RE: Mixed waste analysis

[sbrightwell@shepmill.com (Shane Brightwell)]

Dr. Hochheiser:

3 microcuries of I-125 is a licensable quantity, based on the 10 CFR 30
Schedule B exempt activity value limit of no more than 1 microcurie.
Additionally, the Schedule A activity concentration limit of 10-6
microcuries/ml is even more restrictive (I assume South Carolina's
byproduct materials licensing regs are similar to NRC's).  Both statements
above assume I-125 is the only radioactive material in the sample.  For
additional radioisotopes, the unity rule applies. 

This action by GEL implies that if they are not specifically licensed to
possess in excess of 3 microcuries of I-125, then they can likely have no
more than the Schedule B limit of 1 microcurie total inventory in-house at
any one time.  NOTE:  I could be mistaken, but I believe it is the
SHIPPER's responsibility to verify that a recipient licensee is authorized
to possess the quantities of radioactive material being shipped.  This
typically involves the shipper having a current copy of any recipient's
license, or a written authorization from a representative of the licensee,
such as the RSO.

Nonetheless, I have to agree with your dismay.  It seems like a poor
business practice to refuse/return such a shipment without at least
contacting the shipper (client...) of the circumstances.  This is
DEFINITELY not the first time this has happened in the business, so you're
not alone.  Barringer Labs deals with this issue routinely.  We had to
develop a sample/shipment receiving program to protect the licensee,
without enraging the clients.  Seems to work pretty well so far.

It's a difficult situation, because an environmental labs typically handle
low activity samples; they have to protect themselves against exceeding the
limits of their licenses.  On the other hand, most clients simply don't
know how much activity they're sending in a sample/sample set.  They're
sending it to the lab to find out!  

I hope this information helps.  Please contact me directly if you want.


Respectfully,

Shane Brightwell, M.S., CHP
Senior Staff Engineer
Shepherd Miller, Inc.
3801 Automation Way
Suite 100
Fort Collins, CO 80525
Ph: (970)223-9600 (main)
    (970)206-4315 (office)
    (970)481-3036 (cell)
FAX:(970)223-7171
mailto:sbrightwell@shepmill.com
http://www.shepmill.com

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