Summary of Mixed Waste Requirements

 

3.1       What Is Mixed Waste?

Mixed-waste storage at the Hazardous Waste Handling Facility (HWHF) is governed by the Part B Permit, and is subject to dual regulations by EPA and DOE. A compliance order, known as the Site Treatment Plan, governs the treatment of mixed waste once it reaches the HWHF. This compliance order was issued to all DOE sites, because treatment technologies and facilities are scarce, and the waste must be stored in excess of one year.

In fiscal year (FY) 2003, Berkeley Lab began recharging generators for the management of mixed wastes due to the cost of management, treatment, and disposal. All mixed wastes received at the HWHF will be recharged to the generator according to the latest pricing structure.

In essence, all mixed waste must meet the segregation, packing, labeling, and storage guidelines for both radioactive and hazardous wastes. All mixed wastes should be segregated from hazardous or radioactive wastes. Below are the most common mixed- waste categories, and their description, segregation, packaging, labeling, and pickup requirements. For other waste categories, please contact your generator assistant.

3.2       Liquid Mixed Waste

3.2.1      Segregation

Mixed radioactive liquid wastes with short-lived isotopes [e.g., < 30-day half-life (³²P)] should be segregated from isotopes with half-lives between 30 and 90 days (³⁵S, ¹²⁵I) and from long-lived isotopes (³H, ¹⁴C).

3.2.1.1   Decay-in-Place Storage

The Waste Management (WM) Group provides decay-in-place storage at the HWHF for liquids containing isotopes with half-lives < 90 days. Once the waste has decayed through a minimum of 10 half-lives, and an analysis has confirmed that all isotopes are below minimal detectable concentrations, it will be reclassified as hazardous.

3.2.2      Packaging

All mixed radioactive liquid wastes must be stored in a container with a tight-fitting lid and a structural integrity that is compatible with the waste. A variety of containers are available from vendors. If you have questions regarding the compatibility of your waste with the container, please contact your generator assistant.

Accumulate mixed radioactive liquids in an appropriately sized container. If your process generates a small amount of waste, do not accumulate the waste in a 5-gallon container. Use a smaller container and request a waste pickup more frequently. Conversely, do not overfill containers. This creates a safety hazard to those around you and to the RCTs upon pickup, and might create potential contamination issues.  You are also charged based on the size of the container, not the amount of waste.

3.2.3      Labeling 

A Hazardous Waste Label (Figure 3-1) and a Radioactive Material Tag (Figure 3-2) must be attached to the container once the first addition of waste is placed in the container. Sections A, F, and G of the Radioactive Material Tag, with the exception of the generator signature, must be filled out. If there is a possibility of contaminating the Radioactive Material Tag while adding waste to the container, you may post the Tag nearby, but the container must refer to the Tag number (e.g., R0XXXX). In most cases, the radioactive liquid mixed-waste container receives multiple additions of waste until it is full. In this case, an Accumulation Log is used to record these multiple additions. Do not use the Radioactive Material Tag to record multiple additions of the same isotope to the container.

3.2.4      Storage

The storage of your liquid mixed-waste container must be in a mixed-waste satellite accumulation area (MWSAA). An MWSAA is similar to a hazardous waste SAA, but must be located inside your Radioactive Materials Area (RMA).

Figure 3-1. Example of a properly completed Hazardous Waste Label.		Figure 3-2. Example of a Radioactive Material Tag.

3.2.5      Setting up an MWSAA

The MWSAA must be located within the boundaries of your RMA, at or near the point of waste generation, and must be under the control of the generator. The MWSAA must be at or near the site where the waste is generated so the MWSAA can be controlled by staff while they are working. Your MWSAA must be located in the room where the mixed waste is generated, or in an immediately adjacent room, within your RMA (with no intervening hallway). The intent of this requirement is to provide virtually full-time monitoring of the MWSAA by the individual(s) generating the waste.

Fire Code requires that the MWSAA be located away from all exit doors or areas where it could hamper egress in the event of a fire or spill. Appropriate spill cleanup materials should be located near your MWSAA, especially if large amounts of mixed wastes (up to 55 gallons) are accumulated.

