RADIOACTIVE
WASTE DISPOSAL
“BEST AVAILABLE
TECHNIQUE”
A BAT Guide for
University of Cambridge
Departments
Revised version 1.3
Prepared by: Barrie Fuller
Updated July 2012
(Review date 2013)
‘Best Available Technique’
Introduction
These rules are written to ensure that radiation doses to employees and others,
resulting from the use of ionising radiations. In specific work, are restricted to as
low as is reasonably practicable (ALARP). Additionally, theses rules* refer to the
policy to be observed in this Department to ensure that Best Practicable Means
(BAT) are employed to minimise the activity of disposed radioactive waste,
minimise the volume of radiation effects of such disposals on the environment
and on members of the public.
* See BAT statement appendix 5, Health and Safety handbook:
www.zoo.cam.ac.uk/zooonly/safety/policy.html
* BAT Zoology document website:
www.zoo.cam.ac.uk/zooonly/safety/docs_links.html
Departments BAT Statement and Practical Arrangements
Radioactive waste disposal – BAT requirements/policy in the Department of
Zoology, to meet the requirements of the current EPR10 (ERP/TB3135DN
13/12/11) which replaces Certificate of Authorisation (Authorisation
Ref.No.AF1730/CD6063-17/03/2010) for Accumulation and Disposal of
Radioactive Waste, issued under the terms of the Radioactive Substances Act,
1993.
Best Available Technique (BAT) is a system of comparing options and making
choices for the disposal of radioactive substances (waste) that will result in the
lowest radiation dose to members of the public, whilst taking into account factors
such as time, trouble and money, against the benefits of carrying out the
activities that results in the generation of the radioactive waste. Factors that are
included in the Department of Zoology’s approach to BAT are:
1. Justification of the use of radioactive substances used in the work,
including consultation with the University’s RPA and senior management
of the Department (Catherine Green, Barrie Fuller or PI). Designs of all
processes within the Department are based on this philosophy.
2. Minimisation of activity bought and used, and the volume and activity
disposed of. The ‘Quality Assurance’ methods that will be employed in
order to select and maintain correctly all processes and equipment
associated with the use and disposal of radioactive substances. Reliable
calculation or estimates of disposal activities.
3. Prevention of generation of additional waste due to contamination.
4. Choice of the least radiotoxic material compatible with experimental
needs.
5. Making and maintaining of ‘accurate’ and comprehensive records of
disposal.
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6. Appropriate instruction and training of all staff involved with radioactive
waste disposal activities. Planning of work to avoid accidents that could
lead to additional disposals.
7. Proper construction of and maintenance of all use, waste storage and
disposal facilities. Consideration of decay storage. QA as above
8. Choice of appropriate waste disposal routes (this must involve discussion
with the Health and Safety Division and University Radiation Protection
Adviser).
9. Regular review and, if necessary, revision of the practices set out in 1-8
above.
The BAT details for each protocol involving radioactive substances in the
Department of Zoology are set out in detail in the corresponding radiation risk
assessment form. BAT decisions must be regularly reviewed. This can be done
(at least annually) when the risk assessment is reviewed or when any relevant
factors in the process are changed or are likely to change. BAT considerations
are in addition to the requirements that doses to employees and others from the
work are ALARP. Care must be exercised that procedures to achieve ALAP at
work do not conflict with BAT requirements (and vice-versa).
BAT and ALARP must be considered together and the disposal routes will be
those that present the Best Practical Environmental Option (BPEO).
Department of Zoology: Operational Arrangements to meet BAT
for the Use and Disposal of Radioactive Substances.
Use and Disposal of Radioactive Substances:

