Re: Silly requirements

[Chris Davey <cdavey@med.phys.ualberta.ca>]

We were recently inspected by the AECB.  The head of the Western Regional 
Office said that he would create some memos in his office to ensure that 
his interpretation was used by all inspectors from his office, and thus 
avoiding surprise, additional requirements at future inspection events.  
This was for items more obscure than the one you mentioned.

I think there's some misunderstanding here...  Also, based on my 
experience as a former inspector for the AECB, I would encourage you to 
challenge this interpretation. Section 22 of the AECRegs never meant what 
you said he said (!) when I used it for inspection purposes!
My argument would be:  the outer container and lid are always there, when 
the sources are in storage, therefore labelling them with isotope and 
activity meets the intent and wording of the regs just fine.

Good luck - I'm _not_ going to label the 2.5 mm diameter sources (in my 
Selectron brachytherapy unit) individually, even if it could be argued 
that the hollow, spherical steel balls with welded-in lids are containers 
for the cesium-137 sources inside.

Regards,

Chris Davey
        RSO  Cross Cancer Institute  11560 University Avenue
        Edmonton   Alberta   Canada  T6G 1Z2
        (403)432-8616   fax 432-8615    email cdavey@med.phys.ualberta.ca

On Thu, 30 Jan 1997, Peter Fundarek wrote:

(snip) 
> 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 (snip) is used as the storage room for sealed 
> sources awaiting disposal and (snip) where we store our neutron sources as 
> well.
> (snip)  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.
> 
(snip) 
> 
> *************************************
> Regards,
> Peter J. Fundarek
> University of Toronto
> CANADA
> email:  p.fundarek@utoronto.ca
> phone:  (416) 978-2374
> fax:  (416) 971-1384
> *************************************