Speakers
Description
Increased awareness of environmental issues has driven the widespread use of beta absorption-based air particulate analyzers. These instruments utilize the radiometric principle with beta ray sealed sources, typically 14C, 63Ni, or 85Kr (with activities from 0.45 MBq up to 75 MBq), to continuously measure the concentration of airborne particulate matter (PM).
These instruments are used both at stationary observatories on the Employer's premises and in external environmental campaigns (e.g., supporting the Fire Brigade following major incidents) at sites that cannot be determined a priori.
This work examines the case study of an Employer who holds multiple sources used in a fixed mode, initially falling under the Practice Notification regime (pursuant to Italian Legislative Decree 101/2020 and Directive 2013/59/EURATOM). The critical issue arises when the Employer needs to move a single device for temporary monitoring at an external site.
Following the transfer, the single source may fall outside regulatory control. This is because the activity of the source, when installed on a mobile unit, can drop below the thresholds established for Practice Notification (Table I-1A) and for the road transport of radioactive materials (Table I-4). This situation creates a scenario of "non-radiological relevance" for the practice. However, upon returning to the original location, the source is once again considered "held" under the notification regime.
This mobility creates three primary challenges:
1. The movement of the source raises questions about the necessary communication to supervisory authorities. Since the original practice was subject to communication, a modification of communication is required to declare the temporary cessation of holding the source at the initially declared location. However, the legislation does not clarify whether this communication must also be sent to the destination supervisory authorities to inform them of the source's presence in their territory, especially when the source itself no longer requires notification.
2. Since the source activity is below the values specified in Table I-4, the mandatory provisions for the transport of radioactive materials do not apply. This means that packaging, markings, or the use of an authorized carrier (ADR) are not required.
However, performing the transport privately exposes the transporter to a significant insurance risk. If the source is involved in theft, loss, or serious events (e.g., fire, major car accident), insurance companies may refuse coverage for "accidents occurring during the transmutation of the atom." While a highly cautious approach involves the a priori use of an authorized ADR carrier, this solution incurs an additional cost that may not be justifiable, as the decree does not legally require it.
3. Ambiguities also exist in managing the transport and holding registration on the Sistema Tracciabilità Rifiuti Materiali e Sorgenti (STRIMS).
• To register the transport, the Employer might be required to list themselves as an authorized transport carrier, even though they are not legally designated as ADR.
• The cessation of holding requires specifying the final destination. This destination is often not owned by the Employer, being an external and temporary monitoring site.
The disparity between the source activity in fixed and mobile modes risks turning these sources into regulatory "ghosts" during transit. It is essential for the Employer and the Radiation Protection Expert to establish clear procedures for communication, transport, and STRIMS registration to avoid penalties from local supervisory authorities.
