Re[2]: Storm Drain Disposal

[gr_cicotte@ccmail.pnl.gov]

          Ahem,
          
          As a former USNRC inspector, I assure anyone that disposing of 
          radioactive material of any kind, which was used or obtained for 
          their use, which is not covered by a general license (such as 
          lantern mantles, anti-static brushes, smoke detectors, etc.) is 
          considered licensed material.  If there isn't a mechanism for 
          disposal in the license of the user, it has to be transferred as 
          implied by Mr. Coogan.  
          
          Materials licenses will almost certainly specify how and how 
          much may be disposed of.  For example, hospitals ROUTINELY send 
          radioisotopes like I126 down the drain.  That is acceptable 
          under the provisions of their license.  However, if they send 
          too much, or the wrong type, e.g., they send I129 into the 
          sewer, and they're required to hold it, or they don't have I129 
          listed on their license, or they send too much at one time, or 
          (ad infinitum) whatever, they're in trouble.
          
          I'm done pontificating.  Now I"ll jump back down from my 
          soapbox.
          
          V/R
          George R. Cicotte
          Research Engineer
          HEALTH PROTECTION DEPARTMENT
          Battelle Pacific Northwest Laboratories


______________________________ Reply Separator _________________________________
Subject: Re: Storm Drain Disposal
Author:  coogen_michael@hq2ccgw.hq.dla.mil at -SMTPlink
Date:    8/4/95 12:18 PM


I would be very cautious of disposing of anything in the storm drains. 
Remember
the movie GATOR.  It surley will come back and haunt you...mike coogen sends
          
          
______________________________ Reply Separator 
_________________________________
Subject: Storm Drain Disposal
Author:  radsafe@romulus.ehs.uiuc.edu at hq2ccgw 
Date:    7/31/95 10:42 AM
          
          
          
          
          
> Someone proposed disposing of radioactive material via storm sewers. 
> I thought that the NRC/DOE/Agreement States prohibited required
> transfer of radioactve materials to licensed recipients only.  The
> sanitary sewer disposal is an exception to this principle, but I know 
> of no such exception for storm sewers (or throwing it over the fence, 
> either).
>
          
          
How about using effluent concentration limits in Appendix B Table 2 of 
-10CFR 20?(or equivalent agreement state regulations). These concentrations 
are for release to unrestricted areas .
          
BTW, I dont believe that "Disposal of RAM" in concentrations below the 
regulatory limits  is  the same as "transfer of  licensed quantities of RAM".
          
Ninni Jacob
Radiation Safety Officer
University of Rhode Island/
Rhode Island Nuclear Science Center