RE: THORIUM AND URYNAL COMPOUNDS

[Dwayne Coburn <coburn@sgi.net>]

I have to agree with you Dave, if there is no commingled RCRA regulated material,  then it is not a "mixed waste", and not regulated under RCRA.  If it is not regulated under RCRA, then you never get to the point of determining if it is a "characteristic waste" under RCRA.  This is not to say that depending on your final disposal site, you will not have to perform some action on the waste to meet the specific sites waste acceptance criteria.  But this would not be "treatment" under RCRA, and would not require any interaction with EPA as long as the material was entirely AEC radioactive waste.
----------
From: 	David Scherer[SMTP:scherer@uiuc.edu]
Sent: 	Wednesday, May 22, 1996 10:11 AM
To: 	Multiple recipients of list
Subject: 	Re: THORIUM AND URYNAL COMPOUNDS

At 03:16 PM 5/21/96 -0500, Myung Chul Jo wrote:

>Uranyl nitrate and thorium nitrates are considered oxidizers, refer to 40
>CFR 261.21. and 49 CFR 172, and radioactive. However, 40 CFR 268.9
>have "Special rules regarding wastes that exhibit a characteristic". U, Th
>nitrates exhibit the characteristic of ignitability. The waste analysis and 
>recordkeeping requirements are stated in 40 CFR 268.7. 
>
>Here is what I did, (1) file waste analysis and treatment plan to regional
>EPA  (2) Our treatment plan was to deactivate the ignitability of U, Th
>nitrate powder by solidifying in concrete (3) After approval from the EPA,
>U, Th nitrates are mixed with concrete and solidified. (4) The solidified
>nitrates no longer exhibit the characteristic of ignitability. (5)
>Therefore the solidified nitrates are treated as low level
>radioactive waste.  
>
It is my understanding that the Resource Conservation Recovery Act
specifically excludes materials regulated under the Atomic Energy Act.
Since U and Th are defined as source material, they are AEA-regulated and exempt from RCRA.  Mixed waste comes into the picture only when the AEA-regulated materials are comingled with RCRA-regulated materials.  For example Pb-210 would not be mixed waste, because it is byproduct material. If it were mixed with stable Pb in a form that was a characteristic waste, the combination would be mixed waste.  (At least, that was the guidance I received at an EPA mixed waste workshop in Chicago during February, 1992.)
It would appear that U and Th wastes would follow similar considerations.

Any comments from EPA employees or other experts?

Dave Scherer
scherer@uiuc.edu