WASTE CERTIFICATION PROGRAM PLAN - REVISION 7 Page: 24 of 72
This report is part of the collection entitled: Office of Scientific & Technical Information Technical Reports and was provided to UNT Digital Library by the UNT Libraries Government Documents Department.
Extracted Text
The following text was automatically extracted from the image on this page using optical character recognition software:
4.3 NRA DETERMINATION FOR HAZARDOUS WASTE
4.3.1 Introduction
NRA determination is one of the requirements in the WAC for hazardous waste to be
shipped to an off-site commercial TSD facility that is not licensed to handle radioactivity. The
requirement is mandated by the DOE Performance Objective for Certification of Non-
Radioactive Hazardous Waste issued in 1995. The decision to pursue an NRA determination for
a hazardous waste package is based on having adequate and appropriate PK for the package or
on the amount of analysis required to make a determination. Analysis beyond that which is
required to meet WAC or analytical expenditures that are not cost-effective based on the type
and volume of waste are neither required nor desirable. NRA determinations will be based on
documented PK, surface surveys, sampling and analysis or a combination of these methods.
Hazardous waste that does not qualify for NRA will be classified as mixed waste.
4.3.2 Scope and Limitations
NRA classification requirements apply to hazardous waste as defined in 40 CFR 261-
268 and Tennessee (TN) Rule 1200-1-11-.01 to .10 as RCRA regulated and waste defined by 40
CFR 761 as TSCA-regulated. Recyclables including used oil, silver sludge, and fluorescent
bulbs are specifically excluded from the NRA determination process under this plan, but are
subject to ORNL Procedure, ORNL-RP-420 for free release of materials. Hazardous waste is
eligible for NRA evaluation when there is no evidence that would indicate that the waste has
radioactivity added resulting from DOE operations.
4.3.3 NRA Determination Process
Generator determination of adequate PK is the first step in the process (Figure 4). If
adequate PK exists, classification of waste as NRA requires only documentation of the PK by the
generator [and a surface survey if the waste is being removed from a Radioactive Materials
Management Area (RMMA)]. If adequate PK does not exist, a surface survey and/or sampling
and analysis is required. Certification Process control points and Certification Process step
reviews are incorporated into the NRA process by reviewing the generator RFD forms to ensure
that the documentation, including the PK and any analytical results, is sufficient for making the
NRA determination.
The NRA determination process allows maximum use of any PK that exists for a waste
item. Generators are encouraged to collect and document as much PK information as possible
about the material while it is being used, generated, and stored. PK is useful in two ways. First,
with sufficient PK, wastes can be classified as NRA without additional sampling and analysis
(although a surface survey is required per DOE Order 5400.5 and 10 CFR 835 if the waste is
exiting an RMMA). Second, if PK is insufficient to classify the waste as NRA, the information
may be used to limit the analysis that would be required for NRA classification or mixed waste
characterization. Guidance on what constitutes adequate PK for NRA has been issued in WM-15-
Upcoming Pages
Here’s what’s next.
Search Inside
This report can be searched. Note: Results may vary based on the legibility of text within the document.
Matching Search Results
View nine places within this report that match your search.Tools / Downloads
Get a copy of this page or view the extracted text.
Citing and Sharing
Basic information for referencing this web page. We also provide extended guidance on usage rights, references, copying or embedding.
Reference the current page of this Report.
MORGAN, LK. WASTE CERTIFICATION PROGRAM PLAN - REVISION 7, report, January 8, 2002; United States. (https://digital.library.unt.edu/ark:/67531/metadc733998/m1/24/?q=technical+manual: accessed July 17, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.