Re: Re[2]: Handling and Disposal of Uranyl Acetate

[c0etxlim@mrd42.mrd.usace.army.mil (Luke I. McCormick)]

 I think the confusion is coming in because Uranyl acetate and Uranyl Nitrate
 are CERCLA listed hazardous substances. This does not make them RCRA
 hazardous wastes. The reportable quantity (in the event of a spill or
 uncontrolled release) is 100 pounds (45.4 kilos).  A part of the disposal
 problem comes from uneducated local officials (our own distinguished mayor
 proclaimed that there will never be any radioactive materials in our lanfill)
 and cautious landfill operators and disposal site operators (the Kimball 
 incinerator is screening all incoming shipments with a GM). I can't blame them
 because that is what the public wants.  A lot of my customers would rather
 pay the extra bucks to avoid the potential political fallout, and dispose of
 the Uranyl compounds as rad. waste. 
 
Caveat:  Some states which have RCRA authority have altered the definition of
 mixed waste.  They include NRC rad materials combined with STATE LISTED 
 hazardous wastes, and STATE REGULATED rad materials (usually NORM) with
 RCRA or state listed hazardous wastes.  These are often referred to as
 combined or comingled wastes. Its interesting that a mixed waste in one state
 can be transported to another state where it is not a mixed waste.

For fun:  Now imagine that your mixed waste is a historical artifact, and that 
 there is a tribal interest in the artifact. (More fun with regulations).

Luke McCormick c0etxlim@mrd42.mrd.usace.army.mil

-------------------------------------------------------------------------------- 

> 
> >     It is exempt because of the of the percent thorium to acetate is less 
> >     than limits specified in 10 CFR.   However I believe that it could be 
> >     characterized as mixed waste and might be regulated by RCRA...I would 
> >     disposed of as mixed waste...mike coogen
> 
> I have no idea why (except for pH -- which will vary by generator) UO2Ac
> solutions would be RCRA hazardous under the federal rules.
> 
> UO2Ac is not a flammable, reactive, toxic or listed (U, P, F or K) waste
> under Fed RCRA, near as I can tell.
> 
> If someone has direct interpretive and/or experiencial insight on the
> matter, please chime in.
> 
> John
> 
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