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                                OSWER 9938.9
                                 July, 1991
    Conducting RCRA
       Inspections at
  Mixed Waste Facilities
     Office of Waste Programs
          Enforcement
U.S. Environmental Protection Agency

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                                   NOTICE

This guidance presents only an overview of RCRA inpsections of facilities handling
low-level radioactive mixed waste.  For specific requirements and further
information, refer to the statute, feceral and state regulations, and the information
sources listed in the back of this document.

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                                                                9938.9


                                CONTENTS

Section                                                               Page

1.     INTRODUCTION  	  1-1

2.     REGULATORY OVERVIEW	  2-1

      2.1   DEFINITION OF MIXED WASTE	  2-1

      2.2   HISTORY OF MIXED WASTE REGULATION	  2-1

      2.3   WHEN MIXED WASTE IS REGULATED UNDER RCRA	  2-3

      2.4   REGULATION OF THE RADIOACTIVE COMPONENT	  2-4

      2.5   SPECIAL REGULATORY CONCERNS  	  2-5

           2.5.1  Applicability of the Land Disposal Restrictions to Mixed Wastes. ..  2-5
           2.5.2  Treatment Technologies for Mixed Wastes 	  2-6
           2.5.3  Storage of Mixed Wastes	  2-7
           2.5.4  Generator and TSDF Requirements for Mixed Wastes	  2-8

3.     INSPECTION PREPARATION	  3-1

      3.1   PREVISIT FILE REVIEW AND BACKGROUND INFORMATION
           ON THE FACILITY	  3-1

      3.2   HEALTH AND SAFETY PREPARATION	  3-3

           3.2.1  As Low As Reasonably Achievable	  3-3
           3.2.2  Limiting Radiation Doses	  3-4

4.     CONDUCTING THE INSPECTION	  4-1

      4.1   FAOLITYENTRY	  4-2

      4.2   OPENING DISCUSSION WITH OWNER/OPERATOR	  4-4

      4.3   SAMPLING ACTIVITIES	  4-4

      4.4   COMPLIANCE EVALUATION INSPECTIONS	  4-5

           4.4.1  Waste Handling Practices	  4-5
           4.4.2  Review of Records	  4-6
           4.4.3  Checklists	  4-8
           4.4.4  Documentation/Report	  4-8

      4.5   COMPREHENSIVE GROUND-WATER MONITORING EVALUATION
           INSPECTION	  4-8
                                     111

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                                                          9938.9









                          CONTENTS





4.6   CORRECTIVE ACTION INSPECTIONS	  4-9



4.7   PERMIT-RELATED INSPECTIONS	4-10





Appendices



A    RADIONUCLIDE CHARACTERISTICS



B    REGULATORY ROLES AND AUTHORITIES



C    MIXED WASTE OPERATIONS



D    LIST OF MIXED WASTE CONTACTS



E    NRC MATERIAL LICENSE PROGRAM CODES







                           LIST OF  TABLES



Table                                                           Page



2-1   Definitions of Types of Radioactive Material and Radioactive Waste	  2-2



C-l  Properties of Selected Radionuclides	  C-2



C-2  Mixed Waste Generated by Industrial Facilities	  C-4



C-3  Mixed Waste Generated by Academic/Medical Institutions	  C-7



C74  Nuclear Power Plant Activities that Generate Mixed Waste	  C-9



C-5  Summary of Mixed Waste Management Practices by Waste Type	C-l3
                                IV

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                                                                              9938.9

                                   1.  INTRODUCTION

       Mixed waste is defined as any waste matrix that contains both a hazardous waste component
that is subject to the requirements of the Resource Conservation and Recovery Act (RCRA) and a
radioactive component that is subject to the Atomic Energy Act (AEA). Environmental Protection
Agency (EPA) RCRA inspectors  are familiar with the chemical hazards and technical operations
associated with hazardous waste, but they may not be as familiar with the radioactive hazards and
technical operations associated v.-ith mixed waste. All RCRA inspectors receive training on the
general health and safety concerns of hazardous waste and the unique considerations for different
types of operations and  different types of RCRA inspections. To date, however, most RCRA inspectors
have not received formal guidance on similar concerns for radioactive materials or for mixed waste.

       Since mixed waste is regulated by both RCRA and AEA, new concerns have arisen for inspectors
at facilities that handle mixed waste.  Inspectors must understand how RCRA and AEA requirements
interact at mixed waste facilities.  In general, inspectors must be alert for mismanagement and incorrect
identification of mixed wastes as radioactive wastes. Inspectors may also need to educate facilities
about RCRA requirements that previously did not apply to mixed wastes.

       Both the U.S. Nuclear Regulatory Commission (NRC) and the  U.S. Department of Energy
(DOE)  have jurisdiction over radioactive materials that are subject to AEA. NRC regulates  both
commercial operations and federal operations (with the  exception of DOE operations) that handle
AEA radioactive materials.  DOE controls (through internal directive) radioactive-materials
handling for all DOE operations, DOE contractors, and DOE subcontractors.  This guidance only
addresses RCRA inspections at NRC-licensed facilities that handle  mixed waste.  Although DOE
facilities have different mixed waste  operations, sections of this guidance may still be helpful for
RCRA  mixed waste inspections at DOE facilities.

       The sections in this guidance discuss additional background material with which inspectors
should be familiar with to adequately prioritize, plan, and conduct inspections at mixed  waste
facilities. Chapter 2. provides a brief overview of the  mixed waste regulatory structure. Chapter 3.
addresses the previsit file review and health and safety preparation.  Chapter 4. addresses unique
on-site considerations for the standard RCRA compliance evaluation inspection as well as other RCRA
inspections. References to existing RCRA guidance documents are made throughout the guidance to
direct the reader to more detailed discussions of standard RCRA practices.
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                                                                               9938.9
    Appendix A discusses the radionuclide characteristics of mixed waste.  Appendix B provides more
detail on the regulatory roles and authorities of NRC, DOE, and states at mixed waste  facilities.
Appendix C discusses the universe of NRC-licensed  facilities, the types of mixed waste that each
generates, and the  mixed waste management practices at each type of facility for  each type of mixed
waste. Appendix D provides a list of mixed  waste contacts.
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                                                                             9938.9
                            2.  REGULATORY OVERVIEW

       This chapter presents a brief regulatory overview for the  RCRA inspector at mixed waste
facilities. It discusses:
                     the definition of mixed waste
                     the history of mixed waste regulation
                     when mixed waste is regulated under RCRA
                     regulation of the radioactive component
                     special regulatory concerns

2.1            DEFINITION OF MIXED WASTE

       For a waste to be considered mixed waste, it must contain both radioactive waste as defined by
the Atomic Energy Act (AEA) and hazardous waste as defined by the Resource Conservation and
Recovery Act (RCRA). Hazardous waste must either be or contain material listed in Title 40 of the
Code of Federal Regulations  (CFR) Part 261, Subpart D, or it must exhibit one or more of the four
hazardous characteristics cited in 40 CFR 261, Subpart C.  Radioactive waste is usually classified as
low-level, high-level,  or transuranic waste. The waste may contain source, special  nuclear, or
by-product materials as defined in 10 CFR 20.
       Exhibit 2-1 presents  the definitions of low-level,  high-level, and transuranic waste, and of
source, special  nuclear, and by-product material. Each is defined briefly and  the types of facilities
where the inspector can expect to find the waste or material are indicated.  Additional information on
the general characteristics of radionuclides and types of radiation are described in Appendix A.
Appendix C provides a more detailed description of the facilities that generate mixed  wastes.

2.2            HISTORY OF MIXED WASTE REGULATION

       The AEA, as amended by Reorganization Plan No. 3 of 1970, gives NRC, DOE, and EPA the
authority to establish standards and instructions (by rule,  regulation, or order) to govern the possession
and use of source, special nuclear, or by-product material to promote the common defense and security,
to protect health, or to minimize danger to life or property. The EPA Office of Radiation  Programs
(ORP) is authorized under the AEA, as amended, to establish Federal radiation guidance and
standards, assess new  technologies in the area of radiation, and monitor radiation in the environment.
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                                                                                      9938.9
                                             Exhibit 2-1
                        Definitions of Types of Radioactive Material
                                    and Radioactive Waste*
BY-PRODUCT MATERIAL
SOURCE MATERIAL
SPECIAL NUCLEAR MATERIAL
HIGH-LEVEL  WASTE
LOW-LEVEL  RADIOACTIVE WASTE
TRANSURANIC WASTE
Any radioactive material (except special nuclear material)
yielded in or made radioactive by exposure to  the radiation
incident to the process of producing or utilizing special
nuclear material. Also included are the tailings or wastes
produced by the extraction or concentration of uranium or
thorium from any ore processed primarily for its source
material content. Such tailings or wastes are considered
byproduct material whether or not they are radionuclides.

Uranium, thorium, or any other material that is determined
by the Nuclear Regulatory Commission (NRC) pursuant to
the provisions of Section 2091 of Title 42 to be source
material. Also included are ores containing one or more of
the foregoing materials, in such concentration as the NRC
may by  regulation determine from time to time.

Plutonium, uranium enriched with the isotope 233 or 235, and
any other material which the NRC,  pursuant to the
provisions of Section 2071 of Title 42, determines to be
special nuclear material.  Also includes any material
artificially enriched in any of the foregoing, but does not
include source material.

Highly radioactive material resulting from the reprocessing
of spent nuclear fuel, including liquid waste produced
directly in reprocessing and any solid material derived from
such liquid waste that contains fission products in sufficient
concentrations.  Also included are other highly radioactive
materials that the NRC, consistent with existing law, requires
permanent isolation.

Radioactive material that is not  high-level radioactive waste,
spent nuclear fuel, transuranic waste, or by-product material
as defined in Section 2014(e) (2) of Title 42 of the United
States Code.  The NRC, consistent with existing law, classifies
other types of low-level  radioactive waste

Waste containing more than 100 nanocuries of
alpha-emitting transuranic isotopes, with half-lives greater
than 20 years, per gram of waste, except for (1)  high level
radioactive wastes; (2) wastes that the Department has
determined, with the concurrence of the Administrator, do
not need the degree of isolation required by this part; or (3)
wastes that the Commission has approved for disposal on a
case-by-case basis in accordance with 10 CFR Part 61 (40 CFR
19120 i).
'From "Nuclear Waste Policy Act of 1982," Pub. L. 97425 -2, Jan. 7,1983, 96 Stat. 2202.
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                                                                             9938.9
       In 1976, RCRA established a system for the cradle-to-grave  management of hazardous wastes.
Due to RCRA's statutory  exclusion of source, special nuclear, or by-product material from the definition
of solid waste, some confusion existed regarding the regulation of wastes that contained both
radioactive and hazardous components.  Several Federal Register notices clarified that mixed wastes
were dually regulated by the AEA and RCRA:
      EPA Clarification of RCRA Applicability to Mixed Wastes, July 3, 1986 (51 FR 24504) clarified
       EPA's authority to regulate hazardous component of mixed waste and discussed state
       authorization.
      DOE Clarification of the Definition of By-product Material, May 1, 1987 (51 FR 15 15937)
       clarified that only the actual radionuclides, not the whole waste stream, are considered
       by-product material.
      EPA Clarification of Interim Status Requirements, September 23,1988 (51 FR 24504) extended
       and clarified interim status deadline and qualifications.
    In 1980, with the passage of the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), EPA was authorized to respond to releases or potential releases of any
hazardous substance into the environment, as well as to releases of pollutants or contaminants that may
present an imminent or substantial danger to public health and welfare or  the environment.  Since both
the hazardous waste component and the radioactive component of mixed waste are hazardous
substances as defined by CERCLA, EPA may use its enforcement authorities under CERCLA Sections 104
and 106 to respond to  releases of either component of mixed waste into the environment.

2.3         WHEN MIXED WASTE IS REGULATED UNDER RCRA

    The EPA clarified its position on mixed wastes in the July 3,1986 Federal Register (51 FR 24504) by
stating that while the radioactive component of mixed waste was excluded from RCRA, the
hazardous component was still subject to RCRA. This notice also clarified the role of states in the
regulation of mixed wastes. EPA additionally clarified the requirements for mixed waste facilities
obtaining interim status in the  September 23,1988 Federal Register (53 FR 37045).

    The July 3,1986 notice stated that the hazardous component of mixed waste is regulated under the
base program of RCRA.  Therefore, the state authorization provisions found  at 40 CFR Part 271 apply
to mixed wastes, States which already had authorization for the base RCRA program were given one
year from July 3,1986 (two years if statutory changes were required) to submit plans for authorization

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                                                                             9938.9
of programs to regulate mixed waste. The July 3,1986 Federal Register notice also required states that
are not authorized for the base RCRA program to include provisions to regulate mixed waste in their
package for authorization.

    Whether mixed waste is regulated under RCRA in a particular state depends upon the state's
authorization status. The  September 23,1988 Federal Register notice stated that mixed wastes are
federally regulated under RCRA in states that do not have base  authorization. Mixed waste is
regulated under RCRA by the state in states that have acquired mixed waste authorization. However,
in states with base RCRA authorization mixed waste is not regulated until the state acquires mixed
waste authorization. The states may also have their own regulations that apply.

    The time at which facilities that treat, store, or dispose  of mixed waste are required to notify for
interim status is also determined by the authorization status of the states. The September 23,1988
Federal Register clarified that facilities  which were in existence on or before July 3,1986 were eligible
for interim status.  When the September 23,1988 notice was published there were a number of states
with base RCRA authorization that did not have mixed waste authorization. In these states
facilities that are in existence on or before the date the state receives authorization are eligible for
interim status.

    Facilities that handle mixed waste and that  are regulated under RCRA are responsible for
meeting all RCRA requirements. The inspector should be aware that  if it is not possible to comply with
both RCRA and with requirements of the AEA, RCRA may be inconsistent with the AEA under RCRA
1006 and hence may be inapplicable. EPA considers RCRA requirements to be inconsistent with the
AEA only if compliance with both requirements  is physically impossible. As of the date of this
guidance EPA has identified no inconsistencies in this sense. If a facility declares an inconsistency does
exist, the inspector should notify the Office of Waste Programs Enforcement at EPA Headquarters so
that they may consult  with NRC  on the specific situation.

