Re: Uranyl Acetate

["Scott Richards" <sr996@poppa.fab.albany.edu>]

This now brings up and interesting question. Can we dispose of Uranyl 
Acetate down the sanitary sewer. The NYSDOH has told me that this 
might be possible. The limitations, per DOH, are with the hazardous 
material requirements.

Please comment.

> Your question points out one of the anomalies in the legal nomenclature
> used.  As the responses I have read so far show, Uranyl acetate is a
> hazardous material ... it's LD50 etc.  But your question had to do with
> regulation.
> 
> Uranyl acetate is not specifically regualated for TRANSPORTATION purposes
> as a hazardous material ... it is not specifically identified in the
> HAZARDOUS MATERIAL TABLE .. 49CFR172.101.  It is (as you point out)
> regulated as a radioactive for transportation materials.  You have several
> choices of shipping name, all containing the word "Radioactive, n.o.s." 
> NOS means not otherwise specified.
> 
> The confusion occurs because of the nomenclature.  "Hazardous" is a
> transportation term, and defined by 49CFR.  "Regulated" for these purposes
> is a disposal term, defined for chemical waste (without regard to
> radioactivity) by 40CFR (the Resource Conservation and Recovery Act =
> RCRA).  It gets confusing because we refer to "hazardous waste" almost
> colloquially, when we mean "RCRA regulated."  RCRA wastes may or may not be
> hazardous materials for transportation purposes.  Hazardous materials may
> or may not be RCRA wastes.
> 
> So after this long winded remark, Uranyl acetate is hazardous because of
> it's radioactive nature, and must be disposed of in accordance with the rad
> regs, but it is not "hazardous waste" under the chemical waste regs (RCRA).
> 
Scott Richards, RRPT
Radiation Safety Officer
University at Albany, SUNY
518-442-3497
Fax: 518-442-3783
SR996@poppa.fab.albany.edu