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



Ted



What impact will the soon to be issued TE NORM standard have on this?



_______________________

John R Johnson, PhD

idias@interchange.ubc.ca



----- Original Message -----

From: "Ted de Castro" <tdc@XRAYTED.COM>

To: "RADSAFE Mailing List" <RADSAFE@list.vanderbilt.edu>

Sent: Friday, August 16, 2002 3:57 PM

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





> 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]

>

> --

>

> ************************************************************************

> *  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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