6EPA
                United States
                Environment*! Protection
                Agency
            Office of
            Sot»d Waste and
            Emergency Response
DIRECTIVE NUMBER:  9432.00-2
TITLE: Joint EPA/NRC Guidance on the Definition and
     Identification of Commercial Mixed Low-Level
     Radioactive and Hazardous Waste
APPROVAL DATE: January 8, 1987
EFFECTIVE DATE: March 2, 1987
ORIGINATING OFFICE: osw
Q FINAL
D DRAFT
 LEVEL OF DRAFT
    DA — Signed by AA or OAA
    D B — Signed by Office Director
    D C — Review & Comment
REFERENCE (other documents):
  OS WE Ft       OSWER       OSWER
ME    DIRECTIVE    DIRECTIVE   Dl

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                                                   OSWER POLICY DIRECTIVE WO,
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                       WASHINGTON, D.C. 20460
MAR 2  1987


MEMORANDUM                                     souo wA8fE ANDEMEH^.CV RESPONSE


SUBJECT:  Joint EPA/NRC Guidance on the  Definition  and
          Identification of Commercial Mixed Lpw-Level
          Radioactive and Hazardous Waste

FROM:     Marcia E. Williams, Director   •'/  I' {)/^Xi ^
          Office of Solid Waste  (WH-562 )//M'7^/    \
                                      /
TO:       Hazardous Waste Division Directors
          Regions  I-X


     As you know,  EPA announced  in the Federal Register  on
July 3, 1986  (51 FR 24504) that  in order to obtain  and.maintain
authorization to administer and  enforce  a RCRA Subtitle  C
hazardous waste program, States  must apply for authorization
to regulate the hazardous components of  radioactive mixed waste.
States which received final authorization prior  to  July  3 must
revise their program by July 1,  1988  (or July  1,  1989  if a
statutory amendment is required) to demonstrate  authority to
regulate the hazardous components of radioactive mixed waste.
States initially applying for final authorization after  July 3,
1987 must incorporate this provision in  their  application for
final authorization.  To date, only one  State  (Colorado) has
been authorized for mixed waste.

     Following publication of the July  3 notice  and subsequent
dialogue with the  Nuclear Regulatory Commission  (NRC) and others
regarding the universe of affected wastes, it  became apparent
that generators of commercial low-level  radioactive waste (LLW)
needed guidance to facilitate delineation of whether their LLW
contained a hazardous waste subject to RCRA regulation.   Accordingly,
NRC and EPA jointly developed the attached guidance to  (1) clarify
the definition of  commercial mixed low-level radioactive and
hazardous waste (Mixed LLW) (2)  assist generators of commercial
low-level radioactive waste (LLW) in determining if their LLW are
radioactive mixed  wastes, and (3) answer anticipated questions
about mixed low-level wastes.

     You should feel free to consult with the  contacts  identified
in the guidance regarding specific technical considerations or
your may contact Betty Shackleford, OSW  Mixed  Waste Coordinator
on (FTS) 475-9565.

Attachment

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                                                           05WER POLICY DiRECTiVc MO.

                                                         9482 .00- 2   -
TO ALL NRC LICENSEES:
SUBJECT:   GUIDANCE ON  THE DEFINITION  AND  IDENTIFICATION OF  COMMERCIAL MIXED
          LOW-LEVEL RADIOACTIVE  AND HAZARDOUS  WASTE AND ANSWERS TO ANTICIPATED
          QUESTIONS
Under the Resource Conservation  and  Recovery  Act  (RCRA),  the U.S. Environmental
Protection Agency (EPA)  has  jurisdiction  over the  disposal of solid wastes with
the exception of source, byproduct,  and special nuclear material, which are
regulated by the U.S.  Nuclear Regulatory  Commission  (NRC) under  the Atomic
Energy Act (AEA).  Low-Level  Radioactive  Wastes (LLW) contain source,
byproduct, or special  nuclear materials,  but  they  may also contain chemical
constituents which are hazardous under EPA regulations  in 40 CFR Part 261.
Such wastes are commonly referred to as Mixed Low-Level Radioactive and
Hazardous Waste (Mixed LLW).

