RPPM 7.0 Radioactive Waste Management

7.1 Introduction and general topic information

Radioactive waste management is a complex and highly regulated program.
There are more oversight agencies, both Federal and State; and more regulations and rules to interpret and follow than any other area in the Radiation Protection Program;
There are more licenses and permits to apply for and to maintain and the cost to the University for radioactive waste management is constantly increasing;
Radioactive waste management is the most costly and difficult to maintain support service managed by the Radiation Safety Office;
The categorization, management, handling, processing, transport and disposal of radioactive waste are all difficult and confusing topics.

Radioactive waste generation is a considerations during Authorization application review
The RSC considers all aspects of waste generation and management when reviewing and considering the approval of a radiation use Authorization application, whether for a new user or, an amendment or renewal of an on-going Authorization.
The following questions will be considered by the RSC during the review process:
- Is a radioactive waste minimization plan being implemented ?
- Will wastes be managed in a manner consistent with established procedures?
- Are there any potential public, occupational and/or environmental risks (e.g.- toxicity, carcinogenicity, pathogenicity, flammability) associated with the proposal ?
- What are the immediate and long term consequences to the University for the wastes that may be generated ?

Responsibilities and Methods of Disposal
The RSO radioactive waste management program takes possession and responsibility for the management of all radioactive wastes generated from radioactive materials held under the University’s Broadscope license.
By regulation and licensing conditions, the RSO cannot take possession or dispose of wastes that are created under, or generated from, another entity’s licensed materials.
No University staff or student is to bring radioactive wastes; stock materials or sealed sources; or equipment that contains radioactive material (i.e. – a sealed source) from another licensed institution or entity to a University location;
All transfers of licensed radioactive material that are to be included under the University’s licenses must be:
Initiated by the other entity (licensee) and that entity must have legal authority to possess the specific radioactive material and to transfer it to WSU;
Pre-approved by the RSO (i.e. – RSO will not approve a transfer of “legacy waste” from another licensee (i.e. – depleted source or recalled equipment);
Fully documented with regulatory-required notifications and records.
The primary methods of radioactive waste disposal available to the RSO include:
Release to the Sanitary Sewer, in compliance with State and Federal limits;
Release to Air , as regulated by the Federal Clean Air Act and the campus Air-Operating Permit(s) (AOP) and associated Radioactive Air Emissions License (RAEL);
Decay-in-Storage (DIS) , as a disposal methodology for short-lived, non- mixed wastes (stored for > 10 half-lives) and with documented assurance that the release meets regulatory limits for release to the normal waste stream (i.e. – municipal landfill);
Incineration (Pullman campus only) – as limited by State licenses + permits;
Sealed Source transfer to an alternate licensed recipient (i.e. – to manufacturer for recycling and/or disposal or transfer to a Federal oversight agency);
Transfer to a contracted, licensed waste broker for off-site disposal after compaction, bulking and packaging of low-level radioactive wastes (LLRW) or hazardous chemical waste disposal site.

7.2 Authorized User Management of Radioactive Wastes

Worker Training and Use of Personal Protective Equipment (PPE)
Protective clothing and the use of all assigned doismetry is required for all individuals participating in the handing of radioactive waste;
Radiation Workers assigned duties that involve radioactive waste management must receive AU-provided hazard and function specific training that addresses:
The specific hazards in the wastes (i.e. – radiologic, chemical, biologic, etc.) and the requirements for the use of appropriate handling and packaging protocols
The requirements and use of specific types of PPE;
Waste minimization and segregation protocols;
Required surveying, packaging, labeling and recordkeeping;
The preparation and scheduling for transfers of waste containers from the Authorization’s facilities to the RSO for final processing and disposal.
If requested by the AU, or if needed based on an RSO assessment of function specific technical knowledge and performance by radiation workers, the RSO will provide in-lab training in RAM waste management practices.

