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We are the Environment Agency. It’s our job to look after your environment and make it a better place – for you, and for future generations. The Environment Agency. Out there, making your environment a better place.
Radioactive Substances Act 1993 Regulation of Non-Nuclear Sites
Amber Bannon
RSR Technical Specialist
6 October 2009
Objectives
Overview of legislative requirements
Understanding of RSA93 certificates and their conditions
What to expect during an Environment Agency inspection
Key Legislation for EA Inspectors
1993 Radioactive Substances Act (RSA93)1995 Environment Act (EA95)Ministerial Direction (Radioactive Substances (Basic Safety Standards) (England and Wales) Direction 2000)2005 High-Activity Sealed Radioactive Sources and orphan Sources Regulations (HASS) Environmental Permitting Regulations (imminent!)
Radioactive Substances Act 1993
RSA93 defines radioactive materialContains natural radioactivity at a concentration in excess of values in Sch1 of the ActContains any man-made radioactivity
RSA93 defines radioactive wasteSubstance or article which is radioactive material and has been designated as waste ie. no longer required for use!Substance or article which has become contaminated by radioactive material or other radioactive waste
Radioactive Substances Act 1993
Requirement for users to register use of radioactive substances on premises used for the purpose of an undertaking
Regulates the keeping and use of radioactive material
Regulates the accumulation and disposal of radioactive waste
Environment Act (EA95)
Established the creation of the Environment Agency
S108 – specifies Powers of Entry
S110 – offence to obstruct an authorised person in the exercise of their duties or to pretend to be an authorised person
Ministerial Direction (Radioactive Substances (Basic Safety Standards) (England and Wales) Direction 2000)
Issued under EA95Requires the EA to ensure all exposures to ionising radiation from the disposal of radioactive waste are kept as low as reasonably achievable; economic and social factors being taken into accountAs low as reasonably achievable = BPMBPM condition introduced into RSA93 authorisations in 2003Annual dose constraints:
0.3 mSv for any new source0.5 mSv for any single site1.0 mSv dose limit
Undertakings required to appoint Qualified Experts for radioactive waste management
High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005
Modified RSA93
Stringent new conditions
Security
Financial Provision
High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005
What is a HASS?A sealed source containing a radionuclide listed in Annex 1 of the HASS Directive and whose activity at the time of manufacture is equal to or exceeds the relevant activity level specified in Annex 1; orA sealed source containing a radionuclide which is listed in Annex 1, Table A of the BSS Directive and whose activity at the time of manufacture is equal to or exceeds one hundredth of the corresponding A1 value given in the IAEA Regulations for the safe transport of radioactive materials; orA sealed source, not included in the above, containing a radionuclide for which an A1 value is given in the IAEA Regulations and whose activity at the time of manufacture is equal to or exceeds one hundredth of that A1 value
High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005
A source becomes a HASS at the point when it is ready for saleA source ceases to be HASS only when the activity falls below the exemption levels specified in the BSS DirectiveHASS Regulations implement stringent controls for the life of the sourceExamples are medical teletherapy sources and irradiators
High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005
What is a source of similar level of potential hazard to a HASS?
Any source or aggregation of sources in a single store or use location which falls into source categories 1 to 4 in the NSAC security documentPrimary means of allocating a category is practice, eg. brachytherapy, high/medium dose rates = Category 2Secondary means is by using A/D values
• A = source activity• D = activity of a source above which it is considered to be
a “dangerous source”• D values are listed in NSAC security document
Environmental Permitting Regulations
Will come in to force 01 April 2010
Scope of what we regulate will not change
Regulations will provide a new way of permitting
“better regulation”
should be no increased regulatory burden
Environmental Permitting Regulations
Key points“permit” required for a regulated facility carrying out a radioactive substances activity
Permit transfers will be easier
All applications will require some consultation
All applications will be advertised (National Security excepted)
New process for surrender of permits
Legislation not Covered by EA RSA93 Inspectors
1999 Ionising Radiations Regulations
Ionising Radiation (Medical Exposure) Regulations 2000
Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007
Transfrontier Shipment of Radioactive Waste/Radioactive Substances
Inspection Issues
certificates
management systems
radioactive materials
laboratories
radioactive waste
enforcement
RSA93 Certificates
4 types of certificates:-Sealed sources Registrations
Open sources Registrations
Authorisations for waste accumulation/disposal
Mobile sources Registrations
Management Conditions
Stringent management conditions included in sealed source and authorisation certificates
Key inspection topicRadiation Management Policy
• Signed by Chief Executive
states users intentions on key areas of the use of radioactivity on site
Assists decision making
further documentation (procedures and work instructions) should then provide step-by-step instructions on how to comply with the Policy
Management Conditions
Radiation Management Policy should cover:-structure/organogram/communication/reporting lines roles and responsibilitiesfinance/resourcestrainingmaintenanceemergency preparedness enforcement/disciplinary measureslist of proceduresinternal compliance/QA systemsBest Available Techniques review
Key Procedures
Facility designStaff trainingRisk assessmentProject approvalMaterial orderingMaterial control and useWaste handlingContamination and monitoringRecord keepingDecommissioningManagement of changeUndertaking a BAT assessment/review
Compliance Table
Authorisation AA1234
Condition Purpose Compliance
Sch 1 C1 a Management and resources
RSA93 compliance document Radiation Policy List of written operating procedures BPM statement
Sch 1 C8 Reporting lost radioactive waste
Procedure GST001/01
Sch 1 C12 Record keeping Procedure GST001/02
Radioactive Materials
Request appropriate limits
Request appropriate nuclides
Request appropriate accumulation periods for waste
Assess proposed disposal routes
Stay within your limitsRecords
Control procedures
Laboratories
Avoid contamination Facility design
Good practice / housekeeping
Contamination monitoring
Radioactive Waste
Production
Storage
Records
Disposal
Waste Production
Best Available Techniques!Planning new, refurbished, modified or enlarged production or processesConsidering how production or process is to be carried outMinimisation of the quantities of radioactivity in useWaste minimisation techniques to be employedChoice of discharge route (e.g. use of fume cupboards)Method for minimising contaminationPossible need for abatement of dischargesMaintenance requirements and methodsPrevention of fugitive emissions by process and plant improvementImplementation of a policy of continuous improvement to reduce disposals and discharges, including regular reviewWaste sampling, measurement or estimation and on radiological assessment requirements
Waste Production cont.
Should include:-Justification with a little “j”!OptimisationRisk assessmentFacilities designProceduresWaste managementSecurityDecommissioning
Waste Storage
Storage facilities should be:-clean
tidy
well organised
take account of other hazardous properties eg. biohazard
Waste Disposal
Manage waste to ensureDisposals are made to the appropriate disposal route
Disposals happen on the intended date
Waste is monitored prior to disposal
Suitable records made
Enforcement
WHEN THINGS GO WRONG…….
Site Warnings
Warning Letters (sent to CEO/Rector/Dean)
Formal Caution
Prosecution
Enforcement Notice
Prohibition Notice
ANY QUESTIONS?