Summary of Radioactive Waste Requirements

 

2.1      How Do I Manage Radioactive Waste?

Radioactive waste must be characterized to facilitate on-site storage and off-site transportation, treatment, and disposal. To ensure that your waste can be managed safely at the Hazardous Waste Handling Facility (HWHF) and our off-site facilities, periodic Waste Management Bulletins are issued to advise you of any changes in waste-acceptance criteria.

In an agreement with the state of California, combined waste (radioactive waste that contains a chemical constituent regulated only in California) will be managed as low- level radioactive waste in the generator area. Pursuant to this agreement and by U.S. Department of Energy (DOE) Order 435.1, all radioactive wastes should be kept in the generator area no longer than one year. As long as the requirements listed below are met, there are no other generator requirements for management of low-level radioactive waste in the research or operations areas.

Below are the most common radioactive-waste categories and their descriptions, and their segregation, packaging, labeling, and pickup requirements. For other waste categories, please contact your Generator Assistant.

2.2      Radioactive Dry Wastes

Dry wastes include dry materials such as gloves, paper, empty containers[2], and plastic, rubber, cloth, wood, tools, etc., that are contaminated or activated with radioactive material. Radioactive sharps such as broken glass, needles, razor blades, Pasteur pipettes, or other glass or plastic that might break and pierce the skin must be placed in a rigid container and labeled “radioactive sharps” prior to placement in the dry-waste container. Further information on management of sharps waste can be found in the Medical/Biohazardous Waste Generator Guidelines.

Items prohibited from dry-waste containers include lead, any liquids, agarose or high-liquid-content gels, containers with liquids, mercury, printed circuit boards, lightbulbs, batteries, biological agents, hazardous chemicals, sealed sources, scintillation vials, or transuranic (TRU) waste (see Section 2.6, Miscellaneous Radioactive Wastes).

2.2.1     Segregation

There are no segregation requirements for dry waste other than the prohibited items listed above. It is not currently cost-effective to segregate the short-lived isotopes from long-lived isotopes.

2.2.2     Packaging

Most often, dry waste is collected in a plastic bag inside a radioactive dry-waste cardboard container (Figure 2-1). The cardboard container must be in your Radioactive Material Area (RMA). Place radioactive sharps in a labeled, rigid container prior to placing in the radioactive dry-waste container. Your dry-waste container must be closed at all times unless you are adding waste. Do not overfill containers; overfilling containers creates a safety hazard to those around you and to the technicians upon pickup, and may create potential contamination issues.

 

Figure 2-1. Dry-waste box.

2.2.3     Labeling

A radioactive-material tag (Figure 2-2) must be attached to the container once the first item is placed in the plastic bag. Sections A, F, and G of the tag must be filled out with the exception of the generator signature. If there is a possibility of contaminating the tag while adding waste to the container, you may post the tag nearby, but the container must refer to the tag number (e.g., R0XXXX) and be labeled with the words “Caution Radioactive Material” or the trefoil symbol. Contact your RCT for labels.

 

Figure 2-2. Example of a radioactive-material tag.    

       

In most cases, the radioactive dry-waste container receives multiple additions of waste over a period of time until it is full. In this case, a radioactive-waste accumulation log (Figure 2-3) is used to record these multiple additions of radioactive dry waste. Do not use the radioactive material tag to record multiple additions of the same isotope to the container.

Figure 2-3. Example of a radioactive-waste accumulation log for dry waste.

 

2.2.4     Pickup

When your dry-waste container is full, or is approaching one year from the accumulation start date, close the bag by twisting and taping the end (Figure 2-4). Complete the remainder of the radioactive-material tag by summarizing the isotopes (one entry for each isotope) and constituents (paper, plastic, glass, etc.) based on accumulation log entries for radioactive waste. Account for 100% of the constituents; estimates are acceptable. Do not add waste to the container after the requisition has been submitted.

Figure 2-4. Taped dry-waste bag, ready for waste pickup.

 

Fill out the radioactive/mixed-waste disposal requisition form (Figure 2-5). Fax a copy of the requisition form, tag, and accumulation log to the Waste Management Group at ext. 4838. After the waste review process, your waste will be picked up by technicians and brought to the HWHF, where it will be stored pending packaging for shipment.

2.3      Radioactive Liquid Waste

Radioactive liquid waste is any nonhazardous liquid containing radioactive material. Scintillation vials are not included in this category (see Section 2.4, [Scintillation Vials]).

Items prohibited from radioactive liquid waste include any hazardous chemical in a quantity or form that would make the liquid hazardous (contact your Generator Assistant for guidance).

Figure 2-5. Example of a completed radioactive/mixed-waste disposal requisition form.

