Radioactive Waste Disposal Fact Sheet

FACT SHEET #13

March 2004

Revision: Sixth

NORTHEASTERN UNIVERSITY PROCEDURE FOR DISPOSAL OF

LOW-LEVEL RADIOACTIVE WASTE

DEFINITION. Low-level radioactive wastes (LLRW) have been typically defined more by what they are not than what they are. The Federal definition for LLRW is: Radioactive material that
- is neither high-level waste, nor spent nuclear fuel, nor by-product material as defined in section 11(e)(2) of the U.S. Atomic Energy Act of 1954, as amended, 42 U.S.C. s.2014(e);
- is classified by the Federal Government as low-level radioactive waste, but not including waste which remains a Federal responsibility, as designated in s.3(b) of the Low-Level Radioactive Waste Policy Act, as amended, 42 U.S.C./ s2021c(b), as in effect as of December 8, 1987. For waste generated at Northeastern University this definition can be simplified by breaking down LLRW into four categories which include:
LIQUID SCINTILLATION FLUIDS. There are two categories of waste with the disposal of liquid scintillation fluids (LSF). The two must be kept separate for purposes of disposal. Vials or bulk quantities of LSF or organic solvents containing radionuclides other than H-3 or C-14, with activities of less than 0.05 uCi/ml are considered regulated LSF, and as such are considered radioactive. Vials or bulk quantities of scintillation fluid or organic solvents containing only H-3 and C-14, with activities less than 0.05 uCi/ml are considered deregulated LSF, and may be handled as a chemical waste. Whether this material is handled as a chemical or radioactive waste, the quantity cannot exceed 0.05 uCi/ml. Higher quantities must be diluted down to appropriate concentrations.

Regulated LSF: Vials must be tightly capped and transported in their original boxes, or double contained, using two clear 4 mil poly bag contained within a secondary container, such as 5 gallon buckets.
Deregulated LSF: Bulk scintillation fluids, or other solvents containing only H-3 and C-14 having an activity of less than 0.05 microcuries per milliliter will only be accepted if contained in a gallon or smaller container (vials) with a screw cap. Other containers must be approved by the Office of Environmental Health and Safety (EH&S). If the scintillation fluids are contained in vials they must be brought to room 310C Mugar in the same manner as the regulated LSF. Those in larger containers must be handled through the hazardous "chemical" waste program. These containers must be labeled with a hazardous waste sticker and have all labels and references to radioactivity removed prior to disposal. A fact sheet for disposal of hazardous "chemical" waste is available at the Office of Environmental Health and Safety.

AQUEOUS MATERIALS. Aqueous radioactive wastes which are readily soluble (or is readily dispersible biological material) in water may be disposed of in the sanitary sewerage system. This method is allowed providing that disposal concentration limits outlined by the Nuclear Regulatory Commission in 10 CFR 20.2003 are not exceeded. All sinks that are used for the disposal of radioactive aqueous materials are labeled and posted with log outlining disposal concentration limits. Due to the current limited availability of LLRW disposal facilities for this material, EH&S encourages laboratory workers to utilize this method of disposal if you can stay within the disposal limits. In order to insure that all authorized principal investigators do not exceed the total sanitary disposal limits specified by the Nuclear Regulatory Commission, the Office of Environmental Health and Safety (EH&S) will inspect these sink disposal logs on a quarterly basis. In addition, EH&S will continue to monitor radionuclide purchases and the disposal methods planned with their use, as a second mechanism to avoid exceeding NRC disposal limits. Surplus residual levels of stock materials must be monitored carefully because of their potential high activity. This material includes original containers from radioactive material suppliers and stock solutions made up by laboratory personnel. If disposal limits cannot be maintained, the material is not readily soluble (or is readily dispersible biological material), or it has a half-life of 65 days or greater, then notify EH&S for specific guidance on how to manage and dispose of this material. If the material has a half-life of less than 65 days then it may be stored for decay for 10 half lives untill it is no longer radioactive or it can meet disposal limits. The radioactive waste processing room located in 319A Mugar has available plastic containers to collect aqueous waste unsuitable for a sink disposal and can be decayed. Designate the plastic container by labeling it with a radioactive waste receipt tag, indicating the specific radionuclide to be collected. Only one radionuclide may be collected in any one container. Plastic containers for decay storage may be obtained during designated radioactive waste disposal hours in room 310C Mugar.
SOLID MATERIAL. Solid wastes includes such things as gloves, bench paper, glassware, and other contaminated materials. Solid waste cannot contain more than 0.05% by volume of free standing aqueous liquid. Excess aqueous liquid must be collected or be put down the sink as specified in section 3 above. Solid waste also must not have any liquid scintillation vials containing liquid scintillation fluid. Sharps are considered solid material and must be transferred into sharps containers and never put directly into a bag. Sharps include the following: hypodermic needles and syringes, pasteur pipettes, broken medical glassware, scalpel blades, disposable razors, and suture needles. Sharps handled as radioactive waste must not have any of the other characteristics of infectious waste as defined in Northeastern University's policy for Infectious Waste Disposal. If they do, then this material must be treated (e.g. chemical, autoclave) before disposal as a radioactive waste. All treatment methods must be approved by EH&S, as some could result in the volatilization of vapors containing radioactivity. All solid material must be segregated by type of radionuclide in order to allow for proper waste management. This can be accomplished by using separately labeled bags or dedicating disposal containers for only one radionuclide. Laboratory personnel anticipating difficulty meeting this requirement must contact EH&S. Waste containers or bags identified to be containing more than one radionuclide will be evaluated by EH&S for appropriate waste disposal. Solid material that have been mixed and can not meet decay-in-storage requirements will be disposed of with solid material with a half-life of 65 days or more identified in item "b" below. Three categories of solid material are identified below:

DECAY STORAGE WASTE. solid materials with a half-life of less than 65 days. This material must be allowed to be stored for 10 half-lives and until the waste can no longer be distinguished from background. By using this waste management practice, laboratory personnel are then able to dispose of this material as ordinary rubbish. OEHS encourages laboratories to manage waste in this manner in their own laboratory. If laboratories do not have sufficient storage room then EH&S can provide limited decay storage in 310C Mugar waste processing area or in the radiation waste storeroom located in 29 Hurtig Hall. All waste put into decay storage must have all radioactive warning labels torn off, defaced, or painted with a spray can or marker so that they can not be identified. When the material has been stored for the required decay time (minimum of 10 half lives) the waste must then be extensively surveyed to ensure that radioactive content is not significant. If the count rate is not distinguishable from background then waste can then be "deregulated" and disposed of as ordinary rubbish. If you do decay storage yourself, a decay storage record must be returned to the EH&S and the copy kept on file in your records. Complete the waste disposal receipt identified in item "12" below.
SOLID MATERIAL WITH A HALF-LIFE OF 65 DAYS OR MORE. This material is not allowed to be stored for decay, but instead must be regularly brought to the 310C Mugar waste processing area for disposal during designated waste room hours.
SULFUR-35 DECAY-IN-STORAGE. Sulfur-35 will also be decayed-in-storage but will require special procedures because of its longer half-life and the greater difficulty in monitoring. All Sulfur-35 solid material must be brought to the 310C Mugar waste processing area for proper decay-in-storage management by EH&S. Principal investigators will not be allowed to decay this material themselves. The reason for this is that the waste processing area in 310C Mugar and the extended interim storage area in 29 Hurtig Hall meet or exceed all Federal and State requirements. This centralized processing and interim extended storage is more efficient than having many such sites on campus. Sulfur-35 will be monitored with a Ludlum G-M meter using a 44-88 probe. Waste found to be distinguishable from background after ten half-lives will be stored for an extended period until no longer distinguishable from background. All other procedures identified for Decay Storage Waste in item "a" above will be utilized for Sulfur-35. The waste disposal receipt identified in item "12" below will be utilized for Sulfur-35 decay-in-storage.

ANIMAL CARCASSES. Animal carcasses are broken down into three categories.
- Animal carcasses containing H-3 or C-14 in less than 0.05 uCi/gm quantity have been deregulated by the NRC. This means that animal carcasses containing this quantity or less of this material may be disposed of without regard to their radioactivity. Animal carcasses are to be bagged without any radioactive material labels and disposal must be coordinated through the Research Management Animal Facility.
- Animal carcasses containing H-3 or C-14 in greater than 0.05 uCi/gm quantity, or other radionuclides with a half-life of 65 days or greater have special disposal requirements. It is important that generators of this waste contact OEHS prior to any generation of this material. The current restricted disposal access for the Commonwealth of Massachusetts may not allow for the disposal of this material. Disposal at the current commercial facilities involve extensive preparation prior to disposal. The Office of Environmental Health and Safety will assist generators with all stages of preparing this waste stream for disposal.
- Animal carcasses containing radionuclides other than H-3 or C-14, with a half-life of less than 65 days may be decayed in your freezer if it has been approved by EH&S. These animal carcasses like other deregulated material must be stored for the ten half-lives necessary for it to become a non-radioactive waste. After they have been surveyed and all radiation designations have been removed, they may be turned over to the Research Management Animal Care Facility for appropriate disposal.
MIXED WASTE. Mixed wastes are wastes that contain both a radioactive and hazardous (e.g. flammable, corrosive, toxic, reactive, or listed) component. These wastes are not allowed to be produced at Northeastern University. Two exceptions to this requirement are as follows:

If the radioactive components are H-3 or C-14 with less than 0.05 uCi/ml and they are mixed with a organic solvent. This material is allowed to be disposed of as a hazardous "chemical" waste.
The radioactive component has a half-life of less than 65 days, and the material can be decayed in your laboratory for the 10 half-lives necessary for it to become solely a hazardous "chemical" waste. This material must not be designated a hazardous waste until the end of 10 half-lives and is indistinguishable from background. During the decay period, the material must be labeled as a radioactive material. Following the appropriate decay period all radioactive labels must be removed and a hazardous waste label put in its place.

