Re: Mixed Waste

[michael_coogen@hq2ccgw.hq.dla.mil]

     I would conclude that the Navy has a solid mixed waste problem.  The 
     Navy can store this hazardous material up to 90 days.  I believe after 
     90 days they must file for a permit to store hazardous material with 
     the EPA.  The problem of disposal can easily be resolved.  EnviroCare 
     in Utah has the capability to bury mixed waste.  There may a 
     restriction as to a miminum volume that they will accept.  mike coogen 
     sends


______________________________ Reply Separator _________________________________
Subject: Mixed Waste
Author:  radsafe@romulus.ehs.uiuc.edu at hq2ccgw
Date:    9/7/95 7:42 AM


     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.