1. U.S. Department of Energy Perspectives on Waste Classification
Doug Tonkay
Director, Office of Waste Disposal
LLW Forum Spring 2019 Meeting
April 17, 2019

2. Introduction
US Department of Energy (DOE) Manual identifies requirements for radioactive waste management
Purpose of the Manual
“…manage DOE’s radioactive waste in a manner that is protective of worker and public health and safety, and the environment.”
Risk-informed, performance-based approach for low-level radioactive waste (LLW) classification for on-site disposal
Can consider waste form, containers, barriers, and site conditions
Inadvertent human intrusion also considered
Specific concentration values used to identify transuranic (TRU) waste
High-level radioactive waste (HLW) classified based on origin, but processes available to reclassify based on hazard

3. Nuclear Safety Regulatory Framework
As of : 19 Policies, 126 Orders, and 9 Manuals
DOE Policy ~ IAEA Fundamentals
DOE Orders/Manuals ~ IAEA Requirements
DOE Guides ~ IAEA Guides

4. DOE Directives

5.
Order Chg 1= July 9, 1999 Approved date
DOE O A = Sept 26, 1988 Approved date
DOE O = Feb, 6, 1984 Approved date

6. Facilities USDOE On-Site Facilities and Commercial Options
Idaho National Laboratory
Idaho CERCLA Disposal Facility
RWMC LLW Disposal Facility
Idaho Tank Farm Facility
Remote-Handled LLW Facility
Hanford Site
200 West Burial Grounds
200 East Burial Grounds
Integrated Disposal Facility
ERDF
18 Tank Farms
Fernald
Energy Solutions
Portsmouth
Waste Isolation
Pilot Plant
Weldon Spring
Paducah
Savannah River Site
E Area LLW Facility
Saltstone Disposal Facility
F Area Tank Farm
H Area Tank Farm
Waste Control
Specialists
Nevada National Security Site
Area 5 Rad Waste Management
Area 3 Rad Waste Management
Area 5 RCRA Disposal Facility
Los Alamos National Laboratory
Technical Area 54, Area G
Oak Ridge
EM Waste Management Facility
EM Disposal Facility
SWSA 6
Note the distance and differences (e.g. west versus east, climate, remoteness, etc.)
Avg Annual precip: Idaho Falls = 10.95”, Richland = 7.67”, Los Alamos = 18.86”, Oak Ridge = 55.51”, Pikeville = 52.87” from
Also note the difference between activity versus volume disposal
Existing CERCLA Disposal Facility
LLW Operations Disposal Facility/Tank Farm Closure
Closed Disposal Facility
Proposed CERCLA Disposal Facility
Proposed LLW Disposal Facility/Tank Farm Closure
Facilities
Commercial LLW Disposal Facility

7. Spectrum of Facilities for DOE LLW – DOE Sites
Risk-informed, performance-based approach to identify appropriate disposal; have option to send some waste to off-site facility
Idaho CERCLA Disposal Facility
Double liner, leachate collection
Soils, debris, some large items
Nevada Nuclear Security Site
Unlined trenches, containerized waste
Wide variety of wastes
Mention reactor vessel disposal at ICDF as an example of a unique waste stream…if NRC question on disposal mention Trojan vessel at US Ecology in WA
Saltstone Disposal Facility
Cementitious waste form
Concrete barriers
Savannah River Site Vaults
Reinforced concrete vaults
Wide variety of wastes, voids filled with grout
HLW Tank Closure
Cementitious fill planned
Concrete and steel tanks

8. Spectrum of Facilities for DOE LLW – Commercial
State regulated facilities, use US Nuclear Regulatory Commission (NRC) classification system with a performance assessment
Waste Control Specialists (WCS)
Concrete lined, deep cell
Class A, B, and C LLW and Mixed LLW in Federal Waste Facility
Energy Solutions of Utah (ES) Clive Facility
Disposal cells
Class A LLW and Mixed LLW

9. International Atomic Energy Agency (IAEA)
Comparisons to
International Atomic Energy Agency (IAEA)
DOE uses disposal facilities similar to Very LLW, LLW and Intermediate Level Waste (ILW) facilities as described by IAEA, but does not use the terms VLLW or ILW for definitions
DOE generators have access to commercial options that are equivalent to VLLW
WCS Exempt RCRA,
Bulk Survey for Release (BSFR) in Tennessee, and
Other potential options through authorized limits e.g. US Ecology Grand View, Idaho
While DOE currently defines HLW based on the origin of the waste rather than the presence of significant heat generation and radionuclide activity as described by IAEA, this is currently under review by DOE. 9

10. Oversight
State regulators, U.S. Environmental Protection Agency, and U.S. NRC can be involved for on-site disposal and site closure
Disposal at commercial facilities is regulated by NRC Agreement States
Public involvement during planning and decision process (e.g., National Environmental Policy Act (NEPA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
DOE has independent oversight organizations (e.g. Low-Level Waste Disposal Facility Federal Review Group (LFRG) and Office of Enterprise Assessment (EA))
Not just DOE conducting oversight of facilities and activities; not just doing what we want to do.
LFRG has members from both HQ and the field from EM, SC, AU, NE, and in the future LM