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News and training for radiation workers at Northwestern
University Number 67 November, 2003
Prior Approval is Required for Mixed Waste
Generation
First,
a definition: A mixed waste is
a waste that contains both radioactive waste and a hazardous waste regulated
under the Research Conservation and Recovery Act (RCRA). It is not practical in
most cases for laboratory workers to assess whether a given chemical, when
added to a radioactive waste, creates a mixed waste. That's because the
hazardous waste definitions are extremely complex and detailed. Suffice it to
say that most of the common chemicals you
use in the laboratory would be hazardous wastes, including things like
glacial acetic acid, methanol, and acetone. Therefore, you should assume you
would create a mixed waste if you added even a small amount of a common
laboratory chemical to your radioactive waste.
Why
is mixed waste a problem?
Because there are limited treatment and disposal options, restrictive disposal
timelines and storage requirements, cumbersome joint oversight by multiple
regulatory agencies, and added disposal expenses. In addition, the Federal
penalties for noncompliance with the mixed waste rules can be severe.
What
if "just a little bit" of a chemical is put into a radwaste jug? If any RCRA waste is added to radwaste it must
be considered a mixed waste until proven otherwise. If the chemical is not
specifically listed as a RCRA waste, we have to either apply a number of tests
that characterize its ignitability (flash point), corrosivity (pH), reactivity,
or toxicity, or apply knowledge of the processes that produced the waste to
make a determination. These tests can be time consuming and costly.
Is
creating a mixed waste unavoidable?
In most cases, laboratory processes can be designed so that the end waste
products are not mixed wastes. However, we recognize that in rare instances a
mixed waste may be the unavoidable product. Review your laboratory protocols
carefully to assess this potential before you start the work. If you think that
a mixed waste will result, contact ORS. We will help you assess the process,
avoid generation when possible, minimize the volume, or properly manage the
waste.
Always
enter the chemical constituents on waste cards. The law requires the proper identification of
mixed wastes and the Radioactive Waste Card is the means by which you
communicate it to ORS. Your description also helps to protect ORS employees and
others who have to handle the waste.
Use this NUtrino as a training tool for new workers and required
annual refresher training for current workers. Circulate it among the radiation
workers in your group and have them sign and date the training form on the
back. File it with your authorization and other radiation safety documents for
review during regulatory inspections. Discuss it during laboratory meetings. We
have back issues, or you can print them off the web at
http://www.northwestern.edu/research-safety/rad/nutrino/index.htm.
Office for Research Safety - Office for Research -
Radiation Safety Committee
Ward B-106 Chicago Campus, phone
3-8300
Tech NG71 Evanston Campus, phone 1-5581