EPA402-R-96-015
August 1996
Profile and Management Options for EPA
Laboratory Generated Mixed Waste
Center for Remediation Technology and Tools
Radiation Protection Division
Office of Radiation and Indoor Air
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Prepared under:
Contract No.
68-D2-0156
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DISCLAIMS?
This document has been reviewed and approved for publication by the U.S. Environmental
Protection Agency. Approval does not signify that the contacts necessarily reflect the views and
policies of the Environmental Protection Agency, nor does the mention of trade names or
commercial products and services constitute endorsement or recommendation for use.
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PRffACE
The high costs of mixed waste management and the limited treatment, storage, and disposal
options for mixed waste prompted EPA laboratory staff to approach EPA headquarters staff to
investigate mixed waste generated from laboratory procedures. Mixed waste is composed of
radioactive waste defined under the Atomic Energy Act (AEA) and hazardous waste is defined
under the Resource Conservation and Recovery Act (RCRA). Currently there are only four
mixed waste treatment, storage, or disposal facilities (TSDFs) in the United States accepting
commercially generated mixed waste. No treatment or disposal options exist for certain classes
of mixed waste. Indefinite storage is the only option for mixed waste with no treatment or
disposal capacity.
The U.S. Environmental Protection Agency (EPA)'s Office of Radiation and Indoor Air (ORIA),
Office of Solid Waste (OSW), and Office of Administration/Safety, Health, and Environmental
Management Division (SHEMD) responded to this request and created a cross-office team to
investigate the issue of mixed waste generated from EPA laboratories. This report is designed to
aid EPA in defining future low-level and mixed waste guidance for EPA laboratories.
The first step in this investigation was to quantify and characterize the low-level radioactive
waste and mixed waste generated by EPA laboratories. The second step of the project was to
identify and examine the mixed waste management options and technologies applicable to EPA
laboratories including pollution prevention, recycling, waste segregation, and treatment.
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ACKNOWLEDGMENTS
Carey A. Johnston of ORIA's Remedial Technology and Tools Center is the EPA Work
Assignment Manager for this report. Principle assistance was provided by Neal W. Bonner,
Brian Hayduk, and Barrett J. Riordan of Jack Faucett Associates under EPA Contract Number
68-D2-0156. EPA/ORIA wishes to thank the following individuals for their technical assistance
and review comments on the drafts of this report.
Peter Reinhardt, University of Wisconsin, Madison
Peter C. Ashbrook, University of Illinois at Urbana-Champaign
Captain Ed Rau, NIH, Bethesda, Maryland
Terry Devine, Conference of Radiation Control Program Directors, Frankfort, Kentucky
Frank Wilkes, EPA NHEERL, Gulf Breeze, Florida
Todd Baker, EPA ORD Safety Office, RTP, North Carolina
Zeola Smith, EPA NAREL, Montgomery, Alabama
Jeff Davidson, EPA OA/SHEMD
Renee DuFault, EPA OA/SHEMD
Nancy Hunt, EPA OSW/PSPD
Vern Meyers, EPA OSW/PSPD
Jeff Graines, EPA OSW/PSPD
Rich Lashier, EPA OSW/HWID
Irma McKnight, ORIA Product Review Officer
In addition, the following staff from ORIA's Radiation Protection Division assisted in the
development and review of this document:
Nicholas Lailas, Director, RTTC
Michael Boyd, RTTC
Ron Wilhelm, RTTC
Ambika Bathija, Center for Waste Management
IV
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ABSTRACT
This report identifies and examines the mixed waste management options and technologies
applicable to EPA laboratories including pollution prevention, recycling, waste segregation, and
treatment. The results from a 3-year survey of EPA laboratory produced mixed and low-level
wastes as relevant information from the technical literature, are presented in this report as well.
Ultimately, this report is designed to aid EPA in defining future low-level and mixed waste
guidance for EPA laboratories.
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CONTBJTS
DISCLAIMER ii
PREFACE iii
ACKNOWLEDGMENTS iv
ABSTRACT v
LIST OF TABLES ix
LIST OF FIGURES x
ACRONYMS AND ABBREVIATIONS xi
1. INTRODUCTION AND OVERVIEW 1-1
2. AN INTEGRATED APPROACH TO MIXED WASTE MANAGEMENT 2-1
2.1 Pollution Prevention and Waste Minimization in Laboratories 2-1
2.2 DOE's National Low-Level Waste Management Program Study 2-2
2.3 The Idaho National Engineering Laboratory Study 2-3
2.4 The Role of Pollution Prevention 2-6
2.5 Laboratory-wide Pollution Prevention Programs 2-7
2.6 Summary of Section 2 2-15
3 SUMMARY OF MIXED WASTE MANAGEMENT OPTIONS 3-1
3.1 Regulatory-based Options 3-1
3.1.1 Determination of Equivalent Treatment 3-1
3.1.2 Regulatory Flexibility 3-1
3.2 Source Reduction/Avoidance Options 3-4
3.2.1 Source Reduction 3-4
3.2.2 Substitution/Use of Biodegradable Solvents 3-4
3.2.3 Waste Segregation and Separation 3-7
3.2.4 Process Modifications 3-9
3.2.5 Recycling 3-10
3.2.6 Storage for Decay 3-11
3.2.7 Administrative Controls/Incentives/Accountability Standards 3-13
3.3 Treatment Options 3-14
3.3.1 Treatment Options Applicable to LSC 3-15
3.3.2 Treatment for HPLC Wastes 3-18
4 PROFILES OF MIXED WASTE TREATMENT INDUSTRIES 4-1
VI
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CONTENTS - (Continued)
Page
4.1 DSSI 4-1
4.2 Envirocare 4-3
4.3 Perma-Fix (PFF) 4-3
4.4 NSSI 4-3
4.5 SEG 4-3
4.6 MMT 4-4
4.7 Comparison of Treatment Available Versus Demand Available 4-4
5 CONCLUSIONS, RECOMMENDATIONS, AND SUGGESTIONS FOR
FURTHER RESEARCH 5-1
6 SOURCES CONSULTED 6-1
APPENDIX A: RESULTS OF EPA LABORATORY SURVEY: DATA SUMMARY
REPORT A-l
A.I INTRODUCTION AND OVERVIEW A-l
A.2 PROFILES OF NINE EPA LABORATORIES GENERATING
MW OR LLRW A-2
A.3 OVERVIEW OF LOW-LEVEL RADIOACTIVE WASTE
GENERATED AT EPA LABORATORIES A-5
A.3.1 LLRW Deemed Undisposable A-10
A.3.2 Cost Information for Treatment and Disposal of LLRW .... A-10
A.4 DETAILED MIXED WASTE PROFILE OF EPA
LABORATORIES A-l 1
A.4.1 Analysis of Hazardous Component of Mixed Waste
Generated A-15
A.4.2 Analysis of Radioactive Component of Mixed Waste
Generated A-17
A.4.3 Mixed Waste in Storage A-17
A.4.4 Waste Management Options for EPA Laboratory Mixed
Waste A-18
A.4.5 Profile of Undisposable Mixed Waste A-19
A.4.6 Cost Information A-20
A.5 COMPARISON WITH OTHER MIXED WASTE SURVEYS .... A-21
A.6 CONCLUSION A-23
APPENDIX B: SURVEY INSTRUMENT DISTRIBUTED TO
EPA LABORATORIES B-l
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CO N TBJ TS - (Conti nued)
Page
APPENDIX C: COMMONLY GENERATED RADIONUCLIDES
AT EPA LABORATORIES C-l
APPENDIX D: RESEARCH APPROACH D-l
APPENDIX E: RESULTS OF ORNL SURVEY E-l
APPENDIX F: OVERVIEW OF OTHER MW/LLRW SURVEYS,
DATABASES, AND STATE LOW-LEVEL
RADIOACTIVE WASTE DISPOSAL EFFORTS F-l
Vlll
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LIST OF TABLES
Tables Page
1 Commercial Facilities Overview 4-2
A-l Summary of the MW and LLRW Volumes for EPA Laboratories:
1992-1994 A-2
A-2 Volumes of LLRW for Each EPA Laboratory Grouped by LLW#: 1992-1994 A-6
A-3 LLW Management Option Volume Grouped by EPA Laboratory:
1992-1994 A-7
A-4 Volume of Radionuclide Groupings for EPA Laboratory Generated LLRW:
1992-1994 A-9
A-5 Cost Information for Disposal Facilities: LLRW A-10
A-6 Volume (ft3) of MW Grouped by LLW Stream No.: 1992-1994 A-13
A-7 Volume (ft3) of MW Grouped by Process: 1992-1994 A-14
A-8 Volume and Activity of Grouped Hazardous Waste Components of MW: 1992
1994 Totals A-15
A-9 Volume Percent of Waste with Chemicals Present Versus Waste Generating
Process A-16
A-10 Volume Percent of Waste Using RCRA HW# Versus Waste Generating Process .. A-16
A-l 1 Volume and Activity of Grouped Radioactive Waste Components of MW: 1992-
1994 Totals A-17
A-12 MW Management Option Volume (ft3): 1992-1994 A-19
A-13 Hazardous and Chemical Properties of Undisposable MW Generated at EPA
Laboratories: 1992-1994 A-20
A-14 Cost Information for Disposal Facilities: Mixed Waste A-20
A-15 EPA/NRC 1990 National Profile Mixed Waste Survey Results: Liquid
Scintillation Fluid Production and its Percentage in Generator's
Mixed Waste A-21
A-16 Top Three Mixed Waste Processes at NIH (not including LSF) over the 1989 to
June 1993 Time Period A-22
D-l Framework for Phone Survey Administered to MW Research Staff D-l
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LIST OF FIGURES
Figures Page
1 Mixed Waste Management Schematic 2-4,2-5
2 Mixed Waste Minimization Strategy for Biomedical Waste at the Rockefeller
University 2-10
3 General Volume Reduction Methods for Laboratories 3-5
4 Multi-Color Bag Volume Reduction System 3-8
5 A Hierarchy of Waste Minimization 5-2
A-l EPA LLRW/MW Production A-3
A-2 LLRW Production A-3
A-3 MW Production A-4
A-4 Major LLW# Volumes A-5
A-5 LLW Management Option Volumes A-8
A-6 MW Volume by LLW# A-12
A-7 MW Volume by Process A-12
A-8 MW Management Option Volume A-18
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ACRONYMSAND ABBRB/IATIONS
AEA
BOAT
°C
CESQG
CFC
CFR
ComEd
CRL
CWRU
DIS
DOE
DSSI
EHS
EPA
ft3
GED-Gulf
GL
HPLC
HW
INEL
kg
LLRW
LSC
m3
MFRL
MMT
MW
MWIR
NAREL
NERL-LV
NERL-RTP
NGA
NHEERL-AED
NHEERL-MED
NHEERL-WED
NHEERL-RTP
NIH
Atomic Energy Act
best demonstrated available technology
Centigrade (in degrees)
conditionally exempt small quantity generator
chlorinated fluorocarbons
Code of Federal Regulations
Commonwealth Edison
Central Regional Laboratory, Chicago, IL
Case Western Reserve University
decay-in-storage
U.S. Department of Energy
Diversified Scientific Services, Inc.
environmental, health, and safety
U.S. Environmental Protection Agency
cubic feet
Gulf Ecology Division, Gulf Breeze, FL (EPA)
Geochemistry Laboratory
high-performance liquid chromatography counting
hazardous waste
Idaho National Engineering Laboratory
kilograms
low-level radioactive waste
liquid scintillation counting
cubic meters
Manufacturing and Fabrication Repair Laboratory
Molten Metal Technology, Inc.
mixed waste
Mixed Waste Inventory Report
National Air and Radiation Environmental Laboratory,
Montgomery, AL (EPA)
National Exposure Research Laboratory, Las Vegas, NV (EPA)
National Exposure Research Laboratory, Research Triangle Park,
NC (EPA)
National Governors Association
National Health & Environmental Effects Research Laboratory,
Atlantic Ecology Division, Narragansett, RI (EPA)
National Health & Environmental Effects Research Laboratory,
Mid-Continent Ecology Division, Duluth, MN (EPA)
National Health & Environmental Effects Research Laboratory,
Western Ecology Division, Corvallis, OR (EPA)
National Health & Environmental Effects Research Laboratory,
Research Triangle Park, NC (EPA)
National Institutes of Health
XI
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ACRONYMSAND ABBRB/IATIONS(contd.)
NLLWMP
NPDES
NRC
NRMRL-Breidenbach
NRMRL-Kerr
NRMRL-RTP
NSSI
NTIS
ORIA
ORNL
ORS
OSW
P2
PFF
PPOA
RCRA
RSO
RTP
SEG
SHEMD
SNL
TRU
TSDF
UIUC
VRF
WREAFS
National Low-Level Waste Management Program
National Pollutant Discharge Elimination System
Nuclear Regulatory Commission
National Risk Management Research Laboratory, A.W.
Breidenbach Environmental Research Center, Cincinnati, OH
(EPA)
National Risk Management Research Laboratory, Robert S. Kerr
Environmental Research Center, Ada, OK (EPA)
National Risk Management Research Laboratory, Research
Triangle Park, NC (EPA)
Nuclear Sources and Services, Inc.
National Technical Information Service
Office of Radiation and Indoor Air (EPA)
Oak Ridge National Laboratory
Office of Radiological Safety, Texas A&M University
Office of Solid Waste (EPA)
Pollution Prevention
Perma-Fix of Florida, Inc.
Pollution Prevention Opportunity Assessment
Resource Conservation and Recovery Act
radiation safety officer
Research Triangle Park, NC (EPA)
Scientific Ecology Group, Inc.
Safety, Health, and Environmental Management Division (EPA)
Sandia National Laboratories
transuranic
treatment, storage, and disposal facility
University of Illinois at Urbana-Champaign
volume reduction factor
Waste Reduction Evaluations at Federal Sites
millicuries per gram
xn
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SECTION 1: INTRODUCTION AND OVERVIEW
Mixed waste is subject to a dual regulatory framework under the Resource Conservation and
Recovery Act (RCRA), as administered by the U.S. Environmental Protection Agency (EPA),
and the Atomic Energy Act (AEA), as administered by the U.S. Nuclear Regulatory Commission
(NRC). Generators of mixed waste and the offsite facilities which manage this waste must
satisfy both NRC, which regulates the radioactive component, and EPA, which regulates the
hazardous component. Due to the complex regulatory framework and the lack of approved
treatment and disposal options for these wastes, mixed waste management is a difficult
responsibility.
The principal focus of this report is to identify and examine the wide spectrum of waste
management options and technologies applicable to EPA research facilities including pollution
prevention, recycling, waste segregation, and treatment. Ultimately, this report is designed to aid
EPA in defining future guidance for these laboratories. Relevant information from the technical
literature is presented in this report as a guide for future EPA decisions concerning laboratory
generated low-level and mixed waste.
A survey of 11 EPA laboratories and research facilities was conducted to tabulate the volumes of
mixed waste (MW) and low-level radioactive waste (LLRW) generated in the 1992-1994 time
period. The results of the survey indicate that the generation of mixed waste accounted for 20.6
percent of the total MW and LLRW generated in the 1992-1994 time period. The total volume
of mixed waste generated by the 11 EPA facilities totaled 831.16 ft3 over this 3-year time period.
It was discovered that four radionuclides, 14C, 3H, 32P, and 35S, comprised a substantial portion of
the total volume of LLRW and MW generated in 1992-1994. A detailed analysis of the results of
the survey is attached as Appendix A entitled "Data Summary Report." Appendix B provides a
copy of the survey instrument along with a brief discussion of the survey methodology. A list of
the most commonly used radionuclides generated from various research activities at the EPA
laboratories is in Appendix C.
This Profile Report of EPA laboratory generated mixed waste serves to fulfill the following
objectives1:
• To review the available literature that examines the state-of-the-art technologies
that contribute to improved management of mixed wastes. Emphasis is centered
on analysis techniques and waste segregation, pollution prevention, disposal or
storage, recycling, and treatment options;
• To highlight the applicability of various waste management options based on the
results of the survey of EPA laboratories and identify, to the extent practicable,
!A description of the research approach employed to develop this report is included as
Appendix D.
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the regulatory justifications for these options;
• To outline a suggested integrated waste management framework based on current
research and documentation for improving EPA laboratory practices and waste
minimization efforts for LLRW and MW;
• To provide a succinct profile of the mixed waste treatment facilities and address
treatment availability within the context of the capacity demanded by EPA
facilities; and
• To provide recommendations and suggestions specific to EPA research facilities
as they relate to improved waste management efforts based on the available
literature and surveys of laboratory radiation safety officers (RSOs), academics,
and researchers.
The survey of EPA facilities revealed that two waste generating processes were responsible for
the production of virtually all of the mixed waste at these laboratories: high-performance liquid
chromatography (HPLC) counting and liquid scintillation counting (LSC). Two prior survey
analysis efforts conducted by the Oak Ridge National Laboratory (ORNL) and the Department of
Energy's National Low-Level Waste Management Program (NLLWMP) revealed that the waste
constituents and generating processes of the research laboratories covered are similar to those of
EPA. Summaries of the survey results from these two efforts are provided in the "Data Summary
Report" in Appendix A. Due to the comprehensive scope of the ORNL study (a national profile
on commercially generated mixed waste), Appendix E provides more details of the mixed waste
generated by these institutions. Additional material that highlights the results of other mixed
waste surveys and databases is contained in Appendix F.
A review of the available literature reveals that limited attention has been devoted to the analysis
of specific mixed waste streams. While there is a modest amount of literature focusing on
management options related to liquid scintillation counting procedures due to its importance in
the scientific community, the research is overwhelmingly aimed at the efficacy of prudent
laboratory practices and approaches to improved waste minimization. In fact, there exists
considerable acknowledgment of the many challenges facing laboratory directors and
Environmental, Health, and Safety (EHS) staff associated with minimization of waste generated
from liquid scintillation counting procedures. This discussion is of critical importance for the
RSOs and research staff of EPA laboratories. With this in mind, this report addresses, to the
extent practicable, the waste management options specific to LSC and HPLC. Special attention
is given to the laboratory practices that are conducive to waste minimization and cost-effective
waste management. Although the focus of this report is to address the issues associated with
mixed waste, low-level radioactive waste will be examined where applicable.
The options summary report is organized into six sections. Following this introduction, Section
2 presents an integrated approach to the management of mixed waste and its applicability to EPA
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research facilities. Section 3 outlines the various waste minimization techniques in isolation,
followed by a brief profile of the mixed waste treatment facilities and reported capacity in
Section 4. Section 5 provides an enumeration of conclusions and recommendations based on the
literature collected. Finally, in Section 6, a list of the sources consulted for performing this
report is presented.
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SECTION 2: AN INTEGRATED APPROACH TO MIXED WASTE MANAGEMENT
A review of the compiled literature pointed to several important themes. Most notably,
considerable emphasis was placed on the need to include several components (administrative,
regulatory, training, and recording considerations as well as treatment, minimization, and
prevention) of waste management into an integrated framework. Individual management options
taken in isolation may not be as effective as a more comprehensive approach to waste
management. The literature suggests that a goal-based waste management plan based on prudent
practices should be the objective of any mixed waste management program. Moreover, the waste
minimization program should have top-level management support and direction. Three studies
are outlined below that provide constructive frameworks for examining mixed waste
management from this conceptualized integrated approach.
2.1 POLLUTION PREVENTION AND WASTE MINIMIZATION IN
LABORATORIES
A thorough guide for laboratory directors interested in incorporating pollution prevention
practices in laboratory waste management procedures is Pollution Prevention and Waste
Minimization in Laboratories, edited by Peter A. Reinhardt, K. Leigh Leonard, and Peter C.
Ashbrook. This compilation is designed to provide a review of the state-of-the-art practices and
procedures that promote safety and facilitate the implementation of a waste minimization or
pollution prevention program. The audience for this publication is general in scope and includes
professionals in academia, medicine, commercial research, as well as federal officials. Individual
chapters, however, detail specific cases.
This compilation by Reinhardt et al. is divided into seven sections. The primary topics addressed
include:
• an intuitive, conceptual, and legal appeal for pollution prevention including an
enumeration of the basic concepts in solving waste minimization problems;
• pollution prevention approaches by media, source, and type;
• pollution prevention and institutional issues (policy, administrative, liability
concerns);
• the role that individual laboratories and organizations play in promoting pollution
prevention;
• applications of successful pollution prevention programs; and
• the future of waste minimization in the laboratory.
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Of particular significance is the discussion of waste minimization in medical and other
laboratories. One chapter details the radioactive waste management program at University of
Illinois at Urbana-Champaign (UIUC) where LSC waste is the largest single category of solvent
waste. Despite the availability of biodegradable cocktails, the University has continued to burn
the LSC waste as a fuel supplement at its own power plant due to the realization of cost savings.
Since only small amounts are burned, the practice is exempt from RCRA Part B permit
requirements and the radioisotopes at the point of release are within specified limits. In
connection with requiring researchers to segregate waste by isotopes, the Radiation Safety staff
implemented a number of procedures to reduce the amount of radioactive waste generated. One
of the most significant policies was the decision to require researchers to decontaminate
scintillation cocktail vials instead of disposing of them as radioactive waste.
2.2 DOE's NATIONAL LOW-LEVEL WASTE MANAGEMENT PROGRAM STUDY
Two complementary reports that paralleled this study, the Department of Energy's (DOE)
National Low-Level Waste Management Program's Mixed Waste Minimization and Treatment
(August 1995) and Mixed Waste Stream Analysis (August 1994) present the methodology and
findings associated with a technical analysis conducted on the mixed waste streams generated by
the National Institutes of Health (NIH). The reports characterize the many biomedical waste
streams generated and combine the data for similar process categories. Possible waste
minimization and treatment methodologies are suggested based on NIH personnel interviews and
waste minimization guidelines. For the purposes of this report, considerable focus was devoted
to the two mixed waste generating processes present at the EPA laboratories, high-performance
liquid chromatography (HPLC) scintillation counting and liquid scintillation counting (LSC).
Over 4x/2 years of operation from 1989 to June 1993, HPLC scintillation counting accounted for
almost 26 percent of the 64,146 liters of nonliquid scintillation cocktail mixed waste generated at
NIH. Over the same period, the NIH shipped a total of 696,361 liters of liquid scintillation vials.
There were limited suggestions on how to reduce the volume of HPLC scintillation counting
fluids. It is cautiously stated that some manufacturers of scintillation fluids claim that EPA has
performed aquatic toxicity testing on their fluids and approved them for drain disposal, subject to
state and local discharge permits. Another possible method to reduce HPLC volume is to pay
careful attention to the buffer flow rates during the running of an HPLC procedure. Higher than
normal flow rates can increase the volume of LLMW generated without increasing research
benefits.
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2.3 THE IDAHO NATIONAL ENGINEERING LABORATORY STUDY
In addressing the vexing issue of identifying disposal options for commercially generated mixed
waste, this report endeavored to answer the question: "Which mixed waste has no treatment
option?" Performed by the Idaho National Engineering Laboratory, Mixed Waste Management
Options: 1995 Update, which updates a December 1991 study, estimates the volume of mixed
waste requiring jointly regulated disposal (under the Atomic Energy Act (AEA) and the Resource
Conversation and Recovery Act (RCRA)) based on the National Profile study and presents a
methodological approach for generators to use when deciding how to manage their mixed waste.
It is estimated that 118m3 of mixed waste per year cannot be managed out of existence given
current mixed waste treatment, storage, and disposal options. All but 208 millicuries in 1.69 m3
of the LSC waste are considered to be treatable using commercially available treatment options.
