Re: mixed waste stuff

[David Scherer <scherer@uiuc.edu>]

When I worked for a state government I attended an EPA workshop on mixed
waste regulation.  They said the RCRA specifically excludes materials
defined in the AEA, i.e. source material, byproduct material (both kinds),
and special nuclear material.  However, if AEA materials are combined with
another substance that is subject to RCRA, then the combination is mixed
waste.  The speaker was quite clear that it is the AEA-defined _substance_
that is exempt, even if it has characteristics that would be otherwise
within the scope of RCRA.  In response to a question, the speaker said that
Pb-210, e.g.,  is exempt from RCRA, even though Pb-208 is RCRA regulated.

Dave Scherer
scherer@uiuc.edu