers Label, for a sample regulated asbestos waste label.
  • For SNL/CA, radioactive waste containing regulated asbestos is regulated as mixed waste. For additional requirements regarding management and labeling, see ESH100.2.ENV.24, Manage Mixed Waste at SNL. Also, see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA, and contact the SNL/CA waste management program lead.
  Classified waste.
• Animal carcasses containing radioactive materials must be packaged appropriately.
• Polychlorinated biphenyls (PCBs) that meet the standards for disposal in solid waste or permitted landfills under 40 CFR 761, “Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions.”  See ESH100.2.ENV.3, Manage PCBs, PCB Containers, and PCB Sources Safely, for additional information.
• Particulates less than 200 micrometers in diameter must be packaged appropriately in 6-mil liners or immobilized.

Note: Consult the waste certification official for assistance with managing the above special wastes. See RF 2042-NCI, NNSS Non-Conforming Items, and see Section 3.1 of the NNSSWAC for more information on NNSS requirements related to segregation, packaging, and labeling of these wastes.

• Segregate radioactively contaminated brass and radioactively contaminated electronics.
• Manage these wastes as mixed waste (see ESH100.2.ENV.24, Manage Mixed Waste at SNL) unless characterization is completed to prove the waste is not RCRA regulated or state regulated.

Document radioactive waste items placed into a waste parcel, as applicable, using the Generator Waste Accumulation Disposal Log form (found in SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form), or an equivalent form.

Note: The Generator Waste Accumulation Disposal Log form is for heterogeneous waste, such as metal debris. The Generator Waste Accumulation Disposal Log form is not required if the waste in the waste parcel is a homogeneous waste, such as soil from one site, liquid from one process, or soft personal protective equipment from one process.

• Implement administrative controls on the waste parcel to ensure that only allowable items are placed in the waste parcel. Note:
• It is recommended that form RF 2042-TRS, NNSS Allowable Items, be prepared and placed on the waste parcel as a reminder of the only waste items that are allowed to be placed in the waste parcel.
• Maintain controls and traceability of waste parcels until they are picked up by the WMPPD.

• Use sampling and analysis to complete characterization of the waste parcel when process knowledge and waste control measures are not adequate for complete characterization.
• Ensure that samples of waste are collected by trained Members of the Workforce according to specific sampling procedures.

Notes:

• For additional information see “Radioactive & Mixed Waste Management Waste Sampling & Analysis.”
• The primary waste generator pays the costs of sampling and analysis as part of the requirements to meet POL 95-01, Programmatic Waste Acceptance Criteria.

Consult with the waste characterization project leader for assistance with the following:

• Developing a sampling and analysis approach such that data is representative of the waste, and determining whether a sampling and analysis plan is needed.
• Sampling the waste.
• Interfacing with the appropriate Radiation Protection Representative for radiation protection coverage during the sampling event and for acquiring radiological survey data that could aid in characterization of the waste.
• Interfacing with the on-site radiation protection sample diagnostics (RPSD) contact or the sample management office (SMO) contact. Note: SNL has some radiological laboratory capabilities, but not full capabilities. For some analyses, samples must be sent by the SMO to a commercial laboratory that is state-certified or DOE-certified.
• Complete any necessary forms.

Perform the following when a sampling and analysis plan is required for a project:

• Write the plan in accordance with PLA 96-02, Sampling and Analysis Plan for Characterization of Low-Level Radioactive and Mixed Waste.
• Ensure that the plan is reviewed by appropriate subject matter experts and by the Waste Characterization Team, and that the plan is approved.
• Develop a schedule for updating the plan and supporting procedures in use.

Ensure that a sampling and analysis data package has gone through data validation, as appropriate.

Note: Consult the waste characterization project leader for assistance on data validation. The waste characterization project leader must determine whether data validation is required for a specific data package. If required, the SMO must perform data validation.

Document why sampling and analysis could not be performed, if it is unsafe or impractical to obtain representative samples because of high radioactivity or because of the heterogeneity of the waste material.

