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
*************************************