2.4        REGULATION OF THE RADIOACTIVE COMPONENT

    The radioactive component of mixed waste is regulated by DOE, NRC, and NRC agreement states.
DOE is authorized by AEA to control radioactive operations at DOE facilities. DOE ensures that its
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facilities comply with AEA requirements by issuing departmental orders concerning radioactive
material and waste management.  NRC is authorized by the AEA to regulate source, by-product, and
special nuclear material at all non-DOE facilities (both commercial and government).  NRC issues
licenses to facilities managing and disposing of the  radioactive material; facilities that violate the
terms of their licenses are subject to the sanctions imposed by NRC in accordance with NRCs
Enforcement Policy. Under Section 274 of the AEA, NRC can relinquish to the states portions of its
authority to license and regulate by-product materials, mill tailings, source materials, and  small
quantities of special  nuclear material. States are independent regulatory authorities under the
agreements, but the NRC periodically reviews agreement state programs for adequacy and
compatibility. More detailed descriptions of DOE, NRC, and NRC agreement state roles and
authorities are contained in Appendix B.
2.5         SPECIAL REGULATORY CONCERNS

    Most RCRA regulations do not specifically mention mixed waste. Mixed waste is subject to the
same regulations that apply to any other hazardous waste. However, because of the special nature of
mixed waste it is helpful to examine some of the regulations as they apply to this waste. It would be
too difficult to do an exhaustive analysis, so the discussion in  this section has been limited to land
disposal restrictions and generator requirements, two areas which may be of particular interest at
facilities that handle mixed waste.

2.5.1              Applicability of the Land  Disposal Restrictions to Mixed Wastes

    EPA has the responsibility to assess each RCRA hazardous waste and determine if an appropriate
treatment standard is needed for each waste that is to be land disposed. On November 7,1986, EPA
promulgated the first phase of the land disposal  restrictions (LDR) regulations, which established
the treatment standards for solvents and dioxin-containing hazardous wastes listed in 40 CFR Section
261.31. On July 8,1987, EPA promulgated a final rule establishing treatment standards for a  group of
hazardous wastes referred to as the California-list wastes.  On August 17,1988, June 23,1989, and June
1, 1990, EPA promulgated the treatment standards for the First-, Second-, and Third-Third
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                                                                              9938.9
("scheduled") wastes. The wastes covered by the LDR must meet the treatment standards before they
can be placed in land disposal units. The detailed inspection procedures and the listing of wastes
restricted or prohibited from land disposal can be found in the "Land Disposal Restriction Inspection
Manual" (OSWER Directive No. 9938.1A, February, 1989).

    On June 1,1990, EPA granted a 2-year national capacity variance for certain radioactive mixed
wastes.  The variance, which applies to First-, Second-, and Third-Third wastes and  characteristic
wastes, allows  for continued land disposal in Subtitle C units of these mixed wastes until May 8,1992.
The variance was granted based on a determination by EPA using data supplied by the U5.
Department of Energy, that states there is inadequate treatment capacity for these wastes.  Scheduled
radioactive mixed wastes which are contaminated soil and debris and hazardous wastes containing
naturally occurring radioactive  material are also covered under the variance. Mixed waste  whose
hazardous waste components include a listed solvent waste in 261.31, a listed dioxin-bearing waste in
261.31, or a California-list waste are not included in this variance and are  currently subject to
treatment standards.

    All radioactive mixed wastes which are disposed of by underground injection are currently subject
to the LDR, however. California-list wastes containing PCBs at  concentrations greater than 50 parts
per million (ppm) or Halogenated Organic Compounds (HOCs) at concentrations greater than 10,000
mg/kg became subject to the LDRs on August 8,1988. All other mixed wastes disposed of by underground
injection (including solvents and dioxins, the remaining California-list  wastes, and the First-, Second-,
and Third-Third wastes) had to  comply with the LDR on August 8,1990.

2.5.2               Treatment Technologies for Mixed Wastes

    There are no special treatment standards for most types of mixed wastes. The same technologies
can be used for the hazardous component - whether it is part of a mixed waste or not. For example, a
hazardous waste solvent mixed with  radioactive material has the same treatment standard as the
solvent by itself.  The EPA is aware of concerns that the generally applicable standards may not be
appropriate for some mixed waste streams and is open to the receipt of information that would support
treatability variances (where appropriate)  for mixed wastes.
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                                                                                9938.9
    Although characteristic and First-, Second-, and Third-Third mixed wastes have a variance until
May 8,1992, EPA has established treatment standards for specific categories of these mixed wastes in
40 CFR Section 268.42.  These treatment standards will apply to these wastes in lieu of the treatment
standards for other (nonradioactive) hazardous wastes effective  May 8, 1992.  Several characteristic
high-level mixed wastes generated during the reprocessing of fuel rods have a treatment  standard of
vitrification. Treatment standards have also been  developed for all forms of radioactive mixed waste
containing elemental lead (radioactive lead solids classified as D008).  This D008 treatment standard
does not apply to treatment residuals such as hydroxide sludges, incinerator ashes that can  be
stabilized using conventional pozzolanic stabilization, or organo-lead materials that can be
incinerated and then stabilized as ash. Finally, EPA has established treatment  standards for mixed
waste containing elemental mercury. These  treatment standards are amalgamation using a suitable
material  (for example, zinc, copper, nickel, gold, sulfur) for D009 and U151 and incineration for certain
mercury-contaminated  hydraulic oils.

2.5.3               Storage of Mixed Wastes

    RCRA Section 3004(j) limits the storage of prohibited waste.  This waste may be stored solely for
the purpose of accumulating sufficient quantities to facilitate proper recovery, treatment, or disposal.
For up to 1 year of storage, the burden is on EPA to prove that storage is not solely for the purpose of
accumulating enough wastes for recovery, treatment, or  disposal. After 1 year of storage, the facility
has the burden to prove that storage is indeed being conducted solely for accumulating sufficient
quantities of waste.

    Because few commercial TSD facilities are currently available to accept many types of mixed
wastes, on-site storage  may be the only alternative. As a result, inspectors will  often find that storage
of prohibited mixed waste has exceeded one year.  This lack of treatment capacity is not a defense
under RCRA for violating the storage prohibition. National capacity  variances and case by case
extensions are intended to address the situation where there is a lack of treatment capacity.
Therefore, during the inspection, the RCRA inspector should review and document the facility's
demonstration of why the restricted mixed waste is being stored. EPA is aware of this shortage of
treatment and disposal capacity for mixed waste and  is further evaluating policy options relating to
storage of such wastes.
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                                                                               9938.9
    Generators of more than 1000 kg/mo may not store hazardous wastes, including mixed wastes,

without a storage permit for longer than 90 days, smaller generators may store wastes up to 180 or 270

days depending on the amount generated.  To track the storage period, the owner/operator must mark

the starting date that the prohibited  waste entered storage.
2.5.4               Generator and TSDF Requirements for Mixed Wastes


    The majority of mixed waste facilities the RCRA inspector will encounter will be generators of

mixed wastes. The following is a refresher on the major requirements in 40 CFR  Part 262 for generators

of hazardous waste:


              Notify EPA or the authorized state of the facility's hazardous waste activity as a
               generator of hazardous waste or, if the facility has already notified, file  or amend
               part A applications for units handling mixed  waste;

              Obtain an EPA Hazardous Waste Identification Number:

              Determine if the waste is a hazardous waste through applying knowledge of the waste
               or testing the waste, and maintain any records from such determinations:

              Maintain copies of manifests, manifest discrepancy reports, exception reports or other
               records as required under 40 CFR Part 262 for 3 years;

              Maintain a copy of the facility's contingency plan if the facility is a large quantity
               generator, or meet the requirements of 40 CFR 262.34(d)(5) if the facility is a small
               quantity generator;

              Label hazardous waste tanks and containers with the words "Hazardous Waste" and
               place the start date for accumulation on each container;

              Remove hazardous wastes from the site within 90,180, or 270 days, as applicable; and

              Implement a training program to meet the requirements of 40 CFR Section  265.16 (if the
               facility is a large quantity generator) and  maintain records of the training.
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                            3.  INSPECTION PREPARATION

       Section 2.1 of the RCRA inspection manual (OSWER, 1988) discusses the purposes and
objectives of inspection preparation. For inspectors at mixed waste facilities, however, there are many
new considerations that must be included in the preparation  activities. This chapter presents some of
the ways an inspector can prepare for a mixed waste inspection, including the previsit file review and
health and safety plans.

       Some licensees, particularly nuclear power plants, have  licenses that may impose specific
training or health and safety requirements.  These site specific requirements apply across the board to
facility personnel, NRC inspectors, and RCRA inspectors. For this reason advance coordination with
the facility is  recommended. Coordination is helpful in determining security  requirements of the
facility, personal protective equipment needs, requirements for the inspector to enter any radiation
areas (as defined by 10 CFR 20.202), airborne hazards, bioassay requirements, specific training
requirements, and availability of background information.

3.1            PREVISIT FILE REVIEW AND BACKGROUND INFORMATION ON THE  FACILITY

       The Environmental  Protection Agency (EPA), or the state should have a facility file that  is
accessible and contains relevant information on the facility's compliance status with 40 Code of
Federal Regulations (CFR) 260 through 270. Files should  include updated and documented names and
titles of responsible  persons at the facility, significant design features of the facility, relevant phone
calls, citizen complaints, maps, and other information. Inspectors should also be aware that other
regulatory agencies, such as NRC, may have information or files  on the facility. Other agencies might
also be interested in the RCRA inspector's activities at a facility to plan joint inspections or plan
inspections so that they do not coincide. In any case, these agencies may be a good source of background
information and should be contacted prior to the inspection.

        A quality assurance (QA) program is required at all NRC  licensed power plants. This program
includes documenting deficiencies and nonconformance, using nonconformance reports  (NCRs).
Reviewing NCR logs and reports can assist the inspector in locating specific operational problem areas.
Compliance information may also be available from manifests, effluent and release reports, and
special or unusual occurrence reports.
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       Nuclear production or utilization facilities (e.g. nuclear reactors) are required by 10 CFR 50.34
to include a preliminary  safety analysis report (PSAR) with the application for a construction permit.
Each application for a license to operate the facility must include a final safety analysis report
(FSAR). PSARs and FSARs generally contain information that help the inspector understand the
facility's operations. PSARs are required to contain a description and safety assessment of the site on
which the facility is to be located, a summary description of the facility, a preliminary design of the
facility, an organizational and training plan, and emergency  plans. FSARs are required to contain
information on environmental and meteorological monitoring; description and analysis of the
structures, systems, and components important to the safety of the facility, kinds and quantities of
radioactive materials expected to be produced, and means for controlling and limiting radioactive
effluents and radiation exposures; and organizational structure. Requirements for radioactive waste
management, including releases and monitoring, are found in Chapter 11 of the PSAR and the FSAR. In
addition to the PSAR and  FSAR, the license application is required to include information on
controlling releases of radioactive materials (10 CFR 50.34a),  including an estimate of  the quantity of
radionuclides expected to be released annually to unrestricted areas and a description of the provisions
for packing, storing, and shipping radioactive  materials resulting from treating gaseous and liquid
effluents off-site.

       Technical specifications (10 CFR 50.36a) are also required  for license applications for nuclear
production or utilization facilities. Technical specifications include safety limits, limits on conditions
for operation, surveillance requirements, design features, administrative controls, and written reports.
"Technical specifications on effluents from nuclear power  reactors" (10 CFR 50.36a) require reports to
NRC every 6 months on releases of radioactivity to unrestricted areas and on doses to the public
resulting from effluent releases. Each license may also contain conditions that describe special
measures for  protecting the environment.

       Processes that produce specific hazardous wastes should be identified by  the inspector prior to
the inspection. Information on quantities and characteristics of wastes may be available from the
facility's permits, safety analysis reports (SARs), technical  specifications, and SOPs.  The inspector
can review the facility's operating record to gather information on the use, storage, and disposal of
solvents and other hazardous materials. The inspector should review how wastes are  identified,
which  includes process knowledge and sampling and analyses. (A sample analysis plan must also be
available if the facility is a TSDF.)
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3.2           HEALTH AND SAFETY PREPARATION

       Health and safety requirements are a primary concern during any mixed waste inspection.  The
inspector should identify all requirements for training, personal protective equipment, personal
dosimetry, bioassays, and area monitoring prior to the inspection. Many facility-specific requirements
and potential  hazards are identified in the facility's license and in the  health and safety procedures.
These procedures can be found in  the facility's SARs, technical specifications, management policy,  and
administrative procedures.

       In addition to reviewing facility-specific health and safety requirements, the inspector should
prepare a health and safety plan prior to each facility visit.  This plan must describe safety
equipment and safety procedures that are consistent with  the hazards posed and the inspection
activities to be conducted  at the facility. The persons responsible for preparing the health and safety
plan should include a health  physicist,  who  should contact the radiation safety officer at the facility
being inspected. (EPA health physicists are located in the EPA Office of Radiation Programs in the
regions and at EPA Headquarters.)  This is a major difference between health and safety precautions
that RCRA inspectors traditionally use and those that are  required for protection against radiation
hazards.
3.2.1          As Low As Reasonably Achievable

       The AEA requires that radiation doses be kept "as low as reasonably achievable" (ALARA).
The concept of ALARA recognizes that even low doses of radiation  may have some health effects.
Therefore, it is important for inspectors to avoid unnecessary exposures to radiation. Exposures that
cannot be avoided must be kept as low as possible. Maximum allowable radiation doses are given in
10 CFR Part 20.101. Compliance with ALARA, however, requires radiation exposures to be kept as low
as  possible below these limits.

       The overall objective of ALARA is to keep the total  radiation dose (to workers and the general
population) as low as reasonably possible.  All exposures must be balanced with benefits obtained from
the exposure. Low levels of radiation exposure may result from activities such as routine inspections at
nuclear  facilities.
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       ALARA is implemented through proper design of equipment, an ongoing radiation protection
program (which includes work practices and personal protective equipment), and radiation detection
equipment. Exposures can be minimized through shielding, minimizing time spent near sources, and
maximizing the distance from the radiation source.  Therefore, proper planning, preparation, and
training for a mixed waste inspection is an integral part of keeping the inspector's exposure ALARA.
Coordination with the facility's radiation protection officer may be beneficial in learning about the
facility's ALARA program, policies, and requirements.

