Re: NARM Use/Storage at Universities

[Mike Sturgeon <msturgeon@mriresearch.org>]

David Scherer wrote:
> 
> >I would like to know what the policy is at your institution for Naturally
> >Occurring Material? Specifically, uranium and thorium compounds,
> >namely, uranyl acetate , thorium nitrate, etc.
> 
> I would point out that these are technically _not_ NARM; they are source
> material.  Up to 15 pounds can be used at one time (150 pounds per year)
> under the general license in 10 CFR 40.22.  You should look over the terms
> and conditions of that general license.
> 
> We handle them as we do any other generally licensed source.  We do not
> provide specific procedures.  The used samples are typically disposed of as
> aqueous waste (sanitary sewer).  Unused U & Th reagents are collected by
> the RSO (when we find them).  Presently, we are simply holding them.  You
> might look into recycling the unused reagents rather than disposal.
> 
> I believe most chemical waste firms refuse to take them because they are
> source material and therefore mixed waste.  There was some discussion about
> this on radsafe about a year ago.  You might want to check the radsafe
> archives.
> 
> Regards,
> Dave Scherer
> scherer@uiuc.edu

In regards to whether source material is mixed waste, and therefore,
regulated by RCRA, refer to 40CFR261.4(a)(4).