6 th Annual Radiation Protection Supervisors Seminar 29/01/2015 Tony Butterworth – University RPA / RWA

6th Annual

Radiation Protection Supervisors Seminar

29/01/2015

Tony Butterworth – University RPA / RWA

Timetable•08:45 Arrival (tea, coffee and cake available)

•09:15 Introduction•09:20 Updates in Radiation Protection

•11:00 Morning Break (tea, coffee, and cake available)

•11.30 Radiation Database and Local Radiation Protection Issues

•12.00 Discussions, Any Other Business•12.10 Presentation by Dr. Tom Scott – Interface Analysis Centre

Director •12.40 Lablogic Presentation••13:15 Close

Updates in Radiation Protection

Legislative Matters

(1) IAEA - International Basic Safety Standards

International Basic Safety Standards

• The jointly sponsored edition of the Safety Requirements “Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards” was published as General Safety Requirements Part 3 in July 2014

• This edition supersedes the Interim Edition that was published in 2011

• Reflect international consensus to promote a common approach for ensuring safety


• Revisions follow the recommendations of ICRP e.g. infrastructure for radiological protection and safety:

legal frameworkregulatory authorityoperating managementemployees

and fundamental principles of radiation protection e.g. dose limitation - reduction of the equivalent dose for the lens of the eye


•Classification of:

•3 categories of exposure situations – planned, existing and emergency exposure situations

•3 categories of exposure – occupational, medical and public exposures


•Existing exposure situations are exposure situations that already exist when a decision on control or remediation has to be taken

•Includes natural background radiation and most exposure situations to radon as well as residues from past practices

•Exposure control is based on the use of reference levels (levels of dose or risk above which it is judged inappropriate to allow exposures to occur and below which optimisation of protection is implemented)


•Planned exposure situations are situations involving the planned introduction and operation of sources

•Planned exposure situations include both normal exposures and potential exposures

•Exposure control is based on dose limitation and dose constraint


• Emergency exposure situations are unexpected situations that occur during the operation of a planned situation, or from a malicious act, requiring urgent action

• Exposure control is based on the use of reference levels


• Dose limit = limit set from all regulated sources in planned situations

• Dose constraint/reference level = limit set from a single source in all exposure situations

(2) European Commission

Basic Safety Standards

EC Basic Safety Standards

• The Basic Safety Standards (BSS) Directive (2013/59/Euratom), was adopted on the 5thDecember 2013

• Published in the Official Journal of the European Union on 17th January 2014

• Lays down basic safety standards for protection against the dangers arising from exposure to ionising radiation


• Repeals 5 Euratom Directives which underpin UK regulation of ionising radiation through the Ionising Radiation Regulations 1999 and Radiation (Emergency Preparedness and Public Information Regulations) 2001

• Incorporates the latest recommendations from the International Commission on Radiological Protection (ICRP) published in 2007, and harmonises the EU regime with the Basic Safety Standards of the International Atomic Energy Agency (IAEA)


•Member States are required to bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by 6 February 2018

•HMG policy with regards to how this Directive will be implemented within the UK is still to be agreed and communicated


• HSE is engaging UK stakeholders to broadly ensure that a breadth of interested parties views inform the UK implementation of the Directive

• Existing Stakeholder working groups cover Occupational, Medical, and Public and Environmental Exposures

• Ionising Radiation Regulations 01/01/2018???

(3) International Atomic Energy Agency (IAEA)

IAEA Safety StandardsCurrent status (October 2014)

•129 are established of which 123 are published

•42 drafts are in the development process (30 to revise 41 published Safety Standards)

•Currently, 91% of the standards are established. 39% of the established standards are under revision

•The expected total number is 131

IAEA Safety Standards

•Regulations for the Safe Transport of Radioactive Material – 2012 Edition

•Establishes the regulations that apply to the transport of radioactive material by all modes of transport on land, water or in the air

•Provides requirements useful to governments, regulators, operators of nuclear facilities, carriers, users of radiation sources and cargo handling personnel

IAEA Safety Standards

•Decommissioning of Facilities (2014)

•Establishes requirements for the safe decommissioning of a broad range of facilities e.g. nuclear power plants, former military sites, and relevant medical, industrial and research facilities.

•It addresses all the aspects of decommissioning such as roles and responsibilities and strategy and planning

(4) Environment Agency

EA Guidance

•2011 – EA produced guidance on EPR 2010 out of scope radioactive substances activities e.g.

•VLLW•Small sealed radioactive sources•Uranium and Thorium•Small amounts of open radioactive sources•Medical and veterinary uses of radioactive sources

EA Guidance

•Guidance on Interpretation of ‘Relevant Liquid’

March 2013

•Schedule 23 to EPR2010 contains “out of scope” values for very low concentrations of Naturally Occurring Radioactive material (NORM) in solids liquids and gases and for solids and “relevant liquids” of other radioactive substances

EA Guidance•Initial guidance stated:

The term ‘relevant liquid’ allows certain types of liquid with specified hazardous properties to be treated as a solid for the purposes of EPR 2010 because the exposure pathways are the same as those for solids and the disposal of such materials is to a conventional ‘solid’ waste route i.e. disposal or transfer for the purposes of reuse or recycling, and not to drains, sewers, open water or ground water

EA Guidance

•“Relevant Liquid” means a liquid which is –

(a) Non-aqueous (primary constituent is not water – usually organic solvent); or

(b) Classified (or would be so classified in the absence of its radioactivity) under Council Regulation No. 1

272/2008 as having any of the following hazard classes and hazard categories (as defined in that Regulation)

EA Guidance

• (i) acute toxicity: categories 1, 2 or 3 (LD50/LC50 values defining respective categories)

• (ii) skin corrosion/irritation: category 1 corrosive, sub-categories: 1A, 1B or 1C

• (iii) hazardous to the aquatic environment: acute category 1 or chronic categories 1 or 2

