mail trouble- returning to 11e2 discussion

["Tristan" <tristan@www.blackhat.net>]

I first and formost would like to apologize.  My email has been acting up for

some time, so in the middle of the discussion on 11e2, I was forced to drop

off of radsafe for a couple of weeks.



What I plan on doing is return to the radsafe archives when the december

postings are listed, so that I can see what I missed.



I will answer the few posts I did recieve, but I hope I don't adress something

that was already resolved during the interim period.



The discussion was whether waste from mining sites would in certain

circumstances be considered NORM waste, and not 11e2 byproduct.



- someone mentioned that the EPA has a category called TENORM.  I don't know

if this is relevant, because EPA says NORM is sometimes TENORM, but does not

widen the definition to include 11e2.  "TE" ie "technichally enhanced" only

means some human dug it out of the ground with opposable thumbs and sentience.



- someone mentioned that it depends on when the waste was generated, before or

after the 1978 UMTRA.  I don't think I agree with this for the following reasons. 

if a site is eligible for UMTRA care by the DOE, it needs to be a site that

contributed to the DOE complex.  If it passes that test,  the only thing

generation pre- or post- 1978 affects is whether it recieves an UMTRA I or II

designation.  The waste is still from an UMTRA site regardless.



let me paste a paragraph of one of the point someone made:



"This act was amended in 1978 as part of the UMTRA. Before UMTRA, there was

no subsection (2) of 11 e. Your friend is correct: unprocessed ore is NORM,

once it is processed for its source content, it becomes 11e(2) waste.

All Uranium mill tailings produced after 1978 are 11e(2) waste.

Uranium Mill tailings produced before 1978 could be classified as NORM or

11e(2) depending on the site designation under UMTRA."



So I have already sortof addressed this statement, but it doies bring up

something else.  I propose that just because a new law was passed to regulate

a certain material, that does not exclude (not in this case anyway) materials

that were generated prior to the passage of the legislation.  There are

sections of the law which addressed this older material (said it came from an

UMTRA I site, and said nothing about an exemption from the classification as

Uranium mining waste under the definition.



The 11e2 law is fairly definitive as per specifically covering uranium mining,

and seems to be the only law that relates to waste generated during this

sortof activity.  I understand that even waste from gaseous diffusion plants

has passed as 11e2 here in Texas.  In addition, there has been material at

mining sites here like fence gates, and other unrelated material, which has

been declared 11e2 on principle of the function of the site itself.



On the other hand, someone mentioned waste from a rare earths mining facility

being declared as 11e2 where he or she was employed.   In this case, I would

definitely call it NORM, unless it was thorium related.  Was this site also

used for uranium mining?  This person said it wasn't uranium related, but the

generator's name makes me doubt this.   I didn't get that far, and started

having mail trouble at that point.



Someone else mentioned another point.  Fairly important to adress, although I

can't find it at the moment.  The person stated that mining "overburden" was

not considered 11e2.  I haven't seen this in the law, so I am not sure how it

has legal standing.  (it may have been an EPA statement)  Case in point: first

recall what I mentioned about the formal classification of waste at a mining

site as 11e2 in principle because of the sites function.  Even if that were

not the case, mining sites in Texas have been such a mess that overburden,

tailing, leeching fluid, etc, has run together and become comingled- so I

couldn't tell the difference between a tailings pond and an overburden

collection.  It was terribly sloppy.  



Anyway, I hope I didn't bring up some points that were later in the discussion

after I fell off the list.  

Thanks

















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