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Policy Area

ESH-Environment Safety & Health

Procedure Number

ESH100.2.ENV.24

Procedure Title

Manage Mixed Waste at SNL

Procedure Manager

JARRY, JEFFREY F.

Status

Active

Subject Matter Expert

  • Phillip W. Zelle (Phil)
  • Laura Tidwell (CA)

 

Applicability, Exceptions, and Consequences

This corporate procedure applies to all Members of the Workforce who are primary waste generators responsible for generation and management of mixed waste.

Exceptions to, or deviations from, this procedure must be approved through the Executive Policy Sponsor or Policy Area Manager, if delegated. Click here to view Contacts for Corporate Policies, Processes, and Procedures. See CG100.1.7, Request an Exception to a Policy, Process, or Procedure, for directions on how to obtain an exception to this procedure.  

Granting or permitting exceptions or violations of policy, process, or procedure without authority, regardless of position or title, may be cause for disciplinary action up to and including termination of employment. Violating a policy, process, or procedure may be cause for disciplinary action up to and including termination of employment.

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is located on the Sandia National Laboratories Sandia Restricted Network (SRN).

Procedure Overview

This procedure describes the requirements for managing mixed waste at SNL, including mixed waste that is generated at SNL/NM and mixed waste that is generated at other sites and is returned to SNL/NM for management through the SNL/NM waste management system.

Notes:

  • For additional information regarding management of mixed waste at SNL/CA, contact the SNL/CA waste management program lead.
  • For purposes of this document, DOE and NNSA are synonymous.
  • For purposes of this document, satellite accumulation points (SAPs) and Satellite Accumulation Areas (SAAs) are synonymous.

Procedure Requirements

Training

Activity Responsible Individual Required Action
Ensure Training Compliance Managers

Ensure that:

  • Members of the Workforce complete the training identified in ESH100.2.ENV.24 prior to performing the indicated work activity or fulfilling the indicated role.
    Note: See Sandia corporate procedure HR100.2.1, Identify and Complete Sandia Required Training for all Members of the Workforce.
  • Primary waste generators within the organization who are responsible for generation and management of radioactive waste are appointed.

Waste Minimization

Activity Responsible Individual Required Action
Minimize Mixed Waste Primary waste generators
  • Integrate methods into their daily work operations to minimize the generation of mixed waste.
  • Evaluate the following activities to minimize waste:
    • Identify the least toxic or hazardous material that meets the design or process requirement.
    • Encourage vendors to provide material in reusable or returnable forms.
    • Minimize material use. Consider processes or material modifications that could eliminate or reduce the generation of waste. These changes can often be justified when the cost of waste management and disposal is considered for the life of the project.
    • Limit the introduction and use of chemicals in radioactive waste generating processes. Consider processes or chemical modifications that could eliminate or reduce the generation of mixed waste.
    • Decontaminate equipment.
    • Recycle, reuse, and reclaim chemicals, material, and equipment. Consider the Chemical Exchange Program before purchasing or disposing of unused chemicals.

Note:

  • Primary waste generators should consult the appropriate Environmental Compliance Coordinator or the Pollution Prevention Program contact for ideas about methods of minimizing mixed waste generation in specific processes and for information on pollution prevention opportunity assessments (PPOAs).

Planning and Preparation

Activity Responsible Individual Required Action
Plan and Manage Mixed Waste Primary waste generators

Plan and manage mixed waste in accordance with PG470228, SNL Radioactive Waste Management Basis, as follows:

  • Prepare a technical work document (TWD) that addresses how mixed waste must be managed. For additional information, see ESH100.2.GEN.3, Develop and Use Technical Work Documents, and MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 1, "Radiological Work Planning and Controls."
  • Ensure that the TWD addresses the following at a minimum:
    • Waste characterization, including process knowledge information, and sampling and analysis planning, as applicable.
    • Mixed waste accumulation area.
    • Waste containers, labeling, and packaging.
    • Segregation and control of mixed waste to maintain waste traceability.
    • Estimated volume of mixed waste. Note: As part of the disposal request process, a waste chargeback cost is determined by actual waste volume.
    • Preferred disposal site option. Note: See the relevant subsection for additional information about the items above. An example of a Waste Management Plan is available on the Waste Management and Pollution Prevention Department (WMPPD) website.
  • Reference ESH100.2.ENV.24, Manage Mixed Waste at SNL, in the TWD and state that the requirements in ESH100.2.ENV.24, Manage Mixed Waste at SNL, must be followed. Note: Updates to TWDs can follow each organization’s regular procedure update cycle. 
  • Meet any other applicable packaging and labeling requirements described in POL 95-01, Programmatic Waste Acceptance Criteria (WAC), for an onsite storage facility that is operated by the SNL/NM WMPPD. Note: Consult the radioactive and mixed waste operations contact or the waste certification official for assistance in determining other applicable requirements, including local DOE oversight office requirements at SNL remote sites.
  • Write a request to the permission to generate mixed waste contact that describes:
    • The physical, chemical, and radiological characteristics of the mixed waste to be generated by a process to enable a determination whether a treatment and disposal pathway exists for the waste.
    • An annual forecast of the volume of the mixed waste to be generated.
  • Ensure that the above request for permission to generate mixed waste is:
    • Reviewed and approved by the permission to generate mixed waste contact before mixed waste is generated.  
    • Revised and resubmitted to the permission to generate mixed waste contact if there is a modification to the process that would change the waste form, the hazardous constituents in the waste, the annual generation volume of the mixed waste, or the location where the mixed waste is generated.
    • Implement the requirements in Mixed Waste With No Disposal Path, if it is determined that the waste has no disposal path.
  • If mixed transuranic waste must be generated, consult the transuranic waste management contact before waste is generated, to determine additional requirements regarding packaging, venting, and prohibited items. Note: Primary waste generators should consult the appropriate Environmental Compliance Coordinator before waste is generated, to resolve questions regarding mixed waste planning, accumulation, packaging, segregation, control, characterization, and disposal pathway.

Waste Characterization – Process Knowledge

Activity Responsible Individual Required Action
Document Process Knowledge Primary waste generators
  • Characterize mixed waste to permit proper segregation, treatment, storage, and disposal. Note: If you generate waste in an area where there is potential for radiological contamination or activation, then also see ESH100.2.ENV.23, Manage Radioactive Waste at SNL, "Release of Non-Radioactive Waste."
  • Ensure that physical, chemical, and radiological characteristics of the mixed waste are documented.
  • Document process knowledge for the mixed waste as the first step in waste characterization. Notes:
    • Contact the appropriate Environmental Compliance Coordinator or the waste characterization project leader for assistance in documenting process knowledge.
    • At SNL/CA, also see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA, and consult the waste management program leader for information on additional hazardous wastes that are regulated by the state of California.
    • When process knowledge relies on living memory, the individual's knowledge must be documented and signed by both the interviewer and the interviewee. For telephone interviews, a statement outlining relevant information must be signed by the interviewer (and interviewee, if possible).
  • Provide waste characterization information as an attachment to SF 2042-TRA, Radioactive or Mixed Waste Disposal Request (DR) form.

