U.S. Nuclear Regulatory Commission

Technical Assistance Request Dated September 11, 1992, Regarding the University of Pittsburgh Incinerator Ash Disposal Request and New Information Applicable to August 6, 1991 TAR

HPPOS-285 PDR-9306180040

Title: Technical Assistance Request Dated September 11,

1992, Regarding the University of Pittsburgh Incinerator

Ash Disposal Request and New Information Applicable to

August 6, 1991 TAR

See the memorandum from J. E. Glenn to R. E. Bellamy dated

March 19, 1993. This memo responds to a technical

assistance request (TAR) from Region I, dated September 11,

1992, regarding the University of Pittsburgh incinerator

ash disposal request and new information applicable to a

TAR dated August 6, 1991. The latter TAR was written in

the context of 10 CFR 20.105, but it also applies to "new"

10 CFR 20.1302.

Regarding the incinerator ash disposal request, the

University of Pittsburgh proposes to use concentration

limits applicable only to water effluents, in its

procedures for disposing of the incinerator ash as

"ordinary ash." Although previously allowed by license

condition, the concentration limits are not necessarily

appropriate for disposal of incinerator ash. The Division

of Low-Level Waste Management and Decommissioning estimated

that its generic dose assessment for incinerator ash

disposal would be done by April 1993. Therefore, reply to

this portion of the TAR was withheld until completion of

the assessment.

Regarding review of new information applicable to a TAR

dated August 6, 1991, the following decisions apply.

First, the request for exemption from the posting

requirements of 10 CFR 35.205 (d) may be granted for

emergencies in patient units and critical care situations

where movement of the patient would compromise the health

of the patient. Second, the request for approval of the

higher limits of 10 CFR 20.105 (b) (1) and 20.105 (b) (2)

[or, at present, 10 CFR 20.1302 (b) (ii)] in unrestricted

areas surrounding the rooms of patients receiving

brachytherapy or radiopharmaceutical therapy with

iodine-131 does not provide sufficient information about

the tracking of patients in adjacent rooms, a system to

monitor radiation levels in those rooms, and patient

occupancy times, etc. Therefore, the region was advised to

request clarification of the tracking system and survey

procedures.

Regulatory references: 10 CFR 20.105, 10 CFR 20.1302, 10

CFR 35.205, License Conditions

Subject codes: 3.6, 9.0, 9.3

Applicability: Byproduct Material