Ionising Radiation Health & Safety
Acquisition
and disposal of
radioactive materials
The University of Reading
Safety Guide 18
The University of Reading Safety Guide 18
Acquisition and disposal of radioactive materials
1
2
INTRODUCTION .............................................................................................................. 1
GENERAL POINTS .......................................................................................................... 1
2.1
Definition of "radioactive substance" ................................................................. 1
2.2
Forbidden materials ............................................................................................ 1
2.3
Exemption Orders ............................................................................................... 2
2.4
Uranium inventories ........................................................................................... 2
2.5
Certificates of Authorisation............................................................................... 2
2.6
Best Practicable Means, BPM ............................................................................ 2
2.7
School records .................................................................................................... 3
2.8
Security ............................................................................................................... 3
2.9
Planning and paying for disposal ........................................................................ 3
2.10
Transferring radioactive materials to other workplaces...................................... 3
2.11
Biological and chemical hazards ........................................................................ 4
3
ACQUIRING CLOSED SOURCES .................................................................................. 4
4
DISPOSING OF CLOSED SOURCES.............................................................................. 4
5
ACQUIRING OPEN SOURCES ....................................................................................... 4
5.1
Commercial sources............................................................................................ 5
5.2
Non-commercial sources .................................................................................... 5
5.3
Nomenclature...................................................................................................... 5
5.4
Order validation and forwarding......................................................................... 5
5.5
University Source Numbers (USNs)................................................................... 5
5.6
Delivery dates ..................................................................................................... 5
5.7
Source identification and labelling ..................................................................... 6
5.8
Miscellaneous ordering aspects .......................................................................... 6
6
DISPOSAL OF OPEN SOURCES .................................................................................... 7
6.1
BPM, Best Practicable Environmental Option [BPEO] and waste disposal ...... 7
6.2
Disposal returns .................................................................................................. 7
6.3
Inter-School returns and collation....................................................................... 8
6.4
Disposal of radioactive solids ............................................................................. 8

Additional statement on VLL Waste .................................................................. 9
6.5
Disposal of radioactive liquids ......................................................................... 11
6.6
Disposal of radioactive gaseous waste.............................................................. 11
6.7
Storage of radioactive wastes ........................................................................... 12
6.8
Summary of disposal procedures ...................................................................... 13
7
OPEN SOURCE STOCK CONTROL ............................................................................. 13
8
TRANSPORT................................................................................................................... 14
9
REFERENCES ................................................................................................................. 14
10
ACRONYMS ............................................................................................................... 15
UNIVERSITY OPEN SOURCE STOCK AND DISPOSAL LIMITS SG18 Appendix 1 .... 1
1
MAXIMUM OPEN SOURCE STOCK PERMITTED AT WHITEKNIGHTS 1
2
SCHOOL OPEN SOURCE ALLOCATIONS ................................................... 1
3
MAXIMUM DISPOSALS PER MONTH ......................................................... 1
3.1
Solid waste (BIN/SKIP)...................................................................................... 1
3.2
Aqueous waste (SINK) ....................................................................................... 1
3.3
Organic scintillant (DRUM) ............................................................................... 2
3.4
Gaseous waste (ATMOSPHERE) ...................................................................... 2
Acquisition and disposal of radioactive materials
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3.5
4
4.1
4.2
4.3
5
Other solid waste ................................................................................................ 2
STORAGE FOR DECAY OR COLLECTION .................................................. 2
Aqueous waste: up to 900 days (30 months). ..................................................... 2
Organic scintillant – up to 540 days (18 months) ............................................... 2
Solid waste: up to 900 days (30 months). ........................................................... 2
USE AND DISPOSAL at other University premises ......................................... 3
Malcolm Iosson
University Radiation Safety Officer
Extension 8887
Fifth Edition – as amended
12 April 2005
The University of Reading Safety Guide 18
Acquisition and disposal of radioactive materials
1
INTRODUCTION
This Safety Guide has been prepared to assist School Radiation Protection Supervisors (SRPSs)
and radiation workers to acquire and dispose of radioactive materials in a manner which is safe,
complies with The Ionising Radiation Regulations 1999 (IRR) (References 1 and 2), and is within
agreed limits authorised by the Environment Agency under the Radioactive Substances Act 1993
(see below).
If in any particular case the Guide appears to conflict with the Regulations the latter must be
followed and the University Radiation Safety Officer (URSO) (extension 8887) informed of the
apparent contradiction.
Authority to acquire and dispose of radioactive materials at workplaces is governed by The
Radioactive Substances Act 1993 (RSA) (Reference 3). This Act is enforced by the Environment
Agency (EA). The University has authorisations under the Act to keep and dispose of the
quantities of radioactive materials listed in Appendix 1. Exemption Orders (Section 2.3) are listed
in References 4 - 13.
Other aspects of using radioactive materials and radiation generators (including non-ionising
radiation) are given in Safety Guides 16, 17, 19, 20, 21, and 22. Further advice can be obtained
from the SRPS (see the SRPS Contact List), who will if necessary consult the URSO. Purchasing
orders for radioactive materials can be placed and disposals arranged only with the consent of the
SRPS. See also Section 5.
2
GENERAL POINTS
Before proceeding to the acquisition and disposal of radioactive materials the following general
points should be noted.
2.1
Definition of "radioactive substance"
The term “radioactive substance” is defined in IRR as “any substance which contains one or more
radionuclides whose activity cannot be disregarded for the purposes of radiation protection” –
i.e., any substance that could pose a radiation risk. As theoretically, any radionuclide could pose a
radiation risk to an individual, this could be interpreted as meaning that the Regulations apply to
any work involving a substance containing a radionuclide. Similarly, no minimum activity
exemption is granted under RSA with the exception of specified (naturally radioactive) elements,
such as Uranium, Radium or Radon, where minimum activity levels do apply..