3.2.2          Limiting Radiation Doses

       The inspector needs to understand NRC and  EPA regulations for radiation protection prior to
making a mixed waste inspection. These regulations include maximum permissible radiation doses and
definitions for unrestricted radiation areas,  radiation areas, high-radiation areas, and airborne
radioactivity  areas. Radiation dose equivalents to humans are measured  as  "rems" (roentgen
equivalent man).  The SI unit of dose equivalent is  the Sievart (Sv).

       The NRC, EPA, and OSHA dose limits for radiation workers are all 5 rem/yr.  NRC
regulations are in 10 CFR Part 20 (Standards for Protection Against Radiation). Facilities operating
under  NRC licenses must comply with Standards for Protection Against Radiation. EPA's
recommendations concerning Federal radiation protection guidance for occupational exposure is in 52 FR
2822.

       A memorandum of understanding (MOU) between NRC and the Occupational Safety and
Health Administration (OSHA) was published in the October 31, 1988, Federal Register (53 Federal
Register 43950). The MOU defines the general areas of responsibilities for the two agencies at
NRC-licenced facilities.  OSHA regulations for radiation protection are found in 29 CFR 1910.96 and
generally incorporate requirements of 10 CFR Part 20.

       Inspectors and their employers also  have health and safety obligations including maintaining
up-to-date records on their training, medical monitoring and exposures, and qualifications. OSHA
health and safety requirements for hazardous waste  sites are given in 29 CFR 1910.120 and include
requirements for training, medical monitoring, record keeping, and surveillance.
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                                                                               9938.9
Radiation Areas
       The NRC regulations define four different types of radiation  areas. These are:
                     unrestricted area
                     radiation area
                     high-radiation area
                     airborne radioactivity area
       An unrestricted radiation area is described in 10 CFR 20.105 as an area with radiation levels
such that an individual could not receive a whole body dose in excess of 0,5 rem during one calendar
year.   Additionally, radiation levels in unrestricted areas may not exceed the followng: if an
individual were continuously present in the area, radiation levels could not result in his receiving a
dose in excess of 2 millirems in one hour or 100 millirems in seven consecutive days.

       Radiation areas are defined in 10 CFR 20.202(b)(2) as "any area, accessible to personnel, in
which there exists radiation, originating in whole or in part within licensed material,  at such levels
that a major portion of the body could receive in any one hour a dose in excess of 5 millirem, or in any 5
consecutive days a dose in excess of 100 millirems." All radiation areas must have conspicuous postings
with the warning:
                                         CAUTION
                                    RADIATION  AREA

       High-radiation areas are defined  in 10 CFR 20.202(b)(3) as  "any area... in which there exists
radiation...at such levels that a major portion of the body could receive in any one hour a dose in excess
oflOO millirem."  High-radiation areas are required to have limited  access and automatic alarms and
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                                                                         9938.9

 control devices to limit  radiation exposure to a maximum of 100 millirems per hour.  High-radiation
areas must have postings with the warning:
                                      CAUTION
                             HIGH-RADIATION  AREA

       Airborne-radioactivity areas are defined as any area in which the airborne concentration of
radionuclides exceeds the  concentrations given in 10 CFR 20, Appendix B. Airborne radioactivity areas
must have conspicuous postings:
                                      CAUTION
                       AIRBORNE-RADIOACTIVITY  AREA

       In accordance with 10 CFR 20.203, all radioactive materials (including mixed waste) must be
labeled:
                                       
                                      CAUTION
                           RADIOACTIVE  MATERIALS

       Before entering a nuclear facility, the inspector should determine where waste storage areas
are located and whether he or she will be entering unrestricted areas, radiation areas, high-radiation
areas, or airborne-radioactivity areas. The inspector will need to comply with the facility's
requirements for these areas, including training, personal protective equipment, decontamination,

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                                                                               9938.9

dosimetry, and bioassays (if required). Additional information on these requirements is given below.
RCRA inspectors should generally not be entering radiation areas. If it is necessary the inspector
should be escorted by someone from the facility, or accompanied by a health physicist from the state
or regional offices.

Training

       Proper training is extremely important for all mixed waste inspectors since there is a potential
for exposure to both radiation and hazardous chemicals. All inspectors should receive 40 hours
training, as required by OSHA; this training should  include basic health physics, hazardous materials
chemistry, toxicology, industrial hygiene, and industrial safety.  Eight-hour refresher courses should
be given annually following  the initial training.  Additional training may be useful for a  mixed waste
inspector to understand the hazards associated with  radiation. Health physics training should
include an overview of  ionizing radiation (alpha, beta, gamma, neutron), radiation  health effects,
radiation protection regulations, ALARA concepts,  radiation dosimetry and survey monitoring,
decontamination, and use of personal protective equipment.

       There are several ways of obtaining this additional information. NRC training courses are
available at the NRC Technical Training Center in Chattanooga, TN. EPA and authorized state staff
may participate in  these courses to the extent spaces  are available by contacting:
                      Technical Training Center
                      U.S. Nuclear Regulatory Commission
                      Osbome Office Center, Suite 200
                      Chattanooga, TN  37411
                      615-855-6500  FTS 856-6500
       The NRC Technical Training Center's courses assume that participants  have a fundamental
background in radiation health  physics. There is also a course entitled Radiation Safety at Superfund
Sites that is offered by U.S. EPA through the Hazardous Materials Incident Response Training
Program (FTS 684-7537 or  513-569-7537).

       The NRC Agreement State Program provides for agreement state staff a 5-week fundamental
radiation health physics course  through the Oak Ridge Associated Universities. Due to space
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                                                                                9938.9

 limitations, attendance is often restricted to agreement state staff. However, arrangements to
participate in this course or other radiation health physics courses can be made by contacting:
                      Oak Ridge Associated Universities
                      P.O. Box 117
                      Oak Ridge, TN 67831-0117
                      615-576-3576  FTS 626-3576
       In addition to these training courses, several commercial  organizations provide basic and
specialized radiation training.  The NRC Technical Training Center can provide information on these
courses. These courses, however, may not meet an NRC  licensee's training requirements for facility
entry.  Nuclear power plants usually require additional site specific training with yearly updates.
This requirement must be met by facility personnel and inspectors and may take as long as a week.
Check with the facility before going on-site.

Medical Monitoring and Bioassays

       Hazardous waste workers are also required under 29 CFR 1910.120 to participate in medical
monitoring program. This program includes baseline, annual or biennial, and exit examinations. The
baseline examination should include  a  determination of whether the individual can wear a respirator
and  a written opinion as to the individual's ability to complete  fieldwork.

       NRC has the authority to  require individual bioassay  programs for certain nuclear facilities
where there is a significant airborne-radiation hazard, such as uranium mills. This program helps
determine the individual's exposure to  radiation and provides a check on the effectiveness of the
facility's ALARA program, including ventilation and respiratory protection. Bioassay testing
generally consists of urinalysis and in-vivo whole-body/thyroid/lung counting. Frequency of testing
depends upon frequency of exposure.  Bioassay measurements must incorporate a quality control program
equivalent to requirements given  in the American National Standards Institute/Health Physics
Society publication,  ANSI/HPS-N13.30.

       Generally, RCRA inspectors are provided general personal protective equipment such as
respirators, hard hats, and safety shoes by their  EPA or state health and safety offices.  EPA and state
personnel should request from their management any special equipment needed such as
thermoluminescent dosimeters (TLD) or other dosimeters. Radiation support for health and safety
issues is an important element of personal protection at mixed waste facilities. If a licensed facility
operator provides a personal dosimeter, it must be used in addition to the inspector's own dosimeter.

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                                                                               9938.9

       Up-to-date records for all mixed waste inspectors should be maintained on medical monitoring
results (including physician's statement allowing fieldwork, respirator fit test results, personnel
dosimeter results, and bioassay results), their qualifications (including degrees and relevant
experience), and any relevant training (training used to satisfy requirements of 29 CFR 1910.120,10
CFR 19 and 20, and specific requirements for  nuclear facilities).

Personal Protective Equipment

       Preinspection planning should include an awareness of the health and safety hazards of the
facility and knowledge of what equipment is  required to minimize any potential exposures. The
inspector may need to obtain safety shoes, hard hat, eye protection, hearing protection,
anticontamination coveralls,  gloves, head cover, shoe covers, and a respirator. Anticontamination
clothing and equipment should meet the requirements given in ANSI Z-88.2 or a National Institute of
Occupational Safety and Health (NIOSH) "Certified Personal Protective Equipment List." At some
facilities, additional PPE  may be required. This information needs to be obtained in advance to ensure
that the inspector has the proper PPE.  The inspector is responsible for determining the level of
protection  required based on the types of wastes present at the facility and the type of inspection.

       Respirators will be required if there is any potential of  airborne-radiation hazards.
Requirements for airborne-radionuclide levels are given in 10 CFR 20.103 and  20.203, and concentrations
must be kept below the levels given in  10 CFR 20, Appendix B. Respirator protection factors must
comply with requirements given in 10 CFR 20, Appendix A. Respirators must be approved by the
NIOSH and the Mine Safety and Health Administration (MSHA). In addition, they must be properly
fitted and maintained, and they must be used in compliance with a written respiratory protection
program.  Respirator use should  comply with NRCs "Manual of Respiratory Protection Against
Airborne Radioactive Materials," NUREG-0041. Generally,  respiratory protection for radiation
protection is similar  to that for chemical hazards.  Radiation protection respirators  require special
cartridges to  remove airborne radioactivity.

        Monitoring for radiation exposure is an important consideration during a mixed waste
inspection. Monitoring includes personnel dosimeters (film badges or thermoluminescent dosimeters
(TLDs) and pocket dosimeters), bioassay monitoring, Geiger-Muller (G-M) probes (most often used to
detect surface contamination), and micro-R meters (used to provide direct readouts of exposure from
gamma radiation).
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                                                                               9938.9

       It is recommended that inspectors have the following items available for mixed waste
inspections:

                      Direct reading survey meter (G-M counter, ionization chamber, or micro-R
                      meter)
                      Film badge or TLD

       G-M counters are commonly used portable radiation detecting instruments. They give a readout
in counts-per-minute (cpm), or mR-hr and are especially well suited for gamma and beta  measurements.
Special windows must be used for alpha and beta  counting. Micro-R meters generally contain a
scintillation detector and can give a direct readout of exposure rate. Pocket dosimeters are a little
larger than a pen and are generally worn  in a pocket. They contain an ionization chamber and give a
reading of the total accumulated dose.

       Film badges use photographic emulsions for measuring radiation and can measure most types of
radiation except alphas and weak betas because they generally do not travel far enough to reach the
film badge. Photographic films are placed in a small plastic frame that is worn on the pocket or
collar.  Badges are usually processed every month. The commercial firm processing  the badge provides
the customer with an exposure report.

       TLDs are also used for personnel dosimeters. They rely on thermoluminescent phosphors that
trap electrons due to ionizations. TLDs are read by heating the phosphors, which release  electrons
and cause the phosphor to luminesce. Like film badges, TLDs are generally processed monthly by a
commercial firm that also provides an exposure report. TLDs can be more specific and accurate than
film badges, but the proper phosphor must be chosen for the type of radiation and energy level.
Lithium fluoride (LiF) is generally the phosphor of choice for "tissue equivalent" TLDs and is often
used for personnel dosimeters as an alternative to film badges. Alarm dosimeters or "chirpers" are also
available and provide an audible signal if the dose exceeds a preset level.

       Individuals entering radiation areas who may receive greater than 25 percent of the maximum
permissible dose during any calendar quarter are required to have personnel dosimeters (10 CFR
20.202). TLDs and film badges are required to be processed by a dosimeter processor accredited by the
National Voluntary Accreditation Program  (NVLAP) of the National Institute of Standards &
Technology (N1ST).  Automatic monitoring and alarms  are required for high-radiation areas.
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                                                                               9938.9

       Effective radiation monitoring depends on choosing the proper equipment, which must be
properly calibrated, maintained,  and used.  NRC and Department of Energy (DOE) facilities are
required to provide strict quality control for radiation monitoring, to closely monitor worker exposures,
and to report  individual exposures to their employees.  Nuclear facilities have effective health
physics programs in place that are designed to keep all radiation exposures ALARA. Each facility
has a  radiation safety officer who also often coordinates health physics monitoring.  Nuclear power
plants are required to have a radiation protection manager who is responsible for maintaining
occupational exposures ALARA,  coordinating the health physics program with management, and
implementing a safety program.

       Dosimeter use is extremely effective in  monitoring instantaneous and long-term radiation
exposures, when done  properly. As explained above, all NRC nuclear facilities are required to have in
place a radiation protection program and to define radiation areas.  G-M detectors can give immediate
radiation readouts, micro-R meters give a direct readout of exposure, chirpers give warnings of high
doses, and personnel dosimeters provide individuals with their history of radiation exposure. The
inspector should use survey instruments and dosimetry that are supplied by a reputable commercial
firm.  The proper use, calibration, and quality control of radiation detection methods should result in
accurate, reproducible results necessary for maintaining exposures ALARA.

       Calibration and maintenance records should be maintained for all radiation monitoring
equipment (including survey meters), portable gas analyzers, and respirators. If respirators are issued,
then a written respiratory protection manual must also be available.  Certification statements for PPE
should also be kept in a permanent file.  All records pertaining to health and safety protection of
inspectors should be maintained for at least 30 years.
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                                                                               9938.9
                          4.  CONDUCTING THE INSPECTION

       Mixed waste is handled by both commercial operations and  federal facility operations.  Types
of facilities that generate commercial mixed wastes include nuclear power plants, medical facilities,
universities and industry. Federal facilities are typically defense, energy, and research-related
facilities.

       The NRC uses a series of inspection procedures for inspecting various nuclear reactor, fuel cycle
facility, and material licensee operations. These procedures are published in the NRC "Inspection
Manual." The procedures relate to radioactive waste management, radiation protection, fire
protection,  physical security, facility access, inspector qualifications, and documentation of findings.

       To monitor and enforce RCRA provisions, the EPA or authorized states conduct various
inspections at the hazardous waste handlers' facilities. These inspections include RCRA  compliance
evaluation inspections (CEIs), comprehensive ground-water monitoring evaluation inspections (CMEs),
visual  site inspections (VSIs) under corrective action and corrective action oversight inspections, and
permit-related inspections.  The guidance in this section does not repeat the information in  the RCRA
Inspection Manual but references it where appropriate.

