Integrated Environmental Management, Inc. (IEM)

Radiation Monitoring & Action Plan

0
In December of 2000, the Pennsylvania Department of Environmental Protection (PaDEP) promulgated regulations requiring monitoring for radiation and radioactive materials (25 Pa. Code 273, 277, 279, 281, 283, 284, 288, 289, 293, 295 and 297). The State has also prepared a companion guidance document,'Final Guidance Document on Radioactivity Monitoring at Solid Waste Processing and Disposal Facilities' (PaDEP Document Number: 250-3100-001). While your facility may not intentionally receive or treat radioactivity as part of your in-house operations, if you are classified as one of the following, you may nonetheless be required to comply with the new State rules:

  • Municipal/construction/demolition waste landfills (25 Pa. Code Ch. 273 and 277)
  • Resource recovery and municipal waste transfer or reprocessing facilities (25 Pa. Code Ch. 279 and 283)
  • Commercial municipal waste composting facilities that receive sewage sludge or unseparated municipal waste, or both (25 Pa. Code Ch. 281)
  • Commercial infectious or chemotherapeutic waste processing facilities (25 Pa. Code Ch. 284)
  • Noncaptive residual waste landfills, disposal impoundments, transfer facilities, composting facilities, incinerators, or other noncaptive processing facilities (25 Pa. Code Ch. 288, 289, 293, 295 and 297)

A number of lEM's clients (i.e., recycling firms, solid waste facilities, materials processors, etc.) have already been advised by the PaDEP that they must (1) screen incoming loads for the presence of radioactivity, and (2) have a PaDEP-approved 'Radiation Monitoring and Action Plan' for their waste or recycling streams ... and we are hearing from more of them every day!

For your information, a 'Radiation Monitoring and Action Plan' required by the State must contain several sections. These include but are not limited to the following:

  • Management Responsibilities
  • Radiation Detection Equipment and Initial Procedure
  • Designated Storage Area
  • Action Levels
  • Follow-Up Actions
  • Determination of Origin
  • Disposition and/or Storage of radioactive material
  • Training for facility staff
  • Procedures for surveying
  • Posting suspect containers
  • Program Oversight
  • Periodic Plan Review and Update
  • Records of surveys

However, as with most regulator-mandated activities, there is usually more than one way of achieving the necessary level of compliance without expending any more resources than are absolutely necessary. For example, many facilities have purchased, installed and are maintaining some fairly expensive radiation detection equipment at their entrance gates as part of their own 'Radiation Monitoring and Action Plan'. In some cases, this level of oversight is warranted due to the volumes and types of materials that are being received and handled. However, most facilities within the State have no need for such a comprehensive approach. They would be much better served by the use of small-scale equipment an easy-to-implement procedures.

If your facility is located in Pennsylvania and you are required to prepare such a 'Radiation Monitoring and Action Plan* - but you are looking to keep the cost of the entire process to a practical minimum! - we hope you will consider contacting IEM. Because we have already prepared 'Radiation Monitoring and Action Plans' for a number of Pennsylvania facilities, including equipping them with the necessary instrumentation and training their employees in what needs to be done to stay within the letter of the law, we are able to do the same for others in a highly cost-effective manner. All we would need from you is a description of your operation and the types of materials you typically receive. (If you have written acceptance criteria for these materials in place that you give to your suppliers, all the better!) From there we will prepare a 'Radiation Monitoring and Action Plan' that is appropriate for the scale of your operations, and make sure you understand why and how each step is performed. We will also assist you in resolving any issues raised by the PaDEP during the approval process.

However, if your facility is not located in Pennsylvania but you nonetheless have concerns about inadvertently receiving unwanted radioactive materials from others, a 'Radiation Monitoring and Action Plan' might be just the ticket for you as well.  In your case, IEM would focus on guidance promulgated by your own State agency as input to your plan, along with standard industry monitoring and recording practices, and proven cost control methods as we address your needs.

If you are considering lEM's 'Radiation Monitoring and Action Plan' special service, simply Contact Us. An IEM Certified Health Physicist will work with you to provide you with a firm, fixed price for taking care of this problem for you - in its entirety. There is, of course, no cost or obligation once we deliver our proposal to you ... but when you compare what IEM offers to the cost and effort of completing the work using in-house resources, we think you will be pleasantly surprised.

Customer reviews

No reviews were found for Radiation Monitoring & Action Plan. Be the first to review!