Management concerning changes with the waste burial operations at the Page Ranch site. The impetus for change is due to the University’s pending permit application to EPA for disposal of chemical waste.” (20) 

“The EPA jurisdictional claim arises mainly from an N.R.C. ruling made in 1981 which stated that certain liquid scintillation vials may be disposed of without regard to radioactive content. I chose not to take advantage of this exemption because: 

1) we already had an environmentally safe method of disposal 
2) incineration of even small amounts of tritium and C-14 (the only other alternative) was likely to generate considerable public concern. 

However, by tenuously classifying these liquids scintillation vials as “non-radioactive”, the EPA claims co-mingling of radioactive and non-radioactive waste and therefore jurisdiction over the burial site,...the most expedient course may simply be to turn the liquid scintillation vials in question over to Risk Management for disposal as chemical waste and avoid a potentially damaging dispute with EPA.” (20) 

       The correspondence continues:

“Bob Dorsey is proposing that all future radioactive burials conform to EPA standards. The major change would be “solidification” of all liquid wastes (the remaining, non-exempt scintillation vials plus bulk liquid radio-active waste which constitutes 20% of our total volume) and the use of plastic pit liners. 

The former condition is not unreasonable provided that it involves only the burial of liquid waste as absorbed liquids (in containers having an excess of absorbent materials). Additional costs will be incurred for absorbent materials, drums for burial, and a considerable increase in the time spent on preparation. As a preliminary estimate, the bulk liquid and 20 % of the scintillation vials would require 22 fifty-five gallon drums and 8,000 lbs of absorbent for a monthly cost of $1935. Powered equipment for handling drums