Section 4 Safe Disposal of Radioactive Materials/Waste

4.0) Safe Disposal of Radioactive Waste

Copied from the Radiation Safety Services guidance document 3.7 as published dated 5/97 and as revised 8/97.

4.1) Radioactive Waste Management Policy

The Radiation Safety Service (RSS) processes all radioactive waste generated at the University of Kansas. Any laboratory material and/or labware considered a waste and brought into contact with or is initially considered contaminated by radioactive materials must finally be disposed of by the RSS. Waste is considered any material or component for which the authorized user foresees no further use. All radioactive sources must be ordered through the RSS, and in turn, all waste generated from the experimental use of radioactive sources must be prepared for the RSS. Users are not authorized to discard any radioactive waste to the sewer, vent, or by violating mandated procedures, to regular trash.

RSS is committed to limiting and restricting the release of radioactive materials to the environment. Only those materials that were designed to be released to the environment (air and sewer) should be disposed by venting to the atmosphere or releasing to the sewer. Dilution is not viewed as a true means of disposal. Extensive control is placed upon any experiment generating volatile wastes. In addition, ALARA goals have been adopted to encourage the elimination of any release, and to attempt to reduce the exposure to the public.

Each specific laboratory that generates the waste must manage radioactive waste generated at the University of Kansas. Authorized users are responsible for completing the appropriate records as specified by the RSS and for preparing all wastes for transfer to the RSS for disposal. RSS personnel transport all radioactive waste (solid, liquid, scintillation vials, etc.) in approved containers with the proper packaging and shipping manifests to either Burt Hall or Haworth Hall. Waste is segregated, packaged, and compacted as needed in the radioactive waste processing facility in Burt Hall.

4.2) Radioactive Waste Minimization Program

The radioactive waste minimization program addresses process changes that can be made to reduce or eliminate radioactive wastes, methods to minimize the volume of regulated radioactive wastes through better segregation of materials, and by substitution of nonhazardous materials for hazardous materials. The goal of the radioactive waste minimization plan is to minimize the present and future concerns to the human health and environment by reducing or eliminating radioactive wastes as much as is economically practicable, and by pursuing the best radioactive waste management method that is available. Radioactive waste minimization includes reviewing the use of the materials for alternative methods, improved administrative controls, source reduction (material substitution, practice modifications, inventory management), volume reduction, and alternative treatment and disposal methods.

4.3) Radioactive Waste Storage

Although the user is able to determine the continued usability of radioactively contaminated material and components, radioactive waste storage in the laboratory is not authorized. Designated containers are placed in the laboratory by the RSS for accumulating radioactive wastes. These containers are usually fiber drums for solid and scintillation vial radioactive wastes, marked three and one-half gallon pails for limited generation of scintillation vial radioactive waste, and one gallon plastic/glass jugs for liquid radioactive wastes. Secondary containers are required for liquid radioactive wastes that are accumulating in the laboratory. Only fiber drums and pails provided by the RSS may be placed on the floor. All other radioactive waste containers must be placed on benchtops. Users are required to complete the required documentation describing the radioactive waste and to prepare the waste for RSS transfer when the container is filled.

4.4) Evaluation of Waste Activity

A researcher is responsible for verifying that the conditions of the permit and that the regulations pertaining to the University's license are completely followed. To do so, researchers must often evaluate dose rates, safety precautions, and activity levels from the proposed experimental procedures to gain the necessary information before performing the experiment. In the same way that estimations must be made from these procedures, waste disposal requires that determinations be made either before the waste is generated or at the time of generation. This evaluation is required not only to make sure that regulatory levels are not exceeded, but also that current practices conform to University policies.

Evaluations of this nature do not have to be extensive. Representative samples from different kinds of processes should be analyzed to document activities from each particular waste stream. If one can differentiate between background and the sample (greater than twice background) the sample has detectable activity. For liquid waste the easiest approach to the problem is to release only tertiary rinses to the sanitary sewer. Tertiary rinses do not usually have detectable activity. The waste material, and primary and secondary rinses, usually have activities that exceed detectable activities. Tertiary rinses may be discarded.

Eliminating the release of radioactive materials to the sanitary sewer seems prudent since the sanitary sewer was not designed for such disposal, dilution is not a true means of disposal, and disposal by several licensed facilities may lead to increased levels in the sludge at treatment facilities. In addition, there is some indication that neutralization tanks may concentrate or at least become contaminated with the activity that has been released from the laboratories. Tanks do exist in Haworth and Malott

4.5) Segregation

Prudent practice requires the segregation of radioactive waste as specified by the RSS. Radioactive materials with half-lives less than 60 days that contain no other hazardous chemicals are disposed by decay. The materials in any given container are kept by the RSS for no less than twenty half lives before disposal. Waste costs are often based upon the isotopes that are present and the activity in the waste.

4.6) Shipping Manifests/Recordkeeping

The shipping manifest and waste summary sheet serves two purposes. The first purpose is to document the radioactive waste activity that is removed from the laboratory. This documentation includes the kinds of radioactive waste containers that are removed from the laboratory, as well as the source location for the activity. The second purpose is to fulfill the transportation requirements.

4.7) Specific Types of Radioactive Waste

4.7.1) Solid/Dry Waste

Solid/dry wastes are generated from routine radiation laboratory procedures. These wastes include gloves, absorbent paper, glassware, and other routine labware used in the laboratory that may have come in contact with radiation. Solid wastes are to be placed into 20 gallon fiber drums as specified and supplied by RSS. Segregation is required by isotope. The RSS transfers the fiber drums to Burt Hall where the contents are repackaged into 55 gallon drums for decay in storage and/or disposal.

4.7.2) Aqueous Waste

Aqueous wastes are generated from routine radiation laboratory procedures. These wastes are collected into one gallon plastic/glass containers provided by RSS. Liquid wastes are transferred to RSS for decay in storage and/or disposal.

4.7.3) Scintillation Mixed Wastes

Scintillation mixed wastes are generated from determinations of radioactivity made by placing laboratory samples in vials containing scintillation fluid. Following analysis, the vials containing waste scintillation fluids are placed directly into twenty gallon fiber drums or three and one-half gallon pails in the laboratory. The RSS transfer the fiber drums and pails to Burt, and the contents are repackaged in fifty-five gallon drums for shipment. The drums are shipped on a routine quarterly schedule by a commercial broker to a licensed facility for final disposal by energy recovery.

4.7.4) Solvent Mixed Waste

Solvent mixed waste, (hazardous chemical and radioactive), waste which is regulated under both the EPA and NRC/Agreement State, may be generated in a very limited and restricted manner. Since the disposal depends upon the availability of treatment facilities, the RSS wishes to facilitate necessary research while limiting the generation of mixed waste by encouraging substitution and by promoting the active engagement of the users in reducing quantities of mixed waste. Researchers are required to verify that nonhazardous components will be substituted for hazardous components whenever possible, and that the generation of mixed waste will be eliminated whenever possible.

Satellite accumulation areas exist in laboratories where mixed wastes initially accumulate. The waste container is located near the point of generation, and is under the control of the operator of the process generating the waste. The container is marked with the words "Hazardous Waste." Mixed waste is routinely collected and shipped to a licensed treatment/disposal facility.

4.7.5) Animal/Biological Waste

RSS approval must be received before the generation of any radioactive animal or biological wastes. Such wastes are to be packaged according to RSS procedures. Waste are transferred to RSS for disposal.

4.8) Disposal Capacity

4.8.1) Commercial Disposal

Contractors, possessing the requisite expertise, facilities, and legal right to transport and dispose of low-level radioactive waste in a safe and efficient manner and by all valid and applicable federal, state, and city regulations, provide waste disposal services to commercial disposal facilities. Solid wastes are compacted and prepared for shipment by the RSS. Commercial shipments are very costly. ($2500 drum)

Several basic categories of radioactive waste are produced at the University of Kansas. These categories are determined by the mandates of federal regulatory agencies, the cost to the University and the facilitation of disposal.

4.9) General Procedures

4.9.1) Accumulation

Accumulation of radioactive wastes within laboratories will be under standardized conditions so that all personnel including those of housekeeping and facilities operation will be able to recognize the waste containers. To this end all radioactive waste will be stored in special fiber drums provided by the RSS. The conditions for packaging within the drums will depend upon the category of waste as described below. In some cases it may be inconvenient to store in the drum small volumes of waste to which materials are still being added. In such cases, a clearly labeled box or container located on a bench area reserved for "restricted" work may be approved by the RSS. However, such boxes and/or containers may not be placed on the floor. Liquid wastes must be stored in gallon containers provided by the RSS or as specified by the RSS. Liquid wastes must be in a secondary container which could catch the wastes if the primary container were to break unless the primary container is unbreakable.