The MWSAA must be clearly designated using the purple sign depicted in Figure 3-3. If there is uncertainty regarding the boundaries of the MWSAA, the area should be clearly marked off with tape, arrows, and other signage to unambiguously define the MWSAA boundary. All mixed wastes must be stored in the MWSAA. Maximum storage allowed is 55 gallons of any particular mixed waste stream, or up to 1 quart of acutely or extremely hazardous wastes (see Appendices II and III, respectively). If you wish to accumulate more than 10 gallons (and fewer than 55 gallons) of flammable-liquid mixed waste in an MWSAA, Fire Code requires that your MWSAA be located in a metal “flammables” cabinet. This determination might also be influenced by storage of other flammable liquids in the vicinity of your MWSAA. If you have questions concerning Fire Code applications in your work area, please contact the Berkeley Lab Fire Marshall at x6370.

All mixed wastes must be in containers compatible with the waste. Accumulate liquid corrosive mixed wastes in polyethylene or plastic containers that are known to be compatible with acids or bases. Flammable mixed wastes may not be accumulated in plastic containers of any type other than a listed and approved safety can. (Approved safety cans are available from the Waste Management Group in 5-gallon, 2.5-gallon, and 1-gallon capacities.) If you have small amounts of flammable mixed waste, glass or metal containers may be used, but the maximum allowable glass-container size is 1 pint for Class IA liquids, and 1 quart for Class IB liquids (see Section 1.2.3.1 for further discussion of flammable liquid waste storage).

 

Figure 3-3. Mixed Waste Satellite Accumulation Area (MWSAA) sign.

 

Keep primary waste containers tightly closed at all times except when you are adding waste. The container may be opened up to 15 minutes while you add waste. A funnel in a container opening is not considered closed unless the funnel itself seals to the container and would prevent spillage. Container closures must be secure. Cork, rubber, or ground-glass stoppers; aluminum foil; and polyethylene film or parafilm are not allowed. If the waste is likely to generate gases during storage, vented caps should be used, or the waste should be treated using an approved benchtop treatment procedure. Plastic bags used as containers must be closed (twist-tie, ziplock, tape, staple, or spring clamp). Do not add waste to a mixed waste container after you have submitted the pickup requisition for that container to the HWHF.

Secondary containment is required for all liquid mixed wastes and all wastes accumulated in glass containers. The secondary containers must be compatible with the chemicals they contain. The requirement for secondary containment of waste containers in an SAA or MWSAA is a best-management practice followed throughout industry and government. Secondary-containment capacity of 110% of the largest container being stored is an industry standard. The secondary-containment requirement depends only on the largest container in storage, not on the actual volume of waste being stored. Remember that physical space and segregation of incompatible chemicals in secondary containment are important as well. Each container must be stored safely.

Metal containment is acceptable for noncorrosive wastes.

All liquid mixed wastes require secondary containment based on the largest container stored in the MWSAA. For example:

A lab MWSAA contains three 1-liter bottles of waste. Secondary containment should be able to contain 110% of 1 liter or 1.1 liters. In this case, an 8” × 10” plastic photo tray is acceptable. (8” × 10” × 1” = 80 cubic inches or 1.3 liters).

Secondary containment tubs and trays are available from several suppliers with whom LBNL has system contracts that facilitate ordering. Other plastic trays and tubs are available from suppliers such as VWR, with a two-day delivery time. Appropriate containment options can be found on the Labels/Supplies section of this Web page.

Keep incompatible wastes physically separate in secondary containment as well as in the primary container (e.g., acids and bases; oxidizers and organics; water reactives and aqueous wastes).

California regulations allow waste accumulation for up to one year in an MWSAA; however, under Berkeley Lab policy, waste may accumulate in MWSAAs for up to 275 days (nine months).  This is not a HWHF permit condition. Waste containers should be requisitioned for pickup as soon as they become full. Waste remaining in an MWSAA greater than one year will be subject to an automatic Noncompliance and Corrective Action Report (NCAR).

Do not store chemicals, empty bottles, or other items in your MWSAA, because these items might be mistaken for unlabeled mixed waste. Good housekeeping practices should also be implemented to provide for easy access to your MWSAA.

