Generators of hazardous or mixed waste must comply with the requirements set forth in 40CFR262, or face penalties stated therein.  Researchers are not expected to be experts in the environmental rules and regulations. This course provides the basic needs the generator must fulfill in order to have the environmental and radiological specialists manage those wastes for them and keep SLAC in compliance with the law.

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As the waste generator, you know the most about the waste item’s history, so you can tell us whether or not it was activated while inside the accelerator housing during beam run. You would also be able to tell us if the item was exposed to chemicals and may be contaminated.

You would also be able to provide us with detailed manufacturing information, such as metals used (iron, brass, alloy details), or the MSDS for chemicals.

Officially, SLAC, in its entirety,  is considered one generator. Therefore, individual researchers must take ownership of the by-products of their studies so as to avoid regulatory violations which could potentially shut-down the entire site.

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Evaluate the potential for generating radioactive and mixed waste in your work. Explore options to avoid or minimize its generation.

Prior to any planned generation of mixed waste, complete a Mixed Waste Generation Request Form [pdf] (SLAC Radioactive Waste Manual, Appendix 11A) and submit it to the RP RWMA Group (Joe Christy, x2823, or Olga Ligeti, x2610).  At a minimum, the approval of the ES&H Associate Director is required. If there is no available treatment/disposal path for the proposed mixed waste, then generation of the mixed waste must also be approved by your Associate Director and the DOE SLAC Site Office (SSO).

Upon generation, segregate mixed waste according to (1) the waste's hazardous constituent/property (e.g., lead, mercury, corrosivity, ignitability, etc.) and (2) the waste’s physical form (i.e., segregate liquids and solids).

Package, mark, and label the mixed waste in accordance with the instructions of Chapter 5 in the SLAC Radioactive Waste Manual [pdf].

Complete a Radioactive Material Declaration Form [pdf] (SLAC Radioactive Waste Manual, Appendix 5B).

Notify the RP Field Operations Group (x4299) that the waste is ready to be transferred to the Radioactive Material Storage Yard (RAMSY).

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Just like hazardous waste, mixed waste must be managed in accordance with EPA/California hazardous waste regulations. Under the hazardous waste regulations, SLAC must transfer the mixed waste to a properly licensed/permitted treatment, storage, and disposal (TSD) facility within 90 days of generation, or risk being in violation of the hazardous waste regulations. Failure to comply with the 90-day storage limit could subject SLAC to regulatory fines administered by the state of California and/or the federal EPA.

Because mixed waste is both hazardous and radioactive, the available treatment technology and disposal capacity is very limited, and in some cases, may not exist. For those treatment and disposal options that are available, the TSD facility waste acceptance process is so rigorous, that, complying with the 90-day storage limit may not be possible.  These two issues present a major challenge to SLAC to comply with the 90-day storage limit.

In addition to the regulatory compliance challenge, treatment and disposal of mixed waste is very expensive:

• In 1997, treatment and disposal of only 5 gallons of (radioactive) trichloroethane cost SLAC nearly $20K.
• In 2001, treatment and disposal of < 250 ft³ of (radioactive) elemental lead and lead contaminated waste cost SLAC nearly $110K.
• In 2001-2002, treatment and disposal of nine 4-foot fluorescent light bulbs and one sensor (metal tubing with < 1 lb of elemental mercury) cost SLAC nearly $20K.

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For SLAC internal purposes, any hazardous waste that is also radioactive is a “mixed waste”.  This includes items that would normally be recycled if they were not radioactive: batteries, brass/bronze items, compact fluorescent lamps, fluorescent lamps, incandescent lamps, and lead-soldered items (e.g. circuit boards, copper piping, etc.).

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Use the Mixed Waste Generation Checklist [pdf] in the SLAC Radioactive Waste Manual (Appendix 11B), when planning work operations.

When working in an RMMA, take all possible precautions to prevent inadvertent irradiation or radioactive contamination of hazardous materials. Maintain good housekeeping practices and remove all hazardous materials when no longer needed.

Do not introduce hazardous materials into radioactive processes/work operations if such use could result in the generation of a mixed waste. Use non-hazardous substitutes or modify the process to prevent the generation of mixed waste.

Do not introduce hazardous materials into the design/manufacture of accelerator equipment/components if the equipment/component could subsequently become activated or radioactively contaminated.

Segregate hazardous waste/material from radioactive waste/material in order to prevent cross-contamination.

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By definition, any hazardous waste generated at SLAC, if it becomes radioactive (activated and/or radioactively contaminated), is a mixed waste.  The types of mixed waste generated at SLAC in the past include the following:

• Asbestos piping insulation
• Brass valves, fittings, etc. (lead)
• Compact fluorescent lamps (lead)
• Elemental lead, lead contaminated debris, and lead-soldered items (such as electronic components, circuits boards, soldered copper piping)
• Fluorescent lamps (mercury)
• Fluorescent lamp ballasts (oil, PCB, DEHP)
• Incandescent lamps (lead)
• Solvents (Trichloroethane, Dynasolve)
• Spent ion exchange resin (copper)
• Temperature sensor with elemental mercury
• Used vacuum pump oil and contaminated rags/absorbents

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A list of common hazardous materials that could become a mixed waste (if radioactive) can be found here.

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Under the hazardous waste regulations, scrap metal is excluded from the definition of hazardous waste provided the metal is recycled. Therefore, if you have a scrap metal that meets the definition of a hazardous waste, but you can recycle it, you do not have to manage it as hazardous waste.

At SLAC, (non-radioactive) scrap metal is transferred to Salvage who then arranges for the metal to be recycled. However, radioactive scrap metal cannot be recycled through Salvage, but must be disposed.  If disposed, scrap metal is not excluded from the hazardous waste regulations and must be managed as a hazardous waste if it exhibits a hazardous characteristic (e.g., toxic due to metal content).

Brass Items:

Historically, lead (potentially 1-8% by weight) has been added to brass to improve workability of the metal. Based on laboratory analysis, SLAC radioactive items made of brass do contain lead levels that exceed regulatory levels established for disposal.

Soldered Items:

Soldering typically employs filler metals of tin and lead, often referred to as soft solder. Based on laboratory analysis of copper piping with lead-soldered joints, the solder does contain lead levels that exceed regulatory levels established for disposal.

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Brass items:

Radioactive items made solely of brass are to be managed as mixed waste. If, however, a radioactive waste item is not made solely of brass (i.e., a brass piece is part of, or attached to, the larger waste item), manage the item as radioactive waste only. Upon receipt of such items, RP will evaluate the item to verify its non-hazardous classification. Therefore, do not remove brass pieces from the larger, radioactive waste item until this evaluation has been completed.

Soldered items:

The following soldered items are to be managed as mixed waste:

• Incandescent lamps
• Compact fluorescent lamps with a solder button
• Items with circuit boards
• Computer monitors

Other soldered items need to be evaluated on a case-by-case basis. Manage these items as radioactive waste only.  Upon receipt of such items, RP will evaluate the item to verify its non-hazardous classification. Therefore, do not remove soldered pieces from radioactive waste items until this evaluation has been completed.

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Contact your ES&H Coordinator,

Consult Chapter 11 of the SLAC Radioactive Waste Manual [pdf],

or Call Joe Christy (x2823) or Olga Ligeti (x2610) of the RP Department.

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