Section 3: Radioactive Waste Management

Contents

3.1  General

The generation, storage, transport and disposal of radioactive waste is governed by various Federal, State and Local agencies.  Due to the complicated nature of these wastes, the regulations imposed by these agencies are frequently reviewed and revised. In addition, disposal options for radioactive waste are limited and costly. These issues compel the University to emphasize the need to minimize waste generation whenever possible.

The generator of the radioactive waste is assumed to be the most knowledgeable of its contents.  In the laboratories, Radioactive Material Supervisors are considered to be the generators. They are responsible for monitoring all waste generated by individuals under their supervision to ensure that the waste complies with related regulations. This Section of the Handbook should be used as a  guide by generators to ensure proper management of radioactive waste and compliance with related regulations.

3.2  Radioactive Waste Management in Laboratories

All radioactive waste generated at the University  must:

  • be stored in a “Controlled Area”
  • be properly stored/packaged
  • be properly shielded (as necessary)
  • be properly documented
  • be properly labeled
  • be appropriately segregated

Radioactive waste containers must be stored within controlled radiation areas and shielded as necessary to ensure that the exposure in any unrestricted area does not exceed 2 mrem in any one hour and does not result in a total effective dose equivalent to any non-occupationally exposed individual in excess of the 100 mrem in a year. The containers must be labeled with isotope, activity, date and “Caution Radioactive Materials”. Bench-top waste receptacles must also be provided at each work area and shielded as necessary.

Radioactive wastes must be segregated according to isotope and waste form. The waste must be tallied to ensure proper disposal and reporting. All labels depicting “Radioactive” or radioactive symbols must be obliterated prior to disposal.  Wastes that are found to be improperly labeled, packaged, etc.  will be returned to the laboratory for necessary remediation.

(i) Dry, Solid Waste

Dry, solid radioactive wastes are waste materials such as paper, plastic, gloves, etc., that are contaminated with radioactive materials. Any liquids present in the waste must be strictly incidental (i.e. a drop at the end of a pipette tip, a microliter at the bottom of a vial or moisture on the sides of a beaker). Animal carcasses, scintillation vials, containers of liquids, syringes and sharps are not considered dry, solid radioactive waste. Also, dry wastes may not contain any materials which are pathogenic or infectious.

In the laboratories, dry wastes are generally accumulated in 12 gallon fiber waste drums or in 5 gallon metal pails. These waste receptacles must be segregated by isotope, shielded appropriately and located within a controlled area. All receptacles must also be lined with a 4 mil plastic bag and labeled with:

  • Isotope
  • Total Activity
  • “Caution Radioactive Material”

All labels depicting “Radioactive” or radioactive symbols must be obliterated prior to disposal. Lead or leaded receptacles are not acceptable in this type of waste. Containers with these items will be returned to the generating laboratory for remediation.

A tally sheet is recommended for each container to aid in keeping an accurate record of the total activity of the radioactive waste in the container. Dry solid radioactive waste containers will be picked up for disposal by Radiation Safety staff  (Section 3.3 provides details on radioactive waste pick-ups).  Prior to pick-up the liner must be securely closed with a twist tie or tape, the container lid must be closed with a locking ring and the container must be wipe tested for removable contamination.  Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.  The results of the wipe tests must be written on the back of the waste container tag.

(ii) Aqueous Liquid Waste

Aqueous liquid wastes containing radioactive materials must be accumulated in unbreakable containers not exceeding one gallon in capacity unless specifically approved by the RSO prior to use. The liquid waste containers must prohibit the release of volatile radionuclides and must be in a secondary containment vessel capable of holding the maximum volume of the primary container. The primary liquid waste container must have a “Caution Radioactive” label affixed to it  and it must be labeled with:

  • Volume
  • Isotope
  • Activity
  • Chemical components

Radioactive aqueous liquid wastes and the first rinse of containers must be retained and accumulated for proper disposal. Subsequent rinses may be disposed to the sanitary sewer as long as the limits for disposal and other related requirements, as defined in Section 3.4.1, are complied with.  Radioactive aqueous liquid wastes may not contain any hazardous components and must be accumulated separate from non-aqueous wastes.

