Re[2]: Storm Drain Disposal

[<L666783@LMSC5.IS.LMSC.LOCKHEED.COM>]

Having reviewed many licenses, and license applications, I find that
most licensees box themselves into corners and invite citations via
unnecessarily restrictive statements in their license applications. Face
it, if you include waste disposal procedures in excruciating detail,
you're stuck with them with little flexibility. However, if you say
something like, "We will dispose of our radioactive waste through a
qualified waste broker, or other method in accordance with the
regulations" this allows a lot of options. Remember, the regulations
authorize release of radioactive material to the environment, to air and
water, at certain concentrations, with additional limitations on
sanitary sewer releases. If they say you can do it, why not?

Donald P. Mercado, O/47-20, B/106      PROFS Nickname: DMERCADO
Radiation Safety Officer        Internet: Don@LMSC.Lockheed.com
Lockheed Martin Missiles & Space            Tel. (408) 742-0759
Sunnyvale, Ca 94089                         Fax. (408) 742-0611
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 Subject: Re[2]: Storm Drain Disposal
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           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