**8021\
Rev. 09/2008**

**CHEMICAL AND RADIOACTIVE WASTE MANAGEMENT**

 

**INTRODUCTION**

This chapter describes Fermilab\'s program to manage chemical and
radioactive wastes in compliance with applicable regulations and in a
manner that protects human health and the environment. Fermilab
generates a variety of chemical wastes. There are complex state and
federal regulations governing their management.    The generation,
storage, transport and disposal of hazardous waste is governed by the
federal Resource Conservation and Recovery Act (RCRA). Illinois has
authority to regulate hazardous waste within the state, and also to
regulate the transport and disposal of Special (non-RCRA) wastes.  
Polychlorinated biphenyls (PCBs) and asbestos are regulated by the
federal Toxic Substances Control Act (TSCA) and are classified as
Special Waste in the State of Illinois.

Fermilab, as a byproduct of operating its high energy physics research
program, also generates low level radioactive and mixed wastes. Details
of the Fermilab program for management of radioactive wastes and mixed
wastes are summarized in [Article
441](http://www-esh.fnal.gov/FRCM/Ch04/Ch04.html#__RefHeading___Toc14481128), 
[442](http://www-esh.fnal.gov/FRCM/Ch04/Ch04.html#__RefHeading___Toc14481129)
and
[443](http://www-esh.fnal.gov/FRCM/Ch04/Ch04.html#__RefHeading___Toc14481130)
of the Fermilab Radiological Control Manual as well as the [Low Level
Waste Certification
Program](http://www-esh.fnal.gov/Llwcp/LLWCP2000.htm) (LLWCP).

** **

**DEFINITIONS**

Listed below are a few abbreviated definitions relating to chemical
waste management.

*Chemical Waste* means wastes generated at Fermilab that are regulated
by federal, state or local statutes.  These wastes typically include
solvents, degreasers, coatings, adhesives, lubricants, coolants and
various other commercial chemical products and laboratory reagents.* *

*Construction Coordinator* (CC) means a person specifically assigned to
oversee the work of a fixed-price construction subcontract for
conformance to the subcontract documents.

*Declassified waste* means a waste which has been determined pursuant to
Illinois Administrative Code Section
[808.245](http://ilga.gov/commission/jcar/admincode/035/035008080B02450R.html)
 to not be special waste.

*Disposal* means the discharge, deposit, injection, dumping, spilling,
leaking, or placing of any waste into or on any land or water.

*Generator* means a person directly involved in the activity or process
that generates a waste.

*Hazardous waste* means a waste material that exhibits the
*characteristics* of hazardous waste in:

> [40 CFR
> 261.21](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=57cfd0d5941bbe4493d2086fdf7a9fc8&rgn=div8&view=text&node=40:25.0.1.1.2.3.1.2&idno=40) -
> Ignitability\
> [40 CFR
> 261.22](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=57cfd0d5941bbe4493d2086fdf7a9fc8&rgn=div8&view=text&node=40:25.0.1.1.2.3.1.3&idno=40) -
> Corrosivity\
> [40 CFR
> 261.23](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=57cfd0d5941bbe4493d2086fdf7a9fc8&rgn=div8&view=text&node=40:25.0.1.1.2.3.1.4&idno=40) -
> Reactivity or\
> [40 CFR
> 261.24](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=57cfd0d5941bbe4493d2086fdf7a9fc8&rgn=div8&view=text&node=40:25.0.1.1.2.3.1.5&idno=40) -
> Toxicity characteristic

Or a waste material that is *listed* in:

> [40 CFR
> 261.31](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=57cfd0d5941bbe4493d2086fdf7a9fc8&rgn=div8&view=text&node=40:25.0.1.1.2.4.1.2&idno=40)-
> non-specific sources\
> [40 CFR
> 261.32](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=57cfd0d5941bbe4493d2086fdf7a9fc8&rgn=div8&view=text&node=40:25.0.1.1.2.4.1.3&idno=40) -
> specific sources\
> [40 CFR
> 261.33](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=57cfd0d5941bbe4493d2086fdf7a9fc8&rgn=div8&view=text&node=40:25.0.1.1.2.4.1.4&idno=40) -
> discarded commercial chemical products, off-specification species,
> container residues, and spill residues thereof.

*Mixed waste* means (for the purpose of the chapter) a waste that is
both radioactive and hazardous as defined by RCRA or is a radioactive
PCB waste. A material is radioactive if it does not meet Fermilab\'s
criteria for uncontrolled release in [Article
411](http://www-esh.fnal.gov/FRCM/Ch04/Ch04.html#__RefHeading___Toc14481111)
of the Fermilab Radiological Control Manual.

