Information Notice No. 91-03: Management of Wastes Contaminated with Radioactive Materials ("Red Bag" Waste and Ordinary Trash)

                               UNITED STATES 
                              WASHINGTON, D.C.
                               January 7, 1991
                                   RADIOACTIVE MATERIALS ("RED BAG" WASTE 
                                   AND ORDINARY TRASH)
Addressees:  All medical licensees.
This information notice is intended to remind medical use licensees to 
carefully monitor all waste that may be contaminated with radioactive 
materials.  Waste management facilities not authorized to receive licensable 
radioactive materials are finding wastes contaminated with detectable levels 
of radioactive materials in waste shipments from hospitals. 
It is expected that licensees will distribute this information notice to the 
responsible radiation safety officer and other appropriate staff, review 
this information for application to their own programs for radioactive waste 
management, and consider actions, if appropriate, to prevent radioactive 
materials from inadvertently being included with nonradioactive waste 
shipments.  However, suggestions contained in this information notice do not 
constitute Nuclear Regulatory Commission (NRC) requirements; therefore, no 
specific action or written response is required.
Description of circumstances: 
A growing number of operators of landfills and medical waste incinerators 
are monitoring waste shipments, with certain preset detection levels on the 
monitors, for radioactivity.  In several cases, waste shipments from 
hospitals have contained radioactive materials, with radiation levels that 
exceeded the waste disposal operator's preset detection level.  In some 
cases, landfills or medical waste incinerators have rejected the shipments 
and returned them to the generators.  In general, landfills and medical 
waste incinerators are not authorized to receive or manage radioactive 
Case 1:  Incident involving a medical waste incinerator
Several shipments of biohazardous waste sent to a medical waste incinerator 
in the State of South Carolina contained detectable levels of radioactive 
materials.  South Carolina imposed civil penalties on the generators of the 
waste and prohibited shipments of radioactive wastes from these generators 
into South Carolina until such time as the generators can demonstrate 
compliance with applicable requirements and obtain the required permits. 
                                                            IN 91-03 
                                                            January 7, 1991 
                                                            Page 2 of 4 
Case 2:  Incident involving a medical waste incinerator
The Oklahoma Department of Health notified NRC that a package of medical 
waste received at a incinerator read 11 milliroentgens per hour at the 
package surface.  The Oklahoma Department of Health was notified in 
accordance with the incinerator's operating procedures, which required that 
nonradioactive waste shipments containing radioactive material be rejected.  
Because the truck was returning directly to Toronto, Canada, NRC advised the 
Oklahoma Department of Health to request that the incinerator personnel 
return the packages to the shipper.  The Oklahoma Department of Health 
confirmed that the medical waste was being returned to Canada. 
Case 3:  Incident involving a landfill
A licensee had three incidents involving the release of disposable diapers 
containing microcurie amounts of iodine-131 from diagnostic procedures.  The 
contaminated diapers triggered sodium iodide detectors at a commercial 
landfill.  In one of the incidents, the licensee realized that diapers 
containing iodine-131 had been placed in a dumpster.  The dumpster was fully 
loaded and retrieval of the diapers before the waste was sent to the 
landfill would have been very difficult.  Therefore, the licensee assigned a 
technician, with a GM detector, to monitor the shipment as it was being 
transported to the landfill and to detect the contaminated diapers as the 
dumpster was unloaded.  During unloading, the contaminated diapers were 
retrieved as planned.  Additionally, the licensee subsequently recovered all 
diapers contaminated with iodine-131 from the other two incidents.  The 
quantity of iodine-131 that was reportedly in the disposed diapers ranged 
from 150 to 290 microcuries. 
Case 4:  Incident involving a landfill
A State representative reported that iodine-131, originating from a 
hospital, was found at a county landfill.  The material was transferred back 
to the hospital by the State and placed in the hospital's waste storage 
area.  The material (urine containing 60 microcuries of iodine-131 from a 
diagnostic renal study) was contained within a collection bag from a 
catheter device and was inadvertently disposed of by the hospital staff.  
Surface radiation levels were found to be 3 milliroentgens per hour.  As a 
corrective action, the licensee installed sodium iodide detectors to monitor 
all wastes leaving the hospital.
Case 5:  Incident involving a landfill
A 42-cubic-yard waste container from a hospital caused the scintillation 
counter at a landfill to trigger the alarm indicating the presence of 
radioactivity in the container.  Personnel from the landfill contacted the 
hospital regarding the incident.  Hospital personnel went to the landfill 
and had the container dumped.  Using a 1-inch scintillation detector, the 
hospital recovered one bag of trash containing radioactive material.  
