WM01 Conference, February 25-March 1, 2001, Tucson, AZ

MIXED WASTE MANAGEMENT THE ESSENTIALS Vincent St. Angelo, PE, and Tammy B. Wheeler, CHP BWX Technologies Services, Inc. Lynchburg, VA

ABSTRACT This paper will in a non-biased fashion attempt to set forth the regulatory requirements governing mixed waste management, the first key to successful mixed waste dispositioning. Also to be explored are current and future disposal options available to the regulated community. CURRENT REGULATIONS What is the definition of Hazardous Waste? The Resource Conservation and Recovery Act (RCRA) sets forth the current hazardous waste regulatory requirements. It has been stated that these regulatory requirements are possibly the most complex environmental regulatory requirements ever issued, with the Clean Air Act Amendments of 1990 coming in a close second. Hazardous wastes are essentially solid wastes (as defined in 40 CFR 260) that are either listed under 40 CFR 261, Subpart D, and/or exhibit a characteristic described in 40 CFR 261, Subpart C. Under the RCRA ha zardous waste regulations, solid wastes that meet the definition of hazardous waste are summarily assigned a waste code. Characteristic hazardous wastes (D codes) are those solid wastes which exhibit one of the hazardous waste characteristics defined at 40 CFR 261, Subpart C [see 40 CFR 261.3(a)(2)(i)]. Listed hazardous waste classifications (F, K, P, U codes) are based on the process used to generate the waste (e.g. F- listed spent solvents, F- listed sludges, Klisted wastes from specific sources, etc.). In order to determine if a waste exhibits a characteristic, one may either use process knowledge or test a representative sample of the waste. The Toxic Characteristic Leaching Procedure (TCLP, SW-846 Method 1311) is used to determine if a waste exhibits a toxicity characteristic (codes D004-D043). If the analytical results exceed any of the values specified in 40 CFR 261, Subpart C, the waste is a hazardous waste regardless of the method of disposal. Exceptions for certain hazardous wastes which exhibit a characteristic (scrap metal, used oil, etc.) have been promulgated at 40 CFR 261.4(b). Before any decision may be made by a generator on the method of disposal, it must first be determined whether or not the solid wastes in question are hazardous wastes. Generally, two scenarios exist whereby specific wastes will be hazardous: either they

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contain listed hazardous wastes (e.g. spent solvents), or the wastes themselves exhibit a hazardous waste characteristic (e.g. corrosivity). What must I do in order to dispose of hazardous wastes? Once it is conclusively determined that a particular solid waste is also a hazardous waste, then selection the Land Disposal Restriction (LDR) regulatory requirements, including the LDR Treatment Standards (LDRTS) codified at 40 CFR 268 must be met prior to land disposal of the waste. This includes the requirement to satisfy the Universal Treatment Standards (UTS), codified at 40 CFR 268.48, for any underlying hazardous constituents believed present. This means, for example, that if a characteristic D007 hazardous waste contained both chromium and lead, the lead in addition to the chromium must be treated to meet the UTS even though the waste is hazardous only for chromium. How long can one store hazardous waste? The RCRA LDRs prohibit the storage of hazardous waste not meeting the LDRTS for more than 1 year following the date of generation (a.k.a. the RCRA Section 3004(j) Storage Prohibition). As will be seen below, EPA is presently holding in abeyance this 1 year LDR storage prohibition for mixed waste given the limited disposal capacity for mixed waste in the United States (U.S.) at the present time. Department of Energy Facilities (DOE) are exempted from the one year LDR storage prohibition with length of storage instead regulated by the Federal Facilities Compliance Act of 1992 (FFCA). FFCA requires that DOE facilities negotiate mixed waste treatment and disposal agreements with the Environmental Protection Agency (EPA) and/or authorized states. These agreements dictate the storage and treatment requirements for the mixed waste stockpile at respective DOE facilities. Is Mixed Waste also a Hazardous Waste? Mixed waste is a waste that contains a RCRA hazardous waste component and a radioactive material component. Specifically, Mixed Low-Level Radioactive Waste (a.k.a. mixed waste) is defined as a waste, which satisfies the definition of low- level radioactive waste (LLW) in the Low- Level Radioactive Waste Policy Amendments Act of 1985, and contains hazardous waste. It is important for one to understand how Source, Special Nuclear, and By-Product Materials mixtures are perceived by EPA within the context of this definition in order to properly classify a waste as being mixed waste. Section 1004 of RCRA excludes Source, Special Nuclear, and By-Product Material from the definition of solid (and hazardous) waste. EPA specifically states at 40 CFR 261.4(a)(4) that the following are excluded from the definition of solid waste: Source, special nuclear or by-product material as defined by the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2011 et seq.

