Introduction to Mixed Waste Regulations and Treatment

1
Introduction to Mixed Waste Regulations and
Treatment

• Vince Maio
• ISU 618-02
• 9-5-03 3rd Lecture

2
Topics to be Covered

• Definition of Mixed Waste
• The Hazardous Component
• The Radioactive Component
• Types of Mixed Waste
• Sources of Mixed Waste
• Department of Energy
• Commercial Nuclear Power
• Regulations Concerning Mixed Waste
• Emphasis on the Hazardous Component

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Definition of Mixed Waste

• LLW containing, in addition to radionuclides,
  hazardous chemicals or species (i.e., waste is
  also a hazardous waste as determined by the
  existing EPA laws)
• Hazardous component regulated mostly by the
  Resource Conservation or Recovery (RCRA), but the
  Toxic Substance Control(TSCA) act can play a role
  
• Radionuclide component regulated by NRC ( for
  commercial generated waste) or DOE if related to
  the weapons complex and its associated research.
• The presence of a specific regulated hazardous
  component does not necessarily establish a
  hazardous waste, magnitude and quantity is
  usually relevant

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Definition of Mixed Waste

• In the business mixed waste is occasionally
  defined by what it is not. It is not
• High Level Waste
• Spent Reactor or Production Fuel
• Uranium Mill Tailings
• Transuranic (TRU) waste with RCRA or TSCA
  regulated species is considered mixed waste, but
  the treatment requirements for land disposal are
  drastically different than LL mixed waste
• TRU wastes go to WIPP, which is exempt from RCRA
• Transportation requirements and WIPP WAC may
  require treatment of the hazardous component

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Types of Mixed Waste

• Debris
• wood, metal, plastic, ceramic, from mostly
  decontamination and demolition
• Pipe, valves, glass ware, tools, electronic
  equipment, machinery, glove boxes, HEPA filters
  (may be classified)
• PPE ( respirators, shoe covers, coveralls,
  gloves, cleaning materials)

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Types of Mixed Waste

• Homogeneous Solids and Sludges
• Ion exchange resins
• Waste water treatment residues
• Evaporator bottoms
• Residues from the treatment of high level waste
• Soils
• Incinerator ash
• Oily sludges
• Previously stabilized waste forms

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Types of Mixed Waste

• Aqueous waste waters
• Thermal treatment scrubber blowdown
• Evaporator overhead condensates
• Solvent recovery wash solutions
• Metal plating baths
• Spent decontamination solutions
• Discarded laboratory chemicals
• Acidic dissolver solutions

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Types of Mixed Waste

• Organics
• Solids with heating value
• Spent carbon beds
• Organic IX resins
• Organic Liquids
• Spent extraction solvents
• Contaminated lubricants and degreasers
• Discarded laboratory chemical
• scintillation cocktails

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Types of Mixed Waste

• Unique Wastes
• Reactive Metals
• Explosives
• Pyrophorics
• Shock sensitive chemicals
• Batteries
• Compressed Gas Cylinders
• Note A given Mixed Waste can be of one or more
  of the 5 classes

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Sources of Mixed Waste

• Where did the hazardous component come from?
• More hazardous chemicals used in DOEs weapons
  production and reactor research missions than in
  the commercial nuclear power industry.
• The hazardous component is either an inorganic
  issue (characteristic) or and organic (listed)
  issue or both.

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Sources of Mixed Waste

• Inorganic
• A lot of acid solutions used to dissolve fuel
• A lot of caustic solutions used to decon
  equipment
• Mercury used in catalysts for fuel reprocessing
• Cadmium used in fuel fabrication
• Chromium used as corrosion inhibitor
• Beryllium used in weapons manufacture
• Lead used as shielding
• All metals used in electroplating
• All metals used in research and development

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Sources of Mixed Waste

• Organic
• A lot of solvents used as extraction media in
  reprocessing
• A lot of solvents used as a part and equipment
  degreaser
• A lot of lubricants used in weapons and parts
  machining
• Chlorinated organics used in explosives and as a
  dielectric

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The EPA Regulations for Mixed Wastes

• They can be complex and are constantly changing
• Covered mostly in 40CFR parts 261 through 265
• Inability to be in compliance can be extremely
  costly
• Not knowing the regulations is not an excuse
• Complying with the EPA regulations for hazardous
  waste almost always drives the method as well as
  the cost for storing, handling, treating, and
  disposing of a mixed waste stream
• Assume nothing- consult with your compliance
  professional
• Communicate in the beginning with the regulatory
  body (State or Federal). A lot is
  negotiable-honesty is the best ???

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The EPA Regulations for Mixed Wastes

• RCRA Basics
• mixed waste could carry a listed and/or a
  characteristic hazardous waste code
• Listed
• Usually organic-F,U,K codes
• Treatment required for Land Disposal (i.e., meets
  LDR)
• Treatment will not allow the waste to exit RCRA
• Characteristic-the D codes
• Usually from an inorganic
• Treatment required for Land Disposal
• Treatment usually allows the waste to exit RCRA

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The EPA Regulations for Mixed Wastes

• Listed Waste
• The universal treatment standards (UTS) for
  meeting the Land Disposal Restrictions under the
  RCRA of EPA almost always involves incineration
  or an incineration alternative
• Once a listed waste always a listed waste
• Disposal must be in a subtitle C cell
• Derived from rule applies to residues

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The EPA Regulations for Mixed Wastes

• Listed Waste ( Waste from specific processes)
• Solvents
• Halogenated
• Non-halogenated
• Wastewater treatment sludges from electroplating
• Oils and distillation products
• Control operations to separate listed and
  characteristic treatments

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The EPA Regulations for Mixed Wastes

• Characteristic Waste
• Corrosive, Ignitable, Reactive, or EP toxicity-
• Corrosive- pH between 2.0 and 12.5-D002
• Ignitable - flash point below 140oC-D001
• Reactive- Reacts with water-D003
• The RCRA toxic metals
• very prevalent
• Cd, Cr, Pb, Hg most common, but also organics
• Metal leaches from bulk waste sample above
  hazardous waste determination levels as
  determined with the standardized toxicity
  characteristic leaching procedure (TCLP)

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The EPA Regulations for Mixed Wastes

• Characteristic Wastes-Toxicity
• Hazardous Waste Determination Levels
• Leachability if determined by TCLP
• Determines if waste is hazardous and thus must be
  treated to UTS for LDR
• Underlying Hazardous Constituents (UHC)
• If present may require that UTS acceptable TCLP
  determined leach value is lower than the
  hazardous waste determination value.

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The EPA Regulations for Mixed Wastes

• Other RCRA regulations that are applicable to
  mixed waste.
• Storage must be permitted if longer than 90 days
• Treatment must be permitted
• Even if treatment does not address the hazardous
  component
• Waste must be characterized

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The EPA Regulations for Mixed Wastes

• Other EPA Regulation that may be Applicable to
  Mixed Waste
• Comprehensive Environmental Recovery,
  Compensation, and Liability Act (CERCLA)
• Mixed waste generated from Environmental
  Remediations
• May be exempt from some RCRA
• TSCA PCBs, Asbestos
• The Mega Rule-Direct disposal of PCB-containing
  LLW, unless RCRA components are present

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The EPA Regulations for Mixed Wastes

• Other EPA Regulation that may be Applicable to
  Mixed Waste
• Clean Air Act (CAA)
• Air permits required for Treatment. Especially
  for Thermal treatment
• New Maximum Achievable Control Technology (MACT)
• Requires additional monitoring and treatment
  requirements for hazardous air pollutants-dioxin/f
  urans, acid gases, particulate, mercury .
• NEPA