The Mixed Waste Options report presents a useful categorization of the regulatory requirements,
commercially generated mixed waste streams, and management options. Concerning LSC waste,
a description of the purpose of the procedure, waste disposal issues, and waste minimization
issues are provided. An attached table details the LSC waste generated and stored in 1990. It is
stated that according to 10 CFR 20.2005, LSC fluid wastes can be disposed of without regard to
the radioactive component of the waste if they contain only 3H or 14C with a total concentration
of 0.05 microcurie per gram of scintillation liquid. In those cases where radionuclides other than
3H or 14C are present in the fluid, the exemption may not apply.
For concentrations of nuclides above 0.05 microcurie per gram, waste aggregation is usually
employed to reduce the concentration below the allowable level. The primary waste
minimization option discussed involves substitution of "aqueous" or "biodegradable" compounds
for the more hazardous RCRA-regulated substances. The NIH has implemented a systematic
waste aggregation system coordinated through a central waste management facility that involves
collecting waste from similar processes and waste constituents. State and local regulatory
frameworks dictate the limitations or standards concerning waste aggregation. The NIH, for
example, promulgates internal requirements that determine the limitations on waste aggregation.
Waste aggregation, however, does not imply dilution. Federal Regulation 40 CFR 268.3
prohibits dilution as a substitute for adequate treatment "to achieve compliance with Subpart D
of [40 CFR 268], to circumvent the effective date of a prohibition in Subpart C of [40 CFR 268],
to otherwise avoid a prohibition in Subpart C of [40 CFR 268], or to circumvent a land disposal
prohibition imposed by RCRA section 3004."
The report includes a useful mixed waste management schematic that is reproduced in Figure 1.
Although some of these steps are not applicable for EPA laboratories, the framework and process
flow is conceptually useful. A more detailed discussion of the management options presented in
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Figure 1: Mixed Waste Management Schematic
F o r E ac h M ix ed W a ste Co d e/C la ss
n All Mixed Waste
Eliminated Through
Product Substitution or
Process Change?
n the Radioactiv
Component of the Waste
be Managed Without
Regard to Radioactivity
10 CFR 20.3?
All Radionucli
in the Package Have
a Half-life of <1 Yr
or 5-yr Decay?
Identify Product/Processes
Compare to Expected Costfor Disposal
Manage According to Hazardous
Waste Component Only
Manage According to Hazardous Waste
Component Onlys. Calculate Cost of
Storage for Decay. Compare to
Expected Costfor Disposal
Note: Storage Facility Must be Jointly Regulated
Note: Storage >1 Yr is Subject to RCRA LDR
Standards
Continued on Next Page
Source: Mixed Waste Managment Options: 1995 Update, May 1995
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Figure 1 (continued): Mixed Waste Management Schematic
From Previous Page
an it b
llminated
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4CN3FR26H"
IsWade Hazardous
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or is it Listed Only
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IsT/eatabiljty
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Obtained, Facility Must Meet Minimum Technology Requirements
Unless No Migration Variance Also Granted
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this report is provided in the next section.
Of special significance is the presentation of a three-tiered cost-effectiveness mixed waste
management hierarchy: avoidance, treatment, and regulatory. Management options that fall
under the rubric of the highest level, avoidance, will result in the most substantial cost savings.
RSOs and laboratory staff need to be consciously aware of the importance of this framework and
the substantial cost savings realized by focusing waste management efforts at the highest level of
this hierarchy.
It is clear that the types of mixed waste generated at EPA facilities are analogous to those of
commercial facilities and NIH laboratories. Waste generated from LSC practices comprised a
substantial volume of the total mixed waste in both EPA laboratories and the Oak Ridge National
Laboratory survey mentioned above. The principal radionuclides generated from commercial
sources, the NIH, and the EPA laboratories in their respective time periods of study were
strikingly similar.
2.4 THE ROLE OF POLLUTION PREVENTION
An integrated approach to laboratory mixed waste management necessarily implies pollution
prevention. The term "pollution prevention" has served as an all-encompassing term for any
technique, process, or procedure that minimizes waste. Broadly defined, pollution prevention
refers to activities that keep pollutants from being created in any media. There are many strong
benefits to pollution prevention including safety, waste minimization, efficiency, regulatory
compliance, reduction in liability, and cost reduction. Pollution prevention techniques are a
critical component of prudent laboratory practices and have been incorporated into many
laboratory waste management procedures. A summary of the materials that address pollution
prevention at a laboratory or programmatic level is provided below.
A cooperative program between the federal community and EPA that actively pursues pollution
prevention research and enhance its implementation through technology transfer is EPA's Waste
Reduction Evaluations at Federal Sites (WREAFS). Two documented cases of the success of
this program include work conducted at the Geochemistry Laboratory (GL), which uses a
scintillation counter, and the Manufacturing and Fabrication Repair Laboratory (MFRL) at the
Sandia National Laboratories (SNL) and the Fort Carson Evans Community Hospital Histology
Laboratory in Colorado Springs, CO.
The application of the program at SNL represented a systematic evaluation of project design and
implementation, materials management, and recycling/reuse options. This approach is labeled a
pollution prevention opportunity assessment (PPOA). The conclusions and recommendations
derived from this pollution prevention assessment include the need to:
• incorporate pollution prevention into research proposals;
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• continuously update the training and education of staff;
• employ a central purchasing/distribution system;
• establish an escrowed closeout money account which sets aside money at the
beginning of a project; and
• focus pollution prevention research on site-wide pollution prevention efforts, as
opposed to isolated attempts; these efforts represent the largest potential gain in
waste minimization.
Research at the Evans Community Hospital, which produces mixed waste includes tissue
processing and slide staining. The PPOA revealed that solvent recovery can be a cost-effective
and attractive pollution prevention option to implement. This approach was proven effective for
xylene, ethanol, methanol, and other histology solvents. Volume reduction and substitution were
also considered. An economic feasibility analysis revealed that the payback period for
implementing a solvent recovery program was as low as 11 months.
Distillation as a pollution prevention technique involves heating substances to their boiling point
and collecting the vapor that rises into the condensing portion of the distillation column. Two
documented solvent recovery techniques to enhance the efficiency of solvent separation include
spinning band distillation, which uses a motor driven Teflon band in the distillation column, and
a method that utilizes an atomized plating technique. The one disadvantage with these
approaches is the inability of these methods to separate pure ethanol from ethanol and xylene
mixtures.
These approaches, in microcosm, maybe applicable to EPA laboratories. Researchers at the
Evans Community Hospital concluded that those approaches with the greatest opportunity for
pollution prevention should be considered first. This pollution prevention hierarchy is presented
in Section 5 within the context of a suggested framework for a mixed waste management
program. These cooperative approaches to pollution prevention foster a more proactive strategy
to identify prudent practices and facilitates a more expeditious dissemination of these practices to
other laboratories.
Regulatory complexity and the lack of options for treatment of some mixed waste streams
present notable concern. The importance of incorporating pollution prevention options in
laboratory practices is instrumental to efficient waste management. Specific approaches are
discussed below.
2.5 LABORATORY-WIDE POLLUTION PREVENTION PROGRAMS
Pollution prevention approaches employed at the laboratory level that can be categorized under
the integrated waste management approach are outlined below. These laboratory-wide
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approaches address multiple aspects of waste management and are especially pertinent to EPA
mixed waste generating facilities.
Lewandowski, Joseph J.; Moghissi, A. Alan. "Management of Mixed Waste at a Teaching,
Research, and Health Care Facility," Proceedings of the 3rd Biennial Symposium of
Mixed Waste, Baltimore, MD, August 1995.
This report outlines a strategy to manage the generation and disposal of mixed waste generated
at Temple University. Developed in 1993, this strategy is based on five principles relating to
legal, technological, and budgetary considerations.
The first stage of this strategy involves separating waste into one of eight categories including
waste classified as onsite decay, mixed waste, decay-in-storage, and biological waste. The
investigators are required to separate their waste into these eight categories. Despite initial
concerns of placing undue burdens on researchers, no more than two different waste containers
for the separation of waste were required by any one researcher. The second phase of the strategy
entails further separations of waste into manageable groups. The mixed waste, for example, is
divided into LSC waste and non-LSC waste.
Under the new waste management strategy the regulated scintillation materials (toluene and
xylene) were replaced with other aromatic solvents. These new solvents have nearly the same
efficiency as toluene or xylene, but have flash points that are higher than 60°C and are not listed
in EPA regulations. The purchase of regulated scintillation fluid was significantly curtailed, and
any investigator who submitted a purchase order for regulated scintillation liquid had to provide
written justification to be approved by the University's Office of Environmental Health and
Safety. Because of this policy, the application of regulated liquid scintillation material has been
essentially eliminated.
Another approach in the control of mixed waste production involves the University's Radiation
Protection Committee. An investigator who chooses to use radioactive materials must receive an
authorization from the Radiation Protection Committee and adhere to certain Committee policies
and periodic routine inspections. Alternative protocols are suggested in the Committee review
process to avoid future generation of mixed waste.
Methe, Brian M., "Managing Radioactively Contaminated Infectious Waste at a Large
Biomedical Facility," Health Physics, February 1993, Volume 64, Number 2, pp.187-191.
The Albany Medical Center consists of a 600-bed teaching and medical college and uses
radioactive material in the diagnosis and treatment of patients, and in research in the biological
and medical sciences. The incinerators at the Medical Center were closed in 1993 in response to
air pollution control regulations. Medical waste is shipped to offsite treatment and disposal
facilities. This article details the RSOs responsibilities in managing the low-level radioactive
waste generated as a result of these activities. Three topical areas are discussed including
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screening methods, treatment and storage, and reduction of waste volume.
The medical waste is sent to the waste processing area in 0.4-m3 carts, which are scanned using
an alarming rate meter with a sodium iodide probe sensitive to low-energy photons. All bags
containing detectable radioactivity are removed and set aside and prepared by technicians to be
shipped. The contaminated bags are placed in cardboard boxes with plastic liners and the hot
spots and radioactive isotopes are labeled. It was discovered that a box size of 0.15-m3 that
accepted one bag, conserved storage volume, simplified box handling, and minimized exposure
to the infectious waste.
For the purposes of the Albany Medical Center, two mixed waste treatment options were
considered: 1) treatment of the hazardous component and disposal or 2) storage-for-decay and
disposal as medical waste. This second option is significantly less expensive (by approximately
$9.75 per kg), but the space required for storage is a pressing concern since medical waste needs
to be stored in a freezer to minimize biological composition.
Three strategies are currently being employed to reduce waste volume at its source, including
educating the user, empowering the user, and providing the user meaningful feedback. It is
critical that the user is 1) apprised of the importance of waste handling, segregation, and
prevention and 2) able to identify at which steps of a particular process the radioactively
contaminated material is generated. Finally, it is crucial that constructive feedback that may aid
in minimizing waste generation is conveyed to the user.
Linens, Ilona; Klein, Robert C.; Gershey, Edward L.; "Management of Mixed Wastes from
Biomedical Research" Health Physics, September 1991, 61, 3, pp. 421-426.
At the Rockefeller University, mixed waste generated from biomedical research comprises less
than 1 percent of the University's total LLRW volume. However, the generation of this waste is
integral to this research and will continue to be generated in the future. This article summarizes
the characterization of the biomedically generated mixed waste at The Rockefeller University
and select separation and treatment protocols. Radioactive and chemical characterization
methods are outlined along with separation technologies such as adsorption and extraction, and
evaporation and distillation.
The mixed waste was grouped into three categories: phenol/chloroform mixtures,
acetonitrile/water mixtures, and mixtures of miscellaneous solvents. Figure 2 schematically
portrays this management strategy for biomedical wastes. Effective mixed waste management
programs entail careful waste segregation and labeling. It is concluded that the relevant
regulations (specifically permits) do not provide for a disposal outlet for some mixed waste nor
for extended storage without a RCRA Part B storage permit. Onsite storage remains the only
option for dealing with mixed waste. A considerable number of research facilities do not possess
the financial resources to obtain a RCRA Part B permit which may engender the need to consider
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Figure 2: Mixed Waste Minim ization Strategy for Biomedical Waste at the Rockefiller University
Source: Linins et al., 1 991
M ixed Waste
Radioche mi cal Ana lysis
Radioactive
Phenol/Chloroform
Non-Radioactive Chemical Waste
M isc. Solvents
(benezene, chlorinated mehtanes)
I
Separate Phases
1
0
r ,
rganic 1
r
Aqueous
"TV"
Distill/Evaporate
r
Adsorb Phenol w/ Resin
Chemical
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Phenol-Re sin
Radioactive K M ixed
Still Bottom n Waste
t
Radioactive
Effluent
M ixed Waste
Chemical
Waste
r
Sanitary
Sewer
_r
AcetonitrilelW ater
(methanol, acetic add)
I
Distill/Evaporate
Non-Radioactive
Distillate
ChemicalWaste
Radioactive Still
Bottom
Sanitary Sewer
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suitability of regulatory flexibility. Available regulatory options for waste management are
addressed more thoroughly in Section 5.1.
Lorenz, Steven M., "Decreasing Dry Active Waste Generation by 50% in One Year," Radwaste
Magazine, Sept. 1995, 2, 5, pp. 47-49.
In October 1994, Commonwealth Edison (ComEd) designated a waste reduction program
manager to reduce the generation of dry active waste. The effort resulted in dry active waste
generation reduced by over half in less than a year. This summary document highlights some
examples of the changes implemented to reduce the generation of the waste. The waste
minimization strategy originated with detailed site visits to all 13 ComEd nuclear units. The
purpose of the visits was to demonstrate the importance of incorporating waste minimization
activities into laboratory practices and aid radiation protection staff in identifying minimization
opportunities. The author concludes that the keys to reducing waste minimization include
teamwork, standardization, training, cooperation, and support.
Lorenzen, William A. Operational Aspects of Harvard University's Waste Management
Program, pp. 415-420, August 1995 [Attachment to Fax and Young, August, 1995].
This article provides an overview of the waste management program designed by Harvard
University's Radiation Protection Office. The program is configured around centralized waste
collection rooms coupled with procedures to minimize handling, a decay-in-storage facility and
an on-site incinerator. In terms of personnel, a Group Leader supervises 13 technicians whereby
procedures and process steps are reviewed by process improvement teams. These teams evaluate
efficiency through process streamlining, and understanding customer and business needs. After
staff undergo extensive training which among other things informs the technicians of the waste
acceptance and packaging criteria, the operation of the radioactive waste management program
begins with waste collection in a centralized room for each campus or hospital. The room is
organized for the collection, segregation, and packaging of waste by disposal method.
McCamey, R.B. "Building a Mixed-Waste Prevention Program at Comanche Peak", Radwaste
Magazine, May 1995, 2, 3, pp.21-28.
The article primarily focuses on the techniques established at a specific nuclear utility facility,
Texas Utility's Comanche Peak, for reducing the generation of mixed waste. The techniques
described are primarily management related and focus little on specific technical innovations.
Additionally, the reduction strategies center on reducing the hazardous waste components of
mixed waste rather than the radioactive components.
The prevention techniques primarily involve improving the utility-wide information policy
concerning mixed waste and its components and include:
• Establishing a special interdepartmental mixed waste task force to address the
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problem of mixed waste reduction and prevention,
• Establishing a company-wide database on all mixed waste producing chemicals,
• Involving managers and staff early on in the mixed waste prevention process to
enhance input and ensure rapid program adoption,
• Cooperation and information sharing among departments traditionally isolated,
• Employee education regarding all rules and procedures pertaining to mixed waste
and its components, and
• Detailed product labeling and the distribution of product fact sheets to detail
specific chemical uses, its potential to generate mixed waste, and a list of any safe
alternatives.
Although the article focuses on nuclear power plant facilities, the suggestions for mixed waste
reduction and prevention can easily be applied to all producers of mixed waste and its
components. The overriding concept is to promote sufficient departmental cooperation,
information sharing and accuracy, and employee education.
Party, E.; Gershey, E.L. "Recommendations for Radioactive Waste Reduction in
Biomedical/Academic Institutions," Health Physics, April 1989, 56, 4, pp. 571-572.
The authors assert that many organizations that generate LLRW do not characterize it sufficiently
to achieve maximum volume reduction and waste minimization. It is professed that a significant
volume of waste that must be shipped for burial can be reduced dramatically through decay of
short-lived radioisotopes onsite. The Rockefeller University experienced a 96 percent reduction
in volume of radioactive waste shipped resulting in notable cost savings. To this end, a
sufficiently large storage area is needed to store the contaminated material prior to disposal as
nonradioactive material.
It is suggested that a detailed and systematic waste identification program be implemented that
classifies the source of the material including name of generator, room, department, date,
volume, isotope, activity, etc. Specific guidelines are provided for different waste categories
including solid waste, liquid waste, animal tissues, scintillation vials. Liquid waste, for example,
contains more that 90 percent of the radioactivity disposed at Rockefeller. It is recommended
that this waste be collected in polyethylene bottles and where appropriate held for decay.
Accurate characterization and segregation of the waste is critical to ultimate reductions in
radioactive waste shipped for burial.
Prudent Practices in the Laboratory: Handling and Disposal of Chemicals, The National
Research Council, National Academy Press, Washington, DC, 1995.
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A National Research Council committee prepared this document to delineate the chemical,
regulatory, and educational changes associated with the handling and disposal of chemicals. This
guide was designed for those who use chemicals in the laboratory as well as administrative and
chemical hygiene staff, and environmental safety officers. The report is partitioned into sections
that can be examined individually and address hazard evaluation, risk assessment, management,
disposal, and regulatory issues.
For the purposes of this project, multihazardous waste (chemical, radioactive, and/or biological
components) is outlined in terms of the regulatory issues and suggested management practices.
A recognition of the special problems associated with multihazardous waste is identified. The
report provides a general model of the chemical laboratory as the primary mechanism for prudent
practices conducive to effective waste management.
A detailed discussion of mixed waste minimization strategies including examples of altering
laboratories, source substitution and hazard reduction of mixed waste is outlined. The article
briefly touches on innovative treatment solutions which are to be developed and operational in
the near future. Some of the recommendations made to regulatory agencies in the report include:
• EPA should extend its permit-by-rule provisions to allow scientifically sound
treatment of small quantities of waste generated in laboratories;
• EPA should encourage safe disposal of mixed waste with short half-lives by
excluding the decay-in-storage period from the current 90-day limitation on
storage of hazardous waste; and
• NRC and EPA should establish de minimis levels for radionuclides, below which
laboratory waste can be disposed of without regard to radioactivity.
It is mentioned that although a de minimis level for all types of radionuclides in laboratory
radioactive waste has not been promulgated, licensees can often propose a license-specific de
minimis level, below which mixed waste can be released for management as chemical waste.
Todisco, L.R.; Smith L.R. "A Manufacturer's Perspective on Low-Level Mixed Waste
Treatment, Storage, and Disposal," E.I. Dupont and Co., Inc., NEN Products,
Proceedings of the 3rd Biennial Symposium of Mixed Waste, August 1995, 10 pp.
This article outlines methods for reducing mixed waste at NEN Products, a manufacturer of
radionuclide-labeled research chemicals. A diligent attempt has been made to reduce the
generation of radioactive waste. During the past decade, even with a 50 percent increase in
production, NEN Products Company reduced mixed waste generation 7-fold. This is in light of
the fact that the radioactivity concentrations of mixed waste from the manufacturing processes
have a range of over six orders of magnitude.
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Mixed waste minimization is centered around five basic strategies: 1) reducing the use of
solvents, 2) segregating radioactive constituents of waste, 3) identifying instances where the re-
use of material is feasible, 4) shortening the shelf-life of labeled materials, and 5) source
separating. Education, awareness, and communication were underscored as critical components
of a waste management program. One concern is related to the regulatory stringency of treatment
and disposal options which add significant cost to the manufacture and use of the labeled
chemicals. Several suggestions were made to alleviate this issue including raising allowable
concentration levels, allowing waste to be disposed of at DOE facilities, and providing EPA
RCRA Part B permits at costs commensurate with small-scale onsite decay-in-storage and
treatment operations.
A clear assignment of accountability is an important component of the waste management
program at NEN Products. Estimated costs of the waste generated for each operation are
provided with sufficient detail. The itemization of these costs appears on the operations budget
and must be managed with respect to both ongoing and proposed operations. Other
accountability standards are highlighted in Section 3.2.6 of this report.
Malchman, Warren, "Case Western Reserve University's New 'State-of-the-Art' Low-Level
Waste Facility." Radwaste, September 1995, pp. 42-46.
Case Western Reserve University (CWRU) constructed a 3,000-square foot, $500,000 waste
disposal site for both radioactive and chemical waste in anticipation of the regional facility. The
facility has the capacity to hold 500 55-gallon drums of waste for storage which results in
approximately 4 ft3 of storage space per laboratory that generates radioactive waste. Thus, there
is a compelling need to improve waste management practices and develop rigorous waste
disposal standards so that the current capacity is not exceeded.
This article details the waste management procedures at the CWRU disposal site including
stringent labeling practices, safety features, and surveys. Detailed descriptions are also provided
for waste segregation strategies, waste type definitions, waste shipping and manifesting, personal
protective equipment, and air-handling equipment.
Ring, Joseph; Lorenzen, William; Osborne, Frank; Shapiro, Jacob; Bio-medical Radioactive
Waste Management, July 19, 1995 [Attachment to Fax and Young, August, 1995].
The effectiveness of the radioactive waste management program at Harvard University is
evaluated. The portion of the solid waste shipped to a low-level waste disposal facility was
reduced from 98 percent of the total radioactive waste column in 1980 to 1.09 percent in 1993
and the volume of waste generated per laboratory decreased by just under 50 percent [0.35 m3
(12.31ft3) in 1987 to 0.19 m3 (5.29ft3) in 1993]. The program is operated around a central decay-
in-storage (DIS) facility and an incinerator.
The article continues by detailing the waste collection process. Commercial disposal is 5.7 times
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more expensive per unit volume (on a total cost basis) than University managed waste. The
waste management program, therefore, always begins with a training session designed to educate
staff on waste generation, minimization, and general radiation protection. It was found that
substituting laboratory absorbent pads, commonly referred to as diapers, for thin plastic-backed
bench liners in multiple layers aids in reducing waste volumes. The laboratory technician is the
key to effective waste reduction by identifying modifications of procedures to facilitate reducing
waste. Improved communication resulted from the meetings.
It was discovered that assigning one technician to an area to monitor, collect samples, and other
responsibilities is the most effective means of managing wastes. Prompt feedback and
laboratory-based corrective action have sharply reduced waste management problems. When the
waste is received at the Waste Management Facility the tag data is recorded into a database that
calculates the release date. The decay-in-storage program has proven to be fairly successful in
reducing waste disposal at commercial LLRW facilities. The applicability of this program in
reducing mixed waste disposal was not discussed.