2.2
Forbidden materials
The University's registration forbids the disposal of any waste open sources containing strontium90 or any radionuclide which emits alpha particles. Before work with any such substances can
commence it is essential to inform the URSO, so that he can consult with the EA. Application
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fees to change the Authorisation must be paid by the School concerned at the time that an
application is made.
2.3
Exemption Orders
Several Exemption Orders have been made under RSA relating to phosphatic substances, rare
earths, uranium and thorium, prepared uranium and thorium compounds, geological specimens,
waste closed sources, electronic valves, smoke detectors, gaseous tritium light devices, luminous
articles and testing instruments (References 4 - 13). Consequently it is not necessary to regard
limited quantities of natural uranium (< 2 kg.) and thorium compounds as open sources that must
be registered with Health & Services (Sections 5, 6 and 7). However, such substances must still
be handled according to the requirements of IRR to protect against any associated radiation
hazards.
Note that the Exemption Order for Uranium and Thorium compounds specifies that such
compounds are “natural”, i.e., composed of the different isotopes of the element in their natural
abundance. Technically, therefore, any Uranium compound prepared from depleted Uranium
[“DU”, i.e., depleted in 235U ] does not comply with the Exemption Order. The EA have been
asked for guidance on the application of the Order to compounds prepared from DU, but have yet
to respond. See also Safety Note 7 [New] – “The use of Uranyl Acetate in electron microscopy”.
2.4
Uranium inventories
A Euratom directive (Reference 14) governs the keeping of uranium and similar fissile materials,
such as thorium, etc. If The University begins keeping significant quantities of these materials (>
2kg.) it must account (to the nearest milligram) for all Uranium etc, at The University. This is not
a safety requirement but a security feature to preclude the possibility of accumulating potential
bomb materials. Consequently if any member of The University should acquire Uranium, etc, for
a research programme, then he or she will have to carry out a survey of all such materials at The
University, send details to a national stock-taking point, periodically update the material in the
light of future acquisitions and disposals, etc. Due to the overwhelming administrative procedures
any member of The University contemplating such work - who will have to personally arrange and
carry out all the required procedures - must discuss the proposal with the URSO before work
commences. See also Safety Note 7 (New) – the Use of Uranyl Acetate in Electron Microscopy.
2.5
Certificates of Authorisation
Copies of the relevant Certificates of Authorisation issued by the Environment Agency (which
remain valid until replaced) must be displayed on Health & Safety Noticeboards (Safety Guide 2)
of departments using radioactive materials. Copies are available from the URSO. A key-point
summary is given in Appendix 1.
2.6
Best Practicable Means, BPM
One of the conditions now applied to the Certificate of Authorisation to dispose of radioactive
waste is that “best practicable means” are used to manage the use of radioactive substances, and to
minimise the disposal of radioactive substances into the environment.
BPM may be defined as “The level of management and engineering control that minimises, as far
as practicable, the release of radioactivity to the environment”. There is an obligation to take into
account cost-effectiveness, technological developments, operational safety, social and
environmental factors, but the organisation is not expected to spend money, time or trouble that is
disproportionate to the likely benefits.
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EA Inspectors may request to see a BPM Policy Statement for the University, and examine
evidence and /or inspect the University in respect of conformity with the Statement. The Policy
Statement may be regarded as equivalent to the Health and Safety Policy Statement of the
University, and, like that statement, the detailed policy is by reference to the University Safety
Guides relating to the use of radioactive materials (Safety Guides 16 and 19, in addition to this
Guide), and to any Local Rules or Systems of Work applicable to such use. See section 6 for
details of the application of BPM to waste disposal.
2.7
School records
Local School records of radioactive substances must be maintained, and monthly updates of
disposals sent to the Radioactive Materials Stock Co-ordinator (School of Animal and Microbial
Sciences, extension 7043). Copies of the monthly disposals and stock level records are kept by
Health & Safety Services (Section 7).
2.8
Security
Conditions of the University's EA registration certificates are:
 competent persons must be made responsible for sources, wastes, etc;
 all radioactive materials are either under immediate close supervision or locked away in a
secure place;
 radioactive materials must not be stored with or close to any readily flammable or explosive
materials;
 any loss of radioactive materials must be reported to Health & Safety Services and to the
Police, and all reasonable steps taken to recover the missing materials; and
 loan or hire of radioactive materials is not permitted. (But materials may be donated to other
organisations which have the appropriate authority to hold them.)
2.9
Planning and paying for disposal
The method(s) for disposal must be agreed before any radioactive waste can be produced. Some
disposal methods are very expensive; users must ensure that they are adequately funded to pay the
costs involved before acquisition. Advice on these aspects must be sought from the URSO
(extension 8887) at the planning stage before work begins. A high charge is made by the EA for
any change in the University's authorisations.
2.10 Transferring radioactive materials to other workplaces
Radioactive materials can be transferred to other workplaces. If, for example, members of The
University of Reading move to other universities and wish to take their sources with them, then
providing the recipient workplace(s) has appropriate RSA registration certificates and formally
indicates in writing to the SRPS of the donor School (who must copy the correspondence to the
URSO) that they are willing to accept the materials concerned, the sources can be transferred. The
University records (Section 7) will then be modified accordingly. It should be noted that transfers
of this nature are not a method of disposal. There is no special EA Form to cover these
circumstances. Transportation aspects are described in Safety Guide 16 (Section 12), and Safety
Note 8 “Transport of radioactive materials by road.”
Acquisition and disposal of radioactive materials
2.11 Biological and chemical hazards
This Guide refers only to the radioactivity of materials; due consideration must be given to any
associated biological, chemical and/or other hazards.
3
ACQUIRING CLOSED SOURCES
A closed source may take the form of a radioactive substance encapsulated, for example, between
sheets of plastic. Certain foil sources are also classified as "closed". The term "sealed source" is,
speaking strictly, confined to sources sealed by welding inside a stainless steel case. A sealed
source is, by definition, also "closed"; but a closed source need not be "sealed". Note that certain
instruments may include closed radioactive sources for calibration or detection purposes – these
must also be notified to the URSO before acquisition.
A “suitable and sufficient” risk assessment must be carried out before acquiring any new
radioactive source, and a copy of the assessment supplied to the URSO with the request to acquire
the source.
In compliance with the twin principles that exposure to ionising radiation should be “as low as
reasonably practicable” (ALARP) and that holdings of radioactive materials be minimised, the
holding of any radioactive source must be capable of being justified to an Inspector from the EA.
Production of a copy of the required risk assessment should assist in the justification process, since
the assessment should be used as a means of minimising the risks of using or storing any
radioactive material
The proposed acquisition of a “new” closed source must be notified in writing to the URSO, and
must include a copy of the risk assessment (see above).
A list of closed sources and associated University Source Numbers (USNs) is maintained by
Health & Safety Services. Closed sources must not be mutilated in any way.
4
DISPOSING OF CLOSED SOURCES
Members of The University wishing to dispose of closed sources must consult the URSO well in
advance of the proposed disposal, as disposal of even low activity closed sources is a lengthy and
costly process. When sufficient demand arises, or the number of redundant sources warrants it, a
central collection may be made, and the sources transported to an authorised agency, eg Safeguard
International. The costs involved will be apportioned according to the original owner Schools of
the sources sent for disposal.
In some instances the suppliers of instruments containing closed sources, liquid scintillation
counters for example, may take the source back for refurbishment. The charges involved are
usually only a small fraction of those incurred for disposal.
5
ACQUIRING OPEN SOURCES
The following points must be followed to acquire open (ie unsealed) sources.
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5.1
Commercial sources
All commercial open sources for Whiteknights must be ordered via the Radioactive Materials
Purchasing and Stock Co-ordinator (RMPSC) in the School of AMS (extension 7043 or 7025).
Orders must not be sent directly to the central University Purchasing Office: such orders
will be rejected and returned to the originating Department or School, and will consequently
be delayed.
5.2
Non-commercial sources
Anyone proposing to acquire a "non-commercial source" (eg a specimen obtained from another
research establishment) must discuss the proposal with the Radioactive Materials Stock Coordinator (extension 7043) to ensure that the activity of the source is within the authorised limits
for the campus (Appendix 1) once current holdings are taken into account. If permissible, the
RMPSC will issue a University Source Number (USN – see below) to the material on receipt.
5.3
Nomenclature
Order forms should be completed using the nomenclature used in the "Amersham Research
Products" catalogue where applicable.
5.4
Order validation and forwarding
When an order has been entered satisfactorily into the AMS computer, which checks that the
quantity ordered is within the authorised limit for The University (Appendix 1) with current
holdings taken into account, the official order will be sent via the University Purchasing Office to
the supplier nominated by the person requesting the source. Simultaneously an "Order Forwarded"
form will be sent to both the person requesting the source and the SRPS. If the order exceeds the
authorised limits it will be returned to the person ordering the source with suggestions regarding
amendments.
Total activity limits for each radionuclide apply to the whole of Whiteknights. The division of the
total activity between departments is the result of agreement between the SRPSs concerned - the
URSO may be called on to arbitrate if problems arise. The division of the allotted activity within a
School is the responsibility of the SRPS.
5.5
University Source Numbers (USNs)
The "Order Forwarded" form bears a unique University Source Number (USN) that must be used
in all future correspondence. This number must be permanently applied to the container of the
material when it arrives, and also on the containers of any aliquots taken from the source. There
must be a proper audit trail linking all of the material to records of use and disposal – see section
5.7.
5.6
Delivery dates
Upon delivery of the source to the School the recipient must enter the date of delivery on the tearoff portion of the Order Forwarded form and send it to the Radioactive Materials Purchasing and
Stock Co-ordinator (AMS). The SRPS or alternate should also be informed that the source has
arrived.
The date of delivery of non-commercial sources (section 5.2) is assumed be the date given on the
Request Form.
Acquisition and disposal of radioactive materials
5.7
Source identification and labelling
The USN is the only way that the computer can recognise a particular source. It is strongly
recommended that source containers are labelled with the USN immediately upon receipt and that
aliquots and sub-aliquots are numbered with respect to the parent USN. For example, USN 101
would be divided into aliquots 101/1, 101/2 ... 101/x and sub-aliquots of aliquot 101/2 would be
labelled 101/2/1, 101/2/2 ... 101/2/y and so on.
The adoption of this standard system is unambiguous, easier than writing long chemical and/or
isotope names on containers (many of which are small in size), and permits recognition of a
particular source by any member of The University with respect to the USN. Details of all open
sources are stored as a permanent record in the computer. School record keeping systems,
research notebooks, etc should also operate using the USN.
5.8
Miscellaneous ordering aspects
 Telephone orders
Orders can be made by telephone only when absolutely necessary, for example to synchronise
maximum activity with experimental schedules. The procedure is not to be used as a matter of
course.
The Radioactive Materials Purchasing and Stock Co-ordinator (RMPSC) in the School of AMS
(extension 7043 or 7025) or in their absence the SRPS for the School of AMS (see the SRPS
Contact List) must be contacted before telephoning the supplier, to ensure that authorised limits
on activity are not exceeded. An Order Form must be completed and a USN allocated before the
source is received.
 Bulk purchases and standing orders
Persons wishing to place bulk purchases to take advantage of quantity discounts with periodic
delivery of components items according to user(s) requirements must obtain approval beforehand.
Advance USNs will be allocated. Dates of delivery must still be notified by the person responsible
for each source when it is delivered according to demand (Section 5.6).
