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Re: Mixed Waste

To: radsafe@romulus.ehs.uiuc.edu
Subject: Re: Mixed Waste
From: Hans Honerlah <hansbh1@yahoo.com>
Date: Mon, 24 Apr 2000 12:21:30 -0700 (PDT)
Not to beat a dead horse, 
I agree with Bill, this waste does not appear to be a
listed wasted under RCRA.  You must test for the
ignitability of the waste (characteristic waste,
D001). If the material meets the definition of a
characteristic waste, due to ignitability, it is then
considered a mixed waste until the material is treated
to remove the characteristic that classified it as
mixed (i.e. D001).  The determination of the D001 is
based upon flashpoint and boiling point as defined
within the regulations.  

There are several options for toluene as a
characteristic waste.  To remove the characteristic
(D001) you must meet the treatment standards
technologies DEACT and the universal treatment
standards or technologies RORGS or technologies CMBST
(the technology codes are listed in 40 CFR 268.42
Table 1, 1998 version)

If the waste has a characteristic hazardous waste it
would be a mixed waste until the waste stream is
treated to remove the characteristic, leaving
radioactive waste.

Sounds like a pretty big circle and it can be.

The opinions expressed are mine, mine, mine bla, bla

Hans Honerlah
USACE, Baltimore

--- William V Lipton <liptonw@dteenergy.com> wrote:
> (1) The short answer:  It doesn't have to make
> sense, read the regulations.
> 
> (2) A better answer:  For the EPA, there are 2
> categories of RCRA wastes:  (a)
> listed wastes:  Wastes from certain processes are
> presumed hazardous.  One of
> these, F005, is the use of toluene and certain other
> non-halogenated, organic
> materials as a solvent.  (b) characteristic wastes: 
> corrosivity, reactivity,
> ignitability, and toxicity.  The toxicity
> characteristic involves specified
> materials.  Toluene is NOT a toxicity
> characteristic.  Thus, waste toluene as a
> spent solvent is RCRA regulated, but waste toluene
> as a reagent is not.
> Although this may not make sense to a "simple-minded
> chemist," it is the EPA's
> version of ALARA.  The EPA's rationale is to control
> those processes which have
> a significant environmental impact.  They apparently
> feel that, while toluene is
> not so toxic as to be a hazardous characteristic,
> the use of toluene is a
> solvent should be discouraged and regulated.  Thus,
> with RCRA wastes, process
> knowledge is as important as analytical results. The
> best way to manage
> hazardous waste is to avoid generating it in the
> first place.
> 
> (3) Your comment that, "As an organic solvent, it
> shouldn't be disposed of in a
> landfill." is in complete agreement with RCRA.  This
> is addressed in the "Land
> Disposal Restrictions" which require treatment of
> hazardous waste before
> disposal.  "Nonwastewater," F005 wastes must be
> treated so that the toluene
> concentration is less than 10 mg/kg.
> 
> The opinions expressed are strictly mine.
> It's not about dose, it's about trust.
> 
> Bill Lipton
> liptonw@dteenergy.com
> 
> 
> ruth_weiner wrote:
> 
> > You know, as a simple-minded chemist, I don't
> understand this.  Toluene is
> > an organic solvent as well as a reagent, no matter
> where it is used.  Excess
> > toluene from a reaction or a separation process
> that is contaminated with
> > other reagents is a waste material -- an organic
> waste.  If it is
> > contaminated with radioactive material, it would
> be a mixed waste.  As an
> > organic solvent, it shouldn't be disposed of in a
> landfill.  It can be
> > absorbed and the absorbent disposed of, I guess --
> I am not up on the
> > regulations.
> >
> > Ruth Weiner
> > ruth_weiner@msn.com
> > -----Original Message-----
> > From: William V Lipton <liptonw@dteenergy.com>
> > To: Multiple recipients of list
> <radsafe@romulus.ehs.uiuc.edu>
> > Date: Saturday, April 22, 2000 4:58 AM
> > Subject: Re: Mixed Waste
> >
> > >Toluene is an F005 waste only if it is a "spent
> solvent."  It's thus
> > important
> > >to find out where it originated.  Toluene is
> often used as a reagent in
> > >chemistry labs.  If that is its origin, then it's
> not F005.
> > >
> > >The opinions expressed are strictly mine.
> > >It's not about dose, it's about trust.
> > >
> > >Bill Lipton
> > >liptonw@dteenergy.com
> > >
> > >David Lovett wrote:
> > >
> > >> This is a multi-part message in MIME format.
> > >>
> > >> ------=_NextPart_000_00FF_01BFAAF0.50E19FE0
> > >> Content-Type: text/plain;
> > >>         charset="iso-8859-1"
> > >> Content-Transfer-Encoding: quoted-printable
> > >>
> > >> Radsafers, need some help here.
> > >>
> > >> This station's radwaste system has an inline
> charcoal bed, that had been
> > =
> > >> in service for about six years, processing
> about one million gallons of =
> > >> waste water per year.  In 1999, the charcoal
> bed was exhausted and its =
> > >> contents discharged to the spent resin tank
> (SRT).
> > >>
> > >> In late 1999, the contents of the SRT were
> sluiced to a liner for =
> > >> disposal. This was a mixture of charcoal and
> demin resins, the demins =
> > >> are downstream of the demins.  A sample was
> taken for characterization =
> > >> prior to shipment for diposal.  The sample was
> analyzed for RCRA =
