Disposal of Radioactive Waste at Hanford
The Hanford Site operates lined, RCRA Subtitle C land disposal units for the disposal of non-mixed low level radioactive waste and mixed low level radioactive waste. The regulatory requirements for disposal of both mixed and non-mixed radioactive waste can be complex. This page provides information to help you understand the various environmental regulations and permit requirements as they apply to disposal at the Hanford Site. The complete set of acceptance criteria for Hanford's disposal facilities are found in the Hanford Site Solid Waste Acceptance Criteria.
It is particularly important that DOE sites that plan to ship waste to Hanford understand the site-specific and Washington State requirements prior to treating their waste. Failure to understand these requirements could result in treated waste that cannot be disposed at the Hanford Site.
Types of Waste Accepted in Hanford Disposal Units:
The following is a brief summary of the types of waste that can be managed at Hanford. Additional detail is provided in the subsequent sections of this page on how the various regulations and permit requirements affect disposal at the Hanford Site.
(Useful information on the Federal Land Disposal Restrictions can be found on EPA's LDR Web Site.)
Low-level radioactive waste disposed at Hanford's Mixed Waste Disposal Unit must meet the Federal LDRs of 40 CFR Part 268. The State of Washington has adopted the LDR regulations effective on July 1, 1999. Generators and treatment facilities that ship mixed waste for disposal at the Hanford Site must do the following to demonstrate compliance with LDR regulations:
- Waste analysis: If your waste is subject to concentration-based treatment standards, you must test a representative sample of your waste to demonstrate that it meets the applicable treatment standards. The waste analysis data must be provided with your Waste Profile Sheet or your LDR certification. Under Hanford's Waste Analysis Plan, generators that use a Hanford Site analytical laboratory or use an independent laboratory do not need to provide a corroborative sample to the Hanford Site.
Non-Hanford waste generators who use their own site testing laboratories for LDR analysis must submit a representative sample to Hanford for corroborative testing. Such testing would need to be repeated annually or whenever the waste stream changes.
- LDR certification: You must provide a certification that your waste meets the LDR requirements in accordance with 40 CFR 268.7 and (when applicable) 268.9. You can use any certification form that meets the Federal requirements. For your convenience, we have developed Hanford-specific electronic forms to print LDR certifications. The forms are available on the Tools page of this web site.
As required by the regulations, certification forms are required with the first shipment of the waste stream and each time the certification information changes.
Requirements for Decharacterized Waste and Debris that Exits RCRA
Characteristic-only (D001-D043) waste and hazardous debris can be treated to exit regulation under RCRA (in accordance with 40 CFR 261.3(d) and (f) ) and can be disposed in Hanford's unlined disposal units. For concentration-based treatment standards, you must obtain analytical data and provide LDR certifications as described above for mixed waste disposal. LDR certifications for waste that exits regulation under RCRA are typically made to the EPA Region or authorized State program. Hanford requires that generators provide a copy of that certification.
Washington State Dangerous Waste Regulations
The Washington State Dangerous Waste Regulations (WAC 173-303) regulate a broader universe of waste than the RCRA regulations and have additional land disposal restrictions. Waste generators and treaters must understand Washington's regulations as they apply to disposal of waste. There are two primary areas in which Washington's regulations are more stringent than the RCRA regulations, as follows.
Waste Designation (Additional Waste Numbers)
Washington's regulations specify additional ways for waste to be regulated. These are:
- Waste number WPCB is assigned to discarded transformers, capacitors or bushings contaminated with PCBs between 2 and 50 ppm, and to waste generated from salvaging, rebuilding or discarding 2 - 50 ppm transformers, capacitors or bushings (WAC 173-303-9904). Additionally, since WPCB is a listed waste number (i.e., regulated in the same manner as U, P, F or K listed waste), solid waste that is mixed with or derived from WPCB waste continues to be regulated as WPCB.
- Waste number WSC2 is assigned to solids and semi-solids that exhibit a pH less than or equal to 2 or greater than or equal to 12.5 when tested using SW-846 Method 9045 (WAC 173-303-090).
- Waste numbers WT01 or WT02 are assigned to certain toxic wastes as defined by WAC 173-303-100.
- Waste numbers WP01 or WP02 are assigned to wastes that contain halogenated organic compounds in combined concentration greater than 100 ppm as defined by WAC 173-303-100.