       RCRA compliance procedures are very similar for both NRC-licensed and other hazardous
waste facilities. However, due to the nature of the radioactive wastes, some additional consideration
is necessary for mixed waste handlers. This section focuses on the facility entry, opening discussion
with the owner/operator, and  sampling activities as well as unique  considerations for different types
of RCRA inspections at mixed  waste facilities.  For each of the different types of RCRA inspections,
the purpose of the inspection is briefly discussed, appropriate EPA guidance is referenced, and special
considerations for mixed waste are discussed.  Any special considerations involving health and safety
refer to Section 3.2 of this guidance, which discusses health and safety considerations in detail.
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                                                                                9938.9
4.1             FACILITY ENTRY

       Section 4.1 of the RCRA Inspection Manual discusses facility entry procedures. The inspection
can be prearranged with the facility or unannounced. For a prearranged inspection, the entry
procedure should be obtained in advance and preparations made before the inspection. Although the
ability to do unannounced inspections is important, unannounced inspections on a frequent basis at mixed
waste facilities are discouraged due to the coordination and access logistics and access restrictions
imposed by the facility's license. Advance coordination is almost always recommended for a RCRA
inspector, particularly for initial  facility visits. An exception could be when an inspector wishes to see
specific documents, such as manifests or a waste analysis plan, and does not intend to complete a
comprehensive compliance  evaluation inspection.  In these instances, the requested  documents should
be readily accessible. In addition, unannounced inspections may be more easily managed at
NRC-licensed hospitals  and research centers as opposed to commercial nuclear reactors.

       Certain facilities, including those with military,  intelligence, nuclear-related, and  law
enforcement functions,  have special security, training or health monitoring as prerequisites for facility
access. EPA makes a policy of meeting these special requirements to the maximum extent possible, since
these requirements generally do not conflict with the goals of EPA's environmental compliance
responsibilities. Where  necessary, EPA or state inspectors must obtain the appropriate training for
access to nuclear power  plants and appropriate clearances for access to national security information,
facilities, or restricted data at federal facilities. Where  information has been classified,  restricted, or
protected for national security, law enforcement, or other similar reasons, all  such information is to be
maintained in accordance with these  requirements.

        Some mixed waste facilities may have strict security  requirements.  Many  NRC-licensed
nuclear power plants must comply with security requirements for classified national security
information, restricted data, and strategic special nuclear materials.  Employees with a "need to
know" regarding classified  information  are granted either an "L"  or "Q" clearance.  An L clearance is
based on a Federal Bureau of Investigation (FBI) or Office of Personnel Management (OPM) check,
while a Q clearance  is based on a full field investigation and is the highest clearance level for NRC
facilities.  Certain facilities may be  restricted to individuals with either an L or Q clearance, or the
inspector may need to be escorted while in "secure" areas.  Without a clearance, the inspector will be
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                                                                                 9938.9
denied access to any classified documents. Clearances are now being granted to EPA and state inspectors
based on their need to access nuclear facilities.  Inspectors are required to coordinate with the relevant
agency and to complete all necessary security forms.  NRC security requirements for facilities
containing special nuclear materials are given in 10 CFR 73-Physical Protection of Plants and
Materials.

       EPA has programs for personnel security, document security, and protection of confidential
business information. Protection of information from release has not adversely affected EPA's
environmental mission to date and EPA staff with these responsibilities can assist inspection and
compliance personnel in meeting these special access or security requirements. EPA personnel in need of
security clearances for inspections or other compliance monitoring activities should contact the
Personnel  Security Staff at EPA Headquarters for information on how to  obtain the necessary security
clearances. State personnel should first contact  the federal agency. If state personnel encounter
problems or inordinate delays, they should ask the EPA regional  federal facility coordinator for
assistance in obtaining needed clearances.

       Once the inspector has entered the mixed waste facility he or she will generally be
accompanied by representatives of the facility's management and environmental health or safety
staff.  In most cases, it is desirable to be accompanied by facility staff to ensure proper health and
safety precautions are taken, to locate waste generation  sites, and to get answers to questions regarding
the facility's waste handling practices.  Unescorted  inspections may not be feasible. If an unescorted
inspection is  both desired and possible, it will require written procedures, maps, listings of radiation
areas, and possibly security clearance and special training. Unescorted inspections should also
incorporate a "buddy system," whereby at least two  inspectors perform the inspection. If the inspector
anticipates going into any radiation area he or  she should bring a health physicist along. This system
will greatly increase the safety and  effectiveness of the inspection.

       Section 4.1 of the RCRA Inspection Manual discusses consent to entry and denied access. The
EPA recommends that inspectors wanting unescorted access find out from the facility what types of
training are required for  access and that they bring their training certificates with them.  RCRA
inspectors  should comply with all license requirements identifying site specific safety training. If
inspectors  meet all reasonable requirements and are still denied access, then they should refer to the
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                                                                              9938.9
procedures discussed in the RCRA Inspection Manual. These procedures generally include conferring
with various management levels within the EPA regions and may include obtaining a warrant.  When
unescorted access in radiation areas is needed however, inspectors must undergo training. NRC
inspectors undergo this training through in-house courses, but individual facilities can also provide
this  training. Because this training is generally a day long in duration, adequate time must be set
aside by the inspector. If inspections at individual licensed facilities are expected to be  infrequent,
escorted access by licensee personnel may be sufficient. Sometimes, the facility may request to have a
whole  body count (in vivo examination) before and after the inspection; thus, extra time may be needed
for the entry and should be accounted for in the overall inspection schedule.

4.2           OPENING DISCUSSION WITH OWNER/OPERATOR

       The RCRA regulations may be relatively new to the mixed  waste handler.  Inspectors,
therefore, may need to spend more time than usual to explain the RCRA requirements for mixed waste.
This extra time may be required because many mixed waste facility  operations did not know they were
subject to RCRA regulations until sometime after September 23,1988,  when EPA clarified the status of
these facilities (53 Federal Register 37045).   Information on RCRA may help the facility
representative supply more relevant information about facility operations and equipment. Section 4.2
of the RCRA Inspection Manual describes  this opening discussion.

4.3           SAMPLING Acnvrrres

       All sampling of mixed waste or suspected contaminated media must be in accordance with the
principles of As Low As Reasonably  Achievable (ALARA).  (See Section 3.2 of this guidance for a
discussion of ALARA.) Inspectors are also required to have a Radioactive Materials License in order to
take possession of a sample. These licenses can be obtained through the NRC or through an agreement
state's equivalent department. Since sampling and inspecting mixed wastes  during an inspection can
increase radiation exposures, the  inspector's activities may conflict with ALARA.  In resolving this
conflict, the inspector should consider the number of samples that need to be collected, the health risks
associated  with sampling, the associated costs of sampling and  analysis, and the benefit to be derived
from sampling.  The inspector may be able to limit sampling by having in-depth knowledge of the
operations that generate mixed waste, and by reviewing any waste analysis plans at the facility.  The
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                                                                               9938.9
RCRA Inspection Manual  briefly discusses sampling in Section 4.4 and references more detailed EPA
publications on sampling, such as the Technical Case  Development Guidance (EPA OSWER Directive
No. 9938.3.)

       The inspector should also know that not all laboratories are  authorized to receive mixed
waste. To accept mixed waste, the laboratory needs a license from N'RC. Therefore, the inspector
should select a qualified laboratory before sampling. The RCRA inspector can check with the NRC
regional office or proper agency in the agreement state for the name and location of a qualified
laboratory and should request a copy of the license from the  laboratory. The inspector should also be
aware of shipping requirements for radioactive materials under 49 CFR.

4.4            COMPLIANCE EVALUATION INSPECTIONS

       The compliance evaluation inspection (CEI) is the primary enforcement mechanism for
detecting and verifying RCRA violations. The CEI is a routine inspection of hazardous waste
generators, transporters, and treatment, storage, and disposal facilities to evaluate  facility
compliance with applicable RCRA standards promulgated in 40 Code of Federal Regulations (CFR)
262, 263,264,265, 266, and 268. Inspections conducted under  the enforcement program are initiated
either for neutral purposes (facilities selected completely at random), administrative purposes (to
fulfill statutory requirements to inspect TSDFs every 2 years), or "for cause" (that is,  where probable
violations of RCRA have been observed or brought to the attention of EPA through, for example, an
employee's complaint).  Depending on the circumstances, EPA Headquarters, EPA regional offices, or
authorized state agencies select facilities for inspection.

4.4.1          Waste Handling Practices

       Perhaps the most controversial issue associated with CEIs at mixed waste facilities is testing
to determine whether the waste is hazardous, radioactive, or mixed.  The RCRA inspector should be
prepared for the mixed waste handler to claim that the waste is only a radioactive waste and is not
subject to RCRA  requirements. The handlers will probably rely on their knowledge of how the waste is
generated and managed, since testing the waste may conflict with the principles of ALARA.  Inspectors
should ensure that the generator's assessment is based on sound process knowledge.
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                                                                              9938.9
       Available commercial treatment and disposal for mixed waste is very limited.  As discussed in
Appendix C of this guidance, on-site storage is the primary waste management practice for the mixed
waste generator. The mixed waste is usually stored on-site  until the radioactive material decays and
the remaining hazardous  waste portion can be accepted by a commercial facility.

4.4.2           Review of Records

       The RCRA Inspection Manual describes the records to be reviewed during the CEI. Mixed waste
TSD facilities must have waste analysis plans, contingency plans, personnel training records, and
closure plans. Generators (greater than 1,000 kg/mo) of mixed waste that only accumulate mixed waste
in tanks or containers for 90 days or less must have contingency plans and personnel training records.
The following paragraphs describe the elements in each plan that are unique  to facilities that  handle
mixed waste. RCRA inspectors are only responsible for the hazardous portion of the waste, but they
should be aware that the radioactive nature of the waste will affect the management of the  waste,
the waste analysis, contingency and closure plans, and the  personnel training program.

Waste Analysis Plan

       The purpose of the waste analysis plan is to allow  the  owner/opera tor to properly manage the
waste. Because mixed waste may have rather unique management requirements, Ihe waste analysis
plan should explain how the radioactive  nature of the waste is factored into its analysis. The waste
analysis plan  must describe the nature of the mixed waste, its unique sampling  procedure, its test
parameters and test methods, and its test frequency. The sampling procedure and test frequency must
allow for ALARA  considerations. However, the RCRA inspector is not responsible for checking that
the facility meets its ALARA requirements or any other AEA requirements.

Contingency Plan

       The contingency plan must describe the actions facility personnel will take in response to
releases to the environment. The  inspector should review the plan to see how hazardous waste
component is addressed in responding to a release. The inspector should also ensure that the procedures
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                                                                              9938.9
are consistent with other contingency plans (for example, those that satisfy AEA  requirements as well
as RCRA requirements).

       The plan must describe the arrangements made with local  authorities in dealing with both the
hazardous waste concerns and radioactive concerns. In addition to police departments, fire
departments, hospitals, and contractors, the local authorities must involve the local NRC emergency
response team.  In addition, the plan must include a list of emergency equipment at the  facility. This
emergency equipment should include protective equipment for use with radioactive material.

Personnel Training

       The facility's personnel training program must address the handling of radioactive and
hazardous waste. These elements should include ways to respond to the mixed waste release, as well
as measures for health and safety protection. The inspector should check training records and
interview personnel to determine when they last received training.  (Once again, this is  only training
for handling hazardous materials.  Other agencies  are responsible for checking training requirements
for handling radioactive  material.)

Closure Plan

       A closure plan must include a detailed description of the steps needed to remove or
decontaminate all residues of the hazardous waste component  of the mixed waste and contaminated
containment systems and soils during partial and final closure. If the facility is a TSD, the  inspector
must review the facility's closure cost estimate and demonstration of financial responsibility. The
plan must include procedures for cleaning equipment and removing contaminated soils, methods for
sampling and testing surrounding soils, and criteria for determining the extent of decontamination
necessary to satisfy the closure performance standards. The detailed description must consider the
nature of mixed waste and  describe how the radioactive nature of the waste and subsequent
contamination will be addressed. Additional information on RCRA  closure can be found in "RCRA
Guidance Manual for Subpart G Closure and Post-closure Care Standards and Subpart H Cost
Estimating Requirements," January 15,1987, EPA 530/SW-87-010.
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4.4.3          Checklists

       Both EPA and individual states have developed their own RCRA inspection checklists to be
used during the CEI inspection. In  general, these checklists are easily used for mixed waste since mixed
wastes are subject to the same regulations as other conventional hazardous waste. However, during the
inspection, additional comments should be made for certain subject areas relevant to mixed wastes that
have been identified in this guidance, such as ALARA conflicts with the waste analysis plan, to
reflect the mixed  waste concerns.

4.4.4          Documentation/Report

       The RCRA Inspection Manual describes in detail the documentation and report requirements to
be followed in performing the CEI. Those requirements apply to a mixed waste facility as well.

4.5           COMPREHENSIVE GROUND-WATER MONITORING EVALUATION
              INSPECTION

       The objective of a CME is to evaluate an owner/operator's ground-water monitoring system to
determine whether it is adequately designed and operated to detect releases or to define the rate and
extent of contaminant migration from a regulated unit (landfill, land treatment facility, or surface
impoundment), as required under 40 CFR Parts 264,265, and 270.

       The CME involves office evaluation of technical  documentation and field verification of the
ground-water  monitoring system.  The field verification involves verification of the number, locations,
and screen depths of ground-water monitoring wells, piezometers, and water levels (where deemed
necessary). In addition, ground-water samples are usually collected for analysis to assist in
verification of the  analytical precision and methodology of facility procedures. The detailed CME
guidance can be found in "Final RCRA Comprehensive Ground-Water Monitoring Evaluation Guidance
Document" published  by EPA in December 1986.
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                                                                               9938.9
       If the inspector intends to collect ground-water samples, he or she should refer to the discussion
on sampling in Section 3.3 above and the discussion on health and safety in Section 2.2 of this guidance.
Other than health and safety considerations, the general objectives and procedures for a CME at a
mixed waste facility are identical to a CME at other hazardous waste  facilities.  The health and
safety plan to be followed by RCRA personnel should include detailed procedures for determining the
amount and type of radioactivity in each well and the corresponding health and safety protocols and
equipment.