Investigation of this bag proved that its contents came from the room of a 
patient who had undergone an iodine-131 therapy 
                                                            IN 91-03 
                                                            January 7, 1991 
                                                            Page 3 of 4 
treatment. The trash in the bag was food, plastic and paper dishes and 
utensils, newspapers, and magazines.  The hospital indicated that items 
removed from the room of the iodine-131 therapy patient had been surveyed 
for contamination.  The bag of trash released to the landfill measured 
background levels of radiation (using a GM survey meter).  However, on the 
day of discovery, using a 1-inch scintillation detector, the bag measured 
above background at the surface of the bag, and background at a distance of 
5 feet from the bag.  The hospital estimated that the bag contained less 
than 1 microcurie of iodine-131.  The hospital is considering setting up 
scintillation detectors at all loading docks.  Meanwhile, the hospital is 
holding all trash from iodine-131 therapy patients, before releasing it to 
the normal trash, until hospital personnel measure background radiation 
level, using a scintillation detector.
Since operators of landfills and medical waste incinerators have installed 
radiation detection systems, they have become more aware of radioactive 
materials being shipped to these facilities.  
NRC medical licensees are advised that operators of most landfills and 
incinerators managing medical waste are not licensed to manage low-level 
radioactive materials, and may simply reject any shipment which contains 
detectable levels of radioactivity, regardless of the source. 
If a licensee detects radioactivity in its waste, or if an operator of a 
landfill or medical waste incinerator returns to a licensee a waste shipment 
containing detectable levels of byproduct, source or special nuclear 
material, absent an exemption, the licensee must manage the waste as 
licensed material.  The licensee must evaluate the waste in accordance with 
10 CFR 20.201, "Surveys," and manage the storage/disposal of the waste in 
accordance with the applicable regulations and license conditions.  In 
addition, licensees are reminded that compliance with NRC regulations does 
not relieve NRC licensees from complying with other local, State, and 
Federal requirements regarding waste disposal.
Medical use licensees should be aware that radioactive materials may enter 
their waste-handling process through mechanisms largely beyond their 
control.  Diagnostic and therapy patients who are not required to be 
hospitalized may discard contaminated items with low, but detectable, levels 
of radioactivity into waste containers.  Therefore, detection of radioactive 
material in nonradioactive waste streams does not necessarily indicate poor 
management of radioactive waste or noncompliance with NRC requirements.  
However, licensees may find it prudent to establish a system to monitor all 
outgoing shipments of the waste for any detectable radioactivity, both to 
ensure compliance with NRC requirements and to reduce the costs and risks 
associated with returned shipments.
Improper transfer of licensed materials to unauthorized recipients is a 
violation of NRC requirements and will be considered for enforcement action.
                                                            IN 91-03 
                                                            January 7, 1991 
                                                            Page 4 of 4 
Notwithstanding the foregoing, certain radiologically-contaminated 
biomedical wastes are exempt from NRC regulatory control or disposed of 
through specific procedures precribed by regulation.  For example, excreta 
from individuals undergoing medical diagnosis or therapy with radioactive 
material are exempt from the limitations contained in 10 CFR Part 20.303, 
"Disposal by Release Into Sanitary Sewerage Systems."  In addition, 10 CFR 
Part 20.306, "Disposal of Specific Wastes," states that "any licensee may 
dispose of the following licensed material without regard to its 
radioactivity:  (a) 0.05 microcuries or less of hydrogen-3 or carbon-14, per 
gram of medium, used for liquid scintillation counting; and (b) 0.05 
microcuries or less of hydrogen-3 or carbon-14, per gram of animal tissue of 
averaged over the weight of the entire animal; provided however, tissue may 
not be disposed of under this section in a manner that would permit its use 
either as food for humans or as animal feed." 
This information notice requires no specific action or written response.  If 
you have any questions about the information in this notice, please contact 
the technical contact listed below, or the appropriate regional office. 
                              Richard L. Bangart, Director 
                              Division of Low-Level Waste Management 
                                and Decommissioning
                              Office of Nuclear Material Safety 
                                and Safeguards 
Technical Contact:  Samuel Z. Jones, NMSS
                    (301) 492-0554
 1. List of Recently Issued NMSS
     Information Notices
 2. List of Recently Issued NRC 
     Information Notices

Page Last Reviewed/Updated Thursday, March 25, 2021