PROCEDURE FOR WASTE CONTAMINATED WITH RADIOACTIVE
SUBSTANCES AT RANDWYCK
This regulation specifies the procedure with regard to the separation of radioactive waste at
the source, conditions for the delivery of radioactive waste, internal transportation, temporary
storage and processing of radioactive waste originating from the participating institutions on
the Randwyck site that are covered by the complex permit.
Statutory framework
Radioactive waste is defined as material that contains a certain quantity of radioactive
substances, for which no provisions have been made for it to be used or re-used. It is
prohibited for radioactive waste to be disposed of without a permit unless the activity
(concentrations) of the radionuclides is less than the clearance limits stated within Article 37
of the Radiation Protection Decree [Besluit stralingsbescherming]. The clearance limit is the
activity concentration under which the waste is no longer regarded by the government as
being radioactive. The concentration of radioactivity in waste is determined in practice by
taking a reading. In order to prevent a situation in which the clearance limits are exceeded as
a result of reading errors, the limit values for activity concentrations within this procedure
have been reduced by a factor of 2.
If careful separation takes place at the source, a significant part of the waste that is produced
in monitored or controlled zones is disposed of as conventional waste on the basis of the
aforementioned statutory provisions, as the activity concentrations are below the clearance
limits.
The proportion of the waste of which the activity concentration exceeds the clearance limits
may usually be stored for a period of no more than 2 years to allow it to decay until the
activity concentration falls below the clearance limit, after which time it may still be treated as
conventional waste (which is subject to the Environmental Management Act).
Only waste that cannot decay to give rise to a concentration that lies under the clearance
limits within a period of two years must be regarded as radioactive waste and is transferred
to COVRA (Central Organisation for Radioactive Waste) for further processing and/or
storage.
In certain cases, the use of clearance limits may give rise to undesirable situations such as
(surface) contamination occurring in areas outside of the radiological area. A different aspect
is that, in the case of certain nuclides, a visibly measurable level of radiation in conventional
waste may be detected by external waste processing personnel. The aforementioned
situations must be prevented.
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In order to implement the ALARA principle and to prevent the aforementioned undesirable
situations, the institutions on the Randwyck site have taken up a joint standpoint with regard
to waste containing radioactive substances. With regard to short-lived radioactive waste that
may be stored for no more than two years before it decays, the clearance limit will not form
the basic principle for disposal as conventional waste. Instead, the waste will, if possible, be
stored for at least 10 half-lives within the set time limit, but for no longer than two years, until
the activity concentration is reduced as much as possible.
Classification and separation of waste containing radioactive substances
The separation and separate disposal of the various waste streams that contain radioactive
components result in an optimum policy in the area of radioactive waste substances, which
does justice to the ALARA principle.
Waste must first be separated at nuclide level. This is because the various nuclides are
characterised by variable half-lives and this is therefore indicative of the necessary storage
time. If waste contains a mixture of radionuclides, the nuclide with the longest half-life
determines the storage time of the waste.
The various radionuclides are subsequently divided into the following categories:
 Very short-lived waste is radioactive waste for which it may be estimated, on the basis of
the half-life and the activity, that the activity concentration will be below the applicable
clearance limit within 24 hours, after which time it may be disposed of as non-radioactive
waste.
 Short-lived waste is radioactive waste for which it may be estimated, on the basis of the
half-life and the activity, that the activity concentration will be below the applicable
clearance limit within 2 years, after which time it may be disposed of as non-radioactive
waste.
 Long-lived radioactive waste is radioactive waste for which it may be estimated, on the
basis of the half-life and/or the activity, that the radioactive substances within it will not
have decayed sufficiently within 2 years to be below the applicable clearance limit.
Waste must be separated further on the basis of the non-radioactive component of the
waste. The flow of waste substances contains a variety of materials and varies from liquid
and solid substances to chemicals, biological agents and animal cadaver waste. It must also
be indicated whether the radioactive waste contains ‘hazardous substances’ within the
meaning of the Environmental Management Act [Wet milieubeheer].
For that reason, in addition to separation on the basis of nuclides, the following categories
have been assigned for separation of waste that contains radioactive substances:
 Solid waste
 Liquid waste
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 Counter tubes filled with scintillation fluid
 Cadaver waste
 Encapsulated sources
Furthermore, it must be indicated for all these categories whether the materials are
contaminated with chemical or biological agents (whether or not genetically modified).
