ML20057C530
| ML20057C530 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1993 |
| From: | Dennise Orlando NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Chadzynski L MICHIGAN, STATE OF |
| References | |
| REF-WM-3 NUDOCS 9309290076 | |
| Download: ML20057C530 (2) | |
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UNITED STATES 5'
NUCLEAR REGULATORY COMMISSION
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SEP 161993' j
l Mr. Lawrence Chadzynski, M.P.H.
Environmental Quality Specialist i
Medical Waste Regulatory Program Division of Environmental Health i
Bureau of Environmental and Occupational Health Department of Public Health 3423 N. Logan / Martin L. King Jr. Blvd.
(
P.O. Box 30195
\\
Lansing, MI 48909
Dear Mr. Chadzynski:
I am writing in response to your August 24, 1993 letter in which you requested l
Nuclear Pegulatory Commission approval of a response to Mr. George Kreick of \\
Parke Davis regarding the point at which the storage limitations under Michigan's Medical Waste Regulatory Act would become effective.
Per your-1 proposed letter, you indicated that it would be acceptable for a facility generating radioactive medical waste to hold the waste, in accordance with NRC l
regulations until the radioactivity decayed to background levels. At this point Michigan's 90-day storage limitation on the regulated medical waste would begin.
l NRC staff has reviewed your proposed letter to Mr. Kreick and has no objection i
to the response, as it pertains to the management of radioactive material.
However, you should be aware that NRC regulations governing the medical use of byproduct material at 10 CFR Part 35.92 only allow decay-in-storage of radionuclides with half-lives of 65 days or less unless this regulation is superseded by a license condition allowing otherwise.
In addition, the facility holding the waste for decay-in-storage must determine that the l
radioactivity in the waste cannot be distinguished from background levels i
using an appropriate monitoring technique and that any radiation labels are removed or obliterated prior to releasing the waste as non-radioactive waste.
]
Recently, NRC has been informed of several instances where radioactive j
material has been detected in waste by municipal solid waste disposal facilities.
In many cases this material was generated at medical facilities, i
and although the facility allowed the material to decay prior to releasing it i
as non-radioactive waste, the facility either did not monitor the material adequately (e.g., improper monitoring procedures or inadequate monitoring equipment) or the disposal facility used radiation monitors that were more sensitive than those used by the medical facility. As such,' it may be useful to emphasize to Mr. Kreick that the medical facility is responsible for ensuring that the radioactive material has decayed to background levels and that the radiation labels are removed or obliterated prior to releasing the waste as non-radioactive waste. This could be accomplished by inserting the
, 9 following sentence between the first and second sentences of the fourth i
paragraph:
"These regulations require, among other things, that prior to-4 releasing the waste as non-radioactive waste, facilities authorized to holdm.p, y
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radioactive waste for decay-in-storage must ensure the waste has decayed to background levels and that all radiation labels have been removed or i
obliterated."
i I hope this adequately responds to your request.
If you have any question, please contact me at (301) 504-2566.
Sincerely, Odprai9 grad B/
Dominick A. Orlando, Project Manager Decommissioning and Regulatory Issues Branch Division of Low-Lev 21 Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Ticket 0-0049 DISTRIBUTION:
Central ~ File NMSS r/f JGreeves PLohaus JSurmeier JAustin MBell TJohnson LLWM r/f 76 te e guc=w, %E SUBJECT ABSTRACT: RESPONSE TO REQUEST FORM MICHIGAN REGARDING DECAY-IN-STORAGE OF MEDICAL WASTE
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