ML20138P254

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Forwards in 81-32, Transfer & Disposal of Spent Generators. W/List of Info Notice Issued Between 810804- 811008
ML20138P254
Person / Time
Issue date: 10/23/1981
From: Seyfrit K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
FITZSIMONS ARMY MEDICAL CENTER, AURORA, CO
Shared Package
ML17354B291 List:
References
FOIA-96-395 IEIN-81-32, NUDOCS 9703040148
Download: ML20138P254 (1)


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- UNITED STATES o NUCLEAR REGULATORY COMMISSION

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[. Amuscrow. texas ve0i1 October 23, 1981

' ARMY, DEPART 5ENT . 0F THE NRC LIC. #: 05-00046-13 FITZSIMONS ~ABEY MEEICAL CENTZli ANE EENVfR .' CC 8024C Gentlemen:

The enclosed Infomation' Notice'is forwarded to 'you for information. If-t there are any questions related to the subject, please contact th'is office. A

- copy ha:; been sent to the major manufacturers / suppliers of generators.

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" Q ( (' ..h p wi Karl V. Seyfrit . '/ , ' ,

d Director j l

Enclosures:

1. . IE Infomation Notice No. 81-32 l
2. Recently Issued IE Information Notices  ;

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970304014e 970220 PDR FatA

,OLA,DE96-395 PDR ,

SSINS No.: 6830 Accession No.:

8103300409 IN 81-32 UNITED STATES NUCLEAR REGULATORY ComISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 October 23, 1981 IE INFORMATION NOTICE NO. 81-32: TRANSFER AND/OR DISPOSAL OF SPENT GENERATORS i

Description'of Circumstances:

Upon responding to a complaint recently from a private citizen, local police discovered boxes labeled as radioactive materials on the driveway of a private residence. Subsequent investigation by NRC revealed that the boxes contained eleven used molybdenum-99/ technetium-99m (Mo-99/Tc-99m) generators manufactured by a major supplier of radiopharmaceuticals. Four of the generators had intact lead shielding, and seven generators had no lead shielding. The occupant of the residence w~ as later identified as a ',ubcontractor of the transporting company which has a contract with the major supplier to deliver new generators to, and pick up spent generators from, medical institutions. According to this individual, these spent generators had been given to him for temporary storage, and he had removed lead shielding from some of them for sale. Apparently, many drivers routinely store spent generators at their residences for indefinite periods, and return them to the contractors of the transporting companies only when they are ready to pick up new generators for delivery. NRC inspectors have encountered other situations where recovery of lead shielding from generators apparently h d taken place.

Average exposure rates measured on these generators were approximately 25 mR/hr at contact and 2 mR/hr at 3 feet. Based on information included on the generator labels, the generators were estimated to contain, at the maximum, a total of 43 millicuries of Mo-99 on the day of the inv9stigation. Assuming that 5 mci of Mo-99 remains on a generator column and that 10 seconds are required to handle the column and to separate both internal ant. external layers of the lead shielding, a person could typically receive a dose of roughly 25 mrem to the hcnds from dismantling such a generator.

Caution to Licensees - Users of Generators:

You should note the following if you are involved in the receipt, possession, use, and transfer of these generators:

1. Your NRC license should cont'ain specific procudures for disposing of j spent generators (e.g., return to supplier, etc.). You are also reminded '

of the letter dated June 4, 1981 from the'NRC Material Licensing Branch to all gedical licensees. As stated in this letter, a condition authorizing decay-in-storage of certain, radioacti've materials, including

l IN 81-32 IN 81-32 October 23, 1981 Page 2 of 3 generators, would be automatically placed in new licrosas issued, or added to existing licenses in response to re,ewal requests You were also informed in this letter that you have the option of submitting an amendment request should you desire to add this condition to your license immediately.

The proper way to store spent generators for decay and subsequent disposal is to segregate the generator columns and monitor them separately prior to disposal to ensure decay to background levels. Necessary precautions (e.g.,

use of disposable gloves) should be taken to avoid hand contamination.