Notes:

• Sampling and analysis also may not be required if process knowledge and waste control measures are sufficient to estimate the activity of each radionuclide contaminant and to ensure that there is no RCRA-regulated waste, state-regulated waste, or other prohibited item present (see Segregation and Control of Radioactive Waste).
• Naturally occurring radioactive material (NORM) and other radioactive materials that are exempt from regulation (see MN471016, Radiological Protection Procedures Manual (RPPM), Attachment 6-2, "Exempted Items List") may be present in some commercial products, including building materials, thoriated welding rods, Coleman® lantern mantles, glass that contains thorium or uranium for coloring purposes, camera lenses, and ceramics.
• Wastes containing naturally occurring or other exempt radioactive materials do not require management as radioactive waste, provided the criteria in the Release of Non-Radioactive Waste subsection are met. Consult the appropriate environmental compliance coordinator or the waste characterization project leader for assistance.

• Do not conduct treatment of radioactive waste unless written approval is obtained through the appropriate environmental compliance coordinator and the radioactive and mixed waste treatment contact. Notes:
  • Examples of treatment of radioactive waste that might be conducted by the primary waste generator include:
    • Solidification.
    • Volume-reduction, such as by compaction.
    • Evaporation.
  • In some cases, processing of material or treatment of mixed waste at the generator location may be the most efficient and cost-effective approach. In most cases, it is preferred that treatment of mixed waste be performed by the Waste Management and Pollution Prevention Department (WMPPD) following waste pick-up. 
• Use an appropriate treatment method so that the disposal site can meet its performance objectives. Note: If primary waste generators treat radioactive waste, they should consult the radioactive and mixed waste treatment contact or waste certification official for assistance in developing an appropriate treatment method.
• Document the method used to treat radioactive waste.
• Perform the following when treating radioactive waste by solidification:
  • Document the type and amount of solidification agent used to treat the radioactive waste.
  • Obtain the solidification agent from the radioactive and mixed waste treatment contact.
  • If liquid radioactive waste requires solidification, fill waste containers less than 50 percent full to allow sufficient space for addition of solidification agent.

Do not do any of the following with radioactive waste:

• Allow the waste to enter sanitary sewer lines or storm sewers via sinks, toilets, etc.
• Bury the waste or release it to the ground, either directly or indirectly.
• Discard the waste into trash cans or dumpsters.
• Remove the waste from Sandia-controlled premises.
• Dilute radioactive waste.
• Manage radioactive waste in any manner that could be construed as disposal.

Do not include any information on process knowledge documents or disposal request forms (SF 2042-TRA) that are submitted with regard to classified waste that would cause the documents to be a classified document. 

Note: Consult the appropriate environmental compliance coordinator for assistance in completing the DR.

• Complete SF 2042-TRA, Radioactive or Mixed Waste Disposal Request (DR) form to request pick-up of radioactive waste by the WMPPD . Note: Consult the environmental compliance coordinator for assistance in completing the DR.
• Record each waste parcel on the DR. Note: Multiple radioactive waste parcels can be submitted on one DR, but the waste in each parcel must be of the same physical form as indicated on the DR, unless an exception is granted by the waste characterization project leader.
• Sign the Generator Waste Accumulation Disposal Log (if completed) for each waste parcel.
• Record the start date (the date that waste is first placed in a waste parcel) on the DR.
• Provide a project and task number on the DR to pay the chargeback rate by volume of radioactive waste to be picked up.
• Complete the DR.
• Sign the DR.
• Obtain the appropriate environmental compliance coordinator review and signature on the DR.
• Attach the documents shown in Table 1 to the DR.
• Do not add waste to a waste parcel for which the SF 2042-TRA has been submitted. Note: In general, a minimum of 1 month is needed from disposal request submittal to waste pick-up, when there are no questions, and no additional information is needed to complete the review or the DR form.
• Submit the DR to the radioactive and mixed waste operations contact in a timely manner, such that the waste is picked up within 1 year of the start date. Notes:
  • Primary waste generators should make a copy of the DR for the project file.
  • Once the WMPPD approves the DR, the WMPPD pick-up crew must call to schedule pick-up of the radioactive waste.
  • If the waste parcel cannot be picked up by the WMPPD in accordance with the WMPPD waste acceptance criteria (see SNL, POL 95-01, Programmatic Waste Acceptance Criteria [WAC]), then consult the radioactive and mixed waste operations contact for assistance in determining an appropriate storage area for the waste near the generator location, and in developing a packaging method to meet waste acceptance criteria.

