Council Directive 2003/122/Euratom
Directive on the Control of High Activity
Sealed Radioactive Sources and Orphan Sources (HASS)
Purpose of Directive
To prevent exposure of workers and the public to
ionising radiation arising from the inadequate control of high activity
sealed radioactive sources and orphan sources. In the UK the prevention
of terrorism is also cited as a justification for its implementation.
This Directive came into force on the 22 December
2003 and the EU member states have until the 31 December 2005 to incorporate
the Directive into their legislation.
Definition of High Activity Source
A 'High Activity' sealed source contains one of
the specified radionuclides at an activity equal to or greater than
the specified level. The activity of a source is taken as the activity
at the time of manufacture.
The vast majority of the sealed sources used
in industry and research in the UK are not affected by the HASS directive
as their activity is too low.
Implementation in the UK
In the UK the majority of the requirements detailed
in the directive are already in effect under the Radioactive Substance
Act 1993 or under the Ionising Radiations Regulations 1999. For non-nuclear
sites the Environment Agency will be the licensing and enforcing body.
Costs
The major change introduced by this Directive will
be the need for arrangements to be in place for the whole life of the
source, including disposal, before a Registration licence is
granted. These arrangements must include some suitable means for guaranteeing
disposal. The option favored in the UK consultation document is for
an industry wide 'mutual' fund to be established to aggregate and protect
against the risk that participating holders become insolvent and fail
to fund the costs of disused source management.
A new HASS Registration will be introduced with
its own initial cost and subsistence charge. For 2005/2006 the costs
are likely to be £1,150 for a new HASS Registration and £1,495 for the
subsistence charge.
For those with a band 4C licence (Registration
for one or more closed sources, any one of which exceeds 4 TBq) then
the subsistence fee is to increase from £112 to £1,145. This band covers
those who have a source under an existing Registration which will be
classified as a high activity source under the directive.
Implementation
Member states must introduce the directive by 31/12/05.
In the UK the legislation amending the RSA 93 is planned to be passed
into law by September 2005 to allow time for the systems to be in place
for the beginning of 2006.
The requirements of the directive will not apply
until 31/12/07 to sources placed onto the market before 31/12/05. For
sources which fall into this category a new HASS Registration will not
be required to be in place until 31/12/07.
Records
There will be a new information form, the format
of which is still being decided, which will need to be sent at time
of receipt of a source to the enforcing agency and every 12 months thereafter.
A copy of this form will also need to be sent if there are any changes
to the location or use of a source and when the source is disposed of.
Training
The only addition to the current arrangements is
the requirement to provide training for scrap yards and recycling plants.
The training is to help them understand the basic concepts of radiation
and in identifying sources.
Orphan sources
The directive requires member states to put in
place mechanisms for recovering orphan sources and dealing with any
radiation emergencies that may arise due to these sources. In the UK
this is already covered by the voluntary NAIR scheme but this will be
replaced by a state funded system to comply with the Directive. DEFRA
are likely to lead the response to any radiation emergency in the future.
Member states are also to encourage detection facilities
at scrap yards, recycling centers and transport nodes (e.g. docks).
Detection facilities are becoming common practice in the UK at these
locations and the Government is adding facilities at the major ports.
Government financial support for Orphan sources
Member states are required to organise campaigns
to recover orphan sources including financial contributions. In the
UK a government funded recovery campaign is currently operating providing
financial assistance to certain organisations to dispose of their registered
sources. Further campaigns of this nature are likely to be run in the
future with funding from central government along with an ongoing fund
to help with orphan sources.
Security
Owners of HASS sources will have to demonstrate
that the security around their source is adequate. The Police may be
given enforcing powers with regard to security or this may be the remit
of the EA inspectors at non-nuclear sites.
Radman Associates
As an RPA Body recognised by the HSE, Radman Associates
provide qualified advice on current Radiation Protection legislation.
If you need assistance please
ask.
Draft
regulations intended to implement the Council Directive 2003/122/Euratom
high activity sealed sources and orphan sources (HASS Directive)
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