Notes:

  • A Radiological and Mixed Waste Characterization web page is available on the WMPPD web site for use by generators of mixed waste.
  • See “Waste Characterization-Process Knowledge” in Guidance on Managing Mixed Waste at SNL.
Manage Unknown Waste Primary waste generators

Manage unknown waste for which there is no characterization information as mixed waste, unless process knowledge and/or sampling and analysis can verify that the waste does not contain RCRA-regulated hazardous waste, state-regulated hazardous waste, or radioactive waste.

Notes:

  • Contact the appropriate Environmental Compliance Coordinator for assistance in managing unknown waste.
  • Contact the waste characterization project leader for assistance in characterizing unknown waste.
  • At SNL/CA, also see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA, and consult the appropriate waste management program lead for information on additional hazardous wastes that are regulated by the state of California.

Mixed Waste with No Disposal Path

Activity Responsible Individual Required Action
Manage Mixed Waste with No Disposal Path Primary waste generators
  • Identify no disposal path (NDP) waste in the planning process by describing the type and quantities of waste likely to be generated from a new project or process.
  • Complete an approval request package with assistance from the NDP waste contact, if NDP waste is identified.
  • Obtain approval from DOE prior to generating any NDP waste, with assistance from the NDP waste contact.
  • Take all necessary actions including procurement restrictions to ensure that no materials are procured that may lead to a NDP waste, without receiving prior approval from the DOE/NNSA/Sandia Site Office (SSO).
  • Review and resubmit the request package for approval each year the waste is generated, unless a disposal path becomes available.

Notes:

  • Retain the records of approval in accordance with records retention established by the generating organization.
  • Progress made in locating a viable disposal path is necessary for renewed approval to continue to generate waste with no identified path to disposal.

Mixed Waste Accumulation Area

Activity Responsible Individual Required Action
Set Up Appropriate Mixed Waste Accumulation Areas Primary waste generators

Determine appropriate locations for mixed waste accumulation at a satellite accumulation point (SAP) or at a less-than-90-day accumulation area and ensure that areas used for mixed waste accumulation:

  • Meet the requirements (for SAPs) for SNL (ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM).  Meet the requirements for SNL/CA (ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA).
  • Meet the requirements (for less-than-90-day accumulation areas) for SNL in ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM, “Less-than-90-day Accumulation Area.” Meet the requirements for SNL/CA in ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA.
  • Meet the requirements for radiological work permits and technical work documents specified in MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 1, “Radiological Work Planning and Controls.”
  • Are identified by appropriate radiation protection signs, which are posted clearly and conspicuously. See MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 2, “Posting and Labeling for Radiological Control.” Note: Consult the appropriate Radiation Protection Representative for assistance.
  • Have adequate aisle space around waste containers so that emergency access is preserved (see ESH100.2.FP.1, Manage Fire Protection Requirements). Note: For additional information, see “Mixed Waste Accumulation Areas” in Guidance on Managing Mixed Waste at SNL.
  • Are near the point of generation and under the control of the primary waste generator for waste accumulation at a SAP.
  • Are separated from areas with any other material or waste.
Provide Secondary Containment for Liquid Mixed Waste Primary waste generators
  • Provide secondary containment for mixed waste containers that contain any free liquid and that are outside, inside near a floor drain, or inside where the possibility exists that spilled liquid could be discharged to a sanitary sewer or to the environment.
  • Ensure that secondary containment systems have:
    • Sufficient capacity to contain 10 percent of the total volume of the containers, or the volume of the largest container, whichever is greater.
    • A base that is sufficiently impervious to contain leaks, spills, and precipitation until the accumulated material is removed.
    • A sloped base, elevated shelves, or other design features that prevent the containers from coming into contact with spilled or accumulated liquids.
Handle a Spill or Release of Mixed Waste Primary waste generators
  • Implement the applicable emergency plan immediately. See ESH100.3.1, Prepare for and Manage Emergencies, for specific requirements.
  • Comply with MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 11, "Radiological Incidents."
  • Consult the appropriate Environmental Compliance Coordinator for assistance in complying with ESH100.4.RPT.4, Report Environmental Releases.

Waste Containers, Labeling, and Packaging

Activity Responsible Individual Required Action
Label Waste Parcels Primary waste generators

Label waste parcels using the appropriate labels and tags:

  • Figure 1, Hazardous Waste Label.
  • Figure 2, Sample Caution Radioactive Material Information Tag.
  • Figure 3, Sample Caution Radioactive Material Information Label.
  • Figure 4, Sample Caution Radioactive Material Warning Label.
  • Figure 5, Sample Tritium Waste Warning Label.
  • Figure 6, Sample Danger Contains Asbestos Fibers Label.

Notes:

  • When radioactive waste is placed into a labeled waste container, it is defined as a waste parcel.
  • For additional information regarding labeling waste parcels, see “Waste Containers and Labels” and Packaging Waste in Containers” in Guidance on Managing Mixed Waste at SNL.
Dispose of Labels Members of the Workforce Do not dispose of labels used to indicate mixed waste in normal office trash unless the words “Hazardous Waste,” "Caution," "Radiation," "Radioactive Material," "Tritium Waste," the trefoil, and any other applicable labels have been removed or obliterated (see Figures 1 through 6).
Manage Mixed Transuranic Waste Primary waste generators Consult the transuranic waste management contact for additional requirements regarding packaging and venting of containers, if mixed transuranic waste must be generated.
Contain, Label, and Package Waste Primary waste generators
  • Follow the steps in Process for Labeling and Packaging Containers of Solid Mixed Waste, when labeling and packaging containers of solid mixed waste.
  • Follow the steps in Process for Labeling and Packaging Containers of Liquid Mixed Waste, when managing and labeling containers of liquid mixed waste.