NRC regulations exist  to control the byproduct, source, and special nuclear
material components of the Mixed LLW;  EPA has the  authority and  continues
to develop regulations to control the  hazardous component of the Mixed LLW.
Thus, all of the individual  constituents  of Mixed  LLW are subject to either
NRC or EPA regulations.   However, when the components are combined to become
Mixed LLW, neither agency has exclusive jurisdiction under current Federal
law.  This had led to  a  situation of dual  regulation where both  agencies,
NRC and EPA, regulate  the same waste.

The enclosed document, "Guidance en  the Definition and  Identification of
Commercial Mixed Low-Level Radioactive and Hazardous Waste," was developed
jointly by the NRC and EPA to aid commercial  LLW  generators in assessing
whether they are currently generating  Mixed LLW.   This  guidance  is based on NRC
and EPA regulations in effect en December 1,  1986.   In  addition  to the

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                                                           :C.'£& fOLiCY iJil?£CT!VE NO.

                                                         »482  .  00?.2   -
definition  and  the methodology for identifying  Mixed LLW, which we hereby

endorse,  the  staff has prepared answers to anticipated questions from

generators  which are also included.


                                       Sincerely,
                                       John G.  Davis, Director
                                       Office of Nuclear Material"
                                         Safety and  Safeguards
                                       U. S.  Nuclear Regulatory Commission
                                          Winston  Porter
                                       Assistant Administrator
                                       Office of Solid Waste
                                         and Emergency Response
                                       U.S.  Environmental
                                         Protection  Agency
Enclosures:
As Stated

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                                                            GS'A'ER POLICY DIRECTIVE NO.

                                                           -:•;-> 2  . 00-2   *"•
                 GUIDANCE ON THE DEFINITION AND IDENTIFICATION
         OF COMMERCIAL MIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS WASTE

                                  (87/01/05)

Definition

Mixed Low-Level Radioactive and Hazardous Waste (Mixed LLW)  is defined as waste
that satisfies the definition of low-level radioactive waste (LLW) in the Low-
Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA) and contains
hazardous waste that either (1) is listed as a hazardous waste in Subpart D of
40 CFR Part 261 or (2) causes the LLW to exhibit any of the  hazardous waste
characteristics identified in Subpart C of 40 CFR Part 261.

Identification

The policy provided in this guidance is developed for commercial LLW jointly by
the U.S. Nuclear Regulatory Commission (NRC) and the U.S. Environmental
Protection Agency (EPA).   LLW that contains hazardous wastes defined under the -
Resource Conservation and Recovery Act (RCRA) is Mixed LLW.   Under current
Federal law, such waste is subject to regulation by NRC under the Atomic Energy
Act (AEA), as amended, and by EPA under the AEA and RCRA, as amended.  In the
absence of legislation to the contrary, management and disposal of this waste
must be conducted in compliance with NRC and EPA or equivalent state
regulations.

This guidance presents a methodology (Figure 1) that may be  used by generators
of commercial LLW to identify Mixed LLW.- Implementation of  the methodology
should identify Mixed LLW and aid generators in assessing whether they are
currently generating Mixed LLW.  Generators are cautioned, however, that
application of the methodology does not affect the need to comply with
applicable NRC and EPA regulations.  Because EPA's regulations for hazardous
waste are currently changing, generators should use applicable regulations
that are in effect at the time of implementation of the methodology.  This
guidance has been prepared based on NRC and EPA regulations  in effect on
December 1, 1986.

Application of this methodology to identify Mixed LLW will reveal the
complexities of the definition of Mixed LLW.  If generators  have specific
questions about whether LLW is Mixed LLW, they should promptly contact the
agencies by writing to the persons listed below.

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                                                             CSWER POLICY DIRECTIVE NO.

                                                             432  . 00-2   '*
For questions about whether the              For questions about whether the
waste is low-level radioactive               waste is hazardous waste,
waste, contact:                              contact:

     Dr. Sher Bahadur                             Mr. Alan Corson
     Division of Waste Management                 Deputy Director
     Mail Stop 623-SS                             Characterization and
     U. S. Nuclear Regulatory Commission            Assessment Division
     Washington, DC  20555                        Mail  Code WH-562B
                                                  U.  S.  Environmental
                                                    Protection Agency
                                                  401 M Street, S.W.
                                                  Washington,  DC  20460


                                  Methodology

Step 1. Identify LLW

Step 1 in the methodology requires that the generator determine whether the
waste is LLW as defined in the LLRWPAA. This Act defines LLW as radioactive
material that (A) is not high-level  radioactive waste,  spent nuclear  fuel,  or
byproduct material as defined in section lie.(2) of the AEA (i.e., uranium  or
thorium mill tailings) and (B) the NRC classifies as LLW consistent with
existing law and in accordance with (A).  If the generator determines  that  the
waste is LLW, the generator should proceed to step 2.  If the  determination 1s
negative, then the waste cannot be Mixed'LLW because it is not LLW.  However,
the waste may be another radioactive or hazardous waste regulated under AEA,
RCRA, or both statutes.

