FW: [ RadSafe ] Disposal of non-functioning LSC and gamma counters and other items

[Bryan Kirk]

I'm sure Bob meant to say Atlantic Compact (South Carolina, Connecticut,
New Jersey).

Something generators also need to keep in mind before rushing to ship
radioactive items to someone else, before Barnwell closes, is that
radioactive material, "sources, devices, and other material" that have
no further use, is waste, no matter what the receiving facility tells
you about taking possession for recycling, and waste belongs the
generator forever. Make sure the receiving facility has a legitimate
outlet and takes care of the items before Barnwell closes. 

Also, we hear about a lot of items being shipped common-carrier to
"recyclers" and their only intent is to throw the items in a waste
container. If your recycler has no use for the item when it arrives,
that would make the item a waste when it left the generator, since they
had last use. This would also mean that the shipper may have violated
the NRC / DOT manifesting requirements that state that any radioactive
waste ultimately destined for radioactive landfill must us the NRC 540
waste manifest. And if the items are waste when they left the shippers
site, common carriers who are not permitted for radioactive waste will
have violated the requirements many states have for carriers to have a
radioactive waste transport permit to travel within their state.

I've heard a lot lately about generator being encouraged to ship their
items to certain recyclers because of the cost of calling it waste. Has
the subject of "when does it become a waste" been discussed, or has
anyone seen regulation regarding this?

Bryan Kirk
Bionomics, Inc.
(865) 220-8501

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Robert D Gallagher
Sent: Thursday, August 16, 2007 10:37 AM
To: Larry Addis; Perrero, Daren; Johnston, Thomas; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Disposal of non-functioning LSC and gamma
counters


Barnwell will theoretically close its doors to all radioactive wastes
generated outside the southeast compact mid 2008.

Persons with access to the NW compact will still have a place to go with
Richland operating.

It is also likely that DOE will come up with an option for radioactive
source disposal through OSRP or GTRI programs.

As is normal with radioactive waste, nothing is certain. The only
certain thing is that disposal will be more difficult and usually much
more expensive.

What we are finding is that University regents and their associated
lawyers are looking to eliminate current and future liability. One way
to accomplish that is to get hazardous and radioactive items off campus.
We are being bombarded with exit signs, electron capture detectors, old
sealed sources, and Uranium and Thorium compounds that schools have been
told to get rid of.

Bob Gallagher
NSSI
713 641-0391





-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl]On
Behalf Of Larry Addis
Sent: Thursday, August 16, 2007 9:15 AM
To: Perrero, Daren; Johnston, Thomas; radsafe at radlab.nl
Subject: Re: [ RadSafe ] Disposal of non-functioning LSC and gamma
counters


"after June of '08 there will be nowhere the internal RAM sources can be
disposed"

I haven't heard this. Can you explain?

Larry Addis
Clemson University

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