Figure 3-4. Example of a completed Radioactive/Mixed Waste Requisition Form.

3.2.6      Pickup

When your liquid mixed waste container is full, or is approaching the 275-day (9 month) accumulation time, tighten the lid on the container, and don’t add further waste. Complete the remainder of the Radioactive Material Tag summarizing the isotopes (one entry for each isotope) and constituents (buffers, etc.) based on Accumulation Log entries. Account for 100% of the constituents (estimates are acceptable). Fill out the Radioactive/Mixed Waste Requisition Form (Figure 3-4). Fax a copy of the Requisition Form, Radioactive Material Tag(s), and Accumulation Log(s) to the Waste Management Group at x4838. After the Waste Review Process, your waste will be picked up by your Operational Health Physics (OHP) Radiological Control Technician (RCT) and Waste Management technician, and brought to the HWHF, where it will be stored pending packaging for shipment.

3.3       Mixed Waste Scintillation Vials

Note:  In recent months, we have discovered a regulated hazardous constituent in several batches of UltimaGold (sold by Packard) scintillation fluid. When radioactive material is added at the research bench, this becomes mixed waste and will be charged to your project account. If you are using UltimaGold scintillation fluid, please contact your generator assistant for batches that do not have this problem, or seek an alternative.

3.3.1      Segregation

Significant cost-efficiency can be achieved if scintillation vials are segregated into the following groups.

1.      Vials with radioactivity of ≤ 0.05 microcuries per mL per vial of ³H and/or ¹⁴C, and vials with isotopes with a half-life of < 30 days with no other isotope.

2.      Vials with radioactivity of > 0.05 microcuries per mL per vial of ³H and/or ¹⁴C, and vials with isotopes with a half-life of > 30 days, excluding alpha-emitting isotopes.

3.      Vials with alpha-emitting radioactivity.

Used scintillation fluid such as Hionicfluor, Picofluor, and some batches of Ultima Gold (see above) are regulated as hazardous wastes. All vials containing mixed wastes should be segregated from nonmixed wastes. Contact your generator assistant for more details.

3.3.2      Packaging

Scintillation vials are collected in a plastic bag inside a 12.2 gal container (Figure 3-5). Tighten the screw caps of the scintillation vials prior to placing them in the mixed waste container. The lid of the 12.2 gal container should be in place at all times unless you are adding vials to the bag. Do not overfill the plastic bag. This creates a safety hazard to those around you and the RCTs upon pickup, and might create potential contamination issues. Since the plastic bag is the waste container, the 12.2 gal container suffices for secondary containment.

Figure 3-5. 12.2 gal container for collecting scintillation vials.

3.3.3      Labeling 

A Radioactive Material Tag (Figure 3-2) must be attached to the container once the first scintillation vial is placed in the container. Sections A, F, and G of the Tag, with the exception of the generator signature, must be filled out. A complete and accurate Hazardous Waste Label must also be attached. If there is a possibility of contaminating the Radioactive Material Tag while adding waste to the container, you may post the Tag nearby, but the container must refer to the Tag number (e.g., R0XXXX).

In most cases, the scintillation vial container receives multiple additions of waste until it is full. In this case, a Mixed Waste Accumulation Log (Figure 3-6) is used to record these multiple additions (e.g., number of vials, isotopes, activity). Do not use the Radioactive Material Tag to record multiple additions of the same isotope to the container.

 

Figure 3-6. An example of a Mixed Waste Accumulation Log.

3.3.4      Storage

The storage of your scintillation-vial mixed-waste container must be in an MWSAA. An MWSAA is similar to a hazardous waste SAA, but must be located inside your Radioactive Materials Area (RMA).

 

3.3.5      Pickup

When your scintillation vial container is full, or is approaching 275 days (9 months) from the accumulation start date, close the bag by twisting and taping the end (Figure 3-7). Place the lid on the 12.2 gal container, and twist it shut. Complete the remainder of the Radioactive Material Tag by summarizing the isotopes (one entry for each isotope) and constituents (type of scintillation fluid, lot number, etc.) based on Accumulation Log entries. Fill out the Radioactive/Mixed Waste Requisition Form (Figure 3-4). Fax a copy of the Requisition Form, Tag(s), and Accumulation Log(s) to the Waste Management Group at x4838. Allow 2 weeks for pickup.

