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University of Washington policy states that users of radioactive material must not
produce mixed waste as a result of laboratory processes.
Why?
- There is no means for disposing of mixed material. Vendors and waste disposal
facilities will not accept mixed waste.
- If a lab attempts to dispose of mixed waste as either radioactive waste
or chemical waste the fines and penalties to the University of Washington will
be severe and could result in a CEASE and DESIST Order. This would
prevent the University of Washington from using radioactive material until
the order is rescinded.
- Fines and fees of up to $250,000 per year may be assessed against
the University of Washington by federal and state agencies if mixed wastes were
generated and/or stored on campus.
Most mixed wastes consist of low level radioactive wastes combined with
hazardous materials. This presents several challenges because each type of
waste is regulated by a different agency, with different laws.
One challenging aspect of mixed waste is that radioactive waste is regulated
by the Atomic Energy Act (AEA) and hazardous materials are regulated under the
Resource Conservation and Recovery Act (RCRA). That means that both the Nuclear
Regulatory Commission and the Environmental Protection Agency are involved. RCRA
specifically excludes from its definition of solid waste, "source, special nuclear,
or byproduct material as defined by the AEA". Trying to properly handle materials
that are subject to two sets of regulations is difficult and often very costly.
But the underlying issue is that nuclear waste transport and disposal equipment
and canisters are not designed to contain hazardous waste, which might be corrosive
or flammable. In turn, hazardous waste landfills are not equipped to handle highly
radioactive material. And incineration, a common end for hazardous waste, would
release radioactive elements to the atmosphere.
A list of characteristics and examples of hazardous wastes is available in
Radiation Safety Memorandum No. 15. (If you do not have an available copy,
please contact Radiation Safety at
radsaf@u.washington.edu or 206.543.0463
to request one.)
Most low-level mixed wastes consist of low level radioactive wastes combined
with hazardous materials in the same matrix. This presents several challenges
because each type of waste is regulated by a different agency, with different
rules and applicable laws.
The following are the "Official Definitions" for Low Level Radioactive Waste
and Hazardous Waste:
-
Low Level Waste (LLW)(Radioactive)
- LLW is defined in 10 CFR 61.2
(
Code of Federal Regulations) as
".radioactive waste not classified as high-level radioactive
waste, transuranic waste, spent nuclear fuel, or byproduct
material as defined in section 11e.(2) of the Atomic Energy Act"
-
Hazardous waste
- This type of waste is either listed as a hazardous
waste in Subpart D of 40 CFR Part 261.31-33 or which
exhibits any of the hazardous waste characteristics identified
in Subpart C of 40 CFR Part 261.20-24 (ignitability, corrosivity,
reactivity, toxicity).
*Much of the information presented here is taken from a pamphlet published
by the EPA entitled "Low-Level Mixed
Waste, A RCRA Perspective for NRC Licensees", Dated August, 1990.
Exceptions to the production of mixed waste includes
Liquid Scintillation Fluids
which can be legally shipped to a contract waste disposal vendor to be burned,
and radioactive materials mixed with a hazardous component
that can be neutralized or deactivated in the laboratory. A list of
characteristics and examples of hazardous wastes is available in Radiation
Safety Memorandum No. 15. (If you do not have an available copy, please
contact Radiation Safety at
radsaf@u.washington.edu or 206.543.0463
to request one.)
The Radiation Safety Office will not approve the purchase of radioactive
materials that are labeled to or mixed with a hazardous component unless
it can be shown that the hazardous component is neutralized during use.
The concern of the University of Washington Radiation Safety Committee is that,
from past experience it has become evident that mixed materials will
eventually end up as mixed waste. This puts the University in violation of
mixed waste regulations and has cost various departments a lot of time and money.
Fortunately in many instances the material produced was not a mixed waste or
could be converted to a non-hazardous radioactive waste.
If you believe you may be ordering or generating mixed waste contact
Radiation Safety at
radsaf@u.washington.edu or 206.543.0463 prior
to beginning your work.
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