Step 2. Identify Listed Hazardous Waste

In step 2, the generator determines whether the LLW contains any hazardous
wastes listed in Subpart D of 40 CFR Part 261.   Subpart D of Part 261  is
reproduced in Appendix I of this guidance.  LLW is Mixed LLW if it contains any
hazardous wastes specifically listed in Subpart D of 40 CFR Part 261.   Listed
hazardous wastes include hazardous waste streams from specific and non-specific
sources listed in 40 CFR Parts 261.31 and 261.32 and discarded commercial
chemical products listed in 40 CFR Part 261.33.  The generator is responsible
for determining whether LLW contains listed hazardous wastes.   The
determination should be based on knowledge of the process that generates the
waste.  For example, if a process produces LLW that contains spent solvents
that are specifically listed in the tables of Subpart D of Part 261,  the
generator should suspect that the waste is Mixed LLW.

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Step 1.  Is the Waste LLU?
     No
            Yes,
     It is not Mixed LLW, but it
     may be Hazardous Waste or
     another Radioactive Waste.
Step 2.  Are Listed Hazardous Wastes
         Contained in the LLW?
     No
            Yes
Yes
     The waste is Mixed LLW.
Step 3.  Do Non-AEA Materials cause
         the Waste to exhibit any of
         the Hazardous Waste Characteristics?
                    No
                              The Waste is not Mixed LLW.
                                   Figure 1.  Identification of Mixed LLW.
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                                                                      so
                                                                      -o
                                                                      o
                                                                      o

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                                                             OSWER POLICY DIRECTIVE NO.

                                                           9432  . 00-2
Step 3. Identify Hazardous Characteristics

If the LLW does not contain a listed hazardous waste,  Step 3 of the methodology
requires the generator to determine whether the LLW contains hazardous wastes
that cause the LLW to exhibit any of the hazardous waste characteristics
identified in Subpart C of 40 CFR Part 261.   This determination can be based on
either (1) an assessment of whether the LLW exhibits one or more of the
hazardous waste characteristics because it contains non-AEA materials (i.e.,
materials other than source, special nuclear,  and byproduct materials) based on
the generator's knowledge of the materials or processes used in generating the
LLW or (2) testing of the LLW in accordance with the methods identified in
Subpart C of Part 261.  Except for certain ores containing source material,
which are defined as source material in 10 CFR 40.4(h), and uranium and thorium
mill tailings or wastes, NRC and EPA interpret the definitions of source,
special nuclear, and byproduct materials to include only the radioactive
elements themselves.  Generators should identify non-AEA materials contained in
the LLW by examining the process that generates the waste.  For example, if the
process mixes byproduct material (an AEA material) with a volatile organic
solvent (a non-AEA material), the generator would test representative samples  .
of the LLW that contain the solvent waste to determine if the waste exhibits
any of the characteristics because it contains the solvent.  If the generator
selects testing as the basis for the determination, testing should be performed
if there is reason to suspect that the waste contains non-AEA materials that
may cause the LLW to exhibit the characteristics in Subpart C.

Under these circumstances, the generator should collect and test representative
samples of the LLW to determine if the waste exhibits any of the
characteristics identified in Subpart C because it contains the non-AEA
materials.  These characteristics include ignitability (§261.21), corrosivity
(§261.22), reactivity (§261.23), and Extraction Procedure (EP) toxicity
(§261.24).  Waste testing should be conducted in a manner that is consistent
with the worker protection requirements in 10 CFR Part 20.   The purpose of the
characteristics tests is to identify hazardous wastes that are not specifically
listed in Subpart D of 40 CFR Part 261.  Test methods to collect representative
samples of wastes are described in Appendix I of 40 CFR Part 261.  The samples
should then be tested using the referenced testing protocols (e.g., ASTM
Standard 0-93-79 or D-93-80 for the Pensky-Martens Closed Cup Ignitability
Test).  EPA's testing requirements are reproduced in Appendix II of this
guidance.  It should be noted that on June 13, 1986, EPA proposed a
modification to the EP Toxicity testing requirements to include organic
constituents.

