Re: Contaminated Residential Waste from I-131 Patients

["Paul R. Steinmeyer" <prstein@gyral.com>]

Hello Richard;

A couple of years ago I did a project for a large waste handling company
for their medical waste incineration facilities to address exactly this
issue.  A procedure was developed where the incinerator was given the
option of holding the waste for a day or so and making a rough
estimation of half life based on two measurements.  The short version is
that as long as the half life was less than 10 days and exposure rate
was less than 1 mR/h on the surface of the package, the material could
go back into the waste stream without regard to the radioactive
content.  This procedure was approved by about 15 different states
(Indiana was not part of the project) that I contacted, although a
couple requested that it be held for decay prior to incineration.  In
general, the state folks were tired of expending their resources to
respond to detector alarms only to find trivial quantities of
short-lived medical isotopes and were happy that the company was taking
the initiative.  The procedure also meshes well with CRCPD's guidance on
the subject.

It is my opinion that the purpose of these truck monitors is to prevent
the "big" sources, such as stray density gauges, from getting into the
waste stream.  The purpose should NOT be to detect vanishingly small
quantities of medical isotopes and NORM.  The physical and biological
dangers of dumpster diving to retrieve this sort of radioactive material
are real and immediate, and far outweigh the hypothetical risk from
exposure to the material.

So maybe the solution is to keep hammering away until someone finally
sees the light.  There is precedent.  Keep communicating, and keep
educating!  

Regards,

Paul R. Steinmeyer
Health Physicist
Radiation Safety Associates, Inc.
RSA Laboratories, Inc.
mailto:prstein@radpro.com
voice: 860/228-0487
fax: 860/228-4402


"Richard, Mack L" 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
> 
> ************************************************************************
> The RADSAFE Frequently Asked Questions list, archives and subscription
> information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html