 

2.3.1     Segregation

Radioactive liquid wastes with short-lived isotopes, e.g., <15-day half-life (³²P), should be segregated from isotopes with half-lives between 15 and 90 days (³⁵S, ¹²⁵I) and from long-lived isotopes (³H, ¹⁴C).

Decay-in-place storage. The Waste Management Group provides decay-in-place storage at the HWHF for liquids containing isotopes with half-lives <90 days. Once the waste has decayed through a minimum of 10 half-lives, and has been confirmed to have all isotopes below minimum detectable concentrations and to meet East Bay Municipal Utility District (EBMUD) sanitary sewer-discharge permit requirements, the waste is discharged into the sanitary sewer system at the HWHF.

Note: Some radioactive liquid waste (half-life of 15 hours) can be approved for decay and disposal via the sanitary sewer at the research bench. This activity must be specifically authorized by your Radiological Work Authorization (RWA). Contact your Health Physicist for more information.

2.3.2     Packaging

All radioactive liquid wastes must be stored in a container that is compatible with the waste and that has a tight-fitting lid and structural integrity. A variety of containers are available from various vendors. Some containers for accumulation of large volumes of liquids (30 gallons or more) are available from the Waste Management Group. If you have questions regarding the compatibility of your waste with the container, please contact your Generator Assistant.

All containers of radioactive liquid waste must be stored in your RMA and have secondary containment. As a best-management practice, secondary containment must be able to contain 110% of the liquids if the primary container leaks. For example, a 5-gallon liquid-waste storage container must have secondary containment capable of containing a minimum of 5.5 gallons of liquid even if there are only 2 gallons of waste in the container.

Accumulate radioactive liquids in an appropriately sized container. If your process generates a small amount of waste, do not accumulate the waste in a 5-gallon container. Use a smaller container and request a waste pickup more frequently. Conversely, do not overfill containers; this creates a safety hazard to those around you and to the technicians upon pickup, and may create potential contamination issues.

2.3.3     Labeling 

A radioactive-material tag (Figure 2-2) must be attached to the container once the first addition of waste is placed in the container. Sections A, F, and G of the tag must be filled out, with the exception of the generator signature. If there is a possibility of contaminating the tag while adding waste to the container, you may post the tag nearby, but the container must refer to the tag number (e.g., R0XXXX) and be labeled with the words “Caution Radioactive Material” or the trefoil symbol. Contact your RCT for labels. In most cases, the radioactive-liquid-waste container receives multiple additions of waste until it is full. In this case, a radioactive-waste accumulation log is used to record these multiple additions of radioactive liquid waste (see Figure 2-6). Do not use the radioactive-material tag to record multiple additions of the same isotope to the container. Use of the accumulation log is especially important for radioactive liquid waste that might contain chemicals only regulated by the state of California. This helps your Generator Assistant assure compliance with California regulations when the waste arrives at the HWHF.   

2.3.4     Pickup

When your liquid-waste container is full, or is approaching one year from the accumulation start date, tighten the lid on the container and don’t add further waste. Complete the remainder of the radioactive-material tag by summarizing the isotopes (one entry for each isotope) and constituents (buffers, etc.) based on entries in the accumulation log. Account for 100% of the constituents (estimates are acceptable). Fill out the radioactive/mixed-waste disposal requisition form (Figure 2-5). Fax a copy of the requisition form, tag, and accumulation log to the Waste Management Group at ext. 4838. After the waste review process, your waste will be picked up by the technicians and brought to the HWHF, where it will be stored pending packaging for shipment.

Figure 2-6. Example of a radioactive-waste accumulation log for radioactive liquid waste.

 

2.4      Scintillation Vials

Scintillation vials are typically 10–20 mL vials used in a liquid scintillation counter to measure radioactivity. Scintillation fluid is added to the vial prior to counting.

Note:  In recent months, we have discovered a regulated hazardous constituent in several batches of UltimaGold scintillation fluid (sold by Packard). When radioactive material is added at the research bench, this becomes mixed waste and will be charged to your project account. If you are using UltimaGold scintillation fluid, please contact your Generator Assistant for batches that do not have this problem, or seek an alternative.

2.4.1     Segregation

Significant cost-efficiency can be achieved if scintillation vials are segregated into the following groups:

1. Vials with radioactivity of ≤0.05 microcuries per mL per vial of ³H and/or ¹⁴C, and vials with isotopes with half-lives of <30 days with no other isotope
2. Vials with radioactivity of >0.05 microcuries per mL per vial of ³H and/or ¹⁴C, and vials with isotopes with half-lives of >30 days excluding alpha-emitting isotopes
3. Vials with alpha-emitting radioactivity

Used scintillation fluid such as Hionicfluor, Picofluor, and some batches of UltimaGold (see “Note,” above, in Section 2.4 [Scintillation Vials]) are regulated as hazardous wastes. Vials containing these scintillation fluids should be segregated from others.  Contact your Generator Assistant for more details.

