1. Exemption, Clearance, Discharges
Luc Baekelandt
Safety of radioactive waste management facilities
Amman (Jordan), December 2014

2. Contents Concepts of exclusion, exemption, clearance
Exemption: criteria, derivation of levels
Clearance: criteria, derivation of levels
Discharges
Control of discharges
Summary
LB/ECD/Amman /01

3. Exclusion
Exemption
Clearance
LB/ECD/Amman /02

4. Relevant Safety Requirements
The concepts of exemption and clearance only apply to planned exposure situations.
Exemption shall not be granted to practices deemed not to be justified.
Exposure due to natural sources is generally considered as an existing exposure situation.
Schedule I deals with exemption and clearance specifically.
LB/ECD/Amman /03

5. Concepts of exclusion, exemption and clearance (1)
Authorized
discharge
Exclusion
Radiation
sources
Regulatory
control
Authorized
disposal
Sources and practices involving the exposure of people to ionizing radiation are normally controlled by a system of notification and authorization as exemplified in the IAEA Basic Safety Standards.
In general, prior to the use of radioactive materials, the operator is required to notify the Regulatory Body of his intentions and to apply for an authorization in the form of a registration or a licence. Such authorizations may include specific provisions to ensure that doses to members of the public are kept as low as reasonably achievable and below the appropriate dose limits and constraints.
However, specific sources and practices may be exempted from the system of control, if, based on an analysis of the health hazards involved, the Regulatory Body considers the inclusion of the respective sources or practices in this system to be unnecessary.
Similarly, sources, including substances, materials and objects, within authorized practices may be released from some regulatory requirements if the Regulatory Body considers that this is warranted. This process is known as ‘clearance’.
In addition to the concepts of exemption and clearance, the BSS also make use of the concept of exclusion to define the scope of the regulatory control system.
Note that the concepts of exemption and exclusion relate to the entry into the control system, while clearance relates to the exit of the regulatory control system.
Exemption
Clearance
LB/ECD/Amman /04

6. Concepts of exclusion, exemption and clearance (2)
(de minimis non curat lex)
exposure is essentially
unamenable to control
EXEMPTION
(de minimis non curat praetor)
CLEARANCE
exposure and risk
are trivial
The term ‘exclusion’ relates to exposures that are essentially unamenable to control: the IAEA-BSS state that “exposures deemed to be not amenable to control are excluded from the scope of the Standards”, e.g. exposure from K-40 in the body, exposure from cosmic radiation at the surface of the earth.
It must be noted that ‘excluded exposures’ are not necessarily trivial!
The term ‘exemption’ relates to practices and sources within practices which give rise to trivial exposure and risk.
The term ‘clearance’ relates to materials that are removed from regulatory control and whose further use gives rise to trivial exposures and risk.
In the past, the term “de minimis” was used instead of ‘exemption’. It was an abbreviation of the Latin expression ‘de minimis non curat praetor’. This term was used for the first time in the framework of the London (dumping) convention to define materials that must not be considered as radioactive for the purposes of the Convention.
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7. Exemption – general criteria
Radiation risks arising from the practice or from a source within a practice are sufficiently low as not to warrant regulatory control, with no appreciable likelihood of situations arising that could lead to a failure to meet this criterion.
Regulatory control of the practice or the source would yield no net benefit, in that no reasonable measures for regulatory control would achieve a worthwhile return in terms of reduction of individual doses or of health risks.
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8. Exemption – radiological criteria
Effective dose to be incurred by any individual owing to the exempt practice or the exempt source within the practice:
of the order of 10 µSv or less in a year
1 mSv in a year for low probability scenarios
LB/ECD/Amman /07

9. Derivation of Exemption Levels (1)
For moderate amounts (of the order of a tonne)
RP-65 was published in 1993, with exemption levels for a limited number of radionuclides.
The list of nuclides was completed in 1998.
At that time an additional radiological criterion of 1 man.Sv for the collective dose was used.
in terms of activity (Bq) and activity concentration (Bq/g)
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10. Activty Concentration (Bq/g)
Derivation of Exemption Levels (2)
Radionuclide
H-3
C-14
P-32
S-35
Co-60
Kr-85
Sr-90 +
Tc-99m
I-125
I-131
Cs-137 +
Ir-192
Ra-226
U-235
U-238
Pu-239
Am-241
Total activity
(Bq)
10 000
Activty Concentration (Bq/g)
10 000
1 000 10
100 1
For moderate amounts
Note: lowest values for alpa-emitters and for high-energy beta/gamma-emitters.
LB/ECD/Amman /09

