New Land Disposal Restrictions For Contaminated Soil And Debris And Newly Identified Toxicity Characteristic Organic Wastes

The applicability of the Resource Conservation and Recovery Act (RCRA) Land Disposal Restrictions (LDR) program to radioactive mixed wastes (RMW) has been clarified through US Environmental Protection Agency (EPA) and US Department of Energy (DOE) rulemakings and notices. However, a number of waste management concerns involving RMW and RMW-contaminated soil and debris continue to exist with respect to achieving compliance with LDR provisions and treatment standards. Consequently, DOE has become increasingly proactive in its participation in the LDR rulemaking process and in the identification of LDR compliance issues associated with its RMW inventories. Both data and recommendations from across the DOE complex have been collected and transmitted to EPA in response to proposed requirements that would implement LDR for contaminated soil and debris, and certain newly identified toxicity characteristic (TC) organic wastes. Much of this information focused on concerns related to the application of proposed regulatory approaches to RMW streams. Some highlights from the information included in these DOE responses are presented.