Radioactive Waste Management in Nuclear Medicine: Decay-in-Storage and Disposal Pathways
By Dr. Troy Zhou
Radioactive waste in nuclear medicine is managed through four defined pathways, and choosing the right one comes down to a single physical property: the radionuclide's half-life. Short-lived material such as F-18 and Tc-99m is held until it decays to background and then discarded as ordinary trash (decay-in-storage); soluble, readily dispersible material can be released into the sanitary sewer within strict concentration and quantity limits; and anything too long-lived to decay out on a clinical timescale — I-131 solid waste, Lu-177 contaminated with long-lived Lu-177m, and similar — is transferred to a licensed disposal facility or returned to the manufacturer. Each route has an explicit regulatory home in the NRC rules, and the decision is governed by the same ALARA philosophy that shapes the rest of the radiation safety program.
The technical core of the whole system is one calculation: how many half-lives must pass before the activity is indistinguishable from background. The ten-half-life rule for decay-in-storage — which drops activity to roughly
Introduction
Every nuclear medicine department generates radioactive waste continuously: spent F-18 FDG syringes and vials, Tc-99m generator columns and elution waste, contaminated gloves and absorbent pads, decayed unit-dose containers, and — for therapy programs — I-131 capsule packaging, Lu-177 vials, and patient excreta. Managing that waste is not an afterthought to the clinical workflow; it is an explicit license obligation, a recurring inspection focus, and a direct application of ALARA. Mishandled waste is one of the more common citations on an NRC or Agreement State inspection report, usually because a survey was skipped, a label was left on, or a sewer release exceeded a concentration limit.
This guide gives technologists, physicists, Radiation Safety Officers, and administrators an answer-first framework for the four disposal pathways — decay-in-storage, sanitary-sewer release, licensed disposal or transfer, and return-to-supplier — with the worked decay math behind hold times, a pathway comparison table mapped to the governing regulation, and the NRC and Agreement State rules that decide which route applies. Diagnostic Radiation Physics Services (DRPS) supports nuclear medicine and PET/CT programs across Florida, Maryland, Virginia, Washington DC, California, and Nevada, where waste handling is a routine part of license compliance and survey programs.
Topic Explanation
Radioactive waste management is the set of procedures by which a licensee stores, surveys, and disposes of byproduct material so that it leaves the facility — or enters the ordinary waste stream — within regulatory limits and at the lowest reasonable activity. The organizing principle is that the disposal pathway follows the radionuclide's physical half-life: the shorter the half-life, the more attractive it is to simply wait for the material to decay; the longer the half-life, the more likely the waste must be physically removed by a licensed recipient.
The federal framework is tiered. 10 CFR Part 20, Subpart K ("Waste Disposal") sets the general waste-disposal rules that apply to every NRC licensee, and 10 CFR Part 35 ("Medical Use of Byproduct Material") adds the medical-use-specific decay-in-storage provision. Both sit on top of the dose limits and survey obligations in the rest of Part 20. 12 The conditions, possession limits, and waste procedures specific to a given facility are written into its radioactive material license, with model language drawn from NUREG-1556, Volume 9, the NRC's consolidated guidance for medical-use licenses. 3
Key Terms
- Decay-in-storage (DIS): Holding short-lived byproduct waste until it has decayed to background, then surveying it and disposing of it as ordinary (non-radioactive) trash under 10 CFR 35.92.
- Physical half-life (
): The time for the activity of a radionuclide to fall by half through radioactive decay; the single property that determines which disposal pathway is feasible. - Sanitary-sewer release: Disposal of soluble or readily dispersible byproduct material into the sewer system within the concentration and quantity limits of 10 CFR 20.2003.
- Licensed (authorized) recipient: A facility licensed to receive radioactive waste for treatment, storage, or disposal; waste sent there moves under a shipment manifest per 10 CFR 20.2006.
- 10 CFR 20 Appendix B: The NRC table of effluent and sewer concentration values, and of annual limits on intake and derived air concentrations, that anchors the numeric sewer-release limits.