LEAD PIGS. Lead pigs are prohibited from being disposed through the radioactive or solid waste stream because of their toxic characteristic. This makes it necessary for them to be handled as a hazardous "chemical" waste, as outlined in the Northeastern University Procedure for the Disposal of Hazardous Waste. Lead contaminated with radioactive material is considered a mixed waste and must either be decontaminated or allowed to decay until no longer radioactive. Following appropriate decontamination efforts or storage for decay, all radiation labels must be defaced or removed, and a hazardous waste label put in its place. EH&S should then be contacted to have this material removed as a hazardous chemical waste. EH&S will make efforts to recycle these lead pigs prior to disposal as a hazardous chemical waste. Please contact us if you need any for shielding purposes.
DISPOSAL SCHEDULE. The Office of Environmental Health and Safety has set-up a waste processing area located in room 310C, Mugar Life Science Building. Generators of LLRW may bring their waste to this location during designated waste room hours. Currently this room is open to receive waste between the hours of 10:30 and 11:30 AM on Tuesday, and 2:30 and 3:30 PM on Thursday. In the event that the University is closed due to inclement weather or other reason the waste processing area will also be closed and will reopen on the next scheduled date.
APPROPRIATE CONTAINERS. Low-level radioactive waste must be brought to room 310C Mugar waste processing area in the yellow 5 gallon buckets approved by EH&S. This includes solid, liquid scintillation fluids and bulk aqueous wastes. Clear bags must be used to line all buckets and are available through EH&S. Bags must be sealed with tape or tied closed and the cover to the bucket must be closed at all times during transport. Because of the tendency of liquid scintillation vials to leak if they are not closed tightly, we require that they be accumulated and transported in the yellow bucket that has been double bagged (if vials are not double bagged, waste will be rejected). Liquid Scintillation Vials may also be brought down in the boxes that they come shipped in if they are organized so they are not laying on their side or upside down where they could leak.
STORAGE AND ACCUMULATION. All waste must be stored away from aisles and heavy traffic areas in designated areas. Lids must be kept on the buckets and waste must not be allowed to overflow. If contents of the bucket result in a significant radiation field then workers in the lab should make arrangements for additional shielding. During storage and accumulation of waste, a waste disposal tag must be left on top of the bucket, with a notation of the radionuclides that are being accumulated in it.
WASTE RECEIPTS. All Waste brought to the 310C Mugar waste processing area must have a waste receipt completely filled out and brought down with the bucket prior to it being accepted at this facility. All requested information on the tag must be filled out. At the time of acceptance of the waste you will be given a copy of the tag which you should keep with your other radiation records. Please do not put the tags inside the bucket because they could become contaminated in there and EH&S personnel must handle them at a later time when completing disposal paper work. Laboratory personnel doing their own decay-in-storage must return these tags to EH&S following proper disposition of the waste.
INSPECTION OF WASTE. Waste brought to the 310C Mugar Waste Processing area will be inspected at the time of receipt. This inspection will include reviewing the tag for accuracy, assuring disposal buckets and bags are properly sealed, and finally checking the contents of the bucket to insure they go along with what is designated on the tag. Waste with half-lives less than 90 days must have all radiation symbols defaced. If this inspection determines a problem with the waste, then the waste will be returned to the generator, so the problem with the waste can be corrected. After the waste is received it will undergo a second inspection at the time EH&S transfers it into a shipping drum. If at this time a problem with the waste is found that is related to the generator, then the waste may be returned to the generator to be corrected.
WASTE MINIMIZATION. The U.S. Congress has made waste minimization a national policy and goal of each waste generator. You as a user of radioactive material have the responsibility to minimize the waste you generate. Waste minimization has benefits such as decreasing your exposure to ionizing radiation, protection of the environment, and the overall reduction in the cost of disposal, which we continue to see rise significantly because of the limited access to disposal sites that exists today.

IF YOU HAVE ANY QUESTIONS OR WOULD LIKE ASSISTANCE WITH IDEAS FOR WASTE MINIMIZATION, PLEASE CONTACT THE OFFICE OF ENVIRONMENTAL HEALTH AND SAFETY AT x2769.

Office Of Environmental Health & Safety

Radioactive Waste Disposal Fact Sheet