2.6 SUMMARY FOR SECTION 2
The literature referenced above provides an enumeration of the critical components of a waste
management program. Updated information can be found on the EPA Mixed Waste Team
Internet HomePage which can be found at (http://www.epa.gov/radiation/mixed-waste/). EPA
laboratory directors considering the implementation of an integrated mixed waste management
approach should consider the suggestions provided in the literature. The primary focus of the
mixed waste management program should be directed at pollution prevention. The following
integrated framework is based on the Waste Minimization Program at the University of
Minnesota and other materials referenced above:
• engage all levels of management to a strong commitment to pursue established
mixed waste minimization goals in the facilities pollution prevention plan;
• periodically evaluate the progress in meeting these goals through an audit or other
type of analysis of the current mixed waste generation;
• begin an intensive education and training program for all employees that handle
mixed waste to ensure a thorough understanding of the applicable regulations and
regulatory guidance. Topics should include which waste can be recycled, the need
for source separation, how to segregate waste, importance of a waste minimization
program, and costs and technical difficulties of waste disposal;
• embody a team approach to mixed waste management; consciously pursue an
active information sharing/dissemination program; ensure that continuous
communication is employed between EPA laboratory personnel both inside and
outside the laboratory;
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empower the research technicians to identify waste minimization alternatives;
employ a comprehensive waste separation program; i.e. separate short-lived
isotopes from long-lived isotopes; ensure that detailed product labeling is
employed including source, stream, volume, isotope, etc. is recorded;
employ standardized processes for all laboratories to the extent practicable;
strictly control the use of radioisotopes including the control of purchasing;
critically evaluate the use of radioisotopes, determine if short-lived radioisotopes
can be used;
encourage the substitution of less toxic or nonhazardous substitute materials with
equivalent performance parameters (e.g., biodegradable liquid scintillation
cocktails, solid scintillation counting) for hazardous materials; and
consider the possibility of burning waste containing 3H and 14C in a pathogen
incinerator.
It should also be noted that all levels of management should be in full support of waste
minimization programs. While these programs will likely incur time and money (new equipment,
materials, training, additional procedures, etc.) they will pay for themselves over the long term.
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SECTION 3: SUMMARY OF MIXED WASTE MANAGEMENT OPTIONS
The purpose of this section is to define, identify, and present case studies and applications of the
management options applicable for low-level mixed waste. Where available, the application of
these options to LSC and HPLC is discussed. An overview of mixed waste management options
applicable to all types of generating processes is outlined in Mixed Waste Management Options:
1995 Update. The option groups fall under three general headings: regulatory-based, avoidance,
and treatment; a description of each option group and examples are highlighted below. All of the
option groups listed are pertinent to EPA research facilities. As addressed above, a concerted
approach is needed to aggrandize the effectiveness of a waste management effort.
3.1 REGULATORY-BASED OPTIONS
Several regulatory-based options are available to managers of mixed waste producing facilities
who wish to avoid disposal of certain chemicals and materials in a mixed waste disposal facility.
Four such options are: (1) delisting petition, (2) a no migration variance, (3) a treatability
variance, and (4) a Determination of Equivalent Treatment Petition. Since the latter option is
more applicable to EPA research facilities, it is discussed in more detail below.
3.1.1 Determination of Equivalent Treatment
As the name implies, the Determination of Equivalent Treatment Petition, if granted, would
allow a facility to use an alternative treatment method to achieve the same measure of
performance as that achieved by the specified methods in the Land Disposal Restriction rules.
The petitions must demonstrate that the alternative methods achieve the specified treatment
levels, are in compliance with federal, state, and local requirements; and are protective of human
health and the environment [40 CFR 268.42 (b)].2 Unlike treatability variances, Determination
of Equivalent Treatment petitions, are more likely to be granted than denied. No sources were
identified which contained cost estimates for this type of petition.
3.1.2 Regulatory Flexibility3
A management approach that strives for a flexible regulatory framework may alleviate the high
costs associated with treatment, storage, and disposal without posing additional risks to human
health and the environment. With the exception of the NERL-RTP and NRMRL-Breidenbach,
the total volume of mixed waste generated at each laboratory in the 1992-1994 time period was
2Regional EPA offices offer a "permit-by-rule" provision that allows categorical or
blanket permitting of certain small-scale treatment methods.
3It is important to determine whether or not your authorized state programs may be more
stringent than the federal RCRA program before relying on any of the exceptions discussed in
this section. Even exceptions adopted by an authorized state may be more narrowly interpreted.
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less than 30 ft3. Given the relatively diminutive volume and curie content of the mixed waste
generated at EPA laboratories, these facilities may be able to justifiably exempt themselves from
certain NRC or NRC Agreement State or EPA or EPA RCRA Authorized State regulatory
provisions. An exception that offers regulatory relief for mixed waste generators from virtually
the entire RCRA program, including the permitting requirement, is the "Conditionally Exempt
Small Quantity Generator" provision.4 Although there were no specific examples in the literature
of the efficacy of regulatory-based options, this approach may have some applicability for EPA
facilities.
For example, a CESQG may treat hazardous waste in an onsite elementary neutralization unit
without meeting the requirements in 40 CFR 261.5(f)(3) and (g)(3). Elementary neutralization
units, as defined in 40 CFR 260.10, are exempt from RCRA treatment, storage, and disposal
standards and permitting requirements. The elementary neutralization unit exclusion does not
preclude a CESQG from treating waste in the exempt unit as long as the generator meets the
criteria outlined in 40 CFR 264.1(g)(6), 265.1(c)(10), and 270.1(c)(2)(v). Specifically, the
elementary neutralization unit must meet the definition of a container, tank, tank system,
transport vehicle, or vessel; and be used for neutralizing waste that are hazardous only because of
corrosivity characteristic (RCRA/SF Hotline Report, February 1996)
For large quantity generators (LQG) and small quantity generators (SQG), EPA has consistently
maintained that a permit or interim status is not required of generators if the generator treats
hazardous waste in accumulation units such as tanks or containers that are in full compliance
with the requirements of 40 CFR 262.34 and the special unit-specific requirements found in Part
265 (March 24, 1986; 51 FR 10146, 10168). This treatment must be completed within the
specified regulatory time limitations (RCRA/SF Hotline Report, April 1996).
Used in conjunction with other management options, regulatory approaches can be used to
mitigate the costs associated with the use of a TSD facility. For example, the Oklahoma Medical
Research Foundation recently filed a petition to amend their license. Their radionuclide half-life
license limit allowed for decay-in-storage was extended to 120 days. 40 CFR 260, Subpart C
outlines the general requirements of the petition process.
Currently, there are only a few de minimis levels for onsite radioactive waste disposal. Permitted
sanitary sewer disposal was the management option chosen for 615.4 ft3, or 19.2 percent of the
LLRW generated by EPA laboratories in 1992-1994. Under 10 CFR 20.2003, an NRC licensee
may release licenced radioactive material that is readily soluble or readily dispersible biological
material into any one sewerage system. Total permitted yearly curie loads and concentration
4Special requirements for HW generated by conditionally exempt small quantity
generators, less than 100 kg HW or 1 kg of acute HW in a calendar month are contained in 40
CFR 261.5. Note that this provision includes all HW generated at the facility and not just mixed
waste. However, the generator need not count those HW (or mixed waste) that are excluded
from RCRA regulation.
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levels are detailed in the above Part 20 reference. As indicated previously, NRC licensees can
also propose a license-specific de minimis level for specific radionuclides, below which mixed
waste can be released for management as a chemical waste.5 EPA laboratories may wish to
explore the potential opportunities for filing a petition or proposing a license-specific exemption
based on the curie content of the mixed waste generated.
Under RCRA certain laboratory waste waters are excluded from the definition of hazardous
waste. These provisions are found in 40 CFR 261.3 (a)(2)(iv)(E). These laboratory waste waters
which would otherwise be regulated as a hazardous waste because they contain a listed waste
containing toxic constituents are not considered hazardous. To qualify for this exclusion, the
generator must show that the laboratory wastewater discharge:
• is subject to regulation under either Section 402 (NPDES program) or Section
307(b) (pretreatment program) of the Clean Water Act and
• the annualized average flow of laboratory wastewater does not exceed one percent
of total wastewater flow into the headworks of the facility's wastewater treatment
or pretreatment system; or
• provided the wastes' combined annualized average concentration does not exceed
one part per million in the headworks of the facility s wastewater treatment or
pretreatment facility.
[Note: Toxic (T) waste used in laboratories that are demonstrated not to be discharged to
wastewater is not to be included in the above calculation.]
This exemption does not cover laboratory wastewaters that exhibit a RCRA hazardous
characteristic (ignitable, corrosive, toxic, or reactive). However, as noted in 40 CFR
261.3(a)(2)(iii), if wastes which were listed solely for exhibiting a characteristic were mixed with
other solid wastes, such as a wastewater, and ceased to exhibit any characteristic they would no
longer be considered hazardous wastes (RCRA/SF Hotline Report, May 1996). Also, as noted in
40 CFR 268.1(e)(5), land disposal prohibitions for hazardous characteristic waste do not apply
to laboratory waste displaying ignitability (D001), corrosivity (D003), or organic toxicity (DO 12-
D043) that are managed in accordance with the previously mentioned laboratory wastewater
exclusion.
A flexible regulatory scheme may also reduce timely reporting requirements associated with
compliance, and eliminate regulatory overlap. Although none of the EPA laboratories surveyed
reported significant regulatory hurdles, some commercial and academic laboratories have
articulated substantial regulatory burdens resulting in increasing the cost associated with mixed
5NRC allows LSC fluid with less than 1.85 kBq/g of 3H or 14C to be disposed of without
regard to its radioactivity. See 10 CFR 20.2005(a)(l) for more details.
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waste management. Specifically, representatives from these laboratories have expressed
consternation with both 1) the regulatory stringency of treatment and disposal options and 2) the
regulatory overlap which add to the cost in the use of radioactive materials. One researcher
estimated that meeting all the reporting and training requirements requires approximately 10
percent of laboratory personnel time6.
3.2 SOURCE REDUCTION/AVOIDANCE OPTIONS
Source reduction and avoidance and involve actions that eliminate the production of LLRW/MW
which would require extended storage or access to offsite disposal. The management options
that fall under this activity include substitution, waste segregation and separation, process
modification, pollution prevention, recycling, storage for decay, and administrative controls.
Figure 3 depicts an overview of general volume reduction methods for four types of waste
including solid, liquid, animal, and gas.
3.2.1 Source Reduction
Over the past 2 decades, laboratory protocols for biomedical and basic research have been
progressively scaled down from the liter to milliliter to microliter scale, reducing both reagent
costs and the volume and radioactivity of resulting waste (Linins et al. 1991). EPA laboratory
researchers should try to identify ways to reduce the amount of materials used in experiments.
Significant reductions could be obtainable through a refinement in protocols. These protocol
modifications can greatly reduce the waste volumes, sample preparations, and disposal costs at
EPA laboratories. The following are examples of some protocol modifications which might be
applicable to EPA laboratories.
• Replacing conventional liquid scintillation counting vials (20 ml) with smaller
vials (7 ml) can result in a 3:1 volume reduction (Dagan, 1993).
• Using 2-ml microcentrifuge tubes in place of 7-or 20-ml liquid scintillation vials
during counting of aqueous or filter samples can result in a 50 -75 percent
reduction in waste volume (Elliott, 1993).
3.2.2 Substitution/Use of Biodegradable Solvents
In reference to laboratory procedures, substitution involves the displacement of nonhazardous or
6Personal correspondence with Margaret C. Neville, Ph.D., Professor of Physiology,
University of Colorado School of Medicine, March 25, 1996.
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Figure 3: General Volum e Reduction Methods for Laboratories
SOLID
Incineration
Compaction
Supercompaction
CommeFcWLLRW
Disco sal Facility
GAS
Source: P arty and Oershey, 1989
sswer disposal of MW is not an option for large quantity generators
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nonradioactive materials to perform functions formerly requiring radioisotopes and hazardous
materials. Several commercial, academic, and government laboratories have successfully
substituted nonhazardous solvents to perform various research activities. The primary waste
minimization option discussed involves substitution of "aqueous" or "biodegradable" compounds
for the more hazardous RCRA-regulated substances.
Material substitution is one of the easiest and more cost-effective methods for reducing the level
of mixed waste generated. The example of using water-based solvents instead of other solvents
such as toluene or chloroform is often cited as an example of chemical substitution. Using
enzymes and fluorescent labels instead of radioactive tracers is an example of substitution to
reduce radioactive wastes. Substituting radionuclides with shorter half-lives (32P for 3H or 14C)
can also be used to decrease the amount of mixed waste sent to treatment or long-term storage
facilities.
Certain compounds that have not been identified as hazardous under 40 CFR 261 of RCRA or 40
CFR 122 of the Clean Water Act are being used as solvents in LSC cocktails. Rockefeller
University evaluated a variety of cocktails deemed "biodegradable" based on three criteria:
efficiency, toxicity, and potential for biodegradation (Klein et a/., 1990). The results indicated
that, for a majority of the biodegradable LSC assayed, the cocktails are comparable to RCRA
identified hazardous compounds in terms of efficiency, sample capacity, and viscosity. The
studied compounds were also less acutely toxic and are susceptible to biodegradation. Pacific
Northwest National Laboratory switched to a nonregulated brand (Ultima Gold) and eliminated
the generation of mixed waste from most liquid scintillation counting (Dagan et a/., 1993).
Further research is needed to ensure that 1) widespread environmental contamination does not
occur from the use of these compounds and 2) the efficacy of sewer disposal is fully explored.
Xylene substitutes were examined in detail at the Fort Carson Evans Community Hospital
Histology Laboratory in Colorado Springs, CO. The criteria that were considered in the selection
of a substitute included toxicity, physicochemical characteristics, compatibility with other
materials, performance, availability, recycling requirements, disposal requirements, and cost.
Some of the drawbacks with the use of these substitutes are the relative high cost and their poor
performance for tissue cleaning.
Phenol, chloroform, and 1:1 mixtures of these chemicals are routinely used in molecular biology
laboratories to extract nucleic acids from radiolabeled biological materials and denature proteins
that remain after treatment with enzymes (Linins, et a/., 1991). New procedures that do not use
phenol and chloroform are available in kit form from several suppliers. This avoidance of phenol
and chloroform eliminates the need to treat a toxic and corrosive extraction effluent.
A successful example of waste minimization at the University of Wisconsin-Madison is the
substitution of a toluene-based LSC fluid with nonignitable LSC fluid. This practice alone
eliminated the generation of thousands of gallons per year of waste toluene solutions from liquid
scintillation. The nontoluene based solution reduces the risk of exposing workers to toluene, as
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well as reducing the risk of fire, the environmental hazards of spills, disposal costs, and paper
work requirements.
In the 1992-1994 time period, some of the EPA laboratories used biodegradable cocktails in LSC
procedures, reducing the generation of mixed waste. The EPA researchers who used these non-
hazardous cocktails did not report any substantial loss in efficiency in performing laboratory
experiments7. To minimize mixed waste volumes, one EPA laboratory RSO reported that
written justification is required to use xylene in any laboratory procedure. Given that toluene
and/or xylene was a constituent in 98.2 percent of the total MW volume generated in EPA
laboratories in 1992-1994, there exists continued potential to reduce MW generation.
3.2.3 Waste Segregation and Separation
Waste segregation describes the practice of keeping different waste streams segregated from the
time they are placed in the collection container through transport, storage, treatment, and
disposal. Waste segregation options do not represent formal technologies as much as systematic
procedures to label and codify MW and LLRW. This also entails grouping wastes of similar
characteristics and identifying opportunities for recycling.
Components of source separation programs in laboratories include: 1) training laboratory
personnel, 2) using sanitary sewer and normal trash properly8, 3) supplying easy-to-use waste
collection containers, 4) establishing waste collection stations, 5) labeling waste collection
containers appropriately, 6) monitoring and minimizing errors, and 7) examining where changes
can be made for improvement.
A common waste segregation approach is the "multicolor bag" system. This has proven
successful in the reuse and reduction of waste material. Two utilities documented reductions of
87 and 74 percent in the volume of LLRW shipped using this approach. Figure 4 schematically
portrays the "multicolor bag" system. Although this model diagrams waste segregation issues
associated with a nuclear utility, the same approach can be extrapolated to a facility that
generates LLRW/MW from few processes.
Source separation aids in minimizing the quantity of mixed waste by preventing waste that does
not need special management considerations from entering the waste stream. Although very
similar in scope to waste segregation, source separation refers to the practice of separating
different types of waste at their point of generation and discard. Waste segregation relies on
7The specific products reported to be used included Opti-fluor, Ultima Gold, and
Cytoscint.
8Of the LLRW generated by EPA laboratories in 1992-1994, low-level waste stream
#202, trash and/or solid waste, accounted for 39.5 percent of the total.
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As Generated Dry-
Active Waste
Figure 4: Multi-Coloi Bag Volum e Reduction System
Colored Bags Volume Reduction Process/Facility
Red X" "X
On-Site Tool Decon(< 1R/hr. <100K/DPM
Hot & C old Tool Issue
Vendor D econ Area (<100K DPM)
Grit Blasting
Large Equipment Deeon(<> 100K/DPM)
Process Results
Reissue/R euse
Free Release
Radtrash/Burial
.Off-site Volume Reduction
Herculite
Large Objects Contaminated
O 6' long, < 1 ton)
E segregation/Re co very
5 a I in g i nt o 5 5 Gallon Drums
Saling into 52 Gallon Drurns/Supercornpaction
Green Bags to Low Background Area for Monitoring
eco nta m in ate d M ate ria I to Low B ack gro un d Are a for M on ito ring
V
Recovery of R eusable Items
Direct Burial (> 1R/hr)
Release as Clean
Radtrash/Burial
EUn Site-Grit Blasting/Sandblasting
Steam Cleaning
Hff- S rie D e co ntarn in ation/S up ercom p action
(Volume Reduction up to 5 to 1
-WFree Release/Reuse
[R adtrash/Burial
Source: NYSERDA,
July 1993
Off-site P rocess ing
Reuse. Avoiding Disposables
High Quality, Avoiding D isposables
On-site Processing
R e issue/R euse
-WHIgh Quality, Avoiding Multiple
ID ress Outs
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proper labeling by the original generator to ensure that waste streams are not pooled
unnecessarily as "organic solvents" or "unknowns."
Careful attention should also be given to the separation of chemicals that are difficult to treat
from other waste streams. These difficult to treat waste streams include RCRA listed hazardous
waste, organometallic mercury, and arsenic compounds. These wastes generally have fewer
disposal options. Residues from treating listed waste are also considered hazardous unless
delisted. Separating this waste from other hazardous waste will result in lower volumes of waste
that are difficult. This will then help to drive down overall treatment costs.
Separate collection of certain waste will also prevent the creation of unbeatable mixtures. For
example, waste containing toxic heavy metals should be separated from organic waste.
Generally, the treatment requirements for these two different waste streams differ significantly.
Liquid scintillation cocktails and animal carcasses containing 3H and 14C, which fall below the
NRC de minimis level of 1.85 kBq/g (10 CFR 20.2005) should be separated from other non-de
minimis waste. There are generally more disposal options, and lower costs.
3.2.4 Process Modifications
Process modifications can occur at any point during the mixed waste generating process, as well
as during the design of the equipment or facilities and in the management of the people and/or
materials coming in contact with the waste. Three components of the process modification
management option are reformulating or redesigning a process, altering procedures and guidance
for material handling and waste segregation, and inventory control.
Examples of reformulating or redesigning a process include everything from changing the way
facilities are designed in order to minimize waste during decommissioning to using small-bore
tubing on high-performance liquid chromatography (HPLC) to reduce the amounts of solvents
required to perform analytical procedures.
Changing LSC methods to avoid the use of vials can also significantly reduce waste volumes.
An alternative to vials is a flat-bed geometry in which multiple samples are deposited within
discrete areas on a well plate or filter sheet. Counting liquid scintillation cocktail samples on a
96-well plate, each well having a capacity of 0.2 ml can result in 100:1 total waste volume
reductions per sample as compared to the use of 20 ml standard vials (Dagan et a/., 1993). If
filtered paper is used, then the filter paper is dried, sealed in a plastic bag with a small quantity of
scintillant and mounted on a rigid metal support plate and counted. Using 12 ml of scintillant per
96 samples on filter paper, some 5,000 samples can be contained in a 10-cm cube, giving a
reduction of more than 95 percent in the waste volume and a proportional reduction in the cost of
scintillant and plastic consumables (Warner et a/., 1985 and 1986). A possible disadvantage for
these methods is the requirement of using flat-bed geometry liquid scintillation counters.
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Other methods have been suggested to reduce waste volumes. Party and Gershey (1989) suggest
counting 32P without scintillation fluid by the Cerenkov method on the 3H setting of a liquid
scintillation counter (-40 percent efficiency). These vials should be kept separate, held for
decay, crushed, and discarded. They also suggest counting 125I without scintillation fluid in a
gamma scintillation counter, hold for decay, and discard as nonradioactive waste.
Even more dramatic reductions in mixed waste production can be accomplished using dry
counting procedures. Wunderly (1989) and Hawkins (1991) have demonstrated that improved
solid scintillation counting methods now offer counting performance similar to LSC for
nonvolatile substrates of less than 200|_iL, with only moderate solute concentrations (less than 1
M). Using the solid scintillator ReadyCap™ with XtalScint™ the liquid sample is added and
then dried onto the solid scintillator. No new instrumentation is required for this system.
Because of its compactness (small size) and dry form, one drum of ReadyCap™ sample is equal
to 30 drums of the same number of liquid scintillator samples in vials.
Altering procedures and guidance for material handling and waste segregation for all operational
practices and procedures should be examined to determine if modifications can reduce the
volume of chemicals and materials ultimately ending up as mixed waste. Analysis should focus
on usage, handling, and storage of materials and chemicals to optimize waste minimization. A
simple technique to prevent an accidental production of a very difficult to treat mixed waste is to
eliminate the use of mercury thermometers with radioactive materials. This will prevent leakage
or breakage of these thermometers into radioactive materials. If a mercury thermometer is to be
used with radioactive materials then the thermometers should be enclosed in protective sleeves.
Inventory control throughout the agency or company will also help reduce the amount of mixed
waste production. Purchases should be specifically based on volume used rather than volume
prices or a particular vendor selection. Such practices will reduce the quantity and volume of
contaminated material (e.g., containers) and reduce the overall volume of chemicals to aid in
inventory control and management.
3.2.5 Recycling
Recycling involves the collection and reuse of material. As a laboratory mixed waste
management option, recycling opportunities are limited. Laboratory uses tend to require high
purity materials to minimize experimental error. Recycling of solvents, for example, may
introduce unacceptable levels of impurities. However, Miyatake and Saito (1984) have shown
that spent LSC containing toluene, dioxane, and [methyl-3H]thymidine can be distilled and
purified by additional refining steps which provide complete removal of radionuclides. In
general, markets for recycled lab materials are limited or nonexistent.
Large-scale laboratories such as Agracetus, Inc. identified unwanted and unused chemicals at
each of their research facilities to find other laboratories that could use these materials. This
simple efficiency initiative resulted in cost savings of several thousand dollars in purchase and
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disposal costs. Likewise, a program at the University of Minnesota recycled 6570 kg of
chemicals in fiscal year 1990-1991, resulting in an estimated cost savings of $155,000.
Of potential interest to EPA laboratories, the redistillation of solvents for recycling has been
shown to be worthwhile. B/R Instrument Corporation experienced considerable success in the
extraction of solvents including xylene, ethanol, toluene, and HPLC wastes using a spinning
band distillation device. Other recycling efforts at EPA laboratories might include the following:
Recycling laboratory glassware and supplies,
• Washing and reusing empty glass liquid scintillation vials. (McElroy et a/., 1982);
• Decontaminating and reusing lead shielding blocks. (Lussiez, 1993); and
• Contacting the Conference of Radiation Control Program Directors, 502/227-4543
for an update on their lists of radioactive materials that are available for adoption
and those sought by others.
