EASR

Question 1

What does EASR18 Stand for and what is it for?

Answer 1

Environmental Authorisations Scotland Regulations 2018

Protection of environment and population from use of radioactive substances

Regulates what radionuclides can be HELD and MANAGEMENT and DISPOSAL of radioactive waste

Question 2

Who is the regulator of EASR18?

Answer 2

SEPA

Question 3

Described the legislation framework in EASR

Answer 3

General Bionding rules + THREE TIERS of AUTHORISATION based on INCREASING COMPLEXITY and RISK

Question 4

What are General Binding Rules (GBRs), and give an example of a GBR

Answer 4

GBRs are a set of manditory rules covering LOWEST RISK work activities.

E.g., Keeping and use of low activities of radioactive substances for medical use.

No need to APPLY to SEPA as long as comply IN FULL with GBRs.

Covers:
- Management of sealed sources < 200 kBq
- Disposal of non-metalic sealled sources < 200 kBq
- Management of smoke detectors < 500 in number
- Disposal of Very Low Level Waste in normal refuse
- Medical discharges of Tc-99m < 10 GBq or < 5 GBq all other radionuclides
- Non-human excreta liquid discharges < 100 MBq

Question 5

What is notification in EASR? Give examples of when notification is required

Answer 5

The first tier of authorisation.

GFRs apply.

Examples:
- Management of sealed sources cat 5 > 200 kBq which cannot be disposed of to dustbin
- Tritium sources > 20 MBq (excluding disposal)
- Management of orphan source
- Management of radioactive waste following decontamination of person following an incident
- Management of radiocative waste following from fire-fighting following an incident

Question 6

What is registration in EASR, give examples of when registration is required?

Answer 6

MUST be applied for where activity > notification level. STANDARD CONDITIONS apply

Examples:
- Sealed source (non-hass) registration
- Holding of radioactive substances up to 10 GBq Tc-99m and 20 MBq of all other substances and no disposal other than those in standard conditions

FIT AND PROPER PERSON ASSESSMENT REQUIRED for registration

Question 7

What is a permit? When is it required? Describe the requirements for/of a permit?

Answer 7

A permit is the HIGHEST TIER of authorisation, for highest risk or non-standard activities.

SEPA undertake assessment before they grant or refuse a permit.

Standard conditions apply and any bespoke permitted conditions

All activities involved in management of radioactive substances and disposals not covered by lower tiers

RADIATION WASTE ADVISER must be appointed for management of radioactive waste

Financial provision required, e.g., disposal of HASS

Question 8

For NHS Board with Nuclear Medicine Department (Imaging and Therapy), what if any authorisation level would be required under EASR18?

Answer 8

1. Registration - For sealed sources (non-HASS)
2. Permit for unsealed - Holdings as greater than registration levels + waste disposal
   - Standard conditions
   - Potentially bespoke conditions
   - Require RWA appointment for management of radioactive waste

Question 9

Can you give an example of a standard condition?

Answer 9

1. FInancial and human resources
2. Management system for radioactive substances
3. written procedures
4. record keeping
5. provision of staff training
6. data returns to SEPA
7. radioactive weaste optimisation
8. Contamination control

Question 10

Can you give examples of bespoke permit conditions?

Answer 10

1. Maximum radioactive substances held on site by raionuclide
2. Monthly limits on liquid waste discharges to sewer by radionuclide
3. Arrangements/conditions for transfer of solid radioactive waste

Question 11

What does HASS Stand for?

Answer 11

High Activity Sealed Source