Carol is right on the money and I'm sure her language comes from years of frustration in trying to reconcile rules that are organically inconsistent. There are plenty of flame throwers out there among the anti-s and yet we dare not criticize them so why pick on one of our own?
For your info, the NRC is in the process of trying to regulate what ICRP calls trivial doses, under the clearance rule (Control of Solids). The question is not one of authority (states can pass more restrictive rules) but one of good public policy.
John Hamrick
----------
From: steve.rima@DOEGJPO.COM[SMTP:steve.rima@DOEGJPO.COM]
Reply To: radsafe@romulus.ehs.uiuc.edu
Sent: Friday, February 11, 2000 9:57 AM
To: Multiple recipients of list
Subject: Re[2]: Contaminated Residential Waste from I-131 Patients
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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