RE: RCRA Waste and Radioactive Seeds

[MARK WINSLOW <WINSLOW.MARK@epamail.epa.gov>]

RE: RCRA Waste and Radioactive Seeds

Radioactive material is NOT RCRA waste.  There is a specific definition for
RCRA hazardous waste in 40 CFR (I don't recall the exact number off
hand).  A material is a RCRA hazardous waste if it fails TCLP, has a very
high or low pH, contains certain metals, or is a specific listed waste. 
Radioactive waste is NOT there and does not need to be documented as
such.  Therefore, follow NRC guidance for documentation etc.

However, there are some caveats regarding radioactive material and EPA. 
EPA considers radioactive material hazardous waste covered under
CERCLA.  Therefore, you retain liability for proper disposal of the material 
FOREVER.  So if your waste broker illegally dumped you waste, you are
liable for the clean up costs and will be followed by the EPA's cost recovery
lawyers.  There are also reporting requirements to the national response
center if you have a spill or release.  (However the numbers are huge.) 


Mark P. Winslow
US EPA - Region II
Radiation and Indoor Air Branch
winslow.mark@epa.gov
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