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Re: Mixed Waste
Reply to: RE>>Mixed Waste
Welcome to Alice's Wonderland of "environmentally correct" waste regulations,
where a brick of lead with 1 radioactive atom becomes "deadly" mixed waste.
Lots of luck guys, you will need it. This will teach you not to dig things
out of the ground that would be perfectly safe if left in the ground (or even
if put BACK in the ground.)
My suggestion is to send the stuff off to Uncle Bill and Aunt Hazel's
"Downhole" Permanent Disposal Service at the Nevada Test Site. Whoops!
Forgot! They are not in "business" anymore. 90 days. hmmmm. tick . . .
tick . . . tick . . .
DISCLAIMER:
Naturally, the above irresponsible opinions are mine alone, and do not reflect
the opinions of LLNL, the University of California, the Department of Energy,
or Uncle Bill or Aunt Hazel.
--------------------------------------
Date: 9/6/95 12:15 PM
To: GARY MANSFIELD
From: radsafe@romulus.ehs.uiuc.edu
If the waste in question contained only Uranium, the exemption in 40 CFR
261.4 (4) would apply, but since lead is present, according to the _listed_
test, 40 CFR 262.11 (b), it is RCRA Hazardous waste. The New Mexico
Environment Department has led Los Alamos National Laboratory to this
conclusion over years of interpretation.
Your friend may have a significant characterization problem with this
discovered material. Since it is radioactive, Department of Transportation
(DOT) requires that he provide a list of the isotopes present, the total
curies of radioactivity present, the wattage for the package, the amount of
fissile material present, and a Transport Index (from 10CFR 71, pertaining
to criticality safety). He also needs to determine if there are forbidden
substances, reportable quantities of materials, and the hazardous waste
constituent codes (e.g. D008 for lead) for the materials present. Other,
more easily obtainable data are also required.
I hope there are no transuranic elements present, because he will be utterly
blocked from shipment because a). he will need a TRUPACT-II shipping
container, b). there is no place to ship it, c). he will have to apply for a
TRUCON content code for the material, and that takes time and yet more
characterization.
> Oh knowledgeable ones,
>
> A colleague of mine employed by the Department of the Navy
>has a problem, and perhaps this group can be of help.
>
> This person has discovered and removed (from the ground)
>some old "slag" which contains radioactive material (radium-225
>and "perhaps" U-238 and thorium isotopes) AND some heavy metals
>(lead, tin, copper, magnesium, beryllium etc).
>
> This material is, of course, mixed waste.
>
>
>The Problem:
>
> The Navy is telling this command that they have 90 days to
>ship this material to a disposal/treatment site or they will be
>in violation of various and sundry California and Federal
>regulations.
>
>BUT:
>
> IS THIS MATERIAL HAZARDOUS WASTE?
>
> DOES THIS MATERIAL HAVE TO BE DISPOSED OF/SHIPPED OFF WITHIN
> 90 DAYS?, and
>
> WHAT SITES CAN ACCEPT THIS WASTE (FROM CALIFORNIA)
>
>
>To digress:
>
> What is a solid waste? 40 CFR 261.2 defines a solid waste
>as any discarded material that is not excluded by 261.4(a)...
>
> 40 CFR 261.4 (Exclusions): Excludes (a) Materials which
>are
>not solid wastes. Subsection (4) exempts a "source, special
>nuclear or byproduct material" (California Title 22 66261.4
>(a)(2) gives the same exemption).
>
>
>So:
>
> As this material does not meet the definition of a RCRA
>SOLID WASTE, nor of a RCRA HAZARDOUS WASTE, - and - it's
>RADIOACTIVE, that component should take precedence over the
>metals that it contains.
>
> Therefore, the 40 CFR 262.34 "Accumulation Time" specifying
>that a generator may accumulate hazardous waste on-site for 90
>days or less without a permit or without having interim
>status..... should not and does not apply.
>
> What do you think, inquiring minds want to know...
>
>
> Thank you all (a head of time) for your input,
>
> Joel Baumbaugh (baumbaug@nosc.mil)
> NRaD
> San Diego, CA
>
>Std. Disclaimer. The thoughts and opinions above are mine and
>mine alone and do not (necessarily) reflect the opinions of the
>Federal Govt., the Navy or my supervisors.
>
>
>
>
>
>
>
>
.,:;-!+=*^&%#$@(^)?->;:,.
David Yeamans
CST-7, MS E516, (505) 665-8832
Los Alamos National Laboratory
Los Alamos, New Mexico 87544
dryeamans@lanl.gov
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From: dryeamans@lanl.gov (David Yeamans, CST-7, 5-8832, dryeamans@lanl.gov)
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Subject: Re: Mixed Waste
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