Operational Procedures and Record Keeping
There are two Radiation Protection Supervisors in the department.
Senior or ‘Lead’ Radiation Protection Supervisor: Dr Catherine Green
(LRPS).
Radiation Protection Supervisor: Mr Barrie Fuller (RPS).
They are responsible for supervising the use of radioactive material
under IRR99 for the Head of Department.
Supervise Area Radiation Representative.
There is one for each area who weekly clean and check the area for
PPE and contamination recording their findings on a weekly record chart.
Procedures for waste can be seen in the ‘Local Rules’
Waste radioactivity may be safely stored in the lab in suitable waste
containers.
This waste must be transferred at regular intervals to the Solid waste store
in the basement where the use of appropriate PPE and containment for
transport from the laboratory to the waste store. The Standard Operating
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Procedure (SOP) displayed in the waste store MUST be followed – see
Facilities.
Contamination
The minimising of contamination is paramount all radioactive work must
be carried out in designated area. Monitoring before and after use must be
recorded for each use and full monitoring recorded every week of all
surfaces PPE must be used and to contain any spills - containment trays
and bench-coat. All stock pots must be checked and double contained.
Registration
All persons must be registers and fill in an Induction schedule for new
workers, user registration, skills questionnaire test and Prior Risk
assessment completed before any work is carried out, and attendance of
a University core course for new users of radioactivity, training instruction by
the RPS or PI, complete a personal Safety training record before using.
Ordering
Ordering is by requisition sent to the RPS and order is produced,
signed by the RPS having end-user, department identity pot number
written on and justification to use and ensure minimum quantities have
been ordered with reference to the RA, BAT and ALARP.
Record keeping.
All stocks are recorded from ‘cradle to grave’ at delivery to reception,
purchasing, delivery to the end user or group representative. Delivery note
copies made with pot number and date received written on, one is attached to
the yellow stock record sheet, one to the Group Assistant and one to the end
user, one attached to the order form in purchasing and the original given to the
RPS for records. In the lab users fill out the required information on the stock
sheet and also any lab records.
Designation of work areas.
In the Department radioactive work is carried out in ‘Supervised Areas’
Each area is considered by the RPS and the University radiation protection
officer on the quantity and type of radionuclide used as to its designation ‘
Supervised’ or ‘ Controlled’. In order to comply with BAT and ALARP areas
are used as a shared facility where possible in order to keep required
designated sites to a minimum.
Contingency Arrangements.
Each area has a ‘spill kit’ for minor spills and there is also a
comprehensive ‘spill kit’ for larger spills in room NT54.
Emergency procedures are displayed in every room and also
addressed on the risk assessment together with information and advice
on what to do with a spill contamination in an emergency/ accident.
Contingency plan is rehearsed with those who will be affected by
incidents. The RPS to arrange contingency rehearsal in order that
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participants understand the SOP of ‘What to do’, ‘Who to call’, ‘not to
panic’ etc. This rehearsal is reported at the Safety Committee
meeting.
Inspection and Review Regimes.
‘Supervised Radiation’ areas are inspected once a month and a bi-annual
report is sent to the LRPS and DSO. Research activity is reviewed by the PI
and LRPS and in the risk assessment and also when changing to a new
radionuclide. The group representative carries out weekly contamination and
inspection check.

Facilities
Supervised Areas has solid waste bins on and under bench which are
sufficient to stop all radiation, and designated sinks for radioactive liquid
waste disposal.
‘Low Level Solid Waste Store’ is a separate room in the basement room B6,
with floor and half wall height painted to contain contamination.
Instructions and Standard Operating Procedures are displayed as follows:
The following minimum standards for radioactive waste packaging are
given below and must be followed when disposing of solid ‘low level’
radioactive waste.
Solid Radioactive Waste from Labs to Store:

Packages must be firmly sealed with radiation tape.

Adhesive labels affixed to all packages.

All sections to be filled in on label.

Information may be permanently written onto the bag.

Radiation tape/label must always be affixed to bags.

Moving waste to store use shielded transfer containers.
Waste Bins/Drums:


Check heavy duty liner is in place.
Make sure waste forms are completed.

DO NOT overfill bins, 50-75% max fill is approximate.