- ALARA: "As Low As Reasonably Achievable" — the design philosophy behind minimizing both the activity disposed of and the dose incurred while handling waste. 4
Key Technical Principles
The disposal decision is structured, not improvised: identify the radionuclide and its half-life, segregate the waste by half-life, choose the pathway the regulations allow for that material, and document the survey or calculation that proves the disposal was compliant. The four pathways and the regulation that governs each are summarized below.
The Four Disposal Pathways
The table maps each pathway to the material it suits, the key regulatory condition, and the controlling citation. Treat it as the decision tree a nuclear medicine waste program is built around; the specific numeric limits (sewer concentrations, possession limits) are license conditions tied to the Appendix B values rather than fixed figures you can memorize.
| Disposal pathway | Applicable material | Key regulatory condition | Regulation cite |
|---|---|---|---|
| Decay-in-storage (DIS) | Short-lived byproduct waste with physical half-life ≤ 120 days (e.g., F-18, Tc-99m, Ga-68, Cu-64, and I-131 within the limit) | Hold ≥ 10 half-lives; before disposal as ordinary trash, survey with a radiation detection survey instrument on its most sensitive scale, no interposed shielding, and confirm indistinguishable from background; remove or deface all radioactive-material labels | 10 CFR 35.92 2 |
| Sanitary-sewer release | Material that is readily soluble or readily dispersible biological material (e.g., aqueous waste, certain patient-derived material) | Stay within the monthly-average concentration limits and annual quantity limits tied to 10 CFR 20 Appendix B; sewer must receive sufficient flow; meet general waste-disposal requirements | 10 CFR 20.2001, 20.2003 1 |
| Licensed disposal / transfer | Longer-lived waste that cannot decay out on a clinical timescale (e.g., sealed sources, long-lived contaminants, mixed waste) | Transfer to a licensed or authorized recipient; ship under a manifest; specific low-activity waste may use 20.2005 routes | 10 CFR 20.2001, 20.2005, 20.2006 1 |
| Return to manufacturer / radiopharmacy | Unit-dose containers, generators (Mo-99/Tc-99m columns), unused therapy doses | Return to the supplier under the supplier's license and the facility's procedures; avoids on-site disposal entirely | License conditions; NUREG-1556 Vol 9 3 |
Most departments use all four. A typical week sees F-18 and Tc-99m waste going to decay-in-storage, aqueous and certain patient-derived material handled within sewer limits, generators returned to the radiopharmacy, and any long-lived or contaminated waste held for licensed transfer.
The Ten-Half-Lives Decay-in-Storage Rule
Decay-in-storage rests on one calculation. Radioactive decay is exponential:
where
In other words, ten half-lives leaves under one part in a thousand of the original activity — the basis for treating fully decayed waste as background-level material. 2 Importantly, 10 CFR 35.92 does not make ten half-lives the disposal trigger by itself: it sets ten half-lives as the minimum hold, and then requires a survey with a radiation detection survey instrument set on its most sensitive scale, with no interposed shielding, that reads indistinguishable from background before the waste is discarded as ordinary trash. The calendar establishes eligibility; the survey authorizes disposal.
The hold time is entirely radionuclide-specific, because it scales with
| Radionuclide | Physical half-life ( |
10 × |
Pathway note |
|---|---|---|---|
| F-18 | ≈ 109.8 min (1.83 h) | ≈ 18.3 hours | Decays out overnight; classic DIS isotope |
| Ga-68 | ≈ 67.7 min | ≈ 11.3 hours | Generator-derived PET; decays out same day |
| Tc-99m | ≈ 6.01 hours | ≈ 2.5 days | Most common DIS workload |
| Cu-64 | ≈ 12.7 hours | ≈ 5.3 days | Hold about a week |
| Lu-177 | ≈ 6.65 days | ≈ 66 days | Within the 120-day limit, but Lu-177m impurity complicates DIS (see below) |
| I-131 | ≈ 8.03 days | ≈ 80 days | Within the limit; long solid-waste hold |
All six of these radionuclides have a physical half-life well under the 120-day ceiling that 10 CFR 35.92 places on decay-in-storage, so each is eligible in principle. 25 In practice, F-18 and Tc-99m dominate the decay-in-storage room because their hold times are measured in hours and days, while I-131 and Lu-177 require holds of many weeks and a correspondingly larger storage footprint.
