FW: [ RadSafe ] Recommendations on testing unknown waste

Thu Aug 16 16:03:03 CDT 2007

Bob,

I don't know if agreement states, other than Texas, have extended the
NRC exemption to cover more than those two waste types, but in general,
for the rest of the nation it applies to biological tissue and
scintillation material.

In fact I've never actually read Texas' version of this NRC regulation.
Can you copy it or give us a link to it. 

Thanks
Bryan Kirk

-----Original Message-----
From: Robert D Gallagher [mailto:rdgallagher at nssihouston.com] 
Sent: Thursday, August 16, 2007 2:51 PM
To: Bryan Kirk
Subject: RE: [ RadSafe ] Recommendations on testing unknown waste

That definition only applies for materials within NRC jurisdiction
areas. As you are aware the state of Texas interprets that are far
broader than NRC and once a material is in Texas, Texas rules apply.

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 1:26 PM
To: Radsafe
Subject: FW: [ RadSafe ] Recommendations on testing unknown waste

Bob,

While I agree with the characterization, I would put in a qualifier that
the H-3, C-14, I-125 <0.05 uCi/g applies to scintillation material and
animal tissue, per the NRC regs.

Bryan Kirk
Bionomics, Inc.
(865) 220-8501
Bryan-bionomics at comcast.net

-----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 10:20 AM
To: sstewar3 at rdg.boehringer-ingelheim.com; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Recommendations on testing unknown waste

There are two ways to characterize a waste for disposal:  knowledge of
the process that generated the waste or analysis of the waste. If you
know how it was generated, you can then conduct analyses to confirm that
it is what you think it should be from the process it came from.  If
lots of persons simply poured a variety of unknown solutions into a
drum, you will have to do analysis of a representative sample. If its
multilayered, you may have to pull a representative sample from each to
properly characterize. The initial tests should be those for
characteristics. The results of those tests will tell you if you need to
do more.

If the nuclides are H-3, C-14, or I-125, annd the activity is less than
0.05 microCi/gm, you may be able to dispose as hazardous only without
regard to the radioactive constituents.

Your message doesn't provide enough of the specifics to be able to
properly assist you.

Bob Gallagher
NSSI
713 641-0391

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl]On
Behalf Of sstewar3 at rdg.boehringer-ingelheim.com
Sent: Thursday, August 16, 2007 8:28 AM
To: radsafe at radlab.nl
Subject: [ RadSafe ] Recommendations on testing unknown waste

Dear RadSafers,

I would appreciate your input on this matter.  We have radioactive
liquid waste, for which we know the activity and isotope, but the
chemical constituents are unknown.  My question is two-fold.  One, how
would one go about testing for the chemical constituents?  Is there a
laboratory that you would recommend?  Two, do we need to find and list
each chemical component, or can we just test the liquid by
characteristic/listed traits, and ship it as such (i.e.: Radioactive
material, flammable, n.o.s)?

You feedback would be appreciated.

Sincerely,

Sarah Stewart

Radiation Safety Specialist
Environmental Affairs & Safety
Boehringer-Ingelheim Pharmaceuticals, Inc.
Ridgefield, CT 06877
(203) 791-6493

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of efforrer at aol.com
Sent: Wednesday, August 15, 2007 4:48 PM
To: radsafe at radlab.nl
Subject: [ RadSafe ] Re: Inquiry about storing mixed waste

Depends on where you are located.? EPA has granted so relief on disposal
and storage of mixed waste.? However California did not adopt that
ruling and you still have to treat as radioactive and hazardous.? All
storage and time limits apply to mixed waste in California.

Gene Forrer

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