Thorium & Uranium nitrates

[Steve Deitch <73552.546@CompuServe.COM>]

To: Radsafe Mailing list recipients:

Third try:  Sorry to try your patience, but I believe I have finally succeeded
in sending out a properly formatted text message, input to me from another
computer!

We have been reading the debate regarding disposal of Uranium and Thorium
compounds, particularly nitrates.  NSSI in Houston is a treater of these
compounds.  Following is NSSI's analysis of current regulation as pertains to
Uranium and Thorium nitrate treatment, written by Bob Gallagher, NSSI President.

May 29,  1996            

I have been following the ongoing communications concerning the treatment and
disposal of
Uranium and thorium compounds. With only a few exceptions, all Uranium and
Thorium
compounds can be disposed as radioactive waste as most of the compounds are not
identified
as hazardous wastes. 

Notable exceptions are the nitrates of Thorium and Uranium. 

If you will review 49CFR 172.101, you will find that Uranium amd Thorium nitrate
require
both a radioactive label and and an oxidizer label. The determination that a
compound is an
oxidizer is based on the definition of oxidizer which is defined in 49CFR Part
173.127. The
basis for the determination of whether a material is to be defined as an
oxidizer is a test which
is described in Appendix F of 49CFR Part 173. The test compares the burning rate
of the
compound when mixed with combustible material with that of several standard
oxidizer
compounds. As both Uranium and Thorium nitrate are listed as oxidizers, it is
apparent that
they are oxidizers based on the tests. 

If you then refer to CFR 40 Part 261.21 (a)(4), you will note that a material
which is an
oxidizer as defined in 49CFR Part 173.151,(This is an error in the regulations.
The reference
should be to 49CFR Part 173.127), the material carries the D001 ignitability
characteristic
code.

The next step is to determine how to eliminate the D001 code. This information
is found in
40CFR Part 268.40 and 40CFR Part 268 Appendix VI. 40CFR Part 268.40 dictates
"DEACT"
as the required treatment if the material is to be land disposed. DEACT is
defined as "
Deactivation to remove the hazardous characteristics of a waste due to its
igniteability,
corrosivity, and/or reactivity".  Appendix VI is more specific as it relates
specifically to D001
Ignitable Oxidizers based on 40 CFR 261.21(a)(4). It defines "CHRED" or "INCIN"
treatment as potential options. CHRED is chemical reduction. INCIN is
incineration. The
rules do not define what specific treatment(s) constitutes DEACT. DEACT must
eliminate the
hazardous characteristic that caused the material to be defined as D001. For the
Uranium and
Thorium Nitrate the test which defined them as oxidizers was 49CFR Part 173
Appendix F. 

The generator of the waste must therefor determine that the waste form after
treatment is no
longer an oxidizer by performing the 49CFR Appendix F tests. 

NSSI has been corresponding with the EPA,  and S. Carolina and Washington
regulatory
agencies to request that they redefine the treatment they accept for Uranium and
Thorium
Nitrate. It appears that Washington will be requiring certification that the
material has been
tested per 49CFR 173.127. They will also be defining that their published
guidance concerning
on site treatment will apply only to Washington generators, and that the
guidance only applies
to wastes where the Uranium and Thorium nitrate are the only hazardous
constituents. EPA
agrees with the Washington approach and is encouraging S. Carolina to require
similar
documentation. 

At this time I am not aware of anyone who has tested the Uranium or Thorium
Nitrate and
concrete mixtures to determine that they will pass the 49CFR Appendix F oxidizer
tests. Each
generator who treats or has a broker treat his materials by this methodology
must certify that
the resultant waste passes the 49CFR Appendix F tests. If you utilize a broker,
you should
require a certification from him to assure that the test was conducted.





If you need additional information or clarification, please contact me.
 
Sincerely, 


Robert D. Gallagher
President