2.4.2     Packaging

Scintillation vials are collected in a plastic bag inside a 12.2 gal container (see Figure 2-7). The container must be in your RMA. Tighten the screw caps of the scintillation vials prior to placing them in the waste container. The lid of the 12.2 gal container should be in place at all times unless you are adding vials to the bag. Do not overfill the plastic bag; overfilling creates a safety hazard to those around you and to the RCTs upon pickup, and may create potential contamination issues. Since the plastic bag is the waste container, the 12.2 gal container suffices for secondary containment. If you generate large quantities of scintillation vials and have room in your lab, you may request a 30 gal drum from Waste Management to collect scintillation vials.

2.4.3     Labeling 

A radioactive-material tag (Figure 2-2) must be attached to the container once the first scintillation vial is placed in the container. Sections A, F, and G of the tag, with the exception of the generator signature, must be filled out. If there is a possibility of contaminating the tag while adding waste to the container, you may post the tag nearby, but the container must refer to the tag number (R0XXXX) and be labeled with the words “Caution Radioactive Material” or the trefoil symbol. Contact your RCT for labels.

Figure 2-7. Scintillation vials are collected in a plastic bag inside a 12.2 gal container.

 

In most cases, the scintillation-vial container receives multiple additions of waste until it is full. In this case, a radioactive-waste accumulation log is used to record multiple additions of scintillation vials (Figure 2-8). Do not use the radioactive-material tag to record multiple additions of the same isotope to the container. Use of the radioactive-waste accumulation log is especially important, as virtually all scintillation fluids are regulated by the state of California. The use of the radioactive-waste accumulation log helps your Generator Assistant assure compliance with California regulations when the waste comes to the HWHF.

Figure 2-8. Example of a radioactive-waste accumulation log for scintillation vials.

 

2.4.4     Pickup

When your scintillation-vial container is full, or is approaching one year from the accumulation start date, close the bag by twisting and taping the end (Figure 2-9). Place the lid on the 12.2 gal container and twist it shut. Do not add waste to the container after the requisition has been submitted. Complete the remainder of the radioactive-material tag by summarizing the isotopes (one entry for each isotope) and constituents (type of scintillation fluid, lot number, etc.) based on radioactive waste accumulation log entries. Fill out the radioactive/mixed-waste disposal requisition form (Figure 2-5). Fax a copy of the requisition form, radioactive material tag, and accumulation log to the Waste Management Group at ext. 4838.

After the waste review process, your waste will be picked up by technicians and brought to the HWHF, where it will be stored pending packaging for shipment.

 

Figure 2-9. Twist-and-tape method of closure.

 

2.5      Animal Tissue

Radioactive animal tissue includes biological components such as animals, animal parts, or any biological cultures that might putrefy.

2.5.1     Segregation

Animal tissue with radioactivity of ≤0.05 microcuries per gram of ³H and/or ¹⁴C, and no other isotope, should be segregated from other animal tissue.

Animal tissue containing only isotopes with half-lives of <15 hours should be segregated from other animal tissue and held in the generator’s lab for a minimum of 10 half-lives. The Operational Health Physics (OHP) RCT will release the animal tissue for disposal in the pathological waste container.

2.5.2     Packaging

Animal tissue should be kept frozen and contained in clear, double-plastic bags (Figure 2-10). Radioactive animal tissue must be stored in your RMA. Tape or otherwise protect any sharp items such as claws. Do not overfill the bag. This creates a safety hazard to those around you and to the technicians upon pickup, and may create potential contamination issues.

Figure 2-10. Double-bagged animal tissue.

2.5.3     Labeling

A radioactive-material tag must be attached to the plastic bag once the animal tissue has been packaged. All sections of the tag must be completed.

2.5.4     Pickup

When your animal tissue is ready for pickup, fill out the radioactive/mixed waste disposal requisition form. Fax a copy of the requisition form and tag to the Waste Management Group at ext. 4838. After the waste review process, your waste will be picked up by the technicians and brought to the HWHF, where it will be stored pending packaging for shipment.

2.6      Miscellaneous Radioactive Wastes

The following wastes are generated infrequently. Contact your Generator Assistant for more information. All items must be stored in your RMA.

2.6.1     Empty Containers

Empty containers that are contaminated with radioactivity and that previously contained an acutely or extremely hazardous waste, such as arsenic compounds, cyanide compounds, beryllium compounds, cadmium compounds, or concentrated hydrochloric acid, must be managed as separate items. A separate radioactive-material tag must be filled out and attached to the container. Fax the tag and radioactive/mixed-waste disposal requisition form to the Waste Management Group at ext. 4838.

