[ RadSafe ] More radioactive debris turning up in garbage

[Jim Hardeman]

Andrew *
 
There's a legal point here ... up to the point at which the radioactive materials enter the body of a patient, they are licensed radioactive materials ... once they enter the patient, at that point (with a few exceptions regarding doses to family members, etc.) the materials become exempt from license control.
 
We've been finding Tc-99m on/in hospital equipment UPSTREAM of the point at which the materials enter a patient ... i.e. the materials are still under the control of the licensee, in this case the medical facility. The issue here is not the hazard posed by these materials in a disposal situation ... the issue is the loss of control of licensed radioactive materials, and it is upon that basis that we have and will persue enforcement action.
 
All the licensee has to do is monitor its trash to prevent radioactive materials from leaving their loading dock, and they have no concerns.
 
Jim

>>> "Andrew Lukban" <alukban at chpnet.org> 4/28/2005 14:56:53 >>>


So the hot waste can either come from a hospital or from someone's home.
If it comes from a hospital, the hospital gets fined because the waste
is traceable. If it comes from anywhere else, someone gets fined but it
is not likely the hospital because it is not "usually" traceable to the
hospital nor are all sources of alarms due to medical use RAM ending up
in hospital waste. My very biased viewpoint is that the hospital should
not get fined... let the patients go home :)

The waste industry does know the problem and does know how to minimise
the "annoyance alarms". Some interesting links where the waste industry
themselves have studied the problem and made reccomendations:

http://www.astswmo.org/Publications/pdf/radiomatsurveyfinalreport.pdf

http://www.lacity.org/ead/EADWeb-MWR/lea/Workshop%20Binder%20Material/RadiationReport%20Florida.pdf





>>> <Marty.Bourquin at grace.com> 04/28/05 10:14 AM >>> 
The issue really isnt whether or not the waste is exempted. If it sets 
off the montiors at the landfill it will not be accepted by the landfill

operator. Once that alarm goes off most facilities want nothing to do 
with it. They will typically just call in someone (regulator) to take 
care of the problem - often by making the truck sit till it decays. 

Education, Education Education 

Marty Bourquin 
Manager EHS, RSO 
W.R. Grace 
Chattanooga, TN 
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