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19 July 2008

Answer to Question #6912 Submitted to "Ask the Experts"

Category: Radioactive Waste Disposal — Disposal

The following question was answered by an expert in the appropriate field:

I am working with a facility that has various small pieces of equipment with very low levels of radioactivity. At what point can we safely and legally dispose of these items in the trash? Is there a "de minimus" activity level? Please provide the appropriate CFR (Code of Federal Regulations) reference.

Thank you for your question pertaining to the disposal of solid materials containing low levels of radioactivity. The U.S. Nuclear Regulatory Commission (NRC) general radiation protection guidelines in 10 CFR Part 20 would be the appropriate regulatory reference. In particular, Section 2002 of Part 20 provides for a case-by-case review for the disposal of radioactive materials in unlicensed facilities (i.e., routine trash):

§ 20.2002 Method for obtaining approval of proposed disposal procedures. A licensee or applicant for a license may apply to the Commission for approval of proposed procedures, not otherwise authorized in the regulations in this chapter, to dispose of licensed material generated in the licensee's activities. Each application shall include:

(a) A description of the waste containing licensed material to be disposed of, including the physical and chemical properties important to risk evaluation, and the proposed manner and conditions of waste disposal; and

(b) An analysis and evaluation of pertinent information on the nature of the environment; and

(c) The nature and location of other potentially affected licensed and unlicensed facilities; and

(d) Analyses and procedures to ensure that doses are maintained ALARA and within the dose limits in this part.

The NRC usually evaluates releases of solid materials on a case-by-case basis using either (1) license conditions that address the disposal of materials or (2) existing regulatory guidance. Note that 10 CFR Part 20 provides acceptable limits for releases of liquids and gases in effluent discharges, but sets no such limits for solid materials. Historically, many materials licenses have received NRC approval to dispose of potentially contaminated materials and equipment that met the surface activity guidelines specified in Fuel Cycle Policy and Guidance Directive FC 83-23, "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Byproduct, Source, or Special Nuclear Materials Licenses." Provided that the materials and equipment satisfied the table of surface contamination criteria, the materials were released without further regulatory control. Note: The surface contamination levels in FC-83 are the same as those contained in Regulatory Guide 1.86.

Additionally, the licensee must be able to demonstrate to NRC inspectors that the method of survey used is capable of detecting the presence of radioactive materials at the specified release criteria. The applicable survey regulations can be found in Section 1501 of Part 20:

(a) Each licensee shall make or cause to be made, surveys that--

    (1) May be necessary for the licensee to comply with the regulations in this part; and
    (2) Are reasonable under the circumstances to evaluate--
        (i) The magnitude and extent of radiation levels; and
        (ii) Concentrations or quantities of radioactive material; and
        (iii) The potential radiological hazards.

Eric Abelquist, CHP

Answer posted on 30 October 2007. The information and material posted on this Web site is intended as general reference information only. Specific facts and circumstances may alter the concepts and applications of materials and information described herein. The information provided is not a substitute for professional advice and should not be relied upon in the absence of such professional advice specific to whatever facts and circumstances are presented in any given situation. Answers are correct at the time they are posted on the Web site. Be advised that over time, some requirements could change, new data could be made available, or Internet links could change. For answers that have been posted for several months or longer, please check the current status of the posted information prior to using the responses for specific applications.