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

This does not mean that any waste containing Source, Special Nuclear, and ByProduct Materials is automatically exempt from RCRA hazardous waste regulation. On April 7, 1987 EPA and Nuclear Regulatory Commission (NRC) published in the Federal Register (52 FR 11147) their Joint EPA/NRC Guidance on the Definition and Identification of Commercial Mixed Low-Level Radioactive and Hazardous Waste. In this guidance document, the distinction is made between hazardous waste constituents and Source, Special Nuclear, and By-Product Materials in a mixed waste. Although the Source, Special Nuclear, and By-Product Materials in a mixed waste are exempt from the definition of solid (and hazardous) waste, the hazardous component causing classification of a waste as hazardous waste (e.g. a solution containing inseparable chromium and Uranium 235) is not exempt. Hence, if a commingled chromium and Uranium 235 bearing waste failed TCLP for chromium, the waste would still be hazardous RCRA Code D007) due to the chromium constituent. Natural and Accelerated Radioactive Material (NARM) is a special case. Because NARM is not classifiable as LLW, a mixture containing a NARM fraction and a hazardous waste fraction is not classified as mixed waste. In the September 1998 RCRA Hotline Report, EPA states: NORM is a subset of naturally occurring or accelerator-produced radioactive materials (NARM). The definition of NARM includes both radioactive materials produced by an accelerator used in sub- atomic particle physics research, and NORM. Neither NORM nor NARM is regulated under the AEA. EPA believes that because NORM is not regulated under the AEA, a NORM waste that is also a RCRA hazardous waste does not meet the definition of a mixed waste (55 FR 22520, 22645; June 1, 1990.) Such a waste, therefore, would be regulated only as a hazardous waste under RCRA, and not a mixed waste under both RCRA and AEA. For example metallic waste destined for reclamation as scrap metal is specifically exempted from the definition of solid waste (40 CFR 261.4(a)(13)) so the RCRA storage and disposal requirements do not apply. However, more and more scrap metal operations scan for the presence of radioactivity and will reject a shipment if positive detections occur. Hence, if a scrap shipment were rejected by a scrap metal recycler due to NARM contamination, the waste would not be exempted from RCRA since it could no longer be recyclable as scrap metal. Hence, many of the enforcement discretion policies afforded to mixed waste by EPA would not be available to this waste How is the generation, storage, and disposal of mixed waste regulated? Mixed waste contains both LLW and ha zardous waste fractions and as such it is subject to dual regulation: the NRC (or agreement state) would regulate the radioactive fraction, while the EPA (or authorized state) would regulate the hazardous waste fraction.

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

There are also states where mixed waste is not regulated at all under RCRA. This quirk results from EPAs long standing position that regulations not promulgated pursuant to the Hazardous and Solid Waste Amendments of 1984 do not take effect in states which have authority over the base RCRA program. The base RCRA program is essentially those regulatory requirements promulgated at 40 CFR 260-265 (e.g. waste identification, generator standards, interim and permitted facility standards). Hence, in essence, those states, which sought and were granted authority by EPA to regulate the base RCRA program prior to the recognition of mixed waste (i.e. prior to the Low-Level Radioactive Waste Policy Amendments Act of 1985) cannot regulate mixed waste under the authority of RCRA until they seek and a re granted the authority to regulate mixed waste. This is because EPAs regulation of mixed waste was promulgated as a non-HSWA requirement meaning EPA could not regulate mixed waste in those states with base RCRA program authority. Additionally, states with authority to regulate the base RCRA program are themselves unable to regulate mixed waste until such time as they seek and are granted the authority to regulate mixed waste. Hence, in these instances, both the state and EPA are unable to regulate mixed waste. A listing of those states lacking mixed waste regulatory authority may be found at www.epa.gov under the mixed waste homepage. PENDING REGULATIONS What does the future hold for mixed waste regulation? The ability to treat and dispose of mixed waste has been a difficult task to say the least given that the requirements of two and possibly three regulatory entities must be simultaneously satisfied. Fortunately, EPA and NRC are cognizant of this dual regulatory quagmire and there has been recent movement to streamline the regulation of mixed waste. The following three initiatives are currently at various stages of development in the regulatory process. November 19, 1999 Treatment, Storage, Transportation Proposed Rule On November 19, 1999 EPA at 64 FR 63464 issued a proposed rulemaking meant to reduce the burden placed on mixed waste generators. This rulemaking essentially proposed that mixed waste stored under a recognized NRC (or authorized state) license would be exempted from RCRA Part B permitting requirements for both treatment and storage. Recall that extended storage (usually greater than 90 days for RCRA Large Quantity Generators) and treatment of hazardous waste generally requires that the generator/treater secure a RCRA Part B permit at monumental expense. Importantly, LDRTS would still apply to the disposal of mixed wastes under the proposal. Hazardous Waste Identification Rule (HWIR) In an attempt to reduce the regulatory burden on all hazardous (and mixed) waste generators, EPA in 1995 & 1996 proposed two rules known collectively as the Hazardous

