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6th Annual Radiation Protection Supervisors Seminar 29/01/2015


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Title: 6th Annual Radiation Protection Supervisors Seminar 29/01/2015

6th AnnualRadiation Protection Supervisors
Seminar 29/01/2015
Tony Butterworth University RPA / RWA
  • 0845 Arrival (tea, coffee and cake available)
  • 0915 Introduction
  • 0920 Updates in Radiation Protection
  • 1100 Morning Break (tea, coffee, and cake
  • 11.30 Radiation Database and Local Radiation
    Protection Issues
  • 12.00 Discussions, Any Other Business
  • 12.10 Presentation by Dr. Tom Scott Interface
    Analysis Centre Director
  • 12.40 Lablogic Presentation
  • 1315 Close

Updates in Radiation Protection
Legislative Matters
  • (1) IAEA - International Basic
  • Safety Standards

International Basic Safety Standards
  • The jointly sponsored edition of the Safety
    Requirements Radiation Protection and Safety of
    Radiation Sources International Basic Safety
    Standards was published as General Safety
    Requirements Part 3 in July 2014
  • This edition supersedes the Interim Edition that
    was published in 2011
  • Reflect international consensus to promote a
    common approach for ensuring safety

International Basic Safety Standards
  • Revisions follow the recommendations of ICRP e.g.
    infrastructure for radiological protection and
  • legal framework
  • regulatory authority
  • operating management
  • employees
  • and fundamental principles of radiation
    protection e.g. dose limitation - reduction of
    the equivalent dose for the lens of the eye

International Basic Safety Standards
  • Classification of
  • 3 categories of exposure situations planned,
    existing and emergency exposure situations
  • 3 categories of exposure occupational, medical
    and public exposures

International Basic Safety Standards
  • Existing exposure situations are exposure
    situations that already exist when a decision on
    control or remediation has to be taken
  • Includes natural background radiation and most
    exposure situations to radon as well as residues
    from past practices
  • Exposure control is based on the use of reference
    levels (levels of dose or risk above which it is
    judged inappropriate to allow exposures to occur
    and below which optimisation of protection is

International Basic Safety Standards
  • Planned exposure situations are situations
    involving the planned introduction and operation
    of sources
  • Planned exposure situations include both normal
    exposures and potential exposures
  • Exposure control is based on dose limitation and
    dose constraint

International Basic Safety Standards
  • Emergency exposure situations are unexpected
    situations that occur during the operation of a
    planned situation, or from a malicious act,
    requiring urgent action
  • Exposure control is based on the use of reference

International Basic Safety Standards
  • Dose limit limit set from all
  • regulated sources in planned
  • situations
  • Dose constraint/reference
  • level limit set from a single
  • source in all exposure situations

  • (2) European Commission
  • Basic Safety Standards

EC Basic Safety Standards
  • The Basic Safety Standards (BSS) Directive
    (2013/59/Euratom), was adopted on the 5thDecember
  • Published in the Official Journal of the European
    Union on 17th January 2014
  • Lays down basic safety standards for protection
    against the dangers arising from exposure to
    ionising radiation

EC Basic Safety Standards
  • Repeals 5 Euratom Directives which underpin UK
    regulation of ionising radiation through the
    Ionising Radiation Regulations 1999 and Radiation
    (Emergency Preparedness and Public Information
    Regulations) 2001
  • Incorporates the latest recommendations from the
    International Commission on Radiological
    Protection (ICRP) published in 2007, and
    harmonises the EU regime with the Basic Safety
    Standards of the International Atomic Energy
    Agency (IAEA)

EC Basic Safety Standards
  • Member States are required to bring into force
    the laws, regulations and administrative
    provisions necessary to comply with this
    Directive by 6 February 2018
  • HMG policy with regards to how this Directive
    will be implemented within the UK is still to be
    agreed and communicated

EC Basic Safety Standards
  • HSE is engaging UK stakeholders to broadly
    ensure that a breadth of interested parties views
    inform the UK implementation of the Directive
  • Existing Stakeholder working groups cover
    Occupational, Medical, and Public and
    Environmental Exposures
  • Ionising Radiation Regulations 01/01/2018???

