ML20056C051
| ML20056C051 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/1992 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Asarch K DIAGNOSTIC PRODUCTS CORP. |
| Shared Package | |
| ML20056C052 | List: |
| References | |
| HPPOS-300, NUDOCS 9207080282 | |
| Download: ML20056C051 (2) | |
Text
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5s Diagnostic Products Corporation ATTN:
Kenneth B. Asarch, Pharm.D.,Ph.D.
Director of Regulatory Affairs 5700 West 96th Street Los Angeles, CA 90045 RE:
LETTER DATED MAY 20, 1992 REGARDING ALTERNATIVE METHOD OF DISPOSAL FOR CONTAMINATED PLASTIC TEST TUBES
Dear Dr. Asarch,
This responds to your letter dated May-20,1992 to E. William Brach which requested that Nuclear Regulatory Commission provide a written position on:
- 1) The proposed technique for decontamination and disposal of radioactively contaminated test tubes, and
- 2) Whether there is a specific requirement for NRC licensees to obtain NRC approval of this disposal method pursuant to 10 CFR 20.302.
The method outlined in the letter is currently used by many of NRC's licensees. The test tubes are disposed as normal trash by licensees, following an adequate radiation survey as required by 10 L ' 20.201(b).
Regarding request (1) above, it is NRC's position that each licensee must make an adequate survey of trash prior to disposal.
If the trash is not known to contain radioactive material and its radiation exposure levels are not distinguishable from background, it may be disposed without regard to radioactive material disposal procedures. This would be the case with test tubesthaparedecontaminated(e.g.,washedinbleach)andsurveyedpriorto disposal Licensees are required by 10 CFR 20.201(b) to make surveys that are
" reasonable under the circumstances to evaluate the extent of radiation
' hazards that may be present." A licensee must be able to demonstrate to NRC inspectors that the method of survey used is capable of detecting the presence of radioactive material in the test tubes.
If a licensee surveys bulk groups or random samples of the test tubes, rather than each single test tube, then the licensee must be able to demonstrate that their survey method is sufficient to detect all radioactive material prior to disposal. Preferably, licensees will document their tests to demonstrate survey adequacy.
' Note that waste held for decay-in-storage does not meet these criteria, as it is already known to contain radioactive material.
Decay-in-sturage waste must be held for the length of time specified in the license condition or in the regulations, which is generally 10 half-lives.
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g NRC licensees are currently allowed to dispose of liquid effluents pursuant to 10 CFR 20.303, and if the test tubes are no longer contaminated, there are no controls on their disposal.
Therefore, regarding request (2), it would not be necessary to obtain NRC approval for a practice specifically allowed by the regulations.
On January 1, 1994, the revised Part 20 becomes effective for all licensees.
At that time, 10 CFR 20.2003 will limit disposal of licensed material into-the sanitary sewer system. The limiting value for monthly average concentrations for releases to sewers, listed in Table 3 of Appendix B to the revised Part '20, is 2 x 10'5 microcuries per milliliter for iodine-125, assuming that iodine-125 is the only radionuclide released into the sanitary sewers.
The comparable limit is 4 x 10'5 microcuries per milliliter for release of soluble iodine-125 in the current Part 20. When a licensee implements the revised Part 20, the allowable release concentration drops by a factor of two.
Regardless of how the test tubes are disposed, any releases of licensed material into the sanitary sewer system must meet the requirements of 10 CFR 20.303 now, and 10 CFR 20,2003 after the revised Part 20 is implemented.
If you have any questions regarding the above matter, please contact Jim Smith at (301) 504-2613.
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$retMS Scy Richard E. Cunningham, Director Olvision of Industrial and Medical Nuclear Safety, NMSS DISTRIBUTION:
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