Worked example — F-18. A morning's spent F-18 FDG syringes are placed in a shielded decay bin at the start of the day. Using
Ten half-lives is
A batch binned at 8:00 a.m. is eligible for a disposal survey the next morning. If a vial held, say, 370 MBq (10 mCi) of residual activity, the 0.1% remaining is on the order of 0.36 MBq (≈ 10 µCi) of total activity spread across the container — which is why the survey-to-background check still has to be performed and read on the most sensitive scale rather than assumed from the math alone.
Worked example — longer-lived isotopes. The same arithmetic gives the minimum holds in the table: Tc-99m (
When Decay-in-Storage Fails: Long-Lived Impurities
A subtle but important failure mode is a short-lived isotope carrying a long-lived radioactive impurity. Lu-177 is the textbook case. According to PubMed, a prospective study of Lu-177-dotatate (Lutathera) waste found that although Lu-177 itself (
Sanitary-Sewer Release and Appendix B
Releasing licensed material into the sanitary sewer is permitted but tightly bounded by 10 CFR 20.2003. The material must be readily soluble or readily dispersible biological material; the monthly-average concentration in the sewer must not exceed the values referenced from 10 CFR 20 Appendix B, Table 3; and there are annual quantity limits on the total activity released this way. 1 The facility must also have enough sewer flow to dilute the release. Patient excreta are generally exempt from these limits, which is why hospitals can release patient urine and feces from therapy patients to the sewer; but deliberate disposal of departmental aqueous waste down the drain is capped, and the calculation must be documented.
Rather than memorize a single number, point every sewer-release decision at the controlling table. The specific monthly-average sewer concentration limit for a given radionuclide is the value listed in 10 CFR 20 Appendix B, Table 3, and it is radionuclide-specific. Departments that release therapy-related aqueous waste commonly route it through delay (decay) tanks first: the waste is held while short-lived activity decays, then sampled and released in batches within the limits. According to PubMed, one nuclear medicine department used two alternating two-month delay tanks for I-131 toilet effluents, releasing six batches per year, with sampled releases documented well below the recommended bi-monthly release levels. 8 An earlier practical report on Lu-177 therapy similarly collected patient excreta in decay tanks and stored them for one to two months before discharge into the general sewer, within the department's tolerated annual discharge limit. 7
Clinical Impact
Disciplined waste management keeps a nuclear medicine program both compliant and operational. The clearest operational impact is storage footprint: decay-in-storage works only if the program has enough shielded, segregated, dated bins to hold each isotope for its full ten-half-life period without commingling fresh waste with nearly decayed waste. A Tc-99m-heavy general nuclear medicine service can clear most of its waste in days; a therapy program running I-131 and Lu-177 needs weeks-to-months of holding capacity, and — as the Lu-177m impurity case shows — sometimes years of segregated storage for a small fraction of high-activity vials. 67
The patient-safety and worker-safety stakes are real but indirect. Waste held for decay is also a source term: containers must be shielded and stored so that occupational and public dose stays within the 10 CFR Part 20 limits, and the act of surveying and discarding decayed waste is itself a small-but-nonzero dose task best handled under ALARA. The compliance impact is the most visible: skipped disposal surveys, labels left on discarded containers, and sewer releases without documentation are among the waste-handling findings inspectors cite. Getting the pathway and the paperwork right is what keeps a waste program out of an inspection report. For the broader pattern of where programs fall short, see our overview of common radiation safety violations and how to avoid them.
Practical Tips
A waste program runs on segregation, dating, and surveys. The practices below keep decay-in-storage defensible and the other pathways within limits.