3.2.6 Storage for Decay9
The relatively short half-lives of the radioactive components of some mixed waste warrant
storing the waste for a period of time until the radioactive levels are undetectable.10 If approved
by NRC or an Agreement State, as well as the proposed disposal facility, the waste may then be
disposed of as a hazardous waste without regard to its radiological component. This is known as
storage for decay. NRC considers materials with half-lives of under 65 days to be appropriate for
the storage for decay management option. NRC may also consider storage for decay for isotopes
with half-lives greater than 65 days on a permit-by-permit basis.
As indicated in Mixed Waste Management Options: 1995 Update, estimates for storing chemicals
and materials for decay vary depending on the source and initial quantity. Decay-in-storage
requires segregating LLRW by the half-life of the isotopes contained and storing it until the
contained activity and measurable radiation exposure rates are indistinguishable from natural
background. Rockefeller University, NY, used decay-in-storage to reduce their LLRW required
for storage by more than 95 percent (Party et. al. 1989). Party also estimates in the same article
that the decay of short-lived radionuclides on-site can eliminate 74 percent of the LLRW
materials now shipped for burial.
9The U.S. EPA is extending its "Policy on Enforcement of RCRA Section 3004(j) Storage
Prohibition at Facilities Generating Mixed Radioactive/Hazardous Wastes," until April 20, 1998.
Storage of mixed waste subject to Land Disposal Restrictions is unlawful under the section
3004(j) storage prohibition. The policy states, however, that violators who (1) are faced with an
impossibility of complying with the RCRA regulations and (2) are storing their waste in an
environmentally responsible manner will be a low enforcement priority for EPA. The low
priority applies to that waste in which no treatment or disposal option exists.
10Refer to 10 CFR 35.92 for more details.
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Recently EPA and NRC issued joint guidance on the storage of mixed waste, NRC/EPA
Low-Level Mixed Waste Storage Guidance (60 FR 40204 - 40211, August 7, 1995). This draft
guidance states that storage for decay meets the definition of treatment as defined in 40 CFR
260.10, insofar as it is a method or technique designed to change the physical character or
composition (amount of radioactivity) in mixed waste. Decay-in-storage subsequently makes the
treatment of the hazardous constiutents safer, and renders them safer for transport. EPA
considers decay-in-storage a necessary and useful part of the best demonstrated available
technology (BDAT) treatment process. Thus, limited periods of approved decay-in-storage of
mixed waste do not violate the RCRA section 3004(j) storage prohibition. As indicated in 40
CFR 268.50, a hazardous waste generator may store this waste for the sole purpose of
accumulation11 to facilitate proper recovery, treatment, or disposal. The generator may store the
waste for up to 1 year unless EPA can demonstrate that storage was not completed solely for the
purpose of accumulation. After 1 year, the generator must bear the burden of proving that the
waste is stored solely for this purpose.
It should be noted that even under this proposed guidance, facilities are still required to obtain a
RCRA hazardous waste storage permit if they store hazardous waste (including mixed waste) for
longer than the allowed accumulation period (90, 180, or 270 days).
For the mixed waste generated in the 1992-1994 time period, EPA laboratories have not
exercised the storage-for-decay management option. However, the storage-for-decay option was
employed for 77 ft3 of LLRW generated in the 3-year study period. Many laboratories and
research facilities in the commercial sector rely on the storage-for-decay management option as
the principle means of managing LLRW. It is recommended that liquid waste should be
collected in polyethylene bottles (4-20 L) which, unlike those of glass, are unbreakable, produce
less bremsstrahlung, are impervious to most organic chemicals, and do not form sharp edges
when compacted (Party et al. 1989).
Two articles summarized below provide examples of existing decay-in-storage facilities.
Fax, Gene and Young, Chuck. Site Visit to the Harvard University Storage and Incinerator
Facility, The Cadmus Group, August 8, 1995.
This document provides a summary of a site visit to the Harvard University low-level radioactive
waste Decay-In-Storage (DIS) facility and incinerator. Most of the approximately 20,000 cu ft of
radioactive waste generated per year is derived from the biological and medical waste programs
at Harvard. The DIS facility has a storage capacity of 6,000 drums (54,000 cu ft), a freezer of
266-drum (2,000 cu ft) capacity, and a 25-drum facility for storing flammable liquid scintillation
fluid. Management of radioactive waste is completed through the DIS facility. Decay-in-storage
"The total volume of mixed waste stored for accumulation by the EPA laboratories in
1992-1994 was 0.06 ft3.
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waste that has half lives of 180 days or less are packed, stored for 10 half-lives plus 1 calendar
year, and surveyed for radiation levels. Animal waste is stored for decay using the same release
criteria for DIS waste and then processed at the onsite incinerator.12 Tritium/C-14 waste has half-
lives greater than 180 days and are disposed of by burial at the Barnwell site. A broker arranges
for the LSC waste to be disposed of at a fuel blending facility.
Hamawy, George and Passler, Carl; "The Decay-in-Storage Room at the Einstein College of
Medicine," Radwaste Magazine, March 1995, 2, 2, pp. 14-17.
A decay-in-storage room to handle radioactive waste at Albert Einstein College of Medicine was
constructed to anticipate the closing of the waste burial site at Barnwell. The determination of
maximum volume stored, area required, location of facility, room preparation, waste collection,
and postoperation is discussed. It was estimated that the maximum accumulated waste volume
was 1880 ft3 and would stabilize in an elapsed period of 3 years.
3.2.7 Administrative Controls/Incentives/Accountability Standards
Administrative Controls refer to actions taken to reduce the need for extended LLRW storage.
Examples include using radionuclides with short half-lives, prohibiting research that would
produce problematic waste streams, and exercising the option to discharge limited amounts of
nonhazardous liquid waste under permitted conditions into a sanitary sewer system13.
Berry, Robert O.; Jablonski, Susan M.; "Low-Level Radioactive Waste Management at Texas
A&M University," Radwaste Magazine, September 1995, 2, 5, pp. 39-41.
The Office of Radiological Safety (ORS) at Texas A&M University is responsible for the
management and regulation of radioactive materials associated with the research activities at the
University and established a program to control the type and amount of waste generated from
research activities. The program is designed to minimize both the waste that is transported to the
Barnwell facility (an expensive option) and the waste housed at the temporary storage onsite
facility that is destined for disposal.
The waste management and waste minimization incentive procedures consist of four
components: intensive training, source substitution, segregation, and a fee-based generation
schedule. Two notable practices employed at the University include written justifications on the
12Treatment of radioactive carcasses by vacuum drying has proved to be a simple and cost
effective solution at S&G Enterprises, Inc. in Germantown, WI.
"Permitted sanitary sewer disposal was the management option chosen for 615.4 ft3, or
19.2 percent of the LLRW generated by EPA laboratories in 1992-1994. Under 10 CFR
20.2003(a)(4), an NRC licensee may release Icurie per year of radioactive material into any one
sewerage system, with the exception of 3H which has a release limit of 5 curies per year.
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part of the researcher for the use of longer-lived radionuclides (more than 300 days) and an
accountability standard that entails a per pound disposal fee (depending on the nature of the
radionuclides involved) charged to the sublicensee. The results of the comprehensive waste
management program implemented by ORS has led to a decrease in the volume of the waste
generated.
3.3 TREATMENT OPTIONS
Treatment involves the physical or chemical processes that produce a smaller waste volume or
more stable waste form. In general there is treatment for mixed waste streams containing
regulated metals or organic liquids while there is little or no treatment available for mixed waste
streams containing organic solids. The treatment technologies appropriate for the EPA generated
MW and LLRW are:
• Compaction and supercompaction reduce the volume of dry MW/LLRW by
applying external pressure. These processes are measured by a volume reduction
factor (VRF) which for laboratory waste can be a high as 10 to 1.
• Incineration is a thermal treatment technology that involves the combustion of
material through contact with a controlled flame in enclosed chambers.
• Solidification is a process where a solidification agent (usually cement, asphalt, or
polymers) is applied to immobilize liquid waste and sludge not acceptable for
disposal.
• Absorption is a conditioning technique used to treat institutional liquid
MW/LLRW. The liquid is stored within a porous material such as silica,
vermiculite, or organic materials.
• Amalgamation with copper, zinc, or other reagents is an immobilization method
applied to mercury waste before land disposal. The method of amalgamation was
successfully used at ESfEL on radioactively contaminated elemental mercury waste
which was then able to pass TCLP for mercury (Tyson 1993).
• Decontamination and free release involve the removal of radioactive material
from a surface of an object by either chemical or physical means.
• Chemical oxidation processes use a chemical oxidizing agent or a combination of
agents (e.e., hypochlorite, hydrogen peroxide, or ozone) to react with the
contaminant. The process can be enhanced with the addition of ultraviolet light.
Chemical oxidation is used in many industrial processes and in the treatment of
potable water to remove a broad range of natural and synthetic organic
compounds (Anderson 1994). NIH developed an ultraviolet peroxidation system
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that is primarily used to treat aqueous solutions.
• Biological treatment uses established, maintained, and controlled microbial
communities to breakdown toxic organic compounds to cellular mass, carbon
dioxide, water, and other inert inorganic residuals. This treatment has realized
moderate success for processing stored liquid scintillation waste.
In addition to the treatment options described above, there are incinerators using controlled air,
excess air, fluidized bed, rotary kiln, and slagging pyrolysis technologies. Another research
option, supercritical water oxidation, is a process that destroys the hazardous component of
certain mixed wastes.
The study conducted by the National Low-Level Waste Management Program based on mixed
waste generated at NIH identified five minimization techniques to reduce organic volumes:
Phase Separation - Where a nonpolar hydrophobic nonaqueous organic phase separates
from the aqueous phase, the organic liquid phase can be separated and disposed of offsite
at a facility or by a steam-reforming technology.
Chemical Oxidation - The process uses UV light and hydrogen peroxide to oxidize
organic compounds to carbon dioxide and water.
Carbon Adsorption - The use of commercially available granulated activated carbon
(GAC) to absorb organics contained in aqueous feed streams.
Solvent Extraction - The process uses a nonpolar organic compound with a low solubility
in water which would be contacted concurrently with the waste stream in a liquid/liquid
contacting vessel where the organic reagents would be transferred out of the aqueous
phase and into the extraction solvent phase.
Steam Reforming - Reforming reactions occur in a near oxygen free environment under
high pressure and temperature and allow an extremely high conversion of organics
(wastes) to the primary conversion products of CO2, H2O, and H2.
The NLLWMP recommended technique for removal of organics is physical phase separation
followed by chemical oxidation.
3.3.1 Treatment Options Applicable to LSC
Although there is a limited discussion of the waste management options for HPLC and LSC, two
sources devoted considerable attention to this topic. A dated but comprehensive examination of
the alternative methods for the management of LSC waste was performed by Lidia Roche-Farmer
in 1980. A survey of the handling and disposal problems associated with LSC waste is presented
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along with a discussion of disposal methods. This article performs a critical analysis of:
evaporation, distillation, solidification (microencapsulation and polymerization), conversion, and
combustion (incineration and addition to fuel), as applied to LSC waste.
The NLLWMP study reviews the management options associated with both HPLC and LSC.
The following sections summarize the materials that address these waste streams specifically.
3.3.1.1 Distillation. Distillation entails heating a mixture to separate the more volatile from the
less volatile parts, and condensing the resultant vaport to produce a more nearly pure substance.
The two primary types of distillation include simple distillation, for liquids with boiling points
more than 30°F apart, and fractional distillation for mixtures with boiling points of only a few
degrees apart. This process is not effective for separating ethanol and toluene. As mentioned
previously, Miyatake and Saito (1984) have shown that spect LSC containing toluene, dioxane,
and [methyl-3H]thymidine can be distilled. Distillation followed by several simple refining
treatments may be useful as a preliminary step before the disposal of the waste scintillation
cocktail. However, distillation is time consuming, requires an elaborate monitoring scheme, and
may be more appropriate for large laboratories.
3.3.1.2 Solidification. The purpose of solidification is to immobilize the hazardous materials to
reduce vapor pressure, and thus the fire hazards. Two solidification methods that have been used
for immobilizing LSC cocktails include microencapsulation, which entraps LSC waste in a
polymer matrix and polymerization, which involves the chemical union of small molecules into
large ones. This latter process generally entails high costs and requires specialized personnel,
technology, and equipment. The application of both of these processes produces a waste form
that is relatively safe to transport. Unlike the polymerization technique which involves direct
chemical bonding, applying microencapsulation does not produce a thermodynamically stable
state. Both techniques require further treatment and/or disposal considerations.
3.3.1.3 Conversion to a Less Hazardous Chemical Form. Conversion of organic solvents to other
chemical forms facilitates disposal of this waste. Conversion of these materials may include
several different processes such as oxidation and salting-out techniques. Some of the solvents;
e.g., toluene and xylene, may be oxidized, under mild conditions, to give less hazardous chemical
forms (Roche-Farmer, 1980). Toluene and xylene oxidize to benzoic acid and phthalic acid
respectively. This method would not work for 1,2,4-trimethylbenzene as it does not oxidize
under mild conditions. This process is of special significance for small research facilities like the
EPA laboratories that generate liquid scintillation counting waste since it can be performed
onsite.
3.3.1.4 Incineration and Fuel Blending. Incineration reduces the volume and toxicity of waste
materials by destroying hazardous organic compounds to nonhazardous products such as water
and carbon dioxide. Currently most of the LSC and HPLC wastes generated at EPA facilities are
sent offsite to the Perma-Fix, Gainesville, FL, cement kiln facility where they are used as
supplemental fuel. Advantages of the technique are: it is proven and well-understood; it results
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in almost complete reduction of toxic organics if strict monitoring procedures are emphasized; it
is a low-treatment technology if operated properly; and it eliminates liquids, producing a waste
that is dense and easy to transport. Some of the notable drawbacks of incineration include the
relatively high cost, the risks associated with transportation, and the potential for release of
radioactive materials into the environment. There are also costs associated with disposal of
radioactive ash generated from incineration. The HW standards for owners and operators of
incinerators are contained in 40 CFR 264, Subpart O.
One final waste management option that has been utilized at different laboratories is the
incorporation of LSC waste into fuel. The combustion of toluene and xylene has the capacity to
produce a considerable amount of energy. This represents a simple method of disposal, although
like incineration, radioactive materials are released into the environment. As discussed earlier,
the University of Illinois has burned LSC cocktails as a fuel supplement at its own power plant.
This approach has been approved by NRC and the Illinois Department of Nuclear Safety
provided that the levels of radioisotopes at the point of the release are within specified levels as
defined in 10 CFR 20, Subpart D and 10 CFR 20, Appendix B. In addition, an air quality permit
issued by the Illinois Environmental Protection Agency was required. The regulatory limitations
surrounding fuel mixing are included in Boiler-Industrial-Furnace rules in 40 CFR 266, Subpart
H.
Although public opposition limits the widespread use of fuel blending, this option would provide
a viable waste management option given that EPA laboratories possess the appropriate facilities
(such as an onsite utility boiler or incinerator). Fuel blending is especially conducive to burning
3H and 14C. NERL-RTP currently uses its incinerator to treat LLRW onsite. Small quantity
onsite burner exemptions from obtaining a RCRA Part B Permit are listed in 10 CFR 266.108
based on the allowable HW burning rate in gallons per month. In addition, a conditionally
exempt small quantity generator (CESQG) may treat or dispose of hazardous waste onsite
provided the generator meets certain requirements in 40 CFR Sections 261.5(f)(3) and (g)(3). At
the Mayo Clinic in Rochester, Minnesota, approximately 15,000 gallons of nonhalogenated
organic solvents such as xylene, alcohols, and acetone are burned annually as a source of fuel for
a campus boiler. Extensive use of nonhazardous solvents limits the opportunities for fuel
blending.
3.3.1.5 Bioprocessing. Bioprocessing is an alternative technology that involves the use of
microorganisms which can metabolize aromatic solvents of the type used in LSC waste. The use
of microorganisms serving as biocatalysts in a continuous flow system designed for the
processing of stored liquid scintillation waste has demonstrated success in processing stored,
"hot" LSC waste. Details of the applicability of bioprocessing to treating mixed waste was
presented at the 3rd Biennial Symposium of Mixed Waste in a report entitled "'Bioprocessing' of
Mixed Waste: A Success Story."
A bioprocess demonstration was conducted on commercial formulation of LSC; the initial results
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of this technology indicate that hazardous organic solvents, xylene, and pseudocumene14 have
been removed due to processing. The process was applied to two barrels containing LSC waste
with a tritium radioactive component and pseudocumene-based hazardous constituent. Further
research will determine the applicability of the process to treat EPA generated mixed waste.
Initial results have revealed that bioprocessing can satisfactorily remove certain hazardous
constituents from mixed waste. The technology is considered an alternative to incineration and
could be considered a more environmentally friendly means of treating this waste.
3.3.2 Treatment for HPLC Waste
There is limited documentation on the applicability of specific treatment technologies to HPLC
waste. Generally, the technologies applicable to LSC are also pertinent to treat HPLC waste.
However, the HPLC analyses generally require a wide variety of solvents warranting the need for
management options that are able to isolate these chemicals. Solvent recovery processes such as
distillation may provide as a suitable technology to segregate the target waste.
Separation of the HPLC waste constituents maybe another method of reducing the amount of
waste needed to be treated. HPLC waste containing acetonitrile, methanol, and water can be
separated into fractions that can be disposed of. Distillation and flash evaporation (70-90 °C)
yielded a nonradioactive distillate of acetonitrile, methanol, and water that can be disposed of as
aqueous chemical waste. The still bottom, which represents about 40-50 percent of the original
waste volume, can be discharged to the sanitary sewer as permitted under 10 CFR 20.2003
(Linins et al, 1991).
Using any of the previously mentioned mixed waste treatment procedures onsite for anything
larger than bench-scale experiments will require a RCRA Part B permit as a treatment, storage,
and disposal facility which for small generators can be difficult and expensive to meet.
14Pseudocumene and xylene were the hazardous constituents in 111 Al ft3 (33 percent) of
the total volume of mixed waste generated at EPA laboratories in 1992-1994.
3-18
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SECTION 4: PROFILESOF MIXED WASTE TREATMENT INDUSTRIES
In situations where the generation of mixed waste is unavoidable, several options (referred to as
treatment, storage, and disposal or TSD options) are available depending upon resources,
treatment facility availability and capacity, and the type of material being treated. The hazardous
component may be separated from the radioactive component(s) or destroyed, or the radioactive
component maybe decayed to undetectable levels.
There are currently four operating commercial facilities which treat mixed waste:
• Diversified Scientific Services, Inc. (DSSI)
• Envirocare of Utah, Inc. (Envirocare)
• Perma-Fix of Florida, Inc. (PFF)
• Nuclear Sources and Services Inc./Recovery Services Inc. (NSSI)
Three of these TSD facilities, DSSI, NSSI, and Perma-Fix, represented the management option
for 814.1 ft3 or 97.9 percent of the mixed waste generated by the EPA facilities in 1992-1994.
Perma-Fix was the option employed for 95.7 percent of the waste generated in the3-year study
period.
In addition, two facilities not currently operational are seeking to enter the mixed waste treatment
industry.
Scientific Ecology Group, Inc. (SEG)15
• Molten Metal Technology, Inc. (MMT)
A summary of the treatment facilities' primary waste handled, treatment and disposal process, as
well as planned future treatment or disposal processes for each facility can be found in Table 1.
4.1 DSSI
Opened in 1989, DSSI primarily provides thermal treatment of mixed waste (liquids only) by
combustion of organic-containing waste for energy production. The facility is recognized as a
beneficial reuse facility for RCRA regulated waste because the energy generated through the
thermal process is recovered. DSSI operates a 22,000-square-foot facility located in Kingston,
Tennessee.
DSSI currently has seven permits and licenses associated with the management of mixed waste
which allow them to process wastes with EPA waste codes of D001, D004 - D043, F001 - F005,
and various U- and P-listed materials. Although thermal destruction is the primary treatment
15SEG is awaiting a Hazardous Waste Part B Permit for mixed waste treatment.
4-1
-------
Table 1
Commercial Facilities Overview
Facility
DSSI
Envirocare
NSSI
Perma-Fix
SEG
MMT
Primary Waste
Treated
Organic containing
waste
(Liquids only)
Solid waste
(metals
contamination)
Organic liquids
Scintillation cocktail
waste (including vials)
None
None
Primary Treatment
Processes (in use)
Combustion for energy
recovery
Stabilization (including
chemical oxidation, chemical
reduction, neutralization, and
deactivation in reaction)
Blending to reduce
radioactivity below MFC
values
Blending for offsite treatment
for energy recovery
None
None
Disposal Processes
Stabilization of solid
treatment residue and
burial in Envirocare
Facility
Landfill - Envirocare
operates the only
mixed waste landfill
site
None (transport
blended waste, as
nonradio active, to
offsite facilities)
None (transport
blended fuel off-site)
NA
NA
Future
Processes
None
Macro/Micro -
encapsulation
None
Stabilization
Stabilization
Steam
Reforming
Q-CEP™
Source: Mixed Waste Treatment Study (Draft) prepared by Duke Engineering & Services, Inc. for Electric Power
Research Institute.
process, they are also permitted to process waste through decanting of liquid waste and the
blending of waste. The radioactivity concentration limits can be summed as follows:
• Allows receipt of 2000 isotopes
• The facility can not possess more than 10 curies onsite for atomic numbers 1-83.
• Process or feed stream can not exceed a level of 0.05uCi/g for 3H and 14C
• Process or feed stream can not exceed 0.002uCi/g for all other isotopes
(combined)
Waste with activity levels higher than those described above can be accepted but must be
blended with lower activity waste prior to processing in order to meet the feed limits. The cost
to generators for disposal of low-level mixed waste varies depending on waste characteristics.
The costs to treat low-level mixed waste can be as low as $30 per gallon.
4-2
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4.2 ENVIROCARE
Envirocare, located 75 miles west of Salt Lake City, Utah, was licensed to treat and dispose of
mixed waste in 1993. The treatment technologies used at their facility include chemical
stabilization, chemical oxidation, chemical reduction, chemical deactivation, and neutralization.
The facility has the capacity to treat 150 tons of mixed waste per day. Envirocare has also
applied for a Part B permit for macroencapsulation of contaminated lead shielding. Mixed waste
that is eligible for treatment at Envirocare include EPA waste codes D001-D043, F001-F012,
F019, F024, F028, KOI 1, K013, K050-K052, K061, K069, as well as many P- and U- listed
waste. Envirocare does not publicize any costs relating to waste disposal.
4.3 PERMA-FIX OF FLORIDA (PFF)
Located in Gainesville, Florida, PFF operates two waste management processes, one of which is
for the treatment of mixed waste. This facility provides handling and disposal of liquid
scintillation vials regulated as mixed waste. The vials are processed for ultimate use as a
supplemental fuel in a cement kiln operated by a local corporation. The other facility provides
handling, storage, and disposal of hazardous and nonhazardous wastes.
PFF's current license permits a total of 30 nuclides for liquid scintillation materials and the
materials received, processed, and transported to the kiln may not exceed 0.05 microcuries per
gram of medium. The facility is also trying to receive approval to process additional liquid
scintillation nuclides and other nonliquid scintillation fluids contaminated with radionuclides. In
addition, PFF plans to apply for approval for alternative treatment capabilities such as
stabilization. Depending on waste stream specifics, quantity, and generator location, the cost of
disposing a 7.5 cubic-foot drum of liquid scintillation vials could be $180.
