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

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

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