  • (3) International Atomic Energy Agency (IAEA)

IAEA Safety Standards
  • Current status (October 2014)
  • 129 are established of which 123 are published
  • 42 drafts are in the development process (30 to
    revise 41 published Safety Standards)
  • Currently, 91 of the standards are established.
    39 of the established standards are under
  • The expected total number is 131

IAEA Safety Standards
  • Regulations for the Safe Transport of Radioactive
    Material 2012 Edition
  • Establishes the regulations that apply to the
    transport of radioactive material by all modes of
    transport on land, water or in the air
  • Provides requirements useful to governments,
    regulators, operators of nuclear facilities,
    carriers, users of radiation sources and cargo
    handling personnel

IAEA Safety Standards
  • Decommissioning of Facilities (2014)
  • Establishes requirements for the safe
    decommissioning of a broad range of facilities
    e.g. nuclear power plants, former military sites,
    and relevant medical, industrial and research
  • It addresses all the aspects of decommissioning
    such as roles and responsibilities and strategy
    and planning

  • (4) Environment Agency

EA Guidance
  • 2011 EA produced guidance on EPR 2010 out of
    scope radioactive substances activities e.g.
  • VLLW
  • Small sealed radioactive sources
  • Uranium and Thorium
  • Small amounts of open radioactive sources
  • Medical and veterinary uses of radioactive

EA Guidance
  • Guidance on Interpretation of Relevant Liquid
  • March 2013
  • Schedule 23 to EPR2010 contains out of scope
    values for very low concentrations of Naturally
    Occurring Radioactive material (NORM) in solids
    liquids and gases and for solids and relevant
    liquids of other radioactive substances

EA Guidance
  • Initial guidance stated
  • The term relevant liquid allows certain types
    of liquid with specified hazardous properties to
    be treated as a solid for the purposes of EPR
    2010 because the exposure pathways are the same
    as those for solids and the disposal of such
    materials is to a conventional solid waste
    route i.e. disposal or transfer for the purposes
    of reuse or recycling, and not to drains,
    sewers, open water or ground water

EA Guidance
  • Relevant Liquid means a liquid which is
  • (a) Non-aqueous (primary constituent is not
    water usually organic solvent) or
  • (b) Classified (or would be so classified in the
    absence of its radioactivity) under Council
    Regulation No. 1 272/2008 as having any of the
    following hazard classes and hazard categories
    (as defined in that Regulation)

EA Guidance
  • (i) acute toxicity categories 1, 2 or 3
    (LD50/LC50 values defining respective categories)
  • (ii) skin corrosion/irritation category 1
    corrosive, sub-categories 1A, 1B or 1C
  • (iii) hazardous to the aquatic environment acute
    category 1 or chronic categories 1 or 2

EA Guidance
  • Therefore to determine if a liquid is a relevant
    liquid there are two considerations
  • (1) is the liquid a non-aqueous liquid
  • (2) does it have one of the specified hazard
    classes or categories

EA Guidance
  • Guidance on NORM Industrial Activities
  • March 2013
  • This guidance is for businesses and individuals
    who have to handle naturally occurring
    radioactive substances to determine whether the
    radioactive substances regulatory regime applies

EA Guidance
  • EPR 2010 only applies to naturally occurring
    radioactive substances that meet two criteria
  • (i) They must arise from industrial activities
    that are specified in the legislation (NORM
    Industrial Activities)
  • (ii) They must contain concentrations of
    naturally occurring radionuclides above
    specified values (NORM out of scope values)

EA Guidance
  • If a substance does not satisfy both of these
    criteria then it is not subject to the
    radioactive substances legislation
  • If it does satisfy the criteria, then it is
    subject to the legislation and will require
    permitting unless it is exempt

EA Guidance
EA Radioactive Waste Advisers
  • There is a requirement under European law for
    people who keep or use radioactive material, or
    who accumulate or dispose of radioactive waste,
    to appoint advisers, known as qualified
    experts, to advise them on radiological
  • In the UK we call the qualified expert for
    radioactive waste management and environmental
    radiation protection a 'Radioactive Waste Adviser'

EA Radioactive Waste Advisers
  • Radioactive Waste Advisers (RWA) are specialists
    in radioactive waste disposal and environmental
    radiation protection who have demonstrated
    competence in the Radioactive Waste Adviser
  • RWA is a similar position to the RPA
  • RWA appointed in writing by the permit holder
    (Director of SHS on behalf of UoB Council)

EA Radioactive Waste Advisers
  • UoB RWA Tony Butterworth
  • Certificate of Competence granted 01/09/2014 by
    RPA 2000
  • Renewed every 5 years

EA Draft Legislation - Enforcement Undertakings
  • Comes into force 06/04/2015 (if passed by both
    Houses of Parliament)
  • Will be implemented as an amendment to EPR 2010
  • An alternative to prosecution for environmental
  • Primary purpose is to allow the offender to
    restore and remediate any environmental damage
    they have caused

EA Draft Legislation - Enforcement Undertakings
  • If an operator has technically committed an
    offence, but offers an enforcement undertaking,
    the EA accept it, and the operator completes the
    undertaking to their satisfaction, then the
    operator is not deemed to have committed an
  • A tool for the EA to use where they believe that
    prosecution would be too heavy-handed
  • Expectation that the EA will issue some examples
    pertinent to the RSR sector when legislation
    comes into effect

  • (5) NaCTSO
  • https//www.gov.uk/nactso

  • UK Threat Level is currently SEVERE a
    terrorist attack is highly likely
  • Current document - Security Requirements for
    Radioactive Sources, April 2011 (Restricted
    available from RPA)
  • provides detailed information on the specific
    security measures that must be applied to sources
    as part of the regime
  • sets out the more general security requirements
    for site protection where radiological sources
    are based

  • For Source Categories 3 and 4 e.g. 2GBq Sodium-22
    sealed source, Security level C requirements are
  • Compliance with IRR 99 and EPR 2010
  • Site security plan (updated annually)
  • Ability and options for upgrades of security for
    increased threat

  • Information security plan
  • Personal background checks
  • Provide a means to detect unauthorised removal of
  • Source protected from unauthorised access by 1
    physical security measure

  • Remember
  • Purchase of new permitted sealed sources may
    affect the NaCTSO security rating for the
    building and will need the advice of a CTSO
    Adviser regarding suitable security arrangements
    BEFORE sources arrive on site
  • Consult with RPA in first instance

  • Euro-Protect 2012-2013
  • A joint venture between NaCTSO and Avon and
    Somerset Constabulary, with financial assistance
    from the European Commission
  • The project aims to address the key challenge of
    how to protect Europe from the threat of
    terrorism, through partnership with the
    commercial and private sectors

  • The training is limited to public sector counter
    terrorism practitioners, from all of the EU
    Member States and includes practical guidance on
    how to identify vulnerabilities at key locations,
    how to survey sites and deliver structured and
    risk commensurate protective security advice
  • In 2013, courses will focus on the protection of
    pathogens, toxins, radiological sources
    (including HASS) and pre-cursor chemicals

  • 3 sessions organised, situated in Bristol
  • UoB involvement for biological and radiation
    exercises (HASS security arrangements)
  • Post event response from CTSA -
  • The training programme has proven to be a great
    success and a fine advert for partnership
    between our two organisations

ICRP Publications
  • Publication 120 (2013) - Radiological Protection
    in Cardiology
  • Provides guidance to assist cardiologists with
    justification procedures and optimisation of
    protection in cardiac CT studies, cardiac nuclear
    medicine studies, and fluoroscopically guided
    cardiac interventions

ICRP Publications
  • Publication 121 (2013) - Radiological Protection
    in Paediatric Diagnostic and Interventional
  • Provides guiding principles of radiological
    protection for referring clinicians and clinical
    staff performing diagnostic imaging and
    interventional procedures for pediatric patients
  • Guidelines and suggestions for radiological
    protection in radiography and fluoroscopy,
    interventional radiology, and computed tomography

ICRP Publications
  • Publication 122 (2013) Radiological Protection
    in Geological Disposal of Long-lived Solid
    Radioactive Waste
  • Updates and consolidates previous ICRP
  • Includes the consideration of the different
    stages in the life time of a geological disposal

ICRP Publications
  • Publication 123 (2013) Assessment of Radiation
    Exposure of Astronauts in Space
  • Astronauts not usually classified as being
    occupationally exposed in the sense of the
    general ICRP system for radiation protection of
    workers applied on Earth
  • Describes the terms and methods used to assess
    the radiation exposure of astronauts, and
    provides data for the assessment of organ doses

ICRP Publications
  • Publication 124 (2014) Protection of the
    Environment under Different Exposure Situations
  • Expands upon the Commissions objectives in
    relation to protection of animals and plants in
    their natural environment and how these
    objective can be met

ICRP Publications
  • Reference Animals and Plants (RAPs) set of 12
    identified, wide geographic distribution and
    typical of different environments
  • Derived Consideration Reference Levels (DCRLs)
    relate to radiation effects to doses over and
    above their normal local background levels
  • Different potential pathways of exposure
    inhalation, ingestion, contamination, external

ICRP Publications
  • Publication 125 Radiological Protection in
    Security Screening (2014)
  • Principles of justification, optimisation of
    protection, and dose limitation are directly
  • If justified then the framework for protection as
    a planned exposure situation should be employed
  • Consideration of several scenarios e.g. exposure
    of stowaways in a cargo container

ICRP Publications
  • Publication 126 Radiological Protection against
    Radon Exposure (2014)
  • Provides updated guidance on radiological
    protection against radon exposure
  • Integrated approach for protection against radon
    in all buildings whatever their purpose and
    status of their occupants, rather than
    workplaces, mixed-use buildings and dwellings

ICRP Publications
  • ICRP recommended derived upper reference level
    still set as 300 Bq/m3 (corresponds to a 10 mSv
    annual dose)
  • ICRP strongly encourages national authorities to
    set national derived reference levels in the
    range 100-300 Bq/m3 taking economic and social
    circumstances into account
  • (Current IRR99 workplace action level is 400
    Bq/m3 and HSE dwelling action level is 200 Bq/m3)

SRP Publications
  • J. Radiological Protection Vol. 33 No. 1 (March
  • Radon exposure
  • Installations of sumps in Ireland homes decreased
    radon levels by 80-90
  • Inspection of domestic radon preventative
    measures found barriers were commonly either not
    installed correctly or damaged on installation

SRP Publications
  • A study into radon exposure from granite worktops
    installed in the home concluded that radon levels
    were x2000 lower than outdoor radon
    concentrations therefore there is a low
    probability of granite worktops causing elevated
    levels of radon in the home

SRP Publications
  • J. Radiological Protection Vol. 33 No. 2 (June
  • 26 year follow up study of Chernobyl clean-up
    workers from Estonia
  • Cohort of 4810 men, contributing approx. 99K
    person-years at risk
  • Study examined cancer incidence (1986-2008) and
    mortality (1986-2011)

SRP Publications
  • No definite health effects attributable to
  • However UNSCEAR 2008 report concluded mental
    health to be the major public health issue among
    exposed populations, particularly clean-up
    workers who were sent into a stressful and
    dangerous environment without adequate
    information and protective gear and live in fear
    of potential adverse health outcomes

  • Study found that the elevated suicide risk has

SRP Publications
  • J. Radiological Protection Vol. 34 No. 2 (June
  • Assessment of Radiation Doses in the UK from the
    Fukushima Daiichi Nuclear Accident (11/03/2011)
  • Conducted by Public Health England (PHE)
  • Air monitoring performed, measurements of
    radionuclides in grass and soil were made and
    monitoring data from surface water, rainwater and
    ground deposition was recorded (29/03/2011

SRP Publications
  • Doses were estimated for the main exposure
    pathways - inhalation of airborne radioactivity,
    ingestion of food and external irradiation from
    radionuclides deposited on the ground
  • Confirmed their initial reporting that there was
    no public health risk and estimated doses were
    about the same as a person in the UK would
    receive in an hour from natural background

SRP Publications
  • J. Radiological Protection Vol. 34 No. 2 (June
  • Developing the Radiation Protection Safety
    Culture in the UK
  • Two areas identified as having a strong influence
    on UK society healthcare and nuclear industry
  • 2005, PHE reported that the annual collective
    occupational dose in the UK nuclear industry was
    similar in magnitude to that from the healthcare

SRP Publications
  • Each sector has specific challenges, but with
    overlapping common factors
  • Exchange of safety culture knowledge between the
    sectors may act to develop RP culture in both and
    have a wider impact in other sectors
  • Examples of improvement action plans for each

SRP Publications
  • Recent surveys (2011, 2014) in the medical sector
  • Average of 32 late, 11 non-returned dosimeters
    per year

SRP Publications
European ALARA Network
  • Issue 33 (September 2013)
  • Incident in a Slovenian brewery due to incorrect
    installation of a new X-ray tube in a fill level
  • Maintenance worker replaced a circuit board in a
    gauging system x-ray tube attached to board
    however had been mounted incorrectly by supplier
  • Tube window was facing a wrong direction when
    installed (towards worker rather than towards the
    production line)

European ALARA Network
  • Worker noted that when the unit was operational
    there was no reading on a dose rate meter at the
    detector position however there was a significant
    dose rate at the position he was standing and had
    been standing when installing and testing the
  • Dose reconstruction estimated an effective dose
    of 5 mSv

European ALARA Network
  • Lessons learned included
  • Introduction of a programme of workplace
  • Issue of personal dosimeters for maintenance
  • Basic radiation protection training for all
    workers working in the vicinity of sources of
    ionising radiation
  • Replacement of aging gauge equipment where spare
    parts were becoming increasing unavailable

European ALARA Network
  • Issue 34 (February 2014)
  • HSE Prosecution of Health Service Trust for
    Overexposure of an Interventional Radiologist
  • 2011 Trust appointed a new interventional
    radiologist who used the same method for CT
    fluoroscopy that he had been using in Germany on
    a different manufacturers CT scanner

European ALARA Network
  • His technique involved him standing next to the
    CT scanner and observing real time images which
    meant that his hands were in the main x-ray beam
    whilst carrying out procedures for up to 30
    seconds at a time
  • Only issued with a TLD body badge as ring badges
    were unavailable when he started
  • Other doctors and managers deferred to his
    apparent greater knowledge in operating the CT
  • Trust RPA not consulted

European ALARA Network
  • 3 months later he was issued with ring badges and
    on analysis indicated a skin radiation exposure
    in excess of 500 mSv (IRR 99 annual extremity
    dose limit)
  • Trust estimated his actual exposure was likely to
    have exceeded 1 Sv although he did not exhibit
    any form of immediate apparent radiation injury
  • Trust fined 30,000 for breaches of IRR 99 not
    having suitable and sufficient risk assessment in
    place and exceeding dose limit to the skin

European ALARA Network
  • Lessons learned
  • Ensure procedures are in place to make sure new
    staff are given suitable information, instruction
    and training to enable them to work in a safe
    manner and in accordance with the organisations
    policies and procedures
  • Ensure all new work activities are properly risk
    assessed involve the RPA

European ALARA Network
  • Issue 35 (October 2014)
  • European ALARA Network Workshop Report
    Education and Training in Radiation Protection
    Improving ALARA Culture (7-9/05/2014)
  • Consideration of how radiation protection
    education and training programmes can be
    delivered effectively and how these can improve
    radiation protection in practice and help
    disseminate ALARA culture

European ALARA Network
  • Discussions based on
  • Building ALARA in radiation protection training
  • Measuring effectiveness of training
  • The role of qualification and recognition schemes
  • Training tools and methods
  • National approaches to training

European ALARA Network
  • Conclusions and recommendations
  • Assessing the effectiveness of training should be
    promoted by Regulatory Authorities and
    professional societies
  • Training should include up-to-date training
    techniques and technologies as well as radiation
    protection theory
  • Training should be practical and realistic
    including the use of real radiation sources where

European ALARA Network
  • On-the-job training should be properly structured
    and involve suitably trained mentors
  • Member States should aim to establish clear and
    transparent national schemes for the recognition
    of Radiation Protection Expert competence
  • Develop education and training in radiation
    protection for the public and include radiation
    protection information and data on the Internet

OTHEA Reports
  • 1. Contractors contaminated when clearing out a
    vacant building
  • Locked metal cabinet being moved by 2 contractors
  • A bottle inside broke and liquid started seeping
  • Opening the cabinet revealed x4 1.5L unbroken
    bottles x1 broken 2.5L bottle
  • x1 empty plastic drum
  • All were labeled with radioactive material tape

OTHEA Reports
  • Liquid (organic) had contaminated the hands and
    forearms of the 2 contractors
  • Subsequent investigation concluded each bottle
    contained approx. 40kBq C-14 in toluene - lt 1
    ALI and likely that only a small fraction of this
    activity would have been taken into the bodies of
    the contaminated persons
  • Therefore internal doses from this incident were

OTHEA Reports
  • Fortunate that higher activities or more
    radiotoxic materials were not involved and
    significant radiation doses were not incurred
  • Lessons learned
  • All radioactive material should be accounted for
    (physical check and records) and removed before
    occupiers vacate the premises

OTHEA Reports
  • Appropriate monitoring should always be carried
    out (and recorded) in order to verify that any
    contamination has been removed
  • Advice should be sought if any suspect items
    found which are labelled with the radiation
    trefoil sign BEFORE items are moved/removed

OTHEA Reports
  • 2. Unsafe transport of waste radiotherapy source
  • Company contracted to move a disused radiotherapy
    source (129 TBq Co-60 sealed source) to a waste
    repository 160km distance
  • Used a Type B container, transport by road,
    journey time approx. 3 hours

OTHEA Reports
  • When consignment arrived monitoring confirmed a
    narrow collimated beam was being emitted
    vertically downwards from the package giving a
    dose rate of 3.5 Sv/hr
  • Subsequent investigation by the regulatory
    authorities found that a vital shield plug was
    missing from the transport container allowing the
    beam to be emitted
  • Contractor order to pay a total of 358,000 in
    fines and costs

OTHEA Reports
  • Concluded that there was no evidence that anyone
    had received a significant radiation exposure
    during preparation and transport of the source
  • However there was a potential for persons to
    exceed the dose limit within seconds and suffer
    deterministic injuries within minutes or hours
  • If an employee had been exposed to the radiation
    beam for the duration of the journey this could
    have proved fatal

OTHEA Reports
  • Lessons learned
  • Transport quality assurance procedures must be
    adhered to
  • Satisfactory monitoring must be carried out by
    consignors to ensure radiation doses are as

AURPO Newsletters
  • Reminder HSE Notification
  • Radiation employers need to inform the HSE when
    details of a previous notification are no longer
    correct, e.g.
  • Employers details or those of their premises
  • The source category changes
  • The source is to be used at a different premises

AURPO Newsletters
  • Security by Design workshop report Stockholm
    January 2014
  • Approach to high activity source security in USA
    is now focussed on the insider threat an
    authorised user who is coerced or subverted to
    access or provide access to a high activity
    source by bypassing all the external physical
    security measures and detection systems
  • NaCTSO are following suit

AURPO Newsletters
  • EA RSR Inspections
  • 2013 EA inspected approx. 1500 sites nationally
  • Frequency of inspection
  • Permits C,D, and H annual e.g. precinct
    sealed sources, precinct unsealed sources
  • Permit G - Every 2 years
  • e.g. Langford unsealed sources

AURPO Newsletters
  • Notes from the Small Users Liaison Group (SULG)
    Meeting 10th June 2014
  • 92 of sites scheduled for an annual EA
    inspection had received a visit
  • ONR undertook 31 transport audits on hospitals,
    including serving 3 improvement notices on one
    hospital for failing to implement previous audit

AURPO Newsletters
  • HSE inspections now occur reactively
  • Current concerns involve site radiography
    equipment several incidents have occurred
    involving source detachment and a snapped cable
  • Reported that contamination had been found on
    brachytherapy sources supplied to hospitals
    operators reminded to check for contamination
    both pre and post installation

AURPO Newsletters
  • ONR Safeguards
  • Meetings with Euratom Inspection and Accountancy
    sections concluded that National Location Outside
    Facilities (NLOFs) may be set up in the UK
  • Operators within an NLOF report to ONR Safeguards
    who will then submit formal reports to Euratom

AURPO Newsletters
  • Trial with 26 organisations reporting DU
    inventories has been successful
  • Will be rolled out to a further 36 organisations
    including Universities
  • Euratom have not agreed to de minimus levels as
    they still want an opportunity to inspect an
    organisations accountancy system and physical

WINS Best Practice Guides
  • WINS World Institute for Nuclear Security
  • https//www.wins.org/index.php?article_id61
  • Provide an international forum for those
    accountable for nuclear security to share and
    promote the implementation of best security
  • Produce Best Practice Guides 33 produced to

WINS Best Practice Guides
  • 1.4 Nuclear Security Culture
  • 3.4 Managing Internal Threats
  • 4.4 Material Control and Accountancy in Support
    of Nuclear Security
  • 5.1 Security of High Activity Radioactive
  • All include questionnaires for senior managers /
    first-line supervisors / staff

WINS Best Practice Guides
  • E.g. 3.4 Managing Internal Threats -
    Questionnaire for first-line supervisors
  • Is consideration of the consequences of malicious
    internal acts a part of the risk management
  • Are you confident that security incidents by
    individuals are being reported by your managers
    without delay?

WINS Best Practice Guides
  • RPA will email RPSs (via) database with a list
    of the best practice guides RPA can then send
    copies to RPSs on request
  • May be useful in raising awareness amongst staff
    regarding security of radioactive sources and
    improving the security culture within your

UK Prosecutions
  • 29/09/2014 - Rolls Royce Marine Power Operations
    Ltd has been fined 200,000 and ordered to pay
    costs of 176,500 following the loss of a
    radioactive source at its plant in Derby
  • Significant failings led to a radioactive source
    (a capsule which was the size of a small screw)
    being lost for approximately five hours at the
    Sinfin Lane site on 3 March 2011

