Follow up of former recommendations From To By Pascal Deboodt Head of Health Physics & Safety Department Belgian Nuclear Research Centre SCK●CEN

Contents The 1st EAN Workshop (Saclay, France, December 1997) Follow up At the EC level - At the EAN level European Regulatory Framework and Perspectives

What have been the recommendations of the 1st Workshop of the EAN? (1) Need to develop tools to estimate dose rates in complex and evolving environments and activity levels of large amounts of waste Need to develop techniques, models and software to realistically predict and follow-up internal exposures Need to take into account a total risk approach with various trade-offs such as radiological and conventional risks, public and occupational exposure, imposed and voluntary risks, human health and environmental hazards

What have been the recommendations of the 1st Workshop of the EAN? (2) Need to develop tools to introduce transparency and coherence in the decision aiding, particularly in the case of the trade-offs identified in 3rd recommendation Need to enlarge the ISOE to plants being decommissioned in order to have available an international database and feedback experience exchange support Need to create an ALARA culture in the non-nuclear sector where there are significant opportunities to improve ALARA

What have been the recommendations of the 1st Workshop of the EAN? (3) Need to adopt an uniform system of control in Europe to demonstrate that an acceptable level of risk has been achieved when materials arising from decommissioning are cleared Need for clear criteria to be applied in the radiological aspects of the remediation of contaminated sites and for protocols covering means of demonstrating compliance to the regulator and to the public

Follow-up Preliminary remarks Not the official point of view of the EC! (but with A. Janssens support/comments) Focus on the follow-up of the 1st EAN-WS

Follow-up Setting the scene…! (1) EUROPEAN COMMISSION EAN 1996 DIR 96/29 ? 1997 WS 1 DIR 97/43 1998 WS 2 1999 WS 3 RP-95,96,101,107,108,112 2000 WS 4 RP-113,114,115,117,122(1) 2001 WS 5 EASN RP-124 2002 WS 6 RP-122(2) EFNDT/NRPB 2003 WS 7 SMOPIE project

Follow-up Setting the scene…! (2) European ALARA Sub Network (EASN) European Federation of Non Destructive Testing (EFNDT) National Radiological Protection Board (NRPB) Swedish Radiation Protection Authority (SSI) Strategies and Methods for OPtimization of Internal Exposure of workers from industrial natural sources (SMOPIE) EURopean Accident and Incident Data Exchange (EURAIDE)

First of all...! Publication RP 108 “ALARA and Decommissioning – Proceedings of the 1st European ALARA Network Workshop”, Luxembourg, 1999

Follow up 2.1. “Tools – Doserates” Support provided to the extension of existing software (VISIPLAN  VRIMOR, PANTHERE) Other software (see meeting of the SFRP, Sochaux, October 2003)

Follow up 2.2. “Internal Exposures” Main recommendations Dose data required Assessment of the internal dose Internal dose monitoring techniques Application of ALARA for internal exposures ... and involvement of the managers! Need for a network in this area

Follow up 2.3. “Total Risk Approach” Main recommendations Study of the transfer of risks Education and risks Involvement of all the stakeholders

Follow up 2.3. “Total Risk Approach” Conference on Occupational Exposure Geneva – August 2002 ASARA? Draft International Action Plan (IAEA – ILO)

Follow up 2.5. “ISOE” 2nd Workshop ISOE, Tarragona, 2000 “Observations and Recommendations from the 1st EAN Workshop to improve ALARA implementation during decommissioning”; (Pascal Crouail, Christian Lefaure, John Croft) “The ALARA approach and related Classical Safety Factors”; (Pascal Deboodt) 4th Workshop ISOE, Lyon, 2004 “The European ALARA Sub Network: a growing child!”; (Hanne Troen, Pascal Deboodt (proposal)) European ALARA Sub Network Information System on Occupational Exposure

Follow up 2.6. “ALARA Culture – Non Nuclear Sector” The EAN itself! Translation of the Directive 96/29 et 97/43 5th Workshop and 6th Workshop SMOPIE, EURAIDE

Follow up 2.7. “Uniform system of Control” Many publications at the EC level (after 1997) RP 107 “Establishment of reference levels for regulatory control of workplaces where materials are processed which contains enhanced levels of NO radionuclides” (1999) RP 113 “Recommended radiological protection criteria for the clearance of buildings and building rubble from the dismantling of nuclear installations” (2000) RP 114 “Definition of clearance levels for the release of radioactively contaminated buildings and building rubble” (2000) RP 122 “Practical Use of the Concepts of Clearance and Exemption” (2000-2002) Part 1: Guidance on General Clearance Levels for Practices Part 2: Application of the Concepts of Clearance and Exemption to Natural Radiation Sources