4.4 NSSI
NSSI is located in southeastern Texas and operates a facility which processes radioactive,
hazardous, and mixed wastes, although their primary market is hazardous waste. The mixed
waste that is treated is processed to remove hazardous characteristics and/or to reduce the levels
of radioactivity to below regulatory concentrations. Examples of technologies employed by
NSSI in the treatment process include blending of waste for use as fuel, oxidation, neutralization,
reduction, filtration, solidification or stabilization of waste in containers, etc. NSSFs
classification as a (Texas) Class B facility limits it to a 100-Ci site possession limit. The facility
can process a total of 58,530 gallons of waste at any one time. There is also a total of 179,093
gallons of container storage available. An estimate of treatment costs ranges from $100-$ 150 per
gallon of waste.
4.5 SEG
As described above, this facility, located in Oak Ridge, Tennessee, is currently only permitted to
4-3
-------
process radioactive waste and not mixed waste. The facility has a Part B permit which is
pending which would allow it to process low-level radioactive waste. SEG has applied for
permits to treat mixed waste through both incineration and a steam reforming process. The
steam reforming process is not expected to treat waste having 14C or 3H concentrations greater
than 2 millicuries per drum. The projected cost for treatment of a typical dry active waste is
currently $300 per cubic foot.
4.6 MMT
Molten Metal Technology, Inc. is currently in the process of commercially deploying Quantum-
Catalytic Extraction Process™ (Q-CEP™), a patented technology that can process radioactive
and mixed waste streams to decontaminate and recover resources of commercial value while
reducing volume and stabilizing radionuclides. Fundamental to the Q-CEP™ process is a liquid
metal bath which facilitates the dissociation of waste into their constituent elements. The
addition of co-reactants leads to targeted radionuclide partitioning and recycling of waste
components to commercial products. Q-CEP™ has experienced success in its application to
RCRA waste, spent ion exchange resins, and contaminated scrap metal. Major DOE low-level
mixed waste streams in which Q-CEP™ was applied include soils, inorganic sludges, organic
sludges, combustible debris, and inorganic debris. In cooperation with Lockheed Martin Corp, a
facility designed for processing DOE mixed waste is currently under construction. Cost
estimates of this technique are not published.
4.7 COMPARISON OF TREATMENT AVAILABLE VERSUS DEMAND
AVAILABLE
The volumes of mixed waste generated at EPA research facilities will not pose any discernible
constraints on the capacities of these five TSD facilities. As indicated above, EPA faciities
generated 831.16 ft3 of mixed waste in 1992-1994. This is compared to the over 1.28 million ft3
of annual capacity for the incineration of LSC wastes at the TSD facilities highlighted above.
4-4
-------
SECTION 5: CONCLU3ONS, RECOMMENDATIONS, AND SUGGESTIONS FOR
FURTHER RESEARCH
This report has provided a review of the state-of-the-art waste management technologies as they
relate to mixed waste from laboratories and research facilities. This study is to serve as a guide
to EPA research facility directors and staff in pursuing waste minimization and pollution
prevention efforts. Due to considerable attention in the literature, an integrated waste
management framework is outlined and discussed. The application of integrated approaches to
mixed waste management has experienced encouraging success.
Based on survey data, it was discovered that the processes and mixed waste streams generated at
EPA laboratories were quite similar to those generated at commercial and NIH laboratories.
However, the volumes and curie content of the MW produced from 1992-1994 at the EPA
research facilities was substantially less than these other facilities.
Several of the materials reviewed for this effort presented recommendations and suggestions for
future research that are directly applicable to EPA laboratories. A list of these items is provided
below.
• Systematically evaluate all mixed waste generating processes and identify the
potential for waste minimization and pollution prevention16;
• Formally define pollution prevention goals and evaluate how the goals are to be
met;
• Understand the importance of the waste minimization hierarchy as exemplified in
Figure 5. The hierarchy ranks waste minimization practices in order of
preference, based on their overall efficiency, effectiveness, and environmental
impact. It is important to focus on those methods at the top of the hierarchy;
• Explore the opportunities for the applicability of a flexible regulatory framework;
i.e. filing petitions to demonstrate equivalent treatment or proposing a license-
specific de minimis level for certain radionuclides;
• Establish a formal communication conduit with EPA, commercial, federal, and
academic laboratories to distribute research, suggestions, or innovative
approaches to mixed waste management. The development of programs
16The pollution prevention documents filed by each EPA laboratory may serve as a
starting point.
5-1
-------
FigureS: A Hierarchy of Waste Minimization
(ranked by increasing environmental, occupational, and accidental risk)
Goal
Method
Example
Eliminate Waste
Eliminate Hazard
Reduce Hazard of
Raw Material
Use Less
Buy Less
Use Waste As
Raw Material
Use Waste
Beneficially
Reduce Waste
Volume
Reduce Waste
Hazard
Destroy Waste
Change to process that doesnot
generate waste
Change to process that doesnot
generate a hazardous waste
Substitute hazardous material with
non-hazardous material
Substitute hazardous material with
less hazardous material
Reduce scale of procedure or
process
Minimize surplus
Recycle
Reuse
Recover
Reduce waste volume
Waste treatment
Destruction
Computer simulation or modeling]
Substitute surfactant soaps in
oxidizing acid cleaning baths
f Substitute non-ignitable fluid for
L xylene in scintillation counting
f ;•
Use ammonium persulfate
instead of chromium trioxide in
oxidizing acid cleaning baths
[ Microscaleexperiments J
Buy less or in smaller containers;
constrain acquisition of
degradable chemicals;
\ rp ri igtri hi itp QI i rn 11 K J
Distillation of solvents
Use waste base to neutralize
waste acid
Recover silver from photo labs;
fuel blending of solvents
Bulking or commingling of waste
solvents and acids; precipitate
toxic metals from solution
v. .v
[Reduce oxidizing acids; chelated j
I or stabilize toxic metals J
Incineration
J
Source: Reinhardt, 1995
5-2
-------
analogous to EPA's Waste Reduction Evaluations at Federal Sites (WREAFS)
may serve as a model;
Build on existing attempts to improve pollution prevention that embody the
integrated approach to waste management;
Develop a standardized methodology to evaluate specific waste management
options based on cost, efficiency, and environmental considerations. This implies
the development of a "cradle-to-the-grave" life cycle cost approach; and
Identify barriers to the integrated waste management approach and involve lab
personnel in planning and evaluation.
5-3
-------
SECTION 6: SO URGES CONSULTED
The 1993 Massachusetts Low-Level Radioactive Waste Survey Report, The Massachusetts Low-
Level Radioactive Waste Management Board, [data collection and analysis conducted by
Richard B. Fairfull] November 1994.
Albrect, L.B., Childress, T.A. Infectious and Hazardous Waste Protocol for Medical
Facilities,March 1991, 129 pp., Report no. AL-TR-91-0047.
American Chemical Society Task Force on Laboratory Waste Management, Less is Better:
Laboratory Chemical Management for Waste Reduction, 2nd edition, 1993.
Anderson, William C. (Edited) "Innovative site remediation technology: Chemical Treatment
Vol. 2", September 1994, EPA 542-B-94-004.
Berenyi, Eileen Brettler. "MRFs are Bustin' Out All Over," Resource Recycling: North
America's Recycling, April 1, 1995, 14, 4, pp. 28.
Berry, Robert O.; Jablonski, Susan M.; "Low-Level Radioactive Waste Management at Texas
A&M University," Radwaste Magazine, September 1995, 2, 5, pp. 39-41.
Community Partnering Plan Summary, Bureau of Radiation Protection, Pennsylvania
Department of Environmental Protection.
Dagan, E.B.; Selby K.B. Mixed Waste and Waste Minimization; The Effect of Regulations and
Waste Minimization in the Laboratory, Proceedings of the 2nd Biennial Symposium of
Mixed Waste, Baltimore, MD, August 1993.
Elliott, John C. "Liquid Scintillation Sample Analysis in Microcentrifuge Tubes," Health
Physics, January 1993, Volume 64, Number 1, pp.86-90.
Fax, Gene; Young, Chuck. Site Visit to the Harvard University Storage and Incinerator Facility,
The Cadmus Group, August 8, 1995.
Gibbons, J.H. Partnerships Under Pressure. Managing Commercial Low-Level Radioactive
Waste, November 1989, 159 pp., Report no. OTA-O-426.
Gershey, Edward L.; Klein, Robert C.; Party, Esmeralda Perry; Wilkerson, Amy. Low-Level
Radioactive Waste: From Cradle to Grave, New York: VanNostrand Reinhold, 1990.
Gillins, R.L.; DeWitt, L.M.; Wollerman, A.L. Mixed Waste Integrated Program Interim
Evaluation Report on Thermal Treatment Technologies, February 1993, Report No.
DOE/MWIP-2.
6-1
-------
Hamawy, George; Passler, Carl; "The Decay-in-Storage Room at the Einstein College of
Medicine," Radwaste Magazine, March 1995, 2, 2, pp. 14-17.
Hawkins, Edward F. "Solid Scintillators for Receptor Assays: An Environmentally Safe
Alternative to Liquid Scintillation Cocktails,"/. Receptor Research, 11 (1-4): pp. 91-99.
Health Physics Positions Data Base (Rev 1), "Disposal of Solid Scintillation Media," February
1994, Report No. NUREG/CR-5569, pp.140.
Incineration of Low-Level Radioactive and Mixed Wastes: Applicable Regulations and Policies,
July 1993, prepared for EPA - ORIA.
Incineration of Low-Level Radioactive and Mixed Wastes: Waste Handling and Operational
Issues, April 1993, 142 pp., Report No. EPA/402/R-93/012.
Issue Paper From the NGA FFCA Commercial Mixed Waste Subgroup, The National Governors
Association, 1995.
Kirner, N.P.; Faison, G.P.; Johnson, D.R. National Institutes of Health: Mixed Waste Stream
Analysis, August 1994, Report No. DOE/LLW-208.
Kirner, Nancy; Kelly, James; Faison, George, Johnson, Dave. Mixed Waste Management
Options: 1995 Update, Idaho National Engineering Laboratory, prepared for the U.S.
Department of Energy, May 1995, Report No. DOE/LLW-219.
Klein, J.A.; Mrochek, J.E.; Jolley, R.L.; Osborne-Lee, I.W.; Francis, A.A.; Wright, T. National
Profile on Commercially Generated Low-Level Radioactive Mixed Waste, December
1992, Report no. NUREG/CR-5938.
Klein, Robert C. and Gershey, Edward L. "'Biodegradable' Liquid Scintillation Counting
Cocktails," Health Physics, October 1992, 59, 4, pp.461-470.
Krolewski, J.F.; Augsburger, S.T. Consolidated Incineration Facility Model Videotape, 1988, 12
pp., Report no. DP-MS-88-68.
Lewandowski, Joseph J.; Moghissi, A. Alan. "Management of Mixed Waste at a Teaching,
Research, and Health Care Facility," Proceedings of the 3rd Biennial Symposium of
Mixed Waste, Baltimore, MD, August 1995.
Linins, Ilona; Klein, Robert C.; Gershey, Edward L.; "Management of Mixed Wastes from
Biomedical Research," Health Physics, September 1991, 61, 3, pp. 421-426.
Lorenz, Steven M. "Decreasing Dry Active Waste Generation by 50% in One Year," Radwaste
6-2
-------
Magazine, Sept. 1995, 2, 5, pp. 47-49.
Lorenzen, William A. Operational Aspects of Harvard University's Waste Management
Program, pp. 415-420, August 1995 [Attachment to Fax and Young, August, 1995].
Low-Level Radioactive Waste Management in North Carolina, Briefing prepared by the North
Carolina Department of Environment, Health and Natural Resources, Division of
Radiation Protection, 1994.
Low-level Radioactive Waste Storage Study: Interim Report, prepared by the New York State
Energy Research and Development Authority, July 1993.
Low-level Radioactive Waste Storage Study: Volume I: Storage Capacity at Generator Sites,
prepared by the New York State Energy Research and Development Authority,
September 1993.
Lussiez, G.W. "Decontaminating Lead Bricks and Shielding," Proceedings of the 2nd Biennial
Symposium of Mixed Waste, Baltimore, MD, August 1993.
Malchman, Warren. "Case Western Reserve University's New 'State-of-the-Art' Low-Level
Waste Facility," Radwaste, September 1995, pp. 42-46.
Methe, Brian M. "Managing Radioactively Contaminated Infectious Waste at a Large
Biomedical Facility," Health Physics, February 1993, Volume 64, Number 2, pp.187-191.
McCamey, R.B. "Building a Mixed-Waste Prevention Program at Comanche Peak", Radwaste
Magazine, May 1995, 2, 3, pp.21-28.
McElroy, N.L.; Sauerbrunn, B.J.L.; Eckelman, W.C. "The Feasibility of Recycling Glass Liquid
Scintillation Vials," Health Physics, February 1982, Volume 42, Number 2, pp. 236-238.
"Mixed Lab Waste: Is it All Radioactive?" Research & Development, August 1, 1994, 36, 9, pp.
27-32.
The Mixed Waste Inventory Report, Idaho National Engineering Laboratory, Prepared for the
U.S. Department of Energy, November 1995.
Mixed Waste Treatment Study (Draft), Prepared for the Electric Power Research Institute,
Research Project 3800-22, December 1995.
Miyatake, H; Saito, K. "Distillation of Used Liquid Scintillation Cocktail and the Possibility of
Re-utilization of the Recovered Solvent," March 1984, Radioisotopes, 33(3): pp. 146-149.
6-3
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Monthly RCRA/Superfund ffiPCRA Hotline Report, February 1996.
Monthly RCRA/Superfund ffiPCRA Hotline Report, April 1996.
National Institutes of Health: Mixed Waste Minimization and Treatment, Prepared for Lockheed
Idaho Technologies Company and U.S. DOE, August 1995, Report # DOE/LLW-218.
Oden, L.L.; O'Connor, W.K.; Turner, P.C.; Hartman, A.D. Evaluation of the Three-Phase,
Electric Arc Melting Furnace for Treatment of Simulated, Thermally Oxidized
Radioactive and Mixed Wastes, 1995, 26 pp., Report No. BUMINES-RI-9528.
Party, E.; Gershey, E.L. "Recommendations for Radioactive Waste Reduction in
Biomedical/Academic Institutions," Health Physics, April 1989, Volume 56, Number 4,
pp. 571-572.
Prudent Practices in the Laboratory: Handling and Disposal of Chemicals, The National
Research Council, National Academy Press, Washington, DC, 1995.
Radioactive and Mixed Waste Incineration. Background Information Document Volume 1:
Technology, May 1991, prepared for U.S. EPA, Office of Radiation Programs.
Ed. by Reinhardt, Peter A; Leonard, K. Leigh; Ashbrook, Peter C.; Pollution Prevention and
Waste Minimization in Laboratories, Boca Raton, FL: CRC Press, 1996.
Ring, Joseph; Lorenzen, William; Osborne, Frank; Shapiro, Jacob; Bio-medical Radioactive
Waste Management, July 19, 1995 [Attachment to Fax and Young, August, 1995].
Roche-Farmer, Lidia. Study of Alternative Methods for the Management of Liquid Scintillation
Counting Wastes, Division of Fuel Cycle and Material Safety, NRC, February 1980,
Report No. NUREG-0656
Rupp. G.L. Characterizing Containerized Mixed Low-Level Waste for Treatment: A Workshop
Proceeding, May 1993, 312 pp., Report no. EPA/600/R-94/149.
Schwinkendorf, William E.; Brown, Clifton H. "Mixed Waste Separation Technologies,"
Separation Science and Technology, 1995, 30, 7-9, pp. 1725-40.
Science Applications International Corporation. Pollution Prevention Opportunity Assessment
for Two Laboratories at Sandia National Laboratories, U.S. EPA Risk Reduction
Engineering Laboratory, March 1993, Report # EPA/600/SR-93/015.
Todisco, L.R.; Smith L.R. "A Manufacturer's Perspective on Low-Level Mixed Waste
Treatment, Storage, and Disposal," E.I. Dupont and Co., Inc., NEN Products,
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Proceedings of the 3rd Biennial Symposium of Mixed Waste, Baltimore, MD, August
1995,10pp.
Tyson, D. R. "Treatability Study for the Amalgamation of a Radioactively Contaminated
Elemental Mercury Waste at the Idaho National Engineering Laboratory," Proceedings of
the 2nd Biennial Symposium of Mixed Waste, Baltimore, MD, August 1993.
Vavruska, J.S.; Borduin, L.C.; Hutchins, D.A.; Koenig, R.A.; Warner, C.L. Los Alamos
Controlled Air Incinerator for Hazardous Chemical and Mixed Radioactive Wastes,
1986, 11 pp., Report no. LA-UR-86-614.
Wahl, George; Stamm, Deana; Driver, Jeffrey; Cravens, Joe Bob. Pollution Prevention
Opportunity Assessment: Histology Laboratory Xylene Use Fort Carson, Colorado, U.S.
EPA Risk Reduction Engineering Laboratory, October 1992, Report # EPA/600/SR-
92/187.
Warner, G.T.; Potter, C.G.; Yrjonen, T.; Soini, E. "A New Design for a Liquid Scintillation
Counter for Micro-Samples using a Flat-Bed Geometry," International J. Applied
Radiation Isotopes, 1985, 36(10) pp.819-821.
Warner, G.T.; Potter, C.G. "New Liquid Scintillation Counter Eases Vial Disposal Problems,"
Health Physics, 1986, 51(3): pp. 385.
Wolfram, J.H. and Rogers, R.D. [Idaho National Engineering Laboratory] and Finney, R; Attala
A.; Silver, G.L.; and Hertwick, F. Jr. [Mound Applied Technologies] "Bioprocessing of
Mixed Waste: A Success Story," Proceedings of the 3rd Biennial Symposium of Mixed
Waste, Baltimore, MD, August 1995.
Wunderly, Stephen W. "Solid Scintillation Counting: A New Technique for Measuring
Radiolabeled Compounds," Appl. Radiat. Isot, 1989, 40(7), pp. 569-573.
6-5
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APPENDIX A: RESULTS OF EPA LABORATORY SURVEY: DATA SUM MARY REPORT
A.1 INTRODUCTION AND OVERVIEW
The high costs of mixed waste management and the limited treatment, storage, and disposal
capacity for mixed waste prompted EPA laboratory staff to approach EPA headquarters staff to
investigate mixed waste generated from laboratory procedures. Mixed waste is composed of
radioactive waste defined under the Atomic Energy Act (AEA) and hazardous waste defined
under the Resource Conservation and Recovery Act (RCRA). Currently there are only four
mixed waste treatment, storage, or disposal facilities (TSDFs) in the United States accepting
commercially generated mixed waste and no treatment or disposal options exist for certain
classes of mixed waste. Indefinite storage is the only option for mixed waste with no treatment
or disposal capacity.
The U.S. Environmental Protection Agency's (EPA) Office of Radiation and Indoor Air (ORIA),
Office of Solid Waste (OSW), and Office of Administration/Safety, Health, and Environmental
Management Division (SHEMD) responded to this request and created a cross-office team to
investigate the issue of mixed waste generated from EPA laboratories. The first step in this
investigation was to quantify and characterize the low-level radioactive waste and mixed waste
generated by EPA laboratories. This report details the results of a survey of 11 EPA facilities
that were presumed to generate low-level radioactive waste or mixed waste. Comparisons of
findings will be made with other surveys, notably the National Profile on Commercially
Generated Low-Level Radioactive Mixed and the NIH: Mixed Waste Stream Analysis.
Ten laboratories submitted completed surveys. The remaining laboratory, EPA Region 9
Laboratory, does not generate either mixed waste or low-level radioactive waste. A preliminary
investigation of the survey results indicates that the waste produced is generated from relatively
few processes. Thus, waste minimization efforts can be centrally focused on the use,
distribution, and management of these processes.
This data summary report is organized into six sections. Following this introduction, profiles of
the nine EPA laboratories are presented in Section 2. Sections 3 and 4 provide an overview of
low-level radioactive waste and mixed waste, respectively. Section 5 examines the results of this
effort within the context of other survey efforts that parallel this study. The final section, Section
6, provides a conclusion to this report.
A-l
-------
A.2 PRORLESOFNINEB'ALABORATORIESGBJBRATINGMWORLLRVV
Generation of mixed waste accounted for 20.6 percent of the total mixed and low-level
radioactive wastes generated in the 3-year time period studied (Figure A-l). Of the EPA
laboratories queried, the leading generator of low-level radioactive and mixed wastes in 1992-
1994 was the North Carolina Research Triangle Park (RTP) laboratory complex. This complex
is composed of components of three labs - NHEERL, NERL, and NRMRL. The mixed waste
generated at the EPA RTP laboratory complex is almost exclusively produced by NHEERL
researchers.17 Combined these RTP laboratories generate 82.9 percent of the total low-level
radioactive waste (Figure A-2) and 65.9 percent of the total mixed waste (Figure A-3) in these 3
years. The second leading generator for both categories of waste was the National Risk
Management Research Laboratory in Cincinnati with 4.4 percent of the LLRW and 29.3 percent
of the mixed waste. Attachment A-1 lists the applicable hazardous and radioactive waste permits
for the nine EPA laboratories that provided survey responses. Table A-l provides a summary of
the volumes of the mixed and low-level wastes generated by each laboratory.
Table A-l: Summary of the MW and LLRW Volumes for EPA Laboratories: 1992-1994
Laboratory
CRL
GED-Gulf
NAREL
NERL-LV
NERL-RTP
NHEERL-
AED
NHEERL-
MED
NHEERL-
WED
NRMRL-
Breidenbach
NRMRL-Kerr
Totals
Volume (ft3) by Year
1992
MW
0
0
0
0
210.5
0
0.02
1.4
86.5
4
302.42
LLRW
4
34
7.5
23.5
1038
9
0.25
50.3
23.84
26.5
1216.89
1993
MW
0
0
0
0
127.5
0
0.02
1.7
42.55
16
187.77
LLRW
4
34
7.5
22
632.5
6
0.25
5.1
39.84
29.5
780.69
1994
MW
0
0
0
4
210
2
0.02
2.64
114.81
7.5
340.97
LLRW
47.3
34
7.5
31
987.9
3.5
0.27
12.72
76.5
8.1
1208.79
3 -Year Totals
MW
0
0
0
4
548
2
0.06
5.74
243.86
27.5
831.16
LLRW
55.3
102
22.5
76.5
2658.4
18.5
0.77
68.12
140.18
64.1
3206.37
17 Personal correspondence from Todd Baker (RTP) to Jeff Davidson (OA/SHEMD), July
23, 1996.
A-2
-------
(cubic feet)
1216.8980.1%
780.69 80.6%
1992 \
1993
302.4219.9%
187.7719.4%
1208.7978.0%
3206.37 79.4%
831.1620.6%
LLRW MW
Figure A-l. EPA LLRW/MW Production
innnn
1 nnn
*^ *\r\n
1
Af\
l\J
4
Top Four Generators
LL
-
RV
E
•
i/-
]
1
92
RTP
NERL-LV
LL
~~
RV
• •-,
r
i/ - 93 LLRW - 94
NRMRL-Breidenbach
NHEERL-WED
Figure A-2. LLRW Production
A-3
-------
Top Three Generators
1000
100
MW-92
RTF
MW-93
NRMRL-Breidenbach
MW-94
NRMRL-Kerr
Figure A-3. MW Production
The trend in low-level waste to mixed waste production can be seen in Figure A-l to be fairly
uniform at 4:1. This 4:1 ratio from the 3-year survey should be representative of current and
future EPA laboratory LLRW/MW production ratios if no further future action is taken.
