Re: Contaminated Residential Waste from I-131 Patients

[carol marcus <csmarcus@ucla.edu>]

At 08:21 AM 2/11/00 -0600, you wrote:
>Dear Radsafers:
>
>Most of the municipal and residential waste from the City of Indianapolis is
>disposed via a large, municipal incinerator.  A few years ago, radiation
>detectors were installed to monitor all trucks entering the incineration
>facility.  This was done due to an incident in 1992 when a Cs-137 source
>which supposedly came from a stolen moisture/density gauge was discovered in
>ash from the incinerator by a metal scrap dealer who would recover metal
>from the incinerator ash.
>
>Since the installation of the radiation detectors at the incineration
>facility, local hospitals have routinely had waste rejected at the
>incineration facility due to the presence of radioactive materials.
>Fortunately, most of those situations involved short-lived radionuclides
>(most commonly Tc-99m) where the waste was allowed to decay for a day or two
>at the incineration facility and then incinerated.
>
>When the NRC revised the regulations regarding the release of
>radiopharmaceutical therapy patients, the most common being patients treated
>with I-131 for thyroid carcinoma, contaminated residential waste became an
>increasing problem at the incineration facility.  A primary difference
>between residential waste versus hospital waste is that the incineration
>facility cannot determine where the radioactivity came from when the source
>is residential waste.  Furthermore, hospital waste is generally collected
>and transported in a "roll off" container (i.e., the container can
>physically be separated from the truck), while residential waste is
>collected and transported in a truck with a permanently mounted container
>(i.e., a "trash truck").
>
>Unfortunately for the collectors of the residential waste, the only option
>when contaminated, residential waste is rejected at the incinerator is to
>empty the contents onto the ground, sort through the waste using a survey
>instrument, and place the contaminated portion of the waste in another
>container for about 3 months if I-131 is the radionuclide involved.  In
>1999, there were 21 instances of I-131 detected in residential waste.
>
>Earlier this week, a meeting was held which included all of the RSOs from
>the hospitals in Indianapolis/Marion County, waste collectors, incinerator
>representatives, and state regulators to discuss this issue.  Obviously, the
>waste collectors would certainly like to avoid sifting through residential
>waste (can't blame them for that).  All of the RSOs emphasized that the
>hazards associated with the radioactivity are minimal, especially when
>compared with the other hazards of sifting through residential waste (the
>possibilities of what ends up in residential waste are endless).
>
>A primary problem lies with the operating permit for the municipal
>incinerator.  According to the regulators, the permit specifically prohibits
>incineration of radioactive materials (we haven't actually seen a copy of
>the permit).  Even though the permit is issued by the State of Indiana, we
>suspect that EPA guidance is being utilized.  When we (RSOs) suggested that
>the permit be modified, the regulators basically told us that such a change
>would require a hearing which would bring out the environmentalists.  They
>also stated that it would probably require legislative action which would be
>a political "hot potato" that no legislator would touch.
>
>The final result of the meeting was that the waste collectors are asking all
>local hospitals to provide them the residential address of patients treated
>with greater than 33 mCis of I-131 via a faxed form.  Due to confidentiality
>issues, a patient will have to provide written permission for hospitals to
>release such information.  Upon receipt of the faxed form, the waste
>collectors plan to go to the patient's home, survey their waste, and if
>radioactivity is detected, pick up the waste from the patient's home in a
>separate vehicle.  The waste will then be placed in a container at the
>collector's facility and held for decay.  While the actual number of
>man-hours involved will probably be greater, the waste collectors feel that
>this procedure is preferable to the current procedure of sifting through the
>residential waste in search of this material.
>
>I haven't presented this proposal to the nuclear medicine departments at our
>facility as yet.  When I do, I plan to remind them not to "shoot the
>messenger."  This wasn't my idea.  In fact, I think it's a bad idea, but
>then again, I don't have to sift through trash a couple of times a month.
>
>With the increasing use of radiation detectors at waste facilities, there
>must be some of you out there that are grappling with this same problem.  We
>are open to suggestions.
>
>Regards,
>
>Mack L. Richard, M.S., C.H.P.
>Radiation Safety Officer - IUPUI/Indiana Univ. Med. Cntr.
>Phone #: (317) 274-0330   Fax #: (317) 274-2332
>E-Mail Address:  mrichar@iupui.edu
>
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Dear Richard and Radsafers:

Hasn't the State of Indiana heard of a really neat invention called a
portable MCA?  You can actually identify radionuclides with it, instead of
trying to do it by halflife. 

The real problem, of course, is not the medical people, or the patients who
contaminate everything they touch, but with INSIGNIFICANT LEVELS of
contamination.  NRC took that into consideration when, after 7 years of
farce, finally passed the "500 mrem rule".  The problem is permitting a
state to make a scientifically dumb standard for trash of "zero
radioactivity".  That's where the problem is, and that's where it should be
fixed.  Low levels of radioactive contamination (from patient body fluids)
which are unregulated and not required to be buried in LLRW sites or decayed
out should be allowed in garbage dumps or incinerators, just as it is
allowed in hospitals and homes.  It merely requires the ability to identify
and estimate the activity level of medically relevant radionuclides.  This
is not at all difficult.

I really must reject the idea that because some naive and uninformed
bureaucrats make a scientifically nonsensical standard, that the only choice
is for the health physics, medical physics, and medical community to kill
themselves complying with it.  The answer is to CHANGE THE STANDARD.  It
would be nice if NRC did this for us, informing states of unacceptable and
unreasonable standards for low levels of contaminants unassociated with any
risk.  Alas, for years, the NRC has not had the balls or the brains to do
this. Not after the Commissioners and their staffs screwed up BRC big time.
There are even those at NRC who would use irrational state garbage dump
standards as an excuse to take away the 500 mrem rule, rather than defend
good science and cost-effective medicine against irrational hysteria.
Hopefully, the NRC Commissioners will not be so foolish, but I don't see
them making any effort to inform the nation of the basis for safe levels of
medical contaminants, either.

The logical end of this hysteria is to keep all radioactive patients in
isolated hospital rooms with dedicated plumbing until total decay of all the
radionuclides.  This is patently impossible, especially when one considers
trace contaminants that are present, such as Tc-99 with a halflife of about
200,000 years!  The cost of even doing this for most of the radioactivity is
enormous.  I costed it out once for currently used radionuclides in nuclear
medicine without even considering the contaminants.  It went well into the
multibillions of dollars, and would effectively end nuclear medicine.
Considering that the average American has three nuclear medicine procedures
during his lifetime, this is going to affect a lot of people.  

So, if NRC continues to play the coward, get your state rad health group to
work with the garbage folks to fix this.  Get your professional
organizations to help them do so. EDUCATE people on the safety of harmless
levels of generally short or rather short-lived medical radionuclides.
Explain that with a "no radioactivity" policy, it is illegal to dispose of a
banana or a piece of hamburger because of K-40, for example. 

Maybe the National Academy of Sciences could get a contract to make
standards for garbage dumps and incinerators, as waiting for the NRC appears
to be a lost cause.  Maybe there are even better ways.  However, keeping
every atom out of the dump or incinerator isn't one of them.

Ciao, Carol

Carol S. Marcus, Ph.D., M.D.
<csmarcus@ucla.edu> 

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