Re: Contaminated Residential Waste from I-131 Patients

["Zack Clayton" <zack.clayton@epa.state.oh.us>]

>A primary problem lies with the operating permit for the municipal
>incinerator.  According to the regulators, the permit specifically prohibits
>incineration of radioactive materials (we haven't actually seen a copy of
>the permit).  Even though the permit is issued by the State of Indiana, we
>suspect that EPA guidance is being utilized.  When we (RSOs) suggested that
>the permit be modified, the regulators basically told us that such a change
>would require a hearing which would bring out the environmentalists.  They
>also stated that it would probably require legislative action which would be
>a political "hot potato" that no legislator would touch.

Okay,  Who are the regulators and what law is this based on?  All regulations must be based on legislation.  Get a copy of the permit and see if this is really what it says and then check the legal reference.   Guidance is not legislation.  

If a public hearing is held what's the problem?  Isn't that what government is all about?  I would like to hear the rational that tries to explain why a small fraction of a dose that -  is safe for a patient, is safe for the peole living and working with/around the patient, and is not regulated in the sewers - is suddenly not safe in a dilluted trash stream going into an incinerator.  

I would think the union for the trash collectors would have some input to exposing their members to sharps and other disease vectors in residential trash.  (Last I heard, soiled diapers were the leading cause of polio transmission in the US.)  

I'ld also find it interesting to get the public reaction if the anti's tried to suggest banning a common diagnostic and treatment medical procedure.   Or, the voters reaction to legislators who tried it.  I know at least four people who have had radio iodine treatment, and that doesn't count President Bush.  I don't think I'm that unusual with that statistic.

>The final result of the meeting was that the waste collectors are asking all
>local hospitals to provide them the residential address of patients treated
>with greater than 33 mCis of I-131 via a faxed form.  Due to confidentiality
>issues, a patient will have to provide written permission for hospitals to
>release such information.  Upon receipt of the faxed form, the waste
>collectors plan to go to the patient's home, survey their waste, and if
>radioactivity is detected, pick up the waste from the patient's home in a
>separate vehicle.  The waste will then be placed in a container at the
>collector's facility and held for decay.  While the actual number of
>man-hours involved will probably be greater, the waste collectors feel that
>this procedure is preferable to the current procedure of sifting through the
>residential waste in search of this material.

As a patient do I want all my neighbors to know that I've been treated for something that requires the city to come out and separate my trash?  "What kind of ukmpucky do you have, and don't touch me!"
How long will this separate collection continue?  Why survey at all and not just go pick it up and store it for the ten halflives.

My opinion only.




Zack Clayton
Ohio EPA - DERR
email:  zack.clayton@epa.state.oh.us
voice:  614-644-3066
fax:        614-460-8249

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