Epa’s Final Delisting Rule for Tritiated Mixed Waste and Determination of Equivalent Treatment Method for a Cco Process

The United States biomedical R&D community faces limited treatment and disposal options for many of the mixed wastes generated by their research activities. These options are particularly limited for tritiated mixed waste that has both moderate to high tritium content and contains RCRA-regulated hazardous components. Lawrence Berkeley National Laboratory (Berkeley Lab or LBNL) believes it is essential to develop processes for ensuring that mixed wastes may be treated and disposed of in a manner that minimizes impacts on the environment. In 1996 Berkeley Lab decided to conduct a treatability study on tritiated mixed waste, using catalytic chemical oxidation (CCO) technology. Along with selection of a suitable treatment technology, it was necessary to formulate a reasonable management and disposal route. This included ensuring the appropriate legal status of this waste by obtaining a Determination of Equivalent Treatment (DET) for the oxidation approach, and by Delisting the oxidized products. Following these actions, products may be disposed as low-level radioactive waste (LLRW) at a permitted facility. In June 1999, LBNL submitted a "Petition to Delist Tritiated Mixed Waste Treatment Residues", including a DET petition, to the Environmental Protection Agency (EPA) Region IX. After 4 years careful analysis and public education, the EPA granted both LBNL’s petitions for its tritiated mixed waste on August 7, 2003. In the final rule, EPA concluded that the petitioned waste is no longer hazardous and that the CCO treatment is equivalent to combustion. BACKGROUND United States pharmaceutical and biomedical research institutes regularly use tritium and carbon-14 in research and development projects, and generate mixed waste with Curies (Ci) of tritium activity, or mCi of carbon-14. In LBNL's case, the hazardous component of this waste stream included F-listed spent solvents, was designated as high total organic carbon (TOC) ignitable D001 waste, and some batches contained chlorinated hydrocarbons (code D022) [1]. As the EPA and the Nuclear Regulatory Commission (NRC) have acknowledged, dual regulation of mixed waste under the Atomic Energy Act and the Resource Conservation and Recovery Act (RCRA) presents a number of difficulties for storage, treatment, and disposal. Commercial options for treatment and disposal (incineration) of tritiated mixed waste have undesirable environmental (tritium release) and fiscal consequences (e.g., $15 to $30/mCi). As an example, the estimated cost for disposal of the tritiated mixed waste inventory at Berkeley Lab by a permitted treatment facility would be more than $35 million.