General Guidance for Management of RAM Waste in Labs
Radioactive waste is considered to be any waste that contains or is contaminated with radioactive material. Examples include:
Aqueous radioactive solutions
Liquid scintillation counting fluids and vials
Materials contaminated with radioactive material after inactivation of infectious agents, such as:
- Animal carcasses and excreta
- Experimental or spill clean-up materials, absorbent paper, gloves
- Veterinary patient care materials
- Plastic or glassware
Only contaminated items that cannot be easily decontaminated or stored-for-decay (maximum T1/2 < 90 days) are to be placed into RAM waste containers.
Glassware and equipment that is potentially contaminated but will no longer be designated for use with RAM should be surveyed and if contaminated, cleaned and rinsed (decontaminated) and re-surveyed.
When an item is verified to be non-contaminated (< 2x background), it may be released for non-RAM uses or disposed of through normal recycling or waste streams.
Prior to releasing glassware or containers (i.e. – secondary RAM stock containers or “pigs”) for alternate use or disposal, all RAM labeling and indicators must be removed or obliterated.
Proper segregation (sorting) of wastes is an essential component of a waste minimization protocol. Do not mix the following types of waste in the same radioactive waste container:
Liquid waste with dry waste;
Short half-life (< 120 days) with long (> 120 days) half-life wastes;
Waste containing chloroform or trichloroacetic acid (TCA) with any aqueous radioactive waste;
Aqueous solutions with liquid mixed wastes (radioactive material mixed with a hazardous or toxic chemical).
Radioactive wastes generated in labs or other approved facilities must be segregated upon their generation into properly labeled, standardized waste containers.
The common waste segregation categories are:
Solid Radioactive Waste
Liquid Radioactive Waste
Aqueous Liquid RAM Waste
Mixed Hazard Liquid Wastes (toxic chemical + RAM)
Unneeded RAM Stock Inventory and/or Sealed Sources that can be transferred to another Authorization that currently is approved for possession of the material and can use the stock material in a timely manner;
RAM-contaminated Items requiring special handling and that are not to be placed into dry solid waste disposal containers (see RPPM 10A; 10B and/or 10C):
Sharps, including broken glass;
Contaminated glassware (unbroken and potentially useable for RSM associated purposes;
LSC sample counting vials known to be contaminated;
Biological or putrifiable material that contains RAM;
Animal carcasses that contain RAM;
RAM contaminated and disposable or uncleanable animal cages;
Animal bedding that contains RAM.
All RAM waste storage containers (box, carboy, etc.) must be immediately labeled clearly and appropriately as RAM from the time they are first put into use for RAM waste storage. The information on the label must include:
Authorization (AU) name
Date of initial placement of RAM waste in the container
A listing of each radionuclide and the estimated activity of each radionuclide (in millicuries)
Storage location – building and room number.
Contact name (AU or lab supervisor) and laboratory phone number
Radioactive Materials Label, consisting of the radiation symbol (propeller) and the words “Caution, Radioactive Materials”.
- Alternatively, there must be no indication (labeling) on a container indicating the presence of radioactivity or RAM if the container does not contain RAM waste.
RSO-provided waste containers that are dedicated for the management of radioactive wastes are not to be used for any other purpose and must be stored appropriately prior to their use in a secure, restricted access area so they do not come into the possession of individuals who are not trained radiation workers.
In a shared-use facility, all workers must understand that a container labelled as radioactive waste must be secured and accessible only for use by radiation workers listed on the Authorization responsible for the container.

General Guidance for Storage of RAM Wastes in Labs
All stored radioactive waste containers must be secured in approved and posted RAM-use areas (secured from unauthorized access).
It is advisable to store radioactive waste containers away from the primary laboratory work area;
RAM waste storage locations are to be posted, restricted access areas that are surveyed monthly;
Surveys must be documented and records retained at the facility for inspection by auditors;
- If a waste container or storage area (floor) is found to be contaminated (> 2x background) the container or area of the facility must be decontaminated, re-surveyed and documented to be free of contamination;
The exposure (dose) rate in the waste storage area must be reduced to an ALARA level (i.e. – 2 mrem/hr) through the use of appropriate shielding and distance restrictions.

Specific waste management methods available to Authorized Users
- Decay-in-Storage (DIS) may be appropriate for some stored waste containers in some Authorization facilities (see RPPM 10.B).
Prior to an Authorization initiating a DIS protocol for any of their radioactive waste containers, the RSO waste program coordinator must be notified and must pre-approve the specific user’s DIS management protocol (RSO e-mail);
DIS wastes must be appropriate for ALARA and the radionuclide(s) and other hazards present in the wastes;
- Non-volatile materials and forms of radionuclides;
- Not in a chemical or physical form that would create a non-radiological hazard when stored on site;
- No radionuclides present in the waste with a half-life > 90 days.
The required storage interval must be at least10 times the longest half-life of the radionuclide(s) present in the container;
At the end of the required storage interval the container must be surveyed by a trained radiation worker using an appropriate radiation protection survey meter;
Records of the container contents and the release survey verification process must be maintained;
Prior to disposal as normal waste, all container labels that indicate the presence of radioactive material must be removed or obliterated from the waste containers.
Release of Aqueous Liquid RAM Waste to the Sanitary Sewer
Drain disposal of radioactive wastes by a RAM user or laboratory group is not allowed unless the release is appropriate with local and state regulations and pre-approved by the RSO:
An Authorized User may request pre-approval from the RSO for the disposal of a limited amount of aqueous-based liquid, non-alpha radioactive waste of low concentration via the sanitary sewer.
The Authorized User must contact the RSO waste management program coordinator (RSO email) to request and establish an RSO pre-approved protocol for the release of RAM to the sanitary sewer via a pre-designated and posted sink or drain;
A record must be maintained of all approved discharges of radionuclides to the sanitary sewer and a monthly record of the releases must be submitted to the RSO (see RPPM 10E)

NOTE: Due to the WA Department of Ecology designations of dangerous and hazardous chemicals, only three scintillation fluids are currently releasable to the sanitary sewer. AUs are advised to use one of the three products below to assure their scintillation waste will not be characterized as a mixed hazard waste:

Microscint-O
Perkin Elmer Life and Analytical Sciences
Optifluor
Perkin Elmer Life and Analytical Sciences
Ecoscint Original
National Diagnostics

