Uranyl acetate is a RCRA waste

[Steve Deitch <StephenD@compuserve.com>]

Now that I've been disagreed with, I need to respond.

To determine if something is a RCRA waste, the drill is:

Is it a waste?

        Yes.  I am "throwing it away."

Is is a solid waste?

        Yes.  The Definition is Solid, Liquid or Confined Gas.

Is it a RCRA waste?

Let's see.

I checked every definition under "Wastes from SPECIFIC Sources" ("K" codes)
40 CFR261.32  and it wasn't there.

I checked every definition under "Wastes from NONSPECIFIC sources," ("F"
codes) 40 CFR261.31 and it wasn't there.

I checked every definition under "Wastes from COMMERCIAL CHEMICAL PRODUCTS"
("U" and "P" codes) 40CFR261.33 and it wasn't there.

What's left is materials that exhibit the "CHARACTERISTIC" of being
hazardous.  Uranyl acetate does NOT meet the definition of Ignitability --
40CFR261.21, nor the definition of Corrosivity -- 40CFR261.22, nor the
definition of Reactivity -- 40CFR261.23, nor the definition of Toxicity --
40CFR261.24.  (All "D" codes.)

IT IS NOT A "HAZARDOUS WASTE"  (i.e. RCRA regulated material).  This is the
ONLY protocol one may use.

You are referring to 40CFR261.11 "Criteria for listing hazardous waste." 
This states that the administrator shall list a hazardous waste only if it
meets the criteria given.  LD50 is one of the criteria.  But the
ADMINISTRATOR (of EPA) did not list Uranyl acetate.  Perhaps he/she could
have, but didn't.  Only the lists define hazardous waste.  The
Administrator's permissives define the Administrators prerogatives. 
Calling something a RCRA waste is not within the option of a generator, no
matter what your opinion is.  You must follow the protocol.   The decision
trees are in Appendix I to 40CFR Part 260.

So I'm long winded again.  But RCRA allows for no option in what is, and
what is not a regulated material.  You need to look it up.

Steve Deitch
NSSI 713 641 0391
stephend@compuserve.com