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RE: Tritium Exit Signs



I know this is a very late response to this email.  I am wondering if other states have followed up on PA has done. 

At this site:

[PDF] December 20, 1999 The Honorable John D. Dingell Committee on ...File Format: PDF/Adobe Acrobat - View as HTML
Although NRC imposes no specific approval process for this ... use of the product itself, such as use of tritium in self-luminous watches, the use of ...
www.hsrd.ornl.gov/nrc/special/dingell.pdf - Similar pages 

There can be found the following discussion of relevant legal authority, which says to me that an opportunity to address this problem at the source is not being taken.  It's a 1999 letter from Dingell.

"The NRC has statutory responsibility for the protection of health and safety related to the use of source, byproduct, and special nuclear material under the Atomic Energy Act of 1954, as amended (AEA). The Commission's regulations that set standards for protection of the public against radiation appear in 10 CFR Part 20. These regulations limit the radiation exposure (or "dose") that a member of the public can receive from the operation and decommissioning of a NRC-licensed activity. The NRC has used public dose limits in Part 20 (§20.1301) to establish concentration values in Table 2 of Appendix B of Part 20 for radioactivity in gaseous and liquid releases from a nuclear facility to the environment. However, unlike the regulations applicable to gaseous and liquid releases from a licensed nuclear facility, there are currently no generally applicable standards in Part 20 governing releases of solid materials by licensees. As noted above, NRC is currently exploring the need for a standard in this area. At this time, however, NRC
generally addresses the release of solid material on a case-by-case basis using license conditions and existing regulatory guidance. In each case, material may be released from a licensed operation with the understanding and specific acknowledgment that the material may contain very low levels of radioactive material, but that the concentration of radioactive material is so small that its control through licensing for the protection of public health and safety is no longer necessary. This case-by-case approach is consistent with the Commission's general authority under the AEA to regulate material either through the issuance of specific license conditions or through the promulgation of generally applicable rules (e.g., §161b and §81 of the AEA of 1954, as amended). See SEC v. Chenery, 332 U.S. 194, 203 (1947)."  

I am also remembering that years ago there was a program - wish I could remember where it was - I think DOE and DOD. It was called Byproduct Utilization Program, BUP - and later they changed it to something like ART.  To solve this problem it seems to me we should ask if there are stricter limits we should place on the shipments by our nuclear facilities of byproducts for use in manufacturing.  "Radioactive source" source reduction.

In my state, there are state regulations that limit the amount that can be discharged at any one time.  However, the problem with these things is their cumulative uptake and persistence.  So a discharge limit is not good enough.  Does anyone have any more recent information to add on this?

-----Original Message-----
From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On Behalf Of Illig, Richard
Sent: Wednesday, June 28, 2006 1:16 PM
To: p2tech@great-lakes.net
Subject: Tritium Exit Signs

All,

The PADEP, Division of Radiation Protection, recently identified a problem with tritium-powered exit signs relative to landfill disposal.  It seems the tritium (encapsulated in glass) is escaping and contaminating treated water discharges.  Being an isotope of hydrogen, the tritium becomes the hydrogen in water and cannot be separated in a realistic fashion.  For more detailed information please see the following message from a co-worker....

Has anyone dealt with this issue in the past or is able to make suggestions that would help eliminate/minimize this problem?  One concern is the problem will grow with the emphasis on low and no-energy technologies.  I am suggesting working with recyclers, green purchasing groups, and related efforts.

	...I recently gave a presentation on the subject of the improper disposal of tritium emergency exit signs and what we (DEP) can do to educate businesses and industries regarding their proper and lawful disposal. It is our opinion that these licensed radioactive devices are being improperly disposed of in solid waste landfills within the Commonwealth. Recent studies performed by our bureau indicate elevated concentrations of tritium in landfill effluents. BRP has worked with the Bureau of Air Quality, Field Services, and the Bureau of Waste Management to access all opportunities available to communicate with businesses involved with the use and transfer of these signs. I was told about your program, the Site Visit Program, last week and would like to provide you with information regarding this issue and request your programs assistance in communicating with businesses and industry regarding their responsibility for proper disposal of the tritium exit signs. We have created Fact Sheets which can be used for this purpose. If possible, please respond with your advice on how to proceed with this request. I have attached the Tritium Exit Sign Owner Responsibilities Fact Sheet for your review. Additional information can also be found on the web at <http://www.dep.state.pa.us/dep/deputate/airwaste/rp/Radiation_Control_Division/solidwastemonitoring/SolidWasteRadMonitoringFactSheets.htm>

Sincerely, Ric

Richard Illig
Program Specialist
PA Dept. of Environmental Protection
Office of Energy & Technology Deployment
717-772-5834 





 
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P2TECH is hosted by the Great Lakes Information Network:
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with the command 'unsubscribe p2tech' in the body of your message. No
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A map of P2TECH subscribers can be viewed at http://www.frappr.com/p2tech.

This list is managed by the Great Lakes Regional Pollution
Prevention Roundtable (http://www.glrppr.org), part of the
P2Rx national network of regional P2 information centers
(http://www.p2rx.org ).