As shown in Figures A-2 and A-3, there are few observable trends from a 3-year analysis of each
EPA facilities' LLRW and MW production rates. The largest LLRW and MW producer, NERL-
RTP facility with 82.9 percent of the total LLRW production and 65.9 percent of the total MW
production, has no observable trend in LLRW and MW production. Both NERL-RTP LLRW
and MW production rates seem relatively constant. There is, however, a threefold increase in
LLRW production rates from the NRMRL-Breidenbach facility from 23.84 ft3 (1992) to 76.5 ft3
(1994). The other noticeable trend is the fourfold decrease in MW production from the
NHEERL-WED facility from 50.3 ft3 (1992) to 12.72 ft3 (1994).
A-4
-------
A.3 OVERVIEW OF LOW-LEVEL RADIOACTIVE WASTE GENERATED AT EPA
LABORATORIES
As indicated in Table A-l, 3206.37 ft3 of low-level radioactive waste were generated over the 3
study years by EPA facilities. It is worth noting that in 1993 total LLRW produced by all EPA
facilities dropped 64 percent from 1992 production rates; but production rates climbed back to
1992 levels in 1994. Figure A-4 shows the major LLW stream numbers (LLW#) that contribute
to the total LLRW production for all EPA facilities over the 3 years studied. Attachment A-2
describes each LLW stream number and waste management option used in this survey. The top
four LLW# categories which contribute the largest percentages by volume are: 1) trash and/or
solid waste (LLW #202): 1266.5 ft3 or 39.5 percent; 2) liquid scintillation fluids or vials (LLW
#215): 730.54 ft3 or 22.8 percent; 3) Other (LLW #226): 539.2 ft3 or 16.8 percent; and absorbed
aqueous liquids (LLW #212): 309.5 ft3 or 9.7 percent. Tables 2 and 3 display the volumes
generated by each laboratory grouped by LLW number and the volume associated with each
waste management option, respectively.
Major LLW#
cubic feet (1992-1994)
Figure A-4. Major LLW# Volumes
Twelve waste management options were reported by these laboratories. A brief discussion of
each of these designations is presented in Attachment A-2. As shown in Figure A-5 and Table
A-3, permanent offsite disposal/treatment facilities (Barnwell, Hanford, Perma-Fix, and SEG)
A-5
-------
Table A-2: Volumes of LLRW for Each EPA Laboratory Grouped by LLW#: 1992-1994
Laboratory
CRL
GED-Gulf
NAREL
NERL-LV
RTF
NHEERL-AED
NHEERL-MED
NHEERL-WED
NRMRL-
Breidenbach
NRMRL-Kerr
Totals
Year
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
Totals (1992-1994)
LLRW Stream #
201
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
2
0
0
2
2011
0
0
0
0
0
0
0
0
0
0
0
0
0
33
14.9
0
0
0
0.25
0.25
0.25
0
0
0
0
15
20
0
0
0
0.25
48.25
35.15
83.65
2011/2012
0
0
0
0
0
0
0
0
0
0
0
0
29.5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
29.5
0
0
29.5
2013
0
0
0
0
0
0
0
0
0
0
0
0
0
13
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
0
13
202
0
0
0
30
30
30
7.5
7.5
7.5
22.5
21
30
343
274
341
0
0
0
0
0
0
12
2
8.5
22.5
23
54.5
0
0
0
437.5
357.5
471.5
1266.5
203
0
0
23.2
0
0
0
0
0
0
0
0
0
87.5
0
60
7
5
3
0
0
0
0
0
0
0
0
0
0
7.5
0
94.5
12.5
86.2
193.2
207
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
14
0
0.7
0
0
0
0
0
0
14
0
0.7
14.7
212
0
0
0
4
4
4
0
0
0
0
0
0
200
8.5
86.5
1
1
0.5
0
0
0
0
0
0
0
0
0
0
0
0
205
13.5
91
309.5
215
4
4
19.7
0
0
0
0
0
0
1
1
1
183
138
321.5
0
0
0
0
0
0
2.7
0.8
2.24
0
0
0
25.5
20
6.1
216.2
163.8
350.54
730.54
216
0
0
0
0
0
0
0
0
0
0
0
0
6
0
4
0
0
0
0
0
0
0
0
0
0
0.5
1.5
1
2
2
7
2.5
7.5
17
216/219
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.34
0
0
0
0
0
1.34
0
0
1.34
219
0
0
4.4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.02
0
0
0
0
1.34
0.5
0
0
0
0
1.34
4.92
6.26
226
0
0
0
0
0
0
0
0
0
0
0
0
189
166
160
1
0
0
0
0
0
19.6
2.3
1.28
0
0
0
0
0
0
209.6
168.3
161.28
539.2
Totals
4
4
47.3
34
34
34
7.5
7.5
7.5
23.5
22
31
1038
632.5
987.9
9
6
3.5
0.25
0.25
0.27
50.3
5.1
12.72
23.84
39.84
76.5
26.5
29.5
8.1
1216.89
780.69
1208.79
3206.37
A-6
-------
Table A-3: LLW Management Option Volume Grouped by EPA Laboratory: 1992-1994
Laboratory
CRL
GED-Gulf
NAREL
NERL-LV
RTF
NHEERL-
AED
NHEERL-
MED
NHEERL-
WED
NRMRL-
Breidenbach
NRMRL-
Kerr
Totals
Waste Management Option*
Air
Release
0
0
0
0
0
0
0
14.7
0
0
14.7
Barnwell
27.6
0
22.5
0
147.5
0
0
0
96.84
0
294.44
Decay
0
45
0
0
3
0
0
17
4.5
7.5
77
Hanford
0
0
0
43.5
0
0
0
24.5
0
0
68
In-storage
0
51
0
30
4
0
0.75
0
0
0
85.75
Manu.
0
0
0
0
0
0
0.02
0
0
0
0.02
Und.
0
0
0
0
0
18.5
0
0
0
0
18.5
Perma-
Fix
0
0
0
0
7.5
0
0
4.84
0
0
12.34
SEG/
Barnwell
0
0
0
0
0
0
0
0
15
0
15
Self
0
0
0
0
1981.4
0
0
0
0
0
1981.4
Sewer
27.7
6
0
3
515
0
0
7.08
0
56.6
615.38
Wash.
0
0
0
0
0
0
0
0
23.84
0
23.84
Totals
55.3
102
22.5
76.5
2658.4
18.5
0.77
68.12
140.18
64.1
3206.37
* See Attachment A-2 for further explanation.
A-7
-------
represented the waste management option for 389.78 ft3 (12.2 percent) of the total LLRW.18 An
onsite incinerator and disposal facility at the National Exposure Research Laboratory in Research
Triangle Park (designated "self) was the disposal option for 1981.4 ft3 (61.8 percent). Permitted
sanitary sewer disposal was used for 615.4 ft3 (19.2 percent) at four of the EPA queried
laboratories.
cubic feet (1992-1994)
Figure A-5. LLW Management Option Volumes
Table A^ summarizes the volume and activity of LLRW generated by radioactive waste
grouping as reported by the laboratory staff.19 It should be noted that while a wide variety of
radionuclides are used in EPA facilities, the four most common radionuclides,14C, 3H, 32P, and
35S, make up at least 2,615.71 ft3 or 81.6 percent of the total LLRW volume (3,206.37 ft3) and at
least 1,479.0 mCi or 88.9 percent of the total LLRW activity (1,664.1 mCi).
18For the purposes of Figure A-5, the "offsite" option includes both Wash, and Manu.
whereas the "onsite" designation encompasses air-release and decay. Attachment A-2 describes
these options in more detail.
19Volumes for each radionuclide and each waste generating process were not itemized in
the survey.
-------
Table A-4: Volume of Radionuclide Groupings for EPA Laboratory Generated LLRW:
1992-1994
Radionuclide Group
NERL-LV20
45Ca
14p
14C,73As
14C,3H,63Ni
36C1
51Cr
125j
125I,73As,51Cr
59Fe
63Ni
63Ni,241Am,226Ra,60Co,238U,3H,14C,137Cs
32p
32P,51Cr
32P,35S
32P,33P,35S,73As,125I
106Ru,204Tl
35Su
3H
3H,14C
3H,14C,51Cr, 125I
U,Th,Eu
3H,14C,32P,35S
241Am, 239Pu
90Sr, 234U, 238U, 230Th, 232Th, 60Co, 137Cs, 109Cd,
226Ra, 228Ra
Totals
Volume (ft3): 1992-1994
Totals
76.5
2
180.34
4
1.34
2
0.1
10
87.5
8.5
3.56
0.5
17.5
7
6
189
0
51
100.4
1477.13
60
1
572.5
7.5
15
3206.37
Cumulative
Activity (mCi)
16.49
0.033
421.8925
0.1
181.097
0.004
0.2
0.1
16.2
0.0020045
135
118.5
179.925
decayed
0.03
14.3
0.001
16.35
284.095
173.479
14.6
not provided
91
0.7
0.003
1664.1
20Approximately 40 radionuclides existed for each generating process at this laboratory.
A-9
-------
A.3.1 LLRW Deemed Undisposable
One EPA laboratory labeled a portion of their LLRW as undisposable. The National Health &
Environment Effects Research Laboratory in Narragansett reported that a significant portion of
the waste generated in 1992-1994 was undisposable. The two LLRW generating processes, trash
and counting (LLW Stream #s 203 and 212, respectively), accounted for 17.5 ft3 of undisposable
LLW generated over the 3-year period. The Narragansett facility was only able to dispose of one
ft3 of LLW over the 3-year period studied. The principal radionuclides in the Narragansett
undisposable waste consist of 3H and 14C. While management options are currently being
examined, the state of Rhode Island is anoncompact state and generators of radioactive waste
must store the material on-site until an agreement with a disposal facility has been established.
A.3.2 Cost Information for Treatment and Disposal of LLRW
Incomplete cost information for ultimate disposal was provided for four of the waste disposal
facilities. These facilities included Barnwell, Hanford, Perma-Fix, and a combination of SEG
and Barnwell. The table below provides a summary of the cost information provided for each of
these facilities along with the number of instances in which cost information was not provided.
Based on the data provided, the typical cost for LLRW at the Barnwell facility, in 1994 dollars, is
101 $/ft3.
Table A-5: Cost Information for Disposal Facilities: LLRW
Facility
Barnwell
Perma-Fix
SEG/Barnwell
Hanford
Year
1992
1994
1994
1994
not provided
1993
Cost ($/ft3)
60
67
135
30
not provided
524
Number of
No Responses
5
3
1
7
A-10
-------
A.4 DETAILS} MIXED WASTEPROFILEOFEPA LABORATORIES
Of the 10 EPA laboratories surveyed, 8 reported to have generated mixed waste in the 1992-1994
time period totaling 831.16 ft3. This section is designed to provide detailed investigations into
the processes, activity, volumetric parameters, and waste management options of this mixed
waste. The information is presented in tabular and graphical format to help elucidate the waste
characteristics. The hazardous and radioactive components are also analyzed.
Tables A-6 and A-7 delineate the volumes of waste generated by LLW Stream Number and
mixed waste generating process. The survey results indicate that only four LLW Stream
Numbers and two generating processes are generally applicable for the mixed waste produced by
EPA laboratories. Liquid Scintillation Fluids containing 14C or 3H (LLW #215) represented the
largest volume, 423.91 ft3 or 51.0 percent by LLW Stream Number (Figure A-6) and waste
produced for liquid scintillation counting procedures represent the largest volume 598.66 ft3 or
72.0 percent by process category (Figure A-7).
There are no discernible trends in the quantities of mixed waste generated in the 1992-1994 time
period, although the greatest volume of mixed waste was produced in 1994 (340.97 ft3 or 41.0
percent of the 3-year total). This is largely attributable to the increase in the amount of LLW
Stream #215 (liquid scintillation fluids or vials) generated in 1994. Similarly, mixed waste
generated from HPLC counting procedures in 1994 accounted for 105 ft3, which represented a 75
percent increase from 1993.
A-ll
-------
cubic feet (1992-1994)
Figure A-6. MW Volume by LLW#
cubic feet (1992-1994)
\ \
\
Figure A-7. MW Volume by Process
A-12
-------
A-13
-------
Table A-6: Volume (ft3) of MW Grouped by LLW Stream No.: 1992-1994
Laboratory
NERL-LV
RTF
NHEERL-AED
NHEERL-MED
NHEERL-WED
NRMRL-
Breidenbach
NRMRL-Kerr
Totals
Year
94
92
93
94
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
Totals 1992-1994
LLW Stream No.
214
0
67.5
60
105
0
0
0
0
0
0
0
0
0
0
0
0
0
67.5
60
105
232.5
215
4
71.5
33.75
52.5
0
0.02
0.02
0.02
1.4
1.7
2.64
86.5
42.55
114.81
4
1
7.5
163.42
79.02
181.47
423.91
216
0
71.5
33.75
52.5
2
0
0
0
0
0
0
0
0
0
0
0
0
71.5
33.75
54.5
159.75
226
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
15
0
0
15
0
15
Totals
4
210.5
127.5
210
2
0.02
0.02
0.02
1.4
1.7
2.64
86.5
42.55
114.81
4
16
7.5
302.42
187.77
340.97
831.16
A-14
-------
Table A-7: Volume (ft3) of MW Grouped by Process: 1992-1994
Laboratory
NERL-LV
RTF
NHEERL-AED
NHEERL-MED
NHEERL-WED
NRMRL-
Breidenbach
NRMRL-Kerr
Totals
Year
94
92
93
94
94
92
93
94
92
93
94
92
93
94
92
93
94
92
93
94
Totals 1992-1994
Generating Process
HPLC Counting
0
67.5
60
105
0
0
0
0
0
0
0
0
0
0
0
0
0
67.5
60
105
232.5
LSC
4
143
67.5
105
0
0.02
0.02
0.02
1.4
1.7
2.64
86.5
42.55
114.81
4
16
7.5
234.92
127.77
235.97
598.66
Totals
4
210.5
127.5
210
2
0.02
0.02
0.02
1.4
1.7
2.64
86.5
42.55
114.81
4
16
7.5
302.42
187.77
340.97
831.16
A-15
-------
A.4.1 Analysis of Hazardous Component of Mixed Waste Generated
Tables A-8, A-9, and A-10 provide the details of the hazardous components of the mixed waste
reported by the EPA laboratories. Volume and activity of the grouped hazardous waste
component of the MW is presented in Table A-8, while the volume percent of waste with
chemicals present versus RCRA HW # are depicted in Tables A-9 and A-10, respectively. The
principal hazardous chemicals included methanol, toluene, xylene, and 1,2,4 trimethylbenzene.
RCRA hazardous waste numbers D001, F003, and F005 represented the primary HW#s cited.
Table A-8: Volume and Activity of Grouped Hazardous Waste Components of MW:
1992- 1994 Totals
Grouped Hazardous Component
methanol; toluene; 1,2,4 trimethylbenzene
methanol; toluene; chloroform; 1,2,4
trimethylbenzene
methanol; toluene; 1,2,4 trimethylbenzene;
acetone
pseudocumene
pseudocumene; xylene
pseudocumene; xylene; benzene
toluene
toluene; xylene
toluene; 1,2,4 trimethylbenzene
toluene; 1,2,4 trimethylbenzene; chloroform
toluene; 1,2,4 trimethylbenzene;
chloroform; ethanol
xylene; TCE; PCE; BTEX
xylene
Totals
Waste Generating Process
and Volume (ft3)
HPLC Counting
[LLW #]
67.5 [214]
60 [214]
105 [214]
0
0
0
0
0
0
0
0
0
0
232.5
LSC
[LLW #]
0
0
0
15.06 [215, 226]
4 [215]
7.5 [215]
5.74 [215]
247.86 [215]
143 [215, 216]
67.5 [215, 216]
105 [215, 216]
1 [215]
2 [216]
598.66
Cum. Activity
(mCi)
0.4
0.8
1
0.0300059
0.000004
0.0000052
0.515
53.4676
1.8
1.5
1.4
0.0000086
not provided
60.9126237
A-16
-------
Table A-9: Volume Percent of Waste with Chemicals Present versus
Waste Generating Process
Hazardous Component
methanol
toluene
1,2,4 trimethylbenzene
chloroform
acetone
pseudocumene
xylene
benzene
ethanol
TCE
PCE
BTEX
Process
HPLC Counting
100
100
100
25.8
45.2
0
0
0
0
0
0
0
LSC
0
95.1
52.7
28.8
0
4.4
43.8
1.3
17.5
0.17
0.17
0.17
Table A-10: Volume Percent of Waste using RCRA HW # versus Waste Generating Process
RCRA HW #
D001
D002
D006
D018
D022
D039
D040
F003
F005
F006
Process
HPLC Counting
100
0
0
0
25.8
0
0
100
100
0
LSC
99.9
5.6
0.33
1.4
23.2
0.17
0.17
41.4
94.1
0.34
A-17
-------
A.4.2 Analysis of Radioactive Component of Mixed Waste Generated
Table A-l 1 details the radioactive components of the mixed waste generated by EPA laboratories
in the 1992-1994 time period. It is notable that the principal radionuclides are quite similar to the
one produced in the LLRW waste analysis highlighted above. The 14C and 3H combination used
in the liquid scintillation counting procedure accounted for 374.91 ft3 or 45.1 percent of the
mixed waste generated over the 3-year study period. The activity of this grouped component was
55.78 mCi or 91.6 percent which by far represented the largest activity of any other radionuclide
group. If 32P, 45Ca, and 35S are also included with 14C and 3H, these radionuclides represent
596.66 ft3 or 99.7 percent of the total mixed waste generated and virtually all of the total mixed
waste activity.
Table A-l 1: Volume and Activity of Grouped Radioactive Waste Components of MW:
1992- 1994 Totals
Grouped Radioactive Component
14C
45Ca, 32P, 35S
3H
Ni, Cd
32P, 45Ca
3H, 14C
3H, 14C, 32P
3H, 14C, 36C1
3H, 14C, 32P, 45Ca
3H, 14C, 35S, 32P, 45Ca
Totals
Process Volume (ft3)
HPLC
Counting
0
0
0
0
0
0
60
0
67.5
105
232.5
LSC
15
86.25
4
2
71.5
374.91
0
45
0
0
598.66
Cum. Activity
(mCi)
0.0000059
0.4
0.01
not provided
0.1
55.782618
0.8
2.42
0.4
1
60.9126237
A.4.3 Mixed Waste in Storage
The results of the survey indicate that .06 ft3 of the mixed waste generated in the 1992-1994 time
period is being stored for accumulation. The National Health & Environmental Effects Research
Laboratory in Duluth has produced .02 ft3 of mixed waste from liquid scintillation counting
A-l 8
-------
procedures each year consisting of 14C, 3H, and pseudocumene. The waste is to be disposed
pending production of sufficient volume to make it economically reasonable to ship. NHEERL-
MED staff are currently negotiating with TSD facilities to determine the most cost-effective
treatment option. It is anticipated that the accumulated waste will be shipped to a TSD facility in
the summer of 1996.
A.4.4 Waste Management Options for EPA Laboratory Mixed Waste
Six identifiable waste management options were selected for the mixed waste generated by the
seven laboratories. Figure A-8 displays aggregated waste management option information. The
details of the volumes of these options for each laboratory are presented in Table A-12.
Overwhelmingly, the three treatment/disposal facilities, DSSI, NSSI, and Perma-Fix, represented
the most extensively used management option. Of the mixed waste generated in 1992-1994,
814.1 ft3 or 97.9 percent was transported to one of these facilities. Perma-Fix received 95.7
percent of this amount.
cubic feet (1992-1994)
Figure A-8. MW Management Option Volume
A-19
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Table A- 12: MW Management Option Volume (ft3): 1992-1994
Laboratory
NERL-LV
RTF
NHEERL-
AED
NHEERL-
MED
NHEERL-
WED
NRMRL-
Breidenbach
NRMRL-Kerr
Totals
Waste Management Option
DSSI/NSSI
0
0
0
0
0
6.01
0
6.01
In-storage
0
0
0
0.06
0
0
0
0.06
NSSI
4
0
0
0
0
0
8.5
12.5
Perma-Fix
0
548
0
0
5.74
237.85
4
795.59
Und.
0
0
2
0
0
0
15
17
Totals
4
548
2
0.06
5.74
243.85
27.5
831.16
A.4.5 Profile of Undisposable Mixed Waste
Two waste streams generated over the 1992-1994 time period by the EPA laboratories were
deemed undisposable.
In 1993, the Robert S. Kerr Environmental Research Center (Ada, OK) generated 15 ft3 of liquid
scintillation counting fluid (LLW stream #226) with a pseudocumene hazardous component that
was determined to be undisposable. The cumulative activity of this waste (labeled as 14C) is
.0000059 mCi. The RSO indicated that a facility that handles solid low-level mixed waste was
unidentifiable. However, this waste may not be undisposable.
The Health Physics Positions Data Base - Revision I (NUREG/CR-5569) is a collection of NRC
staff positions on a wide range of topics involving radiation protection. The database was
developed by NRC Headquarters and Regional Offices to help ensure uniformity in inspections,
enforcement, and licensing actions. A short discussion and decision regarding the disposal of
solid scintillation media is found on page 140. It concludes that, "If samples meet the specific
activity requirements of 10 CFR 20.2005(a), then the samples maybe disposed of without regard
to their radioactivity." Federal Regulation 10 CFR 20.2005(a) allows for the disposal of liquid
scintillation media containing 0.05 microcuries or less of tritium (H-3) or carbon-14 (C-14) per
gram of medium without regard to its radioactivity. Therefore it would appear that the Kerr
A-20
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waste could be disposed of without regard to its radioactivity, if it meets the following
guidelines:
• Waste is generated from liquid scintillation counting procedures, and
• Waste meets the specific activity limits identified in 10 CFR 20.2005(a)
[i.e., H-3 or C-14 levels less than or equal to 0.05 |-iCi/g].
The second waste stream deemed undisposable was generated through liquid scintillation
counting in 1994 in the NHEERL in Narragansett, RI, and totaled 2 ft3. The radioactive
components consist of cadmium and nickel while the hazardous component is xylene. The RSO
is reportedly unable to find a transporter for this waste. Table A-13 summarizes this information.
Table A-13: Hazardous and Chemical Properties of Undisposable MW Generated at
EPA Laboratories: 1992-1994
Waste
Stream
liquid
scintillation
vials
liquid
scintillation
counting
Year
1994
1993
Radionuclides
[LLW #]
Ni, Cd
[LLW #2 16]
14C
[LLW #226]
Hazardous
Component
[RCRA #]
xylene
[D001,D006, R006]
pseudocumene
[D001]
Volume (ft3)
2
15
Cumulative
Activity (mCi)
not provided
0.0000059
A.4.6 Cost Information
Of the mixed waste that was generated by EPA laboratories in 1992-1994, only three TSD
facilities (Perma-Fix, NSSI, and DSSI) served these laboratories. Table A-15 summarizes the
cost information and lists the number of responses that did not provide these figures.
Table A-14: Cost Information for Disposal Facilities: Mixed Waste
Facility
Perma-Fix
NSSI
Year
1992
1992
1993
1994
Cost ($/ft3)
180
40
48
50
Number of No
Responses
9
11
A-21
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A.5 COMPARISON WITH OTHERMIXED WASTESURVEYS
It is useful to place the results of this analysis within the context of other parallel surveys. A
literature search was conducted to identify other surveys that would serve as a basis of
comparison. The two survey efforts identified include the National Profile on Commercially
Generated Mixed Waste (NUREG/CR -5938) performed by the Oak Ridge National Laboratory
and the DOE National Low-Level Waste Management Program's National Institutes of Health:
Mixed Waste Stream Analysis (DOE/LLW-208).21 Although these surveys were much larger in
scope, the results yield interesting comparisons. Both studies show that laboratory/research
facility generated mixed waste is almost entirely composed of liquid scintillation fluid.