EA Guidance

•Therefore to determine if a liquid is a relevant liquid there are two considerations –

•(1) is the liquid a non-aqueous liquid

•(2) does it have one of the specified hazard classes or categories

EA Guidance

• Guidance on NORM Industrial Activities

March 2013

• This guidance is for businesses and individuals who have to handle naturally occurring radioactive substances to determine whether the radioactive substances regulatory regime applies

EA Guidance

•EPR 2010 only applies to naturally occurring radioactive substances that meet two criteria:

•(i) They must arise from industrial activities that are specified in the legislation (NORM Industrial Activities)

•(ii) They must contain concentrations of naturally occurring radionuclides above specified values (NORM “out of scope” values)

EA Guidance

•If a substance does not satisfy both of these criteria then it is not subject to the radioactive substances legislation

•If it does satisfy the criteria, then it is subject to the legislation and will require permitting unless it is exempt

EA Guidance

EA – Radioactive Waste Advisers

•There is a requirement under European law for people who keep or use radioactive material, or who accumulate or dispose of radioactive waste, to appoint advisers, known as “qualified experts”, to advise them on radiological protection

•In the UK we call the qualified expert for radioactive waste management and environmental radiation protection a 'Radioactive Waste Adviser'


•Radioactive Waste Advisers (RWA) are specialists in radioactive waste disposal and environmental radiation protection who have demonstrated competence in the Radioactive Waste Adviser syllabus

•RWA is a similar position to the RPA

•RWA appointed in writing by the permit holder (Director of S&HS on behalf of UoB Council)


•UoB RWA – Tony Butterworth

•Certificate of Competence granted 01/09/2014 by RPA 2000

•Renewed every 5 years

EA – Draft Legislation - Enforcement Undertakings

•Comes into force 06/04/2015 (if passed by both Houses of Parliament)

•Will be implemented as an amendment to EPR 2010

•An alternative to prosecution for environmental offences

•Primary purpose is to allow the offender to restore and remediate any environmental damage they have caused

EA – Draft Legislation - Enforcement Undertakings

• If an operator has ‘technically’ committed an offence, but offers an enforcement undertaking, the EA accept it, and the operator completes the undertaking to their satisfaction, then the operator is not deemed to have committed an offence

• A tool for the EA to use where they believe that prosecution would be too heavy-handed

• Expectation that the EA will issue some examples pertinent to the RSR sector when legislation comes into effect

(5) NaCTSO

https://www.gov.uk/nactso

NaCTSO• UK Threat Level is currently SEVERE – a terrorist attack is

highly likely

• Current document - Security Requirements for Radioactive Sources, April 2011 (Restricted – available from RPA)

• provides detailed information on the specific security measures that must be applied to sources as part of the regime

• sets out the more general security requirements for site protection where radiological sources are based

NaCTSO

• For Source Categories 3 and 4 e.g. 2GBq Sodium-22 sealed source, Security level C requirements are:

• Compliance with IRR 99 and EPR 2010

• Site security plan (updated annually)

• Ability and options for upgrades of security for increased threat

NaCTSO

• Information security plan

• Personal background checks

• Provide a means to detect unauthorised removal of source

• Source protected from unauthorised access by 1 physical security measure

NaCTSO

Remember

Purchase of new permitted sealed sources may affect the NaCTSO security rating for the building and will need the advice of a CTSO Adviser regarding suitable security arrangements BEFORE sources arrive on site

Consult with RPA in first instance

NaCTSO• Euro-Protect 2012-2013 • A joint venture between NaCTSO and

Avon and Somerset Constabulary, with financial assistance from the European Commission

• The project aims to address the key challenge of how to protect Europe from the threat of terrorism, through partnership with the commercial and private sectors

NaCTSO

•The training is limited to public sector counter terrorism practitioners, from all of the EU Member States and includes practical guidance on how to identify vulnerabilities at key locations, how to survey sites and deliver structured and risk commensurate protective security advice

•In 2013, courses will focus on the protection of pathogens, toxins, radiological sources (including HASS) and pre-cursor chemicals

NaCTSO

• 3 sessions organised, situated in Bristol

•UoB involvement for biological and radiation exercises (HASS security arrangements)

•Post event response from CTSA -

‘The training programme has proven to be a great success and a fine advert for partnership between our two organisations’

Publications

ICRP Publications

• Publication 120 (2013) - Radiological Protection in Cardiology

• Provides guidance to assist cardiologists with justification procedures and optimisation of protection in cardiac CT studies, cardiac nuclear medicine studies, and fluoroscopically guided cardiac interventions

ICRP Publications• Publication 121 (2013) - Radiological Protection

in Paediatric Diagnostic and Interventional Radiology

• Provides guiding principles of radiological protection for referring clinicians and clinical staff performing diagnostic imaging and interventional procedures for pediatric patients

• Guidelines and suggestions for radiological protection in radiography and fluoroscopy, interventional radiology, and computed tomography

ICRP Publications• Publication 122 (2013) – Radiological Protection

in Geological Disposal of Long-lived Solid Radioactive Waste

• Updates and consolidates previous ICRP recommendations

• Includes the consideration of the different stages in the life time of a geological disposal facility

ICRP Publications• Publication 123 (2013) – Assessment of

Radiation Exposure of Astronauts in Space

• Astronauts not usually classified as being occupationally exposed in the sense of the general ICRP system for radiation protection of workers applied on Earth

• Describes the terms and methods used to assess the radiation exposure of astronauts, and provides data for the assessment of organ doses

ICRP Publications

• Publication 124 (2014) – Protection of the Environment under Different Exposure Situations

• Expands upon the Commission’s objectives in relation to protection of animals and plants in their natural environment and how these objective can be met

ICRP Publications

• Reference Animals and Plants (RAPs) – set of 12 identified, wide geographic distribution and typical of different environments

• Derived Consideration Reference Levels (DCRL’s) – relate to radiation effects to doses over and above their normal local background levels

• Different potential pathways of exposure – inhalation, ingestion, contamination, external exposure

ICRP Publications• Publication 125 – Radiological Protection in

Security Screening (2014)

• Principles of justification, optimisation of protection, and dose limitation are directly applicable

• If justified then the framework for protection as a planned exposure situation should be employed

• Consideration of several scenarios e.g. exposure of ‘stowaways’ in a cargo container

ICRP Publications• Publication 126 – Radiological Protection

against Radon Exposure (2014)

• Provides updated guidance on radiological protection against radon exposure

• Integrated approach for protection against radon in all buildings whatever their purpose and status of their occupants, rather than workplaces, mixed-use buildings and dwellings

ICRP Publications

• ICRP recommended derived upper reference level still set as 300 Bq/m3 (corresponds to a 10 mSv annual dose)

• ICRP strongly encourages national authorities to set national derived reference levels in the range 100-300 Bq/m3 taking economic and social circumstances into account

• (Current IRR99 workplace action level is 400 Bq/m3 and HSE dwelling action level is 200 Bq/m3)

SRP PublicationsJ. Radiological Protection Vol. 33 No. 1 (March 2013)

Radon exposure

•Installations of sumps in Ireland homes decreased radon levels by 80-90%

•Inspection of domestic radon preventative measures found barriers were commonly either not installed correctly or damaged on installation

SRP Publications

• A study into radon exposure from granite worktops installed in the home concluded that radon levels were x2000 lower than outdoor radon concentrations therefore there is a low probability of granite worktops causing elevated levels of radon in the home

SRP PublicationsJ. Radiological Protection Vol. 33 No. 2 (June 2013)

•26 year follow up study of Chernobyl clean-up workers from Estonia

•Cohort of 4810 men, contributing approx. 99K person-years at risk

•Study examined cancer incidence (1986-2008) and mortality (1986-2011)

SRP Publications•No definite health effects attributable to radiation

•However UNSCEAR 2008 report concluded mental health to be the major public health issue among exposed populations, particularly clean-up workers who were sent into a stressful and dangerous environment without adequate information and protective gear and live in fear of potential adverse health outcomes

•Study found that the elevated suicide risk has persisted


Assessment of Radiation Doses in the UK from the Fukushima Daiichi Nuclear Accident (11/03/2011)

•Conducted by Public Health England (PHE)

•Air monitoring performed, measurements of radionuclides in grass and soil were made and monitoring data from surface water, rainwater and ground deposition was recorded (29/03/2011 – 15/07/2011)

SRP Publications

•Doses were estimated for the main exposure pathways - inhalation of airborne radioactivity, ingestion of food and external irradiation from radionuclides deposited on the ground

•Confirmed their initial reporting that there was no public health risk and estimated doses were about the same as a person in the UK would receive in an hour from natural background


Developing the Radiation Protection Safety Culture in the UK

•Two areas identified as having a strong influence on UK society – healthcare and nuclear industry sectors

•2005, PHE reported that the annual collective occupational dose in the UK nuclear industry was similar in magnitude to that from the healthcare industry

SRP Publications

•Each sector has specific challenges, but with overlapping common factors

•Exchange of safety culture knowledge between the sectors may act to develop RP culture in both and have a wider impact in other sectors

•Examples of improvement action plans for each sector

SRP PublicationsRecent surveys (2011, 2014) in the medical sector

Average of 32% late, 11 % non-returned dosimeters per year

SRP Publications

Newsletters

European ALARA Network

• Issue 33 (September 2013)

• Incident in a Slovenian brewery due to incorrect installation of a new X-ray tube in a fill level gauge

• Maintenance worker replaced a circuit board in a gauging system – x-ray tube attached to board – however had been mounted incorrectly by supplier

• Tube window was facing a wrong direction when installed (towards worker rather than towards the production line)


• Worker noted that when the unit was operational there was no reading on a dose rate meter at the detector position however there was a significant dose rate at the position he was standing and had been standing when installing and testing the equipment

• Dose reconstruction estimated an effective dose of 5 mSv


•Lessons learned included:

•Introduction of a programme of workplace monitoring•Issue of personal dosimeters for maintenance staff•Basic radiation protection training for all workers working in the vicinity of sources of ionising radiation•Replacement of aging gauge equipment where spare parts were becoming increasing unavailable


• Issue 34 (February 2014)

• HSE Prosecution of Health Service Trust for Overexposure of an Interventional Radiologist

• 2011 Trust appointed a new interventional radiologist who used the same method for CT fluoroscopy that he had been using in Germany on a different manufacturer’s CT scanner

European ALARA Network• His technique involved him standing next to the CT

scanner and observing real time images which meant that his hands were in the main x-ray beam whilst carrying out procedures for up to 30 seconds at a time

• Only issued with a TLD body badge as ring badges were unavailable when he started

• Other doctors and managers deferred to his apparent ‘greater knowledge’ in operating the CT scanner

• Trust RPA not consulted


• 3 months later he was issued with ring badges and on analysis indicated a skin radiation exposure in excess of 500 mSv (IRR 99 annual extremity dose limit)

• Trust estimated his actual exposure was likely to have exceeded 1 Sv although he did not exhibit any form of immediate apparent radiation injury

• Trust fined £30,000 for breaches of IRR 99 – not having suitable and sufficient risk assessment in place and exceeding dose limit to the skin


• Lessons learned:

• Ensure procedures are in place to make sure new staff are given suitable information, instruction and training to enable them to work in a safe manner and in accordance with the organisation’s policies and procedures

• Ensure all new work activities are properly risk assessed – involve the RPA


• Issue 35 (October 2014)

• European ALARA Network Workshop Report – Education and Training in Radiation Protection: Improving ALARA Culture (7-9/05/2014)

