ML19345H098
| ML19345H098 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1980 |
| From: | Miller V NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19345H095 | List: |
| References | |
| FOIA-81-105 NUDOCS 8104300490 | |
| Download: ML19345H098 (4) | |
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June 25, 1980 TO ALL MEDICAL AtiD ACADEMIC LICE?iSEES There are a number of steps licensees engaged in nuclear cedicine practice and bic edical research can take under 11RC rules to substantially reduce, and in some cases eliminate, the need to send radicactive waste to cc:reccial icw-level waste disposal facilities. By taking advantage of these alternatives and foilewing good waste management practices, licensees can often reduce the risk of having their programs iepacted through further curtailment of cc ercial waste dis:csal facilities.
Scce of the more i=0ortant steps that can be taken are to:
1.
Segregate radicactive waste from non-radioactive waste to reduce unnecessary voluce.
This simply recuires a little time and discipline in the laboratory.
2.
Hold waste with short-lived radionuclides in s:crage for decay to background levels, then discose of it in the ordinary trash. This procedure requires a license amenc ent. (See Enclosure 1 for infor=ation to be subc11tted with the amend:ent request).
3.
Release certain materials into the sanitary sewage system in accordance with 10 CFR Part 20.303. No license amendment is required but 10 CFR Par: 20.303 should be carefully reviewed to stay within limits.
Judicicus use of these three steos.can substantially reduce the volume of waste shipped to burial grounds.
Scre nuclear =edicine laboratories using only short-lived radienuclides can eliminate waste shi;;=ents.
Waste from biceedical research is generally sccewhat more cifficult to canage. Two of the =ost ceriaan problems are disposal of licuid scintillation counting waste (LSCW) and ani:al carcasses.
The most frequently used radioisotopes in both are tritium and carten-It.
LSCW presents a particularly troublesc=e problem due to the flarnability and toxicity of the solvents.
Discosal of LSCW has been given s:ecial consideration by NRC. The staff has investigated alternatives to managing nese wastes and the results have ceen cuclished in NUREG-0556.
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. Consideration should be given to dis::csal by incineration for LSCW and laboratory animals containing small amounts of tritium and carbon-14.
This method requires a license amendment; 10 CFR Part 20.305
'contains the provisions for incineration. identifies the information to be submitted with an amendment request for incineration.
There are other provisions in the regulations that cover waste disposal.
We have mentioned only the few that are most easily and commonly used.
Othar regulatory provisions include:
1.
Disposal by burial in soil in accordance with 10 CFR 20.304 (A proposed rule change is under consideration to delete this provision.
It will likely be replaced by a provision which requires specific approval by license amendment for burial).
2.
Release as effluents to unrestricted areas pursuant to 10 CFR Part 20.106.
In keeping with the ALARA concept, this method should nomally be used only for releases incident to the procedures involved.
We suggest that you review and consider alternatives to comerical land burial for the management of your low-level radioactive wasta.
Implementation of some of these alternatives may require an amendment to your license. Amendment requests should be submitted to the Material Licensing Branch through the use of normal channels. Specific licensing questions concerning r1UREG-0656 should be directed to the Material Licensing Branch (301) 427-4232.
Copies of the tiUREG-0656 may be obtained from the Division of Technical Information and Document Centrol, U.S. fluclear Regulatory Comission, Washington, D.C. 20555.
Sincerely, l
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4ateri Licensing Branch l
Division of Fuel' Cycle and Material Safety l
Enclosures:
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1.
Information to be submitted When Requesting Amendment to Dispose of Radioactive Waste by Cecay-In-Storage.
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2.
Information Required for Comission Approval of Treatment or Disposal by Incineration.
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Information to be Submitted When Requesting Amend.ent to Dispose l
of Radioactive Waste by Decay-In-Storage Method
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This is in reference to your request for information concerning authorization to dispose of radioactive waste via decay-in-storage.
In order to hpprove such an amendment request, we need the following information:
1.
Please submit a diagram of the area where the waste will be decayed-in-storage. Show the type, location, and thickness of shielding that you will have available in this area on your diagram.
Your storage area should be large enough to handle an accumulation of used Tc-99m generators as well as other solid waste.
Identify adjacent unrestricted areas located across the walls from the storage area and show that adequate steps have been taken to assure that radiation levels do not exceed the limits specified in 10 CFR 20.105 (enclosed).
2.
Describe your security measures for the decay-in-storage area.
3.
Confirm that radiation levels in this area will be surveyed and recorded at least weekly.
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4.
Describe your procedures for monitoring the waste to assure that it has decayed to background levels prior to disposal. As a minimum, your de-scription should include these points:
a.
Monitor the waste in a low background area.
b.
Monitor with a icw level GM type survey meter as appropriate for contamination surveys.
Use the most sensitive scale.
c.
Remove all shielding prior to monitoring.
d.
Maintain records of these surveys as required under 10 CFR 20.
5.
Note that decay-in-storage may not be a practical method of disposal for Tc-99m generators. These generators may contain long-lived radioisotopic contaminants.
If you intend to dispose of generators by this method, you should include procedures for segregating the generator columns so that they may be monitored separately.
Be certain to submit your amendment request in duplicate. Unless your institution is fee exempt, your request should be accompanied by the appropriate amendment fee.
Refer to 10 CFR 170.
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i INFORMATION REQUIRED FOR C0:0115510:1 APPROVAL. OF TREATMENT OR DISPOSAi. SY INCINEPATION Revised October 3, 1979 1.
State specifically the isotopes you wish to incinerate.
For each isotope listed, you should submit calculations de.nonstrating that air concentrations of the effluents at the stack are in accordance with the requirements of Section 20.106 of 10 CFR Part 20.
2.
Submit the characteristics of the incinerator such as height of the stack, height of and distance to buildings in the surrounding areas, rated airflcw of the incinerator in cubic feet per hour or similar units and its proximity to any air intake ducts.
3.
The gaseous effluent from the incinerator stack should not exceed the limits specified for air in Appendix B, Table II,10 CFR Part 20, when averaged over a twenty-four (24) hour period.
4.
In order to be in ccmpliance with the ALARA philosophy stated in Section 20.1(c) of 10 CFR Part 20, the gaseous effluent from the incinerator stack should be a fraction (approximately 10".) of the limits specified for air in Appendix B. Table II,10 CFR Part 20, when averaged over a one year period.
5.
Describe the method of measurement.or estimation of the concentration of radioactive material appearing in ash residue.
6.
Describe the procedures for handling and disposing of ash from the incinerator.
7.
Describe procedures to be followed to prevent overexposure of personnel during all phases of the operation, including instruction given to personnel handling the ccmbustibles and the ash.
8.
Submit evidence that all State and local regulations concerning incineration of radioactive material have been met,by your institution.
9.
State the maximum number of burns to be performed in any one week and the maximum number of burns per year.
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