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Waste Identification Rule: one in 1995 for Process Wastes (HWIR Process Wastes), and one in 1996 for Media such as soil and groundwater (HWIR Media). These rulemaking provisions essentially would have allowed listed hazardous wastes to exit regulation under RCRA provided some specific de minimus exit level concentration was reached. Under current RCRA hazardous waste regulations, once a listed hazardous waste is generated, it is always a listed hazardous waste unless either de- listed or in the case of media and debris, a determination is made the debris or media no longer contain a listed hazardous waste. Listed hazardous wastes meeting the LDRTS stipulated in 49 CFR 268 may be land disposed, but since listed hazardous wastes remain hazardous wastes (once listed always listed), land disposal must be in a Part B permitted hazardous waste cell. For mixed wastes that are listed hazardous waste, this means land disposal in a mixed waste cell (a cell permitted under RCRA and licensed by the NRC). The proposed HWIRs would allow listed hazardous (and mixed) wastes to exit the RCRA system once the exit level was reached and hence land disposal at a nonpermitted or rad only cell would be allowed. These exit levels have become a contentious issue to all stakeholders involved because they are risk-based levels. Unfortunately, no consensus could be reached on a list of far reaching exit levels and the original 1995 HWIR Process Waste proposal was retracted by EPA. On November 19, 1999 EPA did propose a much scaled down HWIR which would allow hazardous (and mixed) wastes mixtures and derivatives listed solely for the ignitability, corrosivity, and/or reactivity characteristic(s) to exit hazardous waste regulatory requirements provided the mixture/derivative no longer exhibits the characteristic and the applicable LDRTS is met. Work still continues on the development the originally proposed HWIR Process Waste exit levels (under a District of Columbia Circuit Court order) and perhaps in the not so distant future HWIR exit levels will be promulgated. HWIR Media was promulgated in 1998 but it also lacked specific exit levels for contaminated media. It did, however, set forth reduced management and disposal standards for hazardous (and mixed) waste containing media generated during remediation activities. Although not directly related to HWIR, EPA in 1998 (LDR Phase IV Rule) set new LDRTS for hazardous and mixed waste media allowing for increased hazardous waste contaminated media disposal flexibility. RCRA-C Cells A proposal currently under review by the Office of Management and Budget would allow disposal of low activity radioactive wastes at permitted RCRA Subtitle C land disposal facilities. The proposal is intended to facilitate the disposal of mixed waste from small generators. The proposal is based on the premise that RCRA hazardous waste disposal

