Re: Uranyl Acetate: RCRA?

[RONALD GOODWIN <RONALD_GOODWIN@health.ohio.gov>]

     Kristen
     
     It has been a few years since I used Barnwell on a regular basis, 
     however, the question arises?
     
     Will Barnwell - or can Barnwell - accept Uranyl Acetate under their 
     current license?  And if they can, how would one "list" this under 
     49CFR172.101 Hazardous Material Table as this is not listed 
     separately.  Would it have to go under "RADIOACTIVE MATERIAL, n.o.s., 
     Hazard Class 7, UN2982" or some other designation?
     
     I am curious - because Uranyl Acetate is not "Hazardous Waste" listed 
     (40CFR261 Appendices), "Hazardous Materials" listed (49CFR172.101),  
     and I have not dealt with it to know what the normal incident count 
     rate would be on a 55 gallon drum - is there even any problem with 
     sending it to a landfill designed to handle household hazardous 
     materials, such as those operated by BFI, or some other reputable 
     company.
     
     Thanks for starting this conversation.  It's fun to try to figure this 
     one out.
     
     Regards,
     
     Ronald_Goodwin@health.ohio.gov


______________________________ Reply Separator _________________________________
Subject: Uranyl Acetate:  RCRA?
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    2/7/96 1:57 PM


Continuing along the earlier discussion, after pow-wowing with some other 
RSOs, and talking to our hazardous waste people, I decided to fine tune my 
earlier post on uranyl acetate.
     
I stated it was RCRA waste. It actually is not RCRA, nor is it radioactive 
licensed material, but is a waste that is NOT accepted by hazardous waste 
sites, because of the fact that it is above background radiation when 
measured with a detector.  What this effectively boils down to is that we 
must manage this as a "hazardous" waste, even though no law defines it as 
such.
     
The consensus seems to be that many of us are managing it as a radioactive 
material to prevent possible liability or compliance issues.  Does anyone 
have any better ways to "skin this cat"?  One RSO had considered treating 
the waste, but then you have those permitting issues and contaminated 
equipment to deal with.
     
My real motive is to ask ourselves the question, "Must we spend almost 
$3000/drum to dispose of material at Barnwell that is not regulated as a 
chemical or a radioactive material?"  This is the current problem facing 
many of us, and what a waste of resources!
     
Well, enough philosophizing!  I'll be interested to hear any alternative 
ideas that you may have.
     
Again, regards,
     
Kristin
     
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Kristin Erickson, Radiation Safety Officer
Office of Radiation, Chemical and Biological Safety 
C124 Research Complex-Eng.
Michigan State University
East Lansing, Michigan 48824
Telephone: (517) 355-5008   Fax: (517)353-4871   Email: 10525kfb@msu.edu 
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