2.6.2     Manufacturer-labeled Chemical Compounds

Manufacturer-labeled chemical compounds such as tritiated thymadine, or radioactive compounds such as uranyl nitrate or thorium acetate, are considered radioactive waste even though these compounds were not altered at Berkeley Lab. A separate radioactive-material tag must be filled out and attached to the container. Fax the tag and radioactive/mixed-waste disposal requisition form to the Waste Management Group at ext. 4838.

2.6.3     Waste Containing Only Isotopes with Half-Lives Shorter than 15 hours (¹⁸F)

These types of radioactive wastes may be decayed for 10 or more half-lives in generator areas. The OHP RCT will survey and release the wastes. This must be specifically authorized by your Radiological Work Authorization (RWA). Contact your health physicist for more information.

2.6.4     Transuranic (TRU) Waste

TRU waste (i.e., waste with greater than 100 nCi/g of isotopes such as plutonium, americium, neptunium, curium, or californium) may be generated as long as the process by which it was generated can be tied to the United States’ defense mission. If you anticipate generating this waste, please contact your Generator Assistant, who will assist in gathering this documentation. If you have sealed or unsealed sources of TRU waste, please note the source information requirements below. All TRU sealed or unsealed sources should be weighed without any packaging and then placed in a single appropriately sized plastic bag.

2.6.5     High-Efficiency Particulate Air (HEPA) Filters

HEPA filters require gamma spectrometry of the filter, or a historical log of all radioisotopes and chemicals used while that filter was in place to assure accurate isotope characterization. Contact the Low Background Facility at ext. 5679 and your OHP RCT to schedule this service. These results and the radioactive-material tag and radioactive/mixed-waste disposal requisition form should be faxed to the Waste Management Group at ext. 4838.

2.6.6     Discarded Surface-contaminated or Activated Lead

Discarded surface-contaminated or activated lead is currently sent for macroencapsulation as mixed waste at an off-site facility. Small quantities of contaminated or activated lead (<10 bricks) should be individually double-bagged. Each bag must be labeled as hazardous waste, and a radioactive-material tag for all 10 bricks must be attached to each bag. Fill out a radioactive/mixed-waste disposal requisition form, and fax it to the Waste Management Group at ext. 4838. If you have larger quantities of lead, please contact your Generator Assistant.

2.6.7     Sealed Sources

Sealed sources are tracked by the OHP Group. Contact your RCT for information to remove your source from your authorization. Once this has been done, attach a completed radioactive-material tag to the container with the source, and compile the following 12 items of information about the source:

1.      Sealed Source Program tracking number, a.k.a., the “HC” number

2.      General description of the source

3.      Date of manufacture

4.      Name of manufacturer

5.      Physical and chemical composition of the source, including any backing material

6.      Method of sealing the radioactive material. For example, is the radioactive material electro-deposited onto a backing material, or is it encapsulated in something such as Lucite?

7.      Approximate dimensions of the source

8.      Type of shielding (if any). For example, is the shielding an integral part of the source? Is it required for ALARA concerns? Is the shielding contaminated?

9.      Weight of the source. Only the mass of the source itself, including any materials that are integral to the source and exclusive of associated packaging, should be provided. Shielding that is constructed as an integral manufactured component of the sealed source may be included in this weight.

10. Dose rate, particularly if the dose rate exceeds 5 mR/hr at the surface of the source

11. Whether the source is intact or leaking. If it is leaking, what is the contamination level? How is the leakage contained?

12. Any other information that may aid in the characterization of the source, e.g., radiological analysis results

Once you’ve completed the radioactive-material tag and the 12-item description of the source as listed above, fax them along with a radioactive/mixed-waste disposal requisition form to ext. 4838. This information is required by our off-site disposal facility. Sources less than 1 pCi will not be accepted as radioactive waste. Contact your RCT for further instructions. Lead as an integral part of the source is mixed waste, and requires appropriate labeling in addition to the radioactive-material tag.

2.7      Waste Review Process

When the Waste Management Group receives your radioactive-material tag, accumulation log, and requisition form, the information you’ve provided will be entered into our tracking system, and reviewed by your Generator Assistant for completeness and accuracy based on your Accumulation Log. Your Generator Assistant will assign the proper verification sampling, HWHF storage location, and waste stream  based on this information. Once the review is complete, the waste pickup will be scheduled. This process may take up to 10 days from the receipt of your requisition.

2.8      Quality Assurance Testing

Each item entering the HWHF is subject to random sampling. A computer-generated random-selection program chooses which wastes will be sampled for verification of the generator’s characterization. If laboratory analysis results indicate a discrepancy between the generator’s characterization and the analysis results, your Generator Assistant will contact you.