11. Derivation of Exemption Levels (3)
For bulk amounts, solid material, artificial nuclides
Both documents were published in 2005.
in terms of activity concentration (Bq/g)
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12. Activity Concentration (Bq/g)
Derivation of Exemption Levels (4)
Radionuclide
H-3
C-14
P-32
S-35
Co-60
Kr-85
Sr-90 +
Tc-99m
I-125
I-131
Cs-137 +
Ir-192
Ra-226
U-235
U-238
Pu-239
Am-241
Activity Concentration (Bq/g)
100 1
1 000
0.1 - 10
For bulk amounts
Artificial nuclides
Solid material
Exemption levels for bulk amounts are not higher than those for moderate amounts.
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13. Derivation of Exemption Levels (5)
For bulk amounts of material with natural nuclides:
- case by case
- dose criterion of the order of 1 mSv in a year ( commensurate with typical doses due to natural background levels of radiation)
Note:
Material containing radionuclides of natural origin at an activity concentration of less than 1 Bq/g for any radionuclide in the uranium decay chain or the thorium decay chain and of less than 10 Bq/g for K-40 is not subject to the requirements for planned exposure situations. The concept of exemption does not apply for such material.
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14. Practical Application of Exemption
smoke detectors (Am-241)
use of Th and Kr-85 in high intensity gas discharge lamps
exhibition rooms (cloud chamber)
small scale laboratories
use of Th in soldering bolts
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15. Clearance – general criteria
Radiation risks arising from the cleared material are sufficiently low as not to warrant regulatory control, and there is no appreciable likelihood of occurrence for scenarios that could lead to a failure to meet this criterion.
Continued regulatory control of the material would yield no net benefit, in that no reasonable measures would achieve a worthwhile return in terms of reduction of individual doses or of health risks.
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16. Clearance – radiological criteria
Effective dose to be incurred by any individual owing to the cleared material:
of the order of 10 µSv or less in a year
1mSv in a year for low probability scenarios
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17. Derivation of Clearance Levels (1)
For solid material
in terms of activity concentration (Bq/g)
LB/ECD/Amman /16

18. Activity Concentration (Bq/g)
Derivation of Clearance Levels (2)
Radionuclide
H-3
C-14
P-32
S-35
Co-60
Kr-85
Sr-90 +
Tc-99m
I-125
I-131
Cs-137 +
Ir-192
Ra-226
U-235
U-238
Pu-239
Am-241
Activity Concentration (Bq/g)
100 1
1 000
0.1 - 10
Artificial nuclides
Solid material
LB/ECD/Amman /17

19. Derivation of Clearance Levels (3)
For radionuclides of natural origin:
- 10 Bq/g for K-40
- 1 Bq/g for each radionuclide in the uranium decay chain or the thorium decay chain
LB/ECD/Amman /18

20. Derivation of Clearance Levels (4)
For radionuclides of natural origin in residues that might be recycled into construction materials, or the disposal of which is liable to cause contamination of drinking water supplies:
on the basis of a dose criterion of the order of 1 mSv in a year ( commensurate with typical doses due to natural background levels of radiation)
LB/ECD/Amman /19