 Inter-School transfers
A list of current holdings of open courses relating to isotope, compound, activity, person
responsible for the source, etc is available from the Radioactive Materials Purchasing and Stock
Co-ordinator (RMPSC) in the School of AMS (extension 7043 or 7025). However, before any
material is transferred to another user in a different School, a new USN must be issued and a
record made of the transfer by the donor.
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6
DISPOSAL OF OPEN SOURCES
6.1
BPM, Best Practicable Environmental Option [BPEO] and waste disposal
The fundamental requirement of BPM is that the release of radioactivity to the environment is
minimised, as far as reasonably practicable. To achieve such a minimisation involves choosing the
Best Practicable Environmental Option (BPEO). Given that the use of open sources of radioactive
material has been justified, the BPEO should be chosen that minimises both the risks to the
user(s), and the risks to “other persons “ who may be exposed to the activity once it has been
“released to the environment” – i.e., disposed of.
 Identification of the BPEO is a risk-balancing exercise, and would be required at the point of
either applying for a Certificate to discharge or dispose of radioactive waste, or applying for a
Variation in such a Certificate. As such, it would include a Environmental Impact Assessment,
and is not an exercise to be entered into lightly. The University’s current Certificate was issued
in 2000, and is unlikely to be amended in the near future, so undertaking the procedures to
identify the BPEO for waste disposal is not likely to be formally required for some time.
However, it should be remembered that the use of BPM/ BPEO is a continuing obligation, and
the routes of, and techniques adopted for waste disposal must be kept under review.
 Factors that need to be borne in mind when considering the BPEO include the possibility of
“decay storage” for short-lived isotopes. Here, the risks of storage [to the individuals who may
have to enter the store, and be exposed to the radiation from the stored waste] are balanced
against the risks of disposal “to the environment” – for example, if liquid aqueous waste is
disposed of to drain, the activity will be greatly diluted and removed from the premises.
However, people such as sewage workers will then be exposed to the radiation (albeit doses
will be extremely small) when storage on the premises would have prevented their exposure. If
the activity is incorporated into organisms in the food chain, and ends up in fish, which are then
eaten, those persons who eat the fish will be exposed to a dose of radiation that they would
otherwise not have been exposed to. (Note that the University is already permitted to use decay
storage for both solid and aqueous waste labelled with short-lived isotopes such as 32P and 125I.)
 A more detailed appraisal of BPM/ BPEO is available on request from the URSO.
6.2
Disposal returns
As a statutory requirement a full statement of disposals from open sources by all routes must be
compiled every month. The SRPS of each user School must make a monthly return to the
Radioactive Materials Purchasing and Stock Co-ordinator (RMPSC) in the School of AMS
(extension 7043 or 7025) on a standard form, listing the activity disposed of (in Becquerels and/or
microCuries) from each USN. Each method of disposal, eg, "bin", "sink", and the activity
deposited in the store, must be recorded separately. Correction for decay must not be made (see
example below).
When the final aliquot of an open source has been disposed of the USN should be encircled on the
monthly disposals form, so that it can be deleted from the inventory. Nil returns are required if no
disposals have been made during the previous month.
Acquisition and disposal of radioactive materials
Disposals do not need to be corrected for decay - the computer does this automatically - but must
be quoted as a fraction of the original quantity (activity) of material.
 Example
For example, if you received delivery of a 3.7 MBq/ 0.1 ml open source and used/ disposed of 10
l of the original amount during the accountancy month, all you need quote with regard to the
parent USN is 0.37 MBq (370 kBq) and disposal route. In some cases, the disposal quantities by
specific routes are arrived at by calculations based on assumptions made of the uptake or
distribution of the material in an experiment. If this situation applies, a “best estimate” should be
used to arrive at the figures.
Similarly, if you make a second disposal of 1/10th of the original source in two months time, you
will still quote 1/10th even if the isotope has a short half-life and has decayed significantly.
 Cautionary notes
When completing the Monthly Disposal forms:
 enter the dates of disposal in a legible manner, with accuracy and care;
 include only disposals made during the period requested;
 quote Area/School as cited when the open source concerned was ordered and the USN
allocated;
 quote exact dates (DD/MM/YYYY) (not periods) for total daily disposal to the final disposal
point (ie "bin/skip", "drum", "sink", "other", etc) for each USN;
 encircle the USNs when the sources - including all aliquots - are completely exhausted;
 quote quantities as "fractions" of the original quantity obtained (do not correct for decay - see
above example) – note that for some routine processes the allocation of radioactive waste
between the various routes is performed by the computer software; and
 indicate the route of "authorised" disposal transfers outside The University.
6.3
Inter-School returns and collation
"Monthly Disposals" forms must be signed by the SRPS or alternate. In areas where there are
several research groups using open sources it is acceptable if a "Monthly Disposals" form from
each group is checked and forwarded by the SRPS after all the sheets from the groups in his
School are collated, numbered and the top sheet signed by the SRPS. This measure saves the
SRPS having to copy the information from the group forms to one School form.
6.4
Disposal of radioactive solids
Apart from articles or substances to which an Exemption applies (see below), the only route
available for the disposal of solid waste is that of “Very Low Level (VLL)” waste (see below), i.e.,
waste to which specific activity limits apply. Higher activity waste cannot be disposed of by this
route, although the University is permitted to accumulate and store such waste for up to 30
months, provided that:
a) the half-life of the radionuclides concerned is less than 3 months;
b) the total activity is less than 520 MBq [14 MCi], and
c) the total volume of the accumulated waste is less than 6 m3
The effect of these limitations means that, apart from short-lived isotopes, the University has no
authority to dispose of radioactive solid waste other than via the VLL route. The concession of
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Acquisition and disposal of radioactive materials
storage for short-lived isotopes will permit approx. 10x half-life decay or more, depending on the
half-life, allowing the initial activity to decay to below 1/1000 of the initial activity. In most cases,
this will permit disposal via the VLL route (see below.)
