Controlling the NORM Waste Collection Site in Qatar

Where this sits in the decision

Article 4 makes the generation of radioactive waste subject to following the procedures in these rules, collection among them, and to a licence. Article 7 is where the collection procedure itself is written. So the three controls are not advice. They are the content of a duty that another article made a condition.

Clause 1: a barrier, and the signs fixed on it

The work area is defined by putting a barrier around it, and the radiation warning signs are fixed on that barrier. The clause gives a reason for both: so that the work is completed safely.

The wording is one sentence, and the fixing of the signs on the barrier is part of it rather than a separate step.

Clause 3: trained workers only

The clause is a prohibition and not a recommendation. Anyone who is not among the trained workers is not to work in that area.

Note what the clause attaches the ban to: working in the area. It is written about the work and not about mere presence, and we do not stretch it beyond its words.

Clause 4: the plastic cover under the equipment

The floor on which the contaminated equipment is placed is covered. The cover has two described properties: it resists water leaking through, and it stands up to the work without tearing.

Equipment in these rules is a defined word, and the definition reaches containers, pipes and tanks among other things, so the clause is not limited to one shape of item.

The three controls in rows

Clause | What has to exist | What the text does not fix

Clause 1 | a barrier around the work area, with the radiation warning signs fixed on it | no width, no height, no distance from the work, no material and no size of sign

Clause 3 | a ban on anyone untrained working inside the area | no course is named, no training body, no certificate and no period of validity

Clause 4 | a water-resistant plastic cover, able to stand the work without tearing, on the floor under the contaminated equipment | no thickness, no grade of plastic and no margin beyond the footprint of the equipment

A figure that exists, in another article

A barrier with a stated width does appear in the decision, but it is the barrier around the temporary store and not the barrier at the collection site. Article 10 clause 2 puts it at not less than two metres and calls that ring the supervision area. Carrying that figure across to a collection site is our error to avoid, not the text speaking.

A question we raise and do not settle

Why the collection barrier carries no width while the store barrier does is not answered in the text. We do not read the silence as permission and we do not read it as a prohibition. It is a question for the Ministry, and we put it in writing rather than answering it in house.

Four steps in order

First, decide the boundary of the work area on paper before anything is moved, and write down why the boundary falls where it does. The text asks for the area to be defined and leaves the dimension to you.

Second, put up the barrier and fix the radiation warning signs on it. Fixing on the barrier is the wording of the clause, so a sign resting on the ground is not what was described.

Third, cover the floor where the contaminated equipment will be set down, with plastic that resists water and does not tear under the work.

Fourth, keep a list at the entrance of who is trained for this work, so that the ban in clause 3 can actually be applied by whoever is standing there.

A worked case, with our arithmetic

Say the contaminated equipment occupies a footprint of six metres by four, which is twenty four square metres. The clause asks for the floor on which the equipment is placed to be covered, and names no margin. If the operator chooses half a metre of margin on every side, the covered rectangle becomes seven by five, which is thirty five square metres, and the extra eleven square metres is the operator's choice and not a requirement of the text.

Write the choice and its reason in the method statement. A reader who later sees thirty five square metres on a drawing and twenty four in a clause should be able to see where the difference came from.

Does the decision fix a distance for the barrier at a collection site?

No. Clause 1 of article 7 asks for the area to be defined by a barrier with the warning signs fixed on it, and gives no dimension. The width of not less than two metres in the decision belongs to the barrier around the temporary store in article 10, and it is not carried across.

Who may work inside the collection area?

The trained workers. The clause is phrased as a ban on allowing anyone other than them to work in that area, and the decision names no particular course.

Is a paper notice enough as a warning sign?

The clause says the signs are fixed on the barrier. Fixing is the word used. The material of the sign and its size are not in the clause, so we report what the clause asks and we do not add a specification to it.

Must the whole yard be covered in plastic?

The clause ties the cover to the floor on which the contaminated equipment is placed. A margin beyond that is a choice an operator may make, and it is written down as a choice.

Who decides that a piece of equipment is contaminated?

Article 6 is the place of that test, and it turns on the dose at the surface of the equipment being more than twice the radiation background in the State. The background value is not published in this decision, and the reading itself is a measurement for a specialist to take and record with its date.