- Waste number WP03 is assigned to waste that contains certain polycyclic aromatic hydrocarbons in combined concentration greater than 1% (WAC 173-303-100).
Waste numbers WPCB and WSC2 can apply to any waste, whether it has RCRA waste numbers or not. Waste numbers WT01, WT02, WP01, WP02 and WP03 would apply only to waste that does not have RCRA waste numbers. If any waste numbers apply to your waste, it can only be disposed in the Mixed Waste Disposal Unit.
Washington Land Disposal Restrictions
In addition to the LDRs of 40 CFR 268, Washington State has other types of waste that are restricted from land disposal, as described in WAC 173-303-140. Washington's LDRs prohibit disposal of the following types of waste:
- Extremely hazardous waste (as defined by WAC 173-303-070 and 100)
- Liquid waste
- Organic/carbonaceous waste (as defined by WAC 173-303-140)
- Solid acid waste (as defined by WAC 173-303-140)
Hanford Site generators have certain exemptions that allow for disposal of extremely hazardous waste and organic/carbonaceous waste.
Toxic Substances Control Act (TSCA) Regulations
(Useful information on disposal of TSCA regulated PCB waste can be found on EPA's PCB Web Site)
The TSCA regulations (40 CFR 761, particularly 761.50 through 761.64) describe the requirements for disposal of TSCA regulated PCBs. The following is a brief synopsis of the types of TSCA PCB waste that can be disposed at the Hanford Site.
Regulation of PCBs Under the RCRA Land Disposal Restrictions
If a PCB waste is regulated under both RCRA and TSCA, the LDR regulations could require treatment to meet the Universal Treatment Standards (UTS) of 40 CFR 268.48 (depending on the waste numbers and LDR subcategories). The UTS for PCBs is 10 mg/kg (ppm). When a RCRA/TSCA waste must meet the UTS, the PCB concentration cannot exceed 10 ppm PCBs.
Regulation of PCB Waste Under the Washington State Dangerous Waste Regulations
The Washington State Dangerous Waste Regulations regulate some PCB wastes at lower concentrations than under TSCA. There are two primary cases in which Washington is more stringent than TSCA:
- Washington has an additional listed waste number, WPCB, for discarded transformers, capacitors or bushings contaminated with PCBs between 2 and 50 ppm, and for waste generated from salvaging, rebuilding or discarding 2 - 50 ppm transformers, capacitors or bushings (WAC 173-303-9904). Because WPCB is a listed (as opposed to characteristic) waste number, solid waste mixed with or derived from WPCB waste retains this waste number. All WPCB waste must be disposed in the Mixed Waste Disposal Unit.
- Washington regulates halogenated organic compounds, including PCBs, at 100 ppm (0.01 weight percent). Waste that contains 100 to 10,000 ppm PCB receives waste number WP02, which can only be disposed in the Mixed Waste Disposal Unit. Waste that contains greater than 10,000 ppm PCBs receives waste number WP01, which cannot be disposed at the Hanford site. (Note that there is a limited exclusion from regulation of certain TSCA-regulated PCB wastes as Washington Dangerous Waste see WAC 173-303-071(k)).
Hanford Site Permit Requirements
As with any permitted disposal facility, the Hanford Site must implement additional requirements under its permit with the State of Washington. In particular, the Hanford Site performs physical and/or chemical screening of a portion of the waste sent to its disposal units. Physical screening consists of nondestructive examination or visual inspection of the waste. Chemical screening consists of fingerprint chemical analyses.
Hanford's Waste Analysis Plan requires screening of nearly all waste streams. Certain types of waste, such as macroencapsulated debris, may be difficult or impossible to screen after treatment. In cases where a treated waste will be difficult to screen, alternate screening arrangements must be made, such as screening at the generator's or treater's facility. As a result, it is extremely important that sites that plan to ship waste for disposal at the Hanford Site obtain approval to ensure that screening can be performed prior to beginning treatment. The best way to obtain approval is to submit a Waste Profile Sheet prior to treatment (understanding that additional LDR data must be provided subsequent to treatment). Verification requirements will be identified on the Waste Profile Sheet approval documentation. Failure to obtain approval of a Waste Profile Sheet before treatment could result in waste that cannot be disposed at the Hanford Site.