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5

CONCLUSIONS

This report assesses the impact of lack of access to LLRW disposal facilities and the rising costs of LLRW disposed on biomedical research. We expect most of our observations to apply to medical uses of radioactive materials in diagnosis and therapy, but we focused our attention on waste generated in biomedical research and radioactive material suppliers to the biomedical research facilities. Hospitals and academic institutions have been storing radioactive materials onsite for decay for many years because it has been the least expensive and easiest method to deal with short-half-life radionuclides. Despite the extensive use of storage for decay, small volumes of LLRW still need to be sent to disposal facilities. Although disposal capacity in US Nuclear Regulatory Commission licensed facilities nationwide appears to be sufficient for the biomedical needs of the next several decades, the future of commercial LLRW management in the United States is by no means stable beyond that time frame.

The committee has concluded that the central issue in biomedical research LLRW management is cost. Assuming that there might be access to disposal facilities, there is sufficient disposal capacity for the relatively small amount of radioactive waste that the biomedical enterprise produces, and current practices are safe and covered by appropriate regulations. Therefore, the committee chose, in its analysis and recommendations, to focus on cost. However, for some institutions, factors other than cost may become paramount. For example, a large research institution in an urban setting may find that allocating sufficient space for LLRW activities, or the effect that storing radioactive materials has on public relations with neighboring populations, are more pressing issues than costs. Conversely, a small research activity in an institution without an extensive supporting infrastructure may not be able to handle the mechanics of waste disposal, even if the costs are manageable. Whether it is the single most important issue or not, we believe that costs are an important issue at virtually all research institutions.

The biomedical research community has adapted to the challenges presented by national, LLRW compact and state policies for LLRW management. The challenges have been these:

  • Increased costs of onsite or offsite storage, treatment, and disposal. The costs of biomedical LLRW management have risen sharply in the last decade. An important driver of the increase has been the large increase in the cost of shipping and disposing of LLRW at licensed sites. Those increases have caused investigators and institutions to turn to an increased use of storage for decay which requires institutions to devote space and staff support to expanded storage of LLRW. This is an appropriate but expensive approach.



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Page 37 5 CONCLUSIONS This report assesses the impact of lack of access to LLRW disposal facilities and the rising costs of LLRW disposed on biomedical research. We expect most of our observations to apply to medical uses of radioactive materials in diagnosis and therapy, but we focused our attention on waste generated in biomedical research and radioactive material suppliers to the biomedical research facilities. Hospitals and academic institutions have been storing radioactive materials onsite for decay for many years because it has been the least expensive and easiest method to deal with short-half-life radionuclides. Despite the extensive use of storage for decay, small volumes of LLRW still need to be sent to disposal facilities. Although disposal capacity in US Nuclear Regulatory Commission licensed facilities nationwide appears to be sufficient for the biomedical needs of the next several decades, the future of commercial LLRW management in the United States is by no means stable beyond that time frame. The committee has concluded that the central issue in biomedical research LLRW management is cost. Assuming that there might be access to disposal facilities, there is sufficient disposal capacity for the relatively small amount of radioactive waste that the biomedical enterprise produces, and current practices are safe and covered by appropriate regulations. Therefore, the committee chose, in its analysis and recommendations, to focus on cost. However, for some institutions, factors other than cost may become paramount. For example, a large research institution in an urban setting may find that allocating sufficient space for LLRW activities, or the effect that storing radioactive materials has on public relations with neighboring populations, are more pressing issues than costs. Conversely, a small research activity in an institution without an extensive supporting infrastructure may not be able to handle the mechanics of waste disposal, even if the costs are manageable. Whether it is the single most important issue or not, we believe that costs are an important issue at virtually all research institutions. The biomedical research community has adapted to the challenges presented by national, LLRW compact and state policies for LLRW management. The challenges have been these: Increased costs of onsite or offsite storage, treatment, and disposal. The costs of biomedical LLRW management have risen sharply in the last decade. An important driver of the increase has been the large increase in the cost of shipping and disposing of LLRW at licensed sites. Those increases have caused investigators and institutions to turn to an increased use of storage for decay which requires institutions to devote space and staff support to expanded storage of LLRW. This is an appropriate but expensive approach.

