Introduction

The University of Michigan - Department of Occupational Safety & Environmental Health (OSEH) will collect and process the various forms of radioactive waste generated at the University of Michigan provided the waste is properly segregated, packaged and identified according to the methods detailed in this brochure.

Disposal of the various forms of low-level radioactive waste (LLRW) is complex, extremely difficult, and very costly. Waste minimization and segregation are critical to reducing costs, ensuring regulatory compliance, maintaining a safe work place, and protecting the environment. All radioactive waste generators must adhere to the waste minimization and waste segregation guidelines established by OSEH.

Failure to adhere to the segregation and disposal procedures outlined by OSEH will result in:

1. Radioactive waste being returned to the laboratory of origin for repackaging

OR

2. Laboratory personnel repackaging the radioactive waste at OSEH.

Thank you for your cooperation in complying with the following OSEH protocols for the proper segregation and disposal of radioactive wastes at the University of Michigan. Please contact Occupational Safety and Environmental Health (3-4568) should you have any questions regarding these protocols.

General Guidelines for LLRW

• Ensure compliance with Low-Level Radioactive Waste (LLRW) Manifest (refer to page 10).
• Only OSEH can dispose of LLRW generated at the University of Michigan.
• Employ waste minimization techniques at all times.
• Maintain a record of each radionuclide, activity (MicroCurie), any chemicals constituents, and the date each radionuclide is placed into an OSEH-approved waste container. NOTE: Radionuclide activity estimates must be accurate (within an order of magnitude).
• Inform OSEH prior to collection if contact exposure rate on a waste container exceeds 50 mrem/hour.

LONG-LIVED ISOTOPES ( > 90 days half-life)
CATEGORY A	H-3 and/or C-14
CATEGORY B	Na-22, Cl-36, Ca-45, Co-57, Co-58, Fe-59, Co-60, Ni-63, Sr-90, Tc-99, Sn-113, and/or Cs-137, etc. (excluding H-3 and C-14)
INTERMEDIATE-LIVED ISOTOPES ( > 14 days - Less than or equal to 90 days half-life)
CATEGORY C	S-35, P-33, Sc-46, Cr-51, Sr-85, Rb-86, Ru-103, and/or Ce-141, etc.
CATEGORY D	I-125, P-33, Sc-46, Cr-51, Sr-85, Rb-86, Ru-103, and/or Ce-141, etc.
SHORT-LIVED ISOTOPES ( < 14 days half-life)
CATEGORY E	P-32, C-11, F-18, Na-24, Br-82, Y-90, Nb-95, Tc-99m, In-111, I-131, and/or Tl-201, etc.

USE A SEPARATE CONTAINER FOR EACH CATEGORY

*OSEH may require further segregation as necessary for safe handling.

Solid LLRW

Solid radioactive wastes generally should consist of dry contaminated laboratory materials, equipment, and supplies such as paper, unbroken glass, and plastic products.

OSEH provides 7.5 gallon and 28 gallon yellow fiber drums for solid low-level radioactive waste (LLRW) disposal.

Segregate solid radioactive wastes by radionuclide(s). Please see the Table of Acceptable Segregation Categories for LLRW. (Use a separate drum for each category).

GUIDELINES FOR SOLID LLRW

• Ensure yellow fiber waste drum is lined with large plastic bag prior to discarding solid wastes into fiber drum.
• Affix completed Container Label to the designated location (i.e. vinyl label) on upper side of the large yellow fiber drums (lower side of small fiber drums) immediately upon calling in for waste pick-up.

Low-Level Radioactive Sharps

By definition, sharps are those objects which represent a puncture or laceration hazard. Such objects include, but are not limited to, the following: Syringe needles (capped or uncapped), razor blades, scalpel blades, xacto knife blades, sharp metal objects, capillary pipettes, and broken glass objects.

All radioactive sharps MUST be disposed of into either 5-gallon plastic white buckets (available from OSEH), sealed plastic bottles, or other approved sharps containers.

NOTE: Cardboard boxes are no longer acceptable for sharps containment.

The containers must be securely closed (i.e. snapped in place) so that there will be no leakage of radioactive material under conditions normally incident to transportation.

OSEH will provide 5-gallon plastic buckets to your laboratory for SHARPS ONLY. Please DO NOT discard other forms of hazardous or low-level radioactive wastes into these buckets.

Segregate radioactive sharps by radionuclide(s). Please see the Table of Acceptable Segregation Categories for LLRW. (Use a separate bucket for each category).

To avoid potential injury to OSEH-Hazardous Material personnel, sharps are NOT to be placed into the OSEH yellow radioactive waste fiber drums for disposal. Sharp objects discovered in the yellow fiber drums will result in the fiber dorm being returned to laboratory of origin for proper segregation and repackaging.

NOTE: Place Container Label around handle of bucket and affix the two adhesive ends together.

Liquid Scintillation Vials

FILLED LIQUID SCINTILLATION COCKTAIL (LSC) VIALS

OSEH will collect filled or partially-filled liquid scintillation vials containing OSEH-approved non-hazardous or biodegradable scintillation fluid provided the vials are sorted, packaged and prepared according to the methods described below. (Contact OSEH to obtain a current list of acceptable non-hazardous or biodegradable scintillation fluids).

NOTE: Toluene and xylene-based scintillation fluids are prohibited from use at the University of Michigan unless authorization has been received from OSEH.

EMPTY LSC VIALS

• Oseh will collect empty scintillation vials as well as filled vials.
• Indicate activity as < 10 MicroCurie when requesting collection of empty vials.
• Use the vial disposal procedure detailed below to dispose of empty and full scintillation vials.

I. Segregate vials by radionuclidic content

Please see the Table of Acceptable Segregation Categories for LLRW. (Use a separate box for each category).

II. Segregate vials by type: Glass or Plastic

DO NOT mix plastic or glass vials in same box or tray.

NOTE: OSEH recommends the use of glass vials as opposed to plastic wherever possible.

GUIDELINES FOR LIQUID SCINTILLATION VIALS

• Ensure scintillation vial caps are fastened securely and not leaking prior to packaging in trays and boxes.
• Store vials within the cardboard vial flats (trays).
• Insert absorbent material or pad in base of original vial box.
• Pack vial flats containing scintillation vials into box.
• Seal box securely with tape. (Use lab, duct or making tape).
• Record on the top of all boxes of LSC vials either Plastic or Glass.
• Ensure boxes of scintillation vials are not saturated or leaking scintillation fluid prior to OSEH collection. OSEH may choose not to accept severely saturated boxes of vials. This determination is based on the discretion of OSEH personnel.
• OSEH may choose not to accept boxes of vials phoned-in as less.
• than or equal to 1,000 MicroCurie.
• Affix Container Label to top of LSC vial box.

DO NOT

• dispose of commercially prepared liquid scintillation standards with other scintillation vial wastes. (Note: request a special collection).
• discard scintillation fluid or radionuclides down sink drains.
• tape the tops of scintillation vials.
• discard other forms of radioactive waste (eg. gloves, syringes, paper, pads, etc.) in with vials.
• discard scintillation vials (empty or full) into yellow fiber waste drums.
• discard "hot" commercial stock vials with scintillation vials.
• use radioactive material tape to seal boxes of scintillation vials. (Note: use lab, masking or duct tape).

Stock Vials

Stock vials are glass or plastic vials which hold the concentrated radioactive isotope(s) originally given to authorized users.

Stock vials must be properly packaged in sturdy boxes containing sufficient absorbent padding to inhibit shifting of contents and to soak up any potential residual liquid spills.

NOTE: Please ensure stock vials are sealed securely.

Affix Container Label to top of box.

Lead Segregation and Disposal

OSEH will collect lead/leaded objects (e.g. lead pigs, sheet lead, lead bricks, etc.) for disposal.

Lead pigs must be placed in a sturdy box, taped securely shut, and marked "LEAD PIGS". This also includes lead impregnated objects, such as the plastic containers that New England Nuclear uses to ship stock vials in.

All lead objects must be smeared for removable contamination and, if necessary, decontaminated prior to collection.

It is not necessary to manifest lead objects for disposal, however, the lead objects must be placed with any other radioactive waste awaiting collection. Please request a special pick-up if you have lead bricks and/or sheet lead you wish to dispose of.

Pathological Radioactive Waste Packaging and Disposal

Pathological radioactive wastes include: contaminated animal carcasses, organs, blood, tissue, urine, feces, bedding, etc.