21. Practical Application of Clearance
storage of radioactive waste for decay
reduction of waste to be managed as radioactive waste (cost reduction)
guidance for decommissioning of nuclear installations
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22. Specific Clearance Levels
in case the destination of the cleared material is known, for instance recycling and re-use of material for road construction works
dose criteria are the same as those for the derivation of generic clearance levels
IAEA guidance available:
Application of Exemption Principles to the Recycle
and Reuse of Materials from Nuclear Facilities
(1992)
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23. Verification of Clearance Levels (1)
knowledge of the history of the material is very important
procedures to be integrated in the management system
monitoring
record keeping and reporting to the regulatory body
Deliberate dilution in order to meet the values is should not be permitted.
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24. Verification of Clearance Levels (2)
Relevant IAEA publication
published in 2012
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25. Discharges
Licences may include specific provisions to ensure that doses to members of the public are kept as low as reasonably achievable and below the appropriate dose limits and constraints, in particular by imposing discharge limits (for normal operation).
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26. Discharges
= planned and controlled releases of (usually gaseous and liquid ) radioactive material to the environment
(IAEA Safety Glossary)
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27. Relevant Safety Requirements
R 31 – The relevant parties shall ensure that radioactive waste and discharges of radioactive material to the environment are managed in accordance with the authorization.
R 32 – The regulatory body and relevant parties shall ensure that programmes for source monitoring are in place and that the results from the monitoring are recorded and made available.
relevant parties are the licensed operators
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28. Relevant Safety Guides
Published in 2000
Published in 2005
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29. Supporting Safety Reports
Published in 2001
Published in 2010
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30. GSR Part 3, requirement 31 (1)
The application for an authorization for discharges shall comprise information on:
the characteristics and activity of the material to be discharged, and the potential points and methods of discharge
the significant exposure pathways by which discharged radio- nuclides can deliver public exposure
the doses to the representative person due to the planned discharges
the environmental impact
(input to the establishment by the regulatory body of authorized limits on discharge and conditions for their implementation)
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31. GSR Part 3, requirement 31 (2)
Discharge Limits
established by the regulatory body (licence condition)
basis:
licence application (see previous slide)
dose constraint, which is a fraction of the dose limit for members of the public (takes account of other radiation sources, now and in the future)
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32. GSR Part 3, requirement 31 (3)
Registrants and licensees shall, as appropriate and in agreement with the regulatory body, review and adjust their discharge control measures, taking into account:
operating experience,
any changes in exposure pathways and the characteristics of the representative person that could affect the assessment of doses due to the discharges.
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33. GSR Part 3, requirement 32 (1)
Responsibilities of the Regulatory Body
Review and approval of monitoring programmes
Review of periodic reports on public exposure
Making provision for an independent monitoring programme
Assessment of the total exposure of the public from authorized sources and practices
Making provision for maintaining records (discharges, results of monitoring programmes, results of assessment of public exposure)
Verification of compliance with regulatory requirements
The regulatory body shall:
Review and approve monitoring programmes of licensees, which shall be sufficient:
- to ensure that the requirements regarding public exposure in planned exposure situations are satisfied, and
- to assess doses to the public;
Review periodic reports on public exposure (including results of monitoring programmes and dose assessments), submitted by licensees;
Make provision for an independent monitoring programme;
Assess the total exposure of public from authorized sources and practices in the country based on the monitoring data provided by licensees and with the use of the independent monitoring data and assessments, as appropriate.
Make provision for maintaining records of radioactive discharges, results of monitoring programmes, and results of assessment of public exposure;
Verify compliance of an authorized practice with requirements on control of public exposure.
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34. GSR Part 3, requirement 32 (2)
Responsibilities of the Operator
Establishment and implementation of a monitoring programme
Record keeping of results and estimated exposure
Reporting of results to the regulatory body
Reporting of discharges that exceed the limits
Reporting of external exposure levels that exceed the authorized limits
Reporting increase of dose rate or content of radionuclides in the environment
Establish and implement a monitoring programme to ensure that public exposure in relation to sources under his responsibility is adequately assessed, and sufficient to demonstrate compliance with the authorization. This programme shall include the following, as appropriate:
- external exposure from the sources;
- discharges;
- radioactivity in the environment;
- other parameters important for the assessment of public exposure.
Keep appropriate records of the results of the monitoring programmes and estimated exposures
Report, or make available, the results of the monitoring programme to the regulatory body at approved intervals, including, as applicable, the levels and composition of discharges, dose rates at the site boundary and in premises open to members of the public, results of environmental monitoring, results of retrospective assessments of doses to the representative person
Report promptly to the regulatory body any discharges exceeding the authorized limits of discharge in accordance with reporting criteria established by the regulatory body
Report promptly to the regulatory body any direct external exposure levels exceeding the authorized levels in accordance with reporting criteria established by the regulatory body
Report promptly to the regulatory body any significant increase in dose rate or content of radionuclides in the environment that could be attributed to their authorized practice in accordance with reporting criteria established by the regulatory body
LB/ECD/Amman /33

35. GSR Part 3, requirement 32 (3)
Responsibilities of the Operator (cont’d)
Establishment and maintenance of capability to carry out emergency monitoring
Verification of the adequacy of the assumptions made for the assessment of public exposure and environmental impact
Publication of results of environmental monitoring programmes and assessments of public exposure
Establish and maintain a capability to carry out emergency monitoring, in case of unexpected increases in radiation levels or content of radionuclides in the environment due to accidental or other unusual events attributed to his authorized source or facility
Verify the adequacy of the assumptions made for the assessment of public exposure and environmental impact
Publish or make available on request, as appropriate, results of source and environmental monitoring programmes and assessments of public exposure
LB/ECD/Amman /34

36. Safety Guide WS-G-2.3
Provides guidance to the regulatory body on a structured approach to the limitation of risk to members of the public and optimization of protection.
Provides guidance to the responsibilities of operators in conducting discharge operations
Provides guidance to the regulatory body on a structured approach to the limitation of risk to members of the public and optimization of protection.
+ guidance on the responsibilities of operators in conducting discharge operations
Published in 2000
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37. Safety Guide RS-G-1.8
Provides guidance on the strategy of monitoring in relation to the control of discharges and situations requiring intervention.
Three categories of monitoring are discussed:
- monitoring at the source (called “source monitoring”)
- monitoring in the environment (called “environmental monitoring”)
- monitoring of individual exposure (called “individual monitoring”)
Provides guidance on the strategy of monitoring in relation to the control of discharges and situations requiring intervention (such as nuclear or radiological emergency or the past contamination of areas with long-lived radionuclides).
Three categories of monitoring are discussed:
- