RPS-update-directive-2003-122-Euratom
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RPS Update

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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