The National Profile, sponsored by NRC and EPA, was based on 1990 mixed waste generation
by 1,016 industrial, medical, nuclear utility, NRC/state-licensed government facilities and
academic institutions. Table A-15 lists the National Profile results for liquid scintillation fluid
production (ft3) and as a percentage of the total mixed waste produced in 1990. A more detailed
enumeration of the waste generated from this survey is presented in Appendix E.
Table A-15: EPA/NRC 1990 National Profile Mixed Waste Survey Results:
Liquid Scintillation Fluid Production and its Percentage in Generator's Mixed
Waste
Mixed Waste
Generator
Medical Facilities
Academic
NRC/State Licensed
Gov. Facilities
Industrial Facilities
All Generators
Number of
Generators
149
256
134
397
1,016
LSF
Produced
(ft3)
18,800
26,680
20,790
34,000
140,000
LSF Percentage of
Generator's Total Mixed
Waste
94
92
77
68
71
21A third identified survey was the 1995 Mixed Waste Inventory Report (DOE/LLW-223)
(MWIR-1995), a detailed, nationwide compilation of information on DOE mixed waste streams
and treatment systems. Since the DOE mixed waste streams are fundamentally different
processes, the information collected in this survey is incommensurate with the National Profile
and the Mixed Waste Stream Analysis. Approximately 6 of the 3201 waste streams highlighted
in the MWIR-1995 were derived from scintillation counting procedures.
A-22
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DOE's NIH: Mixed Waste Stream Analysis revealed that 46,155 ft3 of liquid scintillation vials
were produced by NIH from 1986-1992. In the same 1992 time frame, NIH produced 4,590 ft3
of liquid scintillation vials while six EPA facilities produced only 242.92 ft3. The top three non-
LSF mixed waste produced at NIH are listed below in Table A-16. NIH non-LSF mixed waste
streams are more diverse than EPA non-LSF mixed waste streams, but there are some
similarities. Notably, NIH HPLC waste ranks second volumetrically only to Gel Fixing/Washing.
Both studies point to the fact that HPLC wastes are common in both EPA and NIH facilities and
make significant contributions to non-LSF mixed waste. One difference between the two studies
is that NIH's number one and three non-LSF mixed waste generating processes are not
commonly found in EPA's facilities.
Table A-16: Top Three Mixed Waste Processes at NIH (not including LSF) over the 1989 to
June 1993 time period
Process Description
Gel Fixing/Washing
HPLC wastes
Filter Washes
Volumes (ft3)
642.78
586.74
291.74
Contents volume percent of
total mixed waste (not LSF)
produced
28.4
25.9
12.9
In both the National Profile and the NIH: Mixed Waste Stream Analysis, the principal
radionuclides were identical in proportion to the ones produced by EPA laboratories. These
radionuclides include 14C, 3H 32P, 45Ca, and 35S. Similarly, the dominant hazardous components
in all three studies were toluene and xylene. The NIH study and the National Profile produced
information of the specific hazardous components of the mixed waste generated. The principal
hazardous constituents of the liquid scintillation counting waste generated by commercial
facilities in 1990 included xylene, toluene, and 1,2,4-trimethylbenzene. PCE was the only
hazardous chemical found in EPA laboratory generated mixed waste and not in NIH mixed
waste. EPA also used the label BTEX (benzene, toluene, ethylbenzene, and xylene) for some of
the hazardous constituents in its mixed waste while NIH did not.
The similarities of the findings of this effort and the two above mentioned surveys indicate that
EPA facility generated mixed waste is representative of other U.S. laboratory and research
facility mixed waste. In all three studies there are similar generating processes producing similar
radionuclides and hazardous components. Process changes that minimize mixed waste at EPA
facilities would have direct applicability in other non-EPA facilities as well. Regulatory
modifications affecting the generation of mixed waste from liquid scintillation counting
procedures could affect many different organizations.
A-23
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A.6 CONCLU3ON
The results of the survey indicate only two processes are responsible for the generation of mixed
waste at the EPA laboratories, HPLC counting, and liquid scintillation counting. Similarly, the
hazardous components of this waste are few in number (12). Considerable attention can be
focused on the use, distribution, and management of these waste generating processes to facilitate
the application of waste minimization techniques. Other surveys that parallel this effort (notably
the NIH study referenced above) reveal that mixed waste is produced from comparable waste
generating processes. Although relative to the commercial sector and other federal research
institutions, the EPA laboratories generate minute quantities of low-level radioactive waste and
mixed waste. EPA and other commercial and Federal laboratories might be able to pool their
resources to explore substantive research and develop solutions that minimize the mixed waste
generated by these processes.
A-24
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Attachment A-l
List of Applicable Hazardous Waste Permits and Radioactive Material Licenses
for EPA Laboratories
Laboratory
NHEERL-WED
Newport, OR
RTP
NHEERL-AED
Narragansett, RI
NRMRL-Kerr
Ada, OK
NERL-LV
Las Vegas, NV
NRMRL-
Breidenbach
Cincinnati, OH
NREERL-MED
Duluth, MN
GED-Gulf Breeze
Gulf Breeze, FL
CRL
Chicago, IL
NAREL
Montgomery, AL
Hazardous Waste
Permit
OR868009991
OR7680030924
OR9680059681
NC 668 009 0002-R3
none listed
none listed
none listed
none listed
NPDES#MNG250078
Industrial Wastewater
Discharge Permit
#012
FL1680009338
none listed
none listed
Governing
Authority
Oregon
Oregon
Oregon
RCRA
RD&D
Permit
NA
NA
NA
NA
Minnesota
Local
Florida
NA
NA
Radioactive
Material License
36-12343-02
32-14048-04
(former SC permit)
38-11957-01
NR-162-D-101-S
27-05861-02
(former WA permit)
34-12736-02
South Carolina RW
Transport Permit
22-13390-01
09-10672-03
12-10243-01
01-07317-01
Governing
Authority
NRC
NRC
NRC
NRC
NRC
NRC
South
Carolina
NRC
NRC
NRC
AL
A-25
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Attachment A-2
Descriptions of Waste Management Option Designations:
Option Description
Air Release Onsite release of contaminated material in containment device22
Barnwell Disposal/Treatment facility
Decay Waste stored for decay onsite and appropriately disposed
Hanford Disposal/Treatment facility
In-storage Waste stored for disposal pending sufficient volume
Manu. Waste management is provided by the manufacturer
Und. LLRW deemed undisposable (waste management option not yet
identified)
Perma-Fix Disposal/Treatment facility
SEG/Barnwell Disposal/Treatment facility
Self Onsite incinerator and disposal
Sewer Disposal in sanitary sewer
Wash. Waste distributed to the State of Washington
Description of LLW Stream Numbers
LLW Stream No. Waste Stream Name
201 Biological Waste (Non-infectious)
1. Animal carcasses containing 14C and/or tritium
2. Animal carcasses containing radioisotopes other than 14C
or tritium
3. Other biological waste
202 Trash and or Solid Waste (not lead) - non-compacted
203 Trash and or Solid Waste (not lead) - compacted
204 Filter Media - Dewatered
205 Filter Media - Solidified
206 Filters, Mechanical
207 Gaseous Sources
208 Incinerator Ash or Residuals
209 Ion Exchange Resins - Dewatered
210 Ion Exchange Resins - Solidified
LLW Stream No. Waste Stream Name
22This management option involves permitted releases from a ventilation hood during
routine experiments and has regulatory justification from the following references: 10 CFR
20.1301, 10CFR20.2002(a)(3), 10 CFR 20.1302, 10 CFR 20.10001-20.2401, and 10 CFR
20.1302(b)(2)(I).
A-26
-------
211 Irradiated Reactor or Pool Components
212 Liquids Aqueous - Absorbed
213 Liquids Aqueous - Solidified
214 Liquids Organic - (Solvents, Chlorinated Solvents, etc.)
215 Liquids Scintillation, containing 14C and/or tritium - (fluids or
vials)
216 Liquids Scintillation, containing radioisotopes other than 14C
and/or tritium - (fluids or vials)
217 Mineral Extraction Waste
218 Uranium S ludges
219 Radioactive Sealed Sources, Devices, or Gauges
220 Solidified Evaporator Bottoms/Concentrates/Sump Sludge
221 Vitrified Ash or Resins
222 Waste Oils (Seal Oils from pumps for example)
1. Solvent-contaminated waste oil
2. Waste oil free from solvent contamination
223 Lead-Containing Waste
1. Blankets
2. Sheeting
3. Shielding
223 Lead Containing Waste
4. Batteries
5. Aqueous liquids
6. Organic liquids
7. Lead-contaminated equipment
8. Lead-contaminated trash
9. Other
224 Mercury-Containing Waste
1. Elemental mercury
2. Hydraulic oil
3. Solids
4. Liquids
5. Other
225 Paint
1. Water-based
2. Oil-based
3. Epoxy-based
4. Lead-based
226 Other - (Specify)
A-27
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APPENDIX B: SURVEY INSTRUMENT DISTRIBUTED TO EPA LABORATORIES
Approach to Dissemination of Survey
Initially, EPA staff contacted the RSOs at 11 EPA laboratories presumed to be generators of low-
level radioactive waste (LLRW) and/or mixed waste (MW) to inform them of the nature of this
survey effort. Ten of these laboratories were discovered to be generators of LLRW or MW. An
EPA approved survey was then disseminated to each laboratory through the requested medium:
e-mail or facsimile. Upon the receipt of the surveys, followup conversations were made with
laboratory staff to clarify individual responses. After clarifications were made, the data were
processed and analyzed (see Appendix A). A copy of the survey instrument follows.
B-l
-------
Mixed and Low Level Radioactive Waste Questionnaire:
Administered to EPA Mixed Waste Generating Facilities by the U.S. Environmental Protection Agency,
Radiation Protection Division & Safety, Health, and Environmental Management Division
Introduction: Goals and Overview of the Survey
The completed profile will also assist the EPA/SHEMD in defining future guidance for facilities working with mixed waste. The ultimate objective
will be to reduce cases of indefinite storage and the resulting high costs as well as to assist laboratory directors to re-evaluate the way in which mixed waste is
managed.
The following survey is divided in sections A through C outlined below. Information is being requested for the calender years 1994, 1993, and 1992.
A brief description and explanation, if necessary, of the information requested is provided in the introduction for each section.
Section A: General Information - Self explanatory
Section B: Low-Level Radioactive Waste (LLRW)
B-l. Generation
B-2. Undisposable LLRW
Section C: Mixed Waste (MW)
C-l. Generation
C-2. Undisposable MW
B-2
-------
Definitions:
The following terms are used in the questionnaire. For clarification purposes, their definitions are provided below.
Management Option: the mixed/low-level waste management option chosen which may include treatment, disposal, or onsite storage as described below.
Treatment: any method, technique, or process designed to change the physical and chemical characteristics of waste to render it less hazardous, safer to transport,
store, or reduce in volume. For the purposes of this study, storage for decay is considered a treatment option while disposal is not considered a treatment option.
Disposal: (for the purposes of this study) permanent offsite storage at a permitted disposal facility.
OnSite Storage: waste that is stored at the site of the waste generating facility (EPA research laboratory).
Undisposable: waste remaining after all current treatment techniques have been exhausted and is the waste which, under current conditions, cannot be disposed
of.
Low-Level Radioactive Waste (LLRW): is defined as radioactive material that (a) is not high-level radioactive waste, spent nuclear fuel, or byproduct material
as defined in section 1 le. (2) of the Atomic Energy Act of 1954 (AEA); i.e., uranium or thorium mill tailings and (b) NRC classifies as LLRW consistent with
existing law and in accordance with (a).
Source Material: Materials that contain Uranium or Thorium ores.
Biological Hazard: Materials that contain infectious agents, sharps, or animal carcasses.
Mixed Waste: is defined as waste that satisfies the definition of LLRW and contains hazardous waste that (1) is listed as hazardous waste in Subpart D of 40
CFR Part 261 or (2) causes the LLRW to exhibit any of the hazardous waste characteristics identified in Subpart C of 40 CFR Part 261. In addition, the
following are included in the definition of hazardous waste for the purpose of this study: oils and sludges, and other wastes classified as hazardous by a RCRA-
authorized state.
Your cooperation in completing this survey is greatly appreciated. To reiterate, the underlying purpose of performing this survey is to establish future guidance
for managing mixed waste at EPA laboratories. Please complete the survey as accurately and thoroughly as possible within two (2) weeks after receipt.
B-3
-------
A. General Information
Facility Information
Name:
Address:
Facility Category
Type of Facility and Number of Staff
NRC/Agreement State License Number:
EPA Identification Number:
EPA Facility Classification Total Quantity Generated
(Kg/month)
Large quantity generator
Small quantity generator
Conditionally exempt small quantity generator
No EPA classification:
Please list all applicable hazardous and radioactive wastes permits and the administering agency for your facility (federal, state, local):
Hazardous:
Radioactive:
B-4
-------
Name, title, and telephone number of person completing form:
Name:
Title:
Tel. No.:
B. Low-Level Radioactive Waste (LLRW)
B-l. Generation Please describe each LLRW stream generated at your facility. Waste that is similar in nature or source (or both) should be grouped
together (e.g., unconsolidated trash, laboratory counting procedures, cleaning of laboratory equipment, animal carcasses, spent sealed sources, etc.)
Do not include those wastes considered as mixed wastes in this section. (Mixed Waste will be detailed in Section C)
Please use the codes in Attachment B-l to complete this section.
Total LLRW Generated: Calendar Year 92
Item
#
1
2
3
4
5
6
7
LLW
Stream
Number
Major
Radionuclides
NRC
Class
A,B, or C
LLW Generating Process
Cumulative
Activity
(mCi)
Biological
Hazard
Source
Material
Volume
(ft3)
Management
Option
Disposal
Facility
Cost
($/ft3)
B-5
-------
Total LLRW Generated: Calendar Year 93
Item
#
1
2
3
4
5
6
7
LLW
Stream
Number
Major
Radionuclides
NRC
Class
A,B, orC
LLW Generating Process
Cumulative
Activity
(mCi)
Biological
Hazard
Source
Material
Volume
(ft3)
Management
Option
Disposal
Facility
Cost
($/ft3)
Total LLRW Generated: Calendar Year 94
Item
#
1
2
3
4
5
6
7
LLW
Stream
Number
Major
Radionuclides
NRC
Class
A,B, orC
LLW Generating Process
Cumulative
Activity
(mCi)
Biological
Hazard
Source
Material
Volume
(ft3)
Management
Option
Disposal
Facility
Cost
($/ft3)
B-6
-------
B-2. Undisposable LLRW
Please give a brief reason for each Item # identified above in B-l as undisposable (i.e. Management Option = 1) under current regulations or conditions (e.g., evaluating
options, holding for deregulation, unable to treat, unable to ship, using as a shield, etc.).
Undisposable Waste: Calendar Year 92
Item #
Reason for Storage
Undisposable Waste: Calendar Year 93
Item #
Reason for Storage
B-7
-------
Undisposable Waste: Calendar Year 94
Item#
Reason for Storage
B-8
-------
C. Mixed Waste (MW)
C-l. Generation
Please describe each MW stream generated at your facility. Waste that is similar in nature or source (or both) should be grouped together (e.g., gel fixing/washing,
HPLC scintillation counting, spent reagents, decontamination of lead shielding, pump seal oil, filter washes, etc.)
Please use the codes in Attachment B-2 to complete this section.
Total Mixed Waste Generated: Calendar Year 92
Item
#
1
2
3
4
LLW
Stream
Number
Physical
Description
MW Generating Process
Major
Radionuclides
NRC
Class
A, B, or C
Cumulative
Activity
(mCi)
Biological
Hazard
Source
Material
Please also identify the following characteristics of the MW streams in the order that they were identified above.
Item
#
1
2
3
4
Volume
(ft3)
Hazardous
Component
RCRA Hazardous Waste Code
Storage
Management
Option
Disposal
Facility
Cost
($/ft3)
B-9
-------
Total Mixed Waste Generation: Calendar Year 93
Item
#
1
2
3
4
LLW
Stream
Number
Physical
Description
MW Generating Process
Major
Radionuclides
NRC
Class
A, B, or C
Cumulative
Activity
(mCi)
Biological
Hazard
Source
Material
Please also identify the following characteristics of the MW streams in the order that they were identified above.
Item
#
1
2
3
4
Volume
(ft3)
Hazardous
Component
RCRA Hazardous Waste Code
Storage
Management
Option
Disposal
Facility
Cost
($/ft3)
B-10
-------
Total Mixed Waste Generation: Calendar Year 94
Item
#
1
2
3
4
LLW
Stream
Number
Physical
Description
MW Generating Process
Major
Radionuclides
NRC
Class
A, B, or C
Cumulative
Activity
(mCi)
Biological
Hazard
Source
Material
Please also identify the following characteristics of the MW streams in the order that they were identified above.
Item
#
1
2
3
4
Volume
(ft3)
Hazardous
Component
RCRA Hazardous Waste Code
Storage
Management
Option
Disposal
Facility
Cost
($/ft3)
B-ll
-------
C-2. Undisposable LLRW
Please give a brief reason for each Item # identified above in C-l as undisposable (i.e. Management Option = 1) under current regulations or conditions (e.g., evaluating
options, holding for deregulation, unable to treat, unable to ship, using as a shield, etc.).
Undisposable Waste: Calendar Year 92
Item #
Reason for Storage
Undisposable Waste: Calendar Year 93
Item#
Reason for Storage
B-12
-------
Undisposable Waste: Calendar Year 94
Item#
Reason for Storage
B-13
-------
Is there any other mixed waste that is not covered by this survey?
Additional Comments:
THANK YOU FOR YOUR ASSISTANCE IN COMPLETING THIS QUESTIONNAIRE.
B-14
-------
ATTACHMENT B-l
Please use the guide to complete Section B.
LLW Stream No. - See Attachment B-3.
Major Radionuclides - Identify the different radionuclides in the waste.
NRC Class A, B, or C - Use 10 CFR 61.55 for determination.
LLW Generating Process - Indicate the process which produces the waste (e.g. laboratory counting
procedures, equipment cleaning, etc.).
Cumulative Activity - Indicate the mCi amount for the waste.
Biological Hazard - If the LLRW is also considered an infectious agent, sharp, or animal carcass, indicate
with a check (/).
Source Material - If the LLRW also contains Uranium or Thorium ores indicate with a check (90 days) and offsite treatment and/or disposal
4 = offsite treatment and/or disposal
5 = other
Disposal Facility - Indicate the final disposal facility (if any) for the waste (e.g., Barnwell, SEG, sewer
discharge, etc.).
Cost ($/ft3) - When possible, please indicate the cost for management of the waste including any handling,
shipping, treatment, storage, or disposal fees.
B-15
-------
ATTACHMENT B-2
Please use the guide to complete Section C.
LLW Stream No. - See Attachment B-3.
Physical Description - Indicate the nature of the waste (e.g., bulk/vials, liquid, solid, aqueous liquids,
ash, uncompacted solid, etc.).
MW Generating Process - Indicate the process which produces the waste (e.g. liquid scintillation
counting, gel fixing/washing, lead shielding decontamination, pump seal oil,
equipment cleaning, etc.).
Major Radionuclides - Identify the different radionuclides in the waste.
NRC Class A, B, or C - Use 10 CFR 61.55 for determination.
Cumulative Activity - Indicate the mCi amount for the waste.
Biological Hazard - If the LLRW is also considered an infectious agent, sharp, or animal carcass, indicate
with a check (/).
Source Material - If the LLRW also contains Uranium or Thorium ores indicate with a check (/).
Volume (ft3) - Indicate the volume for the waste. Note that 30- & 55-gallon drums are approximately 4.0
and 7.5 ft3 respectively.
Hazardous Component - Indicate the hazardous chemical or element in the MW (e.g., toluene, xylene,
acetone, etc). Please refer to Attachment 4 for hazardous waste classification
and sample lists.
RCRA Hazardous Waste Code - Refer to Attachment 4 for sample lists of RCRA hazardous waste
codes.
Storage - Use the following code to indicate the type of storage:
1 = Storage for accumulation for less than the RCRA authorized storage time limit
(usually 90 days)
2 = Storage for accumulation for longer than the RCRA authorized storage time limit
(usually 90 days)
B-16
-------
Attachment B-2 (contd.)
Management Option - Use the following codes for indicating the Management Option for the waste
1 = permanent onsite storage/undisposable
2 = storage for decay
3 = offsite treatment and/or offsite disposal
4 = onsite treatment and/or offsite disposal
5 = onsite treatment and/or onsite disposal
6 = other
Disposal Facility - Indicate the final disposal facility (if any) for the waste (e.g., Envirocare, DSSI, NSSI,
Perma-Fix, etc.).
Cost ($/ft3) - When possible, please indicate the cost for management of the waste including any handling,
shipping, treatment, storage, or disposal fees.
B-17
-------
ATTACHMENT B-3
Indicate the radioactive waste streams by entering their code numbers from the following list. Enter a 3-digit
number for those categories which are not subcategorized, but enter a 4-digit number for a waste stream
identity which is subcategorized (e.g., contaminated lead shielding would be indicated with 2233).
LLW Stream Numbers
LLW Stream No. Waste Stream Name
201 Biological Waste (Non-infectious)
1. Animal carcasses containing 14C and/or tritium
2. Animal carcasses containing radioisotopes other than 14C or tritium
3. Other biological waste
202 Trash and or Solid Waste (not lead) - noncompacted
203 Trash and or Solid Waste (not lead) - compacted
204 Filter Media - Dewatered
205 Filter Media - Solidified
206 Filters, Mechanical
207 Gaseous Sources
208 Incinerator Ash or Residuals
209 Ion Exchange Resins - Dewatered
210 Ion Exchange Resins - Solidified
211 Irradiated Reactor or Pool Components
212 Liquids Aqueous - Absorbed
213 Liquids Aqueous - Solidified
214 Liquids Organic - (Solvents, Chlorinated Solvents, etc.)
215 Liquids Scintillation, containing 14C and/or tritium - (fluids or vials)
216 Liquids Scintillation, containing radioisotopes other than 14C and/or tritium -
(fluids or vials)
217 Mineral Extraction Waste
218 Uranium S ludges
219 Radioactive Sealed Sources, Devices, or Gauges
220 Solidified Evaporator Bottoms/Concentrates/Sump Sludge
221 Vitrified Ash or Resins
222 Waste Oils (Seal Oils from pumps for example)
1. Solvent-contaminated waste oil
2. Waste oil free from solvent contamination
223 Lead-Containing Waste
1. Blankets
2. Sheeting
B-18
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LLW Stream Numbers (contd.)
LLW Stream No. Waste Stream Name
223 Lead-Containing Waste (contd.)
3. Shielding
4. Batteries
5. Aqueous liquids
6. Organic liquids
7. Lead-contaminated equipment
8. Lead-contaminated trash
9. Other
224 Mercury-Containing Waste
225
226
Paint
Other
1.
2.
3.
4.
5.
1.
2.
3.
4.
Elemental mercury
Hydraulic oil
Solids
Liquids
Other
Water-based
Oil-based
Epoxy-based
Lead-based
- (Specify)
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ATTACHMENT B-4
Selected Industry and EPA Hazardous Waste Numbers
Section A. Listed Hazardous Waste
EPA details listed hazardous waste from nonspecific sources in 40 CFR 261 Subpart D: §261.3.