*Radiological Area (RA) waste* means (for the purpose of the chapter) an
area where materials could potentially become radioactive by either
exposure to particle beams capable of causing activation, or by coming
in contact with transferable radioactive contamination.

*Resource Conservation and Recovery Act (RCRA)* means the federal
regulations enacted to establish a framework for national programs to
achieve environmentally sound management of hazardous and nonhazardous
wastes.

*Satellite Accumulation Area (SAA)* means an area at or near the point
of waste generation where waste is temporarily stored and is under the
control of the waste generator.

*Special (Illinois non-RCRA) waste* means a waste that is not hazardous
as defined by RCRA, however, is an industrial process waste, pollution
control waste, medical waste, asbestos waste, or PCB waste for which
there are State of Illinois statutes governing their transport and
disposal.

*Task Manager (TM)*  means a division/section-designated individual
specifically assigned to oversee and direct a work activity.    Usually
this term applies to individuals directing T&M subcontractors.

*Toxic Substances Control Act (TSCA)* means the federal regulations
enacted to control substances determined to cause unreasonable risk to
public health or the environment.  Asbestos abatement and the use,
storage, transport and disposal of polychlorinated biphenyls (PCBs) are
included in these regulations.

*Universal waste* means hazardous wastes that are managed under the
universal waste requirements of [40 CFR
273](http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=fa8173046846ba7fd72fffdb74dcb504&rgn=div5&view=text&node=40:26.0.1.1.7&idno=40)
including certain batteries, pesticides, thermostats and lamps.

*Used Oil* means any oil that has been refined from crude oil, or any
synthetic oil, that has been used and as a result of such use is
contaminated by physical or chemical impurities.

*Waste Coordinator* means a person appointed by the division/section
head with the responsibilities as outlined by the Special
Responsibilities section (below).

 **SPECIAL RESPONSIBILITIES**

Business Services Section shall:

-   Provide a transport vehicle and driver to perform site wide pickups
    of chemical waste under the direction of Hazard Control Technology
    (HCT) Team personnel.

ES&H Section Hazard Control Technology Team shall:

-   Perform routine site wide chemical waste pickups, and special
    pickups when required for generator compliance.

-   Operate and maintain Fermilab\'s RCRA Part B Permitted Hazardous
    Waste Storage Facility and 90 day storage areas at Site 55 in
    compliance with applicable regulatory requirements.

-   Provide annual training to division/section waste coordinators.

-   Provide guidance to division/section waste coordinators on waste
    related issues.

-   Audit division/section waste management programs with a frequency
    sufficient to verify their compliance with applicable requirements.

-   Verify the intended waste treatment, storage and disposal
    facility(s) have a satisfactory regulatory compliance record prior
    to submitting a requisition for a chemical waste disposal contract
    to the Business Services Section.

Divisions/Sections shall:

-   Implement a program to ensure chemical wastes are managed in
    compliance with applicable regulations and Fermilab policy.

-   Ensure that the duties and responsibilities of the Waste Coordinator
    (see below) are effectively discharged. This shall be accomplished
    by appointing a waste coordinator and an alternate, if deemed
    necessary. Alternatively, with the approval of the Senior Laboratory
    Safety Officer, divisions/sections may arrange with the ES&H Section
    by a Memorandum of Agreement for ES&H personnel to perform some of
    these functions. Such agreements do not, however, alter the
    division/section\'s responsibility to ensure that WC duties are
    performed.

-   All divisions and sections are responsible for implementing the
    Laboratory's waste minimization program set forth in Chapter
    [8022](http://www-esh.fnal.gov/FESHM/8000/8022.htm).

Division/Section Waste Coordinators shall:

-   Provide and document training for waste generators.  This training
    should be commensurate with the types and frequency of waste
    generated. 

-   Evaluate all materials to be classified as waste to determine if the
    materials should first be entered in the Fermilab Excess Chemical
    List and/or listed in the Government Supply Administration (GSA)
    Excess Property listing.

-   Conduct and document inspections of satellite accumulation areas
    (SAAs) to ensure wastes are being managed in compliance with
    applicable requirements.

-   Approve Chemical Waste Pickup Request Forms completed by waste
    generators and forward them to the HCT Team.

-   Provide assistance in the characterization, packaging, labeling, and
    temporary storage of waste generated by subcontractors under their
    division/section\'s management as requested by the Task
    Manager/Construction Coordinator whenever such waste is ultimately
    to be transferred to the HCT Team for disposal.