• Consideration of how radiation protection education and training programmes can be delivered effectively and how these can improve radiation protection in practice and help disseminate ALARA culture


• Discussions based on:

• Building ALARA in radiation protection training programmes

• Measuring effectiveness of training• The role of qualification and recognition schemes• Training tools and methods• National approaches to training

European ALARA Network• Conclusions and recommendations:

• Assessing the effectiveness of training should be promoted by Regulatory Authorities and professional societies

• Training should include up-to-date training techniques and technologies as well as radiation protection theory

• Training should be practical and realistic including the use of real radiation sources where appropriate


• On-the-job training should be properly structured and involve suitably trained mentors

• Member States should aim to establish clear and transparent national schemes for the recognition of Radiation Protection Expert competence

• Develop education and training in radiation protection for the public and include radiation protection information and data on the Internet

OTHEA Reports

• 1. Contractors contaminated when clearing out a vacant building

• Locked metal cabinet being moved by 2 contractors• A bottle inside broke and liquid started seeping out• Opening the cabinet revealed x4 1.5L unbroken bottles

x1 broken 2.5L bottle

x1 empty plastic drum• All were labeled with ‘radioactive material’ tape

OTHEA Reports

• Liquid (organic) had contaminated the hands and forearms of the 2 contractors

• Subsequent investigation concluded each bottle contained approx. 40kBq C-14 in toluene - < 1 % ALI and likely that only a small fraction of this activity would have been taken into the bodies of the contaminated persons

• Therefore internal doses from this incident were negligible

OTHEA Reports

• Fortunate that higher activities or more radiotoxic materials were not involved and significant radiation doses were not incurred


• All radioactive material should be accounted for (physical check and records) and removed before occupiers vacate the premises

OTHEA Reports

• Appropriate monitoring should always be carried out (and recorded) in order to verify that any contamination has been removed

• Advice should be sought if any suspect items found which are labelled with the radiation trefoil sign BEFORE items are moved/removed

OTHEA Reports

• 2. Unsafe transport of waste radiotherapy source

• Company contracted to move a disused radiotherapy source (129 TBq Co-60 sealed source) to a waste repository 160km distance

• Used a Type B container, transport by road, journey time approx. 3 hours

OTHEA Reports

• When consignment arrived monitoring confirmed a narrow collimated beam was being emitted vertically downwards from the package giving a dose rate of 3.5 Sv/hr

• Subsequent investigation by the regulatory authorities found that a vital shield plug was missing from the transport container allowing the beam to be emitted

• Contractor order to pay a total of £358,000 in fines and costs

OTHEA Reports

• Concluded that there was no evidence that anyone had received a significant radiation exposure during preparation and transport of the source

• However there was a potential for persons to exceed the dose limit within seconds and suffer deterministic injuries within minutes or hours

• If an employee had been exposed to the radiation beam for the duration of the journey this could have proved fatal

OTHEA Reports


• Transport quality assurance procedures must be adhered to

• Satisfactory monitoring must be carried out by consignors to ensure radiation doses are as expected

AURPO Newsletters

•Reminder – HSE Notification

•Radiation employers need to inform the HSE when details of a previous notification are no longer correct, e.g.

•Employer’s details or those of their premises change•The source category changes•The source is to be used at a different premises

AURPO Newsletters

• ‘Security by Design’ workshop report – Stockholm January 2014

• Approach to high activity source security in USA is now focussed on the ‘insider’ threat – an authorised user who is coerced or subverted to access or provide access to a high activity source by bypassing all the external physical security measures and detection systems

• NaCTSO are following suit

AURPO Newsletters

• EA RSR Inspections

• 2013 – EA inspected approx. 1500 sites nationally

• Frequency of inspection –

Permits C,D, and H – annuale.g. precinct sealed sources, precinct

unsealed sources

Permit G - Every 2 years

e.g. Langford unsealed sources

AURPO Newsletters

•Notes from the Small Users Liaison Group (SULG) Meeting – 10th June 2014

•92% of sites scheduled for an annual EA inspection had received a visit

•ONR undertook 31 transport audits on hospitals, including serving 3 improvement notices on one hospital for failing to implement previous audit findings

AURPO Newsletters

•HSE inspections now occur reactively

•Current concerns involve site radiography equipment several incidents have occurred involving source detachment and a snapped cable

•Reported that contamination had been found on brachytherapy sources supplied to hospitals – operators reminded to check for contamination both pre and post installation

AURPO Newsletters•ONR Safeguards

•Meetings with Euratom Inspection and Accountancy sections concluded that National Location Outside Facilities (NLOF’s) may be set up in the UK

•Operators within an NLOF report to ONR Safeguards who will then submit formal reports to Euratom

AURPO Newsletters

•Trial with 26 organisations reporting DU inventories has been successful

•Will be rolled out to a further 36 organisations including Universities

•Euratom have not agreed to de minimus levels as they still want an opportunity to inspect an organisations accountancy system and physical holdings

WINS – Best Practice Guides

•WINS = World Institute for Nuclear Security

•https://www.wins.org/index.php?article_id=61

•Provide an international forum for those accountable for nuclear security to share and promote the implementation of best security practices

•Produce Best Practice Guides – 33 produced to date


•1.4 Nuclear Security Culture•3.4 Managing Internal Threats•4.4 Material Control and Accountancy in Support of Nuclear Security•5.1 Security of High Activity Radioactive Sources

•All include questionnaires for senior managers / first-line supervisors / staff


•E.g. 3.4 Managing Internal Threats - Questionnaire for first-line supervisors:

•Is consideration of the consequences of malicious internal acts a part of the risk management process?

•Are you confident that security incidents by individuals are being reported by your managers without delay?


