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Re: Mixed Waste

To: radsafe@romulus.ehs.uiuc.edu
Subject: Re: Mixed Waste
From: William V Lipton <liptonw@dteenergy.com>
Date: Mon, 24 Apr 2000 15:41:38 -0400
References: <20000424192131.22446.qmail@web1301.mail.yahoo.com>
This horse is still twitching.

Good point about toluene having the potential to give the waste the
characteristic of  ignitability.  One nitpicking correction:  For RCRA,
boiling point is NOT a factor in determining ignitability.  (Boiling point IS
a factor for determining whether a material is DOT flammable.)  My
understanding is that the toluene is a trace contaminant in charcoal, so this
is unlikely to be ignitable, but this is still a consideration.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com


Hans Honerlah wrote:

> 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
> > > >
> > >
> >
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> > archives and subscription
> > > >information can be accessed at
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> > >
> > >
> >
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> > archives and subscription
> > > information can be accessed at
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> >
> >
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> > information can be accessed at
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> >
>
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- Re: Mixed Waste
  - From: Hans Honerlah <hansbh1@yahoo.com>
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