Introduction & terms of reference

Contact

Notes of meetings of SULG from 6 June 2005 have been taken down from EA site. Email address from which you can request the minutes EA site Webmaster, 6 Sep 2007

News from the SULG - The 32nd meeting of the SULG was held on 4 June 2009 pdf

News from the SULG - The 31st meeting of the SULG was held on 2 December 2008 pdf

News from the SULG - The 30th meeting of the SULG was held on 11 June 2008 pdf

News from the SULG - The 29th meeting of the SULG was held on 27 November 2007 pdf

News from the SULG - The 28th meeting of the SULG was held on 26 June 2007 pdf

News from the SULG - The 27th meeting of the SULG was held on 6 December 2006

News from the SULG - The 26th meeting of the SULG was held on 7 June 2006 pdf

Meeting of SULG on 7 June 2006 - Environment Agency - Policy Update Paper pdf

SULG 25 – Actions update - meeting of SULG on 7 June 2006 pdf

RSR Process update paper - meeting of SULG on 29 November 2005 pdf

SULG 24 – Actions update - meeting of SULG on 29 November 2005 pdf

Report: LLW policy review workshop October 2005 – a small users perspective pdf

Notes of the 24th meeting of SULG on 6 June 2005 (Draft) pdf

Meeting of SULG on 6 June 2005 - Environment Agency - Policy Update Paper pdf

SULG 22 Actions Update pdf Paper provided by the EA at the December 2004 meeting of SULG that updates on actions since the previous meeting.

Meeting of SULG on 9 December 2004 - Environment Agency - Policy update paper pdf

Notes of the 23rd meeting of SULG on 9 December 2004 pdf

Meeting of SULG on 10 June 2004 - Environment Agency - Policy update paper pdf

Notes of the 22nd meeting of SULG on 10 June 2004 pdf (revised - posted 7 June 2005)

Meeting of SULG on 11 December 2003 - Update on High Activity Sealed Sources Directive (HASS) pdf

