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

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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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)

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

10. 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)

11. 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

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

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

14. 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

15. 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

16. 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” ( )
Part 1: Guidance on General Clearance Levels for Practices
Part 2: Application of the Concepts of Clearance and Exemption to Natural Radiation Sources

17. 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

18. European regulatory framework and perspectives

19. 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

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

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

22. 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

23. 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

24. 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

25. 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

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

27. 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

28. 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

29. Perspectives Scope Defining Levels
Current situation and way forward

30. 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,….)

31. 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?

32. 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

33. My time is now over...!
Thank you very much !