Follow up 2.8. “Criteria Remediation” “Investigation of a possible basis for a Common Approach with regard to the REstoration of areas affected by lasting radiation exposure as a result of past or old practice or work activity” Final Report September 1999 Radiation Protection 115 Published Environment Directorate-General 2000

European regulatory framework and perspectives

Directive 96/29 Euratom Art. 3: Reporting Art. 4: Prior authorisation Each Member State shall require the practices referred to in Art. 2 to be reported, except… Art. 4: Prior authorisation Each Member State shall require prior authorisation for the following practices… Art. 5: Authorisation and clearance for disposal, recycling or reuse The disposal, recycling or reuse of radioactive substances or materials containing radioactive substances arising from any practice subject to reporting or prior authorisation... 8 17 25

practice authorities exemption authorisation reporting clearance Exemption - Clearance authorities exemption authorisation reporting practice authorisation clearance waste disposal recycling, reuse

general clearance levels exemption values in BSS authorities authorisation exemption general clearance levels set in legislation practice clearance waste disposal recycling, reuse

Optimisation of the disposal of radioactive waste from dismantling of nuclear installations This paper is concerned with the disposal of radioactive waste from the dismantling of nuclear installations and to what extent the establishment of clearance levels has an impact on the optimisation of decommissioning strategies, in particular with regard to metal recycling. In this context different policy options for the recycling of contaminated or activated scrap metal will be discussed in this paper, referring in particular to guidance produced by the Commission’s “Article 31” Group of Experts. 1 1

Terms of reference Decommissioning costs dismantling – disposal - clearance Disposal options ordinary landfills – repositories – low/medium level repositories Recycling options within nuclear industry – conditional recycling – clearance Cost benefit economic costs – doses Social consideration

Social considerations acceptability to recycling industry aversion consumers of finished products enhanced by antinuclear movements hence commercial interest to guarantee uncontaminated products contractual arrangements controls (monitoring) for safety reasons orphan sources import of scrap Beyond the mere cost-benefit analysis and the economical aspects of the dismantling operations considered in isolation, societal considerations must be taken into account. A very important economic factor is the acceptability of clearance to the recycling industry itself. This acceptability, in turn, is directly affected by a possible aversion of consumers for the idea that trace amounts of radioactivity would appear in the finished products. Thus, for the industry, there might be a detriment in terms of the market value of their production if suspicion is raised as to the possible inclusion of radioactivity. This consideration is very much enhanced by that fact that anti-nuclear movements have very much exploited the fear of people for radioactivity and have pointed to the possibility of radioactivity appearing in consumer products. Indeed, there have been a number of newspaper articles on this subject this year where nuclear opponents have underlined the possibility that industry would get rid of its radioactive scrap through the clearance levels allowed by the new EU Directive on Basic Safety Standards. So, for the industry, there is a commercial interest in being able to guarantee uncontaminated products. 9 9

Import of scrap metal the import of scrap is subject to exemption levels rather than clearance levels consignments with nothing but exempted scrap (at current exemption levels) would readily be detected (false?) alarms also by NORM residues (scales in oil tubes) transport documents may need to identify the origin of the scrap exemption levels to be replaced by general clearance levels? customs controls on grounds of health protection more efficient at borders? information exchange between customs authorities may help to track illicit movements 33 46 43

Buildings reuse for non-nuclear occupation building rubble industrial/other building rubble disposal recycling foundations/landscaping processing crushing/sorting use (road construction, new concrete)

Conclusion Clearance levels General clearance levels (Bq/g) for any type of material default (exemption) value for international trade (SDL) Specific clearance levels (Bq/g) for metal scrap (recycling, secondary smelting ingots) together with surface criteria for thick sheets also for small scale demolition (building rubble) Surface levels (Bq/cm2) for building walls higher levels for subsequent demolition

Conclusion Regulatory control of decommissioning Inventory contamination-free areas radioactive waste material with a potential for clearance surface or mass specific activity Measurement reference nuclides documentation Proposed clearance (type, volume) Clearance, or disposal as radioactive waste on-site storage authorised (conditional) release

Perspectives Scope Defining Levels Current situation and way forward

International No agreement on draft DS161 Concept of exclusion Lack of clarity on implementation demonstration of compliance? No guidance on (general) clearance levels De facto acceptance of EU levels (US, Japan, Russia,….)

European Union Exemption values uniformly transposed Exceptions: The Netherlands (lower value for Co-60) No barriers to place on the market Regulation of the use of materials? Revision of BSS? Lower exemption values (metal clearance levels?) Lower boundary? no practice shall be subject to… (general clearance levels?) “deliberate” addition to toys, ornaments?

International trade EU import restrictions? WTO: equal treatment Apply restrictions also to place on the market in the EU Similar to mushrooms-wild food products Commission Recommendation 2003/274/Euratom General clearance levels also for import Metals: subject to review of volumes

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