-   Act as liaison with the HCT Team on chemical waste related issues.

-   In the event that chemical waste is shipped directly offsite from
    the point of generation, coordinate that shipment with the HCT Team.

Division/Section waste generators shall:

-   Determine if their waste is a hazardous or special chemical waste.

-   Package, label and store chemical waste at a SAA in compliance with
    applicable requirements.

-   Complete and submit a Chemical Waste Pickup Request Form to their
    waste coordinator for waste materials that are prepared for pickup.

 

 

Task Managers and Construction Coordinators shall: 

-   Work directly with their Div./Sec. Chemical Waste Coordinator to
    insure any waste generated during projects they oversee is properly
    managed.

 

**PROCEDURES**

1.  Chemical wastes shall be characterized, labeled, and packaged and
    temporarily stored at satellite accumulation areas (SAAs) by the
    generator. Generator requirements at SAA waste storage areas
    include:

    -   identify waste with the appropriate completed hazardous,
        special, universal, or used oil waste label,

    -   ensure the container is chemically compatible with the waste
        collected,

    -   keep containers closed except when adding or removing waste,

    -   do not store hazardous wastes longer than 90 days,

    -   the total volume of hazardous waste at an SAA shall not exceed
        55 gallons (one quart for P listed acute hazardous waste) for
        longer than 3 days,

    -   do not mix or combine unlike waste materials

2.  To arrange for a waste pickup, the generator completes a Chemical
    Waste Pickup Request Form ([HWSF Form
    #10](http://www-esh.fnal.gov:8001/HCT/Default.html)) and submits it
    to the division/section waste coordinator for review and approval.
    The generator shall ensure that all containers are clean, properly
    labeled and tightly closed prior to pickup.

3.  After review and approval, the waste coordinator submits the
    Chemical Waste Pickup Request Form to the HCT Team.

4.  The HCT Team reviews forms received for completeness and accuracy
    and an informal effort is made to resolve any discrepancies
    discovered by contacting the waste coordinator. If the problem is
    not resolved, it is noted on the form, which is returned to the
    waste coordinator.

5.  The HCT Team notifies waste coordinator of the pickup schedule and
    which waste is approved for pickup.

6.  Routine chemical waste pickups are conducted by the HCT Team with
    assistance, as necessary, from Transportation Services personnel on
    the first and third Wednesday of each month. Special pickups are
    made when necessary to maintain compliance with SAA hazardous waste
    volume limits.

7.  Chemical wastes are transported to the Hazardous Waste Storage
    Facility at Site 55 by, or under the direction of, HCT Team
    personnel where they are temporarily stored pending arrangements for
    shipment offsite for reclamation, treatment or disposal.

8.  After each waste pickup, a copy of the pickup form is returned to
    waste coordinators to confirm which wastes were picked up.

9.  The Technical Appendix (8021 TA) to this chapter contains additional
    waste management requirements, pertaining to specific wastes
    routinely generated at Fermilab and identifies resources available
    on site.

**8021TA**

**TECHNICAL APPENDIX TO\
 CHEMICAL AND RADIOACTIVE WASTE MANAGEMENT**

**Section A. - Additional Waste Management Requirements**

1.  Combining Wastes

2.  Radiological Area (RA) Waste

3.  Generator requirements for Certain Land Disposal Restricted (LDR)
    waste

4.  Declassified Special Waste

5.  Managing Empty Containers and Drums

6.  Offsite waste shipments

**Section B. - Specific Waste Stream Requirements**

1.  Asbestos

2.  Batteries

3.  Fluorescent light ballasts

4.  Medical waste

5.  Mixed waste

6.  PCBs

7.  Rags

8.  Tires

9.  Unknown wastes

10. Used oil

11. White Goods

12. Fluorescent and High Intensity Discharge Lamps containing mercury

**Section C. - Resources**

1.  Containers

2.  Halogen in Oil Screening Tests

**Section A. - Additional Waste Management Requirements:**

1.  *Combining Wastes* - Unlike waste materials shall not be combined by
    the generator except for hazardous waste rags and waste oil
    (detailed below). It is especially important to prevent mixing
    nonhazardous and hazardous wastes. Combining unlike wastes may limit
    waste management and disposal options and increases disposal cost.

