we are the environment agency. it’s our job to look after your environment and make it a better...

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?