After the Waste Review Process, your mixed waste will be picked up by your OHP RCT and WM Technician and brought to the HWHF, where it will be stored pending packaging for shipment.

 

Figure 3-7. Twist-and-tape method of closure.

3.4       Miscellaneous Mixed Wastes

Empty containers that are contaminated with radioactivity and that previously contained an acutely or extremely hazardous waste such as arsenic compounds, cyanide compounds, beryllium compounds, cadmium compounds, or concentrated hydrochloric acid must be managed as separate items. A separate Radioactive Material Tag should be filled out and attached to the container. Fax the Tag and Radioactive/Mixed Waste Requisition Form to the Waste Management Group at x4838. 

Empty containers that are contaminated with radioactivity and have previously contained a hazardous waste other than an acutely or extremely hazardous waste are managed as radioactive waste. Please manage the empty container as radioactive dry waste (see Section 2.2).

Mixed waste containing only isotopes with half-lives shorter than 15 hours (¹⁸F) may be decayed for 10 or more half-lives in generator areas as long as the storage time for the waste does not exceed 275 days.  Otherwise, the container must be requisitioned as mixed waste for pickup.

Transuranic mixed waste (i.e., waste with greater than 100 nCi/g of isotopes such as plutonium, americium, neptunium, curium, or californium) may be generated as long as the process by which it was generated can be tied to the United States’ defense mission. If you anticipate generating this waste, please contact your generator assistant who will assist in gathering this documentation.

Discarded surface-contaminated or activated lead is currently sent for macroencapsulation as mixed waste at an offsite facility. Small quantities of contaminated or activated lead (<10 bricks) should be individually double-bagged, and each bag should be labeled as hazardous waste. Attach a Radioactive Material Tag for all 10 bricks. Fill out a Radioactive/Mixed Waste Requisition Form, and fax it to x4838. If you have larger quantities of lead, please contact your generator assistant.

Sealed Sources with lead as an integral part of the source is mixed waste. Sealed sources are tracked by the OHP Group. Contact your RCT for information to remove your source from your authorization. Once this has been done, do the following for each source:

1. Complete the following 3 documents for each source: (1) a completed Radioactive Material Tag, (2) a Hazardous Waste Label, and (3) a description of the source that specifically provides the 12 items of information listed in Section 2.6.7.  Attach the Hazardous Waste Label and the Radioactive Material Tag to the container with the source. 
2. Once you’ve completed the tag and the 12-item list for each source, fax them along with a Radioactive/Mixed Waste Requisition Form to x4838.

Note:  Sources with lead as an integral part of the source with less than 1 pCi of radioactivity will only be accepted as hazardous waste.

3.5       Benchtop Treatment

·        Copies of representative analysis results characterizing the waste (characterization data can be based on generator information as long as there is assurance that the generating process does not involve the presence of metals or organics).

·        A written neutralization procedure.

·        A list of authorized persons performing the treatment.

·        Evidence that the appropriate procedural training has been completed by each "treater" (a training log showing on-the-job training, along with a brief description of topics covered).

·        Written approval for discharge signed by the Environmental Services Group for waste that can be discharged to the sewer after treatment.

·        The maintenance of a treated waste log indicating the waste-generation date, treatment date, amount of waste treated, and the person who performed the treatment.

·        The waste Radioactive Material Tag notes that the waste is a treatment residual.

Note:  The waste must be treated within 10 days from the generation date.

Generally, treatment is limited to neutralization; however, other treatments can be considered. Before benchtop treatment is authorized by EH&S Waste Management, a review of treatment documentation will be completed. If the waste is intended for drain disposal, this too will be specifically authorized. (Waste does not have to be eligible for sanitary-sewer disposal to be eligible for benchtop treatment.) Your generator assistant will work with you to assure all requirements are met, and will present the information to Waste Management for approval.

Once this information has been submitted to Waste Management, you will receive specific authorization to start benchtop treatment. Please allow up to two weeks from the time this information is submitted for final approval.

3.6       Waste Review Process

3.7       Quality Assurance Testing