4.9.1.1) Documentation Requirements for Drums and Containers

The prerequisites for any drum exchange or waste pickup are that the waste be packaged as requested and that a waste description summary accompany the waste container. This summary (WD-IV) must have the following information.

a) Source Information
- 1) source number
  2) isotope(s)
  3) activity(ies) (volume fraction)
b) Package Information
- 1) package identification
  2) isotope(s)
  3) activity(ies)
  4) type of waste
  - SV - scintillation vials (include cpm/vial)
    S - solid
    Aqueous (include cpm/20ul)
    Og - organic (include cpm/20ul)
  5) date waste was prepared
  6) initials of person responsible for packaging.

4.9.2) Categories of Waste

4.9.2.1) Category I - Deregulated Vials
- a)scintillation vials with only H-3 and C-14.
  b)normally at concentrations no greater than used in liquid scintillation counting systems.
  c)Close vial lids tightly.
  d)Place glass or plastic vials directly into the drum.
  e)Keep lid on the drum between uses - does not have to be lever locked.
  f)When drum is full and the record keeping is complete, call the RSS.
4.9.2.2) Category II - Regulated Vials
- a)scintillation vials other than H-3 and C-14.
  b)normally at concentrations no greater than used in liquid scintillation counting systems.
  c)Close vial lids tightly.
  d)Place glass or plastic vials directly into the drum.
  e)Keep lid on the drum between uses - does not have to be lever locked.
  f)When drum is full and the record keeping is complete, call the RSS.
4.9.2.3) Category III - Dry Solid Waste with Half-Lives Less Than 60 days
- a)Absolutely no liquids of any type.
  b)All needles, razor blades, and other sharp objects must be placed in a clearly labeled container segregated from all other waste.
  c)Keep lid on the drum between uses.
4.9.2.4) Category IV - Dry Solid Waste with Half-Lives Greater Than 60 days
- a)Absolutely no liquids of any type.
  b)All needles, razor blades, and other sharp objects must be placed in a clearly labeled container segregated from all other waste.
  c)Keep lid on the drum between uses.
4.9.2.5) Category V - Water Soluble or Aqueous Waste
- a)No EPA-listed hazardous chemicals may be in this category.
  b)No water-insoluble wastes.
  c)No solids or other debris in this waste.
  d)Place wastes in standard plastic gallon jugs. (Jugs may be purchased from RSS or must be approved.)
  e)Except possibly H-3 and C-14, isotopes shall not be mixed in the same jug. (This applies to jugs in all categories, unless authorized by the RSS.)
4.9.2.6) Category VI - Liquid Wastes not Included in Above Categories
- a)An accurate description of the composition of the waste must be provided. (Nature of all chemicals as well as the usual activity information.)
  b)No solids or debris may be in this waste.
  c)Place wastes in the standard jugs.
4.9.2.7) Category VII - Animals
- a)Animals should be bagged.
  b)Animals should be temporarily stored in a freezer. Methods of storing other than freezing require special arrangements with the RSS.
  c)Arrangements should be made with the RSS for disposal.

4.9.3) Number of Drums Needed per Laboratory

For best operation of this system, the RSS should be consulted as to the number of drums that a particular lab might need. Obviously, a laboratory would not need a drum for a type of waste that is not generated in that lab.

Because many drums might be too much of a burden for a lab generating small volumes of waste, the RSS will review proposals for consolidation of Categories provided that acceptable packaging and labeling arrangements can be made so that the wastes from a single drum can be sorted and segregated by the RSS in a rapid and safe manner. Such an arrangement may be terminated by the RSS if it fails to meet requirements in practice.

Experience indicates that shared drums lead to problems in record keeping and in responsibilities for the wastes.

Drums should be placed in locations where they will not need to be moved frequently.

4.9.4) Pick Up Schedules

When a container has been completely filled, and the paperwork has been completed, a pickup should be scheduled with the RSS. Contact 785-864-4089.

New radioactive waste containers, drum liners, and plastic/glass bottles are provided by the RSS.

4.10) Radiation Generating Devices

Authorization from RSS must be granted to any authorized user prior to transferring a radiation generating device to another laboratory or institution, or to disposing of the unit. RSS will certify that any radiation generating device to be used for parts or to be disposed of has been rendered fully inoperative and that it contains no radioactive sources before it is approved for disposal. RSS will also confirm that any radiation generating device to be used for parts or to be disposed of has had all labels and markings removed, and that appropriate release surveys have been performed before it is approved for disposal. If the unit is to be transferred to another laboratory or institution, RSS will verify that the recipient is appropriately authorized to receive the radiation generating device.