 

Figure 1. Hazardous Waste Label

 

Figure 2. Sample Caution Radioactive Material Information Tag

 

Figure 3. Sample Caution Radioactive Material Information Label

 

Figure 4. Sample Caution Radioactive Material Warning Label

 

Figure 5. Sample Tritium Waste Warning Label

 

Figure 6. Sample Caution Danger Contains Asbestos Fibers Label

 

Process for Labeling and Packaging Containers of Solid Mixed Waste

Step Responsible Individual Required Action
1 Primary waste generators

Obtain the following, as appropriate:

  • A waste accumulation container (such as a plastic bag). If plastic bags are used, they must be clear or light yellow to allow visual inspection of contents through a double-bagged waste parcel.
  • SNL/NM-certified shipping containers, metal box liners, and absorbent through the radioactive and mixed waste operations contact. SNL/NM-certified shipping containers include:
    • 30-gallon metal drums.
    • 55-gallon metal drums.
    • 85-gallon metal drums.
    • 7x4x2-foot metal boxes.
    • 7x4x4-foot metal boxes.
    • Transportainers. Note: Consult the radioactive and mixed waste operations contact to determine the appropriate waste accumulation container or SNL/NM-certified shipping container for the waste.
  • Certification of existing shipping containers, as necessary.
  • Labels and forms.
  • Container-handling equipment.
2 Primary waste generators

Perform the following, as applicable:

  • Verify that a liner is in drums and boxes.
  • Provide documentation demonstrating that the amount of lead used for shielding is not excessive for a specific container of low-level waste. Note: Consult the waste characterization project leader.
3 Primary waste generators

Perform the following before use:

  • Confirm that shipping containers are SNL/NM-certified by:
    • Verifying that the containers have a bar-coded SNL/NM container number (such as SNL/NM004444).
    • Documenting on an SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form, whether the container has a bar-coded SNL/NM container number.
  • Conduct a pre-use inspection of waste containers and liners immediately before placing waste in the containers. The inspection includes:
    • Verifying that containers and liners are in good condition and leak-free (i.e., have no tears, dents, creases, bulges, or corrosion that would compromise the integrity of the container). Minor dents or minor surface corrosion are acceptable.
    • Visually evaluating container integrity and verifying that there is no liquid in the container before it is used.
    • Documenting this pre-use inspection by responding on an SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form. Note: If a nonconforming item has been received from the WMPPD or from a WMPPD-approved vendor, consult the radioactive and mixed waste operations contact.
  • Contact the waste certification official if water is found in a container, or if the integrity of a container has been compromised.
4 Primary waste generators

Perform the following labeling immediately after waste is placed into the waste parcel:

  • Affix and complete a hazardous waste label (Figure 1), as described under the topic, “Labels,” in ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM.
  • Affix and complete, for SNL/CA, the hazardous waste label from the WDDR Database, as described in ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA.
  • Affix a caution radioactive material warning label (see Figure 4) or danger, radioactive material warning label (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 2, “Posting and Labeling for Radiological Control”). Consult the appropriate Radiation Protection Representative for assistance on which label to use.
  • Consult the appropriate Radiation Protection Representative to determine whether a radiological survey is required during accumulation and to determine whether a caution radioactive material information tag or a caution radioactive material information label is required during accumulation (see Figure 2 and Figure 3).
  • Fill in the appropriate information on the information tag or label, if it is required to be attached to the waste parcel during accumulation.
  • Attach a caution tritium waste warning label (see Figure 5) if more than 1 millicurie of tritium is estimated to be present in the waste.
  • Record the start date (the date that mixed waste is first placed in the waste parcel) on the waste parcel.
  • Record a tracking number on the waste parcel if it does not already have an SNL/NM barcode number. This waste parcel tracking number must include the six-digit Disposal Request (DR) number followed by a two-digit sequential number (for example, 081148-01, 081148-02, and so on for multiple parcels on the DR).
5 Primary waste generators

Perform the following actions when segregating and placing mixed waste into a waste parcel:

  • Segregate mixed waste into separate waste parcels (see Segregate and Control Mixed Waste).
  • Add absorbent to waste parcels, if there is potential for condensation or moisture. Example waste parcels include waste excavated from the ground, or potentially damp personal protective equipment, such as Tyvek® coveralls. Consult the radioactive and mixed waste operations contact to obtain absorbent, and for assistance on how much absorbent to use.
  • Keep the waste parcel closed at all times, except when waste is being added or removed.
  • Load SNL/NM-certified shipping containers efficiently to minimize void space.
  • Ensure that the gross weight of the waste parcel does not exceed the maximum allowable gross weight, as stamped on the waste container or according to DOT regulations. Consult the radioactive and mixed waste operations contact for assistance with this determination.
  • Wrap and seal the waste item in plastic, if it is too large to containerize. Contact the radioactive and mixed waste operations contact for assistance.
  • Determine a packaging option for mixed waste, if the mixed waste generated has a dose equivalent rate greater than 200 millirems per hour (mrem/hr) at the surface of the waste container. Consult the radioactive and mixed waste operations contact for assistance.
6 Primary waste generators
  • Use one of the following methods to double-contain parcels of solid mixed waste to prepare for pick-up by the Waste Management and Pollution Prevention Department (WMPPD):
    • Place compactable waste, such as Tyvek® coveralls or latex gloves, in a transparent, labeled plastic bag, and double-bag the waste parcel once full.
    • Use a liner in a metal drum or metal box.
    • Place mixed waste metal debris in a lined, labeled, SNL/NM-certified metal drum or metal box. Ensure that sharps are well taped or boxed before they are double-contained. Note: Consult the appropriate Environmental Compliance Coordinator or the radioactive and mixed waste operations contact for assistance in determining appropriate packaging for mixed waste. 
  • Ensure that the outer container is labeled appropriately for waste parcels, as described in Step 4.
7 Primary waste generators
  • Request a radiological survey by the appropriate Radiation Protection Representative when the waste parcel is full and double-contained (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 8, "Monitoring Areas and Material") to facilitate pick-up of the waste parcel by the WMPPD.
  • Consult the appropriate Radiation Protection Representative for assistance in completing a caution radioactive material information tag or a caution radioactive material information label to be placed on the waste parcel (see Figure 2 and Figure 3).
  • Do not move the mixed waste parcel from a SAP unless the waste is being transferred to a less-than-90-day accumulation area, or is picked up by the WMPPD.

Process for Labeling and Packaging Containers of Liquid Mixed Waste

Step Responsible Individual Required Action
1 Primary waste generators

Collect liquid mixed waste in an appropriate rigid container (plastic, glass, or metal) that has a screw-cap lid, such as a carboy, or collect it in an approved drum. Before the container is used:

  • Consult the radioactive and mixed waste operations contact for assistance on the appropriate container for the liquid waste.
  • Ensure that the container is compatible with the liquid waste.
  • Visually evaluate container integrity and respond appropriately on SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form.
  • Keep the waste container closed at all times, except when waste is being added or removed.
2 Primary waste generators

Perform the following immediately after liquid radioactive waste is placed in the waste parcel:

