Re: Governor Gray Davis has vetoed SB 1970

["Phil Rutherford" <mail@philrutherford.com>]

Barbara,

 

I disagree.  Governor Davis' Executive Order has imposed a moratorium on "decommissioned material" (with residual radioactivity above background) going to Class III landfills.  

 

He clearly means material from any licensed or federal radiological facility that has been released for unrestricted use, using existing release criteria, such as Reg Guide 1.86.  This would apply whether in a "decommissioning" status or in an operational status. 

 

Thus you can forget about release limits in existing licenses.  Unless you are prepared to release everything at non-detect levels, then the only options are (1) keep it onsite until DHS completes its multi-year CEQA EIR,  (2) send it to a Class I or Class II landfill or (3) send it to an out of state Class III landfill.

 

Phil

 

Phil Rutherford
mail@philrutherford.com
www.philrutherford.com

 

 

Babara Hamrick wrote:

OTOH, the immediate result appears to be that, for those licensees not in "decommissioning" status, life should go on as usual - i.e., licensed release criteria for "non-radioactive" waste doesn't appear to be affected, so if one's license conditions say you can dispose of or transfer equipment without regard to the residual radioactivity if the surface contamination meets the licensed limits (e.g., Reg. Guide 1.86), then "Landfill, Ho!"