# Pm Fact Sheet Ash — Bronsamenvatting

## Bron
- Bestand: /root/Documents/HSEQ_kennis/Phoenixmetals/Info Ash/Fact sheet Ash 2025.docx
- Type: DOCX
- Grootte: 39 KB

## Kerninhoud
Factsheet SARU ash
LM van Langen
Version 1.0
November 28, 2024
1. Description of the material
General
Rest stream from crude oil refining. It is a concentrate of metals present in crude oil. This rest steam underwent a high temperature treatment that removed all hydrocarbons, leaving a dry finely powdered ash.
Chemical
Mixture of sodium metavanadate, trinatriumorthovanadate and nickel oxide
SDS available
Radiochemical
Rest stream with naturally occurring radionuclides
Test report gammaspectrometry available
Description of the intended use of the ash
Selective hydrometallurgical extraction of vanadium using lye
Total amount of processed ash: ≤60 kg ash
Batch scale: 3.5 kg of ash
Duration of the campaign: ≤3 months
Actions according to the NL law:
Besluit basisveiligheidsnormen stralingsbescherming
[wetten.nl - Regeling - Besluit basisveiligheidsnormen stralingsbescherming - BWBR0040179]
2.2. Justification 	
Article 2.2. (justification, general)
The following acts and measures must be justified prior to their implementation:
(a) Actions in planned exposure situations;
[See section 3.2] Our <1000 kg  operation is regarded intrinsic safe (see Appendix 3A3a), if the type of handling can be justified.
Our handling can be justified by:
The handling takes place under controlled process conditions
The radionuclides remain in the solid fraction after the extraction
The handling provides valuable knowledge about the valorisation of this rest stream for Society.
I suggest to formulate this justification in the RI&E
3.2 Permit, registration or notification
3.17 
Section 3.2 does not apply to operations within a site with radioactive materials:
C:
in the case of operations in moderate quantities, up to 1 000 kg, of any type of material in which the concentration of activity of the radionuclides in the radioactive substance concerned does not exceed the  exemption values set out in Annex 3, Section B, Table B, column 2. 
Values taken from Annex 3, Section B, Table B, column 2.
Conclusion: for processing the ash at the scale of the demo, section 3.2 does not apply. 
3.3.2. Resource release
Article 3.20. (release, radioactive materials)	
Section 3.2 does not apply to operations with radioactive materials intended for disposal, recycling, reuse or incineration:
 the concentration of activity of the radionuclides in the radioactive substance concerned does not exceed:
2°.the relevant release value for naturally occurring radionuclides set out in Annex 3, part B, Table A, Part 2, or
Values taken from Annex 3, Section B, Table A, part 2.
My conclusion is that we need a notification to dispose of our ‘waste’ material as the activity concentration of the U-238 series is >1 KBq/kg (Bq/g).
Special attention to Annex 3, Section B, Table B, column 3, that states the release value for the total amount of a radionuclide
Values taken from Annex 3, Section B, Table B, column 2.
These values correspond to ca 3.5 kgs of ash (limited by the Pb-210 and Ra-228 quantities) that can be disposed of. 
This is relevant for the ash that will end up in the chemical waste stream from the demo. This is either solid waste, consisting on papers that wiped ash rests or suspended ash particles in liquid waste.
I suggest to formulate in the RI&E how we will dispose of the residue, and that we estimate the absolute amount of ash that we will dispose of in the normal  chemical solid waste.
Article 4.2. (administration and files sources)	
1 An entrepreneur shall keep records of all sources for which he is responsible in which at least data are kept relating to:
a. the type, nature and location of the source;
b.de manner of its application, and
c.de means of transferring the resource or discarding it after cessation of use.
2The entrepreneur who carries out transactions with the source shall keep records of those transactions.
3The administration and files as referred to in the first and second paragraphs shall be housed in a management system.
4The records shall contain at least

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