> > >> hazardous waste as well.
> > >>
> > >> The results on the radiological part, were
> within expectation, however =
> > >> the RCRA analysis showed levels of 120 ppb
> Toluene and Xylene, as well =
> > >> as the expected benzenes et al.  All compounds
> except Toluene and Xylene
> > =
> > >> were below RCRA and LDR criteria.  Xylene,
> 40CFR261.3 subpart D was =
> > >> discounted on the ignitability criteria.
> > >>
> > >> Toluene is a problem here in that the F005 code
> is listed and a =
> > >> justification for not classifying this waste as
> mixed waste is being =
> > >> sought.  Investigation into that history of
> this charcoal bed and =
> > >> documentation and interviews of plant personnel
> have not indidcated any =
> > >> particular incident that might have resulted in
> the introduction of =
> > >> organics into the resin/charcoal mix. =20
> > >>
> > >> Has anyone in the non-nuclear/nuclear
> experienced similar results, is =
> > >> this a mixed was, although < 10% by volume, and
> if any facility has =
> > >> handled the same how was it handled?
> > >>
> > >> Would appreciate a prompt response, the
> implications for the nuclear =
> > >> industry are profound.........
> > >>
> > >>  =20
> > >>
> > >> ------=_NextPart_000_00FF_01BFAAF0.50E19FE0
> > >> Content-Type: text/html;
> > >>         charset="iso-8859-1"
> > >> Content-Transfer-Encoding: quoted-printable
> > >>
> > >> <!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.0
> Transitional//EN">
> > >> <HTML><HEAD>
> > >> <META content=3D"text/html;
> charset=3Diso-8859-1" =
> > >> http-equiv=3DContent-Type>
> > >> <META content=3D"MSHTML 5.00.2919.6307"
> name=3DGENERATOR>
> > >> <STYLE></STYLE>
> > >> </HEAD>
> > >> <BODY bgColor=3D#ffffff>
> > >> <DIV><FONT size=3D2>Radsafers, need some help
> here.</FONT></DIV>
> > >> <DIV> </DIV>
> > >> <DIV><FONT size=3D2>This station's radwaste
> system has an inline =
> > >> charcoal bed,=20
> > >> that had been in service for about six years,
> processing about one =
> > >> million=20
> > >> gallons of waste water per year.  In 1999,
> the charcoal bed was =
> > >> exhausted=20
> > >> and its contents discharged to the spent resin
> tank (SRT).</FONT></DIV>
> > >> <DIV> </DIV>
> > >> <DIV><FONT size=3D2>In late 1999, the contents
> of the SRT were sluiced =
> > >> to a liner=20
> > >> for disposal. This was a mixture of charcoal
> and demin resins, the =
> > >> demins are=20
> > >> downstream of the demins.  A sample
> was taken for =
> > >> characterization=20
> > >> prior to shipment for diposal.  The sample
> was analyzed for RCRA =
> > >> hazardous=20
> > >> waste as well.</FONT></DIV>
> > >> <DIV> </DIV>
> > >> <DIV><FONT size=3D2>The results on the
> radiological part, were within =
> > >> expectation,=20
> > >> however the RCRA analysis showed levels of 120
> ppb Toluene and Xylene, =
> > >> as well=20
> > >> as the expected benzenes et al.  All
> compounds except Toluene and =
> > >> Xylene=20
> > >> were below RCRA and LDR criteria.  Xylene,
> 40CFR261.3 subpart D was
> > =
> > >>
> > >> discounted on the ignitability
> criteria.</FONT></DIV>
> > >> <DIV> </DIV>
> > >> <DIV><FONT size=3D2>Toluene is a problem here
> in that the F005 code is =
> > >> listed and=20
> > >> a justification for not classifying this waste
> as mixed waste is being=20
> > >> sought.  Investigation into that history
> of this charcoal bed and=20
> > >> documentation and interviews of plant personnel
> have not indidcated
> > any=20
> > >> particular incident that might have resulted in
> the introduction of =
> > >> organics=20
> > >> into the resin/charcoal
> mix.  </FONT></DIV>
> > >> <DIV><FONT size=3D2></FONT> </DIV>
> > >> <DIV><FONT size=3D2>Has anyone in
> the non-nuclear/nuclear=20
> > >> experienced similar results, is this a
> mixed was, although < 10%
> > =
> > >> by=20
> > >> volume, and if any facility has handled the
> same how was it=20
> > >> handled?</FONT></DIV>
> > >> <DIV><FONT size=3D2></FONT> </DIV>
> > >> <DIV><FONT size=3D2>Would appreciate a prompt
> response, the =
> > >> implications for=20
> > >> the nuclear industry are
> profound.........</FONT></DIV>
> > >> <DIV><FONT size=3D2></FONT> </DIV>
> > >> <DIV><FONT size=3D2> 
> </FONT></DIV></BODY></HTML>
> > >>
> > >> ------=_NextPart_000_00FF_01BFAAF0.50E19FE0--
> > >>
> > >>
>
************************************************************************
> > >> The RADSAFE Frequently Asked Questions list,
> archives and subscription
> > >> information can be accessed at
> http://www.ehs.uiuc.edu/~rad/radsafe.html
> > >
> >
>
>************************************************************************
> > >The RADSAFE Frequently Asked Questions list,
> archives and subscription
> > >information can be accessed at
> http://www.ehs.uiuc.edu/~rad/radsafe.html
> >
> >
>
************************************************************************
> > The RADSAFE Frequently Asked Questions list,
> archives and subscription
> > information can be accessed at
> http://www.ehs.uiuc.edu/~rad/radsafe.html
> 
>
************************************************************************
> The RADSAFE Frequently Asked Questions list,
> archives and subscription
> information can be accessed at
> http://www.ehs.uiuc.edu/~rad/radsafe.html
> 

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