U.S. Nuclear Regulatory Commission

Letter Dated May 20, 1992, Regarding Alternative Method of Disposal for Contaminated Plastic Test Tubes

HPPOS-300 PDR-9306220335

Title: Letter Dated May 20, 1992, Regarding Alternative

Method of Disposal for Contaminated Plastic Test Tubes

See the letter from R. E. Cunningham to K. B. Asarch

(Diagnostic Products Corporation) dated June 26, 1992. The

letter responds to a request that the NRC provide a written

position on: (1) the licensee's proposed method 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 [or, at present, 10 CFR

20.2003].

It is the NRC's position that each licensee must make an

adequate survey of trash prior to disposal as required by

10 CFR 20.201 (b) [or, at present, 10 CFR 20.1501 (a) (2)].

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 (i.e., ordinary or

non-radioactive trash). This would be the case with test

tubes that are decontaminated (such as washed with bleach)

and surveyed prior to disposal. This does not apply for

decay-in-storage wastes as it is already known to contain

radioactive material. Decay-in-storage waste must be held

for the length of time specified in the license condition

or in the regulations (generally 10 half-lives).

Licensees are required by 10 CFR 20.201 (b) [or 10 CFR

20.1501 (a) (2)] 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 survey bulk

groups of 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.

Licensees are currently allowed to dispose of liquid

effluents pursuant to 10 CFR 20.303 [or 10 CFR 20.2003],

and if the test tubes are no longer contaminated, there are

no controls on their disposal. Therefore, regarding the

second request, it would not be necessary to obtain NRC

approval for a practice specifically allowed by the

regulations.

On January 1, 1994, the revised 10 CFR 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 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 the current 10 CFR 20.303 or 10 CFR

20.2003 after implementation of the revised 10 CFR Part 20.

Regulatory references: 10 CFR 20.201, 10 CFR 20.303, 10

CFR 20.1501, 10 CFR 20.2003

Subject codes: 9.0, 9.2, 9.7

Applicability: Byproduct Material