Method of collection and collection points
The storage of radioactive waste in monitored and controlled zones must be kept to an
absolute minimum in view of the fact that this contributes significantly to the radiation
exposure in the room.
The waste that is created on the Randwyck site, depending on the production, is collected
periodically or on request for (interim) storage in the central waste vault of the Faculty of Health,
Medicine and Life Sciences. The collection of waste is carried out and coordinated from the RNL
department of the Faculty of Health, Medicine and Life Sciences (of Maastricht University), which
manages the waste vault for central storage.
Packing and recording of waste
Packaging waste
The various waste flows must be packed sufficiently in suitable packaging materials. The
packing requirements of COVRA will prevail with regard to waste that is transported to
COVRA as long-lived waste.
Recording details of waste
When packing waste, every item of packaging must be provided with a sticker or form, on
which the following details must be stated next to the hazard symbol for ionising radiation:
- Date
- Nuclide(s)
- Activity per nuclide
- Weight
- Department
- Any additional details with regard to chemical waste products and/or biological agents
Every department keeps their own on-site records in relation to the waste produced and the
RNL department of Maastricht University, which manages the central waste vault, also stores
the data for the purpose of the (electronic) Nuclear Energy Act record.
Transportation of waste
The waste is transported periodically from the temporary storage facility to the waste vault,
using suitable means of transportation. Waste is transported in accordance with the
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regulations for internal transportation via the shortest possible route. If the waste is
transported on the open highway en route, the guidelines of the regulation of Transport of
Hazardous Substances over Land (VLG), as described in publication 26 of the Netherlands
Association for Radiation Hygiene [Nederlandse Vereniging voor Stralingshygiëne], entitled
“Transportation of radioactive substances by road in the Netherlands and Belgium” must be
fulfilled.
Transportation of waste to final destination
Waste with a concentration of radioactive substances that is higher than the clearance
limit
Waste of which the activity concentration is not below the statutory clearance limit value,
even after a storage period of 2 years, is disposed of by COVRA. The “Technical Conditions
for Transfer of Standard Radioactive Waste” stipulated by the COVRA are used in this
regard. The waste is supplied in standard packaging that is provided by COVRA, which has
been checked for contamination beforehand. A consultation takes place with COVRA with
regard to the correct manner of packaging for ‘non-standard’ waste.
Waste with a concentration of radioactive substances that is below the clearance limit
Waste with a sufficiently low activity concentration may be disposed of as conventional
waste. If the waste must be designated as hazardous waste in accordance with the
Environmental Management Act [Wet Milieubeheer], it will be transported as such to a
recognised collector after the storage period to allow it to decay.
In the case of liquid waste, a distinction is made between inorganic (aqueous) and organic
waste. Liquid inorganic waste that does not need to be regarded as hazardous waste is
discharged via the sewerage system, while observing the conditions that form part of the
discharge permit and limits stipulated in the complex permit. The discharge of radioactive
waste water directly from the radionuclide laboratories may be permitted by way of the
regulations of an internal permit.
Responsibilities
Staff members who are exposed to radiation are responsible for ensuring that waste is
separated correctly at the source in accordance with the guidelines that form part of this
procedure. The on-site radiation expert supervises the separated collection of radioactive
waste substances within his/her department and ensures that waste disposal forms are
completed correctly and that waste is transferred in the correct manner to the member of
hazardous waste personnel. The on-site radiation expert also ensures that details of the
waste are registered in the local Nuclear Energy Act record.
The member of hazardous waste personnel is responsible for ensuring that the radioactive
waste is collected, transported and stored in the correct manner. The on-site radiation expert
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of the RNL department undertakes supervisory activities in this regard and takes
responsibility for the central records of radioactive waste. He or she is ultimately responsible
for the correct separation, treatment and storage of the radioactive waste in the central waste
vault, as well as the transportation of the waste to its final destination.
The coordinating radiation expert(s) and the general radiation expert ensure on behalf of the
permit holder(s) that the regulations that form part of the internal permit and the procedures
contained therein in relation to collection, temporary storage and disposal of radioactive
waste are complied with.
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