RE:Waste Disposal at Universities

[CCHOGAN@life.uams.edu]

Our facility decays most of its waste in storage (halflives less than 90 days)
and we do not charge the researchers for this service.  All of our rad waste
is brought to the Radiation Safety Department for storage or disposal by the
research labs.  We only bill for waste that we have to pay to dispose of,
long lived dry waste, LSV, animal carcasses.  We bill the researchers based
on the weight of the waste they generated (it ain't perfect but its better than
nothin').  As for preventing the 'hiding away' of waste to avoid charges, we
have no fool proof method to prevent it.  We conduct radiation safety audits of
all of our labs using radioactive material on either an annual, semiannual, or
quarterly schedule (based on activity used).  During these audits we would 
probably notice any excessive hoarding of waste.  We did have a one time only
'ship-it-while-we-can' drive to clean out any waste that was being kept in the
labs (I think that was right before the first time Barnwell closed).  The 
campus adminstration picked up the tab for that one after our RSO convinced 
them it was better to do that and get rid of it now than to wait until who 
knows when to ship again.  
I can recall any instances where researchers have put rad waste in the regular
waste stream on purpose to avoid charges.  We do check the regular waste cans
in the labs whenever we conduct their audits.  Perhaps doing LSC wipes of the 
regular waste cans would help pick up any H-3 or C-14 that made it into the 
regular waste stream.  
If a researcher leaves orphan waste behind, the department has to pick up the 
tab of any waste disposal charges.  Our campus policy requires a two week 
advance notice of closing any radioisotope laboratory (either leaving campus
or relocating to another lab).  We then do a lab close out audit which includes
wrapping up any loose ends, like waste disposal and remaining inventory.  We
have never had an entire department leave, but if we did I suppose we would go 
to the College that was over that department to collect for disposal cost.
(Incidentally, we do not charge for the close out audits nor any decontamination
cost)
Waste disposal is not a part of our RSOs budget (to my knowledge) execept in 
a few instances where administration has contributed to dispose of old sources
or special items.  Any cost overruns are often absorbed by our Safety office 
budget.  

Waste minimization is encouraged during the approval process, during inservice
training sessions and during the audits.

We do not collect any surcharge on RAM orders, we do have to approve the orders
from the perspective of making sure that they are within their possession 
limits and that they are in compliance with other regulations.  Audit
infractions can trigger a stop to order approvals.

Hope this helps,
Chris Hogan
Chris Hogan
University of Arkansas for Medical Sciences
Occupational Health and Safety
chogan@colan.uams.edu

The above information is my own opinion only and not that of my employer.
My employer has neither read nor approved this message.