REGULATORY STRATEGIES TO MINIMIZE GENERATION OF REGULATED WASTES FROM CLEANUP, CONTINUED USE OR DECOMMISSIONING OF NUCLEAR FACILITIES CONTAMINATED WITH POLYCHLORINATED BIPHENYLS (PCBS) - 11198

Conference · Fri Nov 05 00:00:00 EDT 2010

OSTI ID:1009394

Lowry, N

Disposal costs for liquid PCB radioactive waste are among the highest of any category of regulated waste. The high cost is driven by the fact that disposal options are extremely limited. Toxic Substances Control Act (TSCA) regulations require most liquids with PCBs at concentration of {ge} 50 parts-per-million to be disposed by incineration or equivalent destructive treatment. Disposal fees can be as high as $200 per gallon. This figure does not include packaging and the cost to transport the waste to the disposal facility, or the waste generator's labor costs for managing the waste prior to shipment. Minimizing the generation of liquid radioactive PCB waste is therefore a significant waste management challenge. PCB spill cleanups often generate large volumes of waste. That is because the removal of PCBs typically requires the liberal use of industrial solvents followed by a thorough rinsing process. In a nuclear facility, the cleanup process may be complicated by the presence of radiation and other occupational hazards. Building design and construction features, e.g., the presence of open grating or trenches, may also complicate cleanup. In addition to the technical challenges associated with spill cleanup, selection of the appropriate regulatory requirements and approach may be challenging. The TSCA regulations include three different sections relating to the cleanup of PCB contamination or spills. EPA has also promulgated a separate guidance policy for fresh PCB spills that is published as Subpart G of 40 CFR 761 although it is not an actual regulation. Applicability is based on the circumstances of each contamination event or situation. Other laws or regulations may also apply. Identification of the allowable regulatory options is important. Effective communication with stakeholders, particularly regulators, is just as important. Depending on the regulatory path that is taken, cleanup may necessitate the generation of large quantities of regulated waste. Allowable options must be evaluated carefully in order to reduce compliance risks, protect personnel, limit potential negative impacts on facility operations, and minimize the generation of wastes subject to TSCA. This paper will identify critical factors in selecting the appropriate TSCA regulatory path in order to minimize the generation of radioactive PCB waste and reduce negative impacts to facilities. The importance of communicating pertinent technical issues with facility staff, regulatory personnel, and subsequently, the public, will be discussed. Key points will be illustrated by examples from five former production reactors at the DOE Savannah River Site. In these reactors a polyurethane sealant was used to seal piping penetrations in the biological shield walls. During the intense neutron bombardment that occurred during reactor operation, the sealant broke down into a thick, viscous material that seeped out of the piping penetrations over adjacent equipment and walls. Some of the walls were painted with a PCB product. PCBs from the paint migrated into the degraded sealant, creating PCB 'spill areas' in some of these facilities. The regulatory cleanup approach selected for each facility was based on its operational status, e.g., active, inactive or undergoing decommissioning. The selected strategies served to greatly minimize the generation of radioactive liquid PCB waste. It is expected that this information would be useful to other DOE sites, DOD facilities, and commercial nuclear facilities constructed prior to the 1979 TSCA ban on most manufacturing and uses of PCBs.

• Research Organization: Savannah River Site (SRS), Aiken, SC (United States)
• Sponsoring Organization: USDOE
• DOE Contract Number: DE-AC09-08SR22470
• OSTI ID: 1009394
• Report Number(s): SRNS-STI-2010-00696; TRN: US1101439
• Resource Relation: Conference: Waste Management 2011
• Country of Publication: United States
• Language: English

Related Subjects

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS
12 MANAGEMENT OF RADIOACTIVE WASTES, AND NON-RADIOACTIVE WASTES FROM NUCLEAR FACILITIES
BIOLOGICAL SHIELDS
COMPLIANCE
CONSTRUCTION
CONTAMINATION
DECOMMISSIONING
NEUTRONS
NUCLEAR FACILITIES
PACKAGING
PERSONNEL
POLYCHLORINATED BIPHENYLS
POLYURETHANES
RADIATIONS
RADIOACTIVE WASTES
REACTOR OPERATION
REGULATIONS
SOLVENTS
TOXIC SUBSTANCES CONTROL ACTS
US EPA
WASTE MANAGEMENT
WASTES