If LLW contains a listed hazardous waste or non-AEA materials that cause the
LLW to exhibit any of the hazardous waste characteristics, the waste is Mixed
LLW and must, therefore, be managed and disposed of in compliance with EPA's
RCRA regulations in 40 CFR Parts 124, and 260 through 270, and NRC's
regulations in 10 CFR Parts 20, 30, 40, 61, and 70.  Management and disposal of
Mixed LLW must be conducted in compliance with state requirements in states
with EPA-authorized regulatory programs for the hazardous components of such
waste and NRC agreement state radiation control programs for LLW.

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                                                           OSWER POLICY DIRECTIVE NO.

                                                         U a :•: ?.    0 0 - 2
                             Questions and Answers


As a supplement to the Guidance on the Definition and Identification of
Commercial Mixed Low-Level Radioactive and Hazardous Waste (Mixed LLW),
answers to anticipated questions are included to clarify obscure points
and to stimulate additional questions from potential Mixed LLW generators.

1.  Are my low-level radioactive wastes exempt from RCRA because they are
source, special nuclear, or byproduct materials as defined under the AEA?

Except for certain ores containing source material, which are defined as source
material  in 10 CFR 40.4(h), and uranium and thorium mill tailings or wastes,
NRC and EPA consider that only the radionuclides themselves are exempt from
RCRA.  Section 1004(27) of RCRA excludes source, special nuclear, and byproduct
material  from the definition of "solid waste."  RCRA defines solid waste as:

     "any garbage, refuse, sludge from a waste treatment plant, water supply
     treatment plant, or air pollution control facility and other discarded
     material, including solid, liquid, semi sol id, or contained gaseous
     material resulting from industrial, commercial, mining, and agricultural
     operations, or from community activities, but does not include solid or
     dissolved materials in irrigation return flows or industrial discharges
     which are point sources subject to permits under section 402 of the
     Federal Water Pollution Control Act, as amended (86 Stat. 880), or source,
     special nuclear, or byproduct material as defined by the Atomic Energy Act
     of 1954, as amended (68 Stat. 923)." [emphasis added]

Since "hazardous waste" is a subset of "solid waste," RCRA also excludes
source, special nuclear, and byproduct materials from the definition of
hazardous waste and, therefore, from regulation under EPA's RCRA Subtitle C
program.   Section 11 of the Atomic Energy Act, as amended, defines these
radioactive materials as follows:

     Source material means (1) uranium, thorium, or any other material which is
    'determined by the Atomic Energy Commission (AEC) pursuant to the
     provisions of section 61 of the AEA to be source material, or (2) ores
     containing one or more of the foregoing materials, in such concentration
     as the AEC may by regulation determine from time to time.

     Special nuclear material means (1) plutonium, uranium enriched in the
     isotope 233 or in the isotope 235, and any other material which the AEC,
     pursuant to the provisions of Section 51 of the AEA, determines to be
     special nuclear material; or (2) any material artificially enriched by any
     of the  foregoing, but does not include source material.

     Byproduct material means (1) any radioactive material (except special
     nuclear material) yielded in or made radioactive by exposure to radiation
     incident to the process of producing or utilizing  special nuclear

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                                                            OSWER POLICY OIRECTiVE WO.

                                                          9432  .  00-2   -"
     material, and (2) the tailings or wastes produced by the extraction or
     concentration of uranium or thorium from any ore processed primarily for
     its source material  content.

Source, special nuclear,  and byproduct materials, however, may be mixed with
other radioactive or non-radioactive materials that are not source,  special
nuclear, or byproduct materials.  For example, tritium may be contained in
toluene, a nonhalogenated aromatic solvent.   Consistent with the definition of
byproduct material, the tritium may be considered a byproduct material, while
the toluene that contains the tritium would  not be byproduct material.
Mixtures of toluene and tritium could satisfy the definition of Mixed LLW
because they contain listed hazardous waste  (spent toluene) and tritium that
may qualify as LLW if it  has been produced by activities regulated by NRC under
the AEA.
2.  What are some examples of Mixed LLW?

A preliminary survey performed for the NRC identified two potential  types of
Mixed LLW:

     0 LLW containing organic liquids, such as scintillation liquids and
               vials; organic lab liquids; sludges; and cleaning,
               degreasing, and miscellaneous solvents.

     0 LLW containing heavy metals, such as discarded lead shielding,
               discarded lined containers, and lead oxide dross containing
               uranium oxide; light water reactor (LWR) process wastes
               containing chromate and LWR decontamination resins containing
               chromium; and mercury amalgam in trash.

The preliminary survey concluded that potential Mixed LLW comprises a small
percentage of all LLW.  For example, LLW containing organic liquids accounted
for approximately 2.3% by volume of LLW reported in the preliminary survey
(Bowerman, et al.,  1985).

An earlier survey identified a more diverse universe of potential Mixed LLW
including wastes that contained aldehydes, aliphatic halogenated hydrocarbons,
alkanes, alkenes, amino acids, aromatic hydrocarbons, chelating agents, esters,
ethers, ketones, nitrosamines, nucleotides, pesticides, phenolic compounds,
purines, resins, steroids, and vitamins (General Research Corporation, 1980).
NRC also anticipates that additional LLW may be identified as Mixed LLW in the
future, as generators implement the definition of Mixed LLW and as EPA revises
the definition of hazardous waste.

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                                                          OSV-ES POLiCY DIRECTIVE MO.

                                                         9482  . OOs2   if
3.  Could some "below regulatory concern" wastes be considered Mixed LLW?

A determination that radioactive wastes are below regulatory concern (BRC) for
radioactivity may affect how the wastes are managed or discarded,  but it does
not affect the legal status of the wastes.  Specifically,  their status with
respect to the definition of Mixed LLW does not change.   BRC waste is still LLW
because it satisfies the definition of LLW in the LLRWPAA and is within the
NRC's jurisdictional authority under the AEA.

When radioactive waste contains sufficiently low concentrations or quantities
of radionuclides, NRC may find that they do not need to be managed or disposed
of as radioactive wastes.  For NRC to make such a finding, management and
disposal of the waste must not pose an undue radiological  risk to the public
and the environment.  However, NRC's determination that the radioactive content
of the wastes is below NRC regulatory concern does not relieve licensees from
compliance with applicable rules of other agencies governing non-radiological
hazards (e.g., regulations of EPA or the Department of Transportation).

Therefore, some BRC wastes may still be considered Mixed LLW if they contain
hazardous wastes that have been listed in Subpart D of 40 CFR Part 261 or that
cause the LLW to exhibit any of the hazardous characteristics described in
Subpart C of 40 CFR Part 261.  BRC Mixed LLW may be managed without regard to
its radioactivity (but it must still be managed as a hazardous waste in
compliance with EPA's regulations for hazardous waste generation,  storage,
transportation, treatment, and disposal (cf. 40 CFR Parts 262 through 266)).


4.  If I use chemicals in my process that are identified by EPA as hazardous
constituents, should I assume that my LLW is Mixed LLW?

No.  Low-level radioactive waste that contains hazardous constituents may not
necessarily be Mixed LLW.  As defined above, Mixed LLW is LLW that contains a
known hazardous waste (i.e., a listed hazardous waste) or that exhibits one or
more of the hazardous characteristics because it contains non-AEA materials.
For wastes that are not  listed in Subpart D of 40 CFR Part 261, testing is not
necessarily required to  "determine" whether the LLW exhibits any of the
hazardous characteristics.  A generator may be able to determine whether the
LLW is Mixed LLW based on knowledge of the waste characteristics or the process
that generates the LLW.

Furthermore, if the generator normally segregates LLW from hazardous and other
types of wastes, there is no need to assume that hazardous wastes may have been
inadvertently mixed with LLW or to inspect each container or receptacle to
ensure that inadvertent  mixing has not occurred.  Although the generator is
subject to RCRA  inspections and must follow the manifest, pre-transport, and
other requirements of 40 CFR Part 262, the generator is not required to
demonstrate that every LLW container does not contain hazardous waste.

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                                                              S'""- ~OL!CY DIRECTIVE NO.
5.  What are EPA and NRC currently doing to address the Mixed LLW issue, and
what should generators do in the interim before a regulatory program for Mixed
LLW is established?

An incentive exists for generators to minimize the generation of Mixed LLW
because Mixed LLW must currently be managed and disposed of in compliance with
the regulatory controls of both EPA and NRC.  These dual regulatory controls
complicate management and disposal of the waste.  NRC and EPA are presently
working together to develop guidance for generators and disposal site operators
on the management, treatment, and disposal of Mixed LLW.  In the interim,
generators are encouraged to minimize the generation of Mixed LLW through
management practices such as waste segregation and materials tracking.
Generators and waste handlers are also encouraged to consider treatment
techniques to reduce the amount and hazards of Mixed LLW requiring licensed
land disposal.  Kempf et a± (1986) prepared a preliminary evaluation of current
practices and potential management options for Mixed LLW.  Current disposal
site operators must develop and operate facilities to dispose of Mixed LLW in
compliance with both NRC and EPA requirements or cease disposing of Mixed LLW.
Licensees should recognize that all of these activities must be performed in
compliance with applicable NRC requirements in 10 CFR Parts 20, 30, 40, 50, 61,
and 70, and applicable EPA requirements in 40 CFR Parts 124, and 260 through
270, or applicable State requirements.


6.  What should I do if I believe that the RCRA regulations are inconsistent
with the AEA regulations?

Section 1006 of RCRA states that, "Nothing in this Act shall be construed to
apply to (or to authorize any state, interstate, or local authority to regulate
any activity or substance which is subject to ... the Atomic Energy Act of
1954 (42 U. S. C. 2011 and following) except to the extent that such
application (or regulation) is not inconsistent with the requirements of such
[Act]."  This provision allows the modification of the RCRA requirements when
they are found to be inconsistent with the AEA requirements.  "Inconsistent"
includes situations where satisfying both sets of regulations (RCRA and AEA
regulations) would increase the radiation hazard, would be technically
infeasible, or would violate national security interests.  Variances from the
RCRA requirements may be granted to generators, transporters, and facilities
that treat, store, or dispose of Mixed LLW.

NRC licensees may petition for variances  from RCRA requirements when they
believe that application of one or more of these requirements would be
inconsistent with the AEA.  NRC licensees should first discuss the
inconsistency with NRC prior to preparing the petition.  NRC's review
will ensure that the licensees' interpretations of the AEA requirements
are correct and that the reasons for the  variance petition are technically
sound.

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                                                            OSvviii- rCLlCY DIRECTIVE NO.

                                                           9432.00-2   -
7.  How can I obtain representative samples of heterogeneous trash included in
LLW to perform the hazardous characteristics tests?

Before discussing the collection of representative samples of waste,  generators
are reminded that they are not required to test all LLW to determine  if the
waste contains hazardous wastes that cause the LLW to exhibit the hazardous
waste characteristics.  Such comprehensive testing of all  LLW would likely
violate the principle of keeping radiological  exposures as low as is  reasonably
achievable.  Generators should select testing  as a basis for determining
whether the LLW exhibits any of the hazardous  waste characteristics if they
cannot make the determination based on their knowledge of the process that
generates the LLW.

Representative samples of waste should be collected for testing in accordance
with EPA's regulations in 40 CFR Part 261.20(c), which state that waste samples
collected using applicable methods specified in Appendix I of Part 261 will be
considered as representative samples for hazardous characteristics testing.
This appendix has been included in its entirety in Appendix II of this
guidance.  The sampling techniques described in Appendix I of Part 261 apply to
extremely viscous liquids, fly ash-like material, containerized liquid wastes,
and liquid wastes in pits, ponds, lagoons, and similar reservoirs.  In the
absence of guidance about sampling heterogeneous wastes, generators should use
appropriate portions of the sampling methods described in Appendix I  of Part
261 in combination with other methods to collect, to the maximum extent
practicable, representative samples of the waste to be tested.

References

Bowerman, B. S., Kempf, C. R., MacKenzie, D. R., Siskind,  B. and P. L.
     Piciulo, 1985, "An Analysis of Low-Level  Wastes:  Review of Hazardous
     Waste Regulations and Identification of Radioactive Mixed Wastes,"
     NUREG/CR-4406, U. S. Nuclear Regulatory Commission.

General Research Corporation, 1980, "Study of Chemical Toxicity of Low-Level
     Wastes," NUREG/CR-1793, U. S. Nuclear Regulatory Commission.

Kempf, C. R., MacKenzie, D. R., and B. S. Bowerman, 1986,  "Management of
     Radioactive Mixed Wastes in Commercial Low-Level Wastes," NUREG/CR-4450,
     U. S. Nuclear Regulatory Commission.

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