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Re: Crushing LSC Vials
>
> I have read with interest the discussions regarding crushing of LSC
> vials. Can anyone give me a reference which makes crushing LSC vials to
> separate the LSC fluid from the vials a "process". I am not that familar
> with the RECRA (sp?) rules and regulations.
For NRC Purposes, Part 20.2002 requires that a licensee get NRC approval
before performing any disposal proceedures that are not cover in part 20
subpart K. This would then apply to any mechanical seperation of LSC from
vials, (but probably excludes H3 and C14 if it is less than .05
microcurie per gram).
> All vials that are crushed at this facility have either H-3 or C-14
> with specific activities less than 0.05 uCi/cc. Therefore the waste is not
> a mixed waste since the NRC does not require us to handle it as RAM for the
> purposes of disposal. If this is true, then collection of the LSC fluid
> ... which is a hazardous waste ... is the issue.
My understanding is that all LSCs aren't hazard ous waste. The newer
cocktails are readily aqueous and supposedly "environmently freindly".
The vendors tell me that the newer cocktails are not listed as hazardous
waste so they can be "processed".
The newer cocktails are nice because of the higher flash point and the
lack of Toluene/Xylene/Benzene. We have required all our users to switch
to the newer cocktails, unless they have a specific need. This has really
cut our offsite disposal costs. We may be unique as we have an
incinerator and can incinerate our LSC in plastic vials so we really only
crush the glass and burn the fluids.
> We have an EHO on staff who has worked at EPA. He tells me that his
> reading of the EPA rules does not make crushing of the LSC vials a process. If
> this is a correct intrepretation, then are we dealing with a local and/or regional inspector who has placed his/her own spin on the regs?
>
Our general Saftey people do not have a problem with our current
operations concerning the LSC........
Pat Beyer
Medical College of Wisconsin