Welcome to the Environment section of our webpage. This front page will reflect our most current information on environmental law affecting educational institutions.

January 2009 NRC Fact Sheet on Radiocative Exit Signs

Those entities with more than 500 self luminous EXIT signs containing the radiocative gas tritium (H-3) will receive a notice from the NRC requiring them to assess compliance with NRC and state law and report to the NRC within 60 days. The NRC requires proper recordkeeping and disposal of all radioactive materials. A damaged or broken sign could require an expensive clean up. Schools with these signs are considered a general licensee for NRC purposes and are required to follow these rules:

• must NOT remove the labeling or radioactive symbol, or abandon a sign;
• must properly dispose of an unused sign (see below);
• must report to the NRC or the appropriate Agreement State any lost, stolen or broken signs;
• must inform the NRC or an Agreement State of a name change, change of address or replacement of a general licensee’s designated representative;
• must NOT give away or sell the sign to another individual, company or institution unless the device is to remain in use at its original intended location; in such a case, the transferor is to notify the recipient of the regulatory requirements and must notify the NRC or Agreement State of the transfer within 30 days.

Tritium EXIT signs must NOT be disposed of as normal trash. To dispose of a sign properly, a general licensee must transfer the sign to a specific licensee. This would typically be a manufacturer, distributor, licensed radioactive waste broker, or a licensed low-level radioactive waste disposal facility. These facilities may charge a fee for this service.

           Within 30 days of disposing of a sign, the general licensee is required to file a report to the NRC or Agreement State that includes:

• the device manufacturer’s (or distributor’s) name, model number and serial number;
• the name, address, and license number of the person receiving the device; and
• the date of the transfer.

           Reports should be sent to Director, Office of Federal and State Materials and Environmental Management Programs, ATTN: GLTS, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

Proposed Rule: Standards Applicable to Generators of Hazardous Waste; Standards Applicable to Academic Laboratories, 71 Fed. Reg. 29711, May 23rd, 2006

 The intent of this proposed rule is to establish an alternative set of generator requirements for college and university laboratories that is better suited to their specific circumstances. College and university laboratory operations differ from both industrial laboratories and industrial production facilities that generate hazardous waste. College laboratories generally have a large number of points of generation (i.e. points where waste is originally generated) such as multiple laboratory benchtops within a single laboratory and laboratories located at several areas on a single campus. Laboratories also tend to generate a relatively small volume of hazardous waste at each of these points of generation. This proposed rule is an optional, alternative set of requirements to the existing generator regulations at  Sec.  262.11 and 262.34(c). Those colleges or universities that choose to continue to manage their laboratory hazardous waste under the current hazardous waste regulations may do so, and schools that would like the additional flexibility of the proposed rule may choose to manage their laboratory hazardous waste according to this new set of generator regulations. This proposed rule would provide flexibility in 40 CFR 262.209 with regard to where the hazardous waste determination can be made (i.e. in the laboratory, at an on-site central accumulation area (CAA) or at an on-site TSDF), provided all unwanted materials that are generated in the laboratory are managed according to the provisions described in the new rule. Schools electing to proceed under the proposed rule would have to develop, implement and maintain a Laboratory Management Plan (LMP) containing certain required elements. The proposed rule applies only to hazardous waste generated in laboratories.

College and University Sector Policy Analysis: Definition of Facility, Final Report April 6, 2006
For the past several years, EPA has been investigating the environmental issues facing colleges and universities. The purpose of this report is to analyze the regulatory and policy issues specific to the college and university sector.  In particular, this report: