DCHAS-L Archives, Nov 19 2015 - Re: [DCHAS-L] Disposal Beryllium Tubes

Hello All,

Here is the input from Radiation Safety officer and Environmental Engineer of NIST, Boulder Laboratories:

From: "Grove, Thomas W" <touche**At_Symbol_Here**nist.gov>
Subject: Re: Disposal of X-Ray system components
Date: November 19, 2015 at 6:19:40 AM MST
To: Ranajit Talukdar <ranajit.k.talukdar**At_Symbol_Here**noaa.gov>, "Grove, Thomas W" <touche**At_Symbol_Here**nist.gov>
Cc: "Garrity, David" <david.garrity**At_Symbol_Here**nist.gov>, "Brass, Brian" <brian.brass**At_Symbol_Here**nist.gov>

Good morning; thanks for the additional info.

Since Stony Brook is located in NY, that state regulates x-ray machines. Their process is similar, including the paperwork.

Their x-ray website: www.health.ny.gov/environmental/radiological/radon/registration.htm

I would strongly urge your colleague to contact the Stony Brook Radiation Safety officer to ensure full compliance with all regulations and policies. They have two RSOs; this is the phone number for Sean Harling 631-632-9676.

If you need further help, let me know. Keep me informed on the outcome!
On: 18 November 2015 16:31, "Ranajit Talukdar" <ranajit.k.talukdar**At_Symbol_Here**noaa.gov> wrote:
Hello Thomas,
Thank you for your time. This was regarding a query from Stony Brook University. I am a ACS member and also a ASR in CSD. Stony Brook University person wanted to get rid of the old X-ray equipment, which is equipped with Be window. She was worried about the toxicity of Be rather than other part X-ray tube. I will follow up and forward your mail with a copy to involved in the email with your permission of course. Information you provided is extremely helpful and a learning experience for all.
Let me if I can forward your email or just the information text?
Thanks a lot

Ranajit

Ranajit Talukdar, Ph.D.
Research Scientist
CSD Area Safety Representative
NOAA/ESRL, Chemical Sciences Division
R/CSD 5, DSRC/ 1A129
325 Broadway
Boulder CO 80305-3328
Phone: 303 497 5825
FAX: 303 497 5340
email: Ranajit.K.Talukdar**At_Symbol_Here**noaa.gov

On Nov 18, 2015, at 8:14 AM, Grove, Thomas W <touche**At_Symbol_Here**nist.gov> wrote:

Good morning, I will be glad to help based upon what I know regarding your circumstances.

I adopted the disposition system that Colorado uses as a means of due diligence which should minimize the chance of accidental exposures and the chance that unqualified personnel could operate the equipment.

See the following link for the form used to dispose of x-ray equipment: https://www.colorado.gov/pacific/sites/default/files/HM_xrayform-R-61-final-disposition.pdf

As you can see, if you are merely using a 3^rd party to transfer the equipment, then you provide contact information for the 3rd party.

If the intent is to dispose of the equipment directly as waste, then the machine must be made physically inoperable by dismantling the electrical circuitry such that the machine is not capable of producing radiation. Registrant must provide information on the method of disposal and the name and address of the landfill or recycling company. Please note that x-ray machines are considered electronic waste and must be disposed of properly.

If you need additional help, please call me. If you want further clarification on the disposal you can call the State; 303-692-3448 (Christine Irving, she has been there for a few decades). If she is unavailable, try her boss, Brian Vamvakias, at 303-692-3427.