Solid waste not complying with the requirements for the VLL route would require the University
to apply for a Variation of its waste disposal certificate, and would require a new Environmental
Impact Assessment; justification of the proposed practice, changes to the BPM statement and
demonstration that this would be the best practicable environmental option. A fee – payable by the
School or Department requesting this facility – would be charged by the Environment Agency. As
previously indicated, changes to the Certificate are costly, and take several months to effect, so
research supervisors are urged to examine their practices very carefully to avoid the need for
disposal of “non-VLL” waste by an authorised collector. See additional statement on VLL
waste disposal, below.
 Exemptions
Exemption orders have been made regarding the disposal, under certain conditions, of limited
quantities of uranium and thorium or their compounds (Reference 5 & 6 – see also Safety Note
7(New)), smoke detectors (Reference 10), particular types of closed sources (Reference 8) and
geological specimens (Reference 7). The URSO (extension 8887) must be consulted before
disposing of these items.
 “Very Low Level (VLL)” waste disposal – i.e., dustbin and skip disposal
Small amounts of solid waste, excluding alpha emitters and strontium-90, are authorised for
disposal with ordinary refuse. The limits for such dustbin disposals are:
3
 400 kBq (~ 11 Ci) in any 0.1m (roughly equivalent to an ordinary dustbin); and
 40 kBq (~ 1.1 Ci) per single article.
Note that the limits are 10 times higher for 14C and 3H disposals.
VLL waste must be disposed of within 14 days of production, and not accumulated within
the laboratory. Note however that the University authorisation includes permission to store solid
waste for up to 10 half-lives for isotopes with a half-life of 90 days or less. This facility would
allow “decay-storage” for contaminated items that could not be disposed of by the VLL waste
route at the time of production – for example, contaminated tissues that had been used to clean up
a minor spill of a short-lived isotope.
 Additional statement on VLL Waste
Note: Since the Fifth Edition of this Guide was completed, (November 2004) essential changes to
the procedures for disposal of VLL waste have been implemented. These changes were required
because it was discovered that Grundon (who operate the skip collection and disposal system used
for general waste within the University) were operating a materials recovery and recycling process
from the general waste; this included sorting discarded items by hand for recovery of items such as
plastics, etc. The terms of the VLL waste authorisation require that “materials go directly to
landfill”. To avoid contravention of this requirement, VLL waste should no longer be placed in the
green skips.
At present, the solution to this problem is for all VLL waste to be collected and transported to the
London Road site (see below for transport arrangements), where the waste collection is operated
by Reading Borough Council (RBC). Currently, their waste goes directly to landfill, and complies
with the authorisation. However, if RBC change their system to include a materials recovery
Acquisition and disposal of radioactive materials
process, this route will cease to be available. This would then require the University to apply for/
acquire an authorisation to dispose of solid waste by another route – probably by incineration. The
costs of such a change would inevitably fall on the authorised users, and are likely to add
significantly to the costs of using open sources within the University.
 Removal of identifying marks
All identifying marks or numbers and indications of radioactivity must be removed from
items before disposal. Radioactive symbols must be removed or obliterated from all cans or
packaging material before dustbin disposal to allay unnecessary fears from those who handle the
refuse. See Section 6.6 for labelling requirements.
 Contaminated disposables
Disposable articles, such as tissues, razor blades, syringes and glass or plastic laboratory vessels
should not be accumulated. Once the overall activity level (Appendix 1) has been checked they
can be disposed of in designated “VLL waste bags” for transport to the London Road site. Any
items that could be possibly attractive as salvage should be destroyed before disposal. Note that
any “sharps” that may be contaminated by microorganisms must be rendered safe (from both a
microbiological and a radiological aspect) before disposal. They should be decontaminated by
soaking in an appropriate disinfectant, and rinsed with water (with both used disinfectant
and rinsings being discarded as radioactive liquid waste) before being sent for incineration
as non-radioactive waste.
 VLL waste transport arrangements
At the time of writing, bags of VLL waste are transported to the London Road site by University
transport. Contact the RMPSC (ext. 7043) for details.
 Disposal by incineration
The University does not have any incineration facilities, nor an authorisation to dispose of
radioactive waste by such means. Individual workers therefore must not arrange to transport
radioactive waste from The University for incineration elsewhere. Authorisation for incineration
may be possible, but the procedure is lengthy, and attracts an expensive application fee, payable by
the School generating the waste. Any proposals to initiate procedures that would require
incineration (e.g., of radioactively contaminated animal carcasses) must be discussed with the
URSO (in collaboration with the URPA) well in advance.
 Disposal by authorised agents
This route presently only applies to accumulated organic liquid waste, i.e., liquid scintillant waste.
The URSO must be consulted and the waste must be stored in a safe place whilst awaiting disposal
(Section 6.6), in a labelled container of adequate strength. The RMPSC currently manages the
collection and disposal system for liquid scintillant waste produced in AMS, and should be
contacted by the SRPS of any other School liable to produce scintillant waste. The volume of
waste must not exceed 1 m3 [1000 litres], and the storage period must not exceed 18 months.
 Carcass disposal by burial or maceration
Neither of these routes is now permitted at the University. Disposal by burial is not permitted until
special EA authorisation has been obtained. Changes by Thames Water mean that remains of
small animals can no longer be disposed of by maceration and flushing down the drains.
______________________________________________________________________
SG18(10)
April05
Acquisition and disposal of radioactive materials
6.5
Disposal of radioactive liquids
 Aqueous solutions
Radioactive aqueous solutions can be flushed down normal laboratory drains following dilution.
