Last updated date: | Reason for update: |
---|---|
01 July 2023 | Updated to align with amendments to section 65 of the Regulations where additional options are provided for disposal of low hazard sources without prior approval. |
Associated forms
Purpose of this guide
This regulatory guide sets out ARPANSA’s expectations for the disposal of:
- Controlled apparatus and controlled material under section 65 of the Australia Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations)
- Security enhanced sources under the Code of Practice for the Security of Radioactive Sources (RPS11)
Explanation of terms
In this guide the generic meaning of ‘disposal’ is used. It includes the transfer of controlled apparatus and controlled material (collectively referred to as sources) to another ARPANSA licence holder or to a person/organisation outside of ARPANSA’s jurisdiction.
The term ‘source’ is used to collectively mean controlled apparatus and controlled material.
A ’security enhanced source’ means a radioactive source or aggregation of sources assigned the Category 1, 2 or 3 when using the methodology set out in Schedule B of Code of Practice for the Security of Radioactive Sources (RPS 11).
Introduction
Section 65 of the Regulations provides 4 disposal options:
- The licence holder may dispose of controlled material or controlled apparatus with prior approval from the CEO
- The licence holder may without approval of the CEO transfer the controlled apparatus or controlled material to another licence holder under certain conditions
- The licence holder may without approval of the CEO dispose of the controlled apparatus by returning certain controlled apparatus to the supplier of the controlled apparatus in certain circumstances
- The licence holder may without approval of the CEO dispose of certain controlled apparatus by rendering the controlled apparatus permanently inoperable as a controlled apparatus in certain circumstances.
Under option 2, prior approval is not required to transfer a source to another ARPANSA licence holder provided:
- both entities hold an appropriate licence issued by the CEO of ARPANSA,
- the apparatus does not contain a security enhanced source, and
- the licence holder disposing of the apparatus tells the CEO about the transfer within 7 days.
A Source Transfer Notice must be submitted within 7 days of the transfer.
Where a licence holder routinely disposes of sources as part of routine operations the CEO of ARPANSA can make a special arrangement in the licence under subsection 65(5) of the Regulations so there is no need to seek prior approval to dispose of each source.
Note: Temporary transfer of sources to a service agent for repair or maintenance is not a disposal as ownership is retained by the licence holder. In such cases the licence holder must ensure that the service agent has appropriate training in radiation safety and training with respect to such activities (as required by all licences).
Disposal of controlled apparatus
As defined in section 13 of the Act, controlled apparatus means any of the following:
- An apparatus that produces ionising radiation when energised or that would, if assembled or repaired, be capable of producing ionising radiation when energised
- An apparatus that produces ionising radiation because it contains radioactive material
- An apparatus prescribed by the regulations that produces harmful non-ionising radiation when energised.
Disposal of controlled apparatus often includes destruction or dismantling.
Disposal of controlled apparatus requires prior approval from the CEO of ARPANSA unless the licence makes other arrangements under subsection 65(5) of the Regulations OR the disposal meets the conditions described in paragraphs 65(1)(c) & (d) for certain controlled apparatus. This allows Group 1 controlled apparatus to be returned to the supplier or rendered permanently inoperable without prior approval provided it does not contain controlled material.
To satisfy the CEO of ARPANSA of the ‘destruction’ of a controlled apparatus it must be rendered inoperable in such a way that only expert knowledge and the use of specialised components could potentially restore its function.
In most cases, removal of a critical component(s) and severing the power cables will render the apparatus inoperable. For example:
- In the case of x-ray apparatus, eliminating the vacuum inside the x-ray tube by breaking the glass envelope and severing the high-tension cables will effectively destroy the apparatus.
- In the case of lasers removing the power supply, critical optical components or the amplifying medium will render the apparatus inoperable.
In all cases, the licence holder must take into account the presence of other hazardous materials, for example: beryllium, mercury, cadmium, etc. The licence holder should seek guidance from their local environmental agency on disposal requirements for such material or investigate possible recycling options.
Once destroyed, the apparatus ceases to meet the definition of a controlled apparatus and is therefore no longer subject to regulatory control. Individual dismantled parts are not deemed to be controlled apparatus.
If apparatus is to be disposed of because it has ceased to function, a critical component should still be removed so that repair is not possible.
In the case of apparatus containing radioactive material, removal of the material means the apparatus is no longer ‘controlled’. However, depending on the activity of the material removed, it may still be subject to regulatory control and need to be authorised by a licence.
Where disposal to landfill is proposed, the licence holder should ensure that the removed critical components are discarded separately to the rest of the apparatus unless they are to be retained as spare parts. This is to prevent any chance of them being recombined or repaired. Recycling should be considered where possible.
Transfer a source out of ARPANSA's jurisdiction
Sources are often sold, leased, hired, or given away to a person or organisation in another jurisdiction - such action is regarded as a ‘transfer’. This includes the return of controlled material to the original manufacturer or supplier in another jurisdiction or in some cases overseas.
In the majority of cases prior approval is required for a source to leave ARPANSA’s jurisdiction. However, paragraph 65(1)(c) of the Regulations provides for certain Group 1 controlled apparatus to be returned to the supplier without prior approval as noted above.
Particular attention is required when proposing to dispose of multiple low activity sources in a single shipment. The activity of all sources must be aggregated (using the method in Schedule B of RPS 11) to determine if additional security arrangements apply.
Additional requirements for security enhanced sources:
Licence holders must be aware of the additional security arrangements for security enhanced sources, in particular the requirement for an endorsed transport security plan – see RPS 11 (para 5.3).
It is important that receipt of the source is confirmed at its final destination particularly if overseas.
If the final destination is outside Australia the licence holder must ensure that the required documentation is completed noting that an ARPANSA Export Permit is required for the export of high activity sources. For the definition of a high activity source and information about how to apply for an export permit please see Export permits | ARPANSA.
Transfer a security enhanced source to another ARPANSA licence holder
Under RPS 11 (2.1.11) the transfer of a security enhanced source must have prior approval from the CEO even if the transfer is between ARPANSA licence holders.
Licence holders must comply with the additional security requirements, in particular the requirement for an endorsed transport security plan as per para 5.3 of RPS 11.
How to apply for approval to dispose of a source
Licence holders seeking approval to dispose of a source should use the Request for approval to dispose of a source. Completed forms should be sent to licenceadmin@arpansa.gov.au.
Licence holders must comply with their obligations under the following codes:
- Code of Practice for the Safe Transport of Radioactive Material (RPS C-2)
- Code of Practice for the Security of Radioactive Sources (RPS 11)
- Code for Disposal of Radioactive Waste by the User (RPS C-6)
Follow up actions
Maintaining an accurate inventory
Following physical disposal, the status of the source in the source inventory workbook (SIW) should be changed to ‘Transferred’ or ‘Disposed’ and the date recorded.
Reporting compliance
Compliance reports submitted by licence holders must include summary information about disposals that have occurred during the reporting period. This includes disposals that did not require prior approval to ensure that databases are updated.