UK Prosecutions
  • On the day of the incident the source was being
    used in a purpose-built radiography enclosure.
    During the work the source capsule became
    detached from its holder, was lost out of the end
    of the guide tube being used and ended up inside
    the component being tested
  • The loss of the source was not detected by the
    safety features of the radiography enclosure or
    by the radiographer in charge of the work

UK Prosecutions
  • The loss of the radioactive source was discovered
    when welders working on the component in the
    clean room spotted the capsule and removed it for
    examination, passing it amongst themselves.
  • The radiographers returned for their next shift
    at this point and after some initial confusion,
    which involved some of them directly handling the
    capsule, they correctly identified the object as
    a radioactive source. The room was cleared, the
    radioactive source recovered and the area made

UK Prosecutions
  • The subsequent investigation by the Health and
    Safety Executive (HSE) and the Environment Agency
    found the workers hand exposure to radiation was
    considerably in excess of the annual permitted
    dose of 500 mSv
  • In some cases it was exceeded by up to 32 times
    the permitted amount
  • The investigation also found that the company
    failed to ensure that a suitable and sufficient
    risk assessment was in place for the gamma
    radiography work carried out on site

UK Prosecutions
  • Inadequate procedures together with deficiencies
    in training led to Rolls Royce Marine Power
    Operations Ltd failing to ensure that robust and
    effective controls were in place to manage the
    risk of using high activity radioactive sources
  • Additionally, the capability of the radiation
    monitoring equipment was not well understood and
    failed to detect where the radioactive source was
    at all times which is an essential requirement
    when carrying out radiography work

UK Prosecutions
  • Pleaded guilty to breaching
  • Sections 2(1) and 3(1) of the Health and Safety
    at Work etc Act 1974
  • Regulation 3(1)(a) of the Management of Health
    and Safety at Work Regulations 1999
  • Regulation 11 of the Ionising Radiation
    Regulations 1999
  • Three counts of breaching Regulation 38(2) of the
    Environmental Permitting Regulations 2010

UK Prosecutions
  • 31/03/2014 - Mistras ETS Ltd, based at
    Dillington, Cambridgeshire, was fined 30,000 and
    ordered to pay 4,930 in costs after one of its
    workers suffered radiation burns while carrying
    out tests on safety equipment on19 September
  • The man suffered severe tissue damage to the
    middle, ring and little fingers of his right hand

UK Prosecutions
  • He had been working in a radiography bay with
    x-ray equipment when a separate team was asked to
    test safety equipment and warning beacons, which
    also required the use of x-ray equipment
  • The other employees devised an ad hoc test method
    that involved turning off safety access controls
    and warning alarms for the radiography bays.
    During one test, the injured worker remained in a
    radiation bay, while the x-ray was energised

UK Prosecutions
  • The HSE investigation found that the workers had
    not used the x-ray equipment to test the safety
    equipment before, and that there were no
    procedures in place for them to carry out the
    tests safely
  • As a result they developed their own ad hoc
    method, which led to several important safety
    devices being switched off

UK Prosecutions
  • Pleaded guilty to breaching
  • Section 2(1) of the Health and Safety at Work etc
    Act 1974
  • Regulation 11(1) of the Ionising Radiation
    Regulations 1999

UK Prosecutions
  • 07/10/2013 - United Lincolnshire Hospitals NHS
    Trust was fined a total of 30,000 and ordered to
    pay costs of 15,128
  • An interventional radiologist working with a CT
    scanner at Pilgrim Hospital, Boston, received
    more than double the annual dose limit for skin
    exposure in just over three months

UK Prosecutions
  • His work involved the insertion of biopsy needles
    into patients, which he carried out using the CT
    scanner operating in continuous fluoroscopy
    mode for up to 30 seconds at a time, giving real
    time x-ray images which he observed whilst
    standing next to the scanner
  • Whilst inserting the biopsy needles he was
    placing his hands directly in the main x-ray
    beam, resulting in an overexposure of radiation
    to his hands

UK Prosecutions
  • The scanner, which the trust had bought in 2009,
    was used by a number of other consultants for the
    same purpose but they used the conventional step
    and shoot method which required them to leave
    the room when the CT scanner was generating
  • An investigation by HSE found that the Trust had
    never carried out a risk assessment for the CT
    scanner operating in the fluoroscopy mode so a
    safe system of work was not developed

UK Prosecutions
  • In addition, managers were aware that this
    technique was being carried out but did not
    ensure proper procedures were followed
  • Pleaded guilty to breaching Regulations 7(1) and
    11 of the Ionising Radiations Regulations 1999

