Environmental Permitting Regulations

Question 1

What routes of dispersion of radioactive waste need to be considered? Who is relevant in each case?

Answer 1

Drains - fishers, swimmers
Sewage - sewage treatment workers
Solid waste - bin, landfill, incinerator workers

Question 2

What is EPR?

Answer 2

Environmental Permitting Regulations
- in place to govern the amount and types of radioactive materials released to the environment

Question 3

Who and what does EPR protect?

Answer 3

Public, workers and wildlife

Question 4

What part of healthcare is EPR relevant to?

Answer 4

Nuclear medicine - patients, excreted activity, unsealed source handling, QA sealed sources, waste

Brachytherapy - sealed source handling, HASS, security

Question 5

True or False: Must not operate a regulated site unless under a permit

Answer 5

True - regulation 12

Question 6

What is the environmental impact assessment?

Answer 6

Establishes if and what permits are appropriate based on releases and to demonstrate BAT

Question 7

What is BAT?

Answer 7

Best Available Technique

Question 8

What is HASS?

Answer 8

High Activity Sealed Source

Question 9

What is considered when getting an EA permit?

Answer 9

What activities are performed, types of radioactive materials (radionuclides, activites, tasks), artificial vs NORM, concentrations, half-lives

Question 10

What is NORM?

Answer 10

Naturally Occurring Radioactive Material

Question 11

Are NORM activities regulated?

Answer 11

Yes

Question 12

What is in scope of EPR?

Answer 12

NORMs above certain levels and concentrations
Artificial radionuclides above certain concentrations

Question 13

What is out of scope of EPR?

Answer 13

Half-life <100 s

Question 14

How are substances containing multiple radionuclides handled?

Answer 14

Use summation rule for radioactive compounds

Question 15

What is the summation rule for substance containing multiole radioactive compounds?

Answer 15

sum(Ai/Bi) ratio > 1 is considered radioactive

where A - activity concentration of i
B - scope limit for i

Must take all activities into account (even if half-life <100 s)

Question 16

What are the types of EA permits?

Answer 16

Standard rules
Bespoke

Question 17

What is a standard rule permit?

Answer 17

For low-hazard sealed sources where A/D values and totals are below a threshold

Question 18

What is A/D?

Answer 18

Activiting (GBq) / Danger value (GBq)

Question 19

What is the A/D threshold for a standard EA permit?

Answer 19

0.01

Question 20

What are the specific limits for a bespoke permit based on?

Answer 20

Radionuclides on site
Activities
Uses
Modes of release to environment

Question 21

What must be done when getting a bespoke permit?

Answer 21

Environmental Impact Assessment

Question 22

How is an Environmental Impact Assessment performed?

Answer 22

In three stages
1.Generic dose per unit release values and parameters
2. More site specific, e.g. dispersion, river/sewer-flow rates, using generic DPUR
3. Site-specific DPUR

Question 23

What is considered during an Environmental Impact Assessment?

Answer 23

The projected annual dose to critical groups (local families, fishermen, sewage treatment workers, farmers, children in a brook, anglers, irrigated food consumers)

Question 24

What is contained in the EA permit?

Answer 24

Map of site - geographical extent of permit
Standard rules - permitted activities, techniques
List of allowed radionuclides
HASS sources
Security levels
Accumulation of waste - activity limit, accumulation period
Waste transfer to other premises

Question 25

What is VLLW?

Answer 25

Very low level waste - can dispose of some sealed sources municipally

Question 26

What is the VLLW limit for a single item?

Answer 26

40 kBq

Question 27

What is the VLLW concentration limt?

Answer 27

400 kBq per 0.1 m3

Question 28

What is HASS normally applicable to?

Answer 28

Brachytherapy sources

Question 29

How, and by who, are HASS categorised?

Answer 29

A/D value by IAEA guidelines

Question 30

What does the level of HASS security depend on?

Answer 30

HASS categorisation and the specific source type

Question 31

What should be considered for HASS security?

Answer 31

Number of physical security measures, alarm calling local security or police, counter-terrorism security officer site visits and advice, annual source return (tell EA you still have it), tell EA when you get a new source

Question 32

What are some examples of security around HASS?

Answer 32

CCTV Site security plan Physical locked barriers Security alarm Local security response Police response

Question 33

What is involved in employing BAT?

Answer 33

Optimising releases to the environment Minimising impacts on critical groups, employees and public Include measures at all levels

Question 34

What are some examples of BAT?

Answer 34

Administering minimal possible activity -> less excreted Ordering minimum required activities -> less waste Decay-storing waste before disposal

Question 35

True or False: All permit holders must have a BAT document

Answer 35

True

Question 36

What is a RWA?

Answer 36

Radioactive Waste Advisor (EPR equivalent to RPA for IRR17 or MPE for IR(ME)R17)

Question 37

When should an RWA be appointed?

Answer 37

If the EA permit is for the accumulation or disposal of radioactive waste