Safety Ethic-Pass it On
I value safety
I accept responsibility for safety
I work safely
I prevent at-risk behavior
I promote safety

Tom Grove, NRRPT
Radiation Safety Officer, NIST-Boulder
National Institute of Standards and Technology (NIST)
325 Broadway, Mailcode 173.02
Boulder, CO 80305

Boulder, Safety, Health, and Environment Division
Building 1, Room 4001B

303-497-6540 (office)
303-591-8074 (cell)
303-497-4196 (fax)

On Thu, Nov 19, 2015 at 8:01 AM, Wright, Mike <mwright**At_Symbol_Here**usw.org> wrote:

Thanks! Sadly, this kind of collaboration is all too rare, and we don't have the new standard yet. The trade association representing non-ferrous foundries has challenged most aspects of the proposed standard, and asked for a hearing, which will delay things further. The work that goes into a new OSHA health standard is incredible. Materion and the USW submitted our recommended standard in February 2012. OSHA - quite rightly - can't cede its rulemaking authority to any outside parties, but their proposal was pretty close to ours. However, the text of the proposed regulation is 29 pages long. The detailed analysis of health effects, feasibility, economics, and possible alternatives that OSHA finally published this August is 910 pages long. All of that was necessitated by Congress and the Courts. The Agency accepted public comments up until November 5. They now have the job of analyzing and responding to all those comments, plus anything raised at the hearing. At best the final standard is a year away. All this is why, in the 45 years since the OSH Act was passed, OSHA has promulgated only 23 new health standards.

Mike Wright

Michael J. Wright

Director of Health, Safety and Environment

United Steelworkers

412-562-2580 office

412-370-0105 cell

See us on the web at www.usw.org

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of Weeks Jr., Robert
Sent: Wednesday, November 18, 2015 9:40 AM

To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Disposal Beryllium Tubes

Mr. Wright;

This is super and is the way things should be. Congratulations to both the Steelworkers, Materion, and to OSHA.

Robert (Bob) Weeks, Ph.D., CIH

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of Wright, Mike
Sent: Wednesday, November 18, 2015 7:16 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Disposal Beryllium Tubes

Beryllium is transparent to most wavelengths of x-rays, so it is present in x-ray equipment in the form of x-ray windows. The best source for practical information on beryllium is Materion Brush, the only US producer of the pure metal, and the predominant supplier of beryllium alloys. They can go way beyond the regulatory information and give you good advice on the safety issues. In fact, the company has partnered with our union to advocate for a new, and much more protective OSHA standard. (And when's the last time you saw a company push for more stringent regulation of its major product?) The person to contact is Terry Civic:

Terence M. Civic
Director: Health, Safety and Regulatory Affairs
T - 216.383.3698
M - 216.870.9791
Terence.Civic**At_Symbol_Here**Materion.com

Michael J. Wright

Director of Health, Safety and Environment

United Steelworkers

412-562-2580 office

412-370-0105 cell

See us on the web at www.usw.org

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of Wayne Wood
Sent: Tuesday, November 17, 2015 11:46 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Disposal Beryllium Tubes

Before disposing of old x-ray machines be sure to verify the capacitors and transformers are free of PCB's.

W.

Wayne Wood | Director, Environmental Health and Safety - Directeur, Sante´, securite´ et environnement| McGill University | 3610 rue McTavish Street, 4th floor | Montreal, Quebec, Canada, H3A 1Y2 | Tel: (514) 398-2391

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of ranajit.k.talukdar**At_Symbol_Here**GMAIL.COM
Sent: Tuesday, November 17, 2015 10:56 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Disposal Beryllium Tubes

Hello All

If beryllium is in the powder form it is classified as hazardous waste and it should be disposed as hazardous waste. Since it is in a tube it should be disposed as hazardous waste as one disposes hazardous chemicals etc.

all the best

Ranajit Talukdar

NOAA Earth System Research Laboratory

Chemical Sciences Division

Boulder CO 80305

Sent from my iPhone

On Nov 16, 2015, at 12:55 PM, Sandhya Muralidharan <sandhya.muralidharan**At_Symbol_Here**STONYBROOK.EDU> wrote:

Dear All,

We are looking to dispose some old X-ray equipment at our institution.Are you aware of regulations governing beryllium disposal?

Regards,

Sandhya

--

Sandhya Muralidharan, PhD

Department of Chemistry

Stony Brook University

New York

email - sandhya.muralidharan**At_Symbol_Here**stonybrook.edu

Ranajit Talukdar
NOAA, ESRL, Chemical Sciences Division, R/CSD 5
325 Broadway
Boulder, CO 80305
USA
303-641-9001-cell
303-497-5825 - work

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