  • Affix and complete a hazardous waste label (Figure 1), as described under the topic, “Labels” in ESH100.2.ENV.22, Manage Hazardous Waste at SNL.
  • Affix and complete, for SNL/CA, the hazardous waste label from the WDDR Database, as described in ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA.
  • Affix a caution radioactive material warning label (see Figure 4) or danger, radioactive material warning label (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 2, “Posting and Labeling for Radiological Control”). Consult the appropriate Radiation Protection Representative for assistance on which label to use.
  • Consult the appropriate Radiation Protection Representative to determine whether a radiological survey is required during accumulation and to determine whether a caution radioactive material information tag or caution radioactive material information label is required during accumulation (see Figure 2 and Figure 3).
  • Fill in the appropriate information on the information tag or label, if it is required to be attached to the waste parcel during accumulation.
  • Affix a caution tritium waste warning label (Figure 5) to the waste parcel if more than 1 millicurie of tritium is estimated to be present in the waste.
  • Record the start date (the date that mixed waste is first placed in the parcel) on the waste parcel.
  • Record a tracking number on the waste parcel. This waste parcel tracking number must include the six-digit Disposal Request (DR) number followed by a two-digit sequential number (for example, 081148-01, 081148-02, and so on for multiple parcels on the DR).
3 Primary waste generators Control the liquid waste parcel in a mixed waste accumulation area with secondary containment, as described under the topic, Mixed Waste Accumulation Area.
4 Primary waste generators
  • Ensure that the gross weight of the waste parcel does not exceed the maximum allowable gross weight, as stamped on the container or according to DOT regulations. Consult the radioactive and mixed waste operations contact for assistance with this determination.
  • Allow adequate headspace in a container of liquid waste such that pressure buildup does not cause leakage from the container.
  • Fill the container no more than 50 percent full to allow sufficient space for WMPPD Treatment Team operations, if liquid mixed waste requires stabilization and/or other treatment. Consult the radioactive and mixed waste treatment contact to determine if stabilization or other treatment is required.
5 Primary waste generators

Prepare the liquid waste parcel for pick-up, as follows:

  • If the liquid waste accumulation container is glass, pack it into a sealable metal can with vermiculite or other appropriate material that must hold the liquid container upright and prevents breakage.
  • Place the liquid waste parcel into a bag for double-containment, unless the container is a carboy, a sealable metal can, or a drum.
6 Primary waste generators Label the outer container appropriately, as described in Step 2.
7 Primary waste generators
  • Request a radiological survey by the appropriate Radiation Protection Representative to facilitate pick-up of the waste parcel by the WMPPD (see MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 8, "Monitoring Areas and Material").
  • Consult the appropriate Radiation Protection Representative for assistance in completing a caution radioactive material information tag or a caution radioactive material information label to be placed on the waste parcel (see Figure 2 and Figure 3).
  • Do not move the mixed waste parcel from the SAP, unless the waste is being transferred to a less-than-90-day accumulation area, or is picked up by the WMPPD.

Segregate and Control Mixed Waste

Activity Responsible Individual Required Action
Segregate Mixed Waste Primary waste generators
  • Segregate and control mixed waste to meet applicable RCRA requirements, state requirements, and treatment or disposal site waste acceptance criteria. Lack of appropriate segregation could severely impact waste disposal options.
  • See the topic, ESH100.2.ENV.22 , in ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM, for additional information on segregation of potential RCRA-regulated waste.
  • Contact the waste management program lead at SNL/CA for additional information on segregation and characterization of potential RCRA-regulated and state-regulated waste (also, see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA).
  • Segregate mixed waste into separate waste parcels according to mixed waste treatability groups (see Table 1). Note: Consult the permission to generate mixed waste contact for additional information on treatability groups.
  • Meet the waste compatibility and segregation requirements:
  • See “Waste Compatibility and Segregation,” in ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM.
  • For SNL/CA, see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA.
  • Segregate classified mixed waste from non-classified mixed waste.
  • Manage accountable nuclear material appropriately.

Segregate Potential Mixed Waste into Waste Parcels

 

 Primary waste generators

Segregate mixed waste into separate waste parcels if any of the following are also determined to be present in mixed waste:

  • Asbestos, which is regulated by the Toxic Substances Control Act (TSCA). Note: See Figure 6, Sample Danger Contains Asbestos Fibers Label, for a sample regulated asbestos waste label.
  • Polychlorinated biphenyls (PCBs), which are regulated by TSCA.
  • Compressed gases (unpunctured aerosol cans included).
  • Chelating agents (greater than 1 percent by weight).
  • Pyrophorics.
  • Explosives.
  • Etiologic agents (such as pathogens or infectious waste).
  • Particulates less than 200 micrometers in diameter, which must be packaged appropriately or immobilized.
  • Beryllium greater than 0.1 percent by weight, which may be released as an airborne particulate and must be packaged in sealed impermeable bags, containers, or enclosures to prevent the release of beryllium dust during handling and transportation.
  • Mixed transuranic waste, for which sealed containers greater than 4 liters are prohibited.
  • Animal carcasses.

Notes:

  • Consult the waste certification official for assistance on how to manage, package, and label the above-listed wastes. There may be special packaging and/or labeling requirements for these wastes.
  • For additional information see “Radioactive & Mixed Waste Management Waste Segregation Requirements.”
Segregate  Radioactively Contaminated Brass and  Radioactively Contaminated Electronics Primary waste generators
  • Segregate radioactively contaminated brass and radioactively contaminated electronics.
  • Manage these wastes as mixed waste, unless characterization is completed to prove the waste is not RCRA regulated or state regulated.
Use the Generator Waste Accumulation Disposal Log Form Primary waste generators

Document waste items placed into a waste parcel, as applicable, using the Generator Waste Accumulation Disposal Log form (found in SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form), or an equivalent form.

Note: The Generator Waste Accumulation Disposal Log form is for heterogeneous waste, such as metal debris. The Generator Waste Accumulation Disposal Log form is not required if the waste in the waste parcel is a homogeneous waste, such as soil from one site, liquid from one process, or soft personal protective equipment from one process.
Implement Administrative Controls and Maintain Traceability Primary waste generators
  • Implement administrative controls on the waste parcel to ensure that only allowable items are placed in the waste parcel. Note: It is recommended that form RF 2042-TRS, NNSS Allowable Items, be prepared and placed on the waste parcel as a reminder of the only waste items that are allowed to be placed in the waste parcel. 
  • Maintain controls and traceability of waste parcels until they are picked up by the WMPPD.
Implement Criticality Safety Requirements Primary waste generators Observe criticality safety requirements related to the accumulation of mixed waste if the process involves fissile material (see ESH100.2.SB.2, Ensure Nuclear Criticality Safety, and POL 95-01,Programmatic Waste Acceptance Criteria, for more information).
Segregate Explosive Waste Primary waste generators
  • See ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM, “Management of Excess or Waste Military Munitions,” for requirements related to management of explosive waste.
  • See ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA, for requirements related to management of explosive waste.  If the explosive waste is radioactively contaminated, SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form, must be used instead of an Explosive Waste Disposal Request form.
Segregate Ignitable and Reactive Waste Primary waste generators
  • Take precautions to prevent accidental ignition or reaction of ignitable or reactive mixed waste by keeping this waste away from sources of ignition or reaction (for example, cutting and welding, hot surfaces, frictional heat, or sparks) and radiant heat (for example, direct sunlight, smoking, or open flames).
  • Collect ignitable mixed waste only in a cabinet that complies with applicable guidelines, or in a safety can with an unaltered flame-suppressor mechanism.  Avoid combining ignitable and combustible mixed waste in the same waste container (see ESH100.2.FP.1, Manage Fire Protection Requirements, for additional information on accumulation of flammable material or ignitable waste).

