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Introduction to Mixed Waste Regulations and Treatment

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Assume nothing- consult with your compliance professional ... The RCRA toxic metals. very prevalent. Cd, Cr, Pb, Hg most common, but also organics ... – PowerPoint PPT presentation

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Title: 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

3
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

4
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

5
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)

6
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

7
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

8
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

9
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

10
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.

11
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

12
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

13
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 ???

14
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

15
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

16
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

17
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)

18
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.

19
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

20
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

21
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
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