Regulatory Controls Flashcards
What is a sealed source?
A radioactive source whose structure prevents,under normal conditions of use, dispersion of the radioactive substance.
Which items are not considered sealed sources?
A nuclear reactor
Any fuel element
Electro deposited sources
Tritium foils
What is a High-activity Sealed Source ?
A sealed source which exceeds the legislated A/D activity for that source.
What is an open source?
Radioactive material which is not a sealed source and which is not waste.
What is radioactive waste?
Any open or sealed source which is no longer a source; and the activity cannot be disregarded (IRR17) or the concentration is too high to be exempt (EPR2016)
When does a source no longer a source (give examples)?
- Open sources beyond expiry
- Open sources no longer fit for patient administration
Waste products accumulating in shielded storage - Liquid source discharged to drain
- Open source transferred to another permit holder
- Sealed source disposal or transfer
RAM Control legistlation
EPR2016 RSA93 HASS2005 Hazardous waste regs 2005 IRR17
Describe EPR2016
The Environmental Permitting (England and Wales) Regulations 2016
Governing how much radioactive material can be held for what purpose at any site, how it is kept and used (records, security, procedures, training), and how radioactive waste is disposed of.
What does EPR regulate?
- Industrial (installations) activities
- Mobile plant
- Waste operations
- Mining waste operations
- Water discharges
- Groundwater activities
- Radioactive substances
EPR site requirements
1) A public environmental permit
2) A standard rules permit for cat 5 sources
3) Enviro Security Permit - sealed sources and waste maanagement
When is an EPR Permit required? What does it cover?
- Required for change or address / name
- Require a management sys
- Permit defines use of the source
- Site cannot exceed permitted activity
- Contingency plan
What must an EPR contingency plan cover?
1) Loss or escape of a source
2) Unauth access to a source
3) Premises access other than an auth users
EPR storage requirements
- Containers to be constructed of non-combustible materials
- Not co-located with corrosive, explosive or flammable materials
- Labelling must meet legal requirements for radioactive material
- Storage premises must resist contamination and be easily decontaminated
EPR what to do if a source is lost ?
- Inform the Police & EA (N.B. IRR17 may require the HSE to be informed)
- Recover the sources as far as is reasonably practicable
- Report the circumstances in writing to the EA ASAP
EPR what to do if source escapes ? (due to fire or damage)
- Inform the EA (without delay)
- Prevent further escape
- Minimise the spread of contamination
- Ensure that any discharge of radioactive gas to atmosphere is made in a manner which prevents entry into any building
- Notify the EA in writing
Source Records on day of receipt
Record activity, radionuclide, unique source ID & location
Source Records on the day of removal
Record the activity, radionuclide & to whom/where the source has been disposed of/transferred
Storing records
Make & retain records sufficient to demonstrate whether the limitations & conditions of the Permit are complied with e.g. total permitted activity on the premises at any time
All records must be retained until notified by the EA in writing that the records are no longer required
EPR offences
failures to comply
can be fined
What does the HASS directive cover?
Cradle to grave records
other sources of similar potential hazard level
What is an orphan source?
Source missing paperwork
Application of the “Polluter Pays” principle re recovery & disposal costs.
Additional HASS requirements
Security in accordance with NaCTSO, CTSA
Same security for sealed and open
Additional security measures for HASS
Security culture, awareness of the threat and need to Deter, Detect, Delay
Site security plan
Extendibility of security measures dependent upon the terrorist threat level
Information security plan
Personnel background checks
Specified number of physical security measures (delay source access)
Timely detection of unauthorised access by monitored intruder alarm
Timely police response to alarm
Mobile sources in use require close personal supervision & possibly appropriate communication links
Photographs of sources
Interim reports to EA
Evidence of financial provision for disposal costs
Stringent personnel checks re security
Written source specific emergency procedures (fire, loss, theft or unauthorised use)
What is BSSD 2013?
Consolidates 5 euratom directives:
Basic Safety Standards, Directive 96/29/Euratom (BSSD96)
Medical Exposures, Directive 97/43/Euratom
Outside Workers, Directive 90/641/Euratom (OW)
Control of high activity sealed radioactive sources and orphan sources 2003/122/Euratom (HASS)
Public Information Directive 89/618/Euratom
Radon, Commission Recommendation 90/143/Euratom
Rad sources in licensing IRMER 2017
- System of prior licensing:
- Practitioner licensing
= Not site specific - Employer license
IRMER license requirements
Arrangments of protection & safety staff info/training design features of the installation RIsk assessment Emergency procedures Maintenance and inspection protocols RAW arrangments Quality assurance
ARSAC license requirements
Practitioner must be medically qualified & meet training reqs
Site licence:
- Must have suitable equipment, facilities, and trained staff (MPE/RPA)
Describe CDG2009
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009
Governing by whom and how radioactive materials can be transported on any road to which the public has access.
Implements the ADR The European Agreement concerning the International Carriage of Dangerous Goods by Road); currently ADR2017
What are the CDG duty holders ?
Consignor: consigns RAM for transport
Carrier: transports RAM
Consignee: receives RAM
What are the CDG package types?
Exempt
Excepted
Type A, B, C
What is an exempt package?
Package does not meet reqs to be an excepted package
What is an excepted packaged?
Above exemption lim but beneath type A
What are type A, B and C packages?
Above excepted
Package based on activity and transport requirements
A: normal transport
B: Able to survive sever accidents
C: Even greater
What are the CDG security requirements?
Carrier must have photo ID
Staff must check there ID
Training should include security awareness
