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Radionuclide Exclusion

  • CERCLA excludes a limited category of radioactive materials from the statutory definition of "release"
  • See the following sections of this training: Section 1.7 Statutory and Policy Exclusions; Section 1.7.2 Radioactive Materials 

  • Current EPA policy is not to list releases of radionuclides from facilities with current license issued directly by the NRC

    • NRC is responsible for requiring and overseeing cleanup of radioactive releases at these sites.

    • EPA has authority with NRC for the cleanup of mixed and chemical waste at such sites. 

  • Radionuclides are not part of a separate HRS pathway. Section 7 of the HRS rule contains directions for the HRS factors that must be evaluated differently if radioactive or mixed radioactive wastes are found on the site.

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