Release of Radioactive Waste to Air
Release of volatile radioactive materials to the environment (air) at any University location is not allowed unless the release is appropriate with the locations Air Operating Permit (AOP) and Radioactive Air Emissions License (RAEL);
The only location and facility approved for limited, regulated incineration of RAM wastes, under the oversight of the RSO, is the Pullman campus incineration facility;
Some Authorized Users may be pre-approved by the RSO for specific and limited release of radioactive waste as a gas or aerosol that is produced due to a research process. All releases must be through a fume hood or other approved device, and must be planned and recorded.
An Authorized User must request pre-approval from the RSO (RSO email) for the disposal of a limited amount of volatile non-alpha radioactive waste of low concentration via release to the air;
The Authorized User must submit to the RSO a Summary of Radionuclide Disposals to the Air (see RPPM 10E) on a monthly basis estimating the quantity of the specifically-approved radionuclide(s) released;
The RSO waste management coordinator maintains a record of total atmospheric discharges/month at any specific University location to assure regulatory compliance.

Transfer of Radioactive Wastes to the RSO Radioactive Waste Management Program
Prior to initiating a radioactive waste pick-up the radiation worker must assure that the following activities have been completed (see RPPM 10B):
The radioactive waste container:
Is a standardized type and size appropriate for the waste(s) it contains;
Has been surveyed using an appropriate meter or swipe counting instrument (i.e. – LSC) and a record of the survey is available showing the container is free from radiological contamination (< 2x background);
Is not contaminated with other hazardous materials (i.e. – present on the outside of the container);
Is not damaged in any way and is sealed correctly.
A Radioactive Waste Receipt form (see RPPM 10B) for the waste container to be picked-up must be completed and available for RSO staff to pick-up with the waste container. The receipt form must contain the following information:
Authorized User under who’s Authorization the waste was generated;
Building/Room where radioactive waste is stored under the Authorization;
Type of waste (dry solid; scintillation vials; aqueous liquid; mixed liquid (chemical with RAM) in the container;
Radionuclide(s), chemical form, and activities of each in the waste container;
Chemical form of the radionuclides and chemical components in the waste in the container;
Radiation worker preparing the receipt and container for RSO pick-up;
Any known non-radiological hazards in the waste or other complicating conditions.
Radioactive waste pickups are requested by submission of an on-line waste pick-up request form (RPPM 10E). The following information must be provided on the pickup request:
Name and phone number of person submitting the request form;
Name of Authorized User (P. I.);
Location (building name and room number) of waste containers;
Type, number and size of waste containers to be picked up along with the size and number of desired replacement containers needed;
If special arrangements must be made to pick up waste (i.e. lab is occupied only at certain times, etc.), please include this information under comments on the waste pick-up request e-form.

NOTE: Plan and allow 5 business days for the RSO pickup to be completed once the request has been submitted. If other arrangements are needed, submit an explanatory email from a University email address to the RSO (RSO email) in addition to submitting the pickup request.

Certain radioactive wastes require special handling and disposal arrangements.
Further guidance for the management and disposal of special waste groups can be found on the RSO webpage (www.rso.wsu.edu/) or in RPPM 10B.

The types of radioactive waste that require special handling include:

Biohazardous wastes that are contaminated with radioactive material;
Sharps and full sharps containers (glass pipettes, broken glass, needles and any other small sharp items);
Carcasses and animal bedding from animals administered a radiopharmaceutical or other radioactive material;
Filtration materials (HEPS, charcoal, etc.) that is known or that has potential to be contaminated with radioactive material;
Equipment or facility components (i.e. – sink or part of a bench top) that has been contaminated with a long-lived radionuclide and cannot be decontaminated. NOTE: Large or dense items must not be placed into a dry waste box ! Such items could easily damage equipment and injure workers during waste compaction activities. Notify the RSO waste management coordinator for special disposal requests (radsafe.wsu.edu) for all non-standard contaminated objects.
Certain non-radioactive waste categories associated with ionizing radiation require special processing:
Lead in the form of leaded stock vial containers or sheeting used for shielding (contact Environmental Health and Safety (http://ehs.wsu.edu/) for disposal guidance;
Non-contaminated, disposable or recyclable materials that bear radiation hazard warning labels or statements (i.e. – boxes labeled CAUTION RADIOACTIVE).

When a radiation worker has surveyed the item and knows it is not contaminated (< 2x background), all RAM or radiation related labeling must be removed or obliterated prior to placing such items into normal waste streams or into an alternate use.

Many waste streams contain more than one hazard.
Contact EH&S for assistance with chemical waste questions;
Contact the Biosafety Officer for assistance with biological hazard questions.

7.3 Audits of radioactive waste generation, management and disposals

The RSO monitors and audits all safety requirements and processes involving the management of radioactive wastes at all active radiation use and storage areas on a routine basis;
The RSO staff will immediately notify and AU and the URSO if radioactive waste is:
Considered to be in excess of that expected for the approved use;
Not stored in a clean, secure area;
Not routinely surveyed and maintained in an uncontaminated or controlled-hazard status;
Not being managed within acceptable guidelines.