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

sites, as designed, would provide adequate protection for certain low activity mixed wastes. The proposal offers no HWIR-like exit levels; it simply allows generators of certain low activity wastes to dispose of those wastes at RCRA sites that have obtained a Nuclear Regulatory Commission license. Disposal at these sites would be less costly than at NRC LLRW sites licensed under 10 CFR 61. The proposal sets radionuclide concentration limits for mixed waste that are lower than NRC Class A waste. The proposal would still maintain dual regulatory oversight by EPA and the NRC since the RCRA-C site would still have to maintain an NRC license. However, EPA expects an expedited NRC licensing process based on the premise that RCRA hazardous waste disposal sites are designed to meet the cancer risk criteria of 10-6 to 10-5 which is below the risk levels for NRC-licensed sites by an order of magnitude. MIXED WASTE MANAGEMENT METHODS Is land disposal of mixed wastes possible? Contrary to popular belief of some in the regulated community, land disposal of mixed wastes is possible. Remember that once a solid waste is declared a hazardous waste, the respective LDRTS must be met prior to land disposal. The only difference between hazardous wastes and mixed wastes is the presence of the LLW radionuclide component. Hence, any commercial disposal facility with a RCRA Part B permit and an NRC (or agreement state equivalent) license may accept or treat a mixed waste. There are currently various facilities scattered throughout the U.S. with both Part B permits and an NRC licenses, which accept mixed wastes for treatment and land disposal. Remember too that once a characteristic hazardous (or mixed) waste no longer exhibits a characteristic and meets the LDRTS, it is no longer a hazardous or mixed waste, and disposal in a RCRA permitted disposal cell is no longer required. Not so for listed hazardous or mixed wastes. Once they are generated, they remain listed wastes and achievement of the LDRTS only affords land disposal if desired. Can mixed wastes be treated? Provided a facility has the necessary permits/licenses in place, then the answer in yes. In almost all cases, the goal to be achieved in treatment is to convert the waste to a form amenable to land disposal, which also entails treatment to meet the RCRA LDRTS. As mentioned earlier, in order to treat a mixed waste, RCRA requires that a treater possess a RCRA Part B permit prior to treatment. Securing of a Part B permit can be a gargantuan task with tremendous associated costs and baggage. This fact alone can cause a regulated entity to shun attempting to treat its own waste and seek commercial treatment/disposal avenues. Since these commercial facilities must also secure Part B

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

permits and NRC licenses to perform treatment, the costs of commercial treatment can themselves be prohibitive. Fortunately, there exits under RCRA a policy that allows generators to treat their own wastes in 40 CFR 262.34 compliant storage containers without the necessity of securing a Part B permit. Hence, a licensee could treat its own mixed waste on-site in storage containers to meet the LDRTS for a fraction of the cost of commercial treatment. Although there are specific regulatory requirements to which the licensee must adhere, these requirements are minimally cumbersome and can be performed with a minimum of effort. Because this policy is not codified and could be subject to alternate interpretation by a state with RCRA program primacy, it is imperative that the state regulatory requirements where treatment is to be perfo rmed be carefully examined for consistency with the federal policies. What are the alternatives if mixed waste cannot be treated or disposed? Mixed wastes that do not meet the LDRTS cannot be land disposed. Few options other than treatment or long-term storage are possible. If treatment is not possible, then the wastes must be stored in compliance with all RCRA regulatory requirements. These include storage at RCRA Part B Permitted facilities for storage in excess of 90 days (assuming large quantity ge nerator status), and the prohibition of storage for greater than 1 year of mixed wastes which do not meet the LDRTS (RCRA 3004(j) storage prohibition). Fortunately for the regulated community, EPA recognizes that there simply are no disposal options for certain mixed wastes. For example, D040 characteristic hazardous waste for trichloroethylene (TCE) must be treated to the LDR treatment standard concentration of 6 mg/kg. The only way to treat a hazardous waste to meet the 6 mg/kg treatment standard is through destruction of the organic TCE. The most effective way to destroy the organic is through incineration, however, there is currently no commercially licensed facility that can accept solid mixed wastes for incineration. Hence, a D040 sludge, which has a TCE concentration of say 50 mg/kg has no commercially available disposal option. For this reason, EPA since 1991 (see 56 FR 42730; August 29, 1991) has issued a lower enforcement policy for mixed wastes exceeding the 3004(j) storage prohibition. EPA has extended this policy until October 31, 2001 (see 63 FR 59989, November 6, 1998). What are some examples of current technologies for processing and disposal of mixed wastes? Mixed wastes are a subset of hazardous wastes and as such are also required to meet the LDRTS prior to land disposal. EPA has essentially broken down the universe of wastes into the following classes: metals and organics (notwithstanding the D001 ignitable, D002 corrosive, and D003 reactive characteristic hazardous wastes).