•RPA will email RPS’s (via) database with a list of the best practice guides – RPA can then send copies to RPS’s on request

•May be useful in raising awareness amongst staff regarding security of radioactive sources and improving the security culture within your Schools

UK Prosecutions

•29/09/2014 - Rolls Royce Marine Power Operations Ltd has been fined £200,000 and ordered to pay costs of £176,500 following the loss of a radioactive source at its plant in Derby

•Significant failings led to a radioactive source (a capsule which was the size of a small screw) being lost for approximately five hours at the Sinfin Lane site on 3 March 2011

UK Prosecutions•On the day of the incident the source was being used in a purpose-built radiography enclosure. During the work the source capsule became detached from its holder, was lost out of the end of the guide tube being used and ended up inside the component being tested

•The loss of the source was not detected by the safety features of the radiography enclosure or by the radiographer in charge of the work

UK Prosecutions•The loss of the radioactive source was discovered when welders working on the component in the clean room spotted the capsule and removed it for examination, passing it amongst themselves.

•The radiographers returned for their next shift at this point and after some initial confusion, which involved some of them directly handling the capsule, they correctly identified the object as a radioactive source. The room was cleared, the radioactive source recovered and the area made safe

UK Prosecutions•The subsequent investigation by the Health and Safety Executive (HSE) and the Environment Agency found the workers’ hand exposure to radiation was considerably in excess of the annual permitted dose of 500 mSv

•In some cases it was exceeded by up to 32 times the permitted amount

•The investigation also found that the company failed to ensure that a suitable and sufficient risk assessment was in place for the gamma radiography work carried out on site

UK Prosecutions

• Inadequate procedures together with deficiencies in training led to Rolls Royce Marine Power Operations Ltd failing to ensure that robust and effective controls were in place to manage the risk of using high activity radioactive sources

• Additionally, the capability of the radiation monitoring equipment was not well understood and failed to detect where the radioactive source was at all times which is an essential requirement when carrying out radiography work

UK Prosecutions

•Pleaded guilty to breaching:

•Sections 2(1) and 3(1) of the Health and Safety at Work etc Act 1974•Regulation 3(1)(a) of the Management of Health and Safety at Work Regulations 1999•Regulation 11 of the Ionising Radiation Regulations 1999•Three counts of breaching Regulation 38(2) of the Environmental Permitting Regulations 2010

UK Prosecutions

•31/03/2014 - Mistras ETS Ltd, based at Dillington, Cambridgeshire, was fined £30,000 and ordered to pay £4,930 in costs after one of its workers suffered radiation burns while carrying out tests on safety equipment on19 September 2012

•The man suffered severe tissue damage to the middle, ring and little fingers of his right hand

UK Prosecutions

•He had been working in a radiography bay with x-ray equipment when a separate team was asked to test safety equipment and warning beacons, which also required the use of x-ray equipment

•The other employees devised an ad hoc test method that involved turning off safety access controls and warning alarms for the radiography bays. During one test, the injured worker remained in a radiation bay, while the x-ray was energised

UK Prosecutions

•The HSE investigation found that the workers had not used the x-ray equipment to test the safety equipment before, and that there were no procedures in place for them to carry out the tests safely

•As a result they developed their own ad hoc method, which led to several important safety devices being switched off

UK Prosecutions

•Pleaded guilty to breaching:

•Section 2(1) of the Health and Safety at Work etc Act 1974

•Regulation 11(1) of the Ionising Radiation Regulations 1999

UK Prosecutions

•07/10/2013 - United Lincolnshire Hospitals NHS Trust was fined a total of £30,000 and ordered to pay costs of £15,128

•An interventional radiologist working with a CT scanner at Pilgrim Hospital, Boston, received more than double the annual dose limit for skin exposure in just over three months

UK Prosecutions

•His work involved the insertion of biopsy needles into patients, which he carried out using the CT scanner operating in continuous “fluoroscopy” mode for up to 30 seconds at a time, giving “real time” x-ray images which he observed whilst standing next to the scanner

•Whilst inserting the biopsy needles he was placing his hands directly in the main x-ray beam, resulting in an overexposure of radiation to his hands

UK Prosecutions

•The scanner, which the trust had bought in 2009, was used by a number of other consultants for the same purpose but they used the conventional “step and shoot” method which required them to leave the room when the CT scanner was generating x-rays

•An investigation by HSE found that the Trust had never carried out a risk assessment for the CT scanner operating in the fluoroscopy mode so a safe system of work was not developed

UK Prosecutions

•In addition, managers were aware that this technique was being carried out but did not ensure proper procedures were followed

•Pleaded guilty to breaching Regulations 7(1) and 11 of the Ionising Radiations Regulations 1999

Also Making the News…

•‘Shocking extent of radioactive waste dumped in Scottish seas’ (thecourier.cu.uk, 10/11/2014)

•Documents at the National Records of Scotland have emerged which show more than 75,000 luminised dials coated with radium were tipped into the Tay Estuary after the Second World War between 1954 and 1956 without permission


•Documents also show how the firm UK Time — a forerunner to Timex — arranged a deal with local fishermen to put 35,000 luminised dials coated with radium into drums and dump them in the Tay Estuary in 1949

•The arrangement, according to Scotland Office papers, continued for eight more years at an estimated 5,000 dials a year before dumping was switched to the UK Government’s site at Beaufort’s Dyke between Northern Ireland and Scotland


•‘Kazakhstan authorities on high alert after radioactive container goes missing’ (The Guardian, 02/09/2014)

•A container holding the radioactive substance caesium-137 disappeared in the west of the country

•A police spokesman for the Mangistau region said the material – commonly used for military and medical purposes – appeared to have fallen off a vehicle that was transporting it


•The origin of the missing material was not revealed by authorities in Kazakhstan, which inherited nuclear warheads and a weapons test site when the Soviet Union collapsed

•More than 100 incidents of thefts and other unauthorised activities involving nuclear and radioactive material are reported to the IAEA each year

Also Making the News…•‘Radioactive canister stolen from van in Lancashire’ (BBC News 18/02/2013 and 14/03/2013)

