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

Thu Aug 16 15:48:49 CDT 2007

All,

That is what I mean, but it's not all I mean, if the receiving facility
is honest with you and tells you the source has no value and will go to
a radioactive landfill, then you become a generator of radioactive waste
and not a previous owner of a source / device. If you are a generator of
radioactive waste, the waste is yours forever. And if your waste is
being shipped ultimately for disposal in a radioactive landfill you must
ship in accordance with DOT/NRC/State rules for rad waste, this would
eliminate a lot of common carriers including, unless I am mistaken,
Fed-Ex and UPS. You must also ship to a facility that is licensed for
rad waste, not just rad material.

It is true that OSRP is accepting ownership of sources for recycling
and/or long term storage, this is a legitimate transfer of ownership,
and is being done to remove unwanted sources from the public that have
no outlet. We ship sources, devices to recyclers who truly recycle them
regularly. My comments are aimed mostly at commercial facilities who
except sources under the guise of recycling, but know before the item is
received that it has no commercial value. This is purely a sales
technique used to give the generator a false sense of security, and
avoid costly shipping requirements. I cannot believe, if the facility
failed and the items were traced back to the previous licensee, the
regulatory agency would buy the recycling claim for a leaking Ni 63 ECD
or a decayed Gd 153 bone density source and many, many others.

An example would be a receiving facility paying the licensee $1.00 for a
source that has no value and charging the licensee a handling fee of
$1,000.00 to tell them how to ship it, I do know this goes on. The item
is received, placed in a disposal container and buried. Since it's not
declared waste until the "new owner" receives it, it can be shipped on
common carrier for very little. I know this type of "recycling" has been
going on for years and I guess there is no will by the regulators to
stop it. Another side effect is that it cost state agencies overseeing
the burial sites needed revenue. If the receiving facility, for example,
takes sources from 50 generators and ships them as their own waste that
basically cheats South Carolina out of at least $10,000 in permit fees
and US Ecology / Washington out of at least $21,200 in permit fees and
$24,500 in multiple generator fees.

I just wonder, if I open a facility in SC after July 1, 2008 to take
sources for "recycling" and I began sending these sources for disposal
as my own, how long it would take for SC to stop it?

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

-----Original Message-----
From: Robert D Gallagher [mailto:rdgallagher at nssihouston.com] 
Sent: Thursday, August 16, 2007 2:51 PM
To: Bryan Kirk; Radsafe
Subject: RE: [ RadSafe ] Disposal of non-functioning LSC and gamma
countersand other items

Sources for acceptance by the Los Alamos Offsite Source Recovery Project
are transferred to the ownership of DOE prior to shipment to the
consolidation facility. The sources are not considered by DOE to be
waste and are not at any time considered to be waste. These items are
being placed in various facilities for long term storage. Some
facilities are reusing sources or are cutting the sources open to
recover useful material. All large Am241Be neutron sources are currently
being recycled at NSSI as are some sources of Tritium. These materials
are being legally shipped without the use of the NRC 540.

What Bryan is saying is be sure you know who your material is going to
and what the receiver is doing with it.

A perfect example is the old Gulf Nuclear facility in Webster, TX. Gulf
was a source manufacturer as well as a source disposal facility. Persons
that disposed of sources through Gulf are now PRP's for the
multimillions paid by the EPA to clean up the site. Unless the generator
has a copy of a document showing his source went to land disposal, the
EPA has concluded his source was still on the site and that it's
presence contributed to the site contamination. Persons that thought the
cost of disposal for their sources have realized what appeared to be a
bargain may cost them many times what they saved.

Bob Gallagher
NSSI
713 641-0391

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl]On
Behalf Of Bryan Kirk
Sent: Thursday, August 16, 2007 12:52 PM
To: Radsafe
Subject: FW: [ RadSafe ] Disposal of non-functioning LSC and gamma
countersand other items

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

_______________________________________________
You are currently subscribed to the RadSafe mailing list

Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html

For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/

_______________________________________________
You are currently subscribed to the RadSafe mailing list

Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html

For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/

_______________________________________________
You are currently subscribed to the RadSafe mailing list

Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html

For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/