Re: BacTec Vial Disposal

[Robert Yoss <ryoss@post.its.mcw.edu>]

Bob Carlson wrote:

> Ralph NORTH wrote:
> >
> > We are exploring options for disposing of BacTec vials from two clinics
> > within our institution. The activity per vial is 4 microcuries.
> > Our institution has a broadscope license, with authorization under Part 35.
> > As I understand 10 CFR 31.11(b)(2),we can operate the clinics
> > under general license without filing a Form NRC-483. Please comment.
>
> The problem that may occur is when you already have licnesed activities
> at the same institution.  Then (it's my understanding) everything you do
> is regulated.

  Many, many years ago, when Bactec first came out, the method of disposal was in
low level radioactive waste sites.  The NRC sent a letter to medical licensees
informing them that if they used Bactec under their general license, [10 CFR
31.11] they were exempt from Parts 19 & 20 and therfore need not fill the low
level radioactive waste sites.  Further stated in the letter that with medical
licensees of a specific use a general license was included, but that broad scope
licensees had to apply for a general license.  The NRC idea was, I assume, not to
waste space in low level radioactive waste sites.  The above is based on my
memory, because I can't find a copy of the letter.  I believe it came out in the
late 70's or early 80's.

The NRC did allow, and I again assume still does, the use of a general license
separate from the broad scope license at the same site as long as use, storage,
records, etc. are separate from each other.

Note:  The Biotec vial is still considered biological waste and need to processed
as such.

ryoss@mcw.edu