An adequate quantity of water must be allowed to flow through the drain to minimise retention in
U-traps. The maximum amount of activity that The University is authorised to dispose of via
sinks in one month is given in Appendix 1. Only appropriately labelled stainless steel sinks may
be used for disposals.
Aqueous waste containing short-lived isotopes may be accumulated for up to 30 months before
disposal down the drain. (See Appendix 1)
Any person intending to start a programme involving the production of appreciable quantities of
radioactive aqueous solutions must discuss the problems that may arise with the SRPS - who will,
when necessary, seek advice from the URSO.
 Organic liquids
The following points should be borne in mind regarding the disposal of organic liquids:
 Thames Water forbid the disposal of "Ecoscint" and other biodegradable scintillator fluids by
pouring down laboratory sinks;
 dilution is not a permitted method of disposal; and
 The University does not have direct access, or permission for access, to any incinerator
approved for the disposal of organic liquids.
Radioactive scintillator fluid or organic solvent waste must be disposed of as radioactive waste by
removal through an authorised agent. There are two named authorised agents on the Certificate Shanks Chemical Services Ltd, and S. Grundon (Waste) Ltd. The waste collection contract is
currently with Grundon. Initial correspondence (the invitation to tender) is carried out exclusively
via Health & Safety Services, but subsequent contacts are via the Radioactive Materials
Purchasing and Stock Co-ordinator (RMPSC) in the School of AMS (extension 7043 or 7025) in
consultation with the University Health & Safety Services (extension 8887). The URSO must be
supplied with copies of all relevant documents (including a copy of the waste transfer note)
following completion of the contract.
6.6
Disposal of radioactive gaseous waste
Only small amounts of β and γ-emitters can be discharged at Whiteknights. Note that the annual
limit for Tritium and Carbon-14 (250 MBq) is only 31 times the daily limit (8 MBq). For other β
and γ-emitting isotopes, the daily disposal limit is 1MBq, with an annual limit of 50MBq.
Conditions apply, including the requirement that the final outlet of the disposal route [discharge
stack of fume cupboard] is at least 3 metres above roof height, and that the manner of discharge
should prevent the re-entry of airborne radioactivity into any building.
 Fume cupboards
Special authorisation is not required to carry out experiments in fume cupboards, where a small
amount of incidental vapour may be discharged. The SRPS must be consulted before any work
begins that may generate larger quantities of waste vapour or fumes.
Adequate fume cupboards of an appropriate design, venting to the atmosphere, must be installed
when there might be a significant hazard from airborne radioactive material. Filters are not
advisable as they need to be disposed of at frequent intervals. Cupboard flow rates (minimum 0.5
Acquisition and disposal of radioactive materials
m.sec-1, ideally 0.75 m.sec-1 at 500 mm opening for work with radioactive materials) must be
checked at termly intervals, or whenever there is doubt about the flow rate, and the results
displayed in a conspicuous position on the front facia of the cupboard (whilst not obscuring
vision). Cupboards fitted with the Everwatch monitoring system should be checked for correct
flow rates before, during and after use, to confirm safe operation.
 Vapour hazards from volatile liquids
Care must be taken when storing volatile liquids with a significant level of radioactivity. A buildup of pressure must not be allowed to develop inside a closed vessel which will subsequently be
opened. Any vapour should be allowed to vent to the atmosphere at a point remote from air
intakes.
Note: Tritium contamination of refrigerated stores is a common hazard, due to isotopic exchange
with hydrogen atoms in water. Refrigerators should be regularly checked for contamination, and
regularly defrosted. Note that automatic defrosting [“frost-free” system] could lead to
contamination of the laboratory air and/ or surfaces, since defrost water is often evaporated via the
refrigerator expansion coils, and may be deposited anywhere within the lab, or within the
ductwork of an air-handling system. Regular monitoring is essential, especially when volatile
tritium compounds are being used.
6.7
Storage of radioactive wastes
 Period of storage
Solid waste of low activity ("bin/skip") should be disposed of as quickly as possible, and in any
event, within 14 days. Aqueous liquid waste should be disposed of immediately up to the
permitted limit, unless the half-life is 90 days or less (see below).
Both aqueous liquid and solid wastes containing radionuclides with a half life not exceeding 90
days may be stored for up to 900 days [30 months] to permit the activity to decay (Appendix 1).
Organic liquid waste containing radionuclides with a half life not exceeding 90 days may be stored
for up to 540 days [18 months] to permit the activity to decay (Appendix 1).
 Waste stores
All stores used for active wastes should be suitable for the wastes to be stored in them, and must
contain a log-book to accurately record the contents of the store. The store must be kept locked,
and the key should be available only to authorised persons (Section 2.8).
The Health & Safety Services radioactive materials storeroom (situated at the rear of the School of
Physics adjacent to Health & Safety Services) is available for long-term storage of active waste
being stored to allow decay of short-lived isotopes. All enquiries regarding use of this waste store
must be addressed to the URSO (ext. 8887).
All waste deposited in a designated store must be properly contained (see below) and clearly
labelled so as to identify:
 The name of the originating person/ School
 The USN of the waste
 The estimated activity in the waste
 The date of deposition, and
______________________________________________________________________
SG18(12)
April05
Acquisition and disposal of radioactive materials
 The projected date for removal.
In addition, an entry should be made in the log-book which is kept within the store. Once the waste
is removed for disposal, the log-book entry should be completed to show the actual date of
removal.
 Storage containers: general
All wastes must be kept in suitable containers which prevent any dispersion of the contents,
whether or not the waste is VLL waste in temporary storage or higher activity waste that is in
decay storage. All containers (other than dustbins for very low-level solid waste - see Section 6.4)
should be clearly labelled as above.
 Storage containers for liquids
A suitable receptacle for storing active liquids is a metal drum with a plastic liner or an approved
plastic container. Glass vessels are unsuitable because of risk of breakage: plain metal cans may
leak through a faulty seam. Double containment techniques must be employed.