- Segregate by half-life at the point of generation. Separate bins for F-18, Tc-99m, I-131, Lu-177, and long-lived/mixed waste prevent a short-lived bin from being contaminated by a longer-lived isotope that resets its effective hold time.
- Date every container. Label each bag or container with the date it was sealed and the isotope, so the ten-half-life clock is unambiguous and an inspector can verify the hold at a glance.
- Hold at least ten half-lives, then survey — do not skip the survey. The survey on the most sensitive scale with no interposed shielding, read as indistinguishable from background, is the regulatory authorization to dispose; the calendar only establishes eligibility. 2
- Remove or deface all radioactive-material labels before decayed waste leaves as ordinary trash. A retained trefoil on a discarded box is a classic, avoidable citation. 2
- Watch for long-lived impurities. For Lu-177 and any reactor- or accelerator-produced isotope with a known long-lived contaminant, confirm the effective clearance time rather than assuming the principal half-life governs. 67
- Route aqueous/therapy liquid waste through delay tanks and sample before release. Batch the release, sample it, and document the concentration against the Appendix B-referenced limit. 8
- Keep the survey instrument calibrated and use a defined background. A documented background reading and a current calibration are what make "indistinguishable from background" a number an inspector can accept; our guide to choosing the right radiation survey meter covers instrument selection.
- Document everything. Disposal surveys, sewer-release calculations, and transfer manifests are routine inspection items; the record is as important as the act.
Waste handling and decontamination overlap closely — contaminated PPE, wipes, and absorbent pads from a spill all become radioactive waste managed under these same pathways. For the response side, see our guide to decontamination best practices in nuclear medicine.
Regulatory Considerations
Radioactive waste disposal is governed by explicit federal rules, with Agreement States enforcing compatible versions. The core citations are:
- 10 CFR 35.92 — Decay-in-storage. Permits a licensee to hold byproduct material with a physical half-life of less than 120 days for decay and then dispose of it as ordinary trash, provided the licensee surveys each container with a radiation detection survey instrument set on its most sensitive scale with no interposed shielding and confirms the reading is indistinguishable from background, and removes or defaces all radioactive-material labels before disposal. 2
- 10 CFR Part 20, Subpart K — Waste Disposal. The general waste-disposal framework. 20.2001 sets the general requirements and the permissible methods (transfer to an authorized recipient, decay-in-storage where authorized, or disposal as otherwise approved). 20.2003 governs disposal by release into sanitary sewerage — the material must be readily soluble or readily dispersible, and releases are bounded by the monthly-average concentration and annual quantity limits tied to Appendix B. 20.2005 addresses disposal of specific low-activity waste (certain scintillation media and biological materials) under defined conditions. 20.2006 requires a manifest for waste transferred to a licensed land-disposal or authorized recipient. 1
- 10 CFR 20, Appendix B. The table of effluent concentration and sewer-release values that anchors the numeric limits in 20.2003. Always read the current values directly rather than relying on a remembered number. 1
- NUREG-1556, Volume 9. The NRC's model guidance for medical-use licenses, including the decay-in-storage and waste-handling procedures most programs adapt and an NRC reviewer will recognize. 3
The waste pathways also intersect with patient-release rules. Therapy patients released under 10 CFR 35.75 carry activity home, and their excreta — released to the sewer as exempt patient-derived material — are the largest "disposal" route for many therapy programs, even though they are handled outside the deliberate-release limits of 20.2003. For the licensing framework that authorizes a facility's possession and use in the first place, see our NRC radioactive material license guide.
Jurisdiction determines who enforces these rules:
- Florida, Maryland, Virginia, California, and Nevada are NRC Agreement States: the state radiation control program issues and inspects materials licenses under regulations that are compatible with — and at least as stringent as — the NRC's. Florida, for example, regulates under Florida Administrative Code Chapter 64E-5. 9
- Washington DC is regulated directly by the NRC.
DRPS supports clients across all of these jurisdictions, so waste procedures and disposal records should be written to satisfy the specific regulator that holds the facility's license.
