Re[2]: Contaminated Residential Waste from I-131 Patients

[steve.rima@DOEGJPO.COM (Steven Rima)]

     Geez Carol,
     
     Lighten up!!! I, for one, am getting a bit tired of your nasty diatribes 
     against the NRC. By now, we all know how you feel about that particular 
     agency. (No, I've never worked for them or for any other branch the 
     government, except for my Naval service long ago.) Over my 25+ year career, 
     I've met some very conscientious NRC employees, along with some bad ones.
     
     Maybe I'm mistaken, but I don't believe that the NRC can dictate landfill 
     limits to states. Many states have standards such as Indiana's, where there 
     are detectors at landfills that try to "filter out" all radioactive 
     material. Even if the NRC tried to come up with a scientifically acceptable 
     method for allowing medical isotopes in, states are still legally allowed 
     to have more conservative regulations. If this is not the case, could 
     someone correct me?
     
     I'm definitely NOT defending such practices at landfills, but I don't 
     believe we can lay blame for that problem on the NRC.
     
     Many RADSAFERS get upset with flames against individuals via RADSAFE. Let's 
     not have a double standard where it's okay to flame government agencies 
     repeatedly.
     
     My opinion only,
     
     Please direct any flames to my personal email address below
     
     Steven D. Rima, CHP, CSP
     Manager, Health Physics and Industrial Hygiene
     MACTEC-ERS, LLC
     steve.rima@doegjpo.com

______________________________ Reply Separator _________________________________
Subject: Re: Contaminated Residential Waste from I-131 Patients
Author:  carol marcus <csmarcus@ucla.edu> at Internet
Date:    2/11/00 9:50 AM


     At 08:21 AM 2/11/00 -0600, you wrote: 
Dear Richard and Radsafers:
     
Hasn't the State of Indiana heard of a really neat invention called a 
portable MCA?  You can actually identify radionuclides with it, instead of 
trying to do it by halflife. 
     
The real problem, of course, is not the medical people, or the patients who 
contaminate everything they touch, but with INSIGNIFICANT LEVELS of 
contamination.  NRC took that into consideration when, after 7 years of 
farce, finally passed the "500 mrem rule".  The problem is permitting a 
state to make a scientifically dumb standard for trash of "zero 
radioactivity".  That's where the problem is, and that's where it should be 
fixed.  Low levels of radioactive contamination (from patient body fluids) 
which are unregulated and not required to be buried in LLRW sites or decayed 
out should be allowed in garbage dumps or incinerators, just as it is 
allowed in hospitals and homes.  It merely requires the ability to identify 
and estimate the activity level of medically relevant radionuclides.  This 
is not at all difficult.
     
I really must reject the idea that because some naive and uninformed 
bureaucrats make a scientifically nonsensical standard, that the only choice 
is for the health physics, medical physics, and medical community to kill 
themselves complying with it.  The answer is to CHANGE THE STANDARD.  It 
would be nice if NRC did this for us, informing states of unacceptable and 
unreasonable standards for low levels of contaminants unassociated with any 
risk.  Alas, for years, the NRC has not had the balls or the brains to do 
this. Not after the Commissioners and their staffs screwed up BRC big time. 
There are even those at NRC who would use irrational state garbage dump 
standards as an excuse to take away the 500 mrem rule, rather than defend 
good science and cost-effective medicine against irrational hysteria. 
Hopefully, the NRC Commissioners will not be so foolish, but I don't see them 
making any effort to inform the nation of the basis for safe levels of 
medical contaminants, either.
     
The logical end of this hysteria is to keep all radioactive patients in 
isolated hospital rooms with dedicated plumbing until total decay of all the 
radionuclides.  This is patently impossible, especially when one considers 
trace contaminants that are present, such as Tc-99 with a halflife of about 
200,000 years!  The cost of even doing this for most of the radioactivity is 
enormous.  I costed it out once for currently used radionuclides in nuclear 
medicine without even considering the contaminants.  It went well into the 
multibillions of dollars, and would effectively end nuclear medicine. 
Considering that the average American has three nuclear medicine procedures 
during his lifetime, this is going to affect a lot of people.  
     
So, if NRC continues to play the coward, get your state rad health group to 
work with the garbage folks to fix this.  Get your professional 
organizations to help them do so. EDUCATE people on the safety of harmless 
levels of generally short or rather short-lived medical radionuclides. 
Explain that with a "no radioactivity" policy, it is illegal to dispose of a 
banana or a piece of hamburger because of K-40, for example. 
     
Maybe the National Academy of Sciences could get a contract to make 
standards for garbage dumps and incinerators, as waiting for the NRC appears 
to be a lost cause.  Maybe there are even better ways.  However, keeping 
every atom out of the dump or incinerator isn't one of them.
     
Ciao, Carol
     
Carol S. Marcus, Ph.D., M.D.
<csmarcus@ucla.edu> 
     
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