4.6            CORRECTIVE ACTION INSPECTIONS

       In 1984, Congress passed the Hazardous and Solid Waste  Amendments (HSWA), which
provide EPA with the authority to  require corrective action at RCRA TSD facilities that have
released hazardous waste and  hazardous constituents from solid waste management unit (SWMUs) to
the environment.  The corrective action has four phases: RCRA Facility Assessment (RFA), RCRA
facility investigation (RFI), corrective measures study (CMS), and corrective measures implementation
(CMI).  Usually, EPA or an  authorized state agency  will conduct the RFA at the TSD facility seeking a
permit; if further action is needed, the facility will  conduct the RFI, CMS, and CMI under close
oversight by EPA and the state.

       In the proposed corrective action rules under  Subpart S of RCRA (55 FR 30784, July 27,1990) the
EPA defines SWMUs as:

       Any discernible unit at which solid wastes have been placed at any time,  irrespective
       of whether the unit was  intended for the management of solid or hazardous waste.
       Such units include any area at a facility at which solid wastes have been routinely and
       systematically released.

Because the definition of SWMU is very general, the inspector  should confirm the SWMU's definition
in each EPA regional office before conducting an RFA. As discussed in the preamble to Subpart S, EPA
may also require corrective action for non-SWMUs  under RCRA 3005 (c)(3).

       An RFA consists of three sVeps:  preliminary review (PR),  visual site inspection (VSI), and
sampling visit (SV). During the PR, pertinent information related to the facility's operation and

                                             4-9

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                                                                                9938.9
SWMU will be collected from EPA or state agencies. The VSI is conducted to verify the information
obtained during the PR and  to visually inspect the conditions of SWMUs to determine the  releases.
Based on the results of the PR and VSI, EPA should be able to evaluate the releases from SWMUs.
Otherwise, an SV could be conducted to verify the releases from SWMUs.

       During the VSI, the inspector must conduct a thorough inspection to determine the conditions of
SWMUs and any releases from SWMUs. The VSI covers the mixed waste and hazardous waste
management units, but does not cover radioactive waste.

       When a facility conducts an RFI, CMS, or CMI, EPA or  authorized state agencies may be
involved in the oversight of the corrective action process. This oversight consists of work plan review,
technical documentation review, and field observation. Health and safety concerns are the unique
considerations for  corrective action inspections at facilities that handle mixed  waste. The inspector
should refer to the discussion on sampling in Section 4.3 above as well as the discussion on health and
safety in Section 3.2 of this guidance. The inspector should also be aware that the corrective action
inspections are often at portions of facilities that may have been abandoned  or inactive for some time
and therefore have many more uncertainties associated with health and safety.

4.7            PERMIT-RELATED INSPECTIONS

       Facilities applying for a RCRA permit must submit a Part B  permit application to the
authorized agency for review.  After reviewing the permit application, the  authorized agency will
conduct an inspection to verify the conditions described in the  permit application. After the permit is
issued, the facility  must follow certain conditions as specified  in the permit. Thus,  the permit-related
inspections include pre-permit inspections to verify the permit application information and routine
post-permit  inspections to determine compliance with the permit conditions. The activities associated
with the permit-related inspection are the same as those for the CEI. Therefore, the special
considerations for mixed waste discussed in Section 4.4 above, also apply here.
                                              4-10

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                                                                       9938.9


                                   REFERENCES


10 Code of Federal Regulations, Parts 0-199, Energy.

29 Code of Federal Regulations, Part 1900, Section 1910.96, Ionizing Radiation, 1910.120.

40 Code of Federal Regulations, Part 124 and Parts 260-270, 271, and 273, Hazardous Waste
Management.

49 Code of Federal Regulations, Part 261.

50 Federal Register 28728-28730, July 15,1985.

51 Federal Register 24504, July 3, 1986.

51 Federal Register 40572, November 7,1986.

52 Federal Register 15397, May 1, 1987.

52 Federal Register 15940, May 1, 1987.

52 Federal Register 25760, July 8, 1987.

53 Federal Register 31138, August 8,1988.

53 Federal Register, 43950, October 31, 1988.

54 Federal Register 26594, June 23,1989.

55 Federal Register 22520, June 1,1990.

American National Standards Institute, American Society of  Mechanical Engineers, 1989,
Quality Assurance Program Requirements for Nuclear Facilities, ANSI/ASME NQA-1.

Arena, Victor, 1971, Ionizing Radiation and Life. C.V. Mosby Co., St. Louis.

Barger, Melanie S., U.S. Environmental Protection Agency, Office of Waste Programs
Enforcement, Radioactive Mixed Wastes:  A RCRA Enforcement Perspective.

Basic Nuclear Concepts, Unit 7, Radiation - What Is It and  Where Does It Come From.

Clarification of RCRA Hazardous Waste Testing Requirements  for Mixed Waste, Draft, March
13,1989.

Combined Nuclear Regulatory Commission-Environmental Protection Agency Siting Guidelines
for Disposal of Mixed Low-Level Radioactive and Hazardous Waste, March 1987.

Eisenbud, Merrill, 1973, Environmental Radioactivity, Second Edition. Academic Press, New
York.

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                                                                     9938.9
                           REFERENCES (Continued)
Joint Environmental Protection Agency/Nuclear Regulatory Commission Guidance on the
Definition and Identification of Commercial Mixed Low-Level Radioactive and Hazardous
Waste, Office of Solid Waste and Emergency Response (OSWER) Directive 9432.00-2, January
1987.

Joint Nuclear Regulatory Commission/Environmental Protection Agency Guidance on a
Conceptual Design Approach for  Commercial Mixed Low-Level Radioactive and Hazardous
Waste  Disposal Facilities, August 1987.

Low-Level Radioactive Waste Forum, September 1988,  An Assessment of Mixed Waste
Management Issues and Federal Guidance.

Memorandum, Guidance on the Definition and Identification of Commercial Mixed Low-Level
Radioactive and Hazardous Waste and Answers to Anticipated Questions, January 8, 1987.

Memorandum, Applicability of the TC to Mixed Wastes, February  12,1991.

Memorandum of Understanding Between the Occupational Safety  and Health Administration
and the Nuclear Regulatory Commission, published at 53 Federal Register 43950, October  31,
1988.

National Institutes  of Health, Occupational Safety and Health Administration, United
States Coast Guard, Environmental Protection Agency, October 1985, Occupational Safety and
Health Guidance Manual for Hazardous Waste Site Activities. NIOSH publication 85-115.

Nuclear Management and Resources Council (NMRC), January 16, 1989, The Management of
Mixed Waste in the Nuclear Power Industry. RAE-8807-1.

Office of Technology Assessment (OTA), March 1989, Management Practices and Disposal
Concepts for Low-Level Radioactive Mixed Waste.  RAE-8830-1.

Radiation Survey Instruments, Training Publication No. 208n.

Rogers & Associates Engineering Corporation (for Nuclear Management and Resources Council),
January 16,1989, The Management of Mixed Waste in the Nuclear Power Industry.

U.S. Environmental  Protection Agency, December 1986, Final RCRA Comprehensive Ground-
Water Monitoring Evaluation Guidance Document.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,  March
1988, RCRA Inspection Manual.  Policy Directive 9938.2A.

U.S. Environmental Protection Agency, January 1987, RCRA Guidance Manual for Subpart G
Closure and Post-closure Case Standards and Subpart H Cost Estimating Requirements, EPA
530/SW-087-010.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
February 1989, Land Disposal Restriction Inspection Manual.  Policy Directive 9938.1A.

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                                                                       9938.9
                            REFERENCES (Continued)
U.S. Environmental Protection Agency, March 1989,  Radiological Health and Safety Plan for
Environmental Protection Agency Staff and Contractors Entering the Feed Materials
Production Center (FMPC), Fernald, OH.

U.S. Environmental Protection Agency, April 10,1989, EPA Mixed Waste Training Course Draft
Detailed Outline.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Test
Methods for Evaluation of Solid  Wastes, Physical/Chemical Methods, SW-846, Method 1110.

U.S. Nuclear Regulatory Commission Inspection Manual.

       Procedure 83524, External Occupational Exposure Control and Personal Dosimetry

       Procedure 83525, Internal Exposure Control and Assessment

       Procedure 83526, Control of Radioactive Materials and Contamination, Surveys, and
       Monitoring

       Procedure 83723, Training and Qualifications: General Employee Training, Radiation
       Safety, Plant Chemistry,  Radwaste, and Transportation

       Procedure 83726, Control of Radioactive Materials and Contamination, Surveys, and
       Monitoring

       Procedure 83728, Maintaining Occupational Exposures ALARA

       Procedure 83822, Radiation Protection

       Procedure 84522, Solid Wastes

U.S. Nuclear Regulatory Commission, June 1978, Information Relevant to Ensuring That
Occupational Radiation Exposures Will Be as Low as Is Reasonably Achievable.  Regulatory
Guide 8.8.

U.S. Nuclear Regulatory Commission, August 1988, Regulatory Guide 8.22, Bioassay at
Uranium Mills.

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                                                                                9938.9

                                        APPENDIX A

                         RADIONUCLIDE CHARACTERISTICS

       Radiation is high-energy electromagnetic waves or particles  emitted from the nucleus or
electron shells of certain nuclides. A nuclide that spontaneously emits radiation from its nucleus is
called a radionuclide.  The term spontaneous means that the radiation is emitted without any outside
forces causing the emission.  The four types of radiation that come from the nucleus are alpha, beta,
neutron, and gamma.  X-rays are emitted by electrons. Alpha, beta, and neutron radiation are
particles, while gamma and  x-ray radiation are wave radiation.

       The alpha particle is composed of two protons, two neutrons, and no electrons.  The alpha
particle thus has a plus 2 charge. Alpha particles are typically emitted from the nucleus of heavier
atoms such as uranium-238 (U-238), thorium-232 (Th-232), and plutonium-238 (Pu-238). Because of its
relatively large size, the alpha particle cannot penetrate deeply.  Even the most energetic alpha
particle can only penetrate the body as  far as  the dead-cell layer of the skin.

       Alpha particles have kinetic energy that is lost when interaction occurs with matter.  The two
types of interaction are ionization and excitation.  lonization occurs when there is a direct collision
between an electron and an alpha particle. When  the collision occurs, the electron is driven out of the
electron  shell, producing two charges, the negatively charged electron and  the positively charged
atom.

       Ionizing radiation threatens human health because the ions  that are formed can alter or
destroy cells. It is easy to  protect against alpha exposure with personal protective equipment (PPE).
Ingestion must be carefully avoided because damage from  internal exposure would be severe due to the
high ionization potential of alpha  particles and the lack of a protective dead  cell layer.

       Excitation occurs when an atom absorbs energy and this results in the displacement of an
electron from an inner orbit to an outer orbit. When displaced electrons return to the inner orbits, energy
is emitted in the form of electromagnetic wave radiation. Excitation can also threaten human health
by altering cells, depending on the intensity of the wave radiation.
                                             A-1

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                                                                               9938.9

       Beta particles are positively or negatively charged particles emitted from the nucleus of
atoms. Beta particles can cause direct ionization in a similar manner as alpha particles.   Because beta
particles have a smaller mass and charge than alpha particles, they are more penetrating. PPE will
usually protect against beta exposure.

       Neutrons are particles that have no charge. Therefore, they are more penetrating than either
alpha or beta particles. To  lessen the chances of neutron releases, facilities usually place water or a
low atomic weight material around the source to contain the neutrons to the area in and around the
source.

       Gamma rays are wave radiation with no charge or mass. They are the most serious external
radiation health hazard due to  their high penetrating power.  Thick layers of shielding such as lead,
concrete, or steel may be necessary to contain gamma radiation due to its penetrating ability.

       Different radionuclides can cause different amounts of damage to the body not only because of
their emissions but also  their half-lives. Radionuclides with long half-lives that remain  in the body
for long periods of time are especially damaging.

       Radiation doses are measured by the dose delivered to or absorbed by an object (Arena, 1971).
The roentgen is the  standard unit of exposure in air and is defined in terms of the number of ionizations
produced in air by x- and gamma radiation.  However, since biological effects are caused by absorbed
doses, the  "rad" (radiation absorbed dose) is the standard unit.  The rad is defined as 100 ergs of energy
deposited per gram of  absorbing material from any type of ionizing radiation.  Different Tadiaticms
have different capacities for causing biological damage. For example, 100 rads of gamma rays will not
have the same effect as 100 rads of neutrons.

       To  correct these differences, the unit "rem" is used, where rems = rads x QF (quality factor).
The QF is related to linear energy transfer (energy deposited per unit length of travel through the
medium), as shown in Table 2-1. Generally, the higher the rate of linear energy transfer, the more
likely the radiation is to cause damage. The various radiations most frequently encountered during
RCRA inspections are assumed to have the QFs listed in Table 2-2.
                                              A-2

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                                                                                9938.9
              Table 2-1                                             Table 2-2

         Relationship between QFs
        and Linear Energy Transfer                                      QFs
LET
keV per micron in water
35 or less
3-5 - 7.0
7.0 - 23
23-53
53-175

OF
1
1-2
2-5
5-10
10-20
                                                         Radiation                      F

                                                   Gamma and x-rays                   1

                                                   Beta  particles                       1 -1.7

                                                   Neutron                             10

                                                   Alphaparticles                      10-20

Thus, for a given absorbed dose, alpha particles have the greatest efficiency in inducing biological
effects.
                                             A-3

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                                                                              9938.9

                                       APPENDIX B

                      REGULATORY ROLES AND AUTHORITIES

       Under current statutes and regulations, mixed waste can be regulated by three different Federal
agencies as well as a variety of state agencies. The EPA and the NRC use  legal authority under
different statutes to regulate mixed waste at commercial and non-Department of Energy Federal
facilities. EPA regulates the hazardous waste component of mixed waste, while NRC regulates the
radioactive component. EPA and NRC also legally authorize states to implement their own programs
regulating hazardous waste and  radioactive materials,  respectively.  Thus, state agencies can regulate
respective components of mixed  waste depending on how they are authorized. The U.S. Department of
Energy (DOE) has legal authority to  control the radioactive components of mixed waste at DOE
facilities. However, EPA has jurisdiction over the hazardous  waste component of mixed waste at DOE
facilities. Although DOE facilities are not addressed in this document, DOE's roles and  authorities
are briefly discussed in this section to give the inspector a better overall perspective. EPA's authority
is discussed in Chapter 2 of this guidance; this appendix focuses on the roles and authorities of NRC,
DOE and NRC agreement states.