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Page 38 Temporary interruptions in disposal access. In several instances, access to disposal sites has been closed to investigators from some states. Such closures indicate stresses that would be created by any situation that interrupted access to disposal. Although no state has been denied access for more than six years, there is some indication that denial of access for a longer period of time (10-20 years) would have adverse effects on biomedical research or medical care. The adaptations chosen by institutions and investigators in those states are discussed in this report: increased use of nonradioactive alternatives, increased use of storage for decay, and better management of radioactive-material techniques, such as ordering only the amounts of radionuclides needed. Costs increased, as did the uncertainty about the effects on clinical programs. Fortunately, the interruptions were terminated before any discernible major damage to biomedical research or medical care. A complex and potentially conflicting regulatory setting in which to manage LLRW. Radioactive materials are largely regulated by the US Nuclear Regulatory Commission, but they occasionally are to be disposed of in conjunction with solvents or other materials that are regulated as hazardous materials by EPA. States and local governments also have applicable regulations. The situation is often confusing and difficult for institutions and investigators. Uncertainty regarding the future of LLRW-disposal access and continuity of regulation that drives LLRW-management strategies. The fact that access to disposal has been interrupted in some states and the fact that creating new disposal sites has forced those who must manage LLRW to look for strategies that will work effectively even if access to disposal is denied. Those challenges have caused generators to seek alternative storage, treatment and disposal strategies, as follows: Expansion of onsite management (storage for decay) for most commonly used radionuclides with short half-lives. Storage for decay has always been part of LLRW management, but the amounts and types of radionuclides being stored has grown as disposal has become more expensive. This growth requires a substantial increase in space devoted to storage and in staff effort and recordkeeping. For large urban campuses, finding the available space can pose a serious problem. Direct disposal or incineration of 14C and 3H, the most commonly used longerlived radionuclides. This is an environmentally appropriate strategy for these radionclides because the amounts being disposed of are very small, especially in comparison with the substantial amounts of naturally occurring 14C and 3H.

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Page 39 Development and evaluation of alternative nonradioactive test procedures. Many alternatives that use chemiluminescence or enzyme quantitation have arisen recently and are superior for particular research tasks. That these alternatives use nonradioactive materials is itself a benefit. Improvement of management practices. The improvements include reduction in quantities of radioactive materials ordered, reduction in wastes generated during use, sorting and segregation of noncontaminated items, and overall minimization of final waste quantities and volumes. Expansion of the commitment of space, personnel, and infrastructure to onsite management of LLRW. Overall, those adaptations have been safe, appropriate, and functional, albeit expensive. The selection and use of radioactive material in biomedical research seems to depend most on the efficacy of such materials for their intended purpose. Although it is affected by access to disposal and by government policies related to LLRW management, its use is not strongly dependent on them. That will probably remain true in the future. Biomedical use of radionuclides has declined, as nonradioactive alternatives have become increasingly popular as costs for LLRW management have increased sharply. However, some continued use seems likely, so the disposal problem will still be exist. The current system of biomedical-LLRW disposal creates several burdens. One burden is on the regulators, who must oversee a widely distributed system that operates in many settings. Another is on research institutions, which have to fund and maintain expanded systems for storage and disposal; funding for this institutional effort must compete with other costs of doing research that are usually recovered as indirect cost funds. It is extremely unlikely that new disposal sites will be developed. There is no pressing need for new capacity. There is substantial public opposition to new-site development. The cost of new-site development is high—exceeding $100 million/site—as illustrated by the recent experience of trying to develop a disposal site in California, Illinois, North Carolina, or elsewhere (Ryan and Newcomb, 2000). The greatest risk to the current status of LLRW management in the biomedical research community is an unscheduled and arbitrary closing of current disposal facilities. To maintain existing facilities requires sustained political will and user support. Understanding of the economic basis of LLRW-disposal policy and management strategies needs to be improved. In the main, financial considerations determine which of the available options will be chosen.

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Page 40 If use of radionuclides increases because of the larger national commitment to biomedical research or because of the introduction of new radioassay or radiotherapeutic systems, or if the use of longer-half-life radionuclides increases for any reason, the available system of LLRW management storage, monitoring, inspection, and disposal might not be adequate to meet the needs of this expansion. Although disposal capacity appears to be sufficient for the biomedical research community needs of the next several decades, the future of biomedical-research LLRW management in the United States is not ensured for the longer term. Interruption in access whether from existing site closure, impacts on transportation, or real or perceived problems with alternative storage methods may create more immediate needs for alternative storage or disposal facility development. Although the biomedical research community has adapted to changes in LLRW policy and management options, further stress might not be as well tolerated.