United States Radiation and Indoor Air EPA 402-R-97-012
Environmental Protection (6602J) March 1999
Agency
Draft Regulatory Impact Analysis
for 40 CFR Part 193: Proposed Rule
for Land Disposal of Low-Activity
Mixed Waste
U.S. Environmental Protection Agency
Office of Radiation and Indoor Air
Washington, D.C. 20460
-March 1999-
-------
DRAFT
REGULATORY IMPACT ANALYSIS
for
40 CFR Part 193
Proposed Rule
for
LAND DISPOSAL
OF
LOW-ACTIVITY MIXED WASTE
March 1999
U.S. Environmental Protection Agency
Office of Radiation and Indoor Air
Washington, D.C. 20460
-------
FOREWORD
The Environmental Protection Agency (EPA) is proposing an environmental standard (40 CFR
Part 193) for the disposal of low-activity mixed waste (LAMW), generated by commercial
waste generators, in RCRA Subtitle C disposal facilities, as implemented under Nuclear
Regulatory Commission and Agreement State requirements addressing the presence of
radioactivity.
An announcement of the availability of the Regulatory Impact Analysis (RIA) has appeared in
the Federal Register (later).
Comments should be submitted, in duplicate, to:
Air Docket, ATTN: Docket No. A98-43
Room M-1500 (6102)
U.S. Environmental Protection Agency
Washington, D.C. 20460-0001
For additional information, please contact Mr. Daniel Schultheisz at (202) 564-9349 or Ms.
Betsy Forinash at (202) 564-9233. Alternatively, information may be obtained by writing to:
Radiation Protection Division
Office of Radiation and Indoor Air Programs (6602J)
U.S. Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
-------
PREFACE
This Regulatory Impact Analysis (RIA) is provided in support of a rulemaking for generally
applicable environmental standards for land disposal of low-activity mixed waste (LAMW),
generated by the commercial sector in RCRA Subtitle C disposal facilities, as implemented
under Nuclear Regulatory Commission and Agreement State requirements addressing the
presence of radioactivity. LAMW is a waste with radionuclide concentrations that comply
with the Maximum Contaminant Levels (MCLs) defined by this rule (40 CFR Part 193). The
rule is restricted to LAMW radionuclide concentrations that are less than the limits of 10 CFR
Part 61 for Class A low-level radioactive waste. The RIA presents the regulatory objectives
and framework, RIA methodology, disposal technologies and costs, and an analysis of the
proposed rule.
The RIA is also supported by the Background Information Document for 40 CFR Part 193
(BID), which addresses the technical elements of the risk assessment analysis. The BID
identifies and characterizes LAMW, describes waste disposal technologies considered in the
BID and RIA, presents the methodology used for assessing Critical Population Group (CPG)
doses and risks, and summarizes the results of the risk assessment analysis.
The Preamble to the proposed rule, published in the Federal Register, should be consulted as it
presents additional information about the objectives and rationale of this rulemaking. Docket
No. A98-43, which contains all documents referenced in the Federal Register preamble and
additional material supporting this rulemaking, is available for inspection at:
Air and Radiation Docket and Information Center - Room 1500
(Located on the first floor of the Waterside Mall near the Washington Information
Center)
U. S. Environmental Protection Agency
401 M Street, SW
Washington, DC
Phone number: (202) 260-7548
Facsimile number: (202) 260-4400
The docket may be inspected on weekdays between 8:00 AM and 5:30 PM eastern time.
As provided in 40 CFR Part 2, a reasonable fee may be charged for photocopying.
-------
Table of Contents
Page
Foreword i
Preface ii
Executive Summary ES-1
1. Objective of the Regulatory Impact Analysis 1-1
1.0 Introduction 1-1
1.1 Purpose and Scope 1-2
1.2 Regulatory Objective and Legal Framework 1-4
1.2.1 EPA Statutory Authorities 1-4
1.2.2 Implementation and Applicability of Existing Regulations 1-5
1.3 Objective of Regulatory Impact Analysis 1-11
1.4 Report Format 1-13
2. Proposed Rule for the Disposal of Low-Activity Mixed Waste 2-1
2.0 Introduction 2-1
2.1 Proposed Low-Activity Mixed Waste Standard 2-1
2.2 Defining the Level of Protection 2-6
3. Disposal Facility Options 3-1
3.0 Introduction 3-1
3.1 RCRA-C Regulated Hazardous Waste Facility 3-1
3.2 Conventional Shallow-Land Disposal for Low-Level Radioactive
Waste 3-4
3.3 Low-Activity Waste Disposal at Specifically Authorized Sites 3-7
3.3.1 Envirocare of Utah, Inc 3-7
3.3.2 Waste Control Specialists LLC 3-9
3.3.3 Comparison of Requirements Between Low-Level Radioactive
Waste Disposal Facilities and RCRA-C Hazardous Waste Disposal
Facilities 3-10
3.4 Overview of RCRA-C Hazardous Waste Management Methods 3-12
3.5 Summary of Assumed Facility Features and Model Parameters 3-17
4. Commercially-Generated Mixed Waste 4-1
4.0 Introduction 4-1
4.1 Commercial Mixed Waste Generation 4-1
4.2 Distribution of Low-Level Radioactive Waste and Mixed Waste
Generators 4-7
4.3 Overview of Mixed Waste Management Practices 4-7
5. Waste Disposal Costs 5-1
5.0 Introduction 5-1
5.1 Commercial Waste Disposal Rates for RCRA Subtitle C Facilities 5-1
-------
Table of Contents (Continued)
Page
5.2 Commercial Low-Level Radioactive Waste Disposal Cost 5-4
5.2.1 Richland Waste Disposal Cost Structure 5-4
5.2.2 Barnwell Waste Disposal Cost Structure 5-6
5.2.3 Envirocare Waste Disposal Cost Structure 5-7
5.3 Mixed Waste Treatment Cost 5-8
5.4 Other Waste Management Costs 5-10
5.4.1 Waste Packaging Costs 5-10
5.4.2 Waste Shipping Costs 5-11
5.4.3 Waste Storage Costs 5-11
5.5 Overview of Waste-Management Practices and Issues 5-12
6. Analysis of Impact on Commercial Low-Activity Mixed Waste Generators 6-1
6.0 Introduction 6-1
6.1 Cost-Benefit Analysis Methodology 6-1
6.2 Uncertainties and Constraints 6-2
6.3 Impact Analysis 6-4
6.3.1 Directly Regulated Entities 6-8
6.3.2 Indirectly Affected Entities 6-9
6.3.3 Storage Costs 6-10
6.3.4 Treatment, Packaging and Transportation Costs 6-10
6.3.5 Disposal Costs 6-11
6.3.6 Indirect Costs 6-11
6.4 Risk Assessment Analysis 6-12
6.4.1 Storage Risks 6-12
6.4.2 Treatment, Packaging and Transportation Risks 6-12
6.4.3 Disposal Risks 6-13
6.5 Summary Conclusions 6-13
7. Report Summary 7-1
7.0 Background 7-1
7.1 Summary of Proposed LAMW Disposal Rule 7-1
7.2 Summary of Regulatory Impact Analysis 7-2
References R-l
Attachment A Summary of Disposal Site Waste Acceptance Criteria for the Richland,
Barnwell, Envirocare, and Waste Control Specialists Disposal Sites
Attachment B Listing of RCRA Hazardous Waste Management Options in States with
Commercial Subtitle C Disposal Facilities
iv
-------
List of Tables
Page
Table 2-1 Current EPA Radiation Dose Limits 2-7
Table 3-1 RCRA Hazardous Waste Management Methods - 1995 3-13
Table 3-2 RCRA-C Hazardous Waste Disposal Facilities and 1995
Waste Receipts 3-15
Table 3-3 Quantity of RCRA-C Hazardous Waste Managed and Disposed of and
Number of TSD Facilities - Ranked by Decreasing Amounts of Buried
Waste 3-16
Table 3-4 Summary Features of Alternate Waste Disposal Methods and Base Case ... 3-19
Table 3-5 Assumed RCRA-C Facility Features and Major Model Parameters 3-20
Table 4-1 Categorization of Commercial Mixed Wastes 4-3
Table 4-2 Mixed Waste Generation Profile by Types of Generator 4-4
Table 4-3 Most Often Used Waste Treatment Methods 4-4
Table 4-4 Mixed Waste Radionuclide and Half-Lives 4-6
Table 5-1 RCRA Hazardous Waste Disposal Rates for RCRA D, F, K Waste 5-2
Table 5-2 Summary of Commercial Hazardous Waste Disposal Costs 5-3
Table 5-3 Low-Level Radioactive Waste and Mixed Waste Treatment, Storage, and
Disposal Costs 5-5
Table 5-4 Comparative Waste Disposal Costs Borne by Two Facilities in 1996 5-9
List of Figures
Figure 3-1 Schematic Representation of RCRA-C Facility Features 3-2
Figure 3-2 Schematic Representation of Low-Level Radioactive Waste Disposal
Facility Features 3-5
Figure 6-1 Current Mixed Waste Disposal Status 6-5
Figure 6-2 Anticipated Mixed Waste Disposal Under Proposed Rule 6-7
-------
Executive Summary
The U.S. Environmental Protection Agency (EPA) is proposing a generally applicable
environmental standard (40 CFR Part 193) for the disposal of commercial low-activity mixed
waste (LAMW). Under the rule, LAMW would be disposed of in Resource Conservation and
Recovery Act (RCRA) Subtitle C disposal facilities (RCRA-C facility) under the applicable
requirements of the Nuclear Regulatory Commission and Agreement States (collectively referred
as "NRC/AS"), concerning potential radiological hazards. LAMW, as a subcategory of mixed
waste (MW), is produced when hazardous chemicals become commingled with radioactive
materials. The disposal of LAMW is subject to dual regulatory requirements under RCRA and
the Atomic Energy Act of 1954 (AEA). Various facilities, including medical, educational,
industrial, and nuclear power plants, generate commercial LAMW in small amounts.
The proposed standard will promote the safe and permanent disposal of LAMW in response to
the increased need for disposal facilities and the desire to streamline the regulatory process for
MW. The proposed rule focuses on protection of public health and the environment, as well as
exposed workers, and its requirements are commensurate with the relatively low radiological
hazard presented by LAMW. The EPA's approach establishes maximum LAMW radionuclide
concentration limits, based on Maximum Contaminant Levels (MCLs) developed for members of
the public from all exposure pathways, as a long-term performance standard, and an annual dose
limit of 15 mrem (effective dose equivalent) for RCRA-C facility workers. Waste with multiple
radionuclides would be further restricted under the sum-of-the-ratios rule. The rule is restricted
to LAMW radionuclide concentrations that are less than the limits of 10 CFR Part 61 for Class A
waste.
This disposal alternative provides a level of protection against environmental impacts and public
health risks equivalent to that of current options by limiting the radionuclide concentrations in
LAMW that would be disposed of in RCRA-C facilities. That is to say, disposal risks are
essentially identical between both types of disposal facilities since this approach assumes that
ultimately the radioactivity would be disposed of either in a facility approved for the disposal of
LAMW or in a low-level radioactive waste (LLRW) disposal facility after the hazardous
components of the waste have been removed.
Currently, disposal costs in RCRA-C facilities are significantly less than in facilities authorized
to receive LLRW waste or only certain types of MW. Most waste generators believe that the
ES-1
-------
complexity of the dual regulatory process for MW, including LAMW, impedes the development
of new treatment and disposal facilities and creates the opportunity for facility operators to
charge exorbitant costs. For some waste generators, treatment costs, as opposed to access to
disposal sites and disposal costs, are the major concerns; while for others, a stable regulatory
climate is equally important.
The wide difference in disposal costs between RCRA-C facilities and conventional LLRW
disposal or disposal in the few available MW facilities indicates that significant cost savings
could be achieved, even if only a small fraction of the total amount of the MW generated
nationally were to qualify for disposal as LAMW under this rule. An evaluation of operating
commercial RCRA-C facilities shows that they have ample disposal capacity for the small
amounts of LAMW currently held in storage and expected to be generated in the future.
The States, in exercising their discretionary powers, will determine whether to allow this
alternative, considering existing laws and public participation. It is expected that RCRA-C
facility operators and commercial LAMW generators will utilize the flexibility of the standard,
taking into account practical and economic factors.
An important aspect of the proposed LAMW disposal rule is that it does not impose any new
regulatory or technology requirements, nor does it relieve commercial RCRA-C facility operators
and commercial LAMW generators from having to comply with existing Federal and State
regulations addressing hazardous materials. This rulemaking offers only potential net benefits
because of its voluntary nature. It imposes no new disposal costs and is expected to result in
lower disposal costs for LAMW, as compared to current commercial services. Finally, the rule
permits an additional disposal option for LAMW that is not currently available and better
protects the public and environment by eliminating prolonged storage in numerous facilities not
designed to offer the best level of protection and containment.
ES-2
-------
Chapter 1
Objective of the Regulatory Impact Analysis
1.0 Introduction
Under the authority of the Atomic Energy Act (AEA) of 1954, as amended (AEA 1954), the
Environmental Protection Agency (EPA) is proposing a generally applicable environmental
standard (40 CFR Part 193) for land disposal of low-activity mixed waste (LAMW) generated by
commercial facilities. LAMW is characterized by the presence of both hazardous chemicals and
radioactive materials regulated under the AEA, and excludes high-level waste, transuranic waste,
spent nuclear fuel, or byproduct material, defined as uranium or thorium tailings. Typically,
however, LAMW contains radioactive materials similar to those found in Class A low-level
radioactive waste (LLRW), regulated under 10 CFR Part 61 (Licensing Requirements for Land
Disposal of Radioactive Waste), but at lower concentrations. Otherwise, commercial LAMW is
analogous to other wastes classified as Resource Conservation and Recovery Act (RCRA)
hazardous waste.
Various categories of commercial waste generators, including medical, educational, and
industrial facilities and nuclear power plants, currently generate most of these wastes in small
amounts. This type of generation is likely to continue well into the future. Activities that
generate LAMW include research and development (R&D), laboratory analyses, facility
maintenance, nuclear power plant outages, and decontamination in support of routine facility or
plant operations. In general, such activities do not create new hazardous substances; rather,
LAMW is generated when chemicals are used as cleaning agents or solvents or are part of a
process and thus become commingled with radioactive materials. As a result, commercial
LAMW is often well suited to treatment methods that are currently applied for similar types of
RCRA hazardous wastes. These methods include incineration, vitrification, solidification,
encapsulation, chemical treatment, and recycling.
The disposal of LAMW is complicated by the dual regulatory requirements of RCRA Subtitle C
regulations and the AEA. If it were not for the presence of radioactivity, LAMW would
otherwise be classified and disposed of as RCRA hazardous waste. Because of the increased
need for disposal facilities and the wish to streamline the regulatory process for such wastes, the
EPA is proposing a standard that will promote the safe and permanent disposal of LAMW.
1-1
-------
Additional information supporting the Regulatory Impact Analysis (RIA) can be found in the
Background Information Document for 40 CFR Part 193 (BID).
1.1 Purpose and Scope
This regulatory action addresses the protection of public health by proposing a radiation
exposure standard, 40 CFR Part 193, for land disposal of treated waste characterized by the
presence of hazardous materials and low levels of radioactivity. The disposal method being
considered includes technologies that are used for the disposal of hazardous waste regulated
under RCRA Subtitle C regulations. States have the prerogative in deciding whether this
alternative will be allowed, taking into account existing laws, local governments, and public
participation. Moreover, the Nuclear Regulatory Commission (NRC) and Agreement States
(collectively referred to as "NRC/AS") will be involved because of the presence of AEA-
regulated radioactive materials in LAMW. Since the standard also addresses the presence of
hazardous materials, the disposal technology being considered here is already governed by
Federal and State authorities under RCRA regulations. Accordingly, the standard does not
relieve commercial disposal facilities from having to comply with all applicable regulatory
requirements addressing the presence of hazardous materials, characterizations, and treatment
prior to disposal. Finally, the proposed standard does not relax existing waste acceptance criteria
for disposal facilities regulated by the EPA and State and local agencies.
The proposed rule would provide commercial RCRA Subtitle C facility (RCRA-C facility)
operators and commercial LAMW generators with a more flexible and cost-effective method for
disposing of specific types of mixed waste (MW), given current Federal and State regulations.
Without this action, waste disposal costs are expected to remain high or even increase, since
LAMW would have to be disposed of in facilities designed to receive more hazardous waste or to
be stored for indefinite time periods at the point of generation. The proposed rule would also
free up disposal capacity at facilities specifically designed to receive more hazardous LLRW or
MW, and allow the disposal of LAMW in other, but equally protective facilities. Accordingly,
the proposed standard provides an effective method for disposing of LAMW, which is also
commensurate with the waste's radiological and hazardous properties. In turn, these
considerations should encourage waste generators to dispose of rather than store LAMW. In the
long term, this approach is generally safer for workers and the public, as it places LAMW into a
1-2
-------
small number of facilities designed for disposal, as opposed to leaving it in storage in numerous
facilities not necessarily designed to offer the best level of containment and protection.
Commercial RCRA-C facility operators and commercial LAMW generators are expected to
evaluate and utilize the proposed rule at their discretion, taking into account specific
implementation requirements imposed by the NRC/AS, anticipated demand for this type of
disposal service, and competitive market forces. Given these constraints and uncertainties, the
standard will be used only if the balance between the cost of complying with specific
requirements of the rule and incremental revenues or profits is positive, other factors being equal.
The purpose of the RIA is to assess the merits and potential benefits of EPA's proposed action, as
compared to current practices. In this context, current practices are assumed to include:
• Indefinite storage at the point of generation
• Disposal as hazardous waste after treatment to remove radioactive constituents
• Disposal as LLRW after treatment to remove hazardous constituents
• Treatment and disposal at facilities specifically authorized (e.g., Envirocare) to
receive only certain types of LAMW
The last two examples rely on disposal technologies that are currently in use within the
commercial sector and in compliance with existing LLRW regulations under 10 CFR Part 61 or
equivalent Agreement State regulations. This approach assumes that ultimately the radioactivity
would be disposed of in a facility approved for the disposal of certain types of MW (e.g.,
Envirocare) or in a LLRW facility, such as Barnwell or Richland, after the hazardous
components of the waste have been removed. Since management practices for all LLRW and
certain types of MW already meet applicable Federal and State requirements, the analysis
focuses on assessing differences in impacts for the disposal technology being considered and
comparing them to current practices.
EPA's analysis of the protectiveness of this disposal alternative shows that risks to the Critical
Population Group (CPG) and impact on the environment are minimal, when compared to current
practices involving the storage of LAMW in numerous facilities that offer much less protection.
Although population health effects were not directly modeled, they are assumed to be neutral
because the radioactive component of LAMW, after treatment, ultimately would be disposed of
in a regulated disposal facility.
1-3
-------
Although disposal costs vary depending on waste forms, chemical constituents, radioactivity
levels, and required treatment, waste disposal costs for RCRA-C facilities are much lower than
those for facilities designed for LLRW. For RCRA-C facilities, disposal costs range from $44 to
$220 per cubic meter, while disposal costs for LLRW (i.e., mixed waste treated to remove the
hazardous component) in an NRC/AS disposal facility vary from about $4,000 to $15,000 per
cubic meter. Accordingly, significant savings could be achieved, if even a small fraction of the
total amount of mixed waste generated nationally were to qualify for disposal as LAMW under
this proposed action. The costs of treating LAMW prior to disposal and transportation to
treatment facilities are assumed to be neutral. Transportation costs could in fact be lower, at least
for some LAMW generators, since the proposed rule might result in the availability of additional
disposal sites, located within shorter distances.
1.2 Regulatory Objective and Legal Framework
RCRA-C disposal facility operators utilizing the proposed rule will have to comply with the
regulatory provisions of the EPA and NRC/AS for radioactive materials covered by the AEA. In
addition, the EPA recognizes that States have discretionary powers in deciding whether this
alternative will be allowed, taking into account existing laws, local governments, and public
participation. The proposed standard does not relieve commercial RCRA-C facility operators,
nor commercial LAMW generators, from having to comply with all applicable regulations
addressing the presence of hazardous materials.
These complexities affect the assessment of economic impacts by circumscribing the regulatory
alternatives available, limiting the degree to which cost and risk are used as criteria in comparing
alternatives, determining the manner in which the EPA's standard would be implemented by
other regulatory agencies (NRC/AS), and, finally, determining the costs and risks of current pre-
disposal and disposal practices. Consequently, the economic impact of EPA's proposed standard
depends entirely on the actions of commercial LAMW generators and RCRA-C facility operators
in response to legal constraints arising from these and other Federal and State regulations.
1.2.1 EPA Statutory Authorities
The goal of this action is to provide an additional regulatory avenue for expanding the
availability of LAMW disposal facilities. The statutory authority is the Atomic Energy Act
1-4
-------
(AEA) of 1954, as amended (42 U.S.C. 2011-2296), and Reorganization Plan No. 3 of 1970.'
The Plan transferred the Atomic Energy Commission's (AEC) authority to establish
environmental protection standards for radioactive materials under the AEA to the EPA. The
Plan authorizes the EPA to "establish generally applicable environmental standards for the
protection of the general environment from radioactive material." Under the Plan, standards are
"limits on radiation exposures or levels, or concentrations or quantities of radioactive material,"
that apply to contamination "in the general environment outside the boundaries of locations
under the control of persons possessing or using radioactive material."
The EPA's generally applicable standards must be implemented and enforced by other Federal
agencies. Functions not transferred to the EPA were retained by the AEC, now succeeded by the
NRC and Department of Energy (DOE). EPA's standards apply "outside the boundaries of
locations under the control of persons possessing or using radioactive material." NRC and its
licensees are "persons possessing or using radioactive material" and NRC-licensed sites or
facilities are "locations under [their] control." The EPA's generally applicable standards will "be
used by the AEC/NRC and other Federal agencies in carrying out their direct activities." In
addition, Executive Order 12088, amended in 1987, requires Federal Executive agencies to
comply with "applicable pollution control standards." Thus, NRC, DOE, and other Federal
agencies are responsible for ensuring, through licensing requirements and other restrictions, that
activities at regulated facilities do not exceed the EPA's generally applicable standards.
1.2.2 Implementation and Applicability of Existing Regulations
While the EPA has the authority to promulgate a waste disposal standard, RCRA-C facility
operators are given the responsibility of complying with this and other applicable EPA standards.
Other than noting that the EPA will rely on the NRC/AS for the implementation of the proposed
rule, it is uncertain as to how the proposed rule would in fact be implemented. Currently, the
treatment and disposal of LLRW and MW are regulated under rules promulgated by the EPA,
NRC or Agreement State agencies, and other local government entities. The following presents
an overview of pertinent regulatory requirements and discusses their impacts on or relationships
to the proposed rule.
Reorganization Plan No. 3 of 1970 (35 Fed. Reg. 15623, October 6, 1970), effective December 2,
1970. 84 Stat. 2086 (1970) (codified at 5 U.S.C. App. 1) [hereinafter "the Plan"].
1-5
-------
a) Hazardous and Mixed Waste Regulations
Mixed waste is defined as a waste that contains a hazardous component and radioactive material.
A hazardous waste is either listed under 40 CFR Part 261, Subpart D, and/or exhibits a
characteristic described in 40 CFR Part 261, Subpart C. These characteristics are:
• Ignitability
• Corrosivity
• Reactivity
• Toxicity
Under the exclusions of 40 CFR Part 261.4(a)(4), RCRA explicitly excludes source, byproduct,
and special nuclear material from the definition of "solid" and therefore "hazardous" waste, but it
does not exclude naturally occurring or accelerator-produced radioactive materials (NARM). For
listed wastes, generators must determine whether any waste constituents are listed as hazardous
substances in 40 CFR Part 261, Subpart D. The listings are presented as three categories and
identified by EPA hazardous waste codes. The waste codes are associated with specific waste
descriptions, specific processes that produce waste, or certain chemical compounds. Generators
that produce such wastes are expected to determine, based on process knowledge or appropriate
sampling or analysis, which wastes are RCRA hazardous wastes by examining the listed waste
descriptions and codes. For example, a generator using halogenated solvents (e.g.,
tetrachloroethylene) to remove paint from a radiologically contaminated surface, can determine
that this waste is a listed RCRA hazardous waste by examining the definition for the F002 waste
code for the type of solvents, solvent mixture and blend, and concentration.
In addition to wastes that are specifically listed as hazardous, the "derived from" and "mixture"
rules State that any solid waste derived from the treatment, storage, or disposal of a listed RCRA
hazardous waste or any solid waste mixed with a listed RCRA hazardous waste is itself a listed
RCRA hazardous waste until delisted, as defined in 40 CFR Part 261.3. Soils and debris must
also be managed as hazardous waste if they contain listed waste or exhibit one or more hazardous
waste characteristics, as defined in 40 CFR Part 268.2. The mixture rule prohibits the use of
dilution of land disposal restricted wastes or treatment residuals as a substitute for appropriate
treatment. Exceptions to this prohibition include the dilution of purely corrosive and some types
of reactive and ignitable waste to eliminate the characteristics from the waste. Finally, some
hazardous wastes that are listed solely for a characteristic identified in Subpart C (e.g., a spent
solvent (F003) that is listed only because it is ignitable) are not considered a hazardous waste
1-6
-------
when they are mixed with a solid waste and the resultant mixture no longer exhibits any
characteristics of a hazardous waste.
Hazardous waste disposal facilities are regulated under RCRA requirements of 40 CFR Parts 261
to 268, addressing facility siting and design, waste characterization and treatment, land disposal
restrictions, operation, contingencies, storage and transportation, ground water monitoring and
protection, closure and post-closure care, and financial assurances. The duration of the post
closure care period is 30 years, but it can be extended by the EPA Regional Administrator. The
RCRA program was developed for implementation by State agencies, with EPA oversight. State
regulations are equivalent to EPA regulations, but some States have imposed more stringent
requirements. Once authorized by the EPA, States have the option of defining additional wastes
as hazardous waste under State programs.
For MW, the EPA has determined that the hazardous component is subject to RCRA regulations
(51 Fed. Reg. 24504, July 3,1986). Radioactive material must be classified as source, special
nuclear, or byproduct material subject to the Atomic Energy Act of 1954, as amended. The EPA
has authorized States to revise their programs to incorporate the authority to regulate the
hazardous component of mixed waste. Currently, 39 States have that authority. The eight States
that have base RCRA hazardous waste programs but do not have EPA MW authorization are
Massachusetts, Maine, Rhode Island, New Jersey, Maryland, Virginia, West Virginia, and
Pennsylvania. Finally, the EPA regulates all hazardous wastes in three States, Alaska, Hawaii,
and Iowa, and in all other U.S. Trust Territories, except Guam. In States that are not authorized
for MW, the RCRA land disposal restrictions are in effect. The EPA, NRC, and DOE have
jointly addressed disposal requirements for MW by issuing specific technical guidance (EPA
1997a, 1996a,b,c, 1995,1990a,b, 1987a,b; DOE 1994a,b;NRC 1995,1992a,b, 1989,1988,1987,
1985; 62 Fed. Reg. 62079, November 20,1997). The guidance provides information on a variety
of topics, including clarification on the definition and identification of MW, sampling, testing
and treatment requirements, emerging treatment technologies, best management practices to
minimize MW generation, land disposal restrictions, conceptual designs for disposal facilities,
and siting guidelines.
In the context of the proposed rule, the EPA has determined that there are no major regulatory
impediments that would restrict the introduction of radioactive materials in RCRA-C facilities, as
long as these facilities comply with AEA requirements for the radioactive component of the
1-7
-------
waste. In any case, the requirements addressing the hazardous components of the waste would
remain unchanged.
b) Low-Level Radioactive Waste Regulations
NRC regulations addressing the disposal of LLRW are contained in 10 CFR Part 61, Licensing
Requirements for Land Disposal of Radioactive Waste. The NRC regulations identify
performance objectives addressing the protection of the public and individuals during facility
operations and after closure. The NRC dose limits for members of the public are:
• Annual dose of 25 mrem to the whole body
• Annual dose limit of 75 mrem to the thyroid
Annual dose limit of 25 mrem to any other organ
• All doses and releases of radioactivity should be as low as is reasonably
achievable
In Agreement States, regulations for LLRW disposal have been patterned after the NRC rule,
and, consequently, have similar requirements and dose limits.
The technical requirements address site selection and suitability criteria, facility design,
operation, contingencies, environmental monitoring, waste classification, and waste
characteristics. Low-level radioactive wastes are classified as Class A, B, and C, with Class C
being the most restrictive. Greater-Than-Class-C (GTCC) wastes are considered more hazardous
and warrant more stringent disposal methods, e.g., technologies considered for high-level waste.
Also, 10 CFR Part 61 excludes from its requirements waste containing uranium and thorium
tailings or wastes in quantities greater than 10,000 kg and containing more than five millicuries
of Ra-226. The NRC rule specifies radionuclide concentration limits and waste stability criteria
for each class. Wastes not meeting any of these requirements are excluded and must be managed
by other methods.
The regulations also address facility closure and post-closure institutional care and financial
assurances. Upon closure, the site is prepared for institutional care to ensure that the site and
disposal units will remain stable and not require on-going active maintenance. The custody of
the site is to be transferred to a government entity responsible for its long-term monitoring and
1-8
-------
care. The duration of the post-closure phase is five years, and the duration of the institutional
care period is at least 100 years.
For the proposed rule, the NRC might pattern specific implementation criteria after 10 CFR Part
61. Because 10 CFR Part 61 addresses categories of LLRW that are, on average, more
radiologically hazardous, the requirements for the proposed LAMW rule are expected to be
different. The NRC might decide that the proposed rule could be more efficiently implemented
under the provisions of a general or specific license developed expressly for the rule.
The impact of the proposed regulation on current LLRW management efforts, as managed by
Low-Level Waste Compacts and unaffiliated States, may need to be assessed at the regional or
State level. The radioactive component of LAMW may fall under the jurisdiction of such
entities, depending upon charters and statutes enacted in response to the Low-Level Radioactive
Waste Policy Amendments Act of 1985 (Public Law 99-240). In light of the small amounts of
LAMW that might be disposed of under the proposed rule, this action is not expected to impact
current efforts to develop regional LLRW disposal facilities.
c) Occupational Radiation Protection Regulations
Under the Atomic Energy Act of 1954 (AEA), the Nuclear Regulatory Commission (NRC) has
the responsibility for establishing radiation protection regulations. These regulations cover
activities and radionuclides that fall under the definition of (a) source material, (b) by-product
material, and (c) special nuclear material. Section 274(b) of the AEA also authorizes the NRC to
enter into agreements that allow States to regulate certain activities. Under this program, a State
must have passed its own enabling legislation of authority and must have promulgated
regulations that are compatible with those of the NRC. Under this program, 30 States have
entered into agreements with the NRC and have assumed jurisdiction over the use of by-product
materials (NRC 1998a). These provisions are separate from the States' responsibilities in
protecting workers and the public under rules and regulations addressing naturally occurring and
accelerator-produced radioactive materials (NARM), which are based on requirements similar in
scope to 10 CFR Part 20, Standards for Protection Against Radiation.
Part 20 establishes standards to guard licensees, their employees, and the general public against
radiation associated with the receipt, possession, use, or transfer of source, byproduct, or special
nuclear materials licensed by the NRC (NRC 1998b). The NRC issued a revised version of 10
CFR Part 20 on January 1,1994 (57 Fed. Reg. 38588, August 26, 1992). The revised standards
1-9
-------
reflect current scientific information on radiation protection. Limits for external and internal
radiation exposures were also revised and updated using international concepts. The annual
radiation exposure limit for members of the general public has been reduced to 100 mrem from
500 mrem. Among other requirements, the regulations impose limitations governing:
• Occupational exposure to radiation and radioactive materials
• Concentrations of radioactive material that may be discharged into air or water
• Radiation exposures to the general public
• Facility closure, license termination, and decontamination criteria
These requirements apply to all materials licensed under NRC and Agreement State regulations
and cover all facility operations, including waste management activities, such as treatment,
storage, and preparation for disposal.
The proposed rule considers exposures to RCRA-C facility workers. It compares maximum
LAMW radionuclide concentration limits to annual radiation exposure levels due to
radionuclides that are immobile in ground water or that decay before reaching ground water.
These aspects of the proposed rule should not be interpreted as a redefinition of radiation dose
limits to workers under existing NRC/AS regulatory provisions. Nevertheless, NRC/AS are
expected to evaluate these and other considerations in light of the proposed LAMW rule and
develop a regulatory regime that would be commensurate with the radiological hazards
corresponding to the maximum allowable LAMW radionuclide concentration limits.
d) Atmospheric Radioactive Emissions under NESHAP Regulations
Waste processing may result in the release of radioactivity into the atmosphere, and such
emissions are covered by EPA and NRC regulations. Under 40 CFR Part 61, National Emission
Standards for Hazardous Air Pollutants (NESHAP), the EPA initially regulated the presence of
radioactivity released from all emission sources, including stacks and vents. Such emissions are
regulated under Section 112 of the Clean Air Act and NESHAP (54 Fed. Reg. 51694, December
15,1989). The EPA has since withdrawn the application of NESHAP to NRC and Agreement
State-licensed facilities and gave the NRC and States oversight under 10 CFR Part 20.1101(b)
and NRC Regulatory Guide 8.37, ALARA Levels for Air Effluents from Materials Facilities. The
annual dose limit has remained the same, 10 mrem from all pathways. The requirements apply to
all facilities licensed by NRC/AS, including those engaged in waste processing activities.
1-10
-------
The proposed rule would not result in any changes to NESHAP regulations since the rule focuses
on land disposal. Any facilities treating LAMW for disposal under the proposed rule would be
required to meet all associated requirements, as implemented by the NRC and Agreement States.
1.3 Objective of Regulatory Impact Analysis
The objective of the RIA is to assess the possibility that the proposed rule (40 CFR Part 193) will
offer some net societal benefits, with no degradation in the protection of the public and
environment. Also, the standard is being proposed in the spirit of current Federal efforts to
redesign the regulatory process and minimize the regulatory burden, as recommended by the
National Performance Review (Gore 1993, 1995). The analysis was conducted with an
awareness of other considerations, e.g., a desire to avoid disrupting any activities associated with
the operation of existing commercial RCRA-C disposal facilities or activities supporting the
siting and construction of new LLRW disposal facilities.
Executive Order (EO) 12866 requires EPA to perform a regulatory impact analysis if a regulation
is "major" in its impact (EOP 1993a,b). Under the EO, a regulatory action is considered to be
major if it results in a rule that may:
• Have an annual effect upon the economy of $ 100 million or more or adversely
affect in a material way the economy; a sector of the economy, productivity;
competition; jobs; the environment; public health or safety; or State, local, or
tribal governments or communities
• Create a serious inconsistency or otherwise interfere with an action taken or
planned by another agency
• Materially alter the budgetary impact of entitlements, grants, user fees, or loan
programs or the rights and obligations of recipients thereof
• Raise novel legal or policy issues arising out of legal mandates, the President's
priorities, or the principles set forth in the Executive Order
The EO addresses rulemaking activities that impose new or additional requirements on a
regulated community. However, it is not clear how the requirements of the EO apply to this
regulatory action, since the proposed standard aims to improve the effectiveness of existing
regulations, thereby resulting in cost savings. The standard would be implemented at the
1-11
-------
discretion of RCRA-C facility operators and commercial LAMW generators, who would
consider their own economic interests. Market theory suggests that the relaxation of unnecessary
regulations would result in some benefits to society. The RIA foresees such benefits as an
incentive to provide new or expand existing types of LAMW disposal services, an increase in
MW disposal capacity, and lower disposal costs.
Given these considerations and uncertainty about the applicability of EO 12866, the RIA has
been prepared in a manner generally consistent with the order, but without a formal analysis of
the associated costs and risks of alternatives. The RIA focuses on the impacts and societal
benefits associated with the disposal of LAMW in RCRA-C facilities. Specifically, the objective
of the analysis is to demonstrate that the disposal of LAMW, using RCRA-C disposal
technology, is workable under current waste disposal practices and complies with the
requirements of the EPA, NRC, and Agreement States, assuming that States would allow the
proposed alternative.
The EPA anticipates that NRC/AS, after evaluation, would allow the proposed practice and
implement a regulatory program commensurate with the radiological hazards associated with the
maximum LAMW radionuclide concentration limits. It is envisioned that the regulatory program
would offer a licensing procedure that is different from existing requirements under 10 CFR Part
61 for RCRA-C disposal facilities. Occupational radiation protection would likely be addressed
in light of 10 CFR Part 20 or equivalent State regulations. These issues will directly influence
how commercial RCRA-C facility operators evaluate the feasibility of the proposed rule. For
example, if some of the operators deem the requirements imposed by NRC/AS as too onerous in
light of expected revenues, these operators may decide not to use the provisions of rule. The
decision to use the rule will depend upon the anticipated amounts of LAMW, incremental
operational costs associated with the NRC/AS licensing process, competitive market pressure,
liability, and any additional requirements imposed by State and local governments.
Currently available information regarding MW and LAMW generation rates, volumes, streams,
and radioactivity levels from the commercial sector is insufficient to allow the EPA to perform
more detailed cost and risk assessment analyses. Given the lack of definitive information, the
RIA makes various assumptions and relies on the results of studies characterizing MW volumes
and disposal costs, while recognizing that this simplified approach may not fully represent actual
1-12
-------
LAMW disposal practices. For example, a review of various studies has revealed shortcomings
in:
Determining the total number of facilities generating MW and LAMW
• Assessing the representativeness of facilities captured in past surveys to the
population of MW and LAMW generators
Identifying the various types of MW and LAMW streams and volume
distributions between orphan and treatable MW
• Determining radionuclide distributions and concentrations in MW and LAMW
As a result, the RIA relies on existing characterization studies, while recognizing that the
information incorporates specific uncertainties. Therefore, the results of the MW
characterization should not be interpreted in absolute terms, but rather should be viewed as
bounding estimates and indicators of the variability among activities that result in the generation
of LAMW and LAMW properties. The difficulty in characterizing LLRW and LAMW (as a
subcategory of MW) and inconsistencies in prior characterization results have been addressed by
others (NRC 1990a, 1994a, DOE 1993). Consequently, the shortcomings noted here are
essentially identical to those reported elsewhere.
1.4 Report Format
The RIA contains the following:
• The Executive Summary is contained in Chapter ES of the RIA.
• The introduction, purpose and scope, and legal framework of the RIA are
presented in Chapter 1.
• The proposed standard and level of protection are described in Chapter 2.
• Chapter 3 summarizes waste disposal alternatives, including RCRA-C facilities,
shallow-land burial, low-activity radioactive waste disposal, and assumed facility
features used in modeling exposures and calculating doses.
• Chapter 4 presents a summary of commercial mixed waste volumes and
properties, using the information presented in Chapter 2 of the BID.
1-13
-------
Chapter 5 presents cost data for the disposal of MW, using selected disposal
technologies, and compares such costs with those of other disposal alternatives,
including LLRW technology. This section also presents information on treatment,
storage, and shipping costs.
• Chapter 6 presents the results of the economic analyses, based on the information
given in Chapters 3,4, and 5.
• Chapter 7 summarizes the results and conclusions.
Additional information about the basis and results of the risk assessment analysis can be found in
Chapters 4,5,6, and 7 of the Background Information Document for 40 CFR Part 193 (BID).
1-14
-------
Chapter 2
Proposed Rule for the
Disposal of Low-Activity Mixed Waste
2.0 Introduction
The EPA is proposing a standard (40 CFR Part 193) to ensure that low-activity mixed waste
(LAMW) will be disposed of in a manner that is protective of the public and environment. The
proposed standard will give commercial LAMW generators the flexibility to dispose of such
waste in a cost-effective manner in commercial RCRA Subtitle C facilities (RCRA-C facility).
Additional details about the objective of the rule are presented in Chapter 1 and the Background
Information Document for 40 CFR Part 193 (BID) presents the supporting technical analysis.
2.1 Proposed Low-Activity Mixed Waste Standard
The EPA standard (40 CFR Part 193) does not differentiate among the various types of LAMW
routinely produced by commercial mixed waste (MW) generators. The common denominator of
such wastes is that they are all characterized by low levels of radioactivity and the presence of
hazardous materials. Conceptually, the following diagram illustrates the relationship among
radioactive waste, hazardous waste, and LAMW, as a subcategory of MW.
Hazardous
Waste
(RCRA Authority)
Radioactive
Waste
(AEA Authority)
Mixed
Waste
2-1
-------
The proposed rule includes tables of maximum LAMW radionuclide concentrations that provide
long-term public health protection for members of the Critical Population Group (CPG) and an
annual dose of 15 mrem to RCRA-C facility workers. The proposed EPA standard includes the
following major features:
• Maximum LAMW radionuclide concentration limits for environmentally mobile
radionuclides ensure that members of the public will not receive exposures
exceeding the Maximum Contaminant Levels (MCLs) for drinking water, based
on default CPG-dose modeling assumptions characterizing hypothetical sites,
RCRA-C facility design features, LAMW volumes, and hydrogeological settings.
Maximum LAMW radionuclide concentration limits for radionuclides that are
environmentally immobile or decay before reaching ground water ensure that
annual doses to RCRA-C facility workers do not exceed 15 mrem (CEDE).
• Provisions to allow RCRA-C facilities to develop site-specific maximum LAMW
radionuclide concentration limits that are equivalent to the MCLs, based on long-
term performance assessment analyses using site characteristics and facility design
features.
• Maximum LAMW radionuclide concentration limits ensure that radionuclide
waste concentrations are less than the limits of 10 CFR Part 61.55 for Class A
waste. This restriction also applies to LAMW radionuclide concentrations
developed using site-specific characteristics and facility features.
In preparing the proposed rule, the EPA has examined a series of technical issues, including the
amounts and characteristics of LAMW being generated, the suitability of RCRA-C disposal
technology for waste containing low levels of radioactivity, potential exposure scenarios to the
CPG and facility workers, and the impact of waste form and site-specific climatic and
hydrogeologic factors on radionuclide mobility. In developing maximum LAMW radionuclide
concentration limits, the EPA conducted performance assessment analyses for RCRA-C facilities
assumed to be located in different climatic regions of the United States.
The proposed rule recognizes that RCRA-C facility operators choosing to utilize the provisions
of the rule will need to obtain the appropriate authorization from the NRC or Agreement States
(NRC/AS) to accept LAMW. Wastes will be considered "LAMW" if they are within the
maximum radionuclide concentration limits specified in the proposed rule. Waste with multiple
radionuclides will be restricted to the sum-of-the-ratios rule, i.e., the ratio of all radionuclide
concentrations to their respective limits in the waste mixture cannot exceed unity. In addition,
2-2
-------
the maximum LAMW radionuclide concentration limits will be incorporated into existing waste
acceptance criteria (WAC) developed for each RCRA-C facility.
The rule focuses on commercial RCRA-C facilities because the EPA believes they can provide
this service to the broadest range of commercial LAMW generators. Approximately 20
commercial RCRA-C disposal facilities operate in 16 States (EPA 1997c). Also, there are many
more privately owned RCRA treatment, storage, and disposal (TSD) facilities in the United
States (EPA 1997c). The EPA recognizes that commercial RCRA-C facility operators and
LAMW generators will utilize the proposed standard only after balancing the implementation
requirements embodied in the standard against economic and practical considerations. In the
absence of this standard, the disposal cost of LAMW is expected to remain high or even increase.
Given the high cost of disposal, generators may choose to store such wastes for indefinite time
periods in facilities that do not offer the best protection to the public and environment. The
standard will provide the means to readily dispose of a fraction of the MW volume currently
being held in storage throughout the nation. As a result, LAMW will be rendered less hazardous
through treatment and placement in facilities designed to ensure the long-term protection of the
public and environment.
Facilities that choose to accept LAMW will be subject to both radioactive and hazardous waste
regulations. Under NRC/AS oversight, RCRA-C facilities will be operated in a manner that
ensures compliance with regulatory requirements relating to the radiological component of the
waste, while RCRA-C provisions (including modifications to necessary permits and WAC) will
be overseen by the State, if it has RCRA-delegated authority, or the EPA, if it does not. The
EPA anticipates that NRC/AS might establish a licensing procedure, patterned after existing or
new regulatory requirements. The licensing procedure would take into account protectiveness
requirements to comply with the facility's RCRA-C permit, which would be available for NRC
evaluation. Although hazardous waste disposal facility operators currently have the option of
seeking, under 10 CFR Part 61 (Licensing Requirements for Land Disposal of Radioactive
Waste), a license to accept MW, this procedure is lengthy, complex, and costly. The EPA
believes that a modified licensing procedure would provide an appropriate level of review and
analysis to ensure the proper disposal of LAMW, while still encouraging the creation of
additional disposal capacity.
The rule does not address storage or handling of LAMW. The use of radioactive materials and
generation and storage of LAMW are currently covered under NRC/AS regulations and licenses
2-3
-------
required for any facilities possessing radioactive materials regulated under the AEA. However,
the EPA is expected to issue complementary regulations to existing requirements that address the
storage of mixed wastes, including LAMW. The implementation of the proposed rule is
expected to result in smaller amounts of LAMW being held in storage, which will benefit public
health and safety. Most agree that disposal is a better option than indefinite storage in numerous
facilities not designed to offer the same level of containment and protection offered by disposal
facilities.
Although an NRC/AS license is required to store and handle radioactive materials, the EPA
believes that it would be simpler to obtain the authorization to dispose of LAMW in a RCRA-C
facility than in a LLRW disposal facility. This is evidenced by the fact that thousands of
NRC/AS licensees, with storage and handling operations of varying complexity, are active in the
United States, while only three LLRW disposal facilities are currently operating. Even though
the proposed rule relies on RCRA-C disposal technology, there appears to be no significant
duplicate requirements under RCRA regulations that could be used to offset NRC/AS
requirements for storage and handling and in modifying disposal facility licensing procedure.
The proposed rule considers occupational radiation exposure and doses to RCRA-C facility
workers from radionuclides that are environmentally immobile or that decay before reaching
ground water. The safety of workers exposed to radioactive material is addressed by NRC
radiation protection standards under 10 CFR Part 20 (Standards for Protection Against
Radiation) and equivalent State regulations (NRC 1998b). However, the EPA believes that a
simplified facility licensing procedure could also include simplified radiation worker protection
requirements. If the proposed radionuclide concentrations were low enough, NRC/AS may not
require a full radiation protection program. RCRA-C facility operators are already required to
provide training under the "General Duty Clause" of the Occupational Safety and Health Act
(OSHA, PL 91-596) and OSHA regulations under 29 CFR Part 1910, Occupational Safety and
Health Standards. RCRA-C disposal facility operators may find the prospect of accepting
LAMW under the proposed rule less attractive if extensive requirements related to occupational
radiation protection were imposed.
In its analysis, the EPA has examined several radiation worker exposure scenarios to determine
maximum LAMW radionuclide concentration limits. All of the scenarios assume that LAMW
has already been treated and stabilized, e.g., in a cement and concrete mixture. This means that
exposures and doses to workers are confined to radionuclides that emit strong gamma radiation.
2-4
-------
Other types of radiation, i.e., alpha and beta particles and weak gamma or x-rays, are less likely
to result in exposures and doses because they cannot emerge from stabilized waste and pass
through the wall of the waste container. In its analysis, the EPA assumes that:
• LAMW is solidified in a cement and concrete matrix or in polyethylene
• LAMW containers, such as a metal 55-gallon drum, offer no protection in
reducing radiation exposure levels
• RCRA-C facility personnel work in proximity to waste containers
• Some radionuclides reach secular equilibrium through radioactive decay
• Transportation workers, such as truck drivers, are included in the analysis
• An accident occurs, involving the dropping of a waste drum
The EPA did not look at exposures during LAMW treatment or while wastes are being
generated. Radiation exposure levels and doses incurred during waste generation and treatment
depend on the types and distribution of radionuclides in LAMW and the treatment process.
Because treatment changes waste properties and radionuclide concentration levels, either by
dilution or re-concentration, the EPA would have to base its maximum LAMW concentration
limits on waste received at the treatment facility. This approach would have greatly increased the
complexity of the rule and required the evaluation of the full range of expected MW streams,
variability in radionuclide distributions and concentrations, and characteristics and effectiveness
of various waste treatment processes. The EPA does not intend to address radiation protection
requirements for facility workers and associated handling, processing, and treatment since such
facilities are already operating under existing NRC/AS radiation protection standards (NRC
1998b).
Finally, the proposed rule does not address transportation, since existing Department of
Transportation (49 CFR Parts 172 to 178), NRC (10 CFR Parts 20 and 71), and EPA regulations
(40 CFR Part 263) provide the necessary protection and oversight.
2-5
-------
2.2 Defining the Level of Protection
In deriving maximum LAMW radionuclide concentration limits corresponding to the MCLs, the
EPA has considered several factors, including the environmental mobility of radionuclides and
the long-term performance of RCRA-C facility technology. Many of these considerations reflect
prior Federal and other risk management decisions relating to the evaluation of LLRW disposal
options and acceptable levels of risk defined under different statutory and regulatory actions.
As a first step, the EPA considered national and international radiation protection guidance
developed by non-governmental bodies, such as the International Commission on Radiological
Protection (ICRP) and the National Council on Radiation Protection and Measurements (NCRP).
This guidance suggests a total annual individual dose limit of 100 mrem from exposure to all
radiation sources, except background, accidents, occupational exposures, and medical
procedures. The same dose level has been proposed in Federal Radiation Protection Guidance
for Exposure of the General Public (59 Fed. Reg. 66414, December 23, 1994), which will
become the overall policy for Federal agencies when the final version is published. The
proposed Federal guidance and ICRP Publication No. 46 (ICRP 1985) recommend the
apportionment of the total allowable radiation dose according to specific sources or practices.
The apportionment of the total dose limit is used to ensure that the annual total is less than 100
mrem from all sources of radioactivity or radiation. For comparison, current EPA radiation dose
limits are listed in Table 2-1. Given the novel nature of this proposal and allowing for some
uncertainty in the performance of RCRA-C disposal technology applied to LAMW, it was
deemed prudent to benchmark the maximum LAMW radionuclide concentration limits to MCLs
under the Safe Drinking Water Act (40 CFR Part 141, EPA 1991). Regarding the dose limits
presented in Table 2-1, it is important to understand that the limits are based on different risk
assessment methodology, namely the "critical organ dose" and "effective dose equivalent"
concept. In comparison, doses derived using the "critical organ dose" and "effective dose
equivalent" concept are not totally comparable, but in many instances the doses are roughly
equivalent for some radionuclides, e.g., Co-60 and Cs-137.
In addition to long-term performance, the proposed standard also addresses LAMW containing
radionuclides that are environmentally immobile or that decay before reaching ground water. For
these radionuclides, the concern is that RCRA-C facility workers could be exposed to varying
radiation levels. The exposure pathways include direct external radiation from wastes and
inhalation of contaminated airborne particulates and gases. Such a scenario and its associated
exposure pathways are commonly evaluated in assessing doses and risks to radiation workers.
2-6
-------
For example, the NRC has considered similar exposure scenarios and pathways in promulgating
10 CFR Part 61 for the disposal of LLRW (NRC 1982).
Table 2-1. Current EPA Radiation Dose Limits
Standard
Uranium Fuel Cycle (40 CFR Part 190)
Generic Standard for Management and Storage of
Spent Nuclear Fuel and High-Level Waste (40 CFR
Part 191.03)
Generic Individual-Dose Standard for Disposal of
Spent Nuclear Fuel and High-Level Waste (40 CFR
Part 191.15)
National Emission Standards for Hazardous Air
Pollutants (40 CFR Part 61)
Spent Nuclear Fuel and High-Level Waste Disposal
Limit for Underground Sources of Drinking Water (40
CFR Part 191.24)
Maximum Contaminant Levels for Community
Drinking Water Systems (40 CFR Part 141.16)
Criteria
25 mrem/year00
25 mrem/year^
15 mrem/yea^
lOmrem/year0"
4 mrem/year for beta- and photon-
emitting radionuclides(>)
(i «
(a) Criterion based on "critical organ dose"concept, using ICRP 2 methodology.
(b) Criterion based on "effective dose equivalent" concept, using the methodology of Federal Guidance
Report No. Hand 12.
In assessing exposures and risk to RCRA-C facility workers, an annual dose of 15 mrem was
selected, as compared to 5,000 mrem per year for workers who are declared "radiation workers"
under NRC 10 CFR Part 20 and equivalent State regulations (NRC 1998b). The EPA considers
the 15 mrem dose to be protective for members of the public.
Taking these factors into consideration, it can be shown that relating the maximum LAMW
radionuclide concentrations to the MCLs and an annual dose of 15 mrem for RCRA-C facility
workers is protective in the context of radioactive waste disposal regulations. Additional
information about the basis and results of the risk assessment analysis can be found in Chapters
4, 5, 6 and 7 of the Background Information Document for 40 CFR Part 193 (BID).
2-7
-------
Chapter 3
Disposal Facility Options
3.0 Introduction
In the context of the proposed standard, land disposal is defined as the permanent placement of
waste in specifically designed disposal facilities. Disposal methods are designed to ensure public
health and safety, protect the environment, and assure that protection is achieved over a
reasonable time period, i.e., the time over which the majority of health impacts could occur. The
analysis addresses disposal only in commercially-operated Resource Conservation and Recovery
Act (RCRA) Subtitle C facilities (RCRA-C facility), since this regulatory action addresses land
disposal of waste characterized primarily by the presence of hazardous materials with very low
levels of radioactivity. In addition, background information is presented about the features of
two other types of disposal facilities, a conventional shallow-land burial facility for low-level
radioactive waste (LLRW), and a disposal facility restricted only to specific types of mixed
waste (MW) characterized by very low radionuclide concentrations and containing specific types
of hazardous wastes.
3.1 RCRA-C Regulated Hazardous Waste Facility
Hazardous waste facilities are regulated under the requirements of 40 CFR Parts 261 to 268,
addressing facility siting and design, waste characterization and treatment, land-disposal
restrictions, operation, contingencies, storage and transportation, ground water monitoring and
protection, closure and post-closure care, and financial assurances. Such a facility, under the
requirements of 40 CFR Part 264.301, must have a liner designed, constructed, and installed to
prevent any migration of waste out of the facility to adjacent subsurface soils or ground water
and surface water during its active life, including the closure and post-closure periods (Figure 3-
1). The liner must be constructed of materials that have appropriate chemical properties and
sufficient strength and thickness to prevent failure due to pressure gradients (including static
head and external hydrogeologic forces), physical contact with wastes or leachates, climatic
conditions, and stress of installation and daily operation. The liner must be placed upon a
foundation capable of providing proper support and resistance to pressure gradients from above
and below the liner and preventing liner failures due to settlement, compression, or uplift. The
liner must cover all surrounding soils likely to come in contact with wastes or leachates.
3-1
-------
Evapotranspiration Rainfall
Layer Description
Topsoil/Subsoil Layer
Upper Drain Layer
HOPE Liner so-™.
Low Permeability Soil Layer
Lower Drain Layer
Soil Material
HOPE Liner eo m,i
Soil Liner
>2% Slope
yXV-V--'-V:-! >x:-y:V::-::::- •'.
• '''•'• '• •"""'•'"''• '" '" "''""• '' " "
Collection & Detection Systems S
To Leachate
Collection System
Figure 3-1. Schematic Representation of RCRA-C Facility Features
3-2
-------
The regulations also mandate the installation of a leachate collection and removal system
(LCRS) to manage all leachates from the facility. State regulatory agencies or the EPA Regional
Administrator specify design and operating conditions in the facility permit to ensure that the
leachate depth over the bottom liner does not exceed 30.5 centimeters (1 foot). The LCRS must
be constructed of materials chemically resistant to wastes and expected leachate constituents.
The materials must also be of sufficient strength and thickness to prevent collapse under the
combined pressure exerted by overlying wastes, cover materials, and by any equipment used at
the facility. In addition, the LCRS must be designed and operated to function without clogging
until the scheduled closure of the facility. Also, gas-collection systems are used to control
methane, which is generated by some types of bio-degradable materials.
New facilities constructed after January 29, 1992, must have two or more liners and an LCRS
above and between these liners. The LCRS also functions as a leak-detection system. This leak-
detection system must be capable of detecting, collecting, and removing leaks of hazardous
constituents at the earliest practicable time through all areas likely to be exposed to waste or
leachates during the active life and post-closure care periods. The liner system must include a
top liner designed and constructed of materials (e.g., a geomembrane) to prevent the migration of
hazardous constituents through the liner and a composite bottom liner consisting of at least two
components. The upper component must be designed to prevent the downward migration of
hazardous constituents. The lower component must be designed and constructed of materials to
minimize the migration of hazardous constituents, if a breach in the upper component were to
occur. The lower component must be constructed of at least 91.4 centimeters (3 feet) of
compacted soil material with a hydraulic conductivity of not more than 1 x 10"7 centimeters per
second. The liners must also comply with the design requirements noted above.
The facility must contain a surface-water run-on control system capable of preventing water from
entering the active portions of the facility during peak discharges associated with a 25-year
storm. It must also have a water run-off management system to collect and control water
volumes resulting from a similar type of storm. Collection and holding facilities (e.g., tanks or
basins) associated with water run-on and run-off control systems must be managed expeditiously
after each storm. While a facility is in operation, it must be inspected weekly and after
significant storms to detect evidence of the following:
• Deterioration, malfunctions, or improper operation of surface water run-on and
run-off control systems
3-3
-------
• The presence of liquids in the leak-detection systems
• Proper functioning of wind dispersal control systems
• The presence of leachates in and proper functioning of the LCRS
The operator of a RCRA-C facility must also document the exact locations and dimensions,
including the depth of each disposal cell, with respect to permanently surveyed benchmarks. The
contents of each cell must be recorded along with the approximate location of each type of
hazardous waste within each cell. Incompatible wastes and materials cannot be placed within the
same disposal cell.
Upon closure, all surface facilities and equipment are removed, except for those supporting the
operation of the LCRS and gas removal system. If needed, specific portions of the site that once
supported waste-management activities are remediated, and wastes thus generated are either
disposed of onsite or shipped elsewhere for disposal. The facility is periodically monitored for at
least 30 years; however, the EPA Regional Administrator may extend this time period. These
activities include maintenance to ensure the proper functioning of the LCRS and gas collection
system.
3.2 Conventional Shallow-Land Disposal for Low-Level Radioactive Waste
Conventional shallow-land-disposal (CSLD) technology is currently being used at two
commercially-operating LLRW facilities: Barnwell, South Carolina (Southeast Compact), and
Richland, Washington (Northwest Compact). Access to Richland is restricted to compact
member States only. Barnwell is currently accepting out-of-region waste; however, the future
availability of this site is still uncertain. These facilities meet most current waste disposal criteria
and are being operated in compliance with existing NRC/AS regulations. Attachments A-l and
A-2 summarize the waste acceptance criteria for each facility, addressing physical, radiological,
and chemical properties. The NRC regulations (10 CFR Part 61, Licensing Requirements for
Land Disposal of Radioactive Waste) address the disposal of LLRW in near-surface land
disposal facilities. Part 61 includes several requirements for design and performance objectives,
dose limits, site suitability criteria, facility design and operation, waste classification,
environmental monitoring, site closure, and long-term institutional controls (Figure 3-2). The
provisions of NRC/AS regulations include:
3-4
-------
Dose (EDE) limits for radioactive materials released in surface and water, air,
soils, plants and animals to <.2S mrem/yr to the whole body, ^75 mrem/yr to the
thyroid, and ^25 mrem/yr to any other organ of any member of the public
Provisions to limit radiation exposures to inadvertent intruders
System of waste classification and characterization
Waste radionuclide concentration limits for three classes of waste
Monitoring Well
Cover Soil
^^^^•^^^^^B
Intruder Barrier
Biotic Barrier
Drainage Layer
Low-Level Radioactive
Waste Containers
Figure 3-2. Schematic Representation of Low-Level Radioactive Waste Disposal Facility
Features
3-5
-------
The NRC and States have also issued additional guidance and requirements in the form of
regulatory guides, branch technical positions, and reports. These documents complement
regulatory requirements.
CSLD facilities incorporate specific design objectives and operating requirements specified in
NRC regulations addressing waste characterization and a waste classification system that assigns
radionuclide concentration limits for each class. The three classes of waste are Class A, B, and
C. The most stringent requirements apply to Class C waste. Class B and Class C waste can be
disposed of only in stable forms. For Class C waste, the disposal system requires an appropriate
cover over the waste or an intruder barrier. For Class B and C wastes, the regulations impose
minimum performance standards for the stability of containers and waste forms (300 years) and
longevity of human intrusion barriers (500 years). Any wastes exceeding Class C concentration
limits are not considered suitable for CSLD disposal and would be disposed of elsewhere with
high-level waste or held in storage.
Typically, wastes are placed in engineered shallow trenches, which include a liner made of
compacted soil or clay and liquid collection sumps. Waste, packaged in containers, is placed at
discrete locations, as opposed to random dumping. Waste segregation, either by radioactivity or
other categories (e.g., external radiation exposure rates or waste forms), is part of disposal
operations. If necessary, trenches may be dedicated to specific types of wastes. As each layer of
waste is emplaced, a clean fill or grout is placed over each successive layer. Alternatively, bulk
waste (when free flowing) may be used as backfill around waste containers and packages.
Higher activity wastes (Class B or C) are placed at the bottom of the trench and covered with
other waste and backfill.
When the trench is filled to its designed capacity, the wastes are covered by a multi-layered
capping system. The final cap consists of a system designed to route water infiltration away
from the trench and prevent mechanical erosion and biological intrusion. This cover typically
includes layers of sand, clay, geofabrics, gravel, cobble stones or boulders, and topsoil. The total
land used reflects the number of trenches required to accommodate the anticipated waste volume
over the life of the disposal facility, spacing between trenches, and buffer zone requirements
around the portion of the site dedicated to waste disposal. Upon closure, the site is observed for
a relatively brief period (about five years) before being placed in long-term care for about 100
years. During these time periods, the stability of the site is monitored, environmental samples
are collected and analyzed, and when needed, repairs are made.
3-6
-------
3.3 Low-Activity Waste Disposal at Specifically Authorized Sites
Additional background information is presented about other types of facilities that have been
authorized or are being considered for the disposal of specific types of radioactive wastes
characterized by very low radionuclide concentrations and containing specific types of hazardous
wastes. These facilities are authorized to receive, process, and dispose of radioactive materials
covered by the Atomic Energy Act (AEA) of 1954 and other materials regulated by State
agencies, as naturally occurring and accelerator-produced material (NARM) and naturally
occurring radioactive material (NORM). The two sites include an operational facility,
Envirocare of Utah, Inc., located in Clive, UT, and a new facility, Waste Control Specialists
LLC, located in Andrews County, TX.
3.3.1 Envirocare of Utah, Inc.
The Envirocare of Utah, Inc. disposal site (Envirocare) has been allowed to receive low-specific
activity radioactive waste, mixed waste, NORM/HARM waste, and 1 le.(2) byproduct material,
such as mill tailings and waste containing mill tailings (UDEQ 1998; Envirocare 1995, 1997;
NRC 1993a, 1994b). The site is regulated by the State of Utah's Bureau of Radiation Control,
Bureau of Solid and Hazardous Waste, the Nuclear Regulatory Commission, and the
Environmental Protection Agency (UDEQ 1998, Envirocare 1997). A hazardous waste RCRA
Part B Permit was granted by the State of Utah. The facility also holds a Hazardous and Solid
Waste Amendments permit issued by the EPA, authorizing the treatment, storage in tanks and
containers, and disposal of mixed waste in disposal cells. The facility is located within a 219-
hectare section of Tooele County, Utah. The facility is located in an arid region of the State,
with annual average precipitation rate of about 15 cm.
The low-specific activity radioactive waste and the NORM/NARM license was issued by the
State of Utah's Bureau of Radiation Control. The license application and technical basis were
patterned after the license for the disposal of 2 million cubic meters of mill tailings and EPA
requirements under 40 CFR Part 192. The approval for the disposal of low-activity radioactive
waste was recently amended to the Envirocare license (UDEQ 1998). The amendment
authorizes the disposal of byproduct materials, in addition to NORM/NARM under the same
license. The site has been permitted to dispose of 1 le.(2) byproduct waste from various sources
in dedicated cells (NRC 1993a, 1994b). The disposal of 1 le.(2) material is regulated by the
NRC, and a Part 40 license was issued in 1993 (NRC 1994b). The 1 le.(2) disposal area is about
44 hectares with a planned capacity of 2.3 million cubic meters. For radioactive materials, the
3-7
-------
license provides specific concentration limits for 86 radionuclides, from tritium to curium. The
concentration limits are based on a risk assessment analysis, which used the annual dose (EDE)
limits of 10 CFR Part 61.41 as criteria; the dose limits are 25 mrem to the whole body, 75 mrem
to the thyroid, and 25 mrem to any other organs for members of the public. Upon closure, the
DOE (or another designated Federal agency) will take possession of the 1 le.(2) disposal area.
The custodial agency will maintain in perpetuity a license under NRC regulations after site
closure. The facility has established three trust funds to satisfy State and Federal financial
assurance mechanisms for closure and post-closure maintenance (Envirocare 1997). The trust
funds cover mixed waste, low activity radioactive waste, and 1 le(2) byproduct materials.
Radioactive wastes are managed in bulk form and placed in 12-inch layers in engineered disposal
cells. Each cell includes a liner designed to meet specific requirements, based on waste
properties. Each layer is then covered with another 12 inches of clean soils, in a cut and cover
process. Each lift is compacted to 90% of its optimum density. Once a cell is filled to capacity,
the cell is covered with a seven-foot clay cover, a rock filter zone, and a coarse erosion barrier.
For mixed waste, the process involves placing the material in 12-inch lifts and compacting it to a
specified permeability rate. Wastes containing free-standing liquids are not acceptable; since the
waste is managed in bulk form and placed in 12-inch layers, the process makes it relatively easy
to identify waste with free-standing liquids. A clean soil cover is not used between lifts, unless
the cell is expected to remain idle for a protracted time, e.g., weeks to months. For waste that
cannot be compacted (e.g., solid debris), the facility uses a flowable fill (low-strength concrete)
to fill in void spaces. This waste emplacement method is very similar to that used at other
RCRA-C facilities.
The Utah Bureau of Solid and Hazardous Waste's permit and requirements for mixed waste have
been appended to the radioactive materials license issued by the Bureau of Radiation Control.
The permit lists approved waste streams using EPA land disposal restrictions (LDR) codes for
both specific and non-specific sources, including discarded commercial chemical products, off-
specification materials, manufacturing chemical intermediates, container residues, and spill
residues.
The license includes specific conditions addressing the disposal of mixed or hazardous waste,
which are regulated by the Utah Solid and Hazardous Waste Control Board and Environmental
Protection Agency. The license allows the presence of specific hazardous constituents, primarily
inorganics (e.g., arsenic, cadmium, and lead) and a few organics (e.g., acetone and methylene
3-8
-------
chloride). Other requirements address the presence of debris and its physical properties,
including limits on compressible and non-compressible materials, material gradation, and
dimensions for largest acceptable items. The waste acceptance criteria also require the submittal
of supporting waste characterization analyses, reports, and certifications.
For hazardous materials above RCRA limits, Envirocare is authorized to treat waste to meet the
EPA LDRs. The treatment is used to fix hazardous components within a solid matrix to impede
environmental mobility. The treatment processes include stabilization and solidification or
macro-encapsulation using polyethylene. Because of the size of the treatment and processing
unit, the facility imposes a minimum waste volume of 1.5 cubic meters. Attachment A-3
presents additional details of the waste acceptance criteria.
3.3.2 Waste Control Specialists LLC
Waste Control Specialists LLC (WCS) is a newly permitted commercial facility authorized to
store, process, and dispose of hazardous waste. The facility description and operational features
are based on WCS's 1996 application (WCS 1996,1998). The facility is permitted by the Texas
Natural Resource Conservation Commission (TNRCC). The facility has also been permitted by
the EPA to store, process, and dispose of waste under the Toxic Substance Control Act (TSCA).
In a separate application, WCS has requested the authorization to store, process, and ultimately
dispose of low-level radioactive waste. This application is being processed by the Texas
Department of Health - Bureau of Radiation Control (TDOH-BRC). The application is seeking
the authorization to dispose of radioactive materials, including Class A, B, and C low-level
waste, mixed waste, NORM, and certain types of source and special nuclear materials. As part
of the TNRCC and TDOH-BRC requirements, the facility has established a financial assurance
mechanism for closure and post-closure maintenance. The funding will cover hazardous waste,
mixed waste, and all radioactive waste.
The facility consists of 542 hectares, located within a 6,475-hectare track owned by WCS (WCS
1996). The site include a treatment facility, warehouses, and rail and truck yards. The waste
disposal areas include a large 7.1 million cubic meter RCRA-C facility, divided into 20 cells and
two smaller disposal areas of nearly 490,000 cubic meters each, divided into six cells each (WCS
1996). The smaller units will be used for the disposal of low level radioactive waste and mixed
waste, once authorized. The entire site is situated over a 244-foot thick bed of red clay. The
disposal units include liners equipped with a leak-detection system consisting of a layer of sand
between two compacted clay layers. The disposal units include the leak-detection wells, leachate
3-9
-------
collection wells and pumps, up- and down- gradient monitoring wells, and a surface water run-
off control system. The capping system includes layers of compacted clay and top soils, totaling
five meters in thickness. The annual average precipitation rate is about 36 cm in this part of
Texas.
The waste acceptance criteria address the presence of hazardous materials and radioactivity,
pending issuance of the license, which may include other provisions. The criteria impose
requirements on packaging, waste forms, and properties and characteristics analogous to those
specified in NRC regulations under 10 CFR Part 61. Material concentration and possession
limits have been specified for 83 radionuclides, ranging from H-3 to Cf-252. All waste
shipments must include a complete radiological characterization, including radionuclide
concentrations and total activity. Other requirements address physical properties, expected
treatment methods, description of the process responsible for the waste, listing of all applicable
EPA waste codes, and whether the waste is subject to the alternate treatment standards for debris
or national emission standards for benzene. The waste acceptance criteria also require the
submittal of supporting waste characterization analyses, reports, and certifications. Attachment
A-4 presents additional details on waste acceptance criteria.
3.3.3 Comparison of Requirements Between Low-Level Radioactive Waste Disposal Facilities
and RCRA-C Hazardous Waste Disposal Facilities
The following discussions present information about the major differences and similarities in
engineering concepts and regulatory requirements between low-level radioactive waste disposal
facilities and RCRA-C hazardous waste facilities.
a) Engineering Similarities
A review of design features indicates that the primary objective of both disposal technologies is
to ensure the long-term isolation of the waste from the environment and ensure that water is kept
away from the waste. Both concepts rely on a multi-layered capping system to intercept water
infiltration and drain it away from the disposal cell. The capping system also uses a protective
layer consisting of soil and vegetative covers to minimize wind and water erosion. If water were
to enter the disposal cell, both concepts include systems to detect, sample, collect, and treat
leachates. In both cases, wastes are placed in a manner that eliminates void spaces and relies on
the use of flowable material to fill in void spaces. These measures minimize subsidence of the
waste mass and avoid damaging the integrity of the capping system. In both cases, waste must
3-10
-------
meet specific waste acceptance criteria with respect to stability, restrictions on the presence of
water, and chemical compatibility. For waste not meeting specific waste acceptance criteria, the
requirements dictate that waste be treated using solidification and encapsulation agents, such as
concrete, asphalt, or polymers.
While the major differences in these engineered features tend to be more associated with their
prescriptive requirements, as dictated separately by the EPA and NRC, these design features
strive to achieve the same goal, i.e., containing and isolating hazardous wastes (radioactive and
mixed waste) from the environment.
b) Regulatory Differences
The disposal of radioactive materials and the disposal of RCRA-C hazardous waste are based on
different regulatory approaches. In the context of this rulemaking, the differences are important
because they relate to long-term performance requirements and assurance in demonstrating that
the commingling of radioactive materials and hazardous waste in RCRA-C disposal cells does
not introduce higher risks. More specifically:
• The RCRA approach is highly prescriptive, requiring engineering specifications
for the design of disposal cell liners and caps and leachate collection and
treatment systems. Also, RCRA regulations address operational requirements,
such as the construction of disposal cells, cell closure, ground water monitoring,
post-closure care, and long-term surveillance.
• The AEA approach is performance based, where the requirements impose
radiation exposure and/or dose limits to members of the public, define exposure
scenarios and pathways in assessing impacts on the public, and specify
concentration limits and release rates for radioactive materials migrating into the
environment.
• Both RCRA and AEA regulations assume different time frames in defining
regulatory and institutional controls and for assessing long-term performance. For
AEA materials, it is assumed that institutional knowledge and controls are lost
over time. For RCRA-C waste, the premise is that institutional controls are
maintained and the status of a closed facility is periodically evaluated. RCRA
regulations impose a relatively short post-closure care period (30 years).
However, the EPA Regional Administrator may extend the post-closure care
period to protect human health and environment. For AEA materials, the
institutional control period is 100 years, while long-term performance assessment
analyses consider impacts beyond 1,000 years. In addition, for more
3-11
-------
radiologically hazardous waste, AEA regulations impose standards for the
performance of waste matrices or containers (300 years) and human intrusion
barriers (500 years).
• To isolate hazardous wastes from the environment, RCRA regulations emphasize
containment and measures to monitor the status and stability of disposal cells
during operations, closure, and post-closure phases. AEA regulations
acknowledge that complete containment cannot be assured in the long-term and
that containment must rely on geological features and natural barriers isolating
wastes from the environment.
Although AEA and RCRA regulations are based on different approaches to protecting the
environment and public, the different requirements complement one another in the context of the
proposed rule. For example, the AEA perspective introduces long-term performance assessment
in RCRA system requirements by taking into account hydrogeological features. Furthermore,
the proposed rule does not impose new containment requirements on RCRA-C facility design or
additional specifications on waste forms; rather, the rule establishes maximum radionuclide
concentration limits for low-activity mixed waste (LAMW), based on MCLs for members of the
public from all exposure pathways, as a long-term performance standard, and exposure to
RCRA-C facility workers.
3.4 Overview of RCRA-C Hazardous Waste Management Methods
In 1995,208 million tons of hazardous waste subject to RCRA regulations were managed in
1,983 treatment, storage, and disposal (TSD) facilities, operated both privately and commercially
(EPA 1997b). Of these facilities, 900 were involved in treatment and disposal, while the balance
(1,083) were used for storage (EPA 1997c). Table 3-1 presents a breakdown of management
methods ranked by amounts of waste and number of facilities. A total of 18 waste treatment and
disposal methods, including four nondescript methods (Other Treatment, Other Disposal, Other
Recovery, and Unknown/Invalid Codes), were reported to have been used in 1995.
The majority of the waste (73%) was managed by aqueous treatment methods and 12.3% buried
in disposal cells. Land disposal includes disposal cells, surface impoundments, deepwell and
underground injection, and land treatment and application and farming. The total amount of
waste managed by all burial disposal methods is reported to be 25.6 million tons for 1995. As a
category, cell disposal was used for only 0.6 % of the total amount of waste; only 7.6% of the
TSD facilities used this management method.
3-12
-------
Table 3-1. RCRA Hazardous Waste Management Methods - 1995(a)
Management Method
Aqueous organic treatment
Aqueous organic and inorganic
treatment
Deepwell & underground
injection
Other treatment
Aqueous inorganic treatment
Incineration
Fuel blending
Energy recovery (reuse as fuel)
Landfill(c)
Stabilization
Other disposal - as specified
Metals recovery (reuse)
Surface impoundment
Sludge treatment
Other recovery
Solvent extraction
Land treatment/Application/
Farming
Unknown/Invalid codes
Total
Amount
Managed
(million tons)
116,542
27.66
23.76
17.9
8.37
4.29
244
1.91
1.25
1.02
0.66
0.609
0.575
0.481
0.422
0.356
0.0106
0.000020
208.27
Percentage
of Amount
560
13.3
11.4
8.6
4.0
2.1
1.2
0.9
06
0.5
0.3
0.3
0.3
0.2
0.2
0.2
0.0
0.0
100.0
Number of
Facilities""
106
30
38
320
145
166
100
125
68
85
31
71
7
30
62
164
10
1
900
Percentage
of Facilities
11.8
3.3
4.2
356
16.1
18.4
11.1
13.9
7.6
9.4
34
7.9
0.8
3.3
6.9
182
1.1
O.I
...
(a) Source. The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - National Analysis,
Exhibit 2.11 (EPA 1997b).
(b) Privately and commercially-operated facilities involved in waste treatment and disposal.
(c) Privately and commercially-operated disposal facilities.
3-13
-------
Table 3-2 lists commercial facilities that are approved for land disposal of hazardous waste. This
table also presents the amounts of waste received in 1995. Collectively, the 21 facilities managed
about 1.93 million tons of hazardous waste in 1995. The facilities are located in 16 States, with
three States having more than one facility; these States include California (3), Utah (2), and
Illinois (2). One of the facilities, Envirocare of Utah, Inc., located in Clive, UT, is authorized to
receive mixed waste. Currently, 20 facilities are authorized to receive hazardous waste on a
commercial basis. The Fort Wayne, IN, facility has been closed, and the Baton Rouge, LA,
facility is closed to offsite waste generators, as it will be used to dispose of incinerator waste
generated onsite. An Illinois facility, located in Calumet City, has been recently approved to
receive hazardous waste for disposal cell burial, with shipments starting in 1997; however, the
current operational status of this facility could not be fully confirmed with the operator or State
agency. Of the 20 RCRA-C disposal facilities listed in Table 3-2, only six are assumed to be
located in arid regions: Westmorland, CA; Grand View, ID; Beatty, NV; Clive and Knolls, UT;
and Deer Trail, CO.
Table 3-3 presents the quantity of RCRA-C hazardous waste managed and buried and the number
of TSD facilities located in 16 States. In total, these States managed about 7.2 million tons of
waste, while disposal facilities received about 1.9 million tons and disposed of nearly 812
thousand tons. The number of facilities involved in disposal cell burial is about 2.3% of the total
number of TSD facilities located in these 16 States.
Six States provide services or offer capabilities in most of the reported waste management
methods. In decreasing order, these States are Texas, Ohio, California, Michigan, Illinois, and
New York. The management methods used in the 16 States that have commercial facilities for
land disposal of hazardous wastes parallel those reported at the national level. If the focus were
on land disposal, the States that capture most (>10%) of the RCRA waste volume are, in
decreasing order, Michigan, Oregon, Indiana, Ohio, Louisiana, and South Carolina. The
information presented here is supplemented with a breakdown of management methods used in
each State (see Attachment B).
3-14
-------
Table 3-2. RCRA-C Hazardous Waste Disposal Facilities and 1995 Waste Receipts(a)
State
Alabama
California
Colorado
Idaho
Illinois
Indiana
Louisiana
Michigan
Nevada
New York
Ohio
Oklahoma
Oregon
South Carolina
Texas
Utah
Facility Operator'1"
Chemical Waste Management
Chemical Waste Management
Laidlaw Environmental Services
Laidlaw Environmental Services
Laidlaw Environmental Services
Envirosafe Services of Idaho
Peoria Disposal Company (PDC) Landfill
CID Recycling Disposal Facility
Chemical Waste Management^'
Heritage Environmental Services
Laidlaw Environmental Services'0
Chemical Waste Management
Wayne Disposal Site #2 Landfill
U.S. Ecology
Chemical Waste Management
Envirosafe Services of Ohio
Laidlaw Environmental Services
Chemical Waste Management
Laidlaw Environmental Services
Texas Ecologists, Inc.
Waste Control Specialist
Laidlaw Environmental Services
Envirocare of Utah, Inc.
City
Emmelle
Kettleman City
Westmorland
Button willow
Deer Trail
Grand View
Peoria
Calumet City
Fort Wayne
Roachdale
Baton Rouge
Sulphur
Belleville
Beatty
Model City
Oregon
Waynoka
Arlington
Pinewood
Robstown
Andrews
Knolls
Clive
Amounts
Received at
Facility'0
(tons)
82,008
21,717
13,891
4,979
42,137
33,261
66,737
no data(d)
116,985
68,214
32,171
106,021
126,995
602,017
112,108
119,479
111,319
130,676
77,127
22,371
(g)
34,531
8,995
(a) Source: The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail
Analysis (EPA 1997c).
(b) Status and name of facility operator updated by contacting State agencies.
(c) Quantity of waste received in 1995.
(d) New facility operation since 1997, taken over from CID Recycling & Disposal.
(e) Facility was closed in 1998.
(0 Facility closed to commercial services. Formerly Rollins Environmental Services.
(g) Newly operational facility, not captured in 1995 EPA Biennial report.
3-15
-------
Table 3-3. Quantity of RCRA-C Hazardous Waste Managed and Disposed of and
Number of TSD Facilities - Ranked by Decreasing Amounts of Buried Waste00
State
Michigan
Oregon
Indiana
Ohio
Louisiana
South Carolina
Oklahoma
Utah
New York
Illinois
Alabama
Texas
Idaho
California
Colorado
Nevada
Total
Total Quantity
Managed""
(tons)
1,218,812
131,843
691,119
509,850
519,765
180,290
131,435
95,258
322,312
340,869
307,433
1,728,086
539,567
288,028
102,522
95,662
7,202,851
No. of TSD
Facilities*0
112
11
76
74
49
26
31
21
70
107
42
192
10
136
36
15
1,008
No. of
Land
Disposal
Facilities (d>
2
1
3
2
2
1
1
2
1
1
1
1
1
2
1
1
23
Amounts
Received by
Facilities'"
(tons)
126,995
130,676
185,199
119,479
138,192
77,127
111,319
43,526(8'
112,108
66,737
82,008
22,371
33,261
18,870
42,137
602,017
1,912,022
Amounts
Buried"*
(tons)
134,198
130,520
106,477
106,461
102,320
77,106
34,920
26,526
23,306
21,157
15,764
11,295
10,742
6,361
4,472
158
811,783
(a) Source: The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail
Analysis (EPA 1997c).
(b) Waste reported as "non-wastewater."
(c) Total number of TSD facilities, all wastes and treatment methods.
(d) Limited to waste received from offsite.
(e) Amount of waste reported to have been received by the number of listed disposal facilities
(0 Amount of waste reported to be buried in disposal cells.
(g) Of this total, 8,995 tons were attributed to Envirocare of Utah, Inc.
3-16
-------
In comparing the amounts of waste reported here with those given in the EPA Biennial Survey,
the EPA notes that in some instances the amounts and totals do not always balance. Reasons for
the variances include data characterizing off-year generation (waste generated at the end of a
reporting period but shipped during another reporting year) and waste received for management
from generators not captured by the survey report. In addition, the data compiled in the Biennial
Report do not always provide the means of identifying waste generators and/or TSD facilities that
used disposal facilities, other than those known to receive waste on a commercial basis.
3.5 Summary of Assumed Facility Features and Model Parameters
The selection of any disposal concept must address two kinds of failures: (1) those caused by
long-term processes, such as weathering, and (2) those caused by discrete processes, such as
human intrusion, biological activity, water infiltration, failure of engineered barriers, or sudden
subsidence of the capping system. Factors influencing the choice and design features of waste
disposal concepts include:
• Waste physical and chemical forms
• Waste volumes
• Radionuclide distributions and concentrations
• Total radioactive material inventory
• Radioactive material half-lives
Site-specific factors, such as meteorology, geology, hydrology, topography, and
geochemistry
Factors important in ensuring long-term protection include design features against intrusion, water
infiltration, and waste and cap subsidence. These features must reflect site characteristics. For
instance, below-grade disposal could be considered only if hydrogeological conditions were
appropriate, i.e., sufficient depth to the water table. For some types of wastes, the selection of
disposal technologies depends also on the anticipated amounts of waste requiring disposal. For
example, the disposal of large amounts of contaminated soils or demolition debris using
containers or small disposal cells might be inefficient since this approach does not provide the
expected economy of scale, as compared to bulk disposal.
Ground water is one of the more significant exposure pathways associated with the release of
radioactivity from a disposal site. The radioactivity can be released by leaching, breaching of the
disposal site, slow degradation of the disposal facility, flooding of the disposal unit, or by waste
spillage during disposal. Another exposure pathway is the consumption of contaminated food
3-17
-------
grown on contaminated lands. This may occur through the use of contaminated irrigation water
on crops or through airborne deposition of contaminants on crops. In addition, livestock grazing
on contaminated pastures, given contaminated feed, or watered with contaminated well or surface
water may present another route of exposure. The resulting exposures are dependent on the
consumption rates of contaminated vegetables and crops and animal byproducts. In most
communities, only a fraction of the food consumed by the population is grown locally. The
fraction is higher for rural communities than for urban areas. Accordingly, a number of
hydrogeologic and climatic conditions are considered in evaluating the impact of various
exposure scenarios. Occupational health and safety is not covered here, as other Federal and State
agencies are responsible for those requirements.
The design of waste disposal technologies must also consider processes and methods used to treat
and package waste. In some cases, transportation regulations also prescribe minimum packaging
and waste form or stability requirements. Thus, waste treatment, packaging, transportation, and
disposal methods collectively define a disposal practice. Variations in any of these components
might alter waste forms, contaminant concentrations, and disposal costs and are a decisive factor
in the selection of the most cost-effective management option (EPA 1997a).
The EPA has selected one type of disposal method for inclusion in its radiological risk assessment
since this regulatory action addresses land disposal of waste characterized by the presence of
hazardous materials containing low levels of radioactivity. The analysis addresses disposal only
in commercially-operated RCRA-C facilities. The major features of such facilities are shown in
Tables 3-4 and 3-5. Table 3-5 presents the assumed features and major model parameters used for
the risk assessment analysis. The model parameters were selected to assess the impacts for
RCRA-C facilities assumed to be located in arid, temperate, and humid regions of the United
States. Chapters 4 and 6 of the Background Information Document for 40 CFR 193 (BID) fully
describe the methodology used in calculating doses and results.
Table 3-4 also presents some details about conventional and restricted low-level waste disposal
facilities for comparison. Within the commercial sector, conventional shallow-land-disposal
technology is currently in use at two operating facilities, Barnwell, South Carolina, and Richland,
Washington. These facilities meet most current waste disposal criteria and are being operated in
compliance with NRC (10 CFR Part 61) and equivalent State regulations.
3-18
-------
Table 3-4. Summary Features of Alternate Waste Disposal Methods and Base Case(a)
Disposal Method
I Mnemonic |
Description
I General Acceptance Criteria
Regulated Hazardous Waste
Facility - Compliant with all
RCRA Subtitle C criteria.
RCRA-C
Facility
Disposal in shallow cells with an engineered liner,
capping, and leachate collection system Monitored Tor at
least 30 years Waste disposed of in discrete locations in
containers and in bulk forms within dedicated cells
Elaborate gas collection and venting system may be
required as other waste may contain biodegradable
materials The EPA Administrator may extend the
duration of the monitoring period beyond 30 years
Waste pre-treated, as needed, to
meet RCRA-C waste acceptance
criteria. Waste forms vary, but
primarily include stabilized
waste, ash, soils, debris, and
rubble LAMW must meet
maximum radionuclide
concentration limits, based on
MCLs for members of the public
and facility workers
Conventional Shallow-Land
Disposal - Compliant with all
NRC 10 CFR Part 61 criteria or
equivalent State regulations
CSLD
LLRW classification system for Class A, B, and C wastes
Higher activity waste (e g., Class B and C) disposed of in
deepest section of trench Other wastes with lower
specific activity are placed on top of higher activity waste,
serving as shielding and intruder barrier. Full capping
system. Monitored for 100 years Waste disposed of at
discrete locations, as packages and containers Licensing
procedure requires a long-term performance (1,000 years)
analysis to assess impact on the environment and public
health
LLRW pre-treated, as needed, to
meet waste acceptance criteria
for stability and characteristics
Waste forms vary but primarily
include trash, glass, paper, cloth,
equipment, tools, soils, debris,
and rubble. Waste must meet
radionuclide concentration limits,
depending on waste class
Restricted Shallow-Land Disposal
- Compliant with site-specific
requirements analogous to those
of 10 CFR Part 61, with
restrictions on radionuchdes and
allowable concentrations, and
waste forms
RSLD
Disposal in shallow lifts or discrete cells with an
engineered liner, capping, and leachate collection system
Monitored for at least 100 years Waste disposed of in
containers within dedicated cells and in bulk forms as
compacted lifts covered over with native clays/soil layers
The need for an elaborate gas collection and venting
system not contemplated as wastes containing
biodegradable materials are excluded As part of the
licensing process, a long-term performance analysis is
required to assess impacts on the environment and public
health
Waste pre-treated, as needed, to
meet site-specific waste
acceptance criteria Waste forms
vary but primarily include
stabilized waste, ash. soils,
debris, and rubble Mixed wastes
are typically of low-specific
activity, meeting limits for
radionuclide concentrations,
hazardous materials, and LDRs
(a) See Chapters 4, 5, and 6 of the Background Information Document for 40 CFR Part 193 (BID) for more details
3-19
-------
Table 3-5. Assumed RCRA-C Facility Features and Major Model Parameters*1
la)
Common Features
Assumed Waste Volume (m3)
Cap System
Cap Thickness (m)
Type of Site/Climate
Waste depth (m)
Bottom liner
Unsaturated zone thickness(c-d) (m)
Depth of saturated zone(c) (m)
Distance to well (m)
Distance to surface water (m)
Scenario events
- Cap/Liner degradation (yr)
- Degree of cap degradation (%)
- Degree of liner degradation (%)
- End of events (yr)
Parameters
3,500
Soil with clay
2.0
Arid
10
(b)
62
74.3
50
50
30/30
10
100
31/300
Temperate
10
(b)
1.3
13.6
50
50
30/30
10
100
31/300
Humid
10
(b)
2.4
14.7
50
50
30/30
10
100
31/300
(a) See text and Table 3-4 for definitions and details.
(b) Liners assumed to fail after the specified time period for RIA analysis.
(c) Values reflect the range of data evaluated using site-specific parameters.
(d) Measured from the bottom of the disposal unit to the depth of the unsaturated zone.
Table 3-5 presents the major model assumptions and parameters used for the risk assessment
analysis, in addition to the information presented in Chapters 4, 5 and 6 of the BID. The results of
the risk assessment analysis are presented in Chapter 7 of the BID, while Chapter 8 presents the
results of sensitivity and uncertainty analyses.
The waste volume is based on a default assumption that about 10% of the total waste volume
present in the RCRA-C facility consists of LAM W. The depth of the waste layer is assumed to be
3-20
-------
about 10 meters. The capping system is assumed to be typical of current RCRA-C disposal
technology. The thicknesses of the unsaturated and saturated zones were varied to differentiate
conditions between arid sites and humid and temperate sites. The thicknesses of the unsaturated
and saturated zones are the greatest in arid sites. The distances to the nearest ground water well
and surface stream were assumed to be 50 m for all three sites, assumed to be located in arid,
temperate, and humid regions of the United States.
The scenarios evaluated include specific assumptions regarding the degradation of the cap and
liner systems and combination of waste matrices. The level of degradation is also different
between the cap and liner. The liner is not characterized, since it is assumed to fail at a specific
time, 100% failure after 100 years. In addition, the analysis evaluated the impacts associated with
different types of liner failures, abrupt and gradual, occurring over 300 years. The cap is assumed
to be made of soil and clay. The cap is assumed to be subjected to partial failures, 1%, 10%, and
100%, assumed to occur within the first 30 years. Also, appropriate properties were applied in
modeling water infiltration rates.
Since the model assumes that wastes are contained in packages, it is also assumed that containers
and stabilized waste matrices offer some delay in releasing the radioactivity into leachates and the
environment beyond the disposal cell. The analysis considers the inherent structural stability of
solidified waste (mixed with concrete), waste present in a soil-like form, radioactivity movement
out of the waste under different conditions (via diffusion and hydrodynamic leaching), and the use
of this information in assigning coefficients of distribution (KJ and deriving retardation factors.
In addition, the analysis evaluated whether the results were sensitive to waste placement,
including random placement versus segregation by disposal cells.
3-21
-------
Chapter 4
Commercially-Generated Mixed Waste
4.0 Introduction
In addition to low-level radioactive waste (LLRW), commercial facilities generate low-activity
mixed waste (LAMW), as a subcategory of mixed waste (MW). LAMW is characterized by the
presence of both hazardous chemicals and radioactive materials. Typically, LAMW contains
radioactive materials that are similar to those found in Class A LLRW, regulated under 10 CFR
Part 61 (Licensing Requirements for Land Disposal of Radioactive Waste), but at lower
concentrations. LAMW does not include high-level waste, transuranic waste, spent nuclear fuel
or byproduct material specified as uranium or thorium tailings. Because it contains hazardous
materials, commercially-generated LAMW is analogous to other types of waste classified as
RCRA hazardous waste.
The types of LAMW and the amounts generated vary significantly among industrial facilities and
practices. Activities that generate LAMW include research and development (R&D), laboratory
analyses, facility or plant outages, maintenance, and decontamination activities. Such activities
do not create new hazardous substances; rather LAMW is generated when chemicals are used as
cleaning agents or solvents and become commingled with radioactive materials. Accordingly,
commercial LAMW is often well suited to treatment methods, such as incineration, stabilization,
chemical treatment and recycling, that are currently used in the management of similar types of
RCRA hazardous wastes.
Chapter 1 of the RIA presents more details on the regulatory definition of hazardous waste, and
Chapter 3 presents information about hazardous waste generation rates and the status of
commercial RCRA-C disposal facilities. The LAMW characterization that follows is based on a
more detailed evaluation presented in Chapter 2 of the Background Information Document for 40
CFR Part 193 (BID).
4.1 Commercial Mixed Waste Generation
In 1992, the NRC published a national profile of MW volumes and characteristics (NRC 1992b).
The profile was developed by conducting a survey of 1,323 facilities out of 2,936, with a
4-1
-------
response rate of 76.8%. The profile divides MW properties and generation rates into five
categories, including:
• Utilities - nuclear power plants
• Medical - hospitals, clinics, research facilities and private medical offices
• Academic - university hospitals and medical/nonmedical research facilities
• Government - State and non-DOE Federal agencies
• Industrial - private R&D companies, nondestructive testing, mining, fuel
fabrication, and radiopharmaceutical manufacturing facilities
For each category, MW streams were categorized into ten groups (Table 4-1). The table also
lists some of the most often reported radionuclides. At this time, the EPA is not considering the
amounts of MW generated during the decontamination and decommissioning (D&D) of nuclear
power plants and in support of license renewal activities for plant life extension. The NRC has
acknowledged that there is much uncertainty in predicting these mixed waste volumes. The
amounts of waste are expected to vary extremely among power plants, depending on plant
features and past operating and maintenance practices (NRC 1991,1993b; Numarc 1990; OTA
1989).
Tables 4-2 summarizes the results of the 1990 National Profile for all five categories of LAM W
generators. The summary presents generation rates and volumes held in storage and treated. The
NRC has estimated that a small fraction of the mixed waste volume, ranging from 140 to
524 cubic meters, was untreatable because of the lack of acceptable treatment or disposal
capacity (NRC 1992b). The untreatable wastes reported most often are those containing
chlorinated fluorocarbons (CFC).
The most frequently used treatment methods are summarized in Table 4-3. Most of the liquid
wastes, including oils and organics, are incinerated; metals and other types of solid wastes are
treated via stabilization, distillation, and oxidation. These methods account for about 90% of the
treated waste volume.
Currently, four commercial facilities treat and process MW. They are Perma-Fix, Gainesville,
FL; Diversified Scientific Services, Inc., Kingston, TN; NSSI/Sources & Services, Inc., Houston,
TX; and GTS-Duratek, Bear Creek, TN. These facilities are estimated to have an annual
incineration capacity for liquid scintillation wastes of over 30,000 cubic meters (EPA 1996b).
4-2
-------
Another facility, Allied Technology Group, located in Richland, WA, is anticipated to start
processing MW in the near future. Finally, the Envirocare facility, located in Clive, UT, is
allowed to treat and dispose of specific types of bulk solid materials (UDEQ 1998; NRC 1993a,
1994b). Waste Control Specialists, Inc., located in Andrews County, TX, has applied for a
license to receive and treat mixed wastes; however, the license will require that the treated wastes
be returned to the generator.
Table 4-1. Categorization of Commercial Mixed Wastes(a)
Waste Category
Liquid
Scintillation
Waste Oils
Halogenated
Organics
Lead Wastes
Mercury Wastes
Chromate Wastes
Cadmium Wastes
Aqueous
Corrosive Wastes
Miscellaneous
Organics
Other Hazardous
Materials
Hazardous Component
toluene, xylene
oils
freon, chloroform,
trichloroethane, chlorinated
solvents and organics
lead-bearing ash, oils,
batteries, penetration sealants
mercury-bearing equipment
and debris
chromium-bearing solutions
cadmium
organic/inorganic acids and
bases
solvents, reagents, organics,
organic sludge, trash, ash,
alloys, biological wastes, etc.
Radionuclide Component
H-3,C-14,P-32,S-35,
Ca-45,Ni-63,I-125
H-3, Mn-54, Zn-65, Co-60,
Cs-134,Cs-137
H-3.C-14, P-32, S-35,
Mn-54, Co-58, Co-60, 1-125,
U
P-32,Sr-90, 1-1 25, Co-60, Cs-
137, Ra-226, Th-232, U
H-3, C-14, Mn-54, Co-60, I-
125,Cs-137
Cr-51, Co-60
Co-60, Cs-1 34, Cs- 137
H-3, C-14, P-32, S-35, Cr-51,
Mn-54, Co-60, Ni-63, 1- 125,
Cs-134,U
H-3, C-14, P-32, S-35, Ca-45,
I-125.U
H-3, C-14, P-32, S-35, Cr-51,
Mn-54, Co-60, Ni-63, 1-125,
Cs-134,U
Origin
laboratory
measurements
equipment operation and
maintenance
dry cleaning,
refrigeration, degreasing
and decontamination
research and industrial
activities and clean up
laboratory activities and
clean up
research, maintenance
and waste treatment
decontamination of
reactor internals
decontamination
activities
manufacturing,
laboratory operations
and cleaning
industrial, research and
medical activities
(a) Based on BID, Chapter 2.
4-3
-------
Table 4-2. Mixed Waste Generation Profile by Types of Generator
Facility
Academic
Government
Industrial
Medical
Nuclear Power Plants
Total
1990 Waste Volu me (mj)(1)
Generated
820.7
750.4
1428.0
563.6
385.8
3948.5
Stored
154.2
789
1197.3
63.1
622.5
2116.0
Treated'"'
1581 9
612.5
1115 1
466.3
216.9
3992.6
(a) Taken from NUREG/CR-593 8 (NRC 1992b).
(b) This waste volume is not necessarily additive to that held in storage since waste volumes reported
in any category may have been generated prior to 1990.
Table 4-3. Most Often Used Waste Treatment Methods
Treatment Method
Incineration
Stabilization (cement/ vitrification)
Distillation/oxidation (organics)
Precipitation/neutralization
Decon/encapsulation
Chemical reduction
Thermal recovery
Percent
63.7
19.0
7.8
62
1.8
1.3
0.2
Source: Table 5.3, NRC 1992b.
The results of surveys, conducted periodically by States and Low-Level Radioactive Waste
Compacts, indicate that MW generation rates are decreasing. The decrease is driven by the lack
of storage space, regulatory burden, availability of treatment and disposal options, and costs
(CHWMS 1997, Gingerich 1998). Most of the waste volumes seem to have peaked in 1994 and
then decreased sharply in 1995 and 1996. Reported waste volumes vary, depending on waste
4-4
-------
streams, ranging from a fraction of a cubic meter to several hundred cubic meters for solids,
soils, and spent filters and from a few milliliters to several thousand liters for liquids and sludge.
These changes are believed to reflect more rigorous characterizations to reduce the "apparent"
volume of MW, use of substitute materials to avoid the mixed waste designation, consolidation
of waste containers containing "potential" MW, and rectification of waste within the RCRA-
C classification system. For example, the survey conducted by the LLW Forum revealed that
"there still is orphan mixed waste, but that the amount is very small and appears to be decreasing
as new commercial treatment capacity comes on-line" (CHWMS 1997).
The survey results indicate that most of the wastes are identified as RCRA D001, D002, D006,
D007, D008, D009, D022, F001, F002, F003, and F005 codes, with a small fraction classified as
U codes (see Chapter 2 of the BID for code definitions). The wastes include ignitable and
corrosive materials, cadmium, chromium, lead, mercury, chloroform, and various types of spent
halogenated and non-halogenated solvents. The surveys also indicate that the availability of
waste treatment facilities and knowledge about access to these facilities are rapidly changing. In
one instance, a generator reported having found access to a treatment facility for six types of
wastes, which had been listed six months earlier as orphan waste streams.
The overall range of radionuclide concentrations varies from 10"4 to 10*" pCi/g, assuming unit
bulk density, with a cluster falling within a narrower range of 10+2 to 10+s pCi/g. The data imply
that some MW has activity levels on the order of several hundreds mCi per mL, mainly due to
H-3, C-14, and S-35. The radionuclides cited most often are H-3, C-14, P-32, S-35, Mn-54,
Co-60,1-125, Cs-134, and Cs-137. Radionuclides cited less often include Ca-45, Fe-55, Co-57,
Ni-63, Ga-67, Sr-85, Sr-90, Tc-99, Cd-109,1-123,1-129, Tl-201, Tl-202, Hg-203, Nat-U, U-232,
U-235, U-234, U-238, Nat-Th, Th-228, Th-229, Th-230, Th-232, Ra-226, Ra-228, Pu-238, Pu-
239, Pu-241, Pu-242, and Am-241.
These radionuclides can be grouped by half-lives (Table 4-4). Several radionuclides are short-
lived, with half-lives of less than 120 days. The waste containing these radionuclides can be
managed by a relatively simple process involving segregation and decay-in-storage. The balance
of the radionuclides that are not amenable to storage and decay fall into six groups, with half-
lives ranging from about a year to well over 1,000 years. In the context of this rule,
radionuclides with half-lives of less than five years are of little or no consequence in the risk
assessment analysis.
4-5
-------
Table 4-4. Mixed Waste Radionuclide and Half-Lives
<120 days
P-32, S-35,
Cr-51,
Co-58,
Ga-67,
Sr-85,
Rb-86,
Sr-89, Sr-92,
Zr-95, Zr-97
In-Ill,
Sn-113,
Cd-115,
Cd-117,
1-123,1-125,
Xe-133,
Tl-201,
TI-202,
Hg-203
<1 year
Ca-45,
Mn-54,
Co-57,
Zn-65
<10 years
Na-22,
Fe-55,
Co-60,
Kr-85,
Cd-109,
Sb-125,
Cs-134,
Pm-147,
Th-228,
Ra-228
<30 years
H-3, Sr-90,
Cs-137,
Pu-241
< 100 years
Ni-63,
U-232,
Pu-238
<500 years
Am-241
> 1,000 years
C-14, K-40,
Tc-99, 1-129,
Ra-226,
Th-229,
Th-230,
Th-232,
Pu-239,
Pu-242,
U-234,
U-235,
U-238
The results of the surveys should be interpreted with caution, because the data incorporate some
uncertainties, which include:
• MW constituents and radioactivity levels or concentrations are mostly based on
process knowledge rather than on specific analyses of the presence of hazardous
substances or radionuclides. None of the questionnaires provide a means to check
the validity of the data provided by survey respondents.
• The amounts of MW are based on approximate volumes that may not necessarily
reflect actual amounts present in containers. In most instances, respondents gave
container volumes as opposed to actual waste volumes.
• In some instances, respondents repeatedly reported identical waste radioactivity
levels for two or more different types of MW and volumes.
• MW radioactivity levels may not have been decay-corrected and, in some
instances, may be based on "catalog" values reported by suppliers, as opposed to
calibrated activity levels based on material specification data sheets that
accompany such materials.
Accordingly, MW radionuclide concentrations cited here should not be interpreted in absolute
terms, but rather should be viewed as bounding estimates and indicators of the variability across
4-6
-------
waste generators and streams. Similar inconsistencies in characterizing radioactive wastes have
been addressed elsewhere (NRC 1990a, 1992b, 1994a; DOE 1993).
4.2 Distribution of Low-Level Radioactive Waste and Mixed Waste Generators
Commercial LAMW is generated by facilities authorized to possess and use radioactive materials
under licenses issued by the Nuclear Regulatory Commission (NRC) or counterpart agencies in
Agreement States (collectively referred as "NRC/AS"). Nearly 21,000 facilities are licensed to
possess and use radioactive materials nationwide (NRC 1998a). Of these, the NRC licenses
5,863, while the Agreement States license the balance (14,947).
For this RIA, the generation of LLRW was used to estimate the generation of mixed waste on a
State-by-State basis, assuming that the generation of MW parallels that of LLRW. Since 1990,
LLRW generation rates have decreased significantly, from 32,358 to 9,037 cubic meters in 1997
(DOE 1998). Although one might deduce that mixed waste generation rates have followed a
similar trend, the data do not clearly show such a trend.
The locations of commercial RCRA-C facilities (Chapter 3, Table 3-2) and distribution of
NRC/AS licensees indicates that MW generators are located near RCRA-C facilities, either
within their own State or region. The Western United States (west of the continental divide) is
serviced by seven RCRA-C facilities, excluding Envirocare. In the Central United States, six
RCRA-C facilities are available, covering an area bordered by Illinois, Colorado, Texas, and
Louisiana. On the Eastern seaboard, six RCRA-C facilities are located within an area bounded
by Michigan, Alabama, New York, and South Carolina.
4.3 Overview of Mixed Waste Management Practices
Prior survey results and studies of MW generation practices indicate that some facilities routinely
generate a wide variety of LAMW but in significantly smaller amounts than the LLRW they
generate. Some LAMW streams are being managed using existing regulatory provisions (e.g.,
10 CFR Part 20.2005) and commercial treatment services. These provisions do not relieve
facility operators from complying with any other Federal, State, and local requirements
governing the presence of other types of hazardous materials.
4-7
-------
For radioactive materials that are short-lived (with half-lives of less than 65 days), NRC
Information Notice No. 90-09 (or its equivalent Agreement State counterparts) identifies the
requirements for establishing a decay-in-storage program (NRC 1990b). These provisions
provide the means to "remove" the radiological component from mixed waste, with the
remaining material being managed as a hazardous waste.
For wastes that do not qualify under these provisions, the only recourse includes the use of
specific treatment methods. For example, spent liquid scintillation fluids may be treated by
incineration and used as fuel in kilns or power generation. As revealed by the 1990 National
Profile, scintillation fluids account for about 72% of the waste that is generated and 84% of the
waste that is treated.
Other wastes, such as those containing substances like lead (as bricks or sheets), mercury, and
freon could be recycled because these substances have some economic value. MW containing
flammable solvents is more likely to be incinerated or used as fuels than processed for land
burial. These and other treatment options have been chosen for treating a significant portion
(over 80%) of the commercial MW volume. However, a small amount of untreatable MW still
may not be acceptable for disposal in the context of this rule due to the lack of acceptable
treatment or disposal capacity, elevated radioactivity levels, and the presence of some chemicals.
In practice, MW is stored until a cost-effective treatment method is identified. For example, a
generator may store MW until the volume is large enough to benefit from economy of scale
(Weaner 1998b). In other instances, MW is treated because the presence of unstable or reactive
hazardous constituents requires treatment for safe long-term storage. Accordingly, the process
involves placing most, or at least a significant portion, of the MW volume into semi-perpetual
storage and removing small amounts from storage when cost-effective treatment methods
become available. This scenario assumes that generators have already implemented waste
minimization methods to significantly reduce MW volumes.
In general, treatment costs and availability of treatment methods for specific MW streams have
been forcing generators to apply stricter waste management techniques to reduce inventories and
minimize the need for storage space and reduce the associated operating costs. However, some
generators are not treating or disposing of MW because of associated costs, as opposed to the
lack of available treatment and disposal services. This inaction reflects the generators' need to
4-8
-------
reduce operating costs because of business or budgetary constraints and their expectation that
waste treatment and disposal costs will be lower in the future.
Most facilities generate only small amounts of MW, so the use of commercial treatment services
may not be suitable for processing low volumes of organic liquids containing large amounts of
radioactivity. The use of small bench top processing systems at the point of generation has been
evaluated (Hoerr 1997, Weaner 1997). Bench top treatment systems rely on high-temperature
catalytic oxidation processes to destroy organic and aqueous waste mixtures and collect
radioactivity. Tests conducted with various types of compounds have indicated high destruction
and removal efficiencies, including the efficient removal of radioactivity.
Some MW generators have noted that the dual regulatory program under RCRA and AEA
imposes severe penalties. A widely expressed opinion is that the current regulatory system
results in needless expenditures, without any corresponding increase in the level of protection to
the public and environment (USWAG 1995). The dual regulatory system has created a disposal
crisis since facilities are required to have an NRC/AS license to manage MW, in addition to a
RCRA Part B permit. The associated administrative cost, legal ramifications, and delay in
obtaining such authorizations have caused potential operators of treatment and disposal facilities
to decide against offering this line of services. As a result, commercial M W generators have
been forced to store waste for extended time periods until qualified RCRA and NRC treatment
and disposal facilities become available. The protracted storage of MW is also contrary to the
land disposal restrictions (LDRs), which allow generators to store waste for up to one year if
such storage is necessary to facilitate treatment or disposal of the waste. However, the EPA has
determined that the lack of adequate treatment or disposal capacity is not reason enough to allow
exceptions to the LDR storage provisions. The other major concern is that the possession of very
small amounts of mixed waste could trip a facility into the RCRA corrective action process.
Consequently, generators may be in violation of LDR storage prohibition requirements.
Although the EPA has issued an enforcement discretion policy for such violations, generators are
nevertheless still subject to potential civil actions.
4-9
-------
Chapter 5
Waste Disposal Costs
5.0 Introduction
For comparative purposes, waste management costs were obtained for treatment, disposal, and
storage. The costs are based on commercial rates obtained through informal telephone surveys.
It was not possible to obtain actual disposal costs or rates, as all contacted service providers and
disposal facility operators requested specific information on waste properties, including
radionuclide distribution and concentrations, hazardous substance concentrations, EPA waste
codes, name of generator, disposal site, waste volumes and packaging methods, and EPA or State
waste generator identification number. In other instances, service providers would not release
any information, once they recognized that the caller was not a waste generator and that the
information would be used in a study. As a result, the data presented here may not be
comprehensive but are assumed to be illustrative of the range of costs and expenses that
commercial waste generators incur. Also, in the context of this RJA, the cost difference between
two waste disposal options is more important than their absolute values.
5.1 Commercial Waste Disposal Rates for RCRA Subtitle C Facilities
Without the benefit of specific details about waste streams, disposal costs for hazardous wastes
typically range from $40 to $200 per ton or $44 to $220 per cubic meter, assuming unit bulk
density and excluding local taxes and minimum charges (Table 5-1). The rates were obtained by
calling six commercial RCRA-C disposal facilities, assuming contaminated soils listed as RCRA
D, F, and K wastes (see BID Chapter 2 for EPA waste form and code definitions). Although not
explicitly stated by RCRA-C facility operators, the costs are assumed to reflect full life-cycle
cost components, summed over the pre-operational, operational, and closure and post-closure
periods of the site.
For the purpose of planning environmental remediation projects, the R.S. Means Company has
compiled hazardous waste disposal costs in its ECHOS data base, based on 20 RCRA-C disposal
facilities (Means 1997). The ECHOS data base is commonly used for costing-out environmental
remediation projects. Table 5-2 presents unit disposal costs for treated and untreated hazardous
wastes, based on the ECHOS data base.
5-1
-------
Table 5-1. RCRA Hazardous Waste Disposal Rates for RCRA D, F, K Wastes(a)
Location
Emelle, AL 35459
Keltleman, CA 93239
Westmorland, C A 92281
Buttonwillow, CA 93206
Deer Trail, CO 80 105
Grand View, ID 83624
Peona, IL
Calumet City, IL
Roachdale, IN 46 172
Sulphur, LA
Belleville, Ml 481 II
Beatty, NV 89003
Model City, NY 14107
Oregon, OH 4360S
Waynoka, OK 73860
Arlington, OR 978 12
Pmewood,SC29l25
Robstown, TX 78380
West Valley City, UT 84 119
Facility Operator
Chemical Waste Management
Chemical Waste Management
Laidlaw Environmental Services
Laidlaw Environmental Services
Laidlaw Environmental Services
Envirosafe Services of ID
Peoria Disposal Co. Landfill
CID Recycling Disposal Facility
Heritage Environmental Services
Chemical Waste Management
Wayne Disposal Site #2 Landfill
US Ecology
Chemical Waste Management
Envirosafe Services of Ohio
Laidlaw Environmental Services
Chemical Waste Management
Laidlaw Environmental Services
Texas Ecologists, Inc
Laidlaw Environmental Services
Treated Cost
$95/ton
$200/ton, stabilization
$80/ton direct burial
Won't quote without waste codes
$40/ton ($500 minimum)
$!20/yd'
SSO/drum (if direct burial)
$200/ton
(b)
Won't quote without waste codes.
(c)
$96/ton
$H5/ton
$IOO/ton direct burial, F039
$120/ton
$75
$100/ton
$II5/ton
Won't quote without waste codes
$80/ton
Surcharges
$150 permitting fee, 10 ton min
10% tax + $32/ton (non-cleanup), or $22/ton (cleanup)
10% tax + $10 50/ton (non-cleanup) or $ I/ton (cleanup)
n/a
10%ofcost + $32/ton
includes tax
includes tax
includes tax ($500 permitting fee)
n/a
n/a
includes tax
includes tax
+6% local tax
$11 25/ton
$9/ton
$20/ton
$39
$14/tontax
(a) Obtained by telephone quotes, assuming D, F, K waste codes.
(b) This facility could not be reached; efforts included internet searches, yellow pages, directory assistance, and State contacts.
(c) This facility would not return phone calls.
5-2
-------
Table 5-2. Summary of Commercial Hazardous Waste Disposal Costs00
Facility/State
Kettleman, CA
Arlington, OR
Emelle, AL
Fort Wayne, IN
Model City, NY
Detroit, MI
Averages:
R.S. Means Cost
Book(c)
Treated
Waste
($/m>)
220
259
335
265
265
212
259
304
Untreated
Waste
($/m>)
776
432
503
353
353
459
479
442
State
Taxes
($/m3)
32-76
13-26
81
34
48
18
-
-
County
Taxes
($/m3)
-
-
9
-
-
-
-
Other
Fees
10%
3.6%
-
-
-
-
-
(a)
(b)
(c)
1997 rates obtained by telephone inquiries, assuming contaminated soils classified as RCRA D/F/K wastes.
Rates assume a density of 1.6 g/cm3.
Based on ECHOS data for environmental restoration, Unit Cost Book, with a density of 2000 Ibs/yd3
(Means 1997).
The costs vary from $212 to $335 per cubic meter for treated waste and from $353 to $776 per
cubic meter for untreated waste. These rates exclude State and county taxes and surcharges,
which vary from $18 to $81 per cubic meter and from 3.6 to 10%. For the State of Nevada, the
land disposal tax rate was reported to be $27.07 per metric ton or $43.31 per cubic meter;
however, similar tax rates were not provided for other States (Means 1997).
The range of disposal costs for the same types of wastes may be explained by the current excess
in hazardous waste disposal capacity across the nation. Commercial disposal rates incorporate a
margin that is sufficiently large to provide deep discounts, when business is slow or when
shipments involve large amounts of waste. Using the quotes given in Table 5-1, the variability is
estimated to be about ±150%, excluding taxes and surcharges. Based on the six separate quotes
given in Table 5-2, disposal costs vary by about ±50% for treated waste and ±90% for untreated
waste. It is assumed that the engineering costs of such facilities are probably a small fraction of
the quoted disposal rates. The engineering cost, based on a recent EPA study, is estimated to be
$68 per metric ton or $108 per cubic meter (in 1997 dollars adjusted with a Producer Price Index
(PPI) factor of 1.08) for a generic RCRA-C facility with a capacity of 426,000 metric tons (EPA
1995).
5-3
-------
5.2 Commercial Low-Level Radioactive Waste Disposal Cost
For the three currently operating disposal facilities, low-level radioactive waste (LLRW) disposal
costs are based on information, catalogs, and data obtained during informal telephone inquiries
with facility representatives and service providers. As with RCRA-C facilities, it was not
possible to obtain specific cost data without giving the contacted service providers and disposal
site operators specific information on waste properties. The disposal costs were reported to range
from $5,360 to $12,600 per cubic meter, depending on whether the waste has been compacted
and on waste density, waste volumes, and radioactivity levels (Table 5-3). In some instances, the
costs are different because some costs are based on quotes from waste brokers, who impose
additional fees, such as handling and processing charges, local transportation expenses, and
profits and applicable State and local taxes. As a result, the data presented here illustrate the
range of costs currently incurred by LLRW generators. Another important feature of the current
rate structure is that it encourages the consolidation of waste shipments since it includes charges
imposed on the number of waste containers and shipment manifests in addition to all other costs.
This feature forces small-volume LLRW generators to use the services of brokers and processors
to consolidate small amounts of waste into large shipments.
5.2.1 Richland Waste Disposal Cost Structure
Operated by U.S. Ecology, the Richland LLRW disposal facility is located in Richland, WA.
The facility operator provided a cost schedule, dated May 1,1998 (USE 1998). The Richland
waste disposal schedule presents the following major cost components:
• Site availability charge, based on cumulative waste volume or radiation level,
varying from $95 to a maximum of $137,814
• Base volume disposal rate charge of $ 1,081 per cubic meter ($30.60 per cubic
foot), number of containers per shipment ($1,158 per container), number of
manifested shipments ($6,280 per manifest), and external radiation exposure rates
($133 per container when <200 mR/h to $950,000 per container when >100 R/h)
• Provisions for large volume discounts for D&D waste from nuclear power plants
(20%) and extraordinary waste volumes (48.5%)
5-4
-------
Table 5-3. Low-Level Radioactive Waste and Mixed Waste Treatment, Storage, and Disposal
Costs(a)
Waste
Dry solid
Dry solid
Dry solid
Aqueous liquids
Aqueous liquids
Vials liquid
scintillation fluids
Bulk liquid
scintillation fluids
Aqueous liquids
Dry solid
Mixed waste, as
aqueous liquids
Waste storage costs in
New York
Waste storage costs in
Michigan
Transportation costs
Process
Disposal at Bamwell
Supercompaction and
disposal at Bamwell
Incineration and
disposal at Bamwell
Incineration
Solidification and
disposal at Bamwell
Deregulated
Regulated
Mixed (for above)
Deregulated
Regulated
Mixed (for above)
Decay-in-storage
Decay-in-storage
Incineration
Low-level rad waste1
Hazardous & Mixed
waste
Onsite storage, ~1 10
m3, capacity, 280 m2
When not included in
disposal costs
Cost (S/unit)
$3,125per55-gallon
drum
$1,1 15 -$2,620
per 55-gallon drum
SI 20 per ft3 and
$9 per Ibs
$50 - $90 per gallon
$3, 125 per 55-gallon
drum
S37S/5S-gal drum
$450/55-gal drum
$400/55-gat. drum
$490/SS-gal drum
SS20/SS-gal drum
$500/55-gal drum
$45 per gallon
$55 - $72 per ft3
$30,000 per gallon
n/a
n/a
$500,000
Local: $50 - $400,
within 300 miles.
Beyond 300 miles
$2 00 per mile, plus
tolls and permit fees.
Equivalent Cost
(S/unit)
SI 5,000 perm3
$5,360 -SI 2,600 per
m3
$4,240 per m3
$20 per kg
$13 - $24 per L
$15,000 perm3
$1,800 perm3
$2, 160 perm3
$1,920 perm5
$2,350 per m3
$2,500 per m3
$2,400 per m3
$12 per L
$1,940- $2,540 per
m3
$7,930 per L
$300- $2,200 perm2
SI 3,000 perm2
$1,800 perm2
N/A
Remarks
with density >75
Ibs/ft3
Costs vary depending
on weight, between
<100and<300lbs
Boxes < 50 Ibs
Vary by volume, 1 0-
30 gallon and nuchde
concentrations"4
Based on a 15-gallon
container and half-
lives, <88 days
Based on volume and
half-lives. < 88 days
5 gallon with 0 82 Ci
ofH-3
1993 cost estimates
for NY State waste
generators
1995 cost estimate for
a Michigan university
Total costs beyond
300 miles are assessed
on a case- by-case
basis
(a) Cost rounded off, based on RSO, Inc., Laurel, MD, verbal quotes and 1997 price schedule, NYSERDA
1993, and MLLRWA 1993. Costs do not include expenses for pickup and delivery and supplies.
(b) Concentration limits applied by nuclide, e.g., H-3, <0.003 A*Ci/mL; C-14,<0.001
5-5
-------
• Surcharges for installing concrete barrier ($8,828 each) and heavy objects or
containers above 17,500 Ibs (actual labor and equipment costs, plus 25% margin)
Site surveillance and maintenance fee of 274 per cubic meter ($7.75 per cubic
foot)
State surcharge of $230 per cubic meter ($6.50 per cubic foot)
State business tax (3.3%) and regulatory fee (1 %)
A hypothetical case was constructed to illustrate the total disposal cost for a truckload of nearly
1,000 cubic feet of LLRW. The case assumes a shipment of nine B-25 boxes (90 cubic feet
each) of Class A waste with external exposures of <200 mR/h. The base volume cost is about
$27,000 and the container, shipment, and dose rate costs are about $10,000, $6,300, and $1,200,
respectively. The total cost for miscellaneous surcharges is $12,600, and the cost for the
business tax and regulatory fee is $2,500. The total cost is nearly $60,000, excluding the site
availability charge, which is about $138,000 for this example because the total waste volume is
above 5,000 cubic feet. The unit volume cost is estimated to $224 per cubic foot or nearly
$8,000 per cubic meter. If the shipment were to qualify under the provisions of the
"extraordinary" or "D&D" waste volume discount, the discount rates noted above would be
applied only to the disposal rate charge for the base volume.
5.2.2 Bamwell Waste Disposal Cost Structure
Located in Bamwell, SC, the Bamwell LLRW disposal facility is operated by Chem-Nuclear
Systems. The facility operator provided a cost schedule, dated July 1,1998 (CNSI1998). In
summary, the cost schedule contains the following major components:
Base volume disposal rate charge for standard waste of $9.70 to $15.40 per
kilogram ($4.40 to $7.00 per pound) for packaged waste densities ranging from
0.72 to 1.9 grams per cubic centimeter (45 to 120 pounds per cubic foot), with a
minimum charge of $1,000 per shipment.
Rates for waste with densities above 1.9 grams per cubic meter (120 pounds per
cubic foot) are given on request, depending on waste form and volume.
The base disposal rate includes charges for the extended care fund, South Carolina
waste disposal tax, site stabilization and closure fund, and technology charge for
Class A waste vaults.
5-6
-------
Waste activity charge, $0.30 per mCi, with a maximum charge of $ 120,000 per
shipment.
Container weight surcharge, based on the type of container and weight.
Dose rate surcharge, none for shipments under 200 mR/h. For shipments above
200 mR/h, the base rate multiplier varies from 1.08 to 1.48 for radiation levels
ranging from 0.2-1 R/h to 50 R/h and higher.
Barnwell site access fee, $500 for all shipments made during contracted period.
Class B and C waste surcharges, based on the type of container, waste volume,
and presence of chelating agents.
Irradiated hardware and cask handing fee, $30,000 minimum, based on the type of
container and waste volume.
Special nuclear material surcharge, based on the type of waste and waste volume.
Using the hypothetical case constructed earlier, the total disposal cost is estimated to be
$342,000 or $388 per cubic foot or $13,705 per cubic meter.
5.2.3 Envirocare Waste Disposal Cost Structure
The Envirocare LLRW disposal facility is operated by Envirocare of Utah, Inc. and located in
Clive, UT. The facility operator no longer provides a cost schedule and related information
(Rice 1998). The process requires that a waste profile form be completed and submitted for
waste shipments occurring during the current calendar year. Based on general information, the
following typifies Envirocare's waste disposal schedule:
• Base disposal rate charges vary from $ 1,413 to $2,119 per cubic meter ($40 to
$60 per cubic foot) for small amounts of waste, on the order of a few 1,000 cubic
feet (or about 30 cubic meters)
Waste disposal costs depend on how wastes are packaged and shipped to the site.
Wastes shipped via gondola cars offer the lowest disposal rate.
Surcharges are imposed on wastes that require special handling (e.g., 55-gallon
drums or B-25 boxes shipped by truck) or have unique physical characteristics,
e.g., low waste density and presence of debris
5-7
-------
For mixed wastes, the disposal cost is about twice the rate of conventional wastes.
The cost depends on the types and concentrations of hazardous substances, waste
properties, TCLP results, and required treatment
Under government contracts, DOE, DOD, EPA, and ACE have secured waste
disposal costs on the order of $177 per cubic meter ($5.00 per cubic foot), due to
a large volume discount involving total yearly shipments over 100,000 cubic
yards
The disposal rate includes all fees for closure and post-closure maintenance of the
disposal site under trust funds for mixed waste, low-activity radioactive waste,
and lle.(2) waste
Other surcharges include container and vehicle decontamination, delivery of
waste from December 1 to March 1, under volume shipment, and out-of-
specification wastes
For small quantities of waste, the total unit disposal cost is assumed to be about $55 per cubic
foot or $1,943 per cubic meter, assuming that wastes are shipped by road and that there are no
additional surcharges. For very large amounts of waste, the unit disposal cost is assumed to be
about $6 per cubic foot or $212 per cubic meter, assuming shipments made by rail cars (Rice
1998).
5.3 Mixed Waste Treatment Cost
Since MW is normally treated prior to disposal, generators must determine whether the treatment
can be performed in-house or contracted out to waste brokers or processors. Treatment and
disposal costs are additional expenditures associated with waste storage, packaging, and
shipment. Table 5-3 presents examples of such costs. As with disposal costs, the rates given in
Table 5-3 were obtained through informal telephone surveys and incorporate similar
uncertainties.
Treatment costs are reported to vary significantly, ranging from $12 per liter for liquid waste
held for radioactive decay to $7,930 per liter for liquid MW treated by incineration (Table 5-3).
For comparison, the incineration of conventional low-level liquid waste is reported to vary from
$13 to $24 per liter (Table 5-3). The difference is due to lower radionuclide concentrations and
presence of aqueous liquids, as opposed to organic wastes.
5-8
-------
For some MW, treatment costs can range from $45 to $300 per gallon ($12,000 to $80,000 per
cubic meter), depending on chemical constituents and radioactivity levels and up to $100,000 per
curie for volatile radionuclides, when present at elevated concentrations (Weaner 1998a, b). In
comparison, the solidification of liquid waste and disposal at the Barnwell site as LLRW is
estimated to cost about $15,000 per cubic meter (Table 5-3). The incineration of dry solid waste
with the subsequent disposal of treated ashes at Barnwell is expected to cost about $4,240 per
cubic meter (Table 5-3).
The cost of treating liquid scintillation waste varies depending on whether the waste is shipped in
bulk liquids or contained in vials and whether the waste is regulated or deregulated in the context
of 10 CFR Part 20.2005, addressing the disposal of specifically exempted waste. The treatment
costs vary from $1,800 to $2,500 per cubic meter (Table 5-3).
Table 5-4. Comparative Waste Disposal Costs Borne by Two Facilities in 1996(a)
Waste
Total Volume (L)
H-3 Activity (Ci)
C- 14 Activity
(mCi)
Disposal Costs
Unit Cost* - $/m3
Unit Cost* - $/Ci
Research Institution
LLW - Dry waste
16,950
5,720
57
$200,000
12,000
35
Liquid MW
750
1,970"
0.58"
$300,000
400,000
150
Pharmaceutical Company
LLW - Dry Waste
3,456
0.0566
0.5
$50,000C
14,500
876,000
Liquid MW
22
3"
0
$250,000"
3 14 million
294,000
(a)
(b)
(c)
(d)
(e)
Based on data provided by Dr. Larry Weaner, International Isotope Society (Weaner 1998a, b).
Amounts held in storage at the end of 1996.
Cost to dispose of total inventory of dry active waste as low-level waste.
Cost to dispose of about 850 mCi contained in 21 gallons of liquid mixed waste
Unit costs calculated from data presented in table.
Table 5-4 presents treatment and disposal costs for LLRW and MW incurred in 1996 by two
commercial facilities, a research institution and a pharmaceutical company. For MW, the unit
5-9
-------
disposal costs were reported to be $400,000 per cubic meter and $150 per Ci for the research
institution and $3.1 million per cubic meter and $294,000 per Ci for the pharmaceutical
company. In part, the differences in cost reflect radioactivity levels, treatment methods, waste
brokerage fees, and waste analytical fees. The analytical cost for RCRA-C waste is estimated to
be over $3,000 per sample. For radiochemical analyses, costs can vary from about $50 to over
$200 per sample.
5.4 Other Waste Management Costs
The following presents waste management costs associated with packaging, shipping, and waste
storage. The costs are presented for the sake of completeness. These costs are neutral or
inconsequential compared to LAMW treatment and disposal costs.
5.4.1 Waste Packaging Costs
Waste packaging methods vary, depending upon waste forms, shipping regulations, waste
acceptance criteria of the disposal site, and types of waste containers. Because MW is generated
in small amounts, most of the MW is being stored and shipped in 208-liter (55-gallon) drums and
in lab-packs of various sizes. In most instances, liquid MW is being stored in small containers,
typically with capacities of a few liters, until ready for treatment or shipment. Generally, MW is
carefully segregated since commingling substances with different chemical properties might
complicate the classification of the wastes and result in still higher treatment costs. For MW
generated in larger amounts, appropriately-sized containers are used, including tanks and steel
boxes of varying capacities.
Waste packaging costs vary from as little as $50 for 208-liter (55-gallon) steel drums to several
thousand dollars for tanks designed to hold liquid wastes. For solid wastes, the cost of
containers, such as B-25 boxes (2.5 cubic meters), is about $500, depending on design
specifications and load capacities. Corrosion-resistant waste drum overpacks cost about $160
and $200 for 65- and 95-gallon containers, respectively.
These costs do not include supplemental materials, such as liners, labels, and absorbent and
solidification agents. The costs of drum liners and labels are on the order of a few dollars. The
5-10
-------
costs of absorbent and solidification agents vary as well, e.g., $23 for a one-gallon kit of
Delaware Custom Media to $13 for a 94-pound bag of cement.
5.4.2 Waste Shipping Costs
Waste shipping costs are based on the types of materials, weights, shipping distances, and
whether the vehicle is dedicated to the shipment (i.e., sole use). For local shipments within 300
miles, costs vary from $50 to $400. Generally, costs beyond regionally-defined ranges are given
on a case-by-case basis, taking into account types of wastes, volumes, and weight. The cost is
typically about $2 per mile, excluding tolls and fees for permits.
5.4.3 Waste Storage Costs
Waste storage costs vary, depending on the amounts of waste and provisions for specific
engineered safety features, such as ventilation, liquid waste collection sumps, radiation
monitoring, waste re-packaging, etc. Typically, large industrial facilities and nuclear power
plants include provisions for storage in their overall waste management plans. In many
instances, such facilities are used for all wastes, including hazardous, LLRW, and MW, thereby
minimizing costs.
For small facilities and those generating minimal amounts of waste, storage space is usually
limited and costly. Such generators include startup R&D firms, testing laboratories, academic
institutions, and medical facilities. Accordingly, storage costs can vary significantly, even
among generators that provide similar types of services or conduct nearly identical types of
activities.
Based on a 1993 survey of Michigan licensees, generators producing small amounts of waste
reported incremental costs ranging from $1,000 to $4,000 annually, in 1992 dollars (MLLRWA
1993). The cost of building large dedicated waste storage facilities has been reported to be about
$50,000 for an industrial facility, $140,000 for a university, and over $10 million for a nuclear
utility, in 1992 dollars (MLLRWA 1993). The cost of storing waste at a university was reported
to be about $1,800 per m2, based on a 280 m2 facility designed to hold about 110 cubic meters
(or 0.39 cubic meters of waste per m2 of floor space) of chemical and LLRW (EPA 1996b). The
facility was estimated to cost about $500,000, in 1995 dollars.
5-11
-------
In a 1993 study, the New York State Energy Research and Development Authority reported low-
level waste storage costs ranging from about $300 to $2,200 per m2 (NYSERDA 1993). The
costs varied depending on whether the facility was located in rural or urban areas and by type of
building construction. The cost of building a new waste storage facility designed for both
hazardous waste and LLRW was reported to be nearly $13,000 per m2. A New York utility
reportedly spent $7.2 million for an LLRW storage facility at an existing nuclear power plant
site.
The information presented above implies that storage space is costly. Consequently, it is
expected that commercial LAMW generators would prefer the disposal option in order to reduce
waste management costs.
5.5 Overview of Waste-Management Practices and Issues
As noted earlier, LAMW is routinely generated but mostly in small amounts. These wastes are
assumed to consist primarily of materials that have been treated to meet waste-acceptance criteria
defined by disposal sites. Other types of solid MW, including LAMW, are expected to include
contaminated soils, building rubble, and demolition debris, all containing various levels of
hazardous substances and radioactivity.
Based on information presented in Chapter 3, the current number of commercially operating
RCRA-C facilities is assumed to provide ample capacity to manage the anticipated volume of
treated LAMW covered by the proposed rule (40 CFR Part 193). However, it is not clear how
many of the existing RCRA-C facilities might decide to accept LAMW for disposal. The
decision to accept such wastes would have to consider whether there is enough LAMW to make
a profit in spite of the additional costs associated with NRC/AS requirements and licensing
procedures, however simplified. The cost of processing the license application, based on
schedules from the NRC and States of Texas and Illinois, is estimated to be on the order of
several hundred thousand dollars, excluding the costs for annual inspections and other fees
(IDNS 1998, TRCR 1996, NRC 1998c). For comparison, Waste Control Specialists (WCS)
reported an initial cost of $300,000 for filing for a license with the Texas Department of Health
for its Andrews County facility (WCS 1998). If the NRC/AS were to simplify the licensing
process, the costs noted above could be significantly lower, thereby making the business
opportunity more attractive. A simpler licensing process would result in other cost reductions,
5-12
-------
including, for example, fewer radiation monitoring requirements and less related equipment, and
lower staffing needs to support facility operations.
Only a few of the 20 currently operating facilities are expected to decide to accept LAMW. The
decision to do so might have to consider how existing or planned disposal facilities (e.g.,
Envirocare or WCS) would respond to the proposed rule. For example, existing or planned
facilities might respond by lowering disposal costs, accepting LAMW streams or volumes that
were once turned away, seeking to amend their licenses to accept a broader category of MW, and
offering full services that combine waste treatment and disposal at RCRA-C disposal facilities.
This approach would allow LAMW generators to ship directly to the disposal site, thereby
avoiding waste brokers and processors as intermediaries and eliminating the associated brokerage
fees.
Treatment facility operators believe that there is not enough commercial MW to justify the
construction and operation of new treatment facilities. In order to be cost-effective, such a
facility might need to also accept much larger volumes of mixed waste, e.g., waste generated by
large-scale remediation projects. Some treatment facilities are not accepting MW from Federal
remediation projects because of contractual constraints and related project complexities. The
major MW processors are believed to have excess treatment capacity for some of the most
common waste streams (e.g., liquid scintillation fluids). This capacity could be modified to treat
other types of MW at less cost than installing new capacity. Current treatment fees reflect
elevated fixed costs and operating expenses and permit restrictions imposed on radionuclide
airborne emissions from thermal treatment processes.
Installing additional treatment is reported to be expensive (NSSI 1998). Some of the costs of
setting up and licensing a new treatment facility include:
• Licensing cost of about $0.5 million, including the preparation of a license
application package, and a licensing process support cost ranging from about SI
to $2 million, depending on the duration of the licensing process (an expected
three to five years).
• Liquid waste processing system for about $3 to $5 million; waste stabilization
system for about $0.2 to $0.5 million; and metal retort system for about $1.0
million. All estimates exclude the cost of land and structures.
5-13
-------
For some industries, treatment costs, as opposed to access to disposal sites and disposal costs, are
a major concern, e.g., pharmaceutical laboratories and research and development (R&D)
institutions. For other industries, access to disposal sites and costs are the concerns, e.g., nuclear
power plants and MW generated during decontamination and decommissioning. Some
commercial MW generators believe that regulatory complexity impedes the development of new
treatment facilities and acceptability of waste to existing RCRA-C disposal facilities. The
perception among MW generators is that the complexity of the regulatory process offers the
opportunity for waste treatment facility operators to charge exorbitant costs. For example, some
treatment costs can range from $12,000 to $80,000 per cubic meter, depending on chemical
constituents and radioactivity levels. For volatile radionuclides, treatment costs vary from
$1,400 to $100,000 per curie of H-3 and from $30,000 to $100,000 per curie of C-14, depending
on liquid waste concentration and total activity levels (Weaner 1998a, b). For some institutions,
the cost of treating MW is the critical factor in deciding whether to conduct specific types of
R&D work. In most instances, treatment costs by far outweigh the initial purchase costs of
radiochemicals used in R&D activities. For example, the cost of tritium varies between $3 and
$250 per curie, and the cost of C-14 radiolabeled barium carbonate is about $5,500 per curie
(Weaner 1998b, Amersham 1998). Treatment costs dwarf the initial cost of radiolabeled
products, with ratios of 400-to-l and 33,300-to-l for tritium and 20-to-l for C-14.
Without affordable treatment and disposal outlets, generators are incurring additional expenses.
Such costs include the use of expensive floor space for waste storage, specialized storage systems
(e.g., ventilated and explosion proof cabinets) for some types of hazardous wastes, maintaining
and monitoring waste inventories, and implementing additional occupational health and safety
provisions. For storage purposes, MW is not necessarily characterized by sampling and analysis;
process knowledge is often used instead. More detailed characterizations are performed when a
treatment process and disposal methods have been identified for a specific waste stream. This
approach results in lower operating costs since RCRA waste characterizations typically cost over
$3,000 per sample and radiochemical analyses can cost up to $200 per sample. These cost
differences provide some incentives to treat and process MW to remove either its hazardous or
radioactive component. In general, commercial MW generators are looking for regulatory relief.
They want the ability to treat small (exempted) quantities of MW onsite without the need of a
RCRA Part B Permit. A Part B permit is costly to obtain and imposes a severe administrative
burden. Some R&D work indicates that "bench top" treatment units are effective in treating
some types of MW (Weaner 1997, Hoerr 1997).
5-14
-------
Chapter 6
Analysis of Impact on Commercial Low-Activity Mixed Waste Generators
6.0 Introduction
The proposed rule (40 CFR Part 193) specifies conditions under which certain types of LAMW
may be disposed of in RCRA Subtitle C facilities (RCRA-C facility). The conditions reflect
requirements established by the Nuclear Regulatory Commission and Agreement States (referred
to as "NRC/AS") under the Atomic Energy Act of 1954 (AEA). These requirements are based
on the radiological properties of such wastes. The proposed rule does not change any of the
RCRA controls and technology requirements for the chemically hazardous components of
LAMW, but rather focuses on controls necessary to ensure protection from the radioactive
component. Additional details about the objective and scope of the rule are presented in
Chapters 1 and 2, and the Background Information Document for 40 CFR Part 193 (BID)
presents the results of supporting technical analyses.
6.1 Cost-Benefit Analysis Methodology
The proposed LAMW disposal rule cannot be evaluated by typical approaches, such as that
required under Section 3(f) of Executive Order 12866 for proposed regulations that are expected
to result in significant economic impacts (EOF 1993a,b, OMB 1994). Chapter 1 discusses the
requirements and criteria contained in the Executive Order. Typically, a new environmental
regulation imposes additional requirements or constraints on the affected economic entities, thus
increasing their cost of doing business. In other environmental rulemaking, unduly burdensome
standards might be relaxed. In such a situation, the direction of the cost and health-effect
impacts would be reversed, but some of the broader aspects of a traditional cost-benefit
methodology would still apply.
Since the proposed LAMW disposal rule imposes no additional requirements that would increase
the cost of doing business, the rule would permit an additional disposal option for certain types
of MW that is not now available and result in substantial cost savings to commercial LAMW
generators. The new disposal alternative would provide a level of protection against
environmental and health risks equal to that of current options by limiting maximum
radionuclide concentrations in LAMW that would be disposed of in commercial RCRA-C
6-1
-------
facilities opting to utilize this rule. Hence disposal risks would be essentially identical.
Therefore, the cost-benefit analysis of the proposed rule is reduced to a consideration of the
economic mechanisms that would determine the magnitude of the cost savings and risk reduction
attributable to this rulemaking.
6.2 Uncertainties and Constraints
The economic efficiencies of relaxing unnecessary regulations have been noted in a wide variety
of areas, including the airline, natural gas, and electricity markets'. The current unfulfilled
demand for LAMW disposal services is a result of an artificial monopoly created by dual
regulations for MW. In the current monopolistic setting, the supply of disposal services is
artificially constrained, resulting in a shortage of disposal capacity, which, in turn, has led to
higher costs. The theory of regulated markets suggests that if the price of waste disposal were to
fall, because of the removal of specific prohibitions, then it is expected that such an outcome
would result in net positive societal benefits. Facility operators would then be able to enter a
market that previously did not exist, but would act only if there is a sufficient return on
investment. Depending on the degree of competition, the new market price will be nearer to that
of an ideal market, which would result in the most efficient allocation of disposal capacity.
However, the attainment of a totally free and truly efficient market is perhaps an unreachable
goal in this already highly regulated industry.
The NRC conducted an informal trade-off analysis in developing the requirements for 10 CFR
Part 61 in order to maximize societal benefits. This trade-off analysis balances the costs of better
long-term containment versus health benefits. Theoretically, the marginal cost of control is set to
equal the marginal benefit. In the implementation of its low-level radioactive waste (LLRW)
regulations, the NRC recognized the need for a graded regulatory approach. Because higher
activity LLRW requires a higher degree of containment, three levels of classification were
created, as Classes A, B, and C. The imposition of stringent containment controls also creates an
artificial monopoly, as other means of LLRW disposal are prohibited. If a graded approach
were used for Class A waste, the unnecessarily restrictive controls imposed on the spectrum of
1 See, for example, Economics, lSh Ed., Chapters 17 and 18, Samuelson and Nordhaus (1998) for a
discussion of the efficiency of regulation of environmental "goods."
6-2
-------
waste with lower radionuclide concentrations would be relaxed in proportion to the degree of risk
they pose.
Similarly, if a graded approach were adopted for MW, the level of containment provided by
RCRA-C facilities might be deemed sufficient for the disposal of LAMW. In the current
regulatory regime, this graded approach is prohibited because RCRA-C facilities must obtain
specific authorization from NRC/AS for the appropriate type of license for the disposal of
LLRW. The dual regulatory requirements for RCRA hazardous waste and LLRW are expensive,
complicated, and sometimes inconsistent. The combined effect of these regulations has been the
creation of a backlog of stored MW and LAMW, while available disposal capacity at commercial
RCRA-C facilities goes unused. Additional economic inefficiencies and societal risks have been
created due to the need for prolonged interim storage and transportation over long distances to a
few disposal sites allowed to accept only certain MW.
Several major factors complicate the assessment of costs and benefits. First of all, the proposed
rule does not impose new requirements and costs, as compared to considerations addressed in a
traditional cost-benefit analysis. Second, individual States will decide whether to implement the
proposed disposal method for LAMW, taking into their account existing laws, local
governments, and public participation. In the past, some States have opposed the introduction of
wastes from other States. These States may implement the rule in a way that will continue these
policies. This type of prohibition will reduce the available markets for new LAMW disposal
capacity and, hence, reduce the number of disposal facilities that would participate. It is
assumed, however, that States will not use their discretionary powers to prohibit the disposal
option that is proposed under this rule. On a related matter addressed by States, the proposed
rule is not expected to impact the activities of Low-Level Radioactive Waste Compacts or
unaffiliated States in developing new disposal facilities in response to the Low Level Radioactive
Waste Policy Amendments Act of 1985 (Public Law 99-240) because current and projected
waste generation trends involve only small amounts of LAMW.
Third, the presence of radioactivity in the waste means that the NRC/AS will be involved to
regulate radioactive materials covered by the AEA. If the NRC/AS impose strict requirements to
obtain a permit or license for disposing of commercial LAMW in RCRA-C facilities, there is less
of a chance that the new alternative will be widely adopted.
6-3
-------
Fourth, the EPA believes that reliable and comprehensive information is not available to allow
the EPA to perform detailed cost and risk assessment analyses. Given the lack of adequate
information about commercial MW generation rates, volumes, waste streams, and radioactivity
levels information, the RIA makes various assumptions and relies on the results of studies
characterizing MW volumes and disposal. Waste storage, packaging, and transportation costs are
also important, but they are not quantified in this analysis. This simplified approach may not
fully reflect actual MW and LAMW management practices.
In short, the eventual economic impact of the proposed rule depends entirely on the future
actions of commercial LAMW generators and treatment and commercial RCRA-C facility
operators, and requirements imposed by the NRC/AS for the implementation of the rule, as well
as on legal constraints arising from other Federal and State regulations.
6.3 Impact Analysis
The issues and uncertainties noted in Sections 6.1 and 6.2 preclude the derivation of qualitative
estimates for the types and amounts of LAMW that will be affected by the proposed rule. The
mixed waste disposal industry consists of waste generators, storage and treatment facilities, and
the disposal facilities themselves. The current status of the industry is depicted in Figure 6-1.
The flow chart in this figure depicts the flow of mixed waste from waste generators, through
storage and treatment, to final disposal in one of three types of facilities:
1. A conventional RCRA hazardous waste landfill
2. A conventional LLRW disposal facility
3. A jointly regulated facility that is licensed for both AEA and RCRA wastes under
the proposed rule
The flow chart shows that some types of MW are eligible for special treatment and disposal
under the provisions of 10 CFR Part 20.2005, Disposal of Specific Wastes. Other MW,
containing short-lived radionuclides, is suitable for decay-in-storage before disposal as hazardous
waste. The remaining MW stream is considered a candidate for disposal in a jointly regulated
RCRA-C facility, unless the waste can be treated to remove the hazardous component. If
treatment were successful, the waste is eligible for disposal in a LLRW facility. The current
regulatory situation results in some wastes that are held in storage in untreated form, while other
treated wastes are held in storage because of the unavailability of disposal options at reasonable
6-4
-------
MIXED WASTE
GENERATOR
Can hazardous
component be
Healed?
Is waste eligible lor
component eligible >— No
under 10 CFR 20/>
TREATMENT
OF
HAZARDOUS
COMPONENT
STORAGE
FOR DECAY
is mixed waste
disposal available at
reasonable cost1
RCRA TREATMENT AND DISPOSAL
LLW FACILITY
STATUS QUO
No*
'PERPETUAL'
STORAGE
JOINTLY
REGULATED
FACILITY
Figure 6-1. Current Mixed Waste Disposal Status
6-5
-------
costs. In this context, the flow chart depicts "perpetual" storage as a regulatory "dead-end,"
where there is simply no feasible disposal alternative.
The anticipated results of the proposed rule are depicted in Figure 6-2. The flow chart for MW
has been modified to include two new branches. As a result, some MW generators would have
access to a new disposal option under which treated LAMW could be disposed of in regional
commercial RCRA-C facilities. In addition, the LAMW portion of the current inventory of
treated and untreated MW held in storage would be eligible for disposal under this rule, thus
eliminating the "dead-end" for a portion of LAMW.
Figures 6-1 and 6-2 demonstrate that the economic impacts of the proposed rule would reach far
beyond the financial impacts on commercial RCRA-C facilities. For example, the amounts of
MW managed by decay-in-storage programs would be reduced. In addition, new lower cost
treatment and waste segregation techniques would likely be developed to take advantage of the
new disposal option. Transportation costs and risks would be reduced as a result of having local
or regional disposal outlets for such wastes. Although there are large uncertainties in estimating
the magnitude of the cost savings, the regulation clearly encourages more efficient disposal.
Additional cost savings are expected to result from:
• The reduced need for interim waste storage
• The development and availability of new waste treatment techniques
• The development and application of new waste segregation techniques
• Reduced waste transportation costs
• The availability of lower-priced LAMW disposal in permitted RCRA-C facilities
The proposed rule would not require commercial RCRA-C facilities to take any action, unless
operators choose to accept LAMW. In that event, the operator would have to apply for an
NRC/AS license. To address the disposal of LAMW, it is expected that the NRC/AS would
simplify the licensing process by taking into account the engineering features and administrative
protection requirements already addressed by the RCRA permitting process. Because the
proposed rule is optional, current RCRA-C waste management practices would remain
unchanged, but the rule would impose some additional regulatory requirements and costs.
Commercial RCRA-C facilities utilizing the rule could probably recoup these costs by placing a
disposal fee surcharge on LAMW. The ability to generate a profit would depend on two
important factors:
6-6
-------
MIXED WASTE
GENERATOR
WITH NEW ALTERNATIVE
Can hazardous
component be
liealed?
Yes
Yes
Yes
STORAGE
FOR DECAY
Yes
TREATMENT
OF
HAZARDOUS
COMPONENT
<
r
Yes
RCRA TREATMENT AND DISPOSAL
LLW FACILITY
J~~y>ry low activity wastes
No-i
Is mixod waste
disposal available al >— No*
reasonable cost?
PERPETUAL-
STORAGE
Yes
1
JOINTLY
REGULATED
FACILITY
Figure 6-2. Anticipated Mixed Waste Disposal Under Proposed Rule
6-7
-------
1. The cost of providing disposal capacity, which could be estimated with a
relatively high degree of certainty
2. The future price of LAMW disposal service, which would be very difficult to
estimate because a competitive market for this service does not exist currently
Thus, facility operators must consider factors that would affect the future price of LAMW
disposal in each region, including possible demands for the new LAMW disposal services and
the degree of competitive market forces. The creation of a large number of regional markets
would, in itself, reduce the cost of transporting LAMW from the treatment facility to the disposal
site.
6.3.1 Directly Regulated Entities
The rule focuses on commercial RCRA-C facilities because they already provide related services
to the broadest range of generators. Such facilities already meet all applicable RCRA Subtitle C
permitting requirements. In addition, they would have to meet all radiation-related requirements
of this proposed rule and other applicable standards. Approximately twenty commercial RCRA-
C facilities are currently operating and would form the core of candidates to be regulated under
the proposed rule. In addition, there are many more privately owned RCRA-C facilities, most of
which accept hazardous wastes from only a single or limited numbers of generators. However,
the rule does not specifically address these facilities but recognizes that if a facility or generator
were to select this option, it would have to obtain specific NRC/AS authorization and follow all
established requirements. In reviewing such an application, the NRC/AS would need to consider
whether the proliferation of such facilities would be acceptable, depending upon the provisions
of the rule.
It is not possible to predict how many RCRA-C facilities would choose to utilize the provisions
of the proposed rule. Facilities would have to decide whether the financial benefits of accepting
such wastes outweigh the additional regulatory and technical burden imposed by the NRC/AS
regulations. Few commercial RCRA-C facilities have chosen to apply for a license to dispose of
LLRW under existing regulations. In part, this may be due to the complexity of applying for a
license under 10 CFR Part 61, elevated costs, and the protracted licensing process. Current
license application and processing fees can be on the order of several hundred thousand dollars,
with comparable annual fees. If the RCRA-C facility operator chose not to accept LAMW, the
6-8
-------
proposed rule would have no monetary or operational effect on them. However, the existence of
the rule would give these facilities the option of planning future disposal capacity.
6.3.2 Indirectly Affected Entities
Although RCRA-C facilities would be the only directly regulated entities affected by this
rulemaking, consumers of LAMW disposal services are expected to derive indirect economic
benefits from the new disposal option. Presently, commercial LAMW generators have very few
disposal options. If current treatment and disposal costs have forced generators to store MW and
LAMW at the point of generation, while waiting for additional or new disposal alternatives.
They are faced with onsite storage for indefinite times, with the attendant safety, liability, and
regulatory problems. They incur costs to:
• Stabilize and package LAMW waste
• Provide long-term storage, as an interim measure
• Conduct periodic inventories and characterizations
• Satisfy EPA, NRC, and State regulatory requirements
Their other option is disposal at the only operating commercial MW facility, Envirocare, which
is designed for and caters to generators producing large amounts of bulk wastes. The continued
availability of Envirocare is also dependent on the continued approval of its host State. In
general, the needs of facilities generating small amounts of LAMW have not been adequately
addressed. Such generators, which include hospitals, laboratories, and research institutions, have
limited resources and do not qualify for volume discounts. The prospect of the rule offers a cost-
effective and environmentally acceptable outlet to this under-served segment of the market.
The treatment of mixed waste might also be affected by this rulemaking. New treatment
methods are likely to take advantage of this new disposal option. Segregation of LAMW from
the current MW inventory would offer opportunities for additional costs savings. A separate, but
related, market for the treatment of LAMW would evolve. The price of MW treatment would be
determined by the interaction of supply and demand for LAMW treatment from a large number
of MW generators and volume in regional markets.
6-9
-------
6.3.3 Storage Costs
In general, waste storage systems required for hazardous waste include ventilation systems for
flammable chemicals and, in some cases, explosion-proof vaults. Storage costs include the
expenses of complying with regulatory requirements for conducting inventories and MW
characterizations and the associated administrative burden of tracking hundreds to thousands of
containers holding waste. Storage costs have been shown to vary significantly, depending on the
capacity and complexity of the facility. The cost of building large dedicated waste storage
facilities has been reported to be about $50,000 for an industrial facility, $500,000 for a
university, and over $10 million for a nuclear utility (MLLRWA 1993, EPA 1996b).
6.3.4 Treatment, Packaging, and Transportation Costs
The need to treat LAMW depends on the types of wastes. Treatment of organic fluids and oils
typically includes thermal destruction of the hazardous waste components by incineration or use
as fuel. The resulting ashes or residues must pass the toxicity characteristic leaching procedure
(TCLP) test for any remaining hazardous components and typically require disposal as a
hazardous waste after stabilization. If MW were treated by incineration, some of the
radioactivity would be retained in the ash, while more volatile radionuclides would be entrained
in exhaust gases and discharged into the environment. For some types of solid wastes, hazardous
components typically require encapsulation by grinding the waste and mixing it with concrete or
polymers. Under current practices, disposal charges are calculated, at least partially, on volume
and weight bases. Hence, volume reduction prior to disposal is a common method sought to
reduce costs. Such waste treatment methods are already well established and would not be
impacted by the proposed rule. Accordingly, waste treatment costs are expected to be neutral.
Packaging costs are not addressed in this analysis. These costs reflect requirements for as-
generated and treated wastes established under EPA-permitted treatment and disposal facilities
and DOT shipping regulations. Packaging requirements are well defined, and the related costs
are not expected to change as a result of this rule.
The cost of transportation from treatment facilities or generators to RCRA-C disposal facilities
will be affected by this rule. After the rule's implementation, the total transportation costs are
assumed to be significantly lower, because of the number of more qualified RCRA-C facilities
6-10
-------
will increase. Simple geometric reasoning suggests that transportation costs will be reduced if
more disposal facilities were to open in various regions of the country. A more mathematical
approach to calculating the reduction in shipping distances suggests that transportation distances
might be reduced by about one-third to two-thirds.
Regional and local transportation costs for LLRW and MW can range, for example, from $50 to
$400 per shipment within a 300-mile radius. Beyond 300 miles, shipping costs are assessed on a
case-by-case basis, taking into account waste forms and waste volumes and weight. Shipping
costs are typically $2 per mile, plus tolls and permit fees.
6.3.5 Disposal Costs
Disposal costs for conventional hazardous wastes at RCRA-C facilities are relatively expensive,
but still lower than the amounts charged for MW and LLRW. Disposal costs were found to
range from $40 to $200 per ton or $44 to $220 per cubic meter, assuming unit bulk density and
excluding local taxes and minimum charges. State and county taxes and surcharges vary from
about $18 to $81 per cubic meter and from 4 to 10%. The quoted costs are assumed to reflect
full life-cycle costs, including those incurred during the pre-operational, operational, and closure
and post-closure phases of facility operation, although this was not explicitly stated by the
operators of disposal facilities.
By comparison, disposal costs for LLRW vary from about $4,000 to $15,000 per cubic meter at
Bamwell and Richland. The disposal cost at Envirocare is estimated to be nearly $2,000 per
cubic meter for LLRW and about twice that for MW. In all instances, actual costs can vary
significantly, depending on waste volumes and properties and treatment. Chapter 5 presents
supplemental cost data for treated and untreated hazardous waste, MW, and LLRW.
6.3.6 Indirect Costs
The elevated treatment and disposal costs and the additional administrative burden associated
with the management of LAM W may result in additional indirect societal costs. Anecdotal
evidence suggests that the cost of disposing of such wastes has caused doctors, hospitals, and
diagnostic laboratories to suspend certain types of medical procedures and clinical tests. The
high cost of disposal has sometimes led university researchers to choose less efficient procedures
6-11
-------
instead of more effective alternatives. It is suspected that disposal costs are directly hampering
medical research. These problems could likely be alleviated if there were more disposal facilities
authorized to dispose of LAMW. No attempts were made here to quantify these indirect societal
costs, but the net effect is expected to be large cost savings.
6.4 Risk Assessment Analysis
Risk assessment analyses were performed by quantifying doses to members of the public and
RCRA-C facility workers. This information is described in Chapters 4,5, 6, and 7 of the
Background Information Document for 40 CFR Part 193. The analysis considers risks
associated with treatment, packaging, storage, transportation, and disposal at RCRA-C facilities
only in a qualitative manner.
6.4.1 Storage Risks
The risk assessment analysis does not explicitly characterize the potential risks associated with
LAMW storage, characterization, and inventory activities. In the short-term, the reduction in
dose associated with reduced LAMW storage volumes may be offset by increased exposures
occurring during waste treatment and packaging. In the longer term, the risks would be reduced,
since the amount of LAMW held in storage would decrease as it is shipped to RCRA-C facilities.
The proposed rule assessed exposure and dose to a RCRA-C facility worker, but the EPA's
authority does not extend to "radiation workers" who may be exposed to radioactive materials in
the course of their duties. The NRC/AS are expected to continue to address radiation protection
to workers during storage and treatment at the point of generation and disposal activities as part
of the licensing and implementing procedure developed for RCRA-C facilities opting to utilize
the proposed rule.
6.4.2 Treatment, Packaging and Transportation Risks
The proposed rule is not expected to have an impact on the risks associated with treatment and
packaging. Treatment and stabilization of the RCRA hazardous component will be required for
all LAMW disposed of at RCRA-C facilities under requirements. Transportation risks associated
with LAMW are expected to increase somewhat in the short-term as current LAMW inventories
are shipped out for treatment and eventual disposal at the newly eligible RCRA-C facilities. In
6-12
-------
the longer term, transportation risks will decrease, since shipping distances between generators
and RCRA-C facilities would be reduced by approximately one-third to two-thirds.
The proposed rule would not result in any changes to existing shipping regulations. Existing
DOT, NRC, and EPA regulations are expected to provide the necessary level of protection. The
transportation of hazardous material is regulated under the requirements of the DOT under 49
CFR Parts 171 to 178, the NRC under 10 CFR Parts 20 and 71, and the EPA under 40 CFR Part
263.
6.4.3 Disposal Risks
The risk assessment analysis is based on quantifying the risk to the Critical Population Group
(CPG). Population health effects are not addressed directly but are assumed to parallel the
estimated CPG risks. Estimates of long-term risks to the CPG due to permanent disposal of
LAMW in RCRA-C facilities were developed using exposure models for generic sites assumed
to be located in three different hydrogeological regions. The analysis considers LAMW
generation rates and characteristics, the suitability of RCRA-C disposal technology in
accommodating the presence of radioactivity, potential exposures to facility workers, the impact
of stabilized waste forms in mitigating releases of radioactivity in the environment, and site-
specific climatic factors affecting radionuclide mobility in the environment. Performance
assessment analyses were conducted to establish, as a long-term performance standard,
maximum LAMW radionuclide concentration limits, based on Maximum Contaminant Levels
(MCLs) for drinking water developed for members of the public and an annual dose of 15 mrem
for RCRA-C facility workers. Also, the proposed rule allows RCRA-C facility owners or
operators to use site-specific information to calculate alternative maximum LAMW
concentration limits.
6.5 Summary Conclusions
The analysis shows that it is possible to use commercial RCRA-C facilities for the disposal of
LAMW and the results of the risk assessment indicate no increases in risks to the public or
impacts on the environment. The proposed standard (40 CFR Part 193) will provide the means
to readily dispose of LAMW in facilities designed to ensure the protection of the public and
environment for the long-term. The wide difference in disposal cost between commercial
6-13
-------
RCRA-C facilities and conventional LLRW disposal or disposal in the few available mixed
waste facilities indicates that significant cost savings and more efficient disposal could be
achieved, even if only a small fraction of the total amount of LAMW were to qualify for disposal
under this rule. As a result, the proposed rule is expected to yield only positive net incremental
cost savings and societal benefits. Finally, commercial LAMW generators would be expected to
pass on a portion of the cost savings to the eventual consumers of their products and services.
6-14
-------
Chapter 7
Report Summary
7.0 Background
The U.S. Environmental Protection Agency (EPA) is proposing an environmental standard (40
CFR Part 193) for the disposal of low-activity mixed waste (LAMW) in commercial Resource
Conservation and Recovery Act (RCRA) Subtitle C facilities (RCRA-C facility). LAMW is
characterized by the presence of both hazardous chemicals and radioactive materials. Most of
the LAMW is being generated in small amounts by commercial generators, including medical,
educational, industrial, and nuclear power plants. LAMW is produced when chemicals become
commingled with radioactive materials. If it were not for the presence of very low levels of
radioactivity, LAMW would otherwise be disposed of as a hazardous waste. As a result,
commercial LAMW is often well suited to treatment and disposal methods currently applied to
similar types of RCRA hazardous wastes.
The disposal of LAMW is complicated by the need to comply with redundant regulatory
requirements to meet both radioactive and hazardous waste standards. Because of the increased
demand for disposal facilities and the need to streamline the regulatory process for mixed waste,
the EPA is proposing a standard that will promote the timely and permanent safe disposal of
LAMW. The standard is being proposed in the spirit of current Federal efforts to redesign the
regulatory process and minimize the regulatory burden. Additional information supporting this
rulemaking is contained in the Background Information Document for 40 CFR Part 193 (BID).
7.1 Summary of Proposed LAMW Disposal Rule
The proposed EPA standard includes the following major aspects:
• Maximum allowable LAMW radionuclide concentration limits are based on
ground water Maximum Contaminant Levels (MCLs), as a long-term performance
standard. They apply to exposures to members of the public from all exposure
pathways, including ground water, due to environmentally mobile radionuclides.
• Waste with multiple radionuclides would be further restricted under the sum-of-
the-ratios rule.
7-1
-------
• Provisions to develop site-specific maximum allowable LAMW radionuclide
concentration limits equivalent to the MCLs, based on long-term performance
analyses using site characteristics and facility design features.
• The rule is restricted to LAMW radionuclide concentrations that are less than the
limits of 10 CFR Part 61.55 for Class A waste. This restriction also applies to
LAMW radionuclide concentrations developed using site-specific characteristics
and facility features.
• LAMW that does not meet the requirements of the proposed standard will have to
be held in storage, as is current practice, or treated to remove either the hazardous
or radioactive constituents and disposed of appropriately either at a low-level
radioactive waste disposal facility or at RCRA-C disposal facilities.
• An annual dose limit of 15 mrem (EDE) is established for RCRA-C facility
workers due to the exposure to radionuclides that are environmentally immobile
or decay before reaching ground water.
States, in exercising their discretionary powers, will determine whether to allow
this disposal alternative, taking into account existing laws and public
participation.
• The rule would be implemented under regulatory provisions established by the
Nuclear Regulatory Commission (NRC) and Agreement States, taking into
account the radiological properties of LAMW.
7.2 Summary of Regulatory Impact Analysis:
The following presents the major findings and conclusions of the RIA:
• The risk assessment analysis shows that it is possible to use commercial RCRA-C
facilities, located in both arid and humid regions, as long as radionuclide
concentration limits are correspondingly adjusted.
For facilities located in humid regions, site-specific analyses might be required,
taking into account actual hydrogeological site conditions, disposal cell
engineered features, types of LAMW streams, and radionuclide distributions and
concentrations.
• It is expected that commercial RCRA-C facility operators and commercial
LAMW generators will utilize the proposed rule at their discretion, taking into
account the response of waste generators, potential volume of LAMW that might
7-2
-------
benefit from the proposed rule, incremental operating costs, and potential
revenues.
Without an appropriate standard, disposal costs are expected to remain high or
even increase, as the storage of LAMW would be required for indefinite times in
facilities that do not offer the best level of protection to the public and
environment.
The standard will provide the means to readily dispose of a fraction of the mixed
waste volume that is currently being held in storage throughout the nation.
LAMW will be rendered less hazardous through treatment and placement in
facilities designed to ensure the protection of the public and environment for the
long-term.
There are no impediments in the current RCRA Subtitle C permitting process that
would hinder the implementation of the proposed rule.
The proposed standard does not modify existing waste acceptance criteria or
impose new containment requirements for regulated RCRA-C facilities, nor does
it relax any other applicable Federal and State regulations.
Although AEA and RCRA regulations are based on different approaches to
protecting the environment and public, the different requirements, as dictated
separately by the EPA and NRC, were found to complement one another. In both
instances, the design features strive to achieve the same goal, i.e., containing and
isolating hazardous wastes (radioactive and mixed waste) from the environment.
It is anticipated that only a few of the currently operating commercial RCRA-C
facilities will consider accepting LAMW.
An evaluation of operating commercial RCRA-C facilities indicates that such
facilities offer ample disposal capacity for the anticipated small amounts of
LAMW that are currently held in storage and that are expected to be generated in
the future.
The results of the risk assessment analysis indicate no increases in risks to the
public or impacts on the environment.
The proposed disposal standard is designed to reduce disposal costs with no
degradation of protection of human health and the environment resulting from the
disposal of LAMW.
7-3
-------
The wide difference in disposal cost between commercial RCRA-C facilities and
conventional LLRW disposal or disposal in the few available mixed waste
facilities demonstrates that significant cost savings and more efficient disposal
could be achieved, even if only a small fraction of the total amount of LAM W
generated nationally were to qualify for disposal under this rule.
The proposed rule is expected to yield only positive net incremental cost savings
and societal benefits, and commercial LAMW generators would be expected to
pass on a portion of the cost savings to the eventual consumers of their products
and services.
7-4
-------
AEA 1954
Amersham 1998
CDHS 1989
CHWMS 1997
CNSI 1998
DOE 1993
DOE 1994a
DOE 1994b
DOE 1997
DOE 1998
Envirocare 1995
Envirocare 1997
EOF 1993a
References
Atomic Energy Act of 1954 as amended (42 U.S.C. 2022).
Phone quote for C-14 radiolabeled barium carbonate, Ms. Mary Hansen,
Amersham, Arlington Heights, IL, June 24,1998.
California Department of Health Services, Conceptual Mixed Waste
Management Plan, Ebasco Services, Inc., December 22,1989.
Connecticut Hazardous Waste Management Service, Is There Still Orphan
Mixed Waste? Report on a Survey of Commercial Mixed Waste
Generators, Hartford, CT, July 10,1997.
Chem-Nuclear System, Inc., Barnwell Waste Management Facility and
Price Schedule, July 1, 1998 Rates, Columbia, SC.
Department of Energy, Disposal of Low-Level and Mixed Low-Level
Radioactive Waste During 1990, DOE/EH-0332P, August 1993,
Washington, DC.
Department of Energy, Mixed Waste Landfill Integrated Demonstration
Technology-Summary, DOE/EM-0128P, February 1994, Washington,
DC.
Department of Energy, DOE Methods for Evaluating Environmental and
Waste Management Samples, DOE/EM/0089T, 1994, Washington, DC.
Department of Energy, Integrated DataBase for 1996: Spent Fuel and
Radioactive Waste Inventories, Projections, and Characteristics,
DOE/RW-0006, Rev. 13, December 1997, Washington, DC.
Department of Energy, 1997 State-by-State Assessment of Low-Level
Radioactive Wastes Received at Commercial Disposal Sites, DOE/LL W-
247, Lockheed Martin Idaho Technologies Company, August 1998.
Waste Application and Submittal Package, Envirocare of Utah, Inc.,
March, 1995.
Waste Application and Submittal Package, Envirocare of Utah, Inc., 1997.
President of the United States, Executive Order 12866, September 30,
1993, Executive Office of the President of the United States.
R-l
-------
EOF 1993b
EPA 1987a
EPA1987b
EPA 1988
EPA 1990a
EPA 1990b
EPA 1991
EPA 1995
EPA 1996a
EPA 1996b
President of the United States, Guidance for Implementing Executive
Order 12866, October 12,1993, Memorandum from Mr. Leon E. Panetta,
Executive Office of the President of the United States, Washington, DC.
Environmental Protection Agency, NRC/EPA Siting Guidelines for
Disposal ofLLMW, OSWER Directive 9480.00-14, June 1987,
Washington, DC.
Environmental Protection Agency, Joint NRC/EPA Guidance on a
Conceptual Design Approach for Commercial LLMW Disposal Facilities,
OSWER Directive 9487.00-8, August 3,1987, Washington, DC.
Environmental Protection Agency, Office of Policy Analysis, Draft
Environmental Impact Statement for Proposed Rules, Vol. 2, Economic
Impact Assessment, EPA-520/1-87-012-2, Revision dated August 1988,
Washington, DC.
Environmental Protection Agency, Guidance on the Land Disposal
Restrictions' Effects on Storage and Disposal of Commercial Mixed
Waste, OSWER Directive 9555.00-01, Sept. 28,1990, Washington, DC.
Environmental Protection Agency, Low-Level Mixed Waste - A RCRA
Perspective for NRC Licensees, EPA/530-SW-90-057, August 1990,
Washington, DC.
Environmental Protection Agency, "National Primary Drinking Water
Regulations; Radionuclides," Federal Register, Vol.56, No. 138, 33050,
July 18,1991, Washington, DC.
Environmental Protection Agency, Assessment of the Potential Costs and
Benefits of the Hazardous Waste Identification Rule for Industrial Process
Wastes, Economics, Methods, and Risk Assessment Division, OSWER,
May 25,1995, Washington, DC.
Environmental Protection Agency, Technology Screening Guide for
Radioactively Contaminated Sites, EPA 402-R-96-017, November 1996,
Washington, DC.
Environmental Protection Agency, Profile and Management Options for
EPA Laboratory Generated Mixed Waste, EPA 402-R-96-015, August
1996, Washington, DC.
R-2
-------
EPA 1996c
EPA 1997a
EPA1997b
EPA 1997c
Gingerich 1998
Gore 1993
Gore 1995
Hoerr 1997
ICRP 1985
IDNS 1998
Means 1997
Environmental Protection Agency, Stabilization/Solidification Processes
for Mixed Waste, EPA 402-R-96-014, June 1996, Washington, DC.
Environmental Protection Agency, Best Management Practices (BMPs)
for Soil Treatment Technologies: Suggested Operational Guidelines to
Prevent Cross-Media Transfer of Contaminants During Cleanup
Activities, EPA 530-R-97-007, May 1997, Washington, DC.
Environmental Protection Agency, The National Biennial RCRA
Hazardous Waste Report (Based on 1995 Data) - National Analysis, EPA
530-R-97-022c, August 1997, Washington, DC.
Environmental Protection Agency, The National Biennial RCRA
Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis,
EPA 530-R-97-022d, August 1997, Washington, DC.
Connecticut Hazardous Waste Management Service, correspondence of
May 28,1998, from Mr. Ronald Gingerich to Mr. J-C. Dehmel, SC&A,
Inc., with selected questionnaires. As submitted, the questionnaires did not
identify the names or addresses of the surveyed facilities.
Office of the Vice President of the United States, National Performance
Review, Al Gore, September 7,1993, Washington, DC.
Office of the Vice President of the United States, Reinventing
Environmental Regulations, Al Gore, March 16, 1995, Washington, DC.
Hoerr, D. and Weaner, L., A Prototype High-Temperature Catalytic
Oxidation Process for Mixed Waste in a Pharmaceutical Research
Laboratory, The R.W. Johnson Pharmaceutical Research Institute, Spring
House, PA, 1997.
International Commission on Radiological Protection, Radiation
Protection Principles for the Disposal of Solid Radioactive Waste, Report
No. 46, Pergamon Press, 1985.
Illinois Department of Nuclear Safety, Fees for Radioactive Materials
Licenses and Registrants, Title 32, Chapter II, Part 33 J, Final Rule, April
1,1998, Springfield, IL.
R.S. Means Company, Inc., Environmental Restoration, Unit Cost Book,
Sect. 3-19, Disposal, Kingston, MA, 1997.
R-3
-------
MLLRWA 1993
NRC 1982
NRC 1985
NRC 1987
NRC 1988
NRC 1989
NRC 1990a
NRC 1990b
NRC 1991
NRC1992a
Michigan Low-Level Radioactive Waste Authority, Storage of Low-Level
Radioactive Waste in Michigan, April 1993, Lansing, MI.
Nuclear Regulatory Commission, Final Environmental Impact Statement
on JO CFR Part 61 "Licensing Requirements for Land Disposal of
Radioactive Waste"NUREG-0945,November 1982, Washington, DC.
Nuclear Regulatory Commission, Analysis of Low-Level Wastes: Review
of Hazardous Waste Regulations and Identification of Radioactive Mixed
Wastes, Final Report, NUREG/CR-4406, December 1985, Washington,
DC.
Nuclear Regulatory Commission, Evaluation of Potential Mixed Wastes
Containing Lead, Chromium, Used Oil, or Organic Liquids, NUREG/CR-
4730, January 1987, Washington, DC.
Nuclear Regulatory Commission, Clarification by EPA of Requirements
for Facilities that Treat, Store or Dispose of Radioactive Mixed Waste to
Obtain Interim Status Pursuant to Subtitle C of the Resource Conservation
and Recovery Act (RCRA), October 24,1988, Washington, DC.
Nuclear Regulatory Commission, Guidance on the Definition and
Identification of Commercial Mixed Low-Level Radioactive Waste and
Hazardous Waste, October 4,1989, Washington, DC.
Nuclear Regulatory Commission, Characteristics of Low Level
Radioactive Waste Disposed During 1987 Through 1989, NUREG-1418,
December 1990, Washington, DC.
Nuclear Regulatory Commission, Information Notice No. 90-09, Extended
Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and
Materials Licensees, February 5,1990, Washington, DC.
Nuclear Regulatory Commission, Generic Environmental Impact
Statement for License Renewal of Nuclear Power Plants, NUREG-1437,
Draft, August 1991, Washington, DC.