•The heavy lead yellow canister containing a "small amount" of material, believed to be Iridium 192, was taken over the weekend from a Peugeot Panel Van parked in New Line, Bacup

•A suspicious package was found at Point Retail Park in Rochdale at about 12:45 GMT. It was declared safe by police and has been removed

Conferences & Meetings

SRP Conference 17/10/2013• Practical Radiation Protection

• EPR - An Inspector Calls, Amber Bannon, RSR Inspector

• EPR Permits address :

• Management Systems• Security• Infrastructure• Radionuclide management • Waste management

SRP Conference 17/10/2013

•Users must demonstrate compliance with ALL permit conditions –

Ensure users read and understand permit conditions

Copy of Permit must be available so as to be conveniently read by persons having duties on the premises


•Users must comply with limits specified in permit -

Ensure radionuclides and associated limits are appropriate to activities

Demonstrate compliance – good records!


• Management Systems

• Roles and responsibilities• Staff training• Project approval and risk assessment• Procurement, control, use, waste management• Record keeping• Decommissioning

SRP Conference 17/10/2013• Security

• NaCTSO requirements – sealed sources

• Robust procedures – delivery/acceptance processes

• Physical barriers – secure doors and windows, safes, lockable fridges/freezers, robust containers

• Electronic measures – alarms, CCTV, restricted access e.g. pin numbers, swipe cards


• Infrastructure

• Concentrating work in fewer areas – reduces facility design constraints, limits potential contamination

• Avoid contamination – good practice / housekeeping / maintenance

• Contamination monitoring

SRP Conference 17/10/2013• Radionuclide Management

• Co-ordination of purchasing• Rigorous ordering procedure• Central stock for several users• Use minimum quantities• Demonstrate storage of RA material has been well planned

and implemented• Muster checks• Regular audits


• Waste Management

• Documented BAT assessment – identify all waste streams• Identify how to handle waste created• Identify disposal routes for all possible waste streams• Justification for all accumulation – decay and co-ordination of

waste collections• Assess environmental impacts• Ensure systems and equipment are maintained


• Storage facilities should be:

• Clean• Tidy• Well Organised• Take account of other hazardous properties e.g. biohazard• Bunded if storing liquids

SRP Annual Conference 29-04/2013 – 01/05/2014

Radiation Protection Goals – Guidance, Operational Experience, ALARP, Legislation, Sustainability

•ALARP – RP Culture and More – John Croft

•ALARA = keeping doses As Low As Reasonably Achievable


•Legislation prior to 1970’s :

•Ionising Radiations (Sealed Sources) Regulations 1969

•Ionising Radiations (Unsealed Radioactive Substances) Regulations 1968

•Radioactive Substances Act 1960

ALARA ???


ICRP 26 (1977)

‘All exposures shall be kept as low as reasonably achievable, economic and social factors taken into account’

•Focus on quantitative decision aiding techniques:

•Cost-benefit analysis•Cost effectiveness analysis


• IRR 1985 + ACOP + Guidance

• Quantum change in importance of ALARP

• Introduction of RPA• Proactive Regulators• Professional bodies


• ICRP Publication 55, 1990 - Optimization and Decision-Making in Radiological Protection

• Considered all aspects of optimisation, including cost-benefit, at different levels of complexity

• ICRP Publication 60, 1991

• Explicitly extended ALARA to encompass ‘likelihood of being exposed’ – accident scenarios


• International Radiation Protection Association (IRPA)

• Guiding Principles for Establishing a Radiation Protection Culture, 2014

• Aims to provide guidance to help equip radiation protection professionals to promote a successful RP culture in their organisation and workplace


•RP safety culture includes:

•Clear management commitment

Priorities, processes and deedsClear responsibilities and authority

•Appropriately knowledgeable and trained workforce

Awareness, understanding and competence


• RP culture initiative also supported by:

• World Health Organisation• European ALARA Network• Health Physics Society• American Association Physicists in Medicine


• Current RP culture initiatives:

• Continuing thread in IPRA Congresses

• Part of SRP strategic plan to develop guidance on and implementation of RP culture – working groups set up with sectorial sub-groups (nuclear/medical/research & teaching)

South West Counter Terrorism Intelligence Unit (CTIU) Conference 24/09/2014

•Security Awareness

•Local Resilience Forums (LRFs)

The LRFs aim to plan and prepare for localised incidents and catastrophic emergencies. They work to identify potential risks and produce emergency plans to either prevent or mitigate the impact of any incident on their local communities

South West CTIU Conference 24/09/2014

•LRFs are multi-agency partnerships made up of:

•Category 1 Responders - representatives from local public services, including the emergency services, local authorities, the NHS, the Environment Agency and others

•Category 2 Responders - such as the Highways Agency and public utility companies

•LRFs also work with other partners in the military and voluntary sectors


•43 LRFs in England and Wales

•Avon and Somerset LRF

•Revised Risk Register (v 5.0) – August 2014

•H11 – Accidental release of radioactive material from incorrectly handled or disposed of sources


•Up to 5 fatalities and up to 100 contaminated people requiring medical monitoring. Many worried people may present at hospitals. Radiation may be spread over several kilometers but most concentration where source is opened

•Likelihood - Low (1)•Impact - Significant (3)•Risk Rating - Medium•Assessment Assessor - Environment Agency


•Risk Rating – Very High

•Catastrophic Impact

•H44 – major reservoir dam failure/collapse (n=15)

•HL34, HL8 – fire, flooding, stranding or collision involving a passenger vessel in, or close to, UK waters leading to the ship’s evacuation or partial evacuation at sea


•Insider Threat

•Centre for the Protection of National Infrastructure (CPNI)

•CPNI protects national security by providing protective security advice, covering physical security, personnel security and cyber security/information assurance

