Breaking the Code on Challenging Waste - 13267

Mixed low-level wastes (MLLW) with no available path to treatment or disposal have been longstanding challenges for DOE facilities. Today, mixed wastes with no path to treatment or disposal frequently present themselves in the form of combinations of problematic matrixes, problematic EPA Hazardous Waste Codes, and security classification requirements. In order to successfully treat and disposition these challenging wastes, waste management personnel must be more inquisitive and challenge the status quo more than ever before. All aspects of the waste from how it was generated to how the waste is currently being managed must be revisited. Each fact, the basis of each decision, and each regulatory determination must be investigated and validated. Since many of the difficult waste streams were generated several years ago, it can be quite challenging to locate knowledgeable generators from the time of generation. Significant investigation is often required to obtain the needed information to evaluate legacy waste streams. Special attention must be paid to the little things that may not seem central to the issues being investigated. Solutions are sometimes found in these details. (authors)