Information Notice 1997-03, Defacing of Labels to Comply with 10 CFR 20.1904(b)

Defacing of Labels to Comply with 10 CFR 20.1904(b)

ML031210429
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	02/20/1997
From:	Cool D NRC/NMSS/IMNS
To:
References
IN-97-003, NUDOCS 9702130063
Download: ML031210429 (6)

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 February 20, 1997 NRC INFORMATION NOTICE 97-03: DEFACING OF LABELS TO COMPLY WITH

10 CFR 20.1904(b)

Addressees

All material licensees involved with disposal of medical waste.

Purgose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert

addressees to an issue involved with the defacing of labels, to comply with

10 CFR 20.1904(b). It is expected that recipients will review the information for

applicability to their facilities and consider actions, as appropriate, to avoid similar

problems. However, suggestions contained in this information notice are not NRC

requirements; therefore, no specific action nor written response is required.

DescriDtion of Circumstances

Section 20.1904(b) of 10 CFR Part 20 requires licensees to remove or deface radioactive

material labels, or otherwise clearly indicate that the containers no longer contain

radioactive material, before disposing of them as non-radioactive waste. NRC became

aware of the disposal of used syringes/needles that had been held for decay-in-storage, without licensees removing or defacing the radioactive material labels or otherwise

indicating that the containers no longer contained radioactive material. In this situation, licensees had placed used syringes/needles into opaque plastic inserts, which had then

been capped and placed inside unit dose shields. Used syringes/needles are considered

both biohazardous and radioactive waste. The sealed plastic inserts are placed into waste

barrels, along with other radioactive waste, for decay-in-storage. The barrels are sealed

and labeled with radioactive material labels and held for 10 half-lives for decay and surveys

prior to disposal. Although the waste is no longer considered radioactive, it is still

biohazardous. The sealed barrels' radioactive material labels are defaced, and then the

barrels are disposed of as biohazardous waste by incineration.

Discussion

The radioactive material labels on the used syringes/needles cannot-be defaced without

opening the waste barrels and the plastic inserts, actions that would expose employees to

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-, -IN 97-03 February 20, 1997 the risk of injury from the needles. Additionally, these actions would place licensees in

violation of the Occupational Safety and Health Administration regulation 29 CFR

1910.1030(d)(1),which requires precautions to prevent contact with blood or other

potentially infectious materials, including recommendations not to manipulate used

syringes/needles by hand. The 'Statements of Consideration' for 10 CFR 20.1 904(b)

indicate that the rule only applies to Ovisible" labels, and that when compliance with the

regulations is not feasible, other methods are acceptable. Such methods include placing

placards or labels with the word "empty" on the containers, or compacting the waste, provided that there are no visible labels remaining. Incineration would be another means of

ensuring that there are no visible labels remaining. The "Statements of Consideration" also

indicate that the rule primarily pertains to shipping and other outer containers that do not

ordinarily contain radioactive materials in and of themselves, but serve as secondary

barriers.

If licensees determine that waste disposal procedures are needed to address defacing of

labels to comply with 10 CFR 20.1904(b), the procedures must ensure that no visible

labels remain before transfer for disposal. In one case, a nuclear pharmacy licensee

proposed, and NRC approved, the following procedure for disposing used syringes/needles

without defacing the radioactive material labels on the used syringes/needles:

1. The radioactive material labels visible on the outer waste barrels/containers will

be defaced or removed before transfer to the waste disposal firm;

2. Waste barrels are sealed before delivery to the waste disposal firm;

3. Waste barrels/containers will be delivered directly from the licensee's facility to

a waste disposal firm for disposal;

4. Medical waste is incinerated, end not sent to a medical waste landfill; and

5. The waste disposal firm will be notified that the barrels must not be opened at

any point, and for any reason, before incineration.

Licensees must continue to comply with the waste disposal procedures described in 10

CFR 35.92, or equivalent disposal procedures for non-medical licensees.

4

I -_ IN 97-03 February 20, 1997 This information notice requires no specific action nor written response. If you have

additional questions about the information in this notice, please contact the technical

contact listed below or the appropriate regional office.

Donald A. C ol, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical contact: Sally L. Merchant, NMSS

(301) 415-7874 E-mail: slm2@nrc.gov

Attachments:

1. List of Recently Issued NMSS Information Notices

2. List of Recently Issued NRC Information Notices

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Attachment 1

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IN 97-03 February 20, 1997 LIST OF RECENTLY ISSUED

NMSS INFORMATION NOTICES

Information

Date of

Notice No. Subject Issuance Issued to

96-72 Undetected Failures that May 12/24/96 All teletherapy licensees

Occur During Patient Treat- ments with Teletherapy

Devices

96-70 Year 2000 Effect on Computer 12/24/96 All U.S. Nuclear Regulatory

System Software Commission licensees, certi- ficate holders, and regis- trants

96-66 Recent Misadministrations 12/13/96 All U.S. Nuclear Regulatory

Caused by Incorrect Cali- Commission Medical Use

brations of Strontium-90 Licensees authorized to use

Eye Applicators strontium-90 eye applicators

96-63 Potential Safety Issue 12/05/96 All U.S. Nuclear Regulatory

Regarding the Shipment Commission licensees

of Fissile Material authorized to possess special

nuclear material in unsealed

quantities greater than a

critical mass

96-57 Incident-Reporting Require- 10/30/96 All U.S. Nuclear Regulatory

ments Involving Intakes, Commission licensees

During a 24-Hour Period

that May Cause a Total

Effective Dose Equivalent

in Excess of 0.05 Sv (5 rem)

96-54 Vulnerability of Stainless 10/17/96 All material licensees

Steel to Corrosion When

Sensitized

96-53 Retrofit to Amersham 660 10/15/96 All industrial radiography

Posilock Radiography licensees

Camera to Correct Incon- sistency in 10 CFR Part 34 Compatibility

. V

Attachment 2 IN 97-03 February 20, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

97-02 Cracks Found in Jet Pump 02/06/97 All holders of OLs

Riser Assembly Elbows at or CPs for boiling

Boiling Water Reactors water nuclear power

reactors models 3,

4, 5 and 6, except

those licenses that

have been amended to

possession-only

status

97-01 Improper Electrical Ground- 01/08/97 All holders of OLs

ing Results in Simultaneous or CPs for nuclear

Fires in the Control Room power reactors

and the Safe-Shutdown Equip- ment Room

96-72 Undetected Failure that 12/24/96 All teletherapy

May Occur During Patient licensees

Treatments with Teletherapy

Devices

96-71 Licensee Response to Indi- 12/27/96 All holders of OLs

cations of Tampering, Van- or CPs for nuclear

dalism, or Malicious Mis- power reactors

chief

OL = Operating License

CP = Construction Permit

- v IN 97-03 II February 20, 1997 This information notice requires no specific action nor written response. If you have

additional questions about the information in this notice, please contact the technical

contact listed below or the appropriate regional office.

Donald A. Cool, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical contact: Sally L. Merchant, NMSS

(301) 415-7874 E-mail: sIm2@nrc.gov

Attachments:

1. List of Recently Issued NMSS Information Notices

2. List of Recently Issued NRC Information Notices

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NAME ( TTaylor JiLMerchant rLWCamper STtreby* EKraus- DATE 1/24/97 1/28/97 1/28/97 11/21/96 12/9/9 e

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DATE 11/31/97