Frequently Asked Questions (FAQs)
What is decay-in-storage in nuclear medicine?
Decay-in-storage (DIS) is holding short-lived radioactive waste until it has decayed to background, then disposing of it as ordinary trash. Under 10 CFR 35.92, it applies only to byproduct material with a physical half-life of 120 days or less, the waste must be held for at least ten half-lives, and before disposal it must be surveyed with a radiation detection survey instrument set on its most sensitive scale with no interposed shielding and read as indistinguishable from background.
How long do you have to hold waste for decay-in-storage?
At least ten physical half-lives, which reduces activity to about
Can radioactive material be released into the sanitary sewer?
Yes, within strict limits. Under 10 CFR 20.2003, licensed material released into sanitary sewerage must be readily soluble or readily dispersible biological material, and the activity must stay within monthly-average concentration limits and annual quantity limits tied to the values in 10 CFR 20 Appendix B. Patient excreta are generally exempt, but deliberate disposal of departmental waste down the drain is tightly capped and must be documented.
What are the main radioactive waste disposal pathways for a nuclear medicine department?
Four pathways: decay-in-storage for short-lived isotopes (10 CFR 35.92), sanitary-sewer release within Appendix B limits (10 CFR 20.2003), transfer to a licensed or authorized recipient via a manifest (10 CFR 20.2006), and return to the manufacturer or radiopharmacy. Longer-lived material that cannot decay out on a clinical timescale generally goes by transfer or return.
Why can't all radioactive waste use decay-in-storage?
Decay-in-storage is limited by regulation to material with a physical half-life of 120 days or less, and it is only practical for the shortest-lived isotopes. Longer-lived radionuclides — or short-lived ones contaminated with a long-lived impurity such as Lu-177m in Lu-177 — would require impractically long storage and must instead be transferred to a licensed disposal facility or returned to the supplier.
What must you do before disposing of decayed waste as ordinary trash?
Survey each container with a radiation detection survey instrument set on its most sensitive scale with no interposed shielding and confirm the reading is indistinguishable from background. Then remove or deface all radioactive-material labels before the waste leaves the licensed area. Both steps are explicit 10 CFR 35.92 requirements, and the survey must be documented.
Who regulates radioactive waste disposal in nuclear medicine?
The NRC regulates byproduct material under 10 CFR Part 20 (Subpart K, Waste Disposal) and 10 CFR Part 35. In Agreement States such as Florida, Maryland, Virginia, California, and Nevada, the state radiation control program enforces compatible rules; Washington DC is regulated directly by the NRC.
Do you have to keep records of radioactive waste decay and disposal?
Yes. Decay-in-storage surveys, sewer-release calculations, and transfer manifests must be documented and retained. The 10 CFR 35.92 disposal-survey record and the 10 CFR 20.2006 transfer manifest are routine inspection items.
Key Takeaways
- Radioactive waste in nuclear medicine follows four pathways chosen by half-life: decay-in-storage (10 CFR 35.92), sanitary-sewer release (10 CFR 20.2003), licensed disposal/transfer (10 CFR 20.2001/20.2005/20.2006), and return to the manufacturer.
- Decay-in-storage is limited to byproduct material with a physical half-life ≤ 120 days, held for at least ten half-lives (
remaining), then surveyed on the most sensitive scale with no interposed shielding until indistinguishable from background, with all radioactive-material labels removed or defaced before disposal. - Ten-half-life holds are isotope-specific: ≈ 18 h for F-18, ≈ 2.5 days for Tc-99m, ≈ 66 days for Lu-177, and ≈ 80 days for I-131; the survey, not the calendar, authorizes disposal.
- A long-lived impurity can break decay-in-storage even for an eligible isotope — trace Lu-177m (
d) in Lu-177 pushes effective clearance to years, forcing licensed transfer instead. - Sanitary-sewer release requires readily soluble or readily dispersible material within the 10 CFR 20 Appendix B monthly-concentration and annual-quantity limits; delay tanks and batch sampling keep releases defensible, and the exact Appendix B value must be read from the current rule.
