RE: - Re: saftey of being in the proximity of someone on RAI therapy

["Rick Orthen" <rorthen@cecinc.com>]

The disposal of RAM to sanitary sewers and the resulting reconcentration of

nuclides in the POTW sludge cycle is an ongoing challenge for POTW operators

and landfill operators alike.  It has been known for some time now (at least

since the 1980's--see NRC IN 88-22 and GAO's letter report GAO/RCED-94-133)

that licensee discharges to sewers in compliance with the solubility

requirements of Part 20 does little to reduce reconcentration effects at the

end of the sludge cycle (POTW natural dewatering systems, landspreading,

landfilling).  POTW operators are coming to grips with the reality that they

produce LLW biosolids.  The economic ramifications are not trivial for them.

Not to mention the investigative time consumed by portal alarms at landfills

from POTW sludge cake.



The 'problem' is real for select POTW's and has been detailed by ISCORS in

NUREG-1777 published last November.



Rick Orthen

CEC Inc.



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