2.  *Radiological Area (RA) Waste* - Waste materials that are generated,
    used or stored in a RA, by definition, have the potential for being
    activated or contaminated. The generator of RA waste or other
    authorized individual shall sign the "No Radioactivity Added
    Certification" on the Chemical Waste Pickup Request Form.  This
    certification documents that the waste has been determined by the
    generator to meet Fermilab\'s release criteria by either process
    knowledge, survey or analysis.

3.  *Generator Requirements for Certain Land Disposal Restricted (LDR)
    Waste* - Generator documentation identifying underlying constituents
    in certain characteristic hazardous wastes (EPA ID#s D001, D002, and
    D012 through D043) is required by 40 CFR 268. However, simplified
    rules for lab pack wastes that are incinerated and an exclusion for
    waste treated in a Clean Water Act permitted treatment facility
    eliminate this requirement for most wastes. The generator will be
    notified by HCT Team personnel if this certification/notification
    becomes necessary. When required, the generator shall complete a
    \"LDR Waste Certification Form\" (HWSF Form #8) and attach it to the
    Chemical Waste Pickup Request Form.

4.  *Declassified Special Waste* - The IEPA regulations exclude most
    solid (non liquid) nonhazardous industrial process and pollution
    control wastes from the definition of special waste. However,
    declassifying special waste requires generator certification and
    this documentation must be maintained and made available upon
    request by the waste hauler or destination facility. Disposal of
    these declassified wastes shall be coordinated with the HCT Team.

5.  *Managing Empty Containers and Drums* - Empty is defined in the
    regulations as \"contains no liquid or solid materials which can be
    removed by conventional means, i.e., pouring, pumping, aspirating\".
    Empty containers that previously held \"P listed\" hazardous waste
    require triple rinsing or shall be managed as a hazardous waste.
    Other empty containers with a capacity of [\<]{.underline}5 gallons
    may be discarded in a dumpster after they have been rendered
    unusable. Empty fiberboard and polyethylene drums of any size may be
    discarded in a dumpster, however, they shall be cut in half or
    crushed in a way that prevents reuse. Empty steel drums with a
    capacity of \>5 gallons shall be managed as waste and the generator
    shall identify the material previously contained in the empty drum
    on the Chemical Waste Pickup Request Form. Empty drums are inspected
    and cleaned if necessary by HCT Team, crushed, and recycled as scrap
    metal. Coordinate disposal of these containers with the HCT Team.

6.  *Offsite Waste Shipments* - Offsite shipments of chemical waste
    shall be coordinated with the HCT Team to ensure regulatory
    compliance including:

    -   manifest signature/certification (by HCT Team personnel only)

    -   LDR Notification/Certification

    -   DOT compliance

    -   radiation survey

    -   transport vehicle inspection

    -   Fermilab approval of offsite waste storage, treatment or
        disposal facility(s)

    -   record keeping and reporting requirements

**Section B. - Specific Waste Stream Requirements**

1.  *Asbestos* - Consult with ES&H staff prior to beginning any task
    involving the handling of asbestos containing materials or asbestos
    waste.

2.  *Batteries* - Mercury, lithium, and nickel cadmium batteries are
    universal waste and shall be managed accordingly. Lead acid and lead
    calcium batteries are exempt from regulation as hazardous waste
    under RCRA when recycled if the outer casing of the battery isn't
    damaged or leaking acid.  These batteries shall either be returned
    to a vendor for reclamation when purchasing new batteries or,
    managed as a universal waste and sent for reclamation by the HCT
    Team. All activated batteries, including carbon dry cell batteries,
    are mixed waste (hazardous and radioactive). See *Mixed Waste* below
    for pickup instructions.

3.  *Fluorescent Light Ballasts* -- Many old fluorescent light ballasts
    contain a small PCB capacitor or PCBs in the \"potting material\"
    filler inside the ballast. Any fluorescent light ballast
    manufactured prior to July 1, 1978 or whose manufacture date or PCB
    content is not known shall be assumed to be a TSCA-regulated item
    and managed accordingly. The generator is responsible for making
    this determination. See item 6 below for more TSCA-related
    requirements. PCB ballasts are also special waste and must be so
    labeled. Ballasts that were manufactured after July 1, 1978, or that
    are labeled \"No PCBs\" will be collected by the HCT Team and
    recycled as a best management practice.

4.  *Medical Waste* - Medical waste is a special waste and shall be
    collected in designated containers marked with the international
    biohazard symbol. These containers will be provided by the HCT Team.
    Containers of medical waste needles shall also be marked with the
    word \"Sharps\".