Table 1. Mixed Waste TG Group Descriptions 

SNL
TG No.		 Titles Description
1 Inorganic debris (with an explosive component) This TG includes inorganic debris with an explosive component. Examples include a metal component with an explosive, such as a ferro-electric neutron generator.
2 Inorganic debris (with a water-reactive component) This TG includes inorganic debris that contains a water-reactive component. An example is elemental sodium.
3 Reactive metals This TG includes metals capable of causing fire, under standard temperature and pressure through friction, absorption of moisture, or spontaneous chemical changes. When ignited, these metals burn vigorously and persistently enough to create a hazard.
4 Elemental lead This TG includes waste that contains >50 percent by volume, bulk, and elemental lead. Examples of waste in this category are lead bricks, sheets, pigs, and pipes.
5 Aqueous liquids (corrosives) This TG includes aqueous liquids with a pH <2.0 or >12.5. Examples include nitric acid solutions, sodium hydroxide, and radiological standard solutions.
6 Elemental mercury This TG includes waste that is bulk, pourable liquid mercury. Manometers or other equipment that contains small residual amounts of mercury should be assigned to this debris category.
7 Organic liquids I This TG generally includes scintillation cocktails and other clear, organic liquids that meet the WAC of Permafix in Florida and are not heavily contaminated with metals or other hazardous compounds.
8 Organic debris (with organic contaminants) This TG consists of organic debris that contains mainly organic contaminants (e.g., solvents). Examples of organic debris include plastics, rubber, wood, paper, and cloth.
9 Inorganic debris (with Total Concentrate Leachate Procedure [TCLP] metals) This TG consists of inorganic debris that exhibits the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and/or silver. Examples of inorganic debris include metal, concrete, glass, and brick.
10 Heterogeneous debris This TG includes waste that does not meet the criteria for inorganic debris or organic debris, such as waste that is essentially entirely debris, but which cannot be determined by visual estimate to be inorganic or organic. An example is a high efficiency particulate (HEPA) filter. This TG also includes organic debris that contains both an organic and inorganic contaminant.
11 Organic liquids II This TG consists predominantly of organic liquids that may be contaminated with polychlorinated biphenyls (PCBs), metals, or other hazardous compounds. Examples include oils, Freon©, and ethyline ethylene glycol.
12 Organic debris (with TCLP metals) This TG consists of organic debris that exhibits the characteristic of toxicity, due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and/or silver. Examples of organic debris include plastics, rubber, wood, paper, cloth, and biological materials. The characteristic of toxicity is exhibited if, using the TCLP, any of the metal contaminants in 40 CFR 261.24 are present above the regulatory level. Examples of TCLP metals include arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver.
13 Oxidizers This TG includes waste that is solid and is defined as an oxidizer under Department of Transportation regulations. Examples include uranyl perchlorate, uranyl nitrate, thorium nitrate, and uranium oxynitrate.
14 Aqueous liquids (with organic contaminants) This TG consists predominantly of aqueous liquid contaminated with organic material (e.g., solvents). An example is water with methanol.
15 Soils with <50 percent debris, and particulates with TCLP metals This TG includes soil (estimated to be >50 percent by volume), and debris (estimated to be <50 percent by volume). Examples are sand, silt, rock, and gravel that do not meet the EPA land disposal restriction criteria for classification as debris, and exhibit the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver.
16 Cyanide waste This TG consists of discarded cyanide waste, including waste that is reactive due to the presence of cyanide, or discarded chemicals containing cyanide.
17 Liquid and solid waste with organic and/or metal contaminants This TG consists of a semi-solid or sludge-like material that would require pretreatment to separate liquid from solids. It contains an organic or a metal contaminant, or both. An example is septage.
18 Particulates (with organic contaminants) This TG consists of particulate-sized material containing an organic contaminant. An example is fine charcoal or vermiculite.
19 Liquids with metals This TG consists of liquids or solidified liquids that exhibit the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. Examples would be solidified oils and liquids or noncorrosive liquids with TCLP metals.
20 Propellant with TCLP metals This TG consists of materials that exhibit both the characteristic of ignitability and the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. The characteristic of ignitability is based on process knowledge (e.g., contains nitrocellulose) or analysis. Examples are mock high explosives.
21 Sealed sources with TCLP metals This TG consists of radioactive sources that exhibit the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. An example would be a mixed gamma source adsorbed onto a silver-zeolite substrate or a radium source with a silver foil backing.
22 Reserved This TG has not been defined and is reserved for future use.
23 Thermal batteries This TG consists of thermal batteries, exhibiting both reactivity and toxicity for TCLP metals.
24 Spark gap tubes with TCLP metals This TG consists of spark gap tubes that exhibit the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. Examples include krytron tubes, spark gaps, switch tubes, electron tubes, and over-voltage gap tubes.
25 Classified Items with TCLP metals This TG consists of classified items that exhibit the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. Examples of such items may include neutron generators, firing sets, and electronic components.
26 Debris items with reactives and metal (controllatrons) This TG consists of items that exhibit the characteristic of reactivity and/or the characteristic of toxicity due to one or more of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. The primary example would be controllatrons.
27 High mercury solids and liquids This TG consists of either solid or liquid material that exhibits the characteristic of toxicity due to mercury, such that the mercury concentration is in excess of 260 mg/kg. Examples could include oils or soils contaminated by high levels of mercury.
MTRU MTRU: mixed transuranic waste This TG consists of mixed transuranic waste that exhibits a hazardous waste characteristic or contains a listed hazardous component. Examples might include either compactable (filters) or noncompactable (radioactive sources or rigid items) materials that meet the definition of a mixed transuranic waste.
Note: For additional guidance and for permission to generate mixed waste, consult the permission to generate mixed waste contact.

