Application of EPA regulations to low-level radioactive waste

The survey reported here was conducted with the intent of identifying categories of low-level radioactive wastes which would be classified under EPA regulations 40 CFR Part 261 as hazardous due to the chemical properties of the waste. Three waste types are identified under these criteria as potential radioactive mixed wastes: wastes containing organic liquids; wastes containing lead metal; and wastes containing chromium. The survey also indicated that certain wastes, specific to particular generators, may also be radioactive mixed wastes. Ultimately, the responsibility for determining whether a facility's wastes are mixed wastes rest with the generator. However, the uncertainties as to which regulations are applicable, and the fact that no legal definition of mixed wastes exists, make such a determination difficult. In addition to identifying mixed wastes, appropriate methods for the management of mixed wastes must be defined. In an ongoing study, BNL is evaluating options for the management of mixed wastes. These options will include segregation, substitution, and treatments to reduce or eliminate chemical hazards associated with the wastes listed above. The impacts of the EPA regulations governing hazardous wastes on radioactive mixed waste cannot be assessed in detail until the applicability of these regulations is agreed upon. This issue is still being discussed by EPA and NRC and should be resolved in the near future. Areas of waste management which may affect generators of mixed wastes include: monitoring/tracking of wastes before shipment; chemical testing of wastes; permits for treatment of storage of wastes; and additional packaging requirements. 3 refs., 1 fig., 2 tabs.