5.  *Mixed Waste* - Mixed waste includes radioactive hazardous or PCB
    containing waste and shall be stored only at the HWSF when removed
    from an SAA. Mixed waste generators shall complete and submit a
    Hazardous/Radioactive Waste Certification and Pickup Request Form
    ([HCTT Form #02](http://www-esh.fnal.gov:8001/HCT/Default.html)) to
    the HCT Team to request a waste pickup.

6.  *PCBs* - TSCA requirements pertaining to the in-service use of PCBs
    are addressed in [Chapter
    8040.1](http://www-esh.fnal.gov/FESHM/8000/8040_1.htm). When
    TSCA-regulated PCB items or materials are removed from service, the
    items and any containers used to hold them shall be dated and
    receive both PCB and special waste labels. Temporary storage areas
    must also be labeled with the PCB Large Mark (see [40 CFR
    761.45](http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfr761_07.html)).
    PCB waste must be moved from the point of generation to the HWSF or
    shipped offsite for disposal within 30 days of the out-of-service
    date.

7.  *Rags* - Hazardous waste rags may be collected in a common container
    as long as the hazardous constituents are chemically compatible and
    each hazardous chemical constituent is identified on the containers
    waste label and on the Chemical Waste Pickup Request Form. The
    container shall be kept closed except when adding or removing waste
    to prevent evaporation.

8.  *Tires* - Land disposal of whole tires is prohibited by State
    regulations. Whole tires shall not be discarded in a dumpster. Used
    tires should be returned for reclamation or disposal to the vendor
    who provides new tires.

9.  *Unknown Wastes* - Occasionally materials of unknown origin may be
    discovered. These wastes usually result from containers found in
    dumpsters or containers that are unlabeled or have illegible labels.
    To properly manage and dispose of unknowns, the generator or waste
    coordinator shall conduct and document an investigation as to what
    the waste might be. This investigation shall include the name of
    persons contacted and the best theory as to what the material might
    be, based on the results of the investigation. A copy of the
    investigation shall be attached to the Chemical Waste Pickup Request
    Form when submitted to the HCT Team.

10. *Used Oil* - Used petroleum based lubricating oil is routinely
    generated from several different sources, i.e., motor oil, vacuum
    pump oil, compressor oil, and may be collected in a common
    container. RCRA includes a rebuttable presumption that states waste
    oil containing \>1000 ppm halogen content is a hazardous waste.
    Because of the storage time limitation for hazardous waste at a SAA,
    generators and/or chemical waste coordinators shall perform a
    halogen screening test when the total volume of waste oil at a SAA
    reaches 55 gallons to verify their waste oil is not hazardous waste.
    Test kits will be provided by the HCT Team. Halogen screening by the
    generator is not required for waste oil accumulated in quantities of
    [\<]{.underline}5 gallons at a SAA. It will be screened by the HCT
    Team upon receipt in storage at the HWSF.

11. *White Goods* - White goods include refrigerators, ranges, water
    heaters, freezers, air conditioners, humidifiers and other similar
    domestic and large commercial appliances. White good components
    include \"any chlorofluorocarbon refrigerant, electrical switch
    containing mercury, or a device that may contain PCBs in a closed
    system, such as a dielectric fluid for a capacitor, ballast, or
    other component\". The generator shall remove components from white
    goods prior to disposing of the white goods. White goods can be
    disposed of through Business Services, Scrap Material Service.

12. *Fluorescent and High Intensity Discharge Lamps Containing Mercury
    -* Mercury containing lamps, when recycled, will be classified as a
    Universal Waste. Spent lamps, when removed from service, will be
    transported to a central location by Facilities Engineering Services
    Section (FESS) personnel and stored until a large enough quantity is
    generated to warrant recycling. Containers containing the spent
    lamps shall be marked or labeled with the phrase \"Universal Waste
    Mercury-Containing Lamp(s)\". Individuals other than FESS personnel
    who generate mercury containing lamps may request the lamps be
    picked up by completing a \"Chemical Waste Pickup Request Form\" and
    submitting it to the HCT Team. Residues and fragments from broken
    lamps must be contained and handled the same as intact lamps.

**Section C.- Resources**

1.  Containers - the following containers for collecting chemical waste
    are available from the HCT Team:

    -   55 gallon bung type steel drums

    -   30 gallon open head steel drums

    -   14 gallon open head poly drums

    -   55 gallon open head poly drums

    -   55 gallon open head steel drums

    -   55 gallon open head fiber drums

    -   55 gallon bung type poly drums

2.  Halogen Screening Tests

>