SRP HASS

1
SRPHASS
Chris Englefield 01 November 2005
2
HASS Directive

• Transposed into UK legislation by
• HASS and Orphan Sources Regulations 2005
• Directions to environment agencies from govt
• New security regime for sealed radioactive
  sources
• Environment Agency regulates
• non-nuclear premises (England and Wales)
• tenants on nuclear licensed sites.
• SEPA (Scotland), EHS/IPRI (N.Ireland)
• HSE (operators of nuclear licensed sites)

3
Principal Features 1

• arrangement for safe management of HASS
• including when disused
• financial provision, (or equivalent)
• disused HASS
• authorisations cover
• responsibilities, training, suitable equipment,

4
Principal Features 2

• work and emergency procedures
• record keeping by users and CAs
• notification of transfers
• MS provisions to recover orphan sources
• deal with radiological emergency arising
• regime for security of radioactive materials
• civil non-nuclear sites
• HASS and other sealed sources
• similar level of potential hazard

5
Authorisation

• Extant arrangements of RSA93
• Before granting registration/authorisation Agency
  must now be satisfied user
• can manage HASS and
• meet security requirements
• If both HASS and non-HASS sealed sources
• all covered by one registration,
• some conditions will only apply to HASS

6
What is a HASS?

• Sealed source
• Listed in Annex 1 of the Directive and
• exceeds activity level at manufacture, or
• Listed in Annex 1, Table A, of BSS Directive and
• activity at manufacture is
• gt1/100 of A1 value (TS-R-1IAEA Vienna 2000)
• No lower limit on half-life
• includes relatively short-lived sources
• e.g. Ir-192 (industrial radiography)

7
A new HASS?

• First placed on market on or after
• 01 January 2006
• (existing HASS placed on market on or before
• 31 December 2005)

8
Similar level of potential hazard?

• Any source or aggregation of sources
• in a single storage or use location,
• fall into Categories 1 to 4
• NSACs Security Requirements for Sites and
  Sectors working with Radioactive Sources (NSAC
  October 2005)
• Available only from CTSA

9
Applications and Transition?

• Apply to any new HASS after 01 Jan 2006
• Existing HASS already held
• brought under regime at same time as new
• (not FP or arrangements for disused sources)
• All HASS under regime by 01 Jan 2008
• must make application for existing HASS by
• 1 September 2007 if not brought in earlier.

10
Forms etc?

• Available at our website,
• RSA1cv051 single premises
• RSA1mv051- mobile HASS
• RSA3v051 to accumulate waste HASS
• Interim Guidance
• HASS Band 4H in charging scheme.
• Security Band 4S from 01 April 2006
• (subject to current consultation).

11
Applications

• We assess information in your application, and
• Are likely to visit your premises
• We will consult police on security matters
• They may visit your premises also,
• either jointly or separately

12
You need to demonstrate (1)

• able to comply with limit and conditions of
  cert.
• suitable arrangements for disused HASS
• including adequate financial provision.
• (Defras guidance on financial provision expected
  shortly)
• source replacement docs or
• take-back arrangement docs
• lease arrangement docs or
• certificate of public body underwriting,
• contract with a charged fund holder

13
You need to demonstrate(2)

• Compliance with NSAC standard
• for your Category of sources
• (DO NOT include details in application)
• ability to maintain security over time

14
Management systems

• Sufficient to achieve compliance with
  certificate(s)
• Show you plan, do, check, act
• (to continuously improve the system
• We DO NOT expect a stand-alone system
• likely to be part of existing systems

15
Management systems 2

• Scope
• Definition roles, responsibilities authorities
• Resources and training required
• Procedures
• written procurement, operation, maintenance
• Emergency procedures
• Record Keeping
• Checking own compliance
• Designation of a competent supervisor

16
Checking of HASS

• You will be required to verify (at intervals)
  that
• Each HASS is present and in good order
• Relevant equipment is still present
• (cf. Reg 28 IRR 99) and in good order

17
Marking of HASS

• New HASS
• Do not acquire a new HASS after 31 December 2005
  unless
• It has a unique number by manufacturer
• Where practicable, legibly engraved with id
• Accompanied by written information with its id
• Existing HASS
• need to allocate a unique id to the HASS
• Containers also require marking

18
Photographs of HASS

• New HASS
• manufacturers must provide to you, of
• The source and, as appropriate
• The source container
• Transport packaging
• Associated equipment
• Existing HASS
• where reasonably practicable, take own photos

19
Record keeping

• Sufficient to demonstrate compliance with cert
• e.g.
• maintenance records,
• copies of correspondence
• e.g confirmations that any person to whom you
  transfer a HASS holds a permit.
• Source records

20
Notifications

• existing notifications
• e.g. (cessation of use, change of premises)
• management changes
• going into administration
• non-compliances,
• incidents involving HASS,
• security changes
• loss or theft (notification to include photos)

21
Reporting 1

• To Agency
• Within 14 days of making the initial record
• Every 12 months thereafter
• Within 14 days of any changes
• In a SPECIFIED FORMAT
• (will be available from our website)
• different to Annex 2 of the Directive

22
Reporting 2

• Clear, accurate and consistent
• To enable us to maintain accurate records
• Can be completed by hand
• DO NOT SEND electronically
• Reporting format common to UK regulators
• Data structure explained in Interim Guidance

23
Reporting 3

• Requirement of you AND us
• Be aware of, and have records of each side of a
  HASS transaction
• I am BRIGHT SOURCES LTD and I have sent HASS A1
  to ACME Ltd
• I am ACME LTD and I have received HASS A1 from
  BRIGHT SOURCES LTD
• I am the Regulator and I can map the entire
  life-history of HASS A1

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UK Inventory of HASS

• Secure, electronic and searchable
• Record of the complete life-history of all HASS
• Paper inputs initially
• Electronic comms later
• To inform Regulatory Officers before inspect
• Automatically reconciliation of notifications
• Records of lost HASS
• Identify found HASS
• Used by environment agencies, police,others

25
Conclusions

• Major change in UK regime under RSA93
• HASS sources of similar level of potential
  hazard
• Tougher conditions on users
• Will provide improved control of higher-risk
  sources
• Social, Economic and Environmental protection