Exhibit A shows a properly labeled container and Exhibit B shows two improperly labeled containers: Container A is missing an indication of the isotope. Container B is missing two things: the trefoil symbol and the words “Caution Radioactive Material.”
Dry waste must be labeled in the same manner. There is one thing to recognize about radioactive dry waste. Unless it is a mixed waste, it is often accumulated in containers that do not meet the closure requirements discussed previously. This is fine.
But, if the dry waste is a mixed waste, then it must meet the RCRA container closure requirements. Also, dry radioactive waste such as pipette tips are often collected in smaller containers while the experiment is being conducted and then added to a larger, dry radioactive waste container. These interim containers need to be labeled as described herein, but they do not need to be closed if the waste is limited to contaminated, non-liquid, non-RCRA regulated lab materials (e.g., pipette tips, PPE, etc.).
A couple of other things to be alert to, which would be cited under WAS11 (Other waste management concern) are segregation of isotopes and lab neutralization. Radioactive waste should be segregated by individual isotopes, with the exception of H-3 and C-14 can be combined. If they are not, then cite it as a deficiency under WAS11. In general, we discourage the lab from neutralizing waste due to the LDR (Land Disposal Restriction) notification requirements. If you discover a lab conducting neutralization, ask the Specialist whether a LDR is on file.