Most mixed wastes consist of low level radioactive wastes combined with
hazardous materials. This presents several challenges because each type of
waste is regulated by a different agency, with different laws.
One challenging aspect of mixed waste is that radioactive waste is regulated
by the Atomic Energy Act (AEA) and hazardous materials are regulated under the
Resource Conservation and Recovery Act (RCRA). That means that both the Nuclear
Regulatory Commission and the Environmental Protection Agency are involved. RCRA
specifically excludes from its definition of solid waste, "source, special nuclear,
or byproduct material as defined by the AEA". Trying to properly handle materials
that are subject to two sets of regulations is difficult and often very costly.
Most low-level mixed wastes consist of low level radioactive wastes combined
with hazardous materials in the same matrix. This presents several challenges
because each type of waste is regulated by a different agency, with different
rules and applicable laws.
The following are the "Official Definitions" for Low Level Radioactive Waste
and Hazardous Waste:
Low Level Waste (LLW)(Radioactive)
- LLW is defined in 10 CFR 61.2 (Code of Federal Regulations) as
"radioactive waste not classified as high-level radioactive
waste, transuranic waste, spent nuclear fuel, or byproduct
material as defined in section 11e.(2) of the Atomic Energy Act"
- This type of waste is either listed as a hazardous
waste in Subpart D of 40 CFR Part 261.31-33 or which
exhibits any of the hazardous waste characteristics identified
in Subpart C of 40 CFR Part 261.20-24 (ignitability, corrosivity,
Much of the information presented here is taken from a pamphlet published
by the EPA entitled "Low-Level Mixed
Waste, A RCRA Perspective for NRC Licensees", Dated August, 1990.
Exceptions to the production of mixed waste includes
Liquid Scintillation Fluids
which can be legally shipped to a contract waste disposal vendor to be burned,
and radioactive materials mixed with a hazardous component
that can be neutralized or deactivated in the laboratory.
The Radiation Safety Office will not approve the purchase of radioactive
materials that are labeled to or mixed with a hazardous component unless
it can be shown that the hazardous component is neutralized during use.
The concern of the University of Washington Radiation Safety Committee is that mixed materials will
eventually end up as mixed waste. This costs departments a lot of time and money.
If you believe you may be ordering or generating mixed waste contact
Radiation Safety at
firstname.lastname@example.org or 206.543.0463 prior
to beginning your work.