Mixed Waste in Filters

[pcollopy@ix.netcom.com (Peter Collopy )]

The facility I work at uses filters (both water and air) to remove 
radioactive particulates during the processing of contaminated 
clothing. There is the possibility with some future work we plan to do 
that the clothing will become contaminated with lead, cadmium or 
beryllium. As a consequence we could be faced with generating a mixed 
waste (radioactive and RCRA hazardous).

My read of 40CFR is if the filters do not pass TCLP for the lead and 
cadmium they must be stabilized to not be considered a mixed waste. Is 
that interpretation correct; the follow-up to that is whether I need to 
get a permit to stabilize (I've tried calling our state DER but once I 
asked they said they would get back to me and that was the last (after 
many phone calls to) I heard from them) ? If one needs a permit, how 
hard is it to get and how long would you estimate the submittal and 
approval process (based on your own expereince).

Also Beryllium is P listed but not characteristic (TCLP) - because the 
Be would not be in a dust form (I believe thats the listed form) is it 
still a hazardous waste or is it just a radioactive waste ?

Any help in interpretation would be appreciated - also any EPA number 
where one can call and actually get a return response would be helpful.

To save bandwidth please send replies to pcollopy@ix.netcom.com

Thanks in advance for any help.

Pete C.

PS - does anyone have any good reference articles on the 20:1 rule for 
TCLP ?


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