If the columns are held for decay to background levels, there are no special requirements on disposal except for appropriate surveys to verify total decay, records of the surveys, and defacing or removal of labels on the devices. Any surveys should include the lead shielding. If no contamination is present on the shielding they may be disposed of as normal (non-radioactive) waste.

When storing spent generators for decay and disposal, you must comply with )

the requirements of 10 CFR 20.105 (Permissible levels of radiation i in unrestricted areas) and 10 CFR 20.207 (Storage and control of licensed I materials in unrestricted areas), and 10 CFR 20.203 (posting and labeling )

requirements).

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2. Until verification surveys determine that no radioactivity remains, these spent generators must be treated as licensed material. None of the exemptions in Part 30 would apply. Any person possessing these items (for the purposes of lead recovery or wasta disposal, for instance) would be required to have an NRC license. Any transfer to a person without a license is an unauthor- 1 ized transfer. The only exception would be the delivery of a properly I packaged and labeled item to a common or contract carrier for expeditious transport to an authorized recipient.
3. 10 CFR 30.41 (b)(5) requires that licensed material be transferred only to a person who is generally or specifically licensed by NRC or one of the Agreement States" to receive the material. You should ensure that when transferring spent generators back to the supplier, the common or contract carrier' transporting the generators is fully aware that any operations with or use of the material, other than the actual transport or storage incident thereto, is not authorized. Upon delivery of the generators to the carrier for transport, you are urged to provide specific instructions on the shipping papers, indicating that the generators are to be delivered to the consignee without unnecessary delay, are not to be stored in unauthorized locations, and.should not be dismantled or used by unauthorized persons. As an additional precaution, it would be judicious  ;

3 to estylish a routine point-of-contact with the supplier to inform him of the hrriers being used, and to ask for the supplier's cooperation in reporting to you any apparent instances of improper actions, such as unauthorized lead removal activities.

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IN 81-32 October 23, 1981

Page 3 of 3
4. The generator supplier may have provided instructions in the package inserts regarding proper, safe and legal packaging and transport of generators. If you do not already have these instructions or are unfamiliar with them, contact the supplier's representative immediately.
5. The instructions described in item 4 above may also apply to instances during which defective generators need to be shipped back to the manufacturer.

No written response to this information notice is required. If you need additional information with regard to this matter, contact the appropriate NRC regional office.

Attachment:

Recently issued IE Information Notices 1

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Attachment IN 81-32

, October 23, 1981 RECENTLY ISSUED IE INFORMATION NOTICES Information

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Date of Notice No. Subject Issue Issued to 81-31 Failure of Safety Infection 10/8/81 All power reactor Valves to Operate Against facilities with an Differential Pressure OL or CP 81-30 Valan Swing Check Valves 9/28/81 All power reactor facilities with an OL or CP 81-29 Equipment Qualification 9/23/81 All power reactor Testing Experience facilities with an OL or CP 81-28 Failure of Rockweli-Edward 9/3/81 All power reactor .,

Main Steam Isolation Valves facilities with an OL or CP l 81-27 Flammable Gas Mixtures 9/3/81 All power reactor in the Wasta Gas Decay facilities with an Tanks in PWR Plants OL or CP 81-26 Compilation of Health 9/3/81 All power reactor Physics Related Information facilities with an Items OL or CP 81-25 Open Equalizing Valve 8/21/81 All power reactor of Differential Pressure facilities with an )

Transmitter Causes Reactor OL or CP Scram and Loss of Redundant l Safety Signals 81-24 Auxiliary Feed Pump 8/5/81 All power reactor Turbine Bearing Failures facilities with an OL or CP 81-23 Fuel Assembly Damaged 8/4/81 All power reactor due to Improper Positioning facilities with an  ?

of Handling Equipment OL or CP l

1 OL = Operating License l CP = Construgtion Permit '

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