B.I           NUCLEAR REGULATORY COMMISSION (NRC)

       NRC is authorized  by the AEA, as amended, to regulate production and utilization facilities
and the possession and use  of source, by-product, and special nuclear material. Source, by-product, and
special nuclear material are defined in Section 11 of the AEA and  include the radioactive component of
mixed waste. The applicable NRC regulations are contained in 10 CFR  Parts 19, 20, 30, 40, 50, 60, 61,
and 70, and apply to commercial  and  federal facilities, except for DOE  facilities and  contractors.

       NRC issues licenses to facilities managing (and disposing)  byproduct, source, and special
nuclear material.  Facilities, including those which manage  mixed waste, that violate their license
conditions or the applicable regulations are subject to sanctions imposed  by NRC in accordance with
NRCs Enforcement Policy.  NRC's Enforcement Policy is explained in detail in Chapter 0400 of the
"NRC Inspection  Manual."
                                            B-l

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                                                                             9938.9
B .2           DEPARTMENT OF ENERGY (DOE)

       DOE is authorized by AEA to control radioactive operations  at DOE facilities. DOE interprets
the requirements of the AEA as that Act applies to DOE facilities (May 1, 1987 Federal Register. 52
FR 15940).

       DOE ensures its facilities comply with the AEA requirements  by issuing departmental Orders
concerning radioactive material and waste management. DOE departmental orders on radioactive
material and waste management apply to all DOE elements, contractors, and subcontractors.

       DOE adopted a consistent approach with EPA and NRC concerning the regulation of mixed
waste at DOE facilities (May 1,1987 Federal Register. 52 FR 15937). As a result, DOE mixed waste
management is subject to AEA requirements and applicable RCRA statutory and regulatory
requirements. However, if the application of both RCRA and AEA to DOE mixed waste operations
proves conflicting in specific instances, AEA requirements take precedence.

B .3           NRC AGREEMENT STATES

       Under Section 274 of the AEA, NRC can relinquish to the states portions of its authority to
license and regulate by-product materials (fission and activation products), mill tailings, source
materials, and small quantities of special nuclear material (fissile materials). NRC still retains
regulatory authority over:

             Nuclear reactors
             Exports and imports of nuclear materials and  facilities
             Larger quantities of fissionable material
             Consumer products
             Non-DOE federal  facilities

       The NRC regulations covering the transfer of authority to states are contained in 10 CFR 150.
The mechanism transferring NRC authority to states to regulate the radiological health and safety
aspects of nuclear materials is an agreement between the governor of the state and the NRC-hence the
term "agreement state."  Before signing an agreement, NRC must determine that a  state's radiation
                                            B-2

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                                                                              9938.9

control program is compatible with NRCs, meets applicable parts of the AEA, and is adequate to
protect the public health and safety.

       States are independent regulatory authorities under the agreements, but NRC periodically
reviews agreement states programs for adequacy and compatibility.  Under the AEA, NRC may
terminate an agreement state's program if NRC finds it necessary in order to protect the public health
and safety. NRC may also  temporarily suspend parts or all of an agreement with a state in the case of
an emergency situation where the state fails to take necessary action. Facilities affected by the
suspended agreement will be subject to NRC requirements and not the state requirements during the
emergency. As soon as the emergency situation passes, the suspension of state regulations will end.

       Under the AEA, agreement states do not have jurisdiction over federal facilities.  Thus,
agreement states cannot license or regulate by-product materials, mill tailings, source material, and
special nuclear  material at federal facilities, such as Veterans Administration  hospitals, military
installations, or  DOE facilities. Non-DOE federal facilities remain subject to NRC requirements,
while DOE facilities are subject to DOE departmental orders.
                                             B-3

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                                                                              9938.9

                                       APPENDIX C

                             MIXED WASTE OPERATIONS

       Inspectors should understand the universe of mixed waste operations and current waste
management practices for the facilities that handle mixed waste in their region.  Section C.I  discusses
the universe of mixed waste operations and Section C.2 discusses current waste management practices.
       This section should help the inspector identify and better understand the types of operations
that may generate mixed waste. Beyond these general descriptions, the inspector should consider more
formal approaches to identify and prioritize the need for  inspections. One possibility is  to use the
license codes of the U.S. Nuclear Regulatory Commission (NRC). Attached in Appendix F to this
guidance is a list of the license program codes that NRC uses to classify its material licenses.  Reactor
licenses are in  a separate category and  not included in this list.

C.I            UNIVERSE OF MIXED WASTE OPERATIONS

       The Environmental Protection Agency (EPA) has estimated that there are perhaps a few
thousand NRC and NRC agreement state licensees that potentially generate mixed  waste. The types
of licensees  are categorized as follows: industrial, academic, medical, and nuclear power plants.
Section 2.0 of this guidance addressed the definition of mixed waste and briefly discussed radionuclide
and chemical characteristics of mixed waste. Table 4-1 summarizes some of the types of radionuclides
and radiation associated with mixed waste at the different types of facilities. The  following sections
identify potential mixed waste generators by type of license, provide information on the  processes
generating mixed waste, and identify the radioactive and hazardous waste components of each waste
stream.

C.I.I           Industrial

       Industrial operations that may generate mixed waste include manufacturing and distribution
licensees, radioactive waste  service facilities, and facilities involved in either the  processing of
radioactive materials or the production of special nuclear materials. Table 4-2  identifies the different
categories of industrial facilities and the  types of mixed  waste generated.
       About a quarter of all NRC-licensed industrial facilities generate wastes commonly known as
liquid scintillation cocktails.  This waste is produced from general laboratory procedures for

                                             C-l

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                                                                 Table C-l

                                                    Properties of Selected Radionuclides
                                                                                                    9938.9
Radionuclide      Half-Life
Americum-241      453 years
(Am-241)
Carbon-14
(C-I4)
Cesium-137
(Cs-137)
Coba)t-60
(Co-60)
Hydrogen-3
(Tritium) (H-3)
lodine-125
(1-125)
5,730 years
30 years
5.24
12.26 years
60 days
ftlodes and Energies of
Decay

5.4857 and 5.4430 million
electron volt (meV) alphas,
and 0.0595, 0.0263, and other
meV gammas

0.156 meV beta, max
0514 meV beta, 93.5% max
0.662 meV gamma, (85%)
1.17 meV beta, 65% max
1.48meV beta, max
0.31 meVbeta, max
1.17 meV gamma (100%)
1.33 meV gamma (100%)
0.0186 meV beta, max
100%, electron capture (proton
converted into neutron by
orbital electron), followed by
0.035 meV gamma (7%)
                                                  Special Hazards . Target
                                                  Organs

                                                  Hazardous as an internal
                                                  emitter in lungs or gut
Accumulates in fat
Whole body, liver, spleen,
muscle (metabolized as
potassium)
Gastrointestinal tract, whole
body
Whole body (does not
concentrate in any organ;
present with water)
Accumulates in thyroid
                                                                                                    Users. Sources. Additional Information
                               Produced from Pu-239; used in neutron
                               generators; (transuranicradionuclide; found
                               in reactor, industrial, and research wastes
Produced in atmosphere naturally and by
nuclear weapor testing; naturally occurring
in all organisms; used for scientific
radiolabeling; found in industrial, medical
and academic waste

Produced by nuclear weapon testing, and in
thermal reactors; normally present  in
human body; used as a gamma source in
irradiators; found in reactor,  industrial, and
research waste

Produced by nuclear weapons; activation
product of Cobalt-59; used to label vitamin
B12; used as gamma source in irradiators;
found in industrial, research, and reactor
wastes

Natrually present as isotope of hydrogen;
produced naturally iin the atmosphere and
by nuclear weapons; produced in nuclear
reactors; used for scientific radiolabeling
and in nuclear weapons;

Produced from antimony-123; used in
gamma radiography and for  thyroid
screening; found in medical  and research
wastes, industrial wastes
                                                                      C-2

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Radionuclide       Half-Life
Phosphorus-32       14.3 days
(P-32)
Radium-226
(Ra-226)
Strontium-90
(Sr-90)
Sulfur-35
(S-35)
1620 years
28.8 years
86.7 days
Technetium-99      Z.lSxlO5 years
flc-99)
Uranium-235       7.13x108 years
(U-235)
Uranium-238
(U-238)
451x109 years
                    Table C-l (Continued)

             Properties of Selected Radionuclides

tylodes and Pngrgifs of        Speciall HiWiflrds . Target
                               Organs

                               Concentrates in bone
                                       1.707 meV beta, max
4.78 meV alpha (95%)
4.60 meV alpha (6%)
                                       0.54 meV beta, max
                                       0.168 meV beta, max
                                       0.29 meV beta, max
                   4.1-455 meV alphas and 0.145,
                   0.185, and 0.2 meV gammas
4.15 meV alpha (25%) and
0.048 meV gamma (77%) and
4.20 meV alpha (75%)
Concentrates in bone
                               Concentrates in bone and
                               teeth
                                                                      Skin and testes
                                                  Gastrointestinal tract
                               Bone, gastrointestinal tract,
                               kidneys
Gastrointestinal tract, kidneys
                                                                                                                        9938.9
                                                                                  Usera.Sourc.es, Additional information
Produced from P-31, S-34, and S-32; used
tracer studies and for cancer treatment;
found in research and medical wastes

Naturally occurring; past use in industry.
Found in soils and mixed waste cleanups,
industrial, medical

Produced from atomic fission (nuclear
reactors) and nuclear weapons; used as a
beta source in medical treatment. Found in
reactor, medical, research and industrial
wastes

Produced from S-34 and O-37. Used in
medical and industrial research as a tracer;
found in industrial and medical wastes

Fission product; daughter of Mo-99; Tc 99
used widely as a medical tracer; found in
medical, research, reactor, and industrial
wastes

Naturally occurring; used in nuclear
reactors and nuclear weapons; found in
uranium mining and milling wastes and
defense wastes

Naturally occurring; found in nuclear
reactors and nuclear weapons; found in
defense  wastes, industrial wastes
                                                                   C-3

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                                                                                 9938.9
                                           Table C-2

                          Mixed Waste Generated by Industrial Facilities
     Industrial Facilities
    Types of Mixed Waste
Pharmaceutical manufacturers
Liquid scintillation  cocktails*
Organic chemicals
Lead shielding and containers
Sealed-source manufacturers
Liquid scintillation  cocktails
Organic chemicals
Lead shielding and containers
Irradiator manufacturers
Liquid scintillation  cocktails
Organic chemicals
Lead shielding and containers
Biotechnology manufacturers
Liquid scintillation  cocktails
Organic chemicals
Trash/organic chemicals
Fuel storage facilities


Nuclear waste processors
Corrosive liquid
Liquid scintillation  cocktails
Lead decontamination solutions
Waste oil**
Chlorinated fluorocarbon concentrates
 *       Also includes scintillation vial, fluid, and solvent (10 or 20 mL glass or plastic vial containing
        organic chemicals)

 * *     Waste oil included because some states list oil as a hazardous waste
                                               C-4

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                                                                                 9938.9

counting radioactivity in environmental and facility samples. Liquid scintillation cocktails often
contain an organic solvent, such as acetone, toluene, or  xylene (F-listed solvent wastes), that makes the
waste a hazardous waste.  The principal radionuclides of liquid  scintillation cocktails include tritium
(H-3), C-14, S-35, P-32, and 1-125.  Waste processors receive liquid  scintillation fluids and vials from
other facilities and  then crush the vials and separate the fluid. The vials are made of either glass or
plastic. A 10 mL vial contains about 7 mL of liquid while a 20 mL vial contains about 10 mL of liquid.

       During the manufacture of sealed sources (by-product material is encased in a capsule that
prevents leakage or escape of the  material), pharmaceuticals, radiopharmaceuticals, diagnostics, and
irradiators (radiation sources used for medical or industrial purposes), organic chemicals become
contaminated with radioactivity.   Biotechnology manufacturers, that is, facilities that use genetic
engineering and biological processes, generate contaminated organic chemicals during research
experiments. The processes that produce the contaminated organic chemicals include chemical and
biochemical synthesis of product, purification of product, and cleaning of equipment.  The principal
radionuclides found in these types  of mixed waste are Am-241, S-35, C-14, H-3, Cs-137, P-32, Sr-90, and
Co-60.

       Laboratory trash, such as glassware and equipment components, contaminated with both
organic chemicals and radioactivity, is generated during laboratory research. Tritium, C-14, 1-25, and
P-32 are the radionuclides typically found in laboratory trash mixed waste.

       Lead containers and shielding are contaminated with various long-lived fission product
radioisotopes. The pharmaceutical manufacturing industry uses lead containers to store
radiochemicals.  Other industries use lead containers to ship radioisotopes. The inside surfaces of the
containers are rough and difficult to clean.

       Chlorinated fluorocarbons  are used to clean radioactively contaminated protective clothing
and to decontaminate equipment. Traces of the chlorinated fluorocarbon solvent and radionuclides are
found in the residue or concentrate that remains.
       Spent nuclear fuel storage facilities generate mixed wastes from the cleaning of spent fuel casks
and back-flushing of resin filters. The radionuclides include mixed activation and fission products. The
solution is collected and stored in a carbon steel storage tank.  The  pH of the solution is adjusted to 13 or
13.5 to prevent corrosion.
                                              C-5

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                                                                                9938.9

C.1.2  Academic/Medical Institutions

       Research facilities and universities may use both radioactive materials and hazardous
chemicals.  Medical facilities use radioactive materials as diagnostic tools and for therapeutic
applications.  The amount of mixed waste generated by this type of licensee is probably minimal, if
any. Table C-3 summarizes the type of institution and the potential mixed waste generated.

       Medical schools and universities generate liquid scintillation cocktails from laboratory
radioactive counting procedures. These institutions use a wide range of radioisotopes and organic
solvents, depending on the type of research the facility is conducting.

