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Vanderbilt University Online Radiation Safety Policies & Procedures Manual
Table of Contents

PI's are responsible for ensuring that their staff is familiar with the rules and procedures governing the disposal of radioactive waste. All waste disposals must be accounted for on the accountability record that accompanies each order.

Radioactive waste is collected at the point of generation by VEHS and transported to the Hazardous Waste Management Facility. To request a waste collection, fill out the online "Radioactive Waste Collection Form" which can be found at www.safety.vanderbilt.edu or print it and fax it to 3-7036. The request must be received by 8:30 am to have the waste collected that same day.

Work involving radioactive materials should be carefully planned to minimize the volume of waste generated. Care must be exercised to separate radioactive waste from non-radioactive waste as it is generated. Non-radioactive waste must not be placed in radioactive waste container, as disposal of radioactive waste is very expensive.

Radioactive wastes must be stored only in restricted areas where they can be secured against unauthorized removal. Radioactive waste containers may not be left unattended in a corridor.

All receptacles for radioactive waste must be clearly labeled with an appropriate radiation warning sign.

Radioactive waste should not be allowed to accumulate in the lab. When a waste container is full, a waste collection request should be submitted to VEHS for quick removal.

If the radioactive waste contains gamma emitters or high-energy beta emitters, attention should be given to the location of the waste container in the laboratory to minimize radiation exposure of laboratory personnel. Additional shielding may be required.

Separate waste containers must be set up for short half-life and long half-life wastes. This will reduce waste disposal costs.

Normally, no charge is made to a PI for disposal of radioactive waste. All radioactive waste disposal charges will be billed back to the PI's school or major division (School of Medicine, VUH, Arts and Sciences, Engineering, etc.). However, if unusually large volumes or special procedures become necessary, the school might decide that the PI should bear the unusual charges.

Radioactive waste packaging procedures are complicated due to the license restrictions and cost structures of commercial radioactive waste disposal facilities. Specific waste packaging procedures are as follows:

1. VEHS inspects radioactive waste packaging at the time the waste is collected. If the waste is improperly packaged, then VEHS will not collect the waste. The PI is responsible for ensuring that the waste is properly packaged. If VEHS determines that there are violations of the waste packaging procedures, it is the laboratory's responsibility to repackage the waste.
    
2. Each waste container must have a completed waste disposal tag. Waste cannot be accepted by VEHS unless it has been properly identified and tagged. These tags are only available from VEHS and specific to the type of waste being generated (dry solid, liquid, biowaste, etc.). The tags can be requested on the Radioactive Waste Collection Form.
    
3. Solid and liquid radioactive wastes must be kept separate. The laboratory must have a waste container for dry solid waste and a container for liquid waste.
    
4. All dry radioactive waste must be packaged in a yellow, transparent bag with the radiation emblem on the outside. Waste contaminated with radionuclides with a half-life less than 90 days should be disposed in the large bags available from RPI. Incinerable waste contaminated with radionuclides with a half-life greater than 90 days should be placed into the small bags available only from VEHS (ask for them on your waste collection form). All non-incinerable waste bags must be securely sealed with strong tape and have a "Dry Solid" waste identification tag.
    
5. Radioactive syringe needles, broken glassware, and other sharps must be packaged in a sharps container, clearly marked for radioactive sharps only. Please tag radioactive sharps with the biohazard radioactive waste tag.
    
6. All glass should be packaged separately from other dry waste and put into a box with a completed dry solid radioactive waste tag.
    
7. Liquid waste containers must be in a non-degradable container and have positive fitting caps that must be kept closed. Containers of liquid waste must be tagged with both radioactive Liquid and chemical waste tags (both are available from VEHS). Liquid waste must be separated into aqueous liquid waste and chemical liquid waste. Liquid waste other than scintillation vials cannot be accepted in small vials or syringes. It must be emptied into a bulk liquid container. All liquid waste containers must be placed in secondary containment (a tub or enclosure that will catch any leakage from the bottle).
    
8. Sewer disposal is not to be used as a primary means of disposal; it should be limited to rinse water or the disposal of large volumes of low specific activity liquid. Liquid radioactive waste being disposed via the sewer must be readily soluble in water or biologically dispersible. Sewer disposal is limited to 0.2 mCi (7.4 MBq) per day per PI. Sinks used for sewer disposal must be designated for this purpose by VEHS and labeled as a "Radioactive Hot Sink". If a lab worker is uncomfortable with the process of pouring low specific activity down the drain, VEHS will collect the radioactive liquid waste for disposal.
    
9. Biodegradable scintillation cocktail should be used whenever possible. A list of biodegradable scintillation cocktails is maintained on the VEHS web site www.safety.vanderbilt.edu. If your experiment requires EPA-hazardous scintillation cocktail (solvent based), you will need to request an exemption from VEHS.

Scintillation vial/fluids must be separated into the following four waste streams:

• Biodegradable cocktail with short-lived radionuclides (<90 day half-life)
• Biodegradable cocktail with long-lived radionuclides (>90 day half-life)
• EPA-hazardous cocktail with short-lived radionuclides (<90 day half-life)
• EPA-hazardous cocktail with long-lived radionuclides (>90 day half-life)

Liquid scintillation vials do not have to be emptied into a bulk liquid container. Keep the vials in the original box and trays. If there are no trays, seal the vials in a radioactive waste bag and place it in a box.

9. Mixed waste is radioactive waste mixed with hazardous chemicals. These wastes are not accepted for disposal by most commercial disposal facilities; therefore, they are difficult and costly to dispose of. Non-hazardous chemicals should always substituted whenever possible. Plans for proper disposal of mixed waste should be made in the design stage of the experiment. This may require special approval by the Radiation Safety Committee. Mixed waste requires both a radioactive liquid waste tag and the pink hazardous waste tag.
    
10.  Radioactive waste containing infectious agents shall not be released from the laboratory unless it has been suitably deactivated.
     
11. Animal and tissue waste must be tagged with the Biowaste tag. The maximum weight of an animal carcass is 27 kg. For animal carcasses containing 3H or 14C, the maximum activity is 0.00005 mCi/gram (1.85 kBq/gram) of tissue. Disposal costs may be charged to the PI if activity is over this limit.
     
12. Special work hoods and exhaust systems must be used in operations involving the production of significant amounts of airborne wastes. Approval of the Radiation Safety Committee is required for these operations. Where maximum permissible concentrations may be exceeded, the investigator will be required to trap or otherwise limit the amount of airborne radioactivity released.