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 material
Contains natural radioactivity at a concentration in
excess of values in Sch1 of the Act
Contains any man-made radioactivity
RSA93 defines radioactive waste
Substance 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 EA95
Requires 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 account
As low as reasonably achievable = BPM
BPM condition introduced into RSA93 authorisations in 2003
Annual dose constraints:
0.3 mSv for any new source
0.5 mSv for any single site
1.0 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;
or
A 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; or
A 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 sale
A source ceases to be HASS only when the
activity falls below the exemption levels
specified in the BSS Directive
HASS Regulations implement stringent
controls for the life of the source
Examples 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 document
Primary means of allocating a category is practice, eg.
brachytherapy, high/medium dose rates = Category 2
Secondary 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 topic
Radiation 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 responsibilities
finance/resources
training
maintenance
emergency preparedness
enforcement/disciplinary measures
list of procedures
internal compliance/QA systems
Best Available Techniques review
Key Procedures
Facility design
Staff training
Risk assessment
Project approval
Material ordering
Material control and use
Waste handling
Contamination and monitoring
Record keeping
Decommissioning
Management of change
Undertaking a BAT assessment/review
Compliance Table
Authorisation AA1234
Condition
Purpose
Sch 1 C1 a
Management and
resources
Sch 1 C8
Reporting lost
radioactive waste
Record keeping
Sch 1 C12
Compliance
RSA93 compliance
document
Radiation Policy
List of written operating
procedures
BPM statement
Procedure GST001/01
Procedure GST001/02
Radioactive Materials
Request appropriate limits
Request appropriate nuclides
Request appropriate accumulation periods for
waste
Assess proposed disposal routes
Stay within your limits
Records
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 processes
Considering how production or process is to be carried out
Minimisation of the quantities of radioactivity in use
Waste minimisation techniques to be employed
Choice of discharge route (e.g. use of fume cupboards)
Method for minimising contamination
Possible need for abatement of discharges
Maintenance requirements and methods
Prevention of fugitive emissions by process and plant improvement
Implementation of a policy of continuous improvement to reduce disposals
and discharges, including regular review
Waste sampling, measurement or estimation and on radiological
assessment requirements
Waste Production cont.
Should include:Justification with a little “j”!
Optimisation
Risk assessment
Facilities design
Procedures
Waste management
Security
Decommissioning
Waste Storage
Storage facilities should be:clean
tidy
well organised
take account of other hazardous properties eg.
biohazard
Waste Disposal
Manage waste to ensure
Disposals 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?