Nuclear Regulatory Commission, Clarification of RCRA Hazardous Waste
Testing Requirements for Mixed Waste, Proposed, March 1992,
Washington, DC.
R-4
-------
NRC 1992b
NRC 1993a
NRC 1993b
NRC 1994a
NRC 1994b
NRC 1995
NRC 1998a
NRC 1998b
NRC 1998c
NSSI1998
Numarc 1990
Nuclear Regulatory Commission, National Profile on Commercially
Generated Low Level Radioactive Mixed Waste, NUREG/CR-5938,
December 1992, Washington, DC.
Nuclear Regulatory Commission, Final Environmental Impact Statement
to Construct and Operate a Facility to Receive, Store, and Dispose of
lle.(2) Byproduct Material Near Cliv,e Utah, NUREG-1476, August
1993, Washington, DC.
Nuclear Regulatory Commission, Revised Analyses of Decommissioning
for the Reference Pressurized Water Reactor Power Station, NUREG/CR-
5884, October 1993, Washington, DC.
Nuclear Regulatory Commission, Characterization of Class A Low-Level
Radioactive Waste 1986 Through 1990, NUREG/CR-6147, January 1994,
Washington, DC.
Nuclear Regulatory Commission, License No. SMC-1559, Docket 40-
8989, Envirocare of Utah, Inc., as amended, Aug. 30,1994, Washington,
DC.
Nuclear Regulatory Commission, Draft NRC/EPA, Low-Level Mixed
Waste Storage, August 1995, Washington, DC.
Nuclear Regulatory Commission, Information Digest, NUREG-1350, Vol.
10, November 1998, Washington, DC.
Nuclear Regulatory Commission, Code of Federal Regulations, Title 10,
Part 20, Standards for Protection Against Radiation, 1998, as amended,
Washington, DC.
Nuclear Regulatory Commission, Code of Federal Regulations, Title 10,
Part 170, Fees for Facilities, Materials, Import and Export Licenses, and
Other Regulatory Services under the Atomic Energy Act of 1954, as
amended, 1998, Washington, DC.
NNS/Sources & Services, Inc., correspondence from Mr. Robert Gallagher
and subsequent telephone conversations, May 21,1998.
Nuclear Management and Resources Council, Inc., The Management of
Mixed Low-Level Radioactive Waste in the Nuclear Power Industry,
NUMARC/NESP-006, January 1990, Washington, DC.
R-5
-------
NYSERDA 1993
OMB 1994
OTA 1989
Rice 1998
TRCR 1996
UDEQ 1998
USE 1998
US WAG 1995
New York Energy Research and Development Authority, Low-Level
Radioactive Waste Storage Study, Vol. I: Storage Capability at Generator
Sites, September 1993, Albany, NY.
Office of Management and Budget, "Guidelines and Discount Rates for
Benefit-Cost Analysis of Federal Programs," Circular No. A-94, 1994.
Office of Technology Assessment, Management Practices and Disposal
Concepts for Low-Level Radioactive Mixed Waste - A Background Report,
March 1989, Congress of the United States, Washington, DC.
Telecon with Ms. Sue Rice, Envirocare of Utah, Inc., Salt Lake City, UT,
November 24,1998.
Texas Regulations for Control of Radiation, Fees for Certificates of
Registration, Radioactive Material(s) Licenses, Emergency Planning and
Implementation, and Other Regulatory Services, Part 12, July 1,1996,
Change G-2, Austin, TX.
Utah Department of Environmental Quality, Division of Radiation
Control, Radioactive Material License, License No. UT 2300249,
Amendment No. 1, JO/22/98, Envirocare of Utah, Inc., Salt Lake City, UT.
U.S. Ecology, Inc., Richland Washington Facility Radioactive Waste
Disposal Charges, 8th Rev., May 1,1998, Olympia, WA.
Utilities Solid Waste Activities Group, Eliminating the Dual Regulation of
Mixed Waste Under RCRA and the Atomic Energy Act - Position Paper,
October 1995, Edison Electric Institute, Washington, DC.
WCS 1996
Waste Control Specialist, LLC, License Application for Near Surface Land
Disposal of Radioactive Waste, Rev.O, Dec. 1996, Andrews County, TX.
WCS 1998
Teleconference with Mr. William Dornsife, Waste Control Specialist,
LLC, June 1,16, and 30,1998, Andrews County, TX.
Weanerl997
Weaner, L. and Hoerr, D., A Practical Approach to the Destruction of
Radioactive Organic Mixtures, Sixth International Symposium on the
Synthesis and Applications of Isotopes and Isotopically Labeled
Compounds, Philadelphia, PA, Sept., 14-18,1997.
R-6
-------
Weaner 1998a International Isotope Society, correspondence of February 27, 1998, from
Dr. Larry Weaner to Mr. Albert Colli, U.S. EPA, with results of a 1996
survey of 99 universities and research institutions.
Weaner 1998b Teleconference with Dr. Larry Weaner, on behalf of the International
Isotope Society, June 11,16, and 24; July 10 and 21; and October 14,
1998.
R-7
-------
Attachment A
Summary of Disposal Site Waste Acceptance Criteria
for the
Richland, Barnwell, Envirocare, and Waste Control Specialists
Disposal Sites
-------
Attachment A-1
Summary of Waste Acceptance Criteria for Richland00
Wastes must be fully classified as perNRC and State requirements, appropriate NRC Branch
Technical Positions and license conditions on waste form classification, stability, and radionuclide
concentration averaging, including activation products, mixed fission products, transuranics
(TRU), and source and special nuclear material (SNM).
The following wastes are excluded: hazardous materials, pyrophoric or chemically explosive
materials, toxic gases, or unstable or reactive materials with water.
The following wastes are excluded or require special treatment and pre-approval before disposal:
- Waste containing oils at concentrations > 10% by weight.
Chelating agents in excess of 1% by weight.
- Animal carcasses, biological waste, ashes, pressurized gases, and ion-exchange resins.
- Wastes containing radionuclides with half-lives greater than 5 years and having total
activity levels of l^Ci/cc or greater.
Transuranics above Class A limits (10 nCi/g for alpha emitters with half-lives greater than
5 years, 2,000 nCi/g of Cm-242, and 350 nCi/g for Pu-241.
- Mixed wastes as defined in Washington State Dangerous Waste Regulations, or listed
hazardous wastes or wastes that exhibit any characteristics identified in Subparts D and C
of 40 CFR Part 261.
Listing of radionuclides, activity levels by radionuclides, amounts of SNM and source material,
and container waste volumes and weights. Compliance with NRC's App. F to 10 CFR Part 20 for
H-3, C-14, Tc-99, and 1-129 must be demonstrated.
Bulk liquid wastes are unacceptable unless treated using approved solidification or stabilization
media. All liquids must be rendered non-corrosive before treatment, with a pH limited to a range
of 4 to 11. Free standing liquids are limited to less than 0.5% by volume for treated wastes.
Waste must be buried in closed containers, with internal voids <15% by volume. Waste containers
or objects in excess of 17,500 Ibs require pre-approval. Free standing liquids are limited to less
than 1% by volume for untreated wastes.
Waste must be packaged in containers meeting DOT 7A or 17H performance specifications, high
integrity containers with certificate of compliance or otherwise authorized containers or casks.
Single waste packages are limited to not more than 100 g of U-235,60 g of U-233, or 60 g of Pu in
any combination, such that the sum-of-the-ratios is less than unity.
Single waste packages are limited to not more than 15 g in any combination of U-235, U-233, and
Pu per cubic foot by total volume, with the presence of SNM being uniformly distributed
throughout the waste volume.
In-ground separation requirements for waste packaging containing SNM:
- At least eight inches of soil or four feet of non-SNM-bearing waste in all directions from
any accumulation of packages containing SNM.
Accumulation is defined as <350 g of U-235,200 g of U-233, and 200 g of Pu in any
combination, such that the sum-of-the-ratios is less than unity.
(a) Source: U.S. Ecology, Inc. Radioactive Material License No. WN-I019-2, Amendment No. 24, May 31,
1997 expiration date, under timely renewal. New license expected in Spring of 1999.
-------
Attachment A-2
Summary of Waste Acceptance Criteria for Barnwell(a)
Wastes must be fully classified as per NRC and State requirements, appropriate NRC Branch
Technical Positions and license conditions on waste form classification, stability, and radionuclide
concentration averaging, including activation products, mixed fission products, transuranics
(TRU), and source and special nuclear material (SNM). All Class C waste shipments require pre-
approval.
Waste must exclude hazardous materials, oil and petroleum-based materials, pyrophoric and
flammable solids, toxic gases, chemically explosive materials, unstable or reactive materials with
water, or materials that may induce chemical and galvanic reactions among packaging components
or between packaging and package content.
The following wastes are excluded or require special treatment and pre-approval before disposal:
- Petroleum based oils and waste containing oils at concentration >l% by volume.
Thermex treated liquid wastes and Thermex excluded wastes (oil, paraffin, etc.)
Liquid scintillation fluids (toluene, xylene, dioxane or other similar organic fluids)
Animal carcasses, biological waste, ashes, pressurized gases, sludge, concentrates, ion-
exchange resins, PCBs, asbestos, and laboratory samples.
Wastes containing radionuclides with half-lives greater than 5 years and having total
activity levels of I jzCi/cc or greater.
Transuranics above Class A limits (10 nCi/g for alpha emitters with half-lives greater than
5 years, 2,000 nCi/g of Cm-242, and 350 nCi/g for Pu-241.
Radium present in waste and certain types of devices.
- Mixed wastes as defined in the Low-Level Waste Amendments Act of 1985, South
Carolina Waste Management Regulations, or listed hazardous wastes or wastes that
exhibit any characteristics identified in Subparts D and C of 40 CFR Part 261.
Waste containing chelating agents between 0.1% and 8.0% (by weight) must be solidified or
packaged in high integrity containers. Chelating agents must be identified by names and
percentages. Waste containing chelating agents above 8% are not acceptable.
Listing of all radionuclides, activity levels by radionuclides, amounts of SNM and source material.
and container waste volumes and weights. Compliance with NRC's App F to 10 CFR Part 20 for
the presence of H-3, C-14, Tc-99, and 1-129 must be demonstrated.
Bulk liquid wastes are unacceptable unless treated using approved solidification media. Free
standing liquids are limited to less than 0.5% by volume for treated wastes. Solidified waste must
meet the NRC Branch Technical Positions on waste form stability and solidified Class A product
requirements.
The maximum annual waste disposal volume is limited to 1.2 million ft3 (-34,000 m3). Waste
shipments above 75 ft3 and/or 40,000 Ci must be pre-approved.
Waste must be packaged in containers meeting performance specifications, high integrity
containers with certificate of compliance or otherwise authorized containers or casks. The largest
acceptable container size is 9'4" long, 7"6" wide, and 9'2" high, with a maximum weight of 54,000
Ibs. All other types of containers require pre-approval.
-------
Attachment A-2 (continued)
Summary of Waste Acceptance Criteria for Barnwell(a)
Waste must be buried in closed containers, with internal voids of less than 15% by volume. Free
standing liquids are limited to less than 1% by volume for untreated wastes.
Single waste shipments are limited to not more than 350 g of U-235,200 g of U-233, or 200 g of
Pu in any combination, such that the sum-of-the-ratios is less than unity.
The surface area of any side or projected plane of a package containing U-235, U-233, or Pu must
be greater than 2 ft2. Waste containing SNM must be packaged in 55-gallon or larger containers,
with SNM being uniformly distributed throughout the waste volume.
Shipments of SNM in excess of 100 g of U-235 in any package must defined by its level of
confidence for the stated amount of SNM. Prior notification required for any package containing
SNM in excess of 100 g of U-235 for which the stated level of confidence is less than 95%.
TRUs must be evenly distributed throughout the waste volume and incidental to total radioactivity
levels. Incidental is defined as not more than 1% of the total activity. Pu-241 is excluded from the
1% TRU activity criterion provided that it is not the only TRU in the waste. Wastes containing
only TRU or Pu-241 require special approval.
Waste with external radiation levels above 200 mR/h, radionuclide concentrations greater than 1
mCi/cc, or containing more than I Ci per shipment must be pre-approved. Class A-Unstable waste
must maintain Class A-Unstable classification when radionuclide concentrations are increased by a
factor of ten.
(a) Sources: Chem-Nuclear Systems, LLC, Radioactive Material License No. 097, Amendment No.
47, July 31,2000 expiration date. Chem-Nuclear Systems, Chem-Nuclear Consolidation Facility
Radioactive Material Acceptance Criteria, Procedure DF-AD-009, Rev. 5, Oct. 29, 1998. Chem-
Nuclear Systems Bamwell Office, Bamwell Waste Management Facility Site Disposal Criteria,
Procedure S20-AD-010, Rev. 16, Jan. 30,1998.
-------
Attachment A-3
Summary of Waste Acceptance Criteria for Envirocare"0
A. Waste prohibited For treatment and disposal
• Radioactive materials classified as Class B or C wastes and sealed sources.
• Radioactive materials not specifically approved by the license or radionuclides with average
concentrations above the limits and conditions specified in the license.
• Hazardous wastes that do not contain radioactive materials
• Bulk liquids, non-aqueous waste, or waste with an organic liquid phase.
• Waste containing up to 1% of free liquids by volume, as authorized by 10 CFR Part 61.
• Water reactive, pyrophoric, and shock sensitive materials, biological wastes, and toxic gases.
• DOT forbidden Class 1.1, 1.2, and 1.3 explosives.
• Compressed gas cylinders, unless they meet the definition of empty containers.
EPA waste codes F020, F021, F022, F023, F026, and F027.
• Utah waste codes F999 and P999.
• For hazardous waste above RCRA limits, wastes may be treated to meet LDRs, using stabilization
and solidification or macro-encapsulation using polyethylene.
B. Radiological waste acceptance criteria
• Radiological characterization and evaluation documented in a sampling plan, defining number of
samples, sample weights, composites, and analytical suite.
• Analysis conducted by a Utah certified laboratory, including gamma and alpha spectroscopy
(natural and man-made), isotopic analysis (U, Th, Ra), and presence of total-uranium, natural-U,
and depleted-U, if applicable. Submittal of pre-shipment profile samples is required.
Compliance with NRC's App. F to 10 CFR Part 20 for H-3, C-14, Tc-99, and 1-129.
• Radionuclide concentrations, as ranges and volume weighted average by waste streams and
shipments, and total activity levels and amounts of SNM and source materials.
• For waste containing multiple radionuclides, the sum-of-the-ratios must not exceed unity
• Radionuclide concentrations in a specific container or vehicle can exceed the license limits by up
to a factor of 10 as long as the overall average concentration of the entire shipment is within
authorized limits and waste in such specific containers or vehicles exceeding the limits are not
classified as Class B or C waste.
• Presence of chelating agents identified, if greater than 0.1 % by weight.
• Largest physical dimensions of eight feet by 10 inches for debris. Debris are defined as
decommissioning and routinely generated wastes, including paper, piping, rocks, glass, metals,
concrete, wood bricks, resins, sludge, tailings, residues, and protective clothing.
• Soils and soil-like materials are defined as having graded materials that will pass through a 4 inch
"grizzly" and a dry bulk density greater than 70 pounds per cubic foot (1.12 g/cm3).
• Debris limit of 10% for compactible waste and 25% for non-compactible waste.
• Containerized wastes must have a bulk density of at least 70 pounds per cubic foot (1.12 g/cm3)
Waste shipments are limited to not more than 350 g of U-235,200 g of U-233, or 200 g of Pu in
any combination, such that the sum-of-the-ratios is less than unity.
Waste SNM concentration limits of 10,000 pCi/g for Pu-238/239/240/242, 3,500 pCi/g for Pu-
241, and 500 pCi/g for U-233, 1,700 pCi/g for U-235. Pu-241 is limited to 12% of the Pu-239
content.
• Once disposed of, SNM must be homogeneously distributed throughout the waste volume, such
that concentrations in lifts do not exceed 1,000 pCi/g for Pu-239,3,500 pCi/g for Pu-241, and 770
pCi/g for U-235.
• Other relevant radionuclide limits include 60,000 pCi/g for Cs-137 and 25,000 pCi/g for Sr-90,
among 83 radionuclides. For other radionuclides not listed in the license, the limit is 500 pCi/g,
with approval.
-------
Attachment A-3 (continued)
Summary of Waste Acceptance Criteria for Envirocare00
C. Mixed waste acceptance criteria and characterization process
• Complete physical and chemical properties profiles.
• TCLP certifications for eight metals and 32 organics, plus copper and zinc.
• Hydrogen sulfide and hydrogen cyanide.
• Totals for inorganics and metals, As, Ba, Cd, Cr, Cu, Pb, Se, Ag, and Zn
• Soil pH and paint filter liquids test.
• Mixed waste treatability group, standards, exemptions, etc.
• Standard proctor test for moisture, including average and range of moisture content and no free
standing liquids.
• Total organic halides, semi and volatile organics, chelating agents, pesticides, herbicides, dioxins,
PCBs, etc.
• Waste density, average and range.
• Ignitability, reactivity, explosives, and pyrophoricity.
• Additional analyses for individual waste code LDRs.
• Sampling, including pre-shipment profile, number of samples, sample weights, and composites.
Sources: Envirocare Radioactive Material License No. UT 2300249, Amendment No. 01, expiration date of
Oct. 22,2003. Envirocare Waste Application and Submittal Package, Rev.2, Feb. 21, 1997. U.S. NRC,
Issuance of a Section 274f, Atomic Energy Act Order to Exempt Envirocare of Utah, Inc. from the
Licensing Requirements for Special Nuclear Material in Diffuse Waste that Will be Regulated by the State
of Utah, SECY-98-226, Sept. 29, 1998.
-------
Attachment A-4
Summary of Disposal Site Waste Acceptance Criteria for Waste Control Specialists LLC
A. For radioactive materials, the disposal facility is limited to receive:
• Source materials in any physical and chemical form of <0.05% by weight of U and Th
• Unrefined or unprocessed ores containing U and Th
• Rare earths metals and compounds containing <0.25% by weight of U and Th
• Products containing metal thorium alloys of less than 4% Th by weight
• Depleted uranium from aircraft or missile counter weights
• Self-luminous devices containing H-3, Kr-85, and Pr-147 manufactured under a specific license
• NORM with Ra-226 and Ra-228 at concentrations of less than 30 pCi/g or any other NORM
radionuclides at less than ISO pCi/g
• Soils and products with radionuclide concentrations within limits specified by the license
• Any other items exempted under TRCR Part 40.3 - Exemptions Source Materials, and 40 4 -
Exemptions Radioactive Materials Other than Source Material
• Requirements on packaging, waste forms, and properties and characteristics that are analogous to
those specified in NRC regulations under 10 CFR Part 61.
B. For mixed waste, the acceptance criteria include:
• Complete radiological characterization
• TCLP certifications for eight metals and 32 compounds
• Reactive sulflde and cyanide
• Boiling and flash points and pH
• Fuel content or BTU value
• Waste and material density
• Characterization for ignitability, reactivity, explosives, corrosivity, pyrophoricity,
infectious/etiological agents, putrescibility, autopolymerization, oxidizers, liquid organic
peroxides, and VOCs
• Waste must be treated prior to shipment or treated at WCS under specific arrangements
• Waste prohibited under the land-disposal restrictions of 40 CFR Part 268 are not acceptable,
unless treated under Subpart D
• Waste must be segregated and identified by compatibility groups, as required by 40 CFR Part 264
• Residual liquids must be mixed with absorbent or solidified and shown to meet the paint filter test
• All wastes must be shipped in accordance with the packaging of 40 CFR Part 264, Subpart I
• Some types of PCB wastes may be accepted for storage and disposal under specific arrangements
• Asbestos wastes may be accepted under specific arrangements
-------
Attachment B
Listing of RCRA Hazardous Waste Management Options
in States with Commercial Subtitle C Disposal Facilities
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities00
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwell/underground injection
Alabama
307.4
42
180,731
9
Percentage
of Quantity
O.I
2.0
0.0
0.0
15.1
43.4
26.8
3.8
8.7
Percentage
of Facility
22.2
11.1
11.1
11.1
11 1
444
II. 1
22.2
11.1
California
288.0
136
440,479
23
Percentage
of Quantity
3.2
8.3
2.8
1.9
4.2
6.4
559
0.5
0.7
O.I
2.9
11.8
1.4
Percentage
of Facility
8.7
304
13.0
13.0
8.7
21.7
21.7
13.0
4.3
4.3
21.7
47.8
17.4
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997).
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities00 (cont.)
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwell/underground injection
Other
Colorado
102.5
36
42,137
2
Percentage
of Quantity
1.6
00
87.8
0.0
10.6
Percentage
of Facility
50.0
50.0
50.0
50.0
50.0
Idaho
539.6
10
33,262
2
Percentage
of Quantity
65.3
2.4
323
Percentage
of Facility
50.0
1000
50.0
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997)
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities0" (cont.)
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwell/underground injection
Other
Illinois
340.9
107
324,810
16
Percentage
of Quantity
0.5
13.5
0.0
8.5
O.I
15.7
27.3
1.2
14.0
126
6.5
Percentage
of Facility
18.8
18.8
18.8
12.5
18.8
37.5
31.3
6.3
6.3
31.3
6.3
Indiana
691.1
76
575,587
15
Percentage
of Quantity
24.1
2.0
0.0
22.8
5.0
7.1
0.0
14.4
6.0
18.5
Percentage
of Facility
20.0
20.0
6.7
20.0
26.7
6.7
6.7
13.3
20.0
20.0
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997)
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities00 (cont.)
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwel I/underground injection
Other
Lousiana
519.8
49
285,748
17
Percentage
of Quantity
0.1
6.9
14.6
27.3
33
00
1.5
35.8
10.5
Percentage
of Facility
11.8
11.8
35.3
11.8
5.9
5.9
29.4
11.8
11 8
Michigan
1,218.8
112
1,122,644
16
Percentage
of Quantity
0.0
2.6
0.4
0.7
2.3
62.7
2.4
0.2
3.0
0.1
12.6
1.2
12.0
Percentage
of Facility
125
12.5
6.3
18.8
6.3
18.8
31.3
18.8
12.5
6.3
12.5
375
12.5
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997).
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities00 (cont.)
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwell/underground injection
Other
Nevada
95.7
15
650,010
2
Percentage
of Quantity
0.0
6.9
0.1
14.6
78.4
00
Percentage
of Facility
50.0
50.0
50.0
50.0
100.0
50.0
New York
322.3
70
206,931
11
Percentage
of Quantity
30.2
0.1
0.9
0.0
0.8
0.5
13.9
0.3
41.3
0.7
11.3
Percentage
of Facility
18.2
9.1
36.4
9.1
18.2
18.2
9.1
9.1
9.1
27.3
9.1
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997).
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities00 (cont.)
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwell/underground injection
Other
Ohio
509.9
74
671,205
24
Percentage
of Quantity
0.0
8.9
0.6
14.5
5.9
18.9
0.1
0.0
6.5
O.I
5.9
6.6
15.9
16.1
Percentage
of Facility
8.3
25.0
4.2
12.5
4.2
50.0
8.3
4.2
8.3
8.3
20.8
25.0
8.3
4.2
Oklahoma
131.4
31
135,352
7
Percentage
of Quantity
0.4
0.1
0.0
9.7
3.4
0.8
56.6
0.0
25.8
3.3
Percentage
of Facility
14.3
14.3
14.3
28.6
14.3
14.3
42.9
14.3
14.3
14.3
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997).
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities00 (cont.)
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwell/underground injection
Other
Oregon
131.8
11
130,676
1
Percentage
of Quantity
0.0
O.I
99.9
16.1
00
Percentage
of Facility
100.0
100.0
100.0
4.2
100.0
South Carolina
180.3
26
185,348
7
Percentage
of Quantity
10.8
0.1
41.9
5.7
41.6
Percentage
of Facility
42.9
28.6
42.9
14.3
143
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997).
-------
Attachment B. RCRA Waste Hazardous Waste Management Options in States with Subtitle C Disposal Facilities'" (cont.)
STATE
Total quantity of RCRA
waste managed (thousand tons)
Number of RCRA TSD facilities
Quantity managed from offsite (tons)
Number of facilities
Management Method
Metal recovery (reuse)
Solvent recovery
Other recovery
Incineration
Energy recovery (as fuel)
Fuel blending
Aqueous inorganic treatment
Aqueous organic treatment
Aqueous organic and inorganic treatment
Sludge treatment
Stabilization
Other treatment
Landfill
Land treatment/application/farming
Deepwell/underground injection
Other
Texas
1,728.1
192
939,799
62
Percentage
of Quantity
5.7
3.4
0.6
14.7
18.2
7.1
0.0
11.1
0.0
00
1.5
1.2
1.2
0.0
352
Percentage
of Facility
17.7
19.4
8.1
16.1
21.0
22.6
3.2
12.9
3.2
1.6
4.8
35.5
9.7
4.8
11.3
Utah
95.3
21
80,745
8
Percentage
of Quantity
45.3
20.5
1.3
32.9
Percentage
of Facility
250
25.0
50.0
25.0
(a) The National Biennial RCRA Hazardous Waste Report (Based on 1995 Data) - State Detail Analysis (EPA 530-R-97-022d, August 1997).
------- |