RE: Liquid Scintillation

["Wright, Will (DHS-PSB)" <WWright2@DHS.CA.GOV>]

the holder of the material may be exempt from the licensing requirements such as registration, recordkeeping , reporting etc.

  the material can only be exempt form the disposal standards that apply to licensed material(and all of it, not down to the amount just below the licencing requirement and then you throw it away/give it away) if it is under any threshold that applies to that material or a deminimus disposal quantity. i do not know of any in the regs,there are some articles as such. tritium and carbon 14 in lsf below .5uc/g is considered hazardous waste only. in biomedical waste or any of the other categories listed, it is still handled as radioactive waste unles it is at or below background.  in short, if you give me the Cl-36 i cannot just throw it into the garbage. i can drain dispose under the drain disposal rules; the holder is not required to get licensed but is required to know the rules of holding, managing and disposing of the material by rules that apply to the amount and isotope. this is sometimes called "permit by rule" in the regulated sector. i am not so sure a licensee can giv

e anything away and call that a "manner that constutes disposal".



[Wright, Will (DHS-PSB)]  -----Original Message-----

From: Wes Van Pelt [mailto:WesVanPelt@att.net]

Sent: Wednesday, October 06, 2004 1:29 PM

To: 'Russ Johnson'; 'radsafe@list.Vanderbilt.Edu'

Subject: RE: Liquid Scintillation







Russ and All,



 



The Cl-36 lsc standard is probably less than the license exempt quantity for Cl-36. As a licensee you can transfer it to a person who does not have a license, say yourself or your department head. Then, since they do not have a licensee they are exempt from 10 CFR 20, including the disposal regulations. (Title10 CFR Part 20 applies only to licensees.)  Therefore, they may dispose of the exempt quantity in any way they wish: e.g., trash can, sewer, municipal waste, biomedical waste, hazardous chemical waste broker, etc. Since it is toluene, I recommend the latter. 



 



If my logic is incorrect wrt NRC and Agreement State regulations, please correct me.



 



Best regards,



 



Wes



Wesley R. Van Pelt, PhD, CIH, CHP



Wesley R. Van Pelt Associates, Inc.



 



-----Original Message-----

From: owner-radsafe@list.vanderbilt.edu [mailto:owner-radsafe@list.vanderbilt.edu] On Behalf Of Russ Johnson

Sent: Wednesday, October 06, 2004 12:58 PM

To: radsafe@list.Vanderbilt.Edu

Subject: Liquid Scintillation



 



snip.....



PS- Be careful in ordering some of these. We have a 20 ml Cl-36 standard



in toluene that's been here for years. We tried to dispose of it, but



we're stuck with it. No brokers will even bid on it.



-Russ