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

The LDRTS are reflective of technology based treatment methods currently available to the regulated community for treatment of hazardous/mixed wastes. The LDRTS are designed essentially to achieve the following goals: transformation of metals to a nonleachable form; and destruction of organics to simple carbon compounds (mainly CO2 ). For this reason the technologies for treatment of mixed wastes to meet the LDRTS are almost identical to the technologies for treating non-radioactive hazardous wastes and hence are widely available to the regulated community. For example, if a generator possesses a D007 mixed waste which is hazardous for excessive leaching of chromium, the currently accepted treatment method is conversion of the chromium from the Cr+6 to the Cr+3 valence state and subsequent stabilization of the Cr+3 waste form typically using Ca(OH)2 to form a non- leaching Cr2 (OH)6 waste form that meets the LDRTS for D007 wastes. Many conversion/stabilization agents are commercially available to stabilize metal bearing hazardous/mixed wastes. Also, if the waste treatment is performed in the storage containers at the generators facility, remember that RCRA exempts this type of treatment from permitting requirements so no RCRA Part B permit would be required. Organic waste streams are more problematic than metal wastes in that the primary treatment technologies involve destruction of the organics under oxidizing conditions (thermal or chemical oxidation treatments), or removal of the organics using separation technologies (carbon adsorption). These treatment schemes are typically costly and not easily undertaken by the generator. They are typically performed by commercial disposal facilities (e.g. incinerators). Given that there is currently only one commercial NRC licensed RCRA permitted incineration facility in the U.S., most generators are left treating these waste streams on site using either portable thermal desorption units, or using chemical oxidation or biological treatment in containers (e.g. Fentons chemistry). For example, assume that a generator has onsite a soil containing F001 spent solvent TCE. The LDRTS for F001 is 6.0 mg/kg TCE (notwithstanding the new LDRTS for soils). If the concentration of TCE exceeds the LDRTS, then the generator must destroy the TCE until the concentration is less than 6 mg/kg using a destruction or oxidation technology. Because there are practically no RCRA permitted incinerators accepting mixed waste, generators are left with only two choices: treat on-site, or store on-site until sufficient commercial capacity is available. What types of advanced mixed waste treatment technologies are on the horizon? Many new technologies are being developed in U.S. laboratories for commercial use. Most new and emerging technologies are simply new fine-tuning techniques on older existing technologies. In all cases the goals are the same, treatment of mixed wastes to meet the RCRA LDRTS. Hence, all are variants of metal stabilization and/or destruction/removal of organics.

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

Plasma Vitrification Plasma vitrification of mixed wastes has been widely used by the DOE to stabilize metal and organic bearing mixed wastes. Plasma is the fourth state of matter characterized by an electrically neutral, highly ionized gas made up of ions, electrons and neutral particles. Plasma gas exists at a very high temperature typically in excess of 1000o C. The intense heat of plasma destroys organic contaminants and melts inorganics into a molten ceramic slag. Inorganics and other non-combustibles become trapped in the molten slag, which solidifies into a stable final waste form once cooled. Fluxes and ceramic materials can be added to the waste streams prior to treatment to ensure that there is ample inorganic material to create a bath of molten sla g. Presently Allied Technology Group, Inc., (ATG) is in the process of bringing on- line a commercial plasma vitrification unit in Richland, WA. The system used by ATG is the GASVIT gasification-vitrification process developed by Batelle Memorial Institutes Northwest National Laboratory and International Environmental Technologies of Richmond. The company reports that the facility will not only be able to treat RCRA mixed wastes, but also Toxic Substances Control Act (TSCA) PCB wastes. Quantum-Catalytic Extraction Processing (Q-CEP) The Quantum CEP (Q-CEP) technology is a patented destruction system originally developed by Molten Metal Technology in Knoxville, TN. This treatment process is comprised of two phases: catalytic dissociation and product synthesis. In the catalytic dissociation phase a molten metal bath of iron or nickel is used to break down compounds into their elemental components. Although the process operates at around 3,000E F, thermal destruction is not the primary means of treatment. Instead, the metal bath works as a catalyst, breaking down compounds to their elemental components by providing a lower energy intermediate in the form of an iron-element complex for the liberated elements. Once compounds are broken down to their component elements the conditions inside the reaction vessel can be manipulated and additional reagents can be added so that the intermediate species form new and usable products that can be recycled. The Q-CEP initially contains iron in its solid form. The iron is heated by induction heating until it becomes molten. At that time waste is added to the molten metal bath. Gases, fine solids, pumpable liquids and slurries are bottom fed into the reactor; shreddable solids enter the bath via lances from the top of the reaction vessel; nonshreddable and bulk solids are fed with baffles and lances. Once inside the reactor the wastes become dissolved in the molten bath. Molecules are broken down to their components with the carbon and hydrogen being released as gas and the inorganic constituents remaining dissolved in the metal bath or creating a molten ceramic slag that floats on top of the metal. Radioactive metals are sequestered in the molten bath or in the ceramic slag floating on top. Both are stable final waste fo rms. Some of the more easily volatilized metals are vaporized during the process and captured in the off gas treatment system. Hazardous