Also Making the News
  • Shocking extent of radioactive waste dumped in
    Scottish seas (thecourier.cu.uk, 10/11/2014)
  • Documents at the National Records of Scotland
    have emerged which show more than 75,000
    luminised dials coated with radium were tipped
    into the Tay Estuary after the Second World War
    between 1954 and 1956 without permission

Also Making the News
  • Documents also show how the firm UK Time a
    forerunner to Timex arranged a deal with local
    fishermen to put 35,000 luminised dials coated
    with radium into drums and dump them in the Tay
    Estuary in 1949
  • The arrangement, according to Scotland Office
    papers, continued for eight more years at an
    estimated 5,000 dials a year before dumping was
    switched to the UK Governments site at
    Beauforts Dyke between Northern Ireland and

Also Making the News
  • Kazakhstan authorities on high alert after
    radioactive container goes missing (The
    Guardian, 02/09/2014)
  • A container holding the radioactive substance
    caesium-137 disappeared in the west of the
  • A police spokesman for the Mangistau region said
    the material commonly used for military and
    medical purposes appeared to have fallen off a
    vehicle that was transporting it

Also Making the News
  • The origin of the missing material was not
    revealed by authorities in Kazakhstan, which
    inherited nuclear warheads and a weapons test
    site when the Soviet Union collapsed
  • More than 100 incidents of thefts and other
    unauthorised activities involving nuclear and
    radioactive material are reported to the IAEA
    each year

Also Making the News
  • Radioactive canister stolen from van in
    Lancashire (BBC News 18/02/2013 and 14/03/2013)
  • The heavy lead yellow canister containing a
    "small amount" of material, believed to be
    Iridium 192, was taken over the weekend from a
    Peugeot Panel Van parked in New Line, Bacup
  • A suspicious package was found at Point Retail
    Park in Rochdale at about 1245 GMT. It was
    declared safe by police and has been removed

Conferences Meetings
SRP Conference 17/10/2013
  • Practical Radiation Protection
  • EPR - An Inspector Calls, Amber Bannon, RSR
  • EPR Permits address
  • Management Systems
  • Security
  • Infrastructure
  • Radionuclide management
  • Waste management

SRP Conference 17/10/2013
  • Users must demonstrate compliance with ALL permit
  • Ensure users read and understand permit
  • Copy of Permit must be available so as to be
    conveniently read by persons having duties on
    the premises

SRP Conference 17/10/2013
  • Users must comply with limits specified in permit
  • Ensure radionuclides and associated limits are
    appropriate to activities
  • Demonstrate compliance good records!

SRP Conference 17/10/2013
  • Management Systems
  • Roles and responsibilities
  • Staff training
  • Project approval and risk assessment
  • Procurement, control, use, waste management
  • Record keeping
  • Decommissioning

SRP Conference 17/10/2013
  • Security
  • NaCTSO requirements sealed sources
  • Robust procedures delivery/acceptance processes
  • Physical barriers secure doors and windows,
    safes, lockable fridges/freezers, robust
  • Electronic measures alarms, CCTV, restricted
    access e.g. pin numbers, swipe cards

SRP Conference 17/10/2013
  • Infrastructure
  • Concentrating work in fewer areas reduces
    facility design constraints, limits potential
  • Avoid contamination good practice /
    housekeeping / maintenance
  • Contamination monitoring

SRP Conference 17/10/2013
  • Radionuclide Management
  • Co-ordination of purchasing
  • Rigorous ordering procedure
  • Central stock for several users
  • Use minimum quantities
  • Demonstrate storage of RA material has been well
    planned and implemented
  • Muster checks
  • Regular audits

SRP Conference 17/10/2013
  • Waste Management
  • Documented BAT assessment identify all waste
  • Identify how to handle waste created
  • Identify disposal routes for all possible waste
  • Justification for all accumulation decay and
    co-ordination of waste collections
  • Assess environmental impacts
  • Ensure systems and equipment are maintained

SRP Conference 17/10/2013
  • Storage facilities should be
  • Clean
  • Tidy
  • Well Organised
  • Take account of other hazardous properties e.g.
  • Bunded if storing liquids

SRP Annual Conference 29-04/2013 01/05/2014
  • Radiation Protection Goals Guidance,
    Operational Experience, ALARP, Legislation,
  • ALARP RP Culture and More John Croft
  • ALARA keeping doses As
  • Low
  • As
  • Reasonably
  • Achievable

SRP Annual Conference 29-04/2013 01/05/2014

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