Re: Crushing LSC Vials

["Sharyn Baker" <baker_s@defiance.hsc.colorado.edu>]

        Reply to:   RE>Crushing LSC Vials
TO: JERRY THOAM

If the vials contain RCRA (Resource Recovery Conservation Act) regulated
chemicals like toluene or xylene they must be disposed of properly.  It
probably makes little sense from a safety and personnel standpoint to open them
and pour them into a drum.  The term "process" has a very specific meaning
under RCRA.  Crushing vials is probably not regarded as  part of a "closed
process".  Hence a permit is needed to do such a thing.  Why don't you just
collect the vials in drums and send them out to a place like QUADREX. 

 You will find some help in 40 CFR parts 260 on all of this.  A "mixed waste"
consists of RCRA regulated chemicals mixed with licensed radioactive materials
in any concentration.  

I did not note the origin of this message but if you wish you may email me at: 
 BAKER_S@DEFIANCE.HSC.COLORADO.EDU 

--------------------------------------
Date: 8/9/94 7:41 PM
To: Sharyn Baker
From: radsafe@romulus.ehs.uiuc.edu

	I have read with interest the discussions regarding crushing of LSC
vials.  Can anyone give me a reference which makes crushing LSC vials to 
separate the LSC fluid from the vials a "process".  I am not that familar
with the RECRA (sp?) rules and regulations.

	Please put holes in the following arguement:

	All vials that are crushed at this facility have either H-3 or C-14
with specific activities less than 0.05 uCi/cc.  Therefore the waste is not
a mixed waste since the NRC does not require us to handle it as RAM for the
purposes of disposal.  If this is true, then collection of the LSC fluid
... which is a hazardous waste ... is the issue.

	If crushing the vials is not acceptable.  Is uncapping the vials and
pouring the contents into a flask acceptable?  Or is this a "process" as well?

	We have an EHO on staff who has worked at EPA.  He tells me that his
reading of the EPA rules does not make crushing of the LSC vials a process.  If
this is a correct intrepretation, then are we dealing with a local and/or
regional inspector who has placed his/her own spin on the regs?

	It would be very nice to have a common position on this issue.  If
QUADREX keeps its prices in line with the current price list, then we may
just want to keep sending our vials down there rather than go through the
effort to crush them and separate the LSC.

	Please let me know how you handle LSC at your institutions and what
your own and/or EPA regulators positions are on this issue.

JERRY THOAM

S