       Lead  in the form of foils, sheets, and bricks is used as shielding during experiments with
various types of radionuclides by both medical and university researchers.  The lead shielding becomes
contaminated with the radionuclides during the research process and may be considered a mixed waste
based on lead's toxicity characteristic laboratory procedure (TCLP) toxicity.  Lead storage and
shipping containers for various radioisotopes are also used by medical and university researchers.  The
lead may be contaminated with radium, Sr-90, Cs-137, Co-60, etc.

       Other hazardous waste components of mixed waste generated at universities are organic
solvents such as toluene and acetone which are used to decontaminate laboratory equipment and waste
oil from pumps and equipment used in radiation areas.  The radionuclides usually associated with
mixed waste containing organic chemicals are H-3, C-14, and S-35. Waste oil may be contaminated
with H-3, Co-60, and Cs-137.

C.1.3  Nuclear Power Plants

       Nuclear power plants contribute the largest portion of commercially generated mixed waste.  As
of 1987,109 boiling water reactors and pressurized water reactors were licensed by NRC. Operation of a
nuclear power plant involves many activities that may generate mixed waste, such as routine and
yearly maintenance operations, health physics decontamination, radiochemical laboratory
procedures, and general plant  operations (NMRC, 1989).
       Nuclear power plants  generate liquid scintillation cocktails as a result of laboratory  counting
procedures for radioactivity in environmental and facility monitoring samples.  More than 5,000 reactor
water analyses are performed each year at nuclear power plants (OTA, 1989).
                                             C-6

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                                                                               9938.9
                                              Table C-3

                    Mixed Waste Generated by Academic/Medical Institutions
      Institution
     Medical schools
     Universities
     Hospitals
    Types of Mixed Waste
Liquid scintillation cocktails*
Lead shielding and  containers
Liquid scintillation cocktails
Organic chemicals
Lead shielding and  containers
Waste oil
Reactive chemicals**
Phenol/chloroform**
Lead shielding and  containers
*      Also includes scintillation vial, fluid, and solvent

* *     Although reported as a possible mixed waste, no information available on these waste types
                                             C-7

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                                                                               9938.9

conducted during the reactor shutdown period, called outage maintenance activities.  Radioactively
contaminated organic chemicals are generated during cleaning of equipment during routine maintenance
activities and during the annual expanded maintenance activities Radioactively contaminated waste
oil is generated from changing oil from pumps and equipment used in contaminated areas.  Chlorinated
fluorocarbon solvents are used to clean protective clothing and decontaminate tools and equipment and
can be in the form of spent solvents, sludges, or filters.
       A mixed waste containing chromates can result when system purification resins are changed.
Chromates are used at some nuclear power plants as a corrosion inhibitor. Wastes containing cadmium
result from the use of welding rods containing cadmium, the cleanup of the welds, and the
decontamination of equipment. A sandlike substance, grit, is used to abrasively clean new welds, so the
welds become contaminated with cadmium.
       Most mixed wastes result from use of hazardous chemicals in the power block of a nuclear power
plant.  Table C-4 lists activities that potentially result in the generation of a mixed waste, along with
the hazardous waste constituent.
C.2    CURRENT WASTE MANAGEMENT PRACTICES
       Under EPA or state hazardous waste regulations, waste generators (including mixed waste
generators) are classified by the total amount of hazardous waste they generate each month. Under
EPA regulations, generators of more than 1,000 kg/mo have the most comprehensive waste management
requirements, generators of between 100 and 1,000 kg/mo have fewer requirements, and generators of less
than 100 kg/mo are conditionally exempt from RCRA requirements. NRC licensees may fall into any of
the three categories.
       EPA estimates that about 1 percent of all licensees that generate hazardous waste may also
need to be permitted as treatment, storage, and disposal (TSD) facilities by either EPA or a state
hazardous waste agency (EPA, 1989). A permit may be required if treatment of the waste is done on-site
and is not part of the original process manufacturing unit. A permit to store waste on-site may also be
required depending on the generator status of the licensee and how long the waste is stored on-site.
Generally, conditionally exempt small quantity generators do not need  a storage permit as long as the
total amount of hazardous waste accumulated does not exceed 100 kg/mo. Facilities that generate
between 100 and 1000 kg/month may hold waste on-site for 180 days (or 270 days if transport distance to
a treatment or disposal facility is more than 200 miles) without a storage permit as long as the total
amount of waste does not exceed 6,000 kg. Full generators may accumulate waste on-site for only 90 days
without a permit.  Facilities that treat, store, or dispose of mixed waste on-site will need to be
permitted.

                                            C-8

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                                                                                    9938.9
                                             Table C-4
                     Nuclear Power Plant Activities that Generate Mixed Waste
Activity
                                                                   Hazardous Constituent
Routine Maintenance
        Pump seal replacement

        Laundry drain replacement
        Electrical splicing/cleaning

        Electrical contact cleaning
        Valve packing
        HVAC filter replacement
        Hot shop machining
Outage Maintenance
        Reactor coolant pump oil change

        Eddy testing

        Oring replacement
        Charcoal filter replacement
        Welding rod studs
        Stud cleaning
        Snubber oil change

        Hot shop machining
        Blast grit

 Health Physics
        Equipment decontamination

        Area decontamination
 Radiochemistry Laboratory
        Reactor water analyses

 Plant Operations
        Bead resin change-out
        Equipment decontamination resins

        Cooling system corrosion control
        Dry cleaning

        Tool decontamination
Acetone
Methyl ethyl ketone (MEK)
Acetone
Ethanol
Isopropyl alcohol
Tricholoroethane
Acetone
Acetone
Methanol
Isopropyl alcohol
Toluene
Cutting oils
Acetone
MEK
Toluene
Trichloroethane

Oil
Miscellaneous solvents
Graphite/alcohol mixture

Acetone
Acetone
Cadmium
Trichloroethane
Acetone
MEK
Acetone
Toluene
MEK
Trichloroethane
Cadmium
Acetone
Ethanol
Dichlorobenzene

Liquid scintillation cocktails
(Toluene, xylene)

Chromates
Acids
Bases
Hydrazine
Chlorinated fluorocarbons
(Trichlorotrifluoromethane)
Chlorinated fluorocarbons
                                                 C-9

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                                                                                 9938.9

       The following sections provide a brief description of each major mixed waste type and current
industry management practices. EPA does not necessarily endorse these industry practices. The waste
management options are discussed to provide the inspector with some background on current industry
handling of mixed waste. The inspector must evaluate each practice individually to determine if it is
appropriate and should determine the status of the waste (for example, is it a hazardous waste?) and
the facility (for example, should it be permitted?).

C.2.1  Liquid Scintillation Cocktails

       Industrial facilities and academic institutions sometimes use liquid  scintillation cocktails that
are exempt from NRC disposal regulations. According to 10 CFR 20.306 scintillation fluids with 0.05
ucuries or less of H-3 or C-14 per gram of medium may be disposed of without regard to their
radioactivity.  These wastes are either incinerated on-site or transferred to a waste- processing  facility
for incineration.  The vials are crushed and rinsed prior to disposal.

       Scintillation cocktails that do not qualify for exemption under  10 CFR 20.306 are either stored
for decay  or placed in long-term storage. Scintillation cocktails containing radionuclides with
half-lives  of 60 days  or less are normally stored for decay. Storage is limited  to less than 2 years (10
half-lives). Many of the liquid scintillation  cocktails used in medical, academic, and industrial
research fall into this category. Liquid scintillation cocktails  are normally collected for storage every
30 days and are stored as one unit.  Each unit is separated by type of radionuclide due to different times
for decay. Storage containers may or may not be shielded depending on level of activity. Once the
radioactivity decays to a releasable level, the scintillation cocktail fluid is often incinerated.

       Scintillation  cocktails containing radionuclides  with  longer than a 60-day half-life are  placed
in long-term storage. Most often the liquid is absorbed prior to storage.  Many types of absorbents are
used, including vermiculite, zonolite, floor-dri, and diatomaceous earth.  Since treatment or disposal
methods are not available at this time, scintillation cocktails are placed in long-term storage until
such time as treatment or disposal capacity exists.

C.2.2  Organic Chemicals

       Management of organic chemicals contaminated with radioactivity is either storage for decay
or long-term storage. Storage for decay is used for those organic chemicals that contain radionuclides
                                              C-10

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                                                                                 9938.9
with less than 60-day half-lives. The wastes are collected, separated by radionuclides, and stored in
the same manner as scintillation cocktails. Once the radionuclides have decayed, the organic
chemicals are disposed of.Wastes placed in long-term storage are normally mixed with an absorbent
material prior to storage. Some storage facilities are currently permitted as hazardous waste storage
facilities. Although disposal methods are available for these wastes, research is currently being
conducted on treatment methods to render the wastes nonhazardous. Such methods are not
commercially available at this time. Some recycling of solvents is also being considered.

       Laboratory trash containing organic chemicals and radionuclides is managed in the same
manner as stated above, either storage for decay or long-term storage. Wastes are generally stored in
55-gallon drums in segregated storage areas.

C.2.3  Waste Oil

       Several methods are used for handling radioactively contaminated waste oil, including
filtration,  solidification, incineration, and long-term storage.  Waste oil may or may not be heated
prior to filtering  with multilayer paper filters. Filtration removes particulate radioactive
contaminants and  the oil is recycled through commercial recyclers. The filters are drained and
disposed of.

       Waste oil is also solidified or stabilized prior to disposal. Two of the three low-level
radioactive waste disposal sites (Richland, Washington, and Beatty, Nevada) will accept solidified
waste oil, while the disposal site in Barnwell, South Carolina, will not accept waste oil in any form.

       Incineration of waste oil may take place either at the generator's  facility or off-site. On-site
waste oil  incineration is controlled through special requirements established in the facility's license.
Waste oil may be listed  as a hazardous waste by a state.

C.2.4  Lead Shielding, Containers, and Decontamination Solutions
Contaminated lead may result from the use of lead as shielding or as storage and shipping containers.
The contaminated lead is stored  in 55-gallon drums. Nuclear waste processors and some nuclear power
plants are decontaminating lead. High-pressure water and chemicals or chemicals alone are used to
remove surface contamination of the lead. Once cleaned the lead shielding and containers are often
reused. The decontamination solutions are solidified and disposed of.

                                              C-ll

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                                                                                9938.9
C.2.5  Chlorinated Fluorocarbons
       Industrial facilities and nuclear power plants are currently storing chlorinated fluorocarbon
concentrates. No treatment or disposal methods have been identified for these wastes at this time.

C.2.6  Corrosive Liquids

       The generation of corrosive liquids at spent nuclear fuel storage facilities is expected to
decrease in the near future because of changes in facility operations. However, this waste will continue
to be stored as a liquid in double-walled carbon steel underground tanks. Prior to disposal, the corrosive
mixture will be neutralized.  The waste will then be solidified and disposed of.

C.2.7  Cadmium/Chromate Wastes

       Depending on the processes at the nuclear power plant (such as use of chromium as a corrosion
inhibitor as discussed in Section C.I .3), cadmium- or chromate-containing wastes may be generated.

C.2.8  Summary of Waste Management Practices

       Table C-5 summarizes current mixed waste management practices by each major waste category
and generator. The majority of mixed wastes are either stored for decay or placed in long-term storage.
Wastes are placed in long-term storage when no other management options exist.
                                              C-12

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                                                                               9938.9
                                          Table C-5

                  Summary of Mixed Waste Management Practices by Waste Type
Facility

Liquid Scintillation Cocktails

      Pharmaceutical manufacturer


      Biotechnology manufacturer


      Other manufacturers


      Waste processors



      Medical school


      University


      Nuclear power plant


Organic Chemicals

      Pharmaceutical manufacturers


      Biotechnology manufacturers


      Other manufacturers


      University

      Nuclear power plants
 Lead
      Pharmaceutical manufacturers
       Biotechnology manufacturers
Store for decay
Put in long-term storage

Store for decay
Long-term storage

Store for decay
Long-term storage

Separate fluid
Decontaminate  vial-incinerate
 nonhazardous liquid

Store for decay
Long-term storage

Store for decay
Put in long-term storage

Reclaim solvent
Incinerate
Put in long-term storage
Store for decay
Put in long-term storage

Store for decay
Long-term storage

Store for decay
Put in long-term storage

Put in long-term storage

Recycle
Put in long-term storage
Put in long-term storage
Decontaminate
                                             C-13

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                                                                               9938.9
                                          Table C-5

                  Summary of Mixed Waste Management Practices by Waste Type (Continued)
Facility

Lead (Continued)

      Other manufacturers

      Waste processors



      Medical schools

      Universities

      Nuclear power plants
Put in long-term storage

Decontaminate
Perform solidification (use
 decontamination solutions)

Put in long-term storage

Put in long-term storage

Decontaminate (on- or off-site)
Put in long-term storage
 Waste Oil

      Other manufacturers

      Waste processors



      Universities

      Nuclear power plants



 Chlorinated Fluorocarbons

      Waste processors

      Nuclear power plants


 Corrosive Liquids

      Spent fuel storage

 Cadmium/Chromate Wastes

      Nuclear power plants
Perform solidification

Perform filtration
Perform solidification
Incinerate

Put in long-term storage

Perform filtration
Perform solidification
Incinerate
 Put in long-term storage

 Recycle solvent
 Put in long-term storage
 Put in long-term storage
 Put in long-term storage
                                              C-U

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                                                               9938.9
                                APPENDIX D
                     LIST OF MIXED WASTE CONTACTS
EPA Headquarters
Ellen Epstein
Office of Waste Program Enforcement
OS-520
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202)382-4849
FTS 382-4849
NRC Headquarters

Nick Orlando
Division of Low-Level Waste
Management and Decommissioning
U.S. Nuclear Regulatory Commission
Washington, DC 20555
(301)492-0566
FTS 492-0566
                            NRC Reeional Offices
U.S. Nuclear Regulatory Comission
Region 1
475 Allendale Road
King of Prussia, PA 19406
(215)337-5000
FTS 346-5000

U.S. Nuclear Regulatory Commission
Region 2
101 Marietta Street, Suite 2900
Atlasnta, GA 30323
(404)331-5000
FTS242-4503

