Re: Waste Monitoring

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

I am not aware of any regulatory requirement to monitor.  However, 
some (many?) disposal permits specifically prohibit the disposal 
and/or treatment of radioactive material.  This is sometimes worded 
as to mean regulated quantities (e.g, by NRC or states).

There is certainly no requirement by the radiation regulatory agency 
for non-licensees to monitor incoming waste.  It is possible that the 
body which regulates the disposal facility requires monitoring.

A license is required for someone to possess regulated radioactive 
material.  If the material is exempt from regulation, there are no 
requirements.  So if you check the material and it IS regulated, you 
can't have it.  If you check and it isn't regulated, it's ok.  While 
it seems that it is a catch-22, the regulatory agency is much more 
interested in catching the licensee who made the unauthorized 
transfer than in punishing the party caught holding the bag 
(literally).  However, if the party at fault can't be caught, the 
possessor may be required to pay any necessary disposal costs.  This 
obviously isn't much of a problem for short-lived isotopes, but can 
be onerous for long-lived sources.  In any case, you may wish to 
contact the regulatory agency just to be on the safe side.  The main 
concern is that the material is safely and properly handled.  If you 
are doing that, the agency isn't (generally) going to make too large 
a mess out of things. 

Once it has been determined that the material is exempted from 
regulation, there is no problem doing whatever you want with the 
material.

NOTE: each state may have a different interpretation on what is 
released medical waste.  The regulation itself is vague (except for 
human excreta disposed of via the sanitary sewer).  Texas and, 
apparently, the NRC, agree that once a patient is released from 
confinement, the radioactive material within the patient is exempted 
from regulation.

Hope this provides a little clarity.

Wes

> Date sent:      Tue, 27 May 97 08:31:28 -0500
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           "K. Paul Steinmeyer" <rso@neca.com>
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        Waste Monitoring

> Dear Radsafers:
> 
> I am looking for information regarding the radiological screening of waste
> coming into a landfill, incinerator, or other type of waste facility.  I
> have some information on what can be done and what should be done, but I'm
> trying to find out what must be done as required by regulation.
> 
> -Are there actually any regulatory requirements?
> -Do agreement states differ in this from NRC states?
> -Is radiological screening of incoming waste required (or not required) by
> local or community mandate?
> -What should (or must) be done if I detect radioactive material coming in to
> one of the above mentioned facilities?
> 
> Here's one specific issue:  We all know that it is highly possible to
> receive a quantity of short-lived medical isotope (such as I-131) of
> sufficient activity to easily trigger almost any alarm.  This radioactive
> material, also, most likely, would have been released in a manner which was
> perfectly legal, but still triggers the alarm. 
> So technically, there's no legal issue.
> 
> -If I can positively identify the isotope (through half life or gamma spec),
> can I hold onto it for decay so it doesn't set off someone else's alarm?
> -Are there any regulations against holding an unknown material for a brief
> time to make an identification by its decay rate?
> -Once an isotope is identified as medical waste released appropriately, can
> it continue on in the waste stream?
> 
> I'd appreciate any information anyone could provide me on any of the
> questions above.
> 
> Thanks in advance.
> 
> Paul R. Steinmeyer
> e-mail: info@radpro.com
> fax: (860)228-4402
> ph: (860)228-0487
> 
> 
*********************************************************************
Wesley M. Dunn, CHP                        512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
*********************************************************************