Insider Data Collection Study - Report of Main Findings, April 2013


•Study analysed over 120 UK-based insider cases from both public and private sectors between 2007 and 2012

•Insider Definition:

•A person who exploits, or has the intention to exploit, their legitimate access to an organisation’s assets for unauthorised purposes


•Volunteer/self-initiated insider: those who obtain employment without deliberate intent to abuse their access but at some point personally decide to do so (76%)

•Exploited/recruited insider: those who obtain employment without deliberate intent to abuse their access but at some point are exploited or recruited by a third party to do so (15%)

•Deliberate insider: those who obtain employment with the deliberate intent of abusing their access (6%)


•5 main types of insider activity identified:

•Unauthorised disclosure of sensitive information to a third party or media (47%)•Process corruption – illegitimately altering an internal process or system to achieve a specific, non-authorised objective (42%)•Facilitation of third party access to an organisation’s assets•Physical sabotage•Electronic or IT sabotage


• Significantly more males involved with insider activity (82%) than females (18%)

• 49% of insider cases occurred within the 31-45 years age category

• Majority of insider acts were carried out by permanent staff (88%) – only 7% cases involved contractors and only 5% involved agency or temporary staff

• Duration of insider activity ranged from less than 6 months (41%) to more than 5 years (11%)


•More than 50% of the cases were identified within the first year

•60% cases were individuals who had worked for their organisation for less than 5 years

•76% cases were self-initiated

•6% deliberate infiltration


• Motivation for insider actions included:

• Financial gain (47%)• Ideology (20%)• Desire for recognition (14%)• Loyalty to friends/family/country (14%)• Revenge (6%)

• However reasons for actions were complex, often involving more than one motivational factor


• A clear pattern identified between primary motivation and the type of insider incident

• Ideology and desire for recognition were closely linked to unauthorised disclosure of sensitive information

• Financial gain was most closely linked to process corruption or giving access to assets


• A clear link between an insider act taking place and exploitable weaknesses in an employer’s protective security and management processes. Weaknesses include:

• Poor management practices• Poor use of auditing functions• Lack of protective security controls• Poor security culture• Poor pre-employment screening• Poor communication between business areas

SRP Conference 15/10/2014• Practical Aspects of Decommissioning, Waste

Management and Radiological Assessments

• Decommissioning: Environment Agency Expectations, Gary McMeekan, Nuclear Regulator

• Government definition of decommissioning: To remove the hazard the facility poses progressively, giving due regard to security considerations, the safety of workers and the general public and protecting the environment


• The decommissioning ‘spectrum’

• Fairly straightforward - short half-lives, work in small defined areas, low waste volumes, delay an decay option?

• The challenging - post ‘accident’, known legacy issues, wide range of nuclides, ‘diffuse’ work areas, significant waste volumes

SRP Conference 15/10/2014• Best Available Techniques (BAT)

• A simple test for BAT – can anything further be done to reduce radiological doses? If so , do it, unless the detriments are grossly disproportionate to the benefits gained

• BAT relates to optimisation – if BAT doesn’t provide adequate protection then additional measures must also be used


• People

• The ‘knowledge capture chestnut’• Suitability of those in critical roles, e.g. RWA

• Plant Life Extension

• How does this change decommissioning plans?

Coffee Break(30 minutes)

UoB Regulatory Visits


• Site visits since last RPS seminar have included:

• Euratom Safeguards (Precinct - 24/04/2013)

• Environment Agency (Langford - 20/03/2013)

(Precinct – 29/05/2014)

• NaCTSO (Precinct – 29/05/2014)

UoB Regulatory VisitsEuratom Safeguards (Precinct - 24/04/2013)

‘The inspection proceeded smoothly without any issues which resulted in positive feedback from the Euratom Inspector on the best practices used at Bristol University for their internal accountancy systems

Furthermore thank you for your excellent efforts in the understanding of the Euratom reporting requirements and your time and dedication in compiling and submitting timely and accurate Euratom formal declarations’

(ONR - Safeguards)


Environment Agency Radioactive Substances Compliance Assessment Report (RASCAR 1)

(1) 20/03/2013 – Open Sources Inspection – Langford

‘Inspection of the facilities showed that the designated areas were well defined and labelled and clean and tidy. The radioactive waste store was tidy and well ordered’


(2) 29/05/2014 – Closed Sources Inspection - in conjunction with NaCTSO

‘HASS security and alarm systems were demonstrated and found to be working well. A suitable and robust process has been introduced for the vetting of staff. Records were inspected for several authorised employees and found to be satisfactory’


‘A number of sealed sources are used by the School of Physics. Security features were demonstrated and found to be satisfactory. The ordering procedure for sources was inspected, found to be readily available and understood well by staff’

Minor amendments to training documents and labelling of sources and their containers were highlighted for action

Radioactive Source Database

and Local Radiation Protection

Issues


•Source and aliquot listing for weekly checks - option now implemented via list sources menu

•Download user data - option now implemented from the registered users menu

•Change to risk assessment RP2 form so that if ‘System of Work’ is selected a text box requiring further control measures must now be completed


•Database will move to a new dedicated server in the next few months with minimal downtime

(1 day)

•RPA will keep all users informed via database emails

Local Radiation Issues

• Training – Radiation Workers using Unsealed Sources

• Basic Radiation Protection Unsealed Sources – Refresher Training

• Now available using Blackboard

• 5 Test Papers available (+1 for LVS)

• All users must take a refresher test every 3 years – RPS’s to manage local arrangements


• Training – Transport of Radioactive Materials by Road

• Basic Transport Course – run every 6 months (March /September)

• Refresher Course (multiple choice questionnaire based on current AURPO transport document) to be taken every 3 years

• Transport of RAM by road must involve 2 persons – one trained


• Occurring in 2015

• Monitor calibration date:

Wednesday February 11th


• Please provide:

