Mixed Waste: Ken Smith's questions

[Steve Deitch <StephenD@compuserve.com>]

Ken Smith asked the following questions.  Answers are given:

1. Are any uranium-chemicals (including uranyl nitrate) MIXED waste? [The
above would suggest to me that any chemical containing a Th or U atom in
its molecular formula, is therefore source material, and no matter how
toxic or reactive (chemically), it would NOT be a hazardous waste (CA or
RCRA).]

        It is correct that RCRA 261.4  eliminates the categories you quoted
from the definition of solid waste.  But, (as I see it this created an
anomaly which was solved by the following >>>) NRC and EPA later agreed
that waste which satisfies the definition of LLRW and  which is either
listed in Subpart D, or exhibits a characteristic identified in Subpart C
is dually regulated. 

Our reference is a report titled, "Mixed Waste Disposal Facility
Implementation Plan" done under DOE contract by EG&G people at INEL.  The
Reference quoted is 52 FR 11147.  We presume that California's regulations
"meet or exceed" the federal ones that set the nations standards.

1. Are any uranium-chemicals (including uranyl nitrate) MIXED waste? [The
above would suggest to me that any chemical containing a Th or U atom in
its molecular formula, is therefore source material, and no matter how
toxic or reactive (chemically), it would NOT be a hazardous waste (CA or
RCRA).]

That means that uranium nitrates are RCRA waste because of their oxidizer
characteristic, while uranium acetate would not be -- no K, F, U, P or D
code.

2. If uranium-chemicals are indeed only radioactive waste, what prevents
the direct burial of uranyl nitrate at Barnwell or any other LLRW facility.

        Again, it's RCRA

3. What would prevent a licensee to treat the material, say for instance
uranyl nitrate, into a less hazardous (toxicologically speaking) form, e.g.
uranium oxide in a cement matrix? 

        It's a state by state issue.  Some states are more restrictive as
to the defintion of treatment and permit requirements for RCRA wastes. 
Incidentally, it seems to us that the convestion to oxide, if permissable
without a RCRA permit by a generator is his/her home state, removes the
oxidizer characteristic by eliminating the nitrate.  Simply mixing with
cement does not necessarily do so.  The final arbiter is the oxidizer
test/definition in 49 CFR.

4. Would a solution of C-14 (50 uCi) labeled hexane (0.01 ml) mixed with
crude oil (20 L) be considered a mixed waste? Why?

        Only if its flash point was below 141 F -- the definition of
oxidizer characteristic.  Some crude oils already meet the definition. 
Incidentally, isn't this a moot point?  Barnwell does not accept oils.  We
often treat to recapture the C14 as CO2

Steve Deitch
NSSI
713 641 0391
stephend@compuserve.com