GUIDELINES FOR PATHOLOGICAL RADIOACTIVE WASTE

• Pathological wastes must be completely frozen to be accepted by OSEH personnel.
• Remove all sharps (e.g. needles, razors, scalpels, etc.) and metallic objects from carcasses before freezing and subsequent OSEH collection.
• Radioactive blood, tissue, urine, etc. must be made innocuous or rendered non-toxic prior to OSEH collection (e.g. bleach, detergent, other methods). WARNING: Radioiodines or other volatile radionuclides may become airborne when bleach is added.
• Double-bag animal carcasses in strong (4 mil) plastic bags.
• Outer bag or wrapper should be a yellow opaque bag available from OSEH.
• Contact OSEH for authorization to use walk-in freezers located in: MSRB-I (Rm 2501), MSRB-II (Rm A592) and Kresge II (Rm 3007). Key-use required for entry.
• OSEH must be notified in writing should an Authorized User desire to store radioactive pathological material in an animal freezer under the authorization of another individual or department.
• Contact OSEH if a radioactive storage freezer is filled to capacity, breaks down, or otherwise becomes ineffective in completely freezing animal carcasses, blood, etc..
• Label the outer yellow carcass bag or attach OSEH-provided waste tag with the following instruction: radionuclide(s), activity of each radionuclide (MicroCurie), chemical or biohazardous material (if applicable), date packaged, description of waste (e.g. rats, dog, mice, pig, bedding, blood, feces, etc.), names of contact person and Authorized User, and phone number(s).

DO NOT

• dispose of plastic cages as pathological waste. (Note: empty contents of animal cages into pathological waste bags or 4 mil thick plastic bags and decontaminate cages.
• discard pathological wastes into yellow waste drum.
• freeze pathological wastes in glass containers. (Note: use plastic only).
• discard metal objects (e.g. needles, scalpels, cans, etc.) with pathological material or animal carcasses.
• discard (greater than or equal to 5.0 mCi of I-125 and/or I-131 in a single bag or container of pathological waste.

Radioactive Contamination and Exposure Control for Waste Containers

Removable radioactive contamination on the exterior of all LLRW containers shall be kept as low as practicable.

Laboratory personnel are responsible for:

1. Testing for the presence of external contamination on all waste containers;
2. Removing contamination from the exterior of all waste containers to the limits in the table on the following page;
3. Maintaining a copy of all records of smear test results;
4. Informing OSEH prior to collection of waste if contact exposure rate on any waste container exceeds 50 mrem/hour.

TABLE 10--REMOVABLE EXTERNAL RADIOACTIVE CONTAMINATION--WIPE LIMITS

Maximum permissible limits
Contaminant	MicroCurie/cm2	dpm/cm2
Beta-gamma emitting radionuclides; all radionuclides with half-lives less than ten days; natural uranium; natural thorium,; uranium-235; uranium-238; thorium-232; thorium-228 and thorium-230 when contained in ores or physical concentrates.	10-5	22
All other alpha emitting radionuclides	10-6	2.2

(49 CFR 173.443 Table 10)

REMOVAL OF EXTERNAL CONTAMINATION FROM WASTE CONTAINERS

Every laboratory which generates radioactive waste is responsible for decontaminating the exterior of waste containers to the safe levels listed in the table above. The following contamination testing procedures are required for each type of waste container:

SOLIDS
7.5 gallon and 28 gallon yellow fiber drums are to be smeared (wipe-tested) on the side and bottom of the drum.

SHARPS
5 gallon buckets for sharps containment must be smeared on the handle, top (lid), bottom, and sides of the container. (The same applies to acceptable alternative containers).

LIQUIDS
4L, 10L, and 20L jugs must be smeared on the cap, handle, sides, and bottom of the container.

SCINTILLATION VIALS and STOCK VIALS
The boxes containing the vials are to be smeared on all four sides as well as on the top and bottom.

NOTE: The boxes containing the vials must be properly sealed and have no visible damage so that no leaking of radioactive and/or hazardous material occurs from the box.

LEAD OBJECTS
All lead/leaded objects and lead impregnated materials must be smeared on all sides.

A completed signature on the Low-Level Radioactive Waste (LLRW) Manifest indicates to OSEH personnel that the testing for external container contamination has been completed as required.