Re: Uranyl Nitrate Disposal

[NSSIHOU@aol.com]

Once again the standard for purchase of a radioactive material differs from 
the standards to dispose. 

To begin with, anyone can purchase Uranyl Nitrate. It is sold to chemical 
labs as a reagant. There is a general license for the possession of the 
material. The company which possesses the material is not in violation of any 
regulation so long as they have a valid use for the material. 

It is my opinion that the company could also legally give the material to any 
other person for their use and not be in violation of any regulation as that 
person can also possess the material under the same general license. 

The problem arises when the company no longer has a use for the material and 
calls it a waste. As the material is a hazardous oxidizer by definition, it 
falls under EPA jurisdiction at the time it is first called a waste. Most 
companies at that point have 90 days within which to dispose of the material. 
Calls to hazardous chemical treatment and disposal facilities result in the 
statement, "We are not allowed to take radioactive materials" or "That is a 
mixed waste, we can't take it". Calls to radioactive waste disposal companies 
yield similar statements such as, "We are not authorized to take EPA 
hazardous or mixed wastes" . 
Some enterprising radwaste companies will tell the company they can accept 
the waste if it is blended with concrete and that they will be willing to do 
such blending at the companies site. What they don't tell the company is that 
in most states, a treatment permit is required for such blending and that the 
company is liable should a regulatory agency choose to push the issue. They 
also do not inform the company that one must demonstrate that the blending 
treatment residue no longer is an oxidizer using the tests defined within DOT 
Title 49 nor do these companies do the required tests. Again the failure to 
do such testing exposes the company to liability. 

The best concise answer to the disposal of Uranium Nitrate is to transfer the 
material to a properly permitted treatment and disposal facility with both 
EPA and Radioactive waste treatment permits authorizing the treatment of 
mixed wastes. 

At NSSI, Uranium and Thorium Nitrate compounds are chemically treated to 
replace the Nitrate with other non oxidizer groups allowing the proper 
disposal of the material as dry active waste.   

Robert D. Gallagher
NSSI
713 641-0391
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