6.8
7
Summary of disposal procedures
1.
Dispose of low activity solid waste and aqueous liquid waste up to the monthly limit as soon
as reasonably practicable (and within 14 days of production for solid waste). Checks on
activity may be necessary to demonstrate compliance with the VLL limits.
2.
Remove radioactive signs and any identification marks before dustbin/skip disposal via VLL
waste route
3.
Do not store radioactive wastes for more than the specified period (Appendix 1).
4.
Keep waste awaiting disposal in an adequate labelled container in a suitable locked
radioactive materials store.
5.
If in doubt contact the SRPS (see the SRPS Contact List) or the URSO (extension 8887)
OPEN SOURCE STOCK CONTROL
The open source monthly accounting period is the calendar month. Requests for disposal
information will be sent to SRPSs 7 days before the end of the accounting period and returns must
be received within 7 days after the period. If this information has not been received by the
requested date a reminder will be sent to the Head of School with a copy to the SRPS requesting a
return within 4 days. If this correspondence is ignored the Head of School the SRPS will be given
notice that work involving open sources must stop forthwith throughout the School. If a return
is still not made by a stipulated date all open sources must be surrendered to the URSO. The Head
of the offending School will have to submit a satisfactory written case to the next meeting of the
University Health & Safety Committee (UHSC) if he wishes his School to be considered for
resumption of work involving open sources. Note that the UHSC may at their discretion refuse to
approve such a request until changes are made to procedures, or the School can demonstrate
compliance with any conditions the Committee may impose.
Acquisition and disposal of radioactive materials
This policy has been approved by the Vice-Chancellor and the University Health &Safety
Committee.
It is strongly advised that Schools appoint an alternate or Deputy to act in the absence of the SRPS.
Users of open sources may obtain information regarding their USN's holdings of active material,
etc from the Radioactive Materials Purchasing and Stock Co-ordinator (RMPSC) in the School of
AMS (extension 7043 or 7025). Should disposals of any isotope inadvertently exceed the
authorised limits in any month the URSO must be informed as soon as possible. Procedures will
then require modifying to prevent the mistake being repeated.
Help and general advice on the use and disposal of open radioactive sources is available from the
SRPS and URSO. If the URSO is to be approached the enquiry should be made through SRPSs,
so that they remain fully aware of what is happening within the School for which they are
responsible.
To avoid the unnecessary holding of radioactive materials, the Radioactive Materials Purchasing
and Stock Co-ordinator (RMPSC) in the School of AMS (extension 7043 or 7025) will contact the
holders of open sources from which disposals have not been made for 12 months, at the end of
each year, to check that they are really required and are not being unnecessarily stockpiled.
8
TRANSPORT
The packaging and labelling requirements associated with the transportation of radioactive wastes
are complex. Transportation of radioactive waste off campus is normally effected only by
authorised “persons”, who normally ensure compliance with the relevant Regulations as part of the
contract for waste removal. Transport on public highways of radioactive substances in general is
described in Safety Note 8. It is recommended that the advice of the URSO (extension 8887) is
sought before intended transportation.
Note that these requirements do NOT apply to VLL waste, as this is technically regarded as
“non-radioactive”.
9
REFERENCES
The following references are available for perusal or loan from Health & Safety Services
(extension 8888) or the University Radiation Safety Officer (extension 8887).
1.
The Ionising Radiation Regulations 1999, HMSO, SI 1999/3232, ISBN 0-11-0856-14-7
2.
Work with ionising radiation, HSC, Approved Code of Practice, HMSO 1999, ISBN
7176-1746-7
3.
The Radioactive Substances Act 1993, HMSO, ISBN 0-11-541293-7
4.
The Radioactive Substances (Phosphatic Substances, Rare Earths etc) Exemption Order SI
2710/1962, HMSO
5.
The Radioactive Substances (Uranium and Thorium) Exemption Order SI 2711/1962,
HMSO
6.
The Radioactive Substances (Prepared Uranium and Thorium Compounds) Exemption
Order SI 2711/1962 HMSO
0-
______________________________________________________________________
SG18(14)
April05
Acquisition and disposal of radioactive materials
10
7.
The Radioactive Substances (Geological Specimens) Exemption Order SI 2712/1962,
HMSO
8.
The Radioactive Substances (Waste Closed Sources) Exemption Order SI 1831/1963,
HMSO
9.
The Radioactive Substances (Electronic Valves) Exemption Order SI 1797/1967,
10.
The Radioactive Substances (Smoke Detectors) Exemption Order SI 953/1980, HMSO
11.
The Radioactive Substances (Gaseous Tritium Light Devices) Exemption Order SI
1047/1985, HMSO
12.
The Radioactive Substances (Luminous Articles) Exemption Order SI 1048/1985, HMSO
13.
The Radioactive Substances (Testing Instruments) Exemption Order SI 1049/1985, HMSO
14.
The Commission Regulation (EURATOM) 3227/76 19 October 1976, The European
Communities
ACRONYMS
AMS
DEFRA
SRPS
EA
EURATOM
HMSO
IRR
ISBN
RMPSC
RPA
RSA
URSO
USN
(School of) Animal and Microbial Sciences
Department of the Environment, Food and Rural Affairs
School Radiation Protection Supervisor
Environment Agency
European Atomic Energy Community
Her Majesty's Stationery Office
Ionising Radiations Regulations
International Standard Book Number
Radioactive Materials Purchasing and Stock Co-ordinator
Radiation Protection Adviser
Radioactive Substances Act
University Radiation Safety Officer
University Source Number
HMSO
The University of Reading Safety Information Sheet
UNIVERSITY OPEN SOURCE STOCK AND DISPOSAL LIMITS
SG18 APPENDIX 1
The various authorisations for the University are summarised below; readers should refer to
the original Certificates held by the University Radiation Safety Officer (URSO)(extension
8887), and displayed in user departments, for precise information.