Notes of the 21st meeting of SULG on 11 December 2003 pdf

Notes of the 20th meeting of SULG on 11 June 2003 (reissued November 2004) pdf

A note from SULG that EA have approved for posting on the SRP website UPDATE ON RADIOACTIVE SUBSTANCE REGULATION POLICY MATTERS EA/SULG  Meeting 11 June 2003 1. High Activity Sealed Sources Directive.  The draft HASS Directive will apply controls, additional to those required by the BSS Directive, to high activity sealed radioactive sources.  These additional controls are intended to protect human health and the environment, and will  apply to sealed sources with activity exceeding 1% of the A1 value, for the relevant radionuclide, as defined in IAEA Regulations for Safe Transport of Radioactive Materials (TS-R-1). Defra have led the negotiations on the draft Directive and have advised the Agency that the text has now been finalised, it is expected to be published and in force during the autumn of this year.  Member States will have two years to implement the Directive and are currently considering the optimum mechanism for implementation (Direction, amendment of primary legislation, secondary legislation, etc). Implementation of the Directive will entail additional obligations on the holders of HAS sources and new duties for the relevant regulators.  One aspect under consideration is that of creating a national register of sealed sources.  Another key issue raised by the Directive that is receiving attention, is the requirement for applicants for registration to have satisfied the regulators that they have made adequate financial provision for the safe management of the source when it eventually becomes disused.  The Commission have advised that this might entail; a bank deposit (under government control), or an auditable provision, or insurance provision. 2. Radioactive Source Security.  A number of initiatives are currently underway to improve the security of radioactive sources, both at the international and national levels, these include: International Conference, Vienna 10- 13 March Revised IAEA Code of Conduct Draft IAEA TECDOC on source security HASS Directive UK source security guidance and police Counter Terrorism Security Adviser visits It is proposed that the source security guidance is prepared on a sector basis (health, research & teaching, and industry), and that the guidance is risk based and proportionate.  The Agency has provided the CTSAs with the addresses of approximately 15% of the registered premises in England and Wales which it considers worthy of a visit. 3. Development of UK policy for radioactive waste management:  The Government has issued a progress report to the EFRA Select Committee; key points include: The Government welcomes and supports the HSE/EA/SEPA proposals for better controls on waste conditioning and storage on nuclear sites. It has asked the regulators to work up detailed proposals, including a regulatory impact assessment. Advertisements have been placed for the chair and members of the new independent body, “Committee on Radioactive Waste Management” (CoRWM), to advise government and in due course, decide the best option for managing radioactive waste in the long term. There has been a pilot exercise in Scotland for recovering and managing spent sealed radioactive sources.  The Government is considering how this could be taken forward in the UK more generally, with an amnesty for unwanted sources being one possibility.  Availability of facilities at nuclear sites to receive and package the sources are key to managing disused sources. The setting up of CoRWM has raised the issue of the future role for RWMAC.    The chairman of RWMAC has written to Michael Meacher and to the devolved administrations to express concern over the areas of work which would not be covered if RWMAC were abolished.   A copy of his letter can been seen on the RWMAC web site, www.defra.gov.uk/rwmac/index.htm. 4. Nuclear Reform Bill:   The proposed Nuclear Site and Radioactive Substances Bill  will set up the Nuclear Decommissioning Authority. The Agency has commented to Defra and DTI on drafts of the Bill clauses. They include proposed amendments to RSA 93 which will include a requirement for regular reviews of authorisations and provide the facility for an undertaking to apply for a variation to its authorisation, which currently does not feature in RSA 93.  It will also allow transfers of authorisations between owners/operators of premises situated on nuclear sites. The draft Bill is expected to be published this month.  It is expected that the Bill will be introduced into parliament in the 2003/2004 session, with a view to the Nuclear Decommissioning Authority becoming operational from April 2005. 5. Radioactively contaminated land: The Agency is one of a number of organisations working with Defra to develop the outline of new regulations on radioactively contaminated land, which will effectively extend the EPA 90 Part IIA contaminated land regime to cover hazards from radioactive substances. Defra are soon to be instructing their lawyers to draft regulations and statutory guidance, with a view to consult on these later in the year. It is anticipated that these will not apply to contamination on licensed sites, as this is regulated by HSE. 6. Pollution Inventory: The Radioactive Substances subgroup of the Pollution Inventory Advisory Group met on 1 May 2003 to discuss proposed radioactive substances and thresholds for the mandatory pollution inventory.  The inclusion of limited reporting of transfers was also considered.  The subgroup recommended some changes to the Agency's proposals.  These proposals will be subject to a wider consultation in summer 2003. The proposals essentially involve a minor variation to introduce the information provision condition to those authorisations which don't already have it, followed by issue of a requirement under that condition to provide the PI information.  Details of the latter are still to be finalised. 7. Authorisation of discharges of radioactive waste to the environment: Principles for the assessment of prospective public doses. This document provides guidance on the assessment of prospective public doses arising from authorised discharges of radioactive waste to the environment. The guidance has been jointly agreed with the Scottish Environment Protection Agency, Department of Environment, Northern Ireland, National Radiological Protection Board and Food Standards Agency. The guidance is intended for use by the sponsoring organisations when undertaking prospective radiological assessments. It will also be useful to organisations applying for a new or a variation to an existing radioactive waste discharge authorisation. It is anticipated that the document will enable radiological assessments to be produced in a more consistent and transparent manner.  The document is available at the Environment Agency’s website,   http://www.environment-agency.gov.uk/business/ras/452235/ [Note by SRP Webmaster: The web address quoted gave an error message on 23 June 2003. The correct address is: http://www.environment-agency.gov.uk/business/444304/444637/ras/452235/?version=1&lang=_e (accessed 23 June 2003).] 8. European Commission’s proposed ‘Nuclear Package’.  The Commission have now published their proposals, which include: proposals for new legislation that would bring about the development of common safety standards in Europe covering the full nuclear sector; segregated funds to cover all nuclear liabilities that remain after the operating lifetime of an installation; clearly defined waste programmes for radioactive waste management in each of the Member States of the Union. The national waste management programmes are to include a number of decision points: authorisation for development of appropriate disposal site(s) to be granted no later than 2008. In the case of geological disposal of high-level and long-lived waste, this authorisation could be conditional upon a further period of detailed underground study; in the case of short-lived low and intermediate-level waste, if this is to be disposed of separately from high-level and long-lived waste, authorisation for operation of the disposal facility to be granted no later than 2013; in the case of high-level and long-lived waste, to be disposed of in a geological repository, authorisation for operation of the disposal facility to be granted no later than 2018.. The ‘Nuclear Package’ will lead to, inter alia, two new directives which the Commission refer to as the “Safety Directive” and the “Waste Directive”.a>

Notes of the 19th meeting of SULG on 5 December 2002 Microsoft Word

• Interactive Pilot for RSA applications
• Recent conference on "Radiation Protection issues not under regulatory control"
• BPM for non nuclear authorisations
• Update on Safeguard position
• Disposal of organic liquid waste
• Update regarding "Decay storage"
• Update on RSR Policy matters

top of page

News from the 19th meeting of the SULG, held on 5th December 2002
The 19th meeting of the SULG was held in London on 5th December 2002. The following points were discussed:

• The preparation of guidance by the EA regarding the lending and hiring of sources by Instrument Manufacturers has still to be completed.
• The Guide to RSA93 remains with the legal department at Defra. Details of Exemption Orders are now on the Defra website.
• A presentation was made to SULG of a screen-fillable trial RSA1 open sources application form that the EA propose to pilot over the coming months. This is in early stages of development so do not expect to see early introduction of electronic forms on a routine basis just yet!
• An updated draft of interim guidance on BPM for non-nuclear users of radioactive substances was provided at the meeting. This is a living document that will be subject to ongoing review. The EA have agreed to provide an electronic version which will be placed on the SRP website along with the final approved minutes of the SULG meeting. The document contains details of who to send comments and suggestions to for future improvement of the guidance.
• It is the Agency's intention that mandatory reporting to the Pollution Inventory will commence on 1/01/04 with the first formal report submission in January 2005. All non-nuclear authorisations should be amended during 2003 to reflect this change. It is likely that this opportunity will also be used to add a BPM condition to non-nuclear authorisations.
• Safeguard International is now re-commencing its sealed source disposal service, although full service resumption may take several months to achieve.
• Please will small users note. When completing your voluntary returns to the Pollution Inventory between now and 2005, do ensure that technetium for medical diagnosis is recorded as 99mTc. Last year, some hospitals incorrectly reported discharges of 99Tc to the environment even greater than the nuclear industry!
• Following public consultation on a Compliance Certification Scheme for Environmental Permits, the Agency is planning to implement the Scheme on a phased basis from November 2002 onwards. The data collected will be used to support decision-making within the Agency.
• The EA has established a Sealed Sources Working Group. In the short-term, the work of the group will be dominated by the implications of the HASS Directive. Small users should note that this Directive will have implications for some sources used in brachytherapy/radiotherapy, as well as sources in irradiators and those used in industrial radiography.

The next meeting of the SULG will be held on Wednesday 11th June 2003. Please send any agenda items to cathy.griffiths@sth.nhs.uk or telephone 0114 271 3737.

top of page

Notes of the 18th meeting of SULG on 18 June 2002 and follow on meeting to discuss RAS pollution inventory Microsoft Word:

• Changes to Environment Agency Organisational Structures
• Consultation on UK discharge strategy
• RSA93 template
• Best possible means for non-nuclear authorisations
• Update on RSR Policy Matters

Follow on meeting to discuss RAS pollution inventory

• Review of reporting, 2001
• Mandatory Reporting
• Electronic reporting
• Options for total alpha, total beta and other activity reporting
• Radioactive Consignment Note for waste
• Reporting thresholds

top of page

Notes of the 17th meeting of SULG on 5 December 2001 rtf:

• UK radioactive discharges strategy
• DEFRA consultation document "Managing Radioactive Waste Safely"
• Exemption Orders/Guide to RSA 93
• RSA 93 templates/E Forms
• High Activity Sealed Sources (HASS) Directive
• Best possible means (BPM) requirement for non-nuclear authorisations
• Radioactive Substances Pollution Inventory
• Policy re lending and hiring of sources by instrument manufacturers

top of page

Notes of the 16th meeting of SULG on 2 July 2001 (pdf Help):

• Guidance to RSA93
• EA/IPRI/SEPA/NRPB Dose Assessment Policy and Principles
• Inventory of Sources and Releases (ISR) for radioactive discharges
• Disposal of patient clinical waste and incontinence pads
• EA re-organisation
• Excretion factors
• National Radium Stock
• Advice to Schools

top of page

Introduction
The Small Users Liaison Group was set up following problems highlighted in the twelfth annual report of the Radioactive Waste Management Advisory Committee (RWMAC) in its chapter "Small Users, Big Problems". The terms of reference of the group are:

Received and posted on 8 December 2004 Terms of Reference Environment Agency – Small Users of Radioactivity Liaison Group (SULG) To provide: a forum for effective liaison, communication and consultation between non-nuclear users of radioactive substances and the Environment Agency; and an improved understanding of Agency and Users’ objectives, priorities and constraints in respect of the management of radioactive waste, with the aim of improving both the clarity and consistency of regulation. Structure and Membership The Agency will chair and provide the secretariat for the SULG.  Membership of the Group will be drawn from: Agency:  Appropriate Head Office, Regional and Area staff Users:  Organisations representing the non-nuclear users community such as AURPO, IPEM, PIRSDG, SRP, BNMS, IRP and NRPB. DEFRA:  Radioactive Substances Division.   top of page

Contact
The Society's representatives on the SULG are:

• John Lambley (Email: John.Lambley@matthey.com) and
• Mike Dunn (Email: mike.dunn@uhl-tr.nhs.uk).