Mixture Rule
Any solid waste mixed with one or more listed hazardous waste is hazardous. This rule applies regardless of
what percentage of the waste mixture is composed of listed hazardous waste. (Note that certain so called
"dry waste" such as solvent and radionuclide-contaminated rags, may be hazardous waste via the mixture
rule). The following are exceptions to this rule:
• Wastewater subject to regulation by the Clean Water Act mixed with low concentrations of a listed
waste (unless the resultant mixture exhibits one of the characteristics);
• Mixtures of nonhazardous waste and listed waste that were listed for exhibiting a characteristic (if the
resultant mixture does not exhibit any of the characteristics);
• Mixtures of nonhazardous waste and characteristic hazardous waste that no longer exhibit any of the
characteristics;
• Certain concentrations of spent solvents and laboratory wastewater that are discharged in low
concentrations and do not pose a threat to human health or the environment (see 10 CFR 20.2003 &
10 CFR 20.2005); and
• De minimis losses of discarded commercial chemical products or intermediaries used as raw materials
in manufacturing or produced as byproducts.
Derived-From Rule
Any solid waste generated from the management of a listed hazardous waste (including any sludge, spill
residue, ash, filter, emission control dust, or leachate but not including precipitation run-off) is a hazardous
waste.
Listed Hazardous Wastes from Nonspecific Sources:
EPA HW No. Hazardous Waste
FOOl The following spent halogenated solvents used in degreasing: Tetracloroethylene,
trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and
chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing,
before use, a total of 10 percent of more (by volume) of one or more of the above halogenated
solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery
of these spent solvents and spent solvent mixtures.
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EPA HW No.
Hazardous Waste
F002
F003
F004
F005
The following spent halogenated solvents: Tetrachloroethylene, methylene chloride,
trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, l,l,2-trichloro-l,2,2-trifluoroethane,
ortho-dichlorobenzene, trichlorofluoromethane, and 1,2,2-trichloroethane; all spent solvent
mixtures/blends containing, before use, a total of 10 percent or more (by volume) of one or
more of the above halogenated solvents or those listed in F001, F004, or F005; and still
bottoms form the recovery of these spent solvents and spent solvent mixtures.
The following spent halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl
ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, pseudocumene, and methanol;
all spent solvent mixtures/blends containing, before use, only the above spent nonhalogenated
solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above
nonhalogenated solvents and a total of 10 percent or more (by volume) of one ore more of
those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of
these spent solvents and spent solvent mixtures.
The following spent halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all
spent solvent mixtures/blends containing, before use, a total of 10 percent or more (by volume)
of one ore more of the above nonhalogenated solvents or those solvents listed in F001, F002,
and F005; and still bottoms from the recovery of these spent solvents and spent solvent
mixtures.
The following spent halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide,
isobutanol, pyridine, benzene, 2-ethoxyethanol, trigylcerol, and 2-nitropropane; all spent
solvent mixtures/blends containing, before use, a total of 10 percent or more (by volume) of
one or more of the above nonhalogenated solvents or those solvents listed in F001, F002, or
F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.
F020- F023
F026-F028
Dioxin waste
Dioxin waste
Section B. Characteristic Hazardous Wastes
A solid waste can also be considered hazardous, if it exhibits one or more of the following characteristics.
I. Ignitability
A waste is ignitable and is classified as D001 if it meets any of the following criteria:
1. It is a liquid (except for aqueous solutions containing less than 24 percent alcohol by volume) and has
a flash point less than 140 °F;
2. It is not a liquid and is capable, under standard temperature and pressure, of causing fire through
friction, absorption of moisture or spontaneous chemical changes, and when ignited, burns so
vigorously and persistently that it creates a hazard;
3. It is an ignitable compresses gas, as defined by the Department of Transportation; or
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4. It is an oxidizer, as defined by the Department of Transportation
The following is a sample list of D001 waste:
Acetonitrile
Cis-2-pentene
Coal Tars
Ethanol
Formaldehyde
Formamide
Naphthalene
Organic Solvents
Tetrahydrofuran
II. Corrosivity
A waste is corrosive and is classified as D002 if it meets either of the following criteria:
1. It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, as determined by a
pH meter; or
2. It is a liquid and corrodes steel at a rate greater than 0.25 inches per year at specified conditions.
The following is a sample list of D002 waste.
Acids
Corrosive Liquids
Phenol
Phosphoric Acid
Sodium Hydroxide
Sulphuric Acid
III. Reactivity
A waste is reactive and is classified as D003, if it meets any of the following criteria:
1. It is normally unstable and readily undergoes violent change without detonating;
2. It reacts violently with water;
3. It forms potentially explosive mixtures with water;
4. When formed with water, it generates dangerous quantities of toxic fumes, gases, or vapors;
5. In the case of cyanide- or sulfide-bearing waste, it generates dangerous quantities of toxic fumes,
gases, or vapors when exposed to pH conditions between 2 and 12.5;
6. It detonates or explodes when subjected to a strong initiating force or heated under confinement;
7. It readily detonates or decomposes explosively at standard temperature and pressure; or
8. It is defined by DOT as forbidden explosive, Class A explosive, or Class B explosive.
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The following is a sample list of D003 waste.
Potassium Cyanide
Sodium Cyanide
IV. Toxicity
A waste exhibits the characteristics of toxicity if a representative sample of a liquid or the extract of
a solid waste contains any of the following constituents at a level equal to or greater than the given
value below. The test for toxicity is the Toxic Characteric Leaching Procedure (TCLP) as described
in 40 CFR Part 261, Appendix II (SW-846, Method 1311).
Haz.
No.
mg/1
Haz.
No.
me/1
Haz.
No.
mg/1
D004 Arsenic 5.0 D027 1,4-Dichlorobenzene 7.5 D035
D005 Barium 100.0 D028 1,2-Dichloroethane 0.5 D036
DO 18 Benzene 0.5 D029 1,1-Dichorethylene 0.7 D037
D006 Cadmium 1.0 D030 2,4-Dinitrotoluene 0.1 D038
DO 19 Carbon DO 12 Endrin 0.02 DO 10
tetrachloride 0.5 D031 Heprachlor(and epoxide) 0.008 D011
D020 Chlorodane 0.03 D032 Hexachlorobenzene 0.1 D039
D021 Chlorobenzene 100.0 D033 Hexachloro-1,3-butadiene 0.5 D015
D022 Chloroform 6.0 D034 Hexachloroethane 3.0 D040
D007 Chromium 5.0 D008 Lead 5.0 D041
D023 o-Cresol 200.0 DO 13 Lindane 0.4 D042
D024 m-Cresol 200.0 D009 Mercury 0.2 DO 17
D025 p-Cresol 200.0 D014 Methoxychlor 10.0 D043
D016 2,4-D 10.0
Methyl ethyl ketone 200.0
Nitrobenzene 2.0
Pentachlorophenol 100.0
Pyridine 5.0
Selenium 1.0
Silver 5.0
Tetrachloroethlylene 0.7
Toxaphene 0.5
Trichloroethylene 0.5
2,4,5-Trichlorophenol 400.0
2,4,6-Trichlorophenol 0.2
2,4,5-TP (Silvex) 1.0
Vinyl Chloride 0.2
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APPENDIX C: COMMONLY GENERATED RAD IONU GLIDES AT EPA LABORATORIES
Radio-
nuclide
3H
14C
32p
35S
36C1
45Ca
51Cr
60Co
63Ni
125J
137Cs
225Ra
238U
241Am
Type of Decay
(abundance %)
negative beta emission
(100)
negative beta emission
(100)
negative beta emission
(100)
negative beta emission
(100)
negative beta emission
positive beta emission
orbital electron capture
negative beta emission
gamma (9-8)
X-ray
electron capture
negative beta emission
(100)
negative beta emission
orbital electron capture
negative beta emission
negative beta emission
alpha particle decay,
spontaneous fission
alpha particle decay
Half-life
12.3 years
5, 730 years
14.3 days
87.9 days
3 x 1 05 years
163 days
27.8 days
5.3 years
92 years
60 days
30.0 years
14.8 days
4.91 x 109
years
458 years
Major radiations, Energies (Mev), and
Frequency per disintegration (%)
P- : 0.019 max. No y
P- : 0.156 max. No Y
P " : 1.17 max. No Y
P- : 0.167 max. No Y
p - : 0.709
p + :0.12
No Y
P- : 0.258 max. No Y
Y : 320.1
p- : 1.48 max (0.12%), 0.314 max (99+%)
Y : 1.17(100%), 1.33(100%)
P ' : 0.067
Y : 0.0352
p - : 1.18 max (7%), 0.514 max (93%)
Y : 0.662 (85%), Ba X-rays
e - : 0.624, 0.656 (8%)
P ' : 0.32 max.
Y : 0.04
a: 4.20 (75%), 4. 15 (25%)
Y : Th X-rays
e": 0.03, 0.043
Daughter radiations from 234Th, 234mPa
a : 5.482 (85%), 5.439 (13%), 5.386 (2%)
Y : 0.06, 0.027-0.37
C-l
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APPENDIX D: RESEARCH APPROACH
More than 50 research materials were reviewed to determine applicability to this study (see
Section 6). The materials were collected from the academic, commercial, federal, state, and
medical communities. The review of the literature suggests that the primary focus is dedicated to
addressing mixed waste management at the laboratory level. This warranted the need for an
entire section (Section 2) devoted to addressing an integrated laboratory-wide approach to mixed
waste management.
Two primary search tools were consulted to produce the list of studies for this effort. The first
source, the Victor Network, provided a list of the publications and journals available through the
University of Maryland library system. This aided in identifying academic and other materials
related to laboratory mixed waste management. A second source was the National Technical
Information Service (NTIS) Bibliographic Database that provides a list of government
publications for the years 1977-1995.
Based on the literature survey and contacts with the industry experts, it was discovered that there
are a limited number of studies that focus exclusively on mixed waste generated from
laboratories or research facilities (particularly on HPLC and LSC). This is especially the case for
pollution prevention techniques, recycling options, and waste segregation strategies. A telephone
survey of federal, commercial, and other laboratories was conducted to identify state-of-the-art
waste management techniques and identify literature that would contribute to this study.
Attachment D-l lists the names and organizations of the 37 professionals contacted. Table D-l
below highlights the framework of this survey instrument. Additional materials were collected
from EPA sources that had been accumulated for other research studies.
Table D-1: Framework for Phone Survey Administered to MW Research Staff
1) Clarification of Survey Responses
• General Description of Waste Generating Practice
• Clarification of Management Option
• Incomplete Information
2) Elicit Approaches/Strategies to Improve P2 Practices (MW Focus)
• Determine What is Successful (laboratory practices, analysis
techniques)
• Identify Waste Minimization Goals
• Identify Publishable Research
3) Elicit Suggestions for Further Research/Recommendations
• Are There Significant Technology Data Gaps?
D-l
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ATTACHMENT D-l: LIST OF CONTACTS
Contact
Dick Blauvelt
Lou Todisco
Andy Francis
Jerry Klein
Bob Hilton
Nick Orlando
Jan Berry
Sam Suffrand
Eric Williams
Priscilla Bunton
Paul Longsworth
Stanley Wolfe
Esmeralda Party
John Moore
Kent Hancock
Karen Catlett
Cathy Stanton
William Mills
Cathy Asbell
Frank Masse
Susan Jahansooz
Edwin Becker
Steve Hoeffner
Kevin Twitchell
Roger Scott
Bill Dornsife
Stan Zigma
Carol Creutz
Emmitt Barkley
Fred Petschauer
Peter Reinhardt
Don Carlson
Allen Pasternak
Susan Spencer
Trish Baisden
Andrea Sutherland
Peter Ashbrook
Organization
ASME Mixed Waste Committee Chairman, BDM Federal
NEN Products
Oak Ridge National Laboratory
Oak Ridge National Laboratory
Conversion Systems, Incorporated
Nuclear Regulatory Commission
Oak Ridge National Laboratory
Oak Ridge National Laboratory
Lockheed Idaho
DOE
DOE
DOE
Rockefeller University
Oak Ridge National Laboratory
DOE
Oak Ridge National Laboratory
Stanton Associates
Health Physics Society
Lockheed Idaho
Massachusetts Institute of Technology
Lawrence Berkeley Laboratory
National Institutes of Health
Rust Environmental Services, Clemson Technical Center
Lockheed Idaho
Lockheed Idaho
State of PA Radiation Control Division of Environmental Protection,
Chairman of NCRP, MW Subgroup
Sandia National Laboratories
Brookhaven National Laboratory
Howard Hughes Medical Center
Brookhaven National Laboratory
University of Wisconsin - Madison
University of Texas - Dallas
Cal Rad
University of California - Berkeley
Lawrence Livermore Laboratory
Affymax Research Institute
University of Illinois at Urbana-Champaign
D-2
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APPEN DIX E RESU ITS O F O RN L SU RVEV
Oak Ridge National Laboratory, National Profile on Commercially Generated Low-Level
Radioactive Mixed Waste, December 1992.
The report was jointly sponsored by the Nuclear Regulatory Commission (NRC) and EPA and
attempts to provide a national profile on the volumes, characteristics, and treatability of
commercially generated low-level mixed waste for 1990. The data and conclusions resulted from
a national survey of commercial mixed waste generators which included academic, industrial,
medical, and NRC/Agreement State-licensed government facilities, and nuclear utilities. A list
of some of the findings include:
Generation
Storage
Mixed waste comprised about 9 percent of the low-level radioactive waste
generated in 1990.
140,000 ft3 of mixed waste was generated in the United States in 1990 by
commercial facilities.
Of that:
71% (100,000 ft3) - LSC fluid
• 18% - organic solvents (CFCs), corrosive organics, and waste oil
• 3% - toxic metals
8% - other
The contribution from government facilities was approx. 19% (27,000 ft3)
Of that:
77% - LSC fluid
• 13 % - other organics
75,000 ft3 of mixed waste was identified as being stored onsite in 1990.
Of that, the largest percentage of mixed waste in storage was contaminated
by:
• Cadmium - 35%
LSC fluid-17%
The contribution by government to the total mixed waste in storage was approx.
4 percent (2800 ft3), over half of which was contaminated by LSC fluid. Note
however, that the amounts in storage do not necessarily equate to amounts that are
undisposable or require disposal. Some mixed waste may merely be accumulating
for treatment purposes.
Untreatable
E-l
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Survey indicated that over 4800 ft3 of mixed waste was considered unbeatable in
1990, approximately 31 percent (1,455 ft3) of which came from the government
category. The two primary chemicals found in the unbeatable government mixed
waste were LSC fluids (over 50 percent) and "other organic" compounds (27
percent).
Treatment/Disposal
Approximately 67 percent (143,000 ft3) of the mixed waste generated and in
storage in 1990, including all of the LSC fluid, could be treated by thermal
destruction techniques. This figure does not include the untreatable mixed waste
being stored.
Demand/Capacity
The national profile estimates that existing treatment facilities could have treated
approximately 95 percent of the mixed waste generated during 1990. However,
an important caveat to note is that the U.S. Department of Energy, which is not
included in the survey produces a great deal of mixed waste (approx. 800,000 ft3)
compared to the amount identified in the survey. Thus, if the DOE began
competing for treatment capacity with the other commercially generated mixed
waste there is a potential for a significant shortfall in treatment facility capacity.
Insufficient capacity currently exists, as of 1990, for mixed waste contaminated
with CFCs, some LSC wastes, lead shielding, other waste contaminated with lead
solids, and equipment and debris contaminated with mercury.
E-2
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APPENDIX F: OVERVIEW OFOTHERMW/LLRW SURVEYS, DATABASES* AND STATE
LOW-LEVEL RADIOACTIVE WASTE DISPOSAL EFFORTS
The literature search identified other surveys and databases that address different aspects of waste
management and pollution prevention. In addition, there existed several documented state-level
efforts notably New York, Pennsylvania, and Ohio, that examine approaches to dispose of low-
level radioactive waste generated within their jurisdiction. Discussions with state policy makers
and other researchers suggest that states are examining options for management of LLRW and
MW in the longterm. This has palpable implications for the EPA research facilities that generate
LLRW and MW. EPA facilities that generate these wastes need to keep apprised of the state
specific issues relating to treatment and storage options. It is incumbent upon RSOs and other
research staff to incorporate pollution prevention, storage, and disposal objectives within the
context of these policies.
The New York State Energy Research and Development Authority, Low-Level Radioactive
Waste Storage Study: Vol. 1: Storage and Capability at Generator Sites, September 1993.
The New York State Energy Research and Development Authority conducted a low-level
radioactive waste (LLRW) storage study with three purposes: 1) to evaluate the present ability of
generators of LLRW in New York State to store their waste at the facilities where it is generated,
2) to evaluate the ability of generators to expand existing capacity to allow storage onsite for a
minimum of 10 years; and 3) to investigate the economic viability of establishing a separate
centralized storage facility for Class A LLRW from medical and academic institutions. This
piece does not discuss mixed waste disposal issues specifically, but reaches several valuable and
interesting conclusions.
An in-state disposal facility along with other options designed to increase disposal capacity are
being considered. Extended storage of LLRW is expected to be required for several years after
access to the Barnwell facility is to be discontinued. Detailed questionnaires were administered
by the New York Energy Research and Development Authority to 206 LLRW generating
facilities and site visits were made to 166 facilities. These facilities included nuclear power
plants, hospitals, medical research centers, clinical laboratories, universities, industries, and
government facilities. Briefly, the results of the survey indicate that 142 facilities would have to
store waste on site for extended periods totaling approximately 50,000 cubic feet of LLRW per
year requiring storage. Clearly, it is necessary to reduce the volume of waste requiring storage or
build enhanced storage capacity.
Although the underlying purpose of this survey was do address the pressing need for enhanced
storage capacity for the generation of LLRW, several observations can be culled from this report.
As was the case with the survey of EPA laboratories, cost information associated with storage
and treatment was, at best, sporadically available. To thoroughly analyze the cost considerations
associated with various waste management options, this information is critical to this analysis.
Secondly, there existed significant variations between facilities in the philosophy of managing
research, though the concerns expressed by these laboratories related to onsite storage were
strikingly similar.
F-l
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Community Partnership Plan, Commonwealth of Pennsylvania, Department of Environmental
Protection.
The Commonwealth of Pennsylvania is currently evaluating sites for a LLRW waste disposal
facility. The Commonwealth's Department of Environmental Protection is developing a
Community Partnership Plan which is a voluntary process whereby local municipalities
determine the feasibility of hosting the facility. The construction of the site is in response to the
perceived tenuous acceptance of LLRW at the Barnwell disposal facility. Pennsylvania formed
a "compact" with Delaware, Maryland, and West Virginia so that transportation and disposal of
the low-level waste would be managed at regional level. When the Barnwell facility did not
accept the waste (on an earlier) occasion from Pennsylvania generators, more than 120 temporary
facilities across the state stored these waste.
The National Governors Association, Issue Paper From the NGA FFCA Commercial Mixed
Waste Subgroup, 1995.
The National Governors Association (NGA) convened the Federal Facility Compliance Act
(FFCA) Task Force in May 1994. A Commercial Mixed Waste Subgroup was recommended to
be instituted to examine the feasibility of DOE acceptance of commercial mixed waste. In
addition to the legal considerations, it was recommended that information detailing the volumes,
waste types, and available commercial treatment options be investigated. If DOE facilities are
permitted to accept this waste, the EPA facilities have greater flexibility in selecting options for
waste disposal.
This article describes the correspondence between DOE and the NGA Task Force. Originally a
Low-Level Waste Forum was established in 1986 to respond to state concerns regarding
commercial mixed waste management. After FFCA was passed in 1992, DOE engaged in a
cooperative agreement with NGA to facilitate implementation of the Act and concluded that the
appropriate mechanism for addressing DOE acceptance of mixed waste was via the Forum. A
report was prepared that determined the technical, regulatory, and legal considerations associated
with DOE acceptance of commercial mixed waste would not result in significant additional
requirements for DOE. Another important issue centered around the availability of information
on commercial waste types and volumes.
Mixed Waste Treatment Study (Draft), Prepared for the Electric Power Research Institute,
Research Project 3800-22, December 1995.
The lack of treatment/disposal capacity for mixed waste has resulted in most nuclear utilities
having to store relatively small volumes of mixed waste onsite under the RCRA hazardous waste
permitting requirements. Since most utilities do not have RCRA permits, the regulatory
complexities associated with the management of mixed waste is a significant concern to
generators. This Mixed Waste Treatment Study was designed to provide nuclear utilities with a
comprehensive reference document regarding mixed waste treatment to facilitate the
identification of treatment/disposal options to minimize or eliminate the need for permitted
storage and, ultimately, reduce the cost of mixed waste management.
F-2
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The approach and objectives of this study are analogous to the EPA work assignment. Initially, a
survey of utilities was performed to identify those regulatory options being employed by utilities
for the onsite management of mixed wastes. In addition, an overview of the types of waste,
generating processes, available onsite and offsite treatment options, and an assessment of
potential emerging technologies for treatment is outlined. A majority of the waste generating
processes and management obstacles discussed in this study are not particularly germane to EPA
facilities. A brief highlight of the hazards and treatment issues associated with liquid
scintillation cocktails is provided. The two mixed waste treatment facilities identified as the
applicable treatment providers are Perma-fix and DSSI.
The Mixed Waste Inventory Report, Idaho National Engineering Laboratory, Prepared for the
U.S. Department of Energy, November 1995.
The MWIR-1995 database contains a detailed, nationwide compilation of information on DOE
mixed waste streams and treatment systems. In addition, the 1995 version include data on
nonmixed, transuranic (TRU) waste streams. The data set addresses "stored" streams which are
defined as (a) streams currently in storage at both EM-30 and EM-40 sites and (b) streams that
have yet to be generated but are anticipated within the next 5 years from sources other than
environmental restoration or decontamination and decommissioning activities.
The database represents a comprehensive accounting framework that may serve as a model for
other national surveys such as the National Profile. The processes that generate mixed waste at
DOE facilities are fundamentally different than that of the EPA laboratories. The survey reveals
that DOE facilities do in fact generate LSC cocktails, but these represent minute quantities
relative to other waste streams.
The 1993 Massachusetts Low-Level Radioactive Waste Survey Report, The Massachusetts
Low-Level Radioactive Waste Management Board, [data collection and analysis
conducted by Richard B. Fairfull] 11/94.
This excerpt provides a summary of the total mixed LLRW produced in Massachusetts in 1993
and the concomitant management option. The second largest category 55,577 ft3 of mixed waste
generated was liquid scintillation fluid which was disposed of by incineration at out-of-state
facilities. The onsite storage for decay management option represented only 406.9 ft3 whereas
the waste shipped for disposal accounted for 52,692 ft3. This reinforces the finding that mixed
waste streams generated at EPA laboratories are very similar to those in the commercial, medical,
and federal communities.
Low-Level Radioactive Waste Management in North Carolina, Briefing prepared by the North
Carolina Department of Environment, Health and Natural Resources, Division of
Radiation Protection, 1994.
A summary document prepared by the North Carolina Department of Environment, Health, and
Natural Resources, Division of Radiation Protection, highlighted the volumes and radioactivity
levels of the mixed waste stored in North Carolina at the end of 1994. The survey results
indicated that approximately 750 cubic feet of mixed waste containing 22 curies were being
F-3
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stored at 12 facilities. The Academic category accounted for 60 perceny of the volume of the
stored waste by only 8.6 percent of the radioactivity. Conversely, the Industrial category
accounted for 29 percent of the volume and 91 percent of the radioactivity. It was concluded that
although the survey results may underestimate the total amount of mixed waste being stored in
North Carolina, these amounts are relatively small.
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