• Contact the waste certification official for assistance in meeting requirements such that the waste parcel can be certified.
• Provide additional information that might be required by the waste certification official during certification or assessment activities.
• Provide additional information that might be required by the intended disposal facility to the waste certification official.

Notes:

• The waste certification official periodically observes waste packaging activities that are conducted by the primary waste generator.
• The waste certification official periodically assesses waste management activities that are conducted by the primary waste generator. A report is generated and provided to the primary waste generator, as appropriate. If a finding is identified, see Nonconformances.

Ensure that:

• Your manager is notified.
• An RF 2042-NCA, Nonconformance Corrective Action Report, is completed for the nonconformance and submitted to the WMPPD quality assurance program project leader.
• Corrective actions identified in the Nonconformance Corrective Action Report are implemented and documentation of implementation is provided to the WMPPD quality assurance program project leader.

Notes: Primary waste generators should:

• Implement the OOPS process as appropriate.
• Conduct and document self-assessments for compliance with radioactive waste management requirements.

Do not dispose of radioactive waste in solid waste landfills or Resource Conservation and Recovery Act (RCRA) treatment, storage, and disposal facilities (TSDFs) unless those facilities are appropriately licensed by an agreement state or by the Nuclear Regulatory Commission (NRC) to receive such waste.

Note: Since radioactive materials are prevalent in nature and in common products, it is necessary to distinguish between waste that must be regulated as radioactive waste or waste that is non-regulated.

Use the following release criteria to determine and document whether waste can be managed and disposed of as non-radioactive waste:

• Residual surface radioactivity on the waste is as low as reasonably achievable and below the authorized limit for unrestricted release, as found in MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 6, “Control of Radioactive Material,” Attachment 6-1, "Radioactive Contamination Limits."
• The waste is determined to contain no detectable Sandia-added residual radioactivity in mass or volume, using detection methods described in RPTB-013,Technical Basis for Liquid Scintillation, Gas Flow Proportional and Gamma Spectrometry Counting Times Used for Material Clearance, and include process knowledge.
• The waste contains only naturally occurring radioactive material (NORM), which has not been enhanced by a Sandia process.
• The waste consists of consumer products that are exempt from licensing as by-product material or source material. See Manage Consumer Products for additional information.
• The waste contains SNL-added residual radioactivity that does not meet the criteria stated above, but for which DOE-approved authorized limits (dose or risk-based limits) have been established, provided:
  • The receiving facility is notified of the authorized limits and accepts custody of the waste.
  • The radiation control authority for the NRC or the agreement state concurs with the established limits.
  • If applicable, any restrictions established as part of the authorized limit approval (i.e., specific disposal facility, specific handling precautions, etc.) can be demonstrated to be in place.

Notes:  

• The above release criteria are intended to meet the general prohibition on disposal of radioactive waste at solid and hazardous waste disposal facilities. More restrictive release criteria may be developed on a case-by-case basis to meet specific waste acceptance criteria imposed by a receiving disposal facility.
• For wastes with no reasonable potential for Sandia-added residual radioactivity, these criteria may be met by process knowledge.

Primary waste generators

Dispose of conditionally controlled material waste, either as radioactive waste or mixed waste, as appropriate, in accordance with ESH100.2.ENV.23, Manage Radioactive Waste at SNL, or ESH100.2.ENV.24, Manage Mixed Waste at SNL.

Note: Conditionally controlled material, as listed in the Radiological Protection Procedures Manual (RPPM), is not exempt from licensing and regulation.

• Do not bulk together exempt items in such a manner as to pose a potential radiological hazard and dispose of them as solid waste.
• Manage waste as radioactive waste or mixed waste, as appropriate, if items are bulked together so as to pose a potential radiological hazard.

Notes:

• See MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 6, “Control of Radioactive Material,” Attachment 6-2, “Exempted Items List.”