• List of monitors - include serial numbers

• EL1, 2 and 3 codes for recharging purposes • e.g. SAFE HF4454 6646

• Ensure all monitors are easily identified (tagged)



• Annual stocktakes sealed and unsealed sources – 31st July -

• Unsealed Sources - RP11 for each storage location/lab, RP13 – Justification Form, Radioactive Source Database stock list print-out, signed by RPS

• Sealed Sources – RPS Signs print-out of central listings – if any information has changed e.g. location, complete an RP6



• Leak testing of sealed sources (every 2 years) – complete an RP12 for each source

• Enterprise Resource Planning (ERP) – scheduled for implementation April 2015 (?) – will operate in the same way as PROACTIS for radiochemical orders i.e. order template / RPS approval

• Langford incinerator will be decommissioned (Summer)


Top 10 Audit Recommendations 2013 - 2014

1. HoS is kept informed of radiation issues – RPS attends safety meetings with radiation an agenda item

2. RPS cover for annual leave/extended leave/sickness absence

3. Update local rules (annually) to ensure current practices and arrangements are detailed

4. Radioactive Source Database user registrations and risk assessments are current

5. Instigate a procedure for contingency planning training

Local Radiation Issues Top 10 Audit Recommendations 2013 - 2014

6. If local training is given to new users by someone other than the P.I then formal notification of this task delegation must be sent to the RPS

7. Formally record source checks - unsealed sources = weekly sealed sources = monthly

8. Complete EA Permit compliance document(s)

9. Ensure fridges/freezers are regularly defrosted (especially if storing 3-H)

10. Formally record inspections of PPE


• New Sources of Ionising Radiations

• RPA MUST be informed as early as possible in the procurement process – may require:

• Changes to EA Permit• Building works• Appointment and training of staff

Time and cost implications


UoB Incidents 2013-2014

1. Unauthorised acquisition of radioactive material:

• not using PROACTIS HAZSUB template

• bypassing RPS approval

• incorrect delivery point used for radioactive material



• ensure refresher training is given to users at suitable intervals (sign-off against local rules)

• If a company is not listed when using the Proactis Hazsub template then contact the RPA who will ensure the company is added

Local Radiation Issues2. Personal contamination incident:

• Clean up of a ruptured sealed source, worker was wearing vinyl gloves, lab coat and safety glasses

• After removal of gloves, monitoring of hands gave 100cps to skin surface


• Double glove in contingency scenarios where it is likely that radioactive material could come into contact with the hands

Local Radiation Issues3. Radiation worker received a cut to the skin:

• Using tweezers to prize a radioactive sample from its metal stub, the tweezers slipped and punctured the finger holding the stub

• Double gloves, lab coat and safety glasses were being worn by the worker

• Gloves removed and finger washed under running water for 5 minutes (from a sink in a nearby toilet)

Local Radiation Issues• Lessons learned:

• Risk assessments and SOP’s should be reviewed at least annually and always after an accident/incident or significant change to working procedures

• Risk assessments should include contingency planning for reasonably foreseeable accident scenarios

• Radioactive contamination should always be washed off in a designated radiation sink

Local Radiation Issues• Lab Decommissioning

• International / UK Regulator / Sector Guidance

• IAEA Safety Standards No. GSR Part 6 – ‘Decommissioning of Facilities’ (July 2014)

• SEPA ‘ Guidance on Decommissioning of Non-nuclear Facilities’ (November 2013)

• SRP ‘ A Practical Guide to Decommissioning for the Medical, Industrial or Research Small User’ January (2011)


• Decommissioning Plan to include:

• Description of areas where radioactive substances are or have been used including any that may be contaminated by discharges, leaks or spills

• An outline contamination monitoring protocol

• Anticipated destinations for all radioactive materials and wastes in the premises


• Permit holders must return areas to a satisfactory state:

• Dose to any future user of the premises from any radioactive substances or contamination left in situ will be 10 µSv per year or less

• No radioactive materials or waste left on site that requires permitting


• No radioactive substances or contamination will be left on premises that is likely to result in radioactive waste being generated in the future that will require regulatory approval to be disposed of

• Any loose or mobile contamination will be removed

• There are no radioactive trefoils, markings or labelling remaining on the premises


• At present – RPS to complete an RP10a Clearance Certificate indicating areas monitored /swabbed and remedial action before decommissioning

• Copy sent to RPA for central file

• Signs removed – lab door, sink, sink pipework, fume cupboard (remember to remove discharge point signage), fridge, freezer, etc.

• RPA removes details from Radioactive Source Database


• Further requirements proposed:

• RPS to keep a local log of usage of registered labs to detail:

• Name of P.I • Time of occupation• Isotopes used and maximum activities• Brief description of work• Disposal routes

• RPS to attach log to RP10a when lab is decommissioned


• Donated Equipment

• A range of: perspex screensleaded glassperspex pipette guardsGM mini-monitors (beta probes)

available from the RPA

And Finally…..

How Radioactivity Can Authenticate a Vintage Wine

SRP Newsletter Issue 52 (Summer 2014)

And Finally…..

Nuclear tests in 1950’s and 1960’s released large quantities of artificial radionuclides into the atmosphere – only those with long half lives remain e.g. Cs-137 and over time have been deposited more or less evenly throughout the globe – including grape vines

Late 1990’s development of low background germanium semiconductor detectors – sensitive to very low levels of radioactivity

And Finally…..•Such detectors can highlight the presence of Cs-137 in the wine and variation in its activity as a function of years

•Peaks of activity due to atmospheric nuclear tests between 1952 and 1964 can be detected as well as a peak due to the accident at the Chernobyl nuclear power plant in 1986

•Wine can therefore be ‘dated’ against this reference curve and determine whether it is authentic in view of the expected Cs-137 activity

And Finally…..

•Also possible to identify fraud for great vintages e.g. those before 1950 where traces of Cs-137 are not expected

Discussions A.O.B