Waste Characterization – Sampling and Analysis

Activity Responsible Individual Required Action
Use Sampling and Analysis Primary waste generators
  • Consult the appropriate Environmental Compliance Coordinator or the waste characterization project leader for assistance in sampling and analysis of mixed waste.
  • Consult the SNL/CA waste characterization project leader for information on additional hazardous wastes that are regulated by the state of California, and also see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA.
  • Use sampling and analysis to complete characterization of the waste parcel when process knowledge and waste control measures are not adequate for complete characterization.
  • Ensure that samples of waste are collected by trained Members of the Workforce according to specific sampling procedures.
  • Ensure that mixed waste characterization information includes:
    • Identification of the Resource Conservation and Recovery Act (RCRA)-regulated or state regulated hazardous waste present in the mixed waste. See ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM, for requirements related to the identification of hazardous waste. At SNL/CA, see ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA.
    • Determination of the underlying hazardous constituents (as defined in 40 CFR 268, Land Disposal Restrictions, Subpart A, “General” [40 CFR 268.2 (i)]), if the waste displays a RCRA hazardous characteristic.
    • Estimation of the activity of each radionuclide contaminant in each waste parcel, based on process knowledge and/or sampling and analysis.
    • Identification of contaminants that are controlled by other regulations such as the Toxic Substances Control Act (see Segregate and Control Mixed Waste).

Notes:

  • For additional information see:
    • Radioactive and Mixed Waste Management Waste Sampling and Analysis.
    • Radiological and Mixed Waste Characterization.
    • Waste Management Plan.
  • The primary waste generator pays the costs of sampling and analysis as part of the requirements to meet POL 95-01, Programmatic Waste Acceptance Criteria.
Develop a Sampling and Analysis Approach Primary waste generators

Consult with the waste characterization project leader for assistance with the following:

  • Developing a sampling and analysis approach such that data is representative of the waste, and determining whether a sampling and analysis plan is needed.
  • Sampling the waste.
  • Interfacing with the appropriate radiation protection representative for radiation protection coverage during the sampling event and for acquiring radiological survey data that could aid in characterization of the waste.
  • Interfacing with the on-site radiation protection sample diagnostics contact or the sample management office (SMO) contact. Note: SNL has some radiological laboratory capabilities, but not full capabilities. For some analyses, samples must be sent by the SMO to a commercial laboratory that is state-certified or DOE-certified.
  • Completing any necessary forms.
Develop a Sampling and Analysis Plan Primary waste generators

Perform the following when a sampling and analysis plan is required for a project:

  • Write the plan in accordance with PLA 96-02, Sampling and Analysis Plan for Characterization of Low-Level Mixed and Mixed Waste.
  • Ensure that the plan is reviewed by appropriate subject matter experts and by the Waste Characterization Team, and that the plan is approved.
  • Develop a schedule for updating the plan and supporting procedures in use.
Validate the Data Package Primary waste generators

Ensure that a sampling and analysis data package has gone through data validation, as appropriate.

Note: Consult the waste characterization project leader for assistance on data validation. The waste characterization project leader must determine whether data validation is required for a specific data package. If required, the SMO must perform data validation.
Document When Sampling and Analysis Cannot Be Performed Primary waste generators

Document why sampling and analysis could not be performed, if it is unsafe or impractical to obtain representative samples because of high radioactivity or because of the heterogeneity of the waste material.

Notes:

  • Sampling and analysis also may not be required if process knowledge and waste control measures are sufficient to estimate the activity of each radionuclide contaminant and to ensure that there are no RCRA-regulated waste, state-regulated waste, or other prohibited item present (see the Segregate and Control Mixed Waste subsection).
  • Naturally occurring radioactive material (NORM) and other radioactive materials that are exempt from regulation (see MN471016, Radiological Protection Procedures Manual (RPPM), Attachment 6-2," Exempted Items List") may be present in some commercial products, including building materials, thoriated welding rods, Coleman® lantern mantles, glass that contains thorium or uranium for coloring purposes, camera lenses, and ceramics.
  • Wastes containing naturally occurring or other exempt radioactive materials do not require management as mixed waste, provided the criteria in ESH100.2.ENV.23, Manage Radioactive Waste at SNL, “Release of Non-Radioactive Waste” are met. Consult the appropriate Environmental Compliance Coordinator or the waste characterization project leader for assistance.

Processing of Material or Treatment of Mixed Waste

Activity Responsible Individual Required Action
Treat Mixed Waste Primary waste generators
  • Apply this treatment section only to treatment activities occurring on Sandia-controlled premises within the state of New Mexico. At SNL/CA, treatment of mixed waste is prohibited unless special permits are obtained before treatment.
  • Do not conduct processing of material or treatment of mixed waste unless written approval is obtained through the appropriate Environmental Compliance Coordinator and the radioactive and mixed waste treatment contact. Notes:
    • The written approval would also identify notifications and certifications to be provided by the primary waste generator who conducts treatment required by 40 CFR 268, Land Disposal Restrictions.
    • Examples of processing of material or treatment of mixed waste that might be conducted by the primary waste generator include:
      • Neutralize a liquid solution as part of a process.
      • Conduct physical separation of material to minimize the volume of potential mixed waste.
      • Conduct treatment of mixed waste, such as by stabilization.
    • In some cases, processing of material or treatment of mixed waste at the generator location may be the most efficient and cost-effective approach. In most cases, it is preferred that treatment of mixed waste be performed by the Waste Management and Pollution Prevention Department (WMPPD) following waste pick-up.
  • Use an appropriate method so that the disposal site can meet its performance objectives.
  • Document the method used to process material or treat mixed waste. Note: Consult the radioactive and mixed waste treatment contact or waste certification official for assistance in developing an appropriate method.
  • When treating mixed waste by stabilization:
    • Document the type and amount of stabilization agent used to treat the mixed waste.
    • Obtain the stabilization agent from the radioactive and mixed waste treatment contact.
    • If liquid mixed waste requires stabilization, fill waste containers less than 50 percent full to allow sufficient space for addition of stabilization agent.

Prohibitions Regarding Disposal of Mixed Waste

Activity Responsible Individual Required Action
Comply with Prohibitions Regarding Disposal of Mixed Waste Primary waste generators

Do not do any of the following with mixed waste:

  • Allow the waste to enter sanitary sewer lines or storm sewers via sinks, toilets, etc.
  • Allow the waste to evaporate or disperse into the atmosphere.
  • Bury the waste or release it to the ground, either directly or indirectly.
  • Discard the waste into trash cans or dumpsters.
  • Remove the waste from Sandia-controlled premises.
  • Dilute mixed waste.
  • Manage mixed waste in any manner that could be construed as disposal.

Disposal Request for Pick-up of Mixed Waste

Activity Responsible Individual Required Action
Request Disposal of Classified Mixed Waste Primary waste generators

Do not include any information on process knowledge documents or disposal request forms (SF 2042-TRA) that are submitted with regard to classified mixed waste that would cause the document to be a classified document.

Note: Consult the appropriate Environmental Compliance Coordinator or the waste characterization project leader for assistance in appropriately characterizing classified mixed waste.
Request Disposal of Mixed Waste Primary waste generators
  • Complete SF 2042-TRA, Radioactive or Mixed Waste Disposal Request (DR) form, to request pick-up of mixed waste by the WMPPD. If at SNL/CA, you must also coordinate the submittal of Waste Description and Disposal Request (WDDR)-required documentation in accordance with ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA. Note: Consult the appropriate Environmental Compliance Coordinator for assistance in completing the DR.
  • Record each waste parcel on the DR. Note: Multiple mixed waste parcels can be submitted on one DR, but the waste in each parcel must be of the same treatability group as indicated on the DR, unless an exception is granted by the waste characterization project leader.
  • Sign the Generator Waste Accumulation Disposal Log (if completed) for each waste parcel.
  • Record the start date (the date that waste is first placed in a waste parcel) on the DR.
  • Provide a project and task number on the DR to pay the chargeback rate by volume of mixed waste to be picked up.
  • Complete the DR.
  • Sign the DR.
  • Provide the DR to the appropriate Environmental Compliance Coordinator to review the DR for completeness and to sign the DR.
  • Attach the documents shown in Table 2 to the DR.
  • Submit the Disposal Request form (SF 2042-TRA) to the radioactive and mixed waste operations contact in a timely manner, such that the waste can be picked up from a satellite accumulation point (SAP) before the volume of mixed waste reaches 55 gallons (or 1 quart of acute hazardous waste or extremely hazardous waste), or from a less-than-90-day accumulation area before the 90-day limit expires for the waste parcel.
  • Do not add waste to a waste parcel for which the SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form, has been submitted. Note: In general, a minimum of 1 month is needed from disposal request submittal to waste pick-up, when there are no questions or no additional information is needed to complete the review of the DR form.
  • Submit the DR to the radioactive and mixed waste operations contact in a timely manner such that the waste is picked up within 1 year of the start date. Notes:
    • Primary waste generators should make a copy of the DR for the project file.
    • Once the DR is approved by the WMPPD , the WMPPD pick-up crew must call to schedule pick-up of the mixed waste.
    • If the waste parcel cannot be picked up by the WMPPD in accordance with the WMPPD waste acceptance criteria (see SNL, POL 95-01, Programmatic Waste Acceptance Criteria [WAC]), the primary waste generator should consult the radioactive and mixed waste operations contact for assistance in developing a justification for a variance of the WMPPD waste acceptance criteria, and in developing a packaging method to meet waste acceptance criteria.
Accumulate Mixed Waste for Longer than 1 Year Primary waste generators Request an allowance to accumulate mixed waste for longer than 1 year from the Waste Management and Pollution Prevention Department (WMPPD) Manager or from the SNL/CA waste characterization project leader, if needed.

Table 2. Disposal Request Documents

Document

 

Format
Process knowledge documentation. Memo or other suitable form.

Sampling and analysis results, as needed.

Note: Provided for mixed waste that cannot be characterized through use of process knowledge and waste control.

 PLA 96-02, Sampling and Analysis Plan for Characterization of Low-Level Mixed and Mixed Waste.

The Generator Waste Accumulation Disposal Log.

Note: The log is included for each waste parcel that contains different items within a heterogeneous waste.

 SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form; or an equivalent form.

Radiological survey documentation.

Notes: Review the radiological survey form to ensure that:

  • The form records survey and swipe results and dose rates on the double-contained waste parcel.
  • The appropriate Radiation Protection Representative has completed and signed the form.
 Radiological survey form.

Data validation documentation, as requested by the waste characterization project leader.

Note: This form is documented by the reviewer at the Sample Management Office.

 Data validation review form.
Certification of Mixed Waste Management Office. Data validation review form.

Certify Mixed Waste

Activity Responsible Individual Required Action
Certify Mixed Waste Primary waste generators
  • Contact the waste certification official for assistance in meeting requirements such that the waste parcel can be certified.
  • Provide additional information that might be required by the waste certification official during certification or assessment activities.
  • Provide additional information that might be required by the intended disposal facility to the waste certification official.

Notes:

  • The waste certification official periodically observes waste packaging activities that are conducted by the primary waste generator.
  • The waste certification official periodically assesses waste management activities that are conducted by the primary waste generator. A report is generated and provided to the primary waste generator, as appropriate. If a finding is identified, see Nonconformances.

Nonconformances

Activity Responsible Individual Required Action
Respond to Non-conformance Related to Mixed Waste Management Primary waste generators

Ensure that:

  • Your manager is notified.
  • An RF 2042-NCA, Nonconformance Corrective Action Report, is completed for the nonconformance and submitted to the WMPPD quality assurance program project leader.
  • Corrective actions identified in the Nonconformance Corrective Action Report are implemented and documentation of implementation is provided to the WMPPD quality assurance program project leader.

Note: Primary waste generators must:

  • Implement the OOPS process as appropriate.
  • Conduct and document self-assessments for compliance with mixed waste management requirements.

 

Implementing Tools

Guidance

  • Guidance on Managing Mixed Waste at SNL
  • Waste Management Plan

Forms

  • RF 2042-NCA, Nonconformance Corrective Action Report
  • SF 2042-TRA, Radioactive or Mixed Waste Disposal Request form
  • RF 2042-TRS, NNSS Allowable Items

Websites

  • Radioactive and Mixed Waste Management Waste Segregation Requirements
  • Radioactive and Mixed Waste Management Waste Sampling and Analysis
  • Radiological and Mixed Waste Characterization
  • Waste Management and Pollution Prevention Department (WMPPD)

Requirement Drivers (Prime Contract Baseline Directives)

DOE O 435.1, Chg 1 DOE 5400.5, Chg 2

Additional Drivers

  • DOE/NV-325, Nevada National Security Site Waste Acceptance Criteria (NNSSWAC), Current Revision
  • 10 CFR 830, Subpart A – “Quality Assurance Requirements"
  • 10 CFR 835, Occupational Radiation Protection
  • 40 CFR 261.3, Definition of Hazardous Waste
  • 40 CFR 261.7, Residues of Hazardous Waste in Empty Containers
  • 40 CFR 261.24, Toxicity Characteristic
  • 40 CFR 261.33, Discarded Commercial Chemical Products, Off-Specification Species, Container Residues, and Spill Residues Thereof
  • 40 CFR 262.11, Hazardous Waste Determination
  • 40 CFR 262.34, Accumulation Time
  • 40 CFR 265, Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities
  • 40 CFR 265, Appendix V, "Examples of Potentially Incompatible Waste"
  • 40 CFR 265.171, Condition of Containers
  • 40 CFR 265.172, Compatibility of Waste With Container
  • 40 CFR 265.173, Management of Containers
  • 40 CFR 268, Land Disposal Restrictions
  • 40 CFR 700-789, Toxic Substances Control Act Regulations
  • 40 CFR 761, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions
  • 49 CFR 172, Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information, Training Requirements, and Security Plans
  • 49 CFR 173, Shippers—General Requirements for Shipments and Packagings
  • 20.4.1 NMAC, Hazardous Waste Management
  • 20.9.2 NMAC, Solid Waste Management General Requirements
  • 42 USC 6901, et. seq., Resource Conservation and Recovery Act of 1976
  • 42 USC 13106 et. seq., Pollution Prevention Act of 1990
  • 42 USC 2011, Atomic Energy Act of 1954 (AEA)

 

Training Requirements

Responsible Individual Required Recommended

Primary waste generator

Environmental compliance coordinator involved with mixed waste.

