Rad Waste or Not?

["Oldewage, Hans D" <HDOLDEW@SANDIA.GOV>]

I realize that this may be an elementary question to some, but I suspect I

am not alone...



What is radioactive waste? - or more importantly -  What is not radioactive

waste?  



Once declared radioactive waste, the distinction between high-level, spent

fuel, TRU, and the various classifications of low-level radioactive waste is

relatively clear to me.



I think the root question is (or should be): "is the material regulated

under the Atomic Energy Act?"  If it is regulated under the AEA, then once

declared waste, it is one of the types of radioactive waste mentioned above.

If not, it's not.  Radioactive waste would not include such things as

naturally occurring radioactive materials or unimportant quantities of

source or byproduct materials (i.e., quantities exempted from licensing by

the NRC, or authorized for release from control by the NRC or DOE, under the

authority of the Atomic Energy Act).  



I realize that some states (including ours - New Mexico) have specific NORM

regulations for the oil and gas industry, but that is outside the scope of

this question.



I would be interested in any feedback you can provide on how your facility

(be it DOE or NRC-licensed) makes the initial decision that something is or

is not a radioactive waste.  Some specific examples that we are struggling

with are:

1.  Consumer products (such as construction materials/demolition debris)

containing measurable background levels of naturally occurring radioactive

materials;

2.  Consumer products containing unintentionally enhanced measurable

concentrations of NORM (such as some ceramics, fire bricks, insulating

materials, etc.) - not enhanced by us.

3.  Consumer products containing intentionally enhanced concentrations of

NORM (such as exempt quantities of source material in thoriated welding

rods) - again, not enhanced by us;

4.  Other exempt quantity materials, either source or byproduct materials;

5.  Materials released from controlled areas with detectable surface

contamination below NUREG 1.86 or DOE Order 5400.5 unrestricted release

limits.



If you are inclined to respond, please include whether you are an NRC

licensee or DOE facility, and the state where your facility resides.  



Please respond to me directly (hdoldew@sandia.gov), and I will gladly post

some kind of summary of the responses back to RADSAFE at a later date.



Thanks,

Hans

=======================

Hans Oldewage

Sandia National Laboratories

(505)845-7728

hdoldew@sandia.gov





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