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Re: LLRW - on a more serious note
----- Original Message -----
From: Pete Collopy, CIH,CHP <pcollopy@mjwcorp.com>
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Sent: Thursday, May 04, 2000 4:25 AM
Subject: LLRW - on a more serious note
> Time to stop with my silly posts and ask a serious question. I have a
policy
> question related to when something is radioactive (and greater than
> background) - is it considered low level radioactive waste ? Please
respond
> directly to me so I don't end up cluttering the list. Everyone that sends
me
> a message I will send you a summary of what the responses, if any, were.
>
> A number of the states define Low Level Radioactive Waste as follows:
>
> "Low-level radioactive waste or LLRW or waste means radioactive material
> that is not high-level radioactive waste, transuranic waste, spent nuclear
> fuel or tailings or wastes produced by the extraction or concentration of
> uranium or thorium from any ore processed primarily for it source material
> content, and the U.S. Nuclear Regualtory Commission consistent with
federal
> law classifies as low-level radioactive waste."
>
> My take on this is that if the material is used as part of a licensed
> activity then regardless of its radioactivity content when the material or
> an object contaminated by the radioactive material is no longer useful it
is
> radioactive waste. I would also say that if the radioactive content comes
> about from a non-licensed activity it is then NOT radioactive waste. Of
> course there are certain states that include TENORM as LLRW so by
extension
> if a state had a law on the books, the material from those TENORM
activities
> would also be included as LLRW.
>
> First I would appreciate hearing from anyone who has a different
> interpretation on LLRW. Second given the following scenarios which would
you
> consider to be LLRW, and therefore regulated, and which would you not and
> why. All of the following are somewhat true examples I have run into but
> have never actually gotten a clear direction from any of the regulatory
> agencies who got involved or chose not to be involved. However, there are
> some recent stirrings within one of the states I work in that has the
> regulatory body taking a somewhat restrictive approach where anything
above
> background is to be treated as LLRW. I am sorry I can't say which one at
> this time. One hint is I don't do any work in Alaska.
>
> 1. You have a generally licensed material such as a smoke detector that
gets
> crushed and contaminates a storage area or even a home. Would all the
> contamination be treated as LLRW ? I would think so but what is the real
> obligation of the customer who possessed the source ? While I recognize GL
> materials have certain exemptions applied to them I couldn't find anything
> that specifically ruled not treating the material as LLRW when the usefull
> life was done. Besides it has been my experience that when we come across
> some GL stuff in the public arena ( I've run into some good sized Ra smoke
> detectors) we end up disposing as LLRW.
>
> 2. You are a POTW and you end up reconcentrating material from a licensed
> user up stream of your facility. The material is well below licenseable
> quantities but at greater than background levels in soil (say about 10-20
> pCi/g of some non-alpha emitting radionuclide). What if the material may
be
> from medical usage ? This is a problem when the POTW's sludge ends up
> setting off a disposal facilty's gate detector.
>
> 3. This next one is a bit facetious but it kind of drives home the point
of
> why I am asking. You have collected 1000 baby teeth and claim the Sr-90 in
> them is from licensed reactor processes. Do all the baby teeth constitute
a
> LLRW once you are done analyzing ?
>
> 4. You have a site that formerly used licenseable quantities of
radioactive
> material but has been cleared by the cognizant regulatory body. Lets say
for
> the sake of argument the regulators allow the site to contain 15 pCi/g of
> Cs-137. You are an industrialist who buys the site and finds there are
some
> areas that are over the RCRA metals limit and decide to dispose of the
soil
> because of its chemical composition. Is this a mixed waste ? I think it
may
> be because the site has been cleared based upon site parameters for future
> use and not for moving the soil to another location. On the other hand the
> site is not now being used for licensed activities so how far back does
one
> go to assume licensable material translates to LLRW ?
>
> Sorry for the length but I think this is going to be real policy (and
> practical) headache for everyone in the field if this certain unnamed
state
> decides to carry through with a what is now an unwritten policy and other
> states follow.
>
> Any answers are appreciated as I will proably end up in the next several
> months trying to steer the policy within the state to be more risk based
and
> less prescriptive just because radioactivity is present.
>
> Pete C.
>
> Peter Collopy, CIH, CHP
> MJW Corporation
> 338 Harris Hill Road
> Williamsville, NY 14221
> 716-631-8291 (phone)
> 716-631-5631 (fax)
> pcollopy@mjwcorp.com
>
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