U.S. Nuclear Regulatory Commission
Region 3
Glen Ellyn, IL 60317
(312)790-5500
FTS 388-5500
U.S. Nuclear Regulatory Commission
Region 4
Parkway Central Plaza Building
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
(817)860-8100
FTS 728-8100

U.S. Nuclear Regulatory Commission
Region 5
1450 Maria Lane, Suite 210
Walnut Creek, CA 94596
(415)943-3700
FTS 463-3700
                                     D-l

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                                                                 9938.9
NRC Agreement States

Alabama

Mr. Aubrey V. Godwin, Chief
Bureau of Radiological Health
Environmental Health Administration
Room 314, State Office Building
Montgomery, AL 36130
(205)261-5313

Arizona

Mr. Charles F. Tedford, Director
Arizona Radiation Regulatory Agency
4814 South 40th Street Phoenix, AZ
85040
(602)255-4845

Arkansas

Ms. Greta Dicus, Director
Div. of Radiation Control and
Emergency Management
Arkansas Department of Health
4815 West Markham
Little Rock, AR 72205
(501)661-2301

California

Mr. Edgar D. Baily, Chief
Radiologic Health Branch
Department of Health
714 P Street, Room 498
Sacramento, CA 95814
(916)445-0931
Colorado

Mr. Robert Quillan, Director
Radiation Control  Division
Office of Health Protection
Department of Public Heath
4210 East llth Avenue
Denver, CO 80220
(303)331-8482

Florida

Mary E. Clark, Ph.D., Director
Office of Radiation Control
Department of Health & Rehabilitative
Services
1317 Winewood Boulevard
Tallahassee. FL 32399
(904)487-1004

Georgia

Thomas E. Hill, Acting Director
Radiological Health Section
Depatment of Human Resouces
Room  600
878 Peachtree Street
Atlanta, GA 30309
(404)894-5795

Idaho

Mr. Ernest Ranieri, Supervisor
Compliance Section
Idaho Department of Health & Welfare
Statehouse
Boise, ID 83720
(208)334-5879
                                     D-2

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                                                                 9938.9
Illinois

Thomas W. Ortiger,
DirectorDepartment of Nuclear Safety
1035 Outer Park Drive
Springfield, IL 62704
(217)785-9868

Iowa

Donald A Plater, ChiefBureau of
Radiological Health
Iowa Department of Health
Lucas State Office Building
Des Moines, IA 50319
(515)281-4928

Kansas

Mr. Gerald W. Allen, Chief
Bur.  of Air Quality & Radiation Control
Department of Health &Environment
Forbes Field, Building 321
Topeka, KS 66620
(913)296-1542

Kentucky

Mr. Donald Hughes, Manger
Radiation Control Branch
De[artment of Health Services
Cabinet for Human Services
275 East Main Street
Frankfor, KY 40621
(502)564-3700

Louisiana

Mr.  William H. Spell, Administrator
Nuclear Energy Division
Office of Air Quality & Nuclear Energy
P.O. Box 14690
Baton Rouge, LA 70898
(504)925-4518
Maryland

Mr. Roland G. Fletcher, Administrator
Center for Radiological Health
Department of the Environmnet
2500 Broening Highway
Baltimor, MD 21224
(301)631-3300

Missippi

Mr. Eddie S. Fuente, Director
Division of Radiological Health
State Board of Health
3150 Lawson Street
P.O. Box 1700
Jackson, KS 39215

Nebraska

Mr. Harold Borchert, Direcotr
Division of Radiological Heal thA State
Department of Health
301 Centennial Mall South
P.O. Box 95007
Lincoln, NE 68509

Nevada

Mr. Stanley R. Marshall, Supervisor
Radiological Health Section
Health Division
Department of Human Resources
505 East King Street, Room 202
Carson City, NV 89710
(702)885-5394
                                     D-3

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                                                                9938.9
New Hampshire

Ms. Diane Tefft, Program Manager
Radiological Health Program
Bureau of Environmental Health
Division of Health ServicesHealth &
Welfare Building, Hazen Dr.
Concord, NH 03301
(603)271-4588

New Mexico

Benito J. Garcia, Chief
Community Services Bureau
Environmental Improvement Division
Department of Health & Environment
Santa Fe, NM 87504
(505)-827-2959

North Carolina

Mr. Dayne H. Brown, Chief
Radiation  Protection Section
Division of Facility Services
701 Barbour Drive
Raleigh, NC 27603
(919)-741-4283

North Dakota

Mr. Dana  Mount, Director
Division of Environmental Engineering
Radiological Health Program
State Department of Health
1200  Missouri Avenue
Bismark, ND 58502
(701)224-2348
Oregon

Mr. Ray Paris, Manager
Radiation Control Section
Department of Human Resources
1400 South West Fifth Avenue
Portland, OR 97201

Rhode Island

Mr. Charles McMahon, Acting Chief
Radioactive Materials and X-Ray
Programs
Rhode Island Deprartment of Health
Cannon Building, Davis Street
Providence, RI 02908
(401)227-2438

South Carolina

Mr. Heyward G. Shealy, Chief
Bureau of Radiological Health
S.C. Department of Health and
Environmental Control
J. Marion Sims Building
2600 Bull Street
Columbia, SC 29201
(803)734^1700

Tennessee

Mr. Michael H. Mobley, Director
Division of Radiological Health
TERRA Building, 150 9th Avenue, N.
Nashville, TN 37219
(615)741-7812
                                     D-4

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                                                                  9938.9
Mr. David K. Lacker, Chief
Bureau of Radiation Control
Texas Department of Health
1100W. 49th Street (Mail Only)
Austin, TX 78756
(512)835-7000

Utah

Mr. Larry Anderson, Director
Bureau  of Radiation Control
State Department of Health
288 North 1460 West
P.O. Box 16690
Salt Lake City, UT 84116
(801)538-6734

Washington

Mr. Terry R. Strong, Chief
Office of Radiation Protection
Department of Social & Health Services
Mail Stop LE-13
Olympia, WA 98504
(206)586-8949
                                     D-5

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                                      NRC REGIONAL OFFICES
                                         9938.9
United StatM
NuclMr Regulatory
Commission
                       Addrau
Telephone
I      475 Atendata Road , King ot Prussia. Pennsylvania 19406    2153375000
II     101 Marietta St.. Suite 2900. Atlanta. Georgia 30323        404 331 4503
III     799 Roosevelt Road. Glen Clyn. Illinois 6013 7            312 790 5500
IV     611 Ryan Pla/aDove. Suite 1000, Artinglon. Texas 76011    8178608100
V     1450 Maria Lane. Suite 210. Walnut Creek. California 94596   415 943 3700
                                                           D-6

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PROGRAM
CODE
                                                                9938.9
                                APPENDIX E

                 NRC MATERIAL LICENSE PROGRAM CODES
                                 MARCH, 1990
01100
OHIO
01120
07200
02110
02120
02121
02200
02201
02209
02210
02220
02300
02400
02410
02500
02511
02512
02513
03110
03111
03112
03113
03120
03121
03122
03123
03124
03211
03212
03213
03214
03218
03220
03221
03222
03223
03224
O3225
03231
ACADEMIC TYPE A BROAD
ACADEMIC TYPE B BROAD
ACADEMIC TYPE C BROAD
ACADEMIC OTHER (SECONDARY CODE)
MEDICAL INSTITUTION BROAD
MEDICAL INSTITUTION LIMITED
MEDICAL INSTITUTION CUSTOM
MEDICAL PRIVATE PRACTICE - LIMITED
MEDICAL PRIVATE PRACTICE - CUSTOM
GRANDFATHERED IN-VIVO GENERAL MEDICAL USE
EYE APPLICATORS STRONTIUM-90
MOBILE NUCLEAR MEDICINE SERVICE
TELETHERAPY
VETERINARY NON-HUMAN
IN-VITRO TESTING LABORATORIES
NUCLEAR PHARMACIES
MEDICAL PRODUCT DISTRIBUTION - 32.72
MEDICAL PRODUCT DISTRIBUTION - 32.73
MEDICAL PRODUCT DISTRIBUTION - 32.74
WELL LOGGING BYPRODUCT AND/OR SNM TRACER AND SEALED SOURCES
WELL LOGGING BYPRODUCT AND/OR SNM SEALED SOURCES ONLY
WELL LOGGING BYPRODUCT ONLY- TRACERS ONLY
FIELD FLOODING STUDIES
MEASURING SYSTEMS FIXED GUAGES
MEASURING SYSTEMS PORTABLE GAUGES
MEASURING SYSTEMS ANALYTICAL INSTRUMENTS
MEASURING SYSTEMS GAS CHROMATOGRAPHS
MEASURING SYSTEMS OTHER
MANUFACTURING AND DISTRIBUTION TYPE A BROAD
MANUFACTURING AND DISTRIBUTION TYPE B BROAD
MANUFACTURING AND DISTRIBUTION TYPE C BROAD
MANUFACTURING AND DISTRIBUTION OTHER
NUCLEAR LAUNDRY
LEAK TEST SERVICE ONLY
INSTRUMENT CALIBRATION SERVICE ONLY - SOURCE <100 CURIES
INSTRUMENT CALIBRATION SERVICE ONLY - SOURCE >100 CURIES
LEAK TEST & INSTR CALIBRATION  SERV.  ONLY - SOURCE <100 CURIES
LEAK TEST & INSTR CALIBRATION  SERV.  ONLY - SOURCE >100 CURIES
OTHER SERVICES
WASTE DISPOSAL (BURIAL)
                                    E-l

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                                                                9938.9
PROGRAM
CODE             TITLE

03232        WASTE DISPOSAL SERVICE PREPACKAGED ONLY
03233        WASTE DISPOSAL SERVICE INCINERATION
03234        WASTE DISPOSAL SERVICE PROCESSING AND/OR REOACKAGING
03235        INCINERATION - NONCEOMMERCIAL (SECONDARY CODE)
03240        GENERAL LICENSE DISTRIBUTION - 32.51
03241        GENERAL LICENSE DISTRIBUTION - 32.53
03242        GENERAL LICENSE DISTRIBUTION - 32.57
03243        GENERAL LICENSE DISTRIBUTION - 32.61
03244        GENERAL LICENSE DISTRIBUTION - 32.71
03250        EXEMPT DISTRIBUTION - EXEMPT CONCENTRATIONS AND ITEMS
03251        EXEMPT DISTRIBUTION - CERTAIN ITEMS
03252        EXEMPT DISTRIBUTION - RESINS
03253        EXEMPT DISTRIBUTION - SMALL QUANTITIES
03254        EXEMPT DISTRIBUTION - SELF LUMINOUS PRODUCTS
03255        EXEMPT DISTRIBUTION - SMOKE DETECTORS
03310        INDUSTRIAL RADIOGRAPHY FIXED LOCATION
03320        INDUSTRIAL RADIOGRAPHY TEMPORARY JOB SITES
03510        IRRADIATORS SELF SHIELDED < 10000 CURIES
03511        IRRADIATORS OTHER < 10000 CURIES
03520        IRRADIATORS SELF SHIELDED > 10000 CURIES
03521        IRRADIATORS OTHER > 10000 CURIES
03610        RESEARCH AND DEVELOPMENT TYPE A BROAD
03611        RESEARCH AND DEVELOPMENT TYPE B BROAD
03612        RESEARCH AND DEVELOPMENT TYPE C BROAD
03613        R&D BROAD - MULTISITE-MULTIREGIONAL
03620        RESEARCH AND DEVELOPMENT OTHER
03710        CIVIL DEFENSE
06100        LOW LEVEL WASTE STORAGE AT REACTOR SITES
11100        MILLS
11200        SOURCE MATERIAL OTHER < 150 KILOGRAMS
11210        SOURCE MATERIAL SHIELDING
11220        SOURCE MATERIAL MILITARY MUNITION TESTING
11230        SOURCE MATERIAL GENERAL LICENSE DISTRIBUTION
11300        SOURCE MATERIAL > 150 KILOGRAMS
11400        URANIUM HEXAFLUORIDE (UF6) PRODUCTION PLANTS
11500        SOLUTION MINING (R&D AND COMMERCIAL FACILITIES)
11600        HEAP LEACH, ORE BUYING STATIONS AND BYPRODUCT RECOVERY
11700        RARE EARTH EXTRACTION AND PROCESSING
11800        SOURCE MATERIAL
21130        HOT CELL OPERATIONS
21135        DECOMMISSIONING OF ADVANCED FUEL R&D AND PILOT PLANTS
21210        URANIUM FUEL PROCESSING PLANTS
21215        DECOMMISSIONING OF URANIUM FUEL PROCESSING PLANTS
21240        URANIUM FUEL R&D AND PILOT PLANTS
                                     E-2

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                                                                9938.9
PROGRAM
CODE            TITLE

21310        CRITICAL MASS MATERIAL - UNIVERSITIES
21320        CRITICAL MASS MATERIAL - OTHER THAN UNIVERSITIES
21325        DECOMMISSIONING OF CRITICAL MASS - OTHER THAN UNIVERSITIES
22110        SNM PLUTIONIUM - UNSEALED LESS THAN A CRITICAL MASS
22111        SNM U-235 AND/OR U-233 UNSEALED LESS THAN A CRITICAL MASS
22120        SNM PLUTONIUM - NEUTRON SOURCES < 200 GRAMS
22130        POWER SOURCES WITH BYPRODUCT AND/OR SPECIAL NUCLEAR MATERIAL
22140        SNM PLUTONIUM - SEALED SURGES IN DEVICES
22150        SNM PLUTONIUM - SEALED SOURCES LESS THAN A CRITICAL MASS
22151        SNM U-235 AND/OR U-233 SEALED SOURCES LESS THAN A CRITICAL MASS
22160        PACEMAKER BYPRODUCT AND/OR SNM MEDICAL INSTITUTION
22161        PACEMAKER BYPRODUCT AND/OR SNM INDFVIDUAL
22162        PACEMAKER BYPRODUCT AND/OR SNM MANUFACTURING AND
            DISTRIBUTION
22170        SNM GENERAL LICENS DISTRIBUTION (70.39)
23100        FRESH FUEL STORAGE AT REACTOR SITES
23200        INTERIM SPENT FUEL STORAGE
25110        TRANSPORT - PRIVATE CARRIAGE
  &US GOVERNMENT PRINTING OFFICE: '99'-S17-D03/47O23
                                     E-3

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