EPA Proposed Rule .... We need your support - forward

[Ted de Castro <tdc@XRAYTED.COM>]

I am forwarding this for a colleague not on RADSAFE since it is of

interest and importance to many here - please respond directly as

indicated below.



Thanks,



Ted de Castro



Dear Colleague:



I want you to be aware that the U.S. Environmental Protection Agency

(EPA) is proposing to grant two

petitions relating to the treatment of low-level mixed waste (LLMW). 

Although their proposal is

narrowly targeted to one facility in Government research, this proposal

has the potential to be generically

applied, and will have a very large impact for research organizations

all across the USA.



The EPA proposal is now out for public comment, with responses due by

September 16.  Your letter of

support is essential in facilitating the final rulemaking.



Specifically, the proposal is contained in the Federal Register/Vol. 67,

No. 147/Wednesday, July 31,

2002/pp. 49649-49656 "Hazardous Waste Management System; Proposed

Exclusion for Identifying and

Listing Hazardous Waste and a Determination of Equivalent Treatment."



In this rulemaking, the U.S. Environmental Protection Agency (EPA) is

proposing site-specific regulatory

relief from RCRA so that small volumes of treated mixed waste (LLMW) are

excluded from RCRA, and

the residues may be disposed as LLRW.



The EPA has determined that "the petitioned waste is essentially

tritiated water with no detectable

organic chemical constituents, and therefore we agree with the

petitioner that the petitioned waste is

nonhazardous with respect to the original listing criteria." [Federal

Register, Vol. 67, No. 147, 31 July

2002, p. 49650]. Furthermore, "LBNL has adequately demonstrated that the

CCO technology is

equivalent to combustion for the treatment of organic wastes."  [Federal

Register, Vol. 67, No. 147, 31

July 2002, p. 49650].  The EPA concludes that "We therefore propose to

grant LBNL an exclusion and a

DET for the waste generated by CCO treatment at LBNL."  [Federal

Register, Vol. 67, No. 147, 31 July

2002, p. 49654].



If the proposal becomes final, these determinations will serve as a

precedent for generators of tritiated

mixed waste throughout the USA. Widespread endorsement of EPA's position

will help implementation

of this approach at other sites.



To facilitate your support, please download a sample letter from the web

address listed below.  You can

easily modify it as you see fit, and mail it to the EPA.  Even though

this is a relatively narrow issue,

success here will lead to a much broader gain for the US research

community.



http://home.pacbell.net/pgwillia/delisting/index.html



Thanks for your support -- it is vital to the success of this petition

as a demonstration of working with the

EPA to gain regulatory flexibility on mixed waste issues.

Please contact Philip G. Williams at 510-486-7336 (w) or

pgwillia@pacbell.net if you have questions.

[RadSafe]



-- 



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*  Dr. Philip G. Williams               *  510/444-1640: Voice         *

*  3708 Lake Shore Avenue               *  510/763-1129: Fax           *

*  Oakland, CA 94610-1727, U.S.A.       *  pgwillia@pacbell.net        *

************************************************************************

*  Chair, Low-Level Radioactive Waste (LLRW) Committee                 *

*  International Isotope Society                                       *

*  http://www.intl-isotope-soc.org/index.html                          *

*******************************

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