Call LRPS/RPS to arrange closure of bag with plastic tie.
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Dispose of your waste frequently DO NOT store in labs.
Disposal of CDCs (‘Stock pots’)
Amersham / Perkin Elmer have decided to close the CDC recycling service. The
reason they have taken this action is because they allege that CDCs in
hazardous condition have been returned to them, and checking and processing
returned CDCs represents a ‘safety risk’ to their staff.
Disposal of the CDCs (plastic outer container and ‘lead’ liner) must now be
disposed of through laboratory waste routes. The inner Perspex/glass vials, of
course, must continue to be decontaminated and /or disposed via the radioactive
solid waste route.
All CDCs must be thoroughly checked for contamination and all ‘radioactive’
labels/symbols removed, before disposal. The lead alloy liners can be recycled
via the university hazardous waste system. Please do not dispose of the metal
liners in the solid radioactive waste route, as this material is currently disposed to
landfill – an inappropriate route for lead.
Please regularly depose CDCs from individual laboratories, i.e. as the containers
are used up do not allow them to accumulate – accumulation of CDCs (labelled
or otherwise) are frequently noted by visiting inspectors and are not seen as
good management practice in the control of radioactive substances.
The Procedure for the disposal of all CDCs.



Monitor for contamination (check plastic and lead separately)*
Decontaminate if required and include both plastic and lead
Remove all identification labels

Plastic CDCs outer containers only dispose to general waste bin

Plastic/Lead* CDCs remove lead and send as hazardous chemical waste
Only dispose when you have completed the procedures above and you are
satisfied that there is no contamination on the CDCs before they are
disposed.
Optimisation Policy.
The department has the minimum required ‘Supervised Areas’ totalling four
including the ‘Hot Room’ in order to keep radioactive work to a minimum. Each
area has the required PPE and shielding, and users are required to use minimum
amount of radionuclide (monitored by TLDs) in order to keep workers exposure
to ma minimum - (ALARP).
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If new facilities / area are required /identified before starting out the RPS must be
consulted YOU MUST NOT use radionuclides in a non-designated area, all areas
in the department where radiation is allowed are ‘Supervised’ and neither must
you use radionuclides in a new area until it has been approved.
Design (best practice) Criteria.
Experiments are designed to use the smallest amount possible monitored by the
PI’s and RPSs, The monthly inspection reviews maintenance of areas, PPE,
waste disposal and related facilities used in the supervised areas in order to
maintain best practice and safe management.

Training
All new users are sent on the University radiation substances core training
course for new users
In house training and supervision is arrange and ongoing for all new users and to
those will start before attending the next new users training course. Those new
members who have use radionuclide’s before both here or in another intuition are
monitored and sent on the next available university new user’s course.
Records of training are recorded on:
 Departmental Induction Schedule for new workers: Unsealed Radioactive
Substances
 Ionising Radiations - Users Registration Form
 Skill Questionnaire
 Risk assessment
 Core training Certificate
 Personal Safety Training Record - radiation
Each users has been given a BAT book and explained the University policy on
waste disposal together with book 3 ‘working safely with unsealed radioactive
sources’
Each user is made aware and must follow the University and Department BAT
policy, they also have to justify and demonstrate to the RPS and PI the need to use
radionuclide’s and optimise their quantities in order to use, this is reflected in the
BAT sections of the User and RA forms. Waste must be accurately monitored and
recorded on the stock sheet and also on the bin sheets in the solid waste store and it
is paramount that the standard operating procedure is followed in order to avoid the
penalties that could arise in the event of non-compliance.
Users are instructed to keep accurate records from ‘Cradle to Grave’ of the
radionuclide they use. They must ensure that the stock sheet is filled in correctly
and all the waste sheets in the lab and at the waste store and also to record
these in their experimental records these will be checked by the PI and RPS at
regular intervals to evaluate competence and give training update if required.
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Summary
As a user, or potential user of radioactive substances, YOU must justify your
decision to use radioactivity, and the specific radionuclide for the planned work.
YOU must minimise the amount of radioactivity you use, and minimise the
activity and volume of any arising waste. You must only dispose waste to the
routes agreed with your RPS, and only within the agreed limits and in
accordance with the specific directions in these rules and any associated
departmental documents.
YOU must keep accurate records of all uses and disposals of radioactive
substances. YOU must report any problems with radioactive waste disposal
systems/arrangements to the RPS/Administrator of your department. You and
your colleagues MUST not create unnecessary contamination of work surfaces
or other areas of the department. YOU must regularly monitor work areas and
waste disposal areas, record results and report any problems to your RPS. If
YOU supervise other people you must ensure that they also follow the above
directions. All the above items must also be considered when completing a risk
assessment, BEFORE you start any practical work.
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