Re: Uranyl Nitrate Disposal

[BLHamrick@aol.com]

In a message dated 01/18/2000 7:08:25 PM Pacific Standard Time, 
NSSIHOU@aol.com writes:

<< 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.  >>

Under California (an Agreement State) regulations the general license for 
source material (which includes the above referenced compounds) is as follows:
 
 §30191. General Licenses-Source Material.  
 
     (a) A general license is hereby issued to commercial firms, education, 
and medical institutions and government agencies, authorizing the possession 
and use of not more than 15 pounds of source material at any one time, for 
research, development, educational, commercial or operational purposes. 
Persons authorized to possess and use source material, pursuant to this 
general license, may not receive more than a total of 150 pounds of source 
material in any one calendar year. Any person shall, with respect to such 
source material, be exempt from the provisions of Group 3 of this subchapter, 
except for Sections 30253, 30254 and 30293(a), unless such person also 
possesses source material under a specific license.  
  
 (b) A general license described in Section 30191(a) shall not authorize 
human use; or the use in any device or article which is intended to be placed 
on or in the human body; or the use of any instrument or apparatus (including 
component parts and accessories thereto) intended for human use.  

Note that one of the sections, from which the general licensee is NOT exempt 
is California Code of Regulations, title 17, section 30253, which adopts 10 
CFR 20 (the 01/01/93 version) in its entirety.

The reason waste is treated differently than an isolated transfer (as opposed 
to commercial distribution) is that the an isolated transfer results in a 
disposition of the material consistent with the original intended use, under 
the same general license and restrictions.  Disposal at public landfills or 
other similar sites results in an essentially uncontrolled dispersement of 
the material.

Stop.  Please, do not mistake my statements regarding the regulatory 
restrictions and reasoning as my own personal beliefs.  I think that IF a 
study was done, demonstrating and documenting the minimal effects of the 
unregulated disposal of uranyl nitrates and other similar compounds (as was 
done for the americium in domestically-produced smoke detectors, which can be 
disposed as non-radioactive waste, even in bulk), then there would be no 
problem.  Someone needs to fund and undertake the study.  The public at least 
deserves a considered answer to their questions regarding the safety of 
unregulated disposal....OTOH, they should be willing to pay for it through 
their tax monies.

Barbara <---who thinks she's said too much

 
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