Re: Mixed Waste Storage

[CONATSER.STEVEN_D@FORUM.VA.GOV]

    Some information may be found at www.nara.gov by opening the Federal
Register online via GPO access.  Specify which year of interest, and exact
date of publication if you know it, and search for the specific page of
interest.  The following commo is based on Federal Register, Volume 60,
Number 151, Monday, August 7, 1995, page 40204-40209:
    The following interpretations of this FR are mine alone, and do not
represent established regulations.  However, I interpret the following:
    A.  If a facility generates a quantity of low-level mixed waste that,
when combined with all EPA-defined hazardous waste generated at their
facility, does not exceed 100 kg (~28 gal) per month (or 1 kg of acutely
hazardous waste)...it qualifies as a conditionally exempt small quantity
generator (SQG).  As a result, the facility can dispose of the low-level
mixed waste as low-level radioactive waste...if these materials meet the
disposal site's waste acceptance criteria (40 CFR 261.5).    
    B.  SQG facilities do not need a permit for storage of mixed waste,
and there is no time limit for storage of mixed waste at their facility.
    C.  EPA's interpretation of mixed waste storage (for all facilities)
is that it is allowable...without a permit...to treat mixed waste as
necessary to facilitate treatment or disposal.  This means that all
facilities...that are authorized to decay in storage of RAM (half-lives
less than 90 days)...may be allowed to place mixed waste in storage for
radioactive decay to background without a time constraint.  The time 
constraint for storage of the hazardous waste content...without a permit...
would begin when the radioactive waste content is proven and documented to
have decayed to background.
 
    I believe the issue of mixed waste should be openly discussed in
RADSAFE, and comments to interpretations A thru C above are requested.
    Steven D. Conatser, RSO, VA Medical Center, Detroit