RE: Landfill detector trips

["Simmons, Charlie" <CSimmons@kilstock.com>]

Regarding landfill portal monitors:

I suspect that the primary motivation behind landfill owners/operators
installing sensitive portal monitors is NOT a state regulatory requirement
(indeed, aside from prohibitions on disposal of rad waste, I am not aware of
any federal or state regulations that establish a portal monitor
requirement, setpoint, calibration, operator training, etc.) -- rather,
operators of typical non-hazardous RCRA "D" landfills permitted to receive
non-hazardous waste do not want to incur any cleanup liability for rad
contamination under CERCLA ("Superfund") or comparable state law.  Portal
monitors are prevalent and their use is expanding, without comparable
education, training, or standardization. The usual practice seems to be a
"background zero" which results in many hits.  

This phenomenon is presenting increasing difficulties for persons who
dispose of refractory materials, among other non-RCRA industrial solid
wastes that are slightly elevated in natural U and Th.  My understanding is
that some states provide informal guidance; and CRCPD has drafted a guidance
document, but more education is needed since portal monitors are evolving
into a  "practice." 


Charles Simmons
Counsel for the
Zirconium Environmental Committee
csimmons@kilstock.com
202/508-5806   





-----Original Message-----
From: steve.rima@DOEGJPO.COM [mailto:steve.rima@DOEGJPO.COM]
Sent: Friday, October 29, 1999 1:43 PM
To: Multiple recipients of list
Subject: Re[2]: Release of I-131 Patients


     I too have had the fun of looking into a couple of sanitary landfill 
     alarms. I don't believe that we can lay this problem at the feet of 
     the NRC or any other regulatory agency, at least in most cases. Where 
     I've looked into alarms at landfills, the alarm setpoint was 
     arbitrarily set by the landfill (or the company that installed their 
     detection system), and not by any regulatory requirements. I've seen 
     the same thing at scrap metal yards. How many states have regulations 
     that even require such monitors, let alone mandate the alarm setpoint?
     
     No matter what the limits are, there will always be those who will 
     want their landfills to admit "no radioactive material", along with 
     the companies making and installing such instruments. I don't see this 
     particular problem going away no matter what contamination limits are 
     set by NRC. I see it getting worse as instrument manufacturers make 
     even more sensitive instruments that they push landfills to buy.
     
     Steven D. Rima, CHP, CSP
     Manager, Health Physics and Industrial Hygiene
     MACTEC-ERS, LLC
     steven.rima@doegjpo.com


______________________________ Reply Separator
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     <snip>
     
     Carol Marcus wrote:
     
     
Dear Mark and Radsafers:
     
The problem was not the patient who was released.  The problem is NRC's 
nonsensical requirements at power plants.  Fix those.
     
We had a related incident in Los Angeles at a sanitary landfill that had 
installed highly sensitive NaI(Tl) detectors.  We were picking up diapers 
and other remnants of nuclear medicine procedures.  One day Rad Health spent

hours trying to locate the radioactive trash in a truck, and it turned out 
that the driver had had an NaI-123 thyroid scan and when he drove the truck 
past the detectors, he set them off. We fixed the problem.  We measured all 
trash with nuclear medicine contamination, and set the baseline of the 
detector at 10x background and stopped "discovering" this problem.  All was 
fine for years until a different agency took over, set the meter at 3x 
background, and this "problem" occurred again.
     
The problem is not the patients.  It is foolish regulators who set limits 
that are irrational, and cause all sorts of silly "problems" as a result. 
Today, we have portable spectrometers and can even relay spectrometry 
information to anyone with an identification program.  We could solve this 
"problem" with state-of-the-art technology and good scientific sense. 
Hello?  NRC?  Is anyone home?  Is this going to be the basis for the new 
solid waste regs, or is it going to be another negotiated settlement with 
antinuke hysterical liars?
     
Ciao, Carol
     
Carol S. Marcus, Ph.D., M.D.
<csmarcus@ucla.edu>
     
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