Wild gesse, uranium, and mixed waste...

[Ken Smith <ksmith@cats.ucsc.edu>]

Hi all - 

Once again, a number of e-mail responses to my previous posts have prompted
me to asks some questions.

On my last post regarding uranyl acetate and it's inclusion as a CALIFORNIA
hazardous waste, I stated that:

"Uranyl acetate with a reported LD50-oral rat of 204 mg/Kg (Sax's Dangerous
Properties of Industrial Materials) would still be considered a HW in
California.  Disposal of this material by Californian's would have to be
through a permitted MIXED waste facility (even if shipped out of California
for disposal).  Drain disposal of this material would not be permitted in
Californian due to its inclusion as a California Hazardous Waste."

After receiving a number of replies and a little research, I've learned the
following: 

California Code of Regulations Title 22 Section 66261.4(a)(2) excludes:
"source, special nuclear or by-product material as defined by the federal
Atomic Energy act of 1954, as amended (42 USC 2011 et. sq.);" from being
identified as a California hazardous waste. 

40 CFR 261.4(a)4 also includes the same line about excluding source
material as a Federal (RCRA) hazardous waste.

Following the trail. 42 USC 2011 et. sq. (specifically 42 USC 2014) directs
the NRC to define source material which it has in 10 CFR 20.1003 as:

"(1) Uranium or thorium, or any combination of uranium and thorium in any
physical or chemical form; or
(2) Ores which contained, by weight, one-twentieth of one percent (0.05
percent), or more, of uranium, thorium, or any combination of uranium
thorium.  Source material does not include special nuclear material."