CHALLENGES WITH RETRIEVING TRANSURANIC WASTE FROM THE HANFORD BURIAL GROUNDS

The U.S. DOE's Hanford Reservation produced plutonium and other nuclear materials for the nation's defense starting in World War II. The defense mission generated wastes that were either retrievably stored (i.e. retrievably stored waste) and/or disposed of in burial grounds. Challenges have emerged from retrieving suspect TRU waste including adequacy of records, radiological concerns, container integrity, industrial hygiene and safety issues, the lack of processing/treatment facilities, and the integration of regulatory requirements. All retrievably stored waste is managed as mixed waste and assumed to be TRU waste, unless documented otherwise. Mixed waste is defined as radioactive waste that contains hazardous constituents. The Atomic Energy Act governs waste with radionuclides, and the Resource Conservation and Recovery Act (RCRA) governs waste with hazardous constituents. Waste may also be governed by the Toxic Substances Control Act (TSCA), and a portion may be managed under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). In 1970, TRU waste was required to be placed in 20-year retrievable storage and segregated from other Waste. Prior to that date, segregation did not occur. Because of the changing definition of TRU over the years, and the limitations of early assay equipment, all retrievably stored waste in the burial grounds is managed as suspect TRU. Experience has shown that some of this waste will be characterized as low-level (non-TRU) waste after assay. The majority of the retrieved waste is not amenable to sampling due to waste type and/or radiological issues. Key to waste retrieval and disposition are characterization, historical investigation and research, knowledge of past handling and packaging, as well as a broad understanding and application of the regulations