The State of Development of Waste Forms for Mixed Wastes U.S. Department of Energy's Office of Environmental Management (1999) / Chapter Skim
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3. Mixed Waste Regulations
3. Mixed Waste Regulations
Pages 22-40
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From page 22... ...
These regulations may directly limit DOE's options for selecting a type of waste form by imposing controls on the methods to produce the waste form or by requiring that it pass specific chemical or physical tests. The regulations may also affect the choice of waste form indirectly by imposing performance criteria on the waste form itself, on ~ A recent announcement of proposed Remaking describes strategies that EPA is considering to relieve mixed waste managers from some of the compliance difficulties that arise from dual regulation by EPA and USN8C (EPA, 1999a)
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The acceptance criteria generally do not require specific waste forms, but they may indirectly affect DOE's options by controlling the physical and chemical characteristics of waste materials that are received. TREATMENT AND DISPOSAL REQUIREMENTS The two principal regulatory agencies involved in the treatment and disposal of mixed waste are the EPA and the USNRC.
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24 The State of Development of Waste Forms
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,3 unique wastes from specific industries, and commercial chemical products including residues and spills. These are known as "listed wastes." The second way is for the waste material to exhibit hazardous characteristics of ignitability, corrosivity, reactivity,4 or toxicity; these wastes are referred to as "characteristic wastes." The toxicity characteristic is defined by a list of 40 materials, comprised of seven metals (including lead, chromium, cadmium, and mercury~s, and 33 pesticides and solvents (including chIonnated solvents commonly found In Industrial wastes)
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, which involves the extraction of the solid waste material by a weak acetic acid solution. The presence of characteristic wastes or listed wastes in the extract in excess of established concentration limits confirms the solid waste to be a hazardous waste.
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Listed wastes may be delisted, but may still be subject to the LDRs.7 A more thorough discussion of the TCLP in the context of waste form characterization is provided in Chapter 5. LDRs in 40CFR268 apply to all hazardous wastes, including mixed wastes.
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Each hazardous waste storage or disposal facility must be permitted and approved (40CFR264 and 40CFR2701. · MLLW disposal must meet EPA's hazardous waste landfill regulations, including LDRs (40CFR2681.
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The waste disposal regulations require that releases from the disposal facility meet the radiation protection standards. The USNRC closely regulates the waste form stability and radioactive characteristics of low-level waste materials acceptable for near-surface land disposal through a combination of prescriptive and performance-based requirements (IOCFR61.55-561.
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30 The State of Development of Waste Forms TABLE 2 Allowable Concentrations of I,ong-L~ived Radionuclides for Near-Surface Disposal ..
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Rather than establish designs for a disposal facility or establish strict numerical standards for each radionucTide, USNBC regulations establish performance objectives (IOCFR6l, Subpart C) that define regulatory limits (accepted healthbased standards)
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Recent USNRC documents suggest that a 10,000-year horizon may be an appropriate end point for PA studies covering the disposal system for low-level mixed waste (USNRC, 19971. As will be discussed in Chapters 5 and 6, there are no available tests that can reasonably predict the very long term performance of waste forms.
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WASTE ACCEPTANCE CRITERIA AND OTHER REQUIREMENTS In addition to the waste treatment and disposal regulations that were discussed in the previous section, controls may be imposed at waste treatment or disposal sites through the mechanism of WAC. All DOE facilities are required to have WAC for waste received by that facility for treatment or disposal (DOE Order 5820.2A)
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The WIPP project may accept waste meeting the definition of TRU and MTRU waste, but it may not receive MLLW. Since disposal sites are not available for the majority of MELW, DOE is faced with having to design treatment systems and subsequent waste forms without knowledge of potential constraints that may be imposed in the future.
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Mixec! Waste Regulations 35 .........................................................................................................................................................................
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36 The State of Development of Waste Forms
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(1991, Figure III-1~. COMMENTS AND RECOMMENDATION The state of development of technologies for treating mixed waste and converting it to stable waste forms must be assessed in the context of the regulations that control these wastes.
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From page 38... ...
] 4 The EPA regulatory approach is prescriptive: define the hazardous waste by listing or by its hazardous characteristics as measured by the TRAP, set waste form requirements for resistance to leaching, and require that the disposal facility include features such as a cover, a dual liner, and a leachate collection system.
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EPA's permitting procedure for establishing a disposal facility includes site characteristics but not waste characteristics.~5 The USNRC requires a performance assessment to demonstrate that a disposal facility will meet its performance objectives. The performance assessment must consider both site and waste characteristics.
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The committee recommends that because of the lack of available disposal sites for MLLW and the difficulties in establishing new sites, EM should work with EPA and the USNRC to agree on clear guidelines that describe acceptable waste forms for disposal of mixed waste in future, near-surface disposal facilities. This should be done as soon as possible to reduce the risk of EM deploying technologies that are later judged inadequate because of unanticipated regulatory requirements.
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