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

materials are broken down into carbon and hydrogen, which are released from the metal bath as carbon monoxide and hydrogen gas. These can be sequestered for industrial use. Chlorine from the destruction of organochlorides can be recovered in the form of HCl. Although initially developed by Molten Metals, the Q-CEP technology was sold to Scientific Ecology Group (SEG) and subsequently sold to ATG. It is not known at this time what the exact timetable is for commercial availability of Q-CEP. LowDensity Polyethylene Extrusion This technology was developed at Brookhaven National Labs (BNL) and uses LowDensity Polyethylene (LDPE) as a microencapsulent. BNL has developed two waste encapsulation processes based on thermoplastic binder materials (i) sulfur polymer and (ii) low-density polyethylene. Essentially the waste to be solidified is combined with LDPE pellets. Once combined the waste is heated in a container melting the LDPE and microencapsulating the waste into a LDPE monolith. Another variant uses a sulfur polymer to convent leachable metals such as Cr and Hg into non- leachable forms while simultaneously microenc apsulating the waste. LDPE extrusion technology can be used to encapsulate elemental lead, RCRA debris, or other hazardous and mixed waste metals in order to meet both the LDRTS and RCRAs alternative debris treatment standards at 40 CFR 268. Presently Envirocare of Utah has an LDPE treatment system on- line for treatment of mixed wastes. Provided the waste meets the Envirocare Waste Acceptance Criteria (WAC), land disposal of the solidified monolith could then be made resulting in turnkey treatment and disposal. OFF-SITE PROCESSING CENTERS What existing commercial facilities are currently available for management of mixed wastes? Although limited in number, there are in the U.S. a variety of currently operating processing and disposal facilities for mixed waste management. The four major facilities currently accepting mixed waste are: Envirocare of Utah, Inc. Clive, UT Limited land disposal and some treatment capabilities.

WM01 Conference, February 25-March 1, 2001, Tucson, AZ

Diversified Scientific Services, Inc. (DSSI) Kingston, Tennessee Limited thermal treatment capabilities.

NSSI Houston, TX Primarily long term storage facilities. Potentially limited treatment capabilities.

Perma-Fix Environmental Services, Inc. Gainesville, FL Limited thermal treatment capabilities.

Waste Control Specialists Western Texas Limited land disposal capabilities.

What does the future hold for mixed waste treatment and land disposal? Perhaps the greatest need for mixed waste generators is the need for sufficient mixed wasteland disposal capacity. In the U.S. presently there are three LLW land disposal facilities: Richland, WA (Hanford); Barnwell, SC; and Envirocare of Utah. Of the three, only Envirocare possesses a RCRA Part B permitted waste cell. Hence, only Envirocare (possessing an NRC license and RCRA Part B permit) has a land disposal cell capable of accepting mixed waste. Note that the Richland facility will only accept wastes from the Northwest and Rocky Mountain Compacts, while Barnwell accepts wastes from all states (except NC) as does Envirocare of Utah. Although Barnwell and Richland cannot accept mixed wastes, either of these facilities can accept characteristic mixed wastes, which have been decharacterized and meet the LDRTS, thereby rendering waste LLW only. Recall that listed hazardous (and mixed) wastes are the only RCRA wastes, which remain hazardous (or mixed) even if the LDRTS have been reached. This is a key point to remember as there are a number of facilities (DSSI, NSSI, Perma Fix) possessing the necessary approvals to treat mixed wastes. Once characteristic mixed wastes are treated to meet the LDRTS (and hence usually decharacterized), they are no longer regulated by the RCRA hazardous waste regulations and hence they may be land disposed as ordinary LLW. Although Envirocare currently possesses the only mixed waste cell in the U.S., their acceptability of waste materials is limited. The Envirocare license currently permits disposal of only NRC Class A wastes. Hence, Classes B/C mixed wastes are not acceptable for land disposal at Envirocare. In addition, those Class A mixed wastes not meeting the RCRA LDRTS are also prohibited from land disposal at Envirocare. It should be noted here that Envirocare has recently submitted a license amendment, which

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would allow for disposal of Classes B/C wastes in its mixed waste cell. This license amendment is currently under review.