`Eight years of dual regulation for mixed waste -- where do we go from here?`
Technical Report
·
OSTI ID:133072
- Piper & Marbury, Washington, DC (United States)
Radioactive/hazardous mixed waste (`mixed waste`) has been subject to dual regulation under the Resource Conservation and Recovery Act (`RCRA`) and the Atomic Energy Act (`AEA`) since July, 1986. In these eight years, commercial NRC licensees have established a strong case that dual regulation is unnecessarily burdensome and redundant and that a tailored program combining select elements of RCRA and the AEA is the most appropriate course of regulatory action for these unique materials. Despite sympathetic acknowledgement from regulators that this strategy makes sense, mixed waste remains subject to dual regulation with little prospect for substantial relief in the immediate future. Recognizing that amending the regulatory status quo is a slow and tedious process, the paper will focus on management options available under the current RCRA and AEA programs for removing mixed waste from the most onerous elements of the present regime. This discussion will explore methods available under the existing hazardous waste rules for avoiding the most draconian elements of RCRA`s hazardous waste program, including management options that are exempt from RCRA`s permitting program and treatment options that are available to remove certain mixed wastes from hazardous waste regulation. The paper also will discuss potential options available under the NRC program for removing certain byproducts from the requirement that they be managed at NRC licensed facilities, thus creating new alternatives for off-site treatment and disposal.
- Research Organization:
- Electric Power Research Inst., Palo Alto, CA (United States); Williams (Paul) and Associates, Medina, OH (United States)
- OSTI ID:
- 133072
- Report Number(s):
- EPRI-TR--105134; CONF-940746--
- Country of Publication:
- United States
- Language:
- English
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