Silly requirements

[Peter Fundarek <P.FUNDAREK@utoronto.ca>]

With all the talk on the need for specific levels of control and protection, 
along with previous threads on absurd regulations, I thought that I would share 
my own recent experience.

At the University of Toronto, we manage our own radioactive waste under a 
specific licence from the Atomic Energy Control Board (AECB).  One of the 
facilities where this is carried out is used as the storage room for sealed 
sources awaiting disposal and those which may be used again in the future.  This 
is where we store our neutron sources as well.

The room is specially constructed of 12 inches of reinforced concrete with a 
solid metal door.  It is labelled on the outside as having radioactive 
waste inside.  There is a restricted key access lock and a security system tied 
into the campus police who are close by.  Access to the room is restricted to 
members of the radiation protection section and personnel specifically trained 
to handle radioactive waste (about 10 people in all).  The neutron source 
storage facility is a block of reinforced concrete with pvc pipe vertical source 
holes in it.  Each source hole is seven feet deep.  In each hole is a 30 inch 
shielding plug which has an additional 4 inch cap that rests on the top of the 
block.  A label on the top of the plug indicates the source and its activity.  
To access the sources, one need remove the shielding plug and then retrieve the 
inner source holder that is 54 inches long.  The source is at the bottom of this 
inner holder.

This facility has been inspected twice a year by the AECB group responsible for 
radioactive waste management for the past six years.  No problems have been 
noted.  Now another inspector has come along.  He feels that, according to the 
regulations, the inner source holders are considered containers and therefore 
must be labelled with the proper signage!  He is writing a non-compliance report 
since he considers these sources to be improperly marked.

This is absolutely ridiculous but there is no room for interpretation.  If there 
was the slightest chance that these sources were accessible to the public, I 
might agree but there is none.

As I said in a posting to the Canadian version of radsafe - the goal is 
radiation safety.  How we achieve that goal is immaterial as long as the level 
of protection is consistent and realistic.  The inspector agrees that adding the 
signs will not do anything for radiation safety.  However, the regulations say 
that the signs must be present so therefore we must be in violation of 
something.

We need to focus our resources in areas where they will do the most good.  
Requiring someone to label the obvious is not what I consider a good or prudent 
use of resources.

Just thought I'd release a little steam south of the border to let you know 
things are not that much better up here.

*************************************
Regards,
Peter J. Fundarek
University of Toronto
CANADA
email:  p.fundarek@utoronto.ca
phone:  (416) 978-2374
fax:  (416) 971-1384
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