1
MAXIMUM OPEN SOURCE STOCK PERMITTED AT WHITEKNIGHTS
 CARBON-14
1 GBq (27 mCi)
 IODINE-125
1 GBq (27 mCi)
 PHOSPHORUS-32
600 MBq (16 mCi)
 SULPHUR-35
500 MBq (13.5 mCi)
 TRITIUM-3
5 GBq (135 mCi)
{Note that this amount is a reduction in the 40 GBq previously permitted)
 OTHER ,
300 MBq (8 mCi)
 Any alpha-emitting radionuclides
5 MBq (in total)
2
SCHOOL OPEN SOURCE ALLOCATIONS
A formal allocation is no longer made as more than 90% of materials are purchased within the
School of AMS. Should any difficulties arise the URSO will be the final arbiter.
3
MAXIMUM DISPOSALS PER MONTH
3.1
Solid waste (BIN/SKIP) – Very Low Level Waste ONLY – to London Road skips
 Alpha emitters must not be disposed of via this route.
[There is currently no authorised route for the disposal of alpha emitters, unless use can
be made of one of the Exemption Orders.]
 Limits depend on the size of the skip and the frequency of emptying.
 Not more than 40 kBq (1.1 Ci) per item. (except CARBON-14 and TRITIUM-3, where
the limit is 400 kBq in total.)
 Not more than 400 kBq (11 Ci) per 0.1 m3. (except CARBON-14 and TRITIUM-3,
where the limit is 4 MBq (0.11 MCi) in total.
 Must be disposed of within 14 days of production.
3
Note: The volume of a domestic dustbin is ~ 0.1 m3. A typical skip has a volume of 5 m and
is emptied weekly - in such a case the monthly disposal limit is 80 MBq (2.2 mCi) per skip for
“other” isotopes. The waste must not be identifiable as “radioactive”, and the individual
limits must also be observed. Thus, for example, it would be permitted to dispose of up to 20
MBq of 35S, 150 MBq of 3H and 50 MBq of 14C in a 5m3 skip that was emptied weekly,
provided that the “single item” limits were also observed.
3.2
Aqueous waste (SINK)
 TRITIUM-3 + CARBON-14
 OTHER ,
500 MBq (13.5 mCi)
200 MBq (5.4 mCi)
__________________________________________________________________________________
April 05
SG18 Appendix 1(1)
University open source stock and disposal limits
__________________________________________________________________________________
3.3
Organic scintillant (DRUM)
Removable by Shanks
 TRITIUM-3 + CARBON-14
 OTHER ,
200 MBq (5.4 mCi)
40 MBq (1.08 mCi)
Removable by Grundons.
 TRITIUM-3 + CARBON-14
200 MBq (5.4 mCi)
 SULPHUR-35
40 MBq (1.08 mCi)
 Note that Grundons would not be able to remove liquid scintillant containing isotopes such
as Phosphorus -33 – this falls within the “other ,” classification, and would have to be
removed by Shanks. Users of liquid scintillation fluids should inform the URSO and the
RMPSC if they are likely to use any isotope other than 3H, 14C or 35S before commencing
such work, since this would require the use of Shanks as the waste disposal contractor.
3.4
Gaseous waste (ATMOSPHERE)
 TRITIUM-3 + CARBON-14
 Any other radionuclide (except  emitters)
8 MBq per day (220 Ci per day)
but not more than
250 MBq per year (6.5 mCi per year)
1 MBq per day (27.5 Ci per day)
but not more than
50 MBq per year (1.3 mCi per year)
3.5
Other solid waste
Currently, the University does not have any other authorised routes for disposal of “other solid
waste”. The former ability to send waste for incineration at Compton no longer applies.
4
STORAGE FOR DECAY OR COLLECTION
The wastes described below can be stored up to the maximum periods indicated below in
either the purpose built store belonging to Health & Safety Services at Whiteknights, or the
equivalent store at AMS. Note that “Collection” only applies to organic liquid waste.
4.1 Aqueous waste: up to 900 days (30 months).
Maximum activity 620 MBq (17 mCi).
Applies only to  and  emitters with a half-life of less than 3 months. (Volume not to
3
exceed 0.1 m )
4.2
4.3
Organic scintillant – up to 540 days (18 months)
 TRITIUM-3 and CARBON-14
 OTHERS – ANY /
3
(volume not to exceed 1.0 m )
200 MBq (5.4 mCi)
40 MBq (1.08 mCi)
Solid waste: up to 900 days (30 months).
Maximum activity 520 MBq (14 mCi).
Applies only to  and  emitters with a half-life of less than 3 months. (Volume not to
3
exceed 6 m )
Such waste MUST be disposed of via the VLL route after decay has taken place
__________________________________________________________________________________
SG18 Appendix 1(2)
April 05
University open source stock and disposal limits
__________________________________________________________________________________
5
USE AND DISPOSAL at other University premises
Open radioactive sources must not be used, accumulated or disposed of at any University
premises other than Whiteknights, with the exception of VLL waste at the London Road site.
Licences previously issued for use/ storage at University farms and the London Road site have
all been cancelled.
Note: Any University site, including Bulmershe Court is permitted to use a limited number of
low activity closed sources for teaching purposes only (i.e., when acting as an educational
establishment) without the need for registration under the Radioactive Substances Act,
provided that the sources all comply with the relevant Exemption Order.
At the time of writing, all such closed sources had been disposed of, and no radioactive
sources remain. Any proposals to acquire new closed sources must be thoroughly discussed
with the URSO before being effected, and funds must be available to pay for the final disposal
of the sources when no longer required. See Safety Guide 16 [“Working with Ionising
Radiations”] – Section 8.2, “Closed Sources.”