FW: [ RadSafe ] Recommendations on testing unknown waste

Fri Aug 17 08:57:03 CDT 2007

Bob,

I could not agree more.

Bryan Kirk

-----Original Message-----
From: Robert D Gallagher [mailto:rdgallagher at nssihouston.com] 
Sent: Friday, August 17, 2007 9:34 AM
To: Bryan Kirk
Subject: RE: [ RadSafe ] Recommendations on testing unknown waste

Im not aware of any that do. Texas also has the 300 day rule for wastes
going to commercial land disposal

They also recognize deminimis levels for release.

The NRC would be well advised to do some of the same things in my
opinion.

Bob Gallagher
NSSI

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl]On
Behalf Of Bryan Kirk
Sent: Friday, August 17, 2007 8:19 AM
To: 'Radsafe'
Subject: FW: [ RadSafe ] Recommendations on testing unknown waste

Just wondering, are there any other states that have extended this rule
beyond the NRC definition?

-----Original Message-----
From: nssihou at aol.com [mailto:nssihou at aol.com]
Sent: Thursday, August 16, 2007 9:44 PM
To: Bryan-Bionomics at comcast.net
Subject: Re: [ RadSafe ] Recommendations on testing unknown waste

its not whats in the rules, its their interpretation. Several years ago,
the UT system asked for an interpretation that was far broader than the
rule. The rule says the same thing as the NRC. The letter the agency
sent back to UT allows the use of <.05 for almost any type of waste.
debris, paper, liquids, almost anything.

-----Original Message-----
From: Bryan Kirk <Bryan-Bionomics at comcast.net>
To: 'Radsafe' <radsafe at radlab.nl>
Sent: Thu, 16 Aug 2007 3:03 pm
Subject: FW: [ RadSafe ] Recommendations on testing unknown waste

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
<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
<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
<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
<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
<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

________________________________________________________________________

AOL now offers free email to everyone.  Find out more about what's free

from AOL at AOL.com. _______________________________________________

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/

_______________________________________________

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/

  _____

AOL now offers free email to everyone. Find out more about what's free
from AOL at  <http://www.aol.com?ncid=AOLAOF00020000000437> AOL.com.

_______________________________________________
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/