- Waste handling is governed federally by 10 CFR Part 20 Subpart K and 10 CFR Part 35, with NUREG-1556 Volume 9 model guidance; Agreement States (FL, MD, VA, CA, NV) enforce compatible rules, and Washington DC is regulated directly by the NRC.
Conclusion
Radioactive waste management in nuclear medicine is, at its core, a half-life sorting problem with a paper trail. Short-lived material decays out and is surveyed to background before it becomes ordinary trash; soluble material can be released into the sewer within Appendix B limits; and anything too long-lived — or contaminated with a long-lived impurity — leaves the building under a manifest to a licensed recipient or goes back to the supplier. The ten-half-life rule gives the timing, the survey-to-background check gives the authorization, and the documentation gives the defensibility. A program that segregates by half-life, dates its containers, surveys before it discards, and watches for long-lived impurities will satisfy ALARA, keep occupational and public dose low, and stay off the inspection report.
How DRPS Can Help
Diagnostic Radiation Physics Services helps nuclear medicine and PET/CT programs build defensible radioactive waste programs: decay-in-storage procedures with documented ten-half-life holds and survey-to-background protocols, sanitary-sewer release calculations referenced to 10 CFR 20 Appendix B, transfer-manifest and return-to-supplier workflows, RSO support, and the recordkeeping that satisfies NRC or Agreement State inspectors. We serve Florida, Maryland, Virginia, Washington DC, California, and Nevada and tailor waste procedures to the regulator that holds your license. To review your waste-handling readiness, audit your decay-in-storage survey records, or designate an RSO, contact DRPS or learn more about our Radiation Safety Officer services and radioactive material license support.
Related Resources
- Decontamination best practices in nuclear medicine
- Common PET & RPT isotopes
- NRC radioactive material license guide
- Common radiation safety violations
- Radiation Safety Officer consulting
- Radioactive material license support
References
- U.S. Nuclear Regulatory Commission. 10 CFR Part 20: Standards for Protection Against Radiation (Subpart K — Waste Disposal, §§20.2001–20.2008; Appendix B). ecfr.gov
- U.S. Nuclear Regulatory Commission. 10 CFR 35.92: Decay-in-storage. ecfr.gov
- U.S. Nuclear Regulatory Commission. NUREG-1556, Volume 9, Revision 3: Consolidated Guidance About Materials Licenses — Program-Specific Guidance About Medical Use Licenses. nrc.gov
- U.S. Nuclear Regulatory Commission. ALARA (As Low As Is Reasonably Achievable). nrc.gov
- National Nuclear Data Center, Brookhaven National Laboratory. NuDat / Chart of Nuclides — radionuclide half-life data (F-18, Ga-68, Tc-99m, Cu-64, Lu-177, I-131). nndc.bnl.gov
- Prevot S, Dygaï-Cochet I, Riedinger JM, Vrigneaud JM, Quermonne M, Gallet M, Cochet A. Dealing with dry waste disposal issues associated with 177Lu impurities: a long-term challenge for nuclear medicine departments. EJNMMI Phys. 2023;10(1):3. doi:10.1186/s40658-023-00524-z. doi.org (via PubMed)
- Bakker WH, Breeman WAP, Kwekkeboom DJ, De Jong LC, Krenning EP. Practical aspects of peptide receptor radionuclide therapy with [177Lu][DOTA0,Tyr3]octreotate. Q J Nucl Med Mol Imaging. 2006;50(4):265-271. PubMed
- Ravichandran R, Binukumar JP, Sreeram R, Arunkumar LS. An overview of radioactive waste disposal procedures of a nuclear medicine department. J Med Phys. 2011;36(2):95-99. doi:10.4103/0971-6203.79692. doi.org (via PubMed)
- Florida Department of Health. Florida Administrative Code Chapter 64E-5: Control of Ionizing Radiation. flrules.org