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The purpose for the DIS rules is to cut a
break for licensees so that they do not have to send their short-lived
waste to a licensed disposal facility. Its a way around the inescapable fact
that there is not and will likely never be a de minimus or BRC rule. (And this
is the thanks we get!)
The requirement for both 10 half-lives
decay and a survey showing it is indistinguishable from background becomes more
reasonable when you consider the licensees for which DIS is an option: mostly
small medical and research facilities. Generally these licensees are
unsophisticated in health physics. Most are pretty small operations with RSOs
who are not HPs and whose primary responsibility is not managing the radiation
control program.
By requiring that both criteria be met,
regulators have a little more confidence that the facility's cold trash
won't be setting off alarm bells down stream.
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Clayton Bradt, CHP <raldrich@nysnet.net> phone: 518/457-1202 Assoc. Radiophysicist fax: 518/485-7406 NYS Dept. of Labor Radiological Health Unit Blg.12, Rm 169 State Office Campus Albany, NY 12240 *********************************************************************** |