A tally sheet is recommended for each container to aid in keeping an accurate record of the total activity of the radioactive waste in the container. Liquid waste containers will be picked up for disposal by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). Prior to pick-up the container must be sealed, wipe tested for removable contamination, placed in a 4 mil plastic bag and securely closed with a twist tie or tape. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.

(iii) Non-Aqueous/Organic/Hazardous Chemical Liquid Waste

The generation of non-aqueous, organic, or hazardous chemical radioactive liquid waste is prohibited unless specifically authorized by the RSC. (Section 3.6 provides details on determining if a liquid radioactive waste that will be generated will contain hazardous properties/chemicals). If generation of this type of radioactive liquid waste is authorized, it must be accumulated separate from the aqueous radioactive wastes and in a non-breakable container not exceeding one gallon in capacity.  The waste container must prohibit the release of volatile radionuclides/chemicals, be properly shielded and be contained by a secondary containment vessel capable of holding the maximum volume of the primary container. The primary liquid waste container must have a “Caution Radioactive” label affixed to it  and it must be labeled as to:

  • Volume
  • Isotope
  • Activity
  • Chemical components ( all components of mixture with no abbreviations or chemical formula)
  • pH

Generators must ensure that incompatible compounds are not mixed together and that mixtures which may cause the release of volatile radioactive materials or gases are not created.

A tally sheet is recommended for each container to aid in keeping an accurate record of the total activity of the radioactive waste in the container. This type of waste must never be disposed of through the sanitary sewer system. Liquid waste containers will be picked up by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). Prior to pick-up the container must be sealed, wipe tested for removable contamination, placed in a 4 mil plastic bag and securely closed with a twist tie or tape.  Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.

(iv) Liquid Scintillation Waste

Radioactive scintillation wastes must be stored in the vials in which they are counted and placed in 4mil-lined waste containers (generally, in approved 5 gallon pails). Biodegradable, non-hazardous, high flash point liquid scintillation cocktails must be used unless specific authorization to use alternative cocktail is received from the RSO/RSC. Liquid scintillation wastes must be separated by isotope and by flash point (i.e. low flash point, <180oF,  from high flash point,  > 180oF). 

Liquid scintillation wastes containing 0.05 uCi/ml or less of C14 or H3 are considered de-regulated and must be segregated from radioactive vials. Scintillation wastes that cannot be differentiated from background (<2 x bkg) are considered to be non‑radioactive and must be separated from radioactive scintillation waste.

Tally sheets must be provided for each scintillation vial waste container and the container must be labeled with:

  • Flashpoint (>180oF or < 180oF)
  • Cocktail Name and Manufacturer
  • Total volume in milliliters
  • Isotope or “non-radioactive”
  • Total Activity

Radioactive, de-regulated and non-radioactive scintillation vial waste will all be picked up by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). All scintillation vial waste containers must be securely closed prior to pick-up and wipe tested for removable contamination. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.

(v) Vertebrate Animal Carcasses

Vertebrate animal carcasses and tissue containing radioisotopes must be separated by isotope. Any carcasses containing pathogens must undergo procedures necessary to neutralize the pathogen prior to disposal. Each carcass must be wrapped in absorbent materials and placed in individual plastic bags. Individually wrapped carcasses may be placed in large, 4 mil, transparent plastic bags, not to exceed 2 kg of total weight. Each bag must be labeled with:

  • Isotope
  • Total activity
  • Total weight of the carcass or tissue
  • Date
  • Supervisor’s name

Animal carcasses and/or tissue must be kept frozen at all times prior to disposal.  Since the University’s Radioactive Waste Storage Facility has a limited amount of freezer space,  radioactive animal carcass and tissue waste pick-ups will be scheduled with the generator as space allows. It is the responsibility of the generator to properly label, package and store carcasses until a disposal option or storage space is available.

Animal carcass waste pick-ups will be completed by Radiation Safety staff.  Prior to pick-up, the waste containers/bags must be securely closed and wipe tested for removable contamination. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.

Animal carcasses containing 0.05 uCi/gm or less of C14 or H3 may be disposed of as non‑radioactive. Records of the disposal indicating the assay of the carcass and the date and method of disposal must be maintained indefinitely.

