Information Notice No. 91-03: Management of Wastes Contaminated with Radioactive Materials ("Red Bag" Waste and Ordinary Trash)
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDS
January 7, 1991
Information Notice No. 91-03: MANAGEMENT OF WASTES CONTAMINATED WITH
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.
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
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.
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
Office of Nuclear Material Safety
Technical Contact: Samuel Z. Jones, NMSS
1. List of Recently Issued NMSS
2. List of Recently Issued NRC
Page Last Reviewed/Updated Thursday, March 25, 2021