 ENV112 (annually), RAD210 or RAD230 (every 2 years), ENV189 (once), ENV252 (every 2 years). N/A

Secondary waste generator

ES&H coordinator and project leader involved with mixed waste.

 Primary waste generators train secondary waste generators on waste management requirements applicable to their projects and document this training in organizational files. ENV112 (annually), RAD210 or RAD230 (every 2 years), ENV189 (once).
Primary waste generator (SNL/CA). ENV112CA (annually), RAD210 or RAD230 (every 2 years), ENV189CA (once), ENV252 (every 2 years).  
Secondary waste generator (SNL/CA). Primary waste generators train secondary waste generators on waste management requirements applicable to their projects and document this training in organizational files. ENV112CA (annually), RAD210 or RAD230 (every 2 years), ENV189CA (once).
  ENV252 is a refresher that is required every 2 years following completion of ENV189 or ENV189CA.

Related Processes and Procedures

Processes

  • ESH100.1, Plan Work
  • ESH100.2, Analyze and Control Hazards
  • ESH100.3, Perform Work
  • SCM100.4, Dispose of Property, Material and Services through the Supply Chain

Procedures

 

 

Required Reviews

Review Completion Dates
In Process

Change Summary

Date Summary
03/27/2012

Administrative

Modified

Updated the link to the radioactive and mixed waste operations. (Requirements & Instructions, Process for Labeling and Packaging Containers of Solid Mixed Waste)
03/27/2012

Administrative

Modified

  • Updated the link to the radioactive and mixed waste operations contact throughout the document.
  • Updated the link on Guidance on Managing Mixed Waste at SNL. (Requirements & Instructions, Mixed Waste Accumulation Area)
  • Replaced "division ES&H team radiation protection representative" with "Radiation Protection Representative" and updated the link. (Requirements & Instructions, Process for Labeling and Packaging Containers of Solid Mixed Waste and Waste Characterization - Sampling and Analysis)
  • Updated the link to Radiological and Mixed Waste Characterization. (Requirements & Instructions, Waste Characterization - Sampling and Analysis)
  • Updated the link to POL 95-01. (Requirements & Instructions, Waste Characterization - Sampling and Analysis)
  • Added link to ENV189. (Training)
  • Updated the link to the Waste Management Plan guidance document. (Forms, Links & Tools)
  • Corrected title of DOE/NV-325 to Nevada National Security Site Waste Acceptance Criteria (NNSSWAC). (Additional Drivers)
03/22/2021

Administrative

Modified

  • Updated the link to SNL/CA waste management program lead.  (Overview)
  • Updated the link to the example of a Waste Management Plan. (R&I, Planning & Preparation)
  • Updated the link to Radioactive and Mixed Waste Management Waste Sampling and Analysis. (Requirements & Instructions, Waste Characterization - Sampling and Analysis)
  • Updated the link to the following terms throughout the document.
    • POL 95-01.
    • PLA 96-02.
    • Radioactive and mixed waste operations contact.
    • Radiological and Mixed Waste Characterization web page.
    • Waste certification official.
    • Permission to generate mixed waste contact.
    • Quality assurance program project leader.
    • Transuranic waste management contact.
    • Waste characterization project leader.
    • Waste management program lead.
    • SF 2042-TRA.
    • Guidance on Managing Mixed Waste at SNL.
    • NDP waste contact.
    • On-site radiation protection sample diagnostics contact.
  • Replaced "Division ES&H team environmental compliance coordinator" with "Environmental Compliance Coordinator" throughout the document.
  • Replaced "division ES&H team radiation protection representative" with "Radiation Protection Representative."
  • Replaced "Regulated Waste/Nuclear Material Disposition Department (RWNMDD)" with "Waste Management and Pollution Prevention Department (WMPPD)" throughout the document.
  • Replaced "Segregation and Control of Mixed Waste" with "Segregate and Control Mixed Waste" throughout the document.
  • Replaced "Waste Containers, Label and Packaging" with Waste Containers and Labels and Packaging Waste Containers.
  • Replaced "SF 2042-TRS, NTS Allowable Items" with " RF 2042-TRS, NNSS Allowable Items" throughout the document.
  • Updated the title to ESH100.2.ENV.22 to include "/NM" throughout the document.
  • Corrected the dictionary link to "Sandia-controlled premises."
  • Updated the link to the ES&H coordinator.  (Training)
  • Corrected the title to ESH100.2.ENV.11, ESH100.2.EXP.1 and SCM100.4.1.
  • Updated links to the Additional Drivers.
  • Replaced SAPLE link for subject matter experts with direct link to e-mail for improved usability.

Added

Reference to ESH100.3, Perform Work, and SCM100.4, Dispose of Property, Material and Services through the Supply Chain. (Related Corporate Processes & Procedures)

Deleted

Note text:  "See “Waste Minimization Hierarchy” in Guidance on Managing Mixed Waste at SNL for a description of the hierarchy Sandia follows for waste minimization."
08/11/2011

Administrative

Modified

Replaced James Thompson with Jeff Jarry as procedure manager.
01/21/2011

Administrative

Modified

Updated contact-related links that were overlooked in the changes made on 01/12/2011.
01/12/2011

Administrative

Modified

  • Updated contact-related hyperlinks in Requirements & Instructions.
  • Updated links to guidance materials.
01/06/2011

Administrative

Modified

  • Change SNL/CA subject matter expert from Leighton Ford to Laura Tidwell.
  • Updated all dictionary terms to contain term identification numbers for system consistency.
12/01/2010

Administrative

Modified

  • Updated SAPLE links to subject matter experts for system consistency.
  • Un-merged cells in requirements tables for system consistency.
6/29/2010

Administrative

No changes were made to this procedure.  An archive was generated to capture the images.
6/25/2010

Administrative

Modified

  • Updated HTML code for hyperlinks under "Implementing Tools."
6/17/2010

Administrative

Modified

  • Cleaned up HTML code for hyperlinks under "Forms, Links, and Tools."
  • Updated hyperlink to SME.

 
6/10/2010

Administrative

Modified

Updated procedure designation from" ESH100.2.OTH.1" to "ESH100.2.FP.1."
05/19/2010

Administrative

Modified (bold)

  • Corrected link to mixed waste in Procedure Requirements.