(vi) Radioactive Sharps

All “Sharps” materials such as razor blades, needles, broken glass, syringes (with or without needle attached), etc., that are contaminated with radioactive material must be accumulated in a puncture proof container designated and labeled for radioactive waste only.  The sharps containers must be segregated by isotope, marked radioactive and labeled with the isotope, the activity and the date. Radioactive sharps waste containers will be picked up for disposal by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). The waste containers must be wipe tested for removable contamination prior to pick-up.  Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.  If the sharps waste contains any biological, pathogenic, or infectious material it must undergo procedures necessary to neutralize the biological hazard prior to pick-up for disposal.

3.3 Laboratory Waste Pick-ups

Laboratories may request a radioactive waste pick-up by phone (X-9130) or by completing a “Waste Pick-up” form and sending it to the Environmental Health and Safety Service Office. A “Waste Pick-up” form may also be completed on-line through the Environmental Health and Safety Service Office’s web pages (bfasweb.syr.edu/env_hlth). Radioactive waste pick-ups will be scheduled and completed by Radiation Safety staff.

Radiation Safety staff will perform the transfer of the radioactive wastes to the University’s Radioactive Waste Storage Facility. All radioactive waste must be tallied,  packaged and labeled in accordance with Section 3.2 of this Handbook, prior to arrival of Radiation Safety staff. All liners must be intact and securely closed with twist ties or tape.  Waste which requires special packaging or which does not fall into a specific category outlined in Section 3.2, must be packaged under the direction of Radiation Safety staff.

The generating laboratory must wipe test the radioactive waste container for removable contamination prior to pick-up and indicate the results of the survey on the reverse side of the waste container tag. Any removable contamination detected greater than twice background (>2x bkg/100 cm2) must be remediated to acceptable levels prior to pick-up. Waste container tallies and removable contamination survey results must be retained by the generating laboratory for a minimum of one (1) year.

At the time of pick-up, Radiation Safety staff will inspect the waste for radioactive labels, sharps, syringes, lead, etc. Wastes containing any of these materials will be refused for pick-up until properly removed by the generating laboratory. Radioactive waste tags will be completed for wastes which are found to be suitable for pick-up. These tags will indicate the contents of the waste container including isotope, activity, volume, waste form and generator. The generating laboratory will be requested to sign the waste tag to authorize that the waste information provided is accurate.

3.4 Radioactive Waste Disposal

The disposal of radioactive waste generated at Syracuse University will be accomplished by means of sewer disposal, decay in house or transfer to an authorized recipient. With the exception of sewer disposal, only Radiation Safety staff may dispose of radioactive waste.

Laboratories which generate radioactive waste must provide accurate information regarding the waste (i.e. activity, volume, contents) to Radiation Safety staff at the time of pick-up. This information will be used to ensure proper storage and disposal, for calculating decay dates, for manifesting, etc. Generating labs must prepare radioactive waste for pick-up in accordance with Section 3.2 of this Handbook. Details on requesting radioactive waste pick-ups are provided in Section 3.3 of this Handbook. No radioactive waste may be transported outside of a controlled area without the approval of the RSO.

All radioactive waste must be disposed of in accordance with this Section of the Handbook unless a written waiver is obtained from the RSO. Accidental releases of radioactive materials to the environment must be reported to the RSO immediately.

(i) Sewer Disposal

All releases of liquid radioactive waste to the sanitary sewer must comply with the following requirements:

  • Sewer disposal must be limited to one sink per laboratory and all sinks used for disposing of radioactive materials must be clearly labeled “Caution Radioactive Material Disposal Sink”.
  • Waste must be readily soluble in water.
  • Solutions may not contain any “hazardous” waste
  • Radioactivity concentrations must be diluted to one microcurie or less per liter during disposal.
  • The total annual release by any individual supervisor is limited to 25 mCi.
  • The total daily activity released by an RMS must be less than or equal to the limits listed below (contact Radiation Safety staff for assistance with disposing of isotopes not listed below):

Isotope           Activity(mCi)             Isotope           Activity(mCi)

C14                 015                               Na22                 0.025

P32                  010                               P33                    0.010

H3                    020                              Rb86                 0.015

I125                 005                              S35                    0.010

Tc99                 0.005

(ii) Decay-In-House (DIH)

Decay‑In‑House is the disposal method used for wastes containing short lived radioactive materials.  Short-lived radioactive materials are defined as isotopes with a physical half‑life of less than 90 days. Short-lived radioactive waste must be separated by isotope and waste type. All radioactive markings must be properly defaced or removed from all containers and associated trash prior to placement in disposal containers. DIH waste will be stored in the University’s Radioactive Waste Storage Facility for a minimum of 10 half lives. Once the waste has decayed to background levels, as determined by appropriate surveying methods, the material will be disposed via non-radioactive waste disposal methods. DIH disposal requires proper analysis and documentation and is limited to Radiation Safety staff only.

(iii) Transfer to Outside Recipient

Radioactive  wastes containing isotopes with half lives of greater than 90 days will be stored in the University’s Radioactive Waste Storage Facility. These wastes will be stored separately from DIH waste, by waste type. The storage and inventory of this waste will be under the direction of the RSO.

As disposal options become available, this waste will be packaged by Radiation Safety staff and transferred to an authorized recipient and/or disposal facility. The packaging of this waste for transport and subsequent disposal will be done in accordance with applicable rules and regulations.

3.5 Radioactive Waste Minimization

Radioactive material use laboratories must ensure that all practical steps are taken to minimize the volume of radioactive waste generated. The following steps are designed to assist in minimizing the volume of radioactive waste generated and must be implemented:

  1. Segregate all radioactive waste by isotope and physical form (liquid, solid, etc.).
  1. Substitute short-lived radioisotopes that can be decayed in storage (half‑life less than 90 days) for long-lived radioisotopes wherever possible.
  1. Consider alternative, non‑radioactive methods.
  1. Limit purchases to the minimum quantity needed.
  1. Employ volume minimizing techniques in your procedures.
  1. Handle radioactive materials carefully to prevent contamination.
  1. Carefully plan radioactive material use to avoid any unnecessary contamination.
  1. Verify that waste placed into radioactive waste receptacles is in fact radioactive.

3.6 Radioactive Wastes Which Require Special Attention

(i) Special Radioactive Wastes

Lead and other USEPA and State declared hazardous wastes are prohibited from land burial at current radioactive waste disposal sites. Other wastes, though permitted for disposal, must receive specific authorization from the disposal facility or authorized recipient prior to shipment for disposal. These wastes include the following:

  • Radium waste ‑ waste that contains radioactive radium
  • Gaseous waste ‑ wastes that are radioactive gas (i.e. Kr-85, Xe-133)
  • Acetates and nitrates of Uranium or Thorium
  • Special nuclear material ‑ radioactive materials such as:

Americium ‑ 241            Lithium ‑ 6                    Plutonium-242

Americium ‑ 243            Neptunium ‑ 237           Depleted Uranium-235

Berkelium ‑ 249             Plutonium ‑ 238            Enriched Uranium-235

Californium ‑ 252           Plutonium ‑ 239            Uranium-233

Curium ‑ 246                 Plutonium – 241

  • Waste which contain compounds or materials listed in N. Irving Sax’s Dangerous Properties of Industrial Materials as having a Thr=HlGH via any route except IP or IV

Radiation Safety staff must be contacted for assistance if any waste which requires special attention is encountered.

(ii) “Mixed” Wastes

Radioactive “Mixed Wastes” are radioactive wastes which contain hazardous chemical wastes as defined by the Resource Conservation and Recovery Act (RCRA ) or that exhibit RCRA defined hazardous waste characteristic(s). The production of long halflife (>90 days) radioactive mixed wastes is prohibited. If production of short halflife (<90 days) radioactive mixed waste is unavoidable in an experimental process, the process must be approved by the RSO/RSC prior to generation of the mixed waste. It is the responsibility of the Radioactive Material Supervisor to review all radioactive processes prior to commencement to assure that no long halflife “mixed” wastes will be produced. If a process is likely to result in a radioactive waste which contains contaminants that meet any RCRA defined characteristic or a chemical listed in the tables below, a non-radioactive “dry” run of the procedure must be initially performed with the waste properly analyzed to determine if the waste will indeed be RCRA hazardous.

(iii) RCRA Hazardous Waste Tables

RCRA hazardous waste identification information is found in 40 CFR Part 261 and 6 NYCRR Part 371. Radioactive waste generators are responsible for the proper determination of the hazardous characteristics of all waste generated. For more complete information regarding hazardous waste identification, refer to 40 CFR 261.

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