National spent fuel program preliminary report RCRA characteristics of DOE-owned spent nuclear fuel DOE-SNF-REP-002. Revision 3

This report presents information on the preliminary process knowledge to be used in characterizing all Department of Energy (DOE)-owned Spent Nuclear Fuel (SNF) types that potentially exhibit a Resource Conservation and Recovery Act (RCRA) characteristic. This report also includes the process knowledge, analyses, and rationale used to preliminarily exclude certain SNF types from RCRA regulation under 40 CFR {section}261.4(a)(4), ``Identification and Listing of Hazardous Waste,`` as special nuclear and byproduct material. The evaluations and analyses detailed herein have been undertaken as a proactive approach. In the event that DOE-owned SNF is determined to be a RCRA solid waste, this report provides general direction for each site regarding further characterization efforts. The intent of this report is also to define the path forward to be taken for further evaluation of specific SNF types and a recommended position to be negotiated and established with regional and state regulators throughout the DOE Complex regarding the RCRA-related policy issues