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Wastren presentation


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Wastren presentation

  1. 1. February 26 – March 1, 2012 ♦ Phoenix, ArizonaTreatability Variance for Containerized Liquids in Mixed Debris Waste – Abstract # 12101 Catherine Alstatt, Director of Regulatory Interface and Integration Wastren Advantage Inc. TRU Waste Processing Center Oak Ridge, TN Session # 69
  2. 2. Transuranic Waste Processing Center
  3. 3. • The TWPC’s mission is to process Transuranic (TRU) waste generated from the DOE Oak Ridge National Laboratory (ORNL), including debris, soils, and tank waste.• Waste includes both Contact Handled (CH) waste (<2 millisieverts) and Remote Handled (RH) waste.• Currently, processing CH and RH debris and some soils.• Low level (LL) and Low Level Mixed (LLM) wastes are generated from the processing activities and from the TRU waste.TWPC Mission
  4. 4. • Acceptable Knowledge (AK) prepared for the waste characterizes the waste as mixed waste, meaning it is both radioactive and regulated under the Resource Conservation and Recovery Act (RCRA).• The waste is generally characterized as containing several F listed and D characteristic codes.• The AK also indicates that a number of the debris waste packages contain small amounts of containerized liquids.• The documentation indicates liquid wastes generated in routine lab operations were typically collected for potential recovery of valuable isotopes.Acceptable Knowledge
  5. 5. • However, during activities associated with decontamination and decommissioning (D&D), some containers with small amounts of liquids were placed into the waste containers with debris waste.Acceptable Knowledge
  6. 6. • Many of these containers now hold from 2.5 milliliters (ml) to 237 ml of liquid; a few contain larger volumes.• At least some of these containers were likely empty at the time of generation, but documentation of this condition is lacking.Containerized Liquids
  7. 7. Since WIPP compliant Acceptable Knowledge (AK) isdeveloped on a waste stream basis, rather than anindividual container basis, and includes every potentialRCRA hazardous constituent within the waste stream,it is insufficient for the purpose of characterizingindividual containers of liquid.Containerized Liquids
  8. 8. • Debris waste is defined in 40 CFR 268.2(g) [1] as “solid material exceeding a 60 mm particle size that is intended for disposal and that is: a manufactured object; or plant or animal matter; or natural geologic material.”• The definition further states that intact containers of hazardous waste that are not ruptured and that retain at least 75% of their original volume are not debrisDebris Waste
  9. 9. • The prescribed treatment is removal of intact containers from the debris waste, and treatment of their contents to meet specific Land Disposal Restrictions (LDR) standards.• This is true for containers with incidental amounts of liquids, even if the liquid is less than 50% of the total waste volume.Debris Waste
  10. 10. At the TWPC, the standard treatment for debris mixed LLW ismacroencapsulation in accordance with 40 CFR 268.45standards. For characteristic waste codes there is no need totreat for underlying hazardous constituents (UHCs).The LDR treatment standard for containerized liquids with theassigned listed waste codes are numerical standards.The standard for most of the characteristic codes is also anumerical standard with treatment to meet any UHCs.A few such as D001(ignitable) and D002 (corrosive) must bedeactivated, followed by treatment to meet any UHCs.Land Disposal Restrictions
  11. 11. The EPA has interpreted that a treatment variancemay be granted when treatment to meet the LDRstandard is feasible, but is nevertheless “notappropriate.”Agency rules require alternative standards approvedthrough the variance result in substantial treatment ofhazardous constituents in the waste so that threatsposed by its land disposal are minimized.Treatment Variance Requirements
  12. 12. In response to a “Petition for Site Specific Variance from Treatment Standards at Sandia National Laboratories” dated April 16, 2004 [4], the New Mexico Environment Department (NMED) found that because the wastes contain radioactive materials they are physically different than those that were analyzed to develop the LDR treatment standard. The NMED further found that “treatment and verification of treatment by the usual methods would not be protective of workers”.Basis for Treatability Variance
  13. 13. The existing RCRA LDR treatment standard for liquid wastes relevant to this petition is inappropriate due to the radioactive nature of the waste. The increased radiation exposure resulting from the required extra waste handling operations - including sampling, analysis, and transportation - is inconsistent with EPA guidelines related to minimization of risk to workers.Treatability Variance Applicability
  14. 14. Under the proposed treatment variance containerswith small amounts of free liquids will be treated with aspecialty blend provided by NoChar®.The NoChar® product is a polymer blend that isdesigned to solidify a wide range of organics/aqueoussolutions with one step processing.Proposed Treatment Process
  15. 15. Process creates a solid polymeric matrix, whichwould immobilize RCRA characteristic metalsand reduce any possible leaching if metals arepresent.Additionally, the incorporation into a solid matrixof any ignitable solvents, if present, wouldeliminate the ignitable liquid phase form, infavor of a deactivated solid form.The treated liquids would then be placed backinto the debris waste stream to be treated bymacroencapsulation.Proposed Treatment Process
  16. 16. Current Treatment Process Flow
  17. 17. TWPC Treatment Variance Process FlowProposed Treatment Process
  18. 18. In summary, after each individual liquid-bearing containeris treated with the NoChar® process, it is returned to thedebris waste stream and the entire debris package ismacroencapsulated using a process that meets thespecifications found in 40 CFR 268, Land DisposalRestrictions.The unique properties of NoChar® provide a combinationof acid-base neutralization, immobilization of potentialRCRA metals, and incorporation/deactivation of liquidorganic wastes.The NoChar® Process, followed by finalmacroencapsulation meets and exceeds the RCRA 3004(m) standard regarding minimization of threats to humanhealth and the environment.Proposed Treatability Variance Approach
  19. 19. The proposed variance meets the intent of theTreatment Variance guidelines in that the constituentsof concern are substantially treated and the threat tohuman health and the environment is minimized bysafe disposal of the treatment residuals.Additionally, consistent with the guidelines, risks toworkers and the environment associated with extrahandling and transportation of radioactive material arereduced.Finally, significant amounts of secondary mixed waste,that would otherwise be generated, would beeliminated if the variance was approved.Conclusion
  20. 20. The proposed variance method, with its redundantprotective features of an initial neutralization,immobilization, and deactivation, combined with a finalmacroencapsulation, is the best technology availableto achieve substantial treatment of these wastes whileminimizing radiological exposures from handlingoperations.Conclusion