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Waste Stream Definition



I really need some help from anyone experienced with Waste Characterization issues.  Please reply if you have characterization experience only.



DOE Implementation Guide "DOE G 435.1-1 page III-3 states that Dilution of a Transuranic Waste Stream to reclassify the waste as low-level waste is not permitted"  My question is this.



How do you define "Waste Stream"?



Is it, for example a room, that has waste in it with similar properties, or is it individual piles of waste within the same room?



Here is a situation.



Within a crane room, you have waste with activity that has basically the same ratios of materials radiologically and chemically.  If you pick up a pile of light weight material in this room, you can be above 100 nCi/g long lived alpha (TRU waste limit), but if you take this small pile of material and package it with other materials from the same crane room, the final packaged activity will be below the 100 nCi/g.  



The question?  Since this waste is all from the same area, can I package it to be <100 nCi/g or once I look at a small quantity of it that is above TRU limit, do I have to segregate that quantity and package it as TRU waste so that I do not violate the NO DILUTION requirement? 



I really could use some experienced opinions here.



Thanks

Dave Biela





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