Accepting Mixed Waste as Alternative Feed Material for Processing and Disposal at a Licensed Uranium Mill

摘要

Certain categories of mixed wastes that contain recoverable amounts of natural uranium can be processed for the recovery of valuable uranium, alone or together with other metals, at licensed uranium mills, and the resulting tailings permanently disposed of as 11e.(2) byproduct material in the mill's tailings impoundment, as an alternative to treatment and/or direct disposal at a mixed waste disposal facility. This paper discusses the regulatory background applicable to hazardous wastes, mixed wastes and uranium mills and, in particular, NRC's Alternate Feed Guidance under which alternate feed materials that contain certain types of mixed wastes may be processed and disposed of at uranium mills. The paper discusses the way in which the Alternate Feed Guidance has been interpreted in the past with respect to processing mixed wastes and the significance of recent changes in NRC's interpretation of the Alternate Feed Guidance that sets the stage for a broader range of mixed waste materials to be processed as alternate feed materials. The paper also reviews the le gal rationale and policy reasons why materials that would otherwise have to be treated and/or disposed of as mixed waste, at a mixed waste disposal facility, are exempt from RCRA when reprocessed as alternate feed material at a uranium mill and become subject to the sole jurisdiction of NRC, and some of the reasons why processing mixed wastes as alternate feed materials at uranium mills is preferable to direct disposal. Finally, the paper concludes with a discussion of the specific acceptance, characterization and certification requirements applicable to alternate feed materials and mixed wastes at International Uranium (USA) Corporation's White Mesa Mill, which has been the most active uranium mill in the processing of alternate feed materials under the Alternate Feed Guidance.