RE: RCRA Waste and Radioactive Seeds

[Craig Reed <CReed@novoste.com>]

In the bigger picture and slightly off the (radioactive seed) topic, a
non-radioactive hazard in surplus/excess/speculative accumulation of
material may prompt RCRA type controls, depending upon the specific
rules of the State.  Ohio EPA used to and may still monitor the
stockpile of DOE depleted uranium hexafluoride, not on a radioactivity
basis (which is covered by the Atomic Energy Act), but with regards to
the fluorine component.

Craig Reed
creed@novoste.com

 

> -----Original Message-----
> From:	MARK WINSLOW [SMTP:WINSLOW.MARK@epamail.epa.gov]
> Sent:	Friday, November 27, 1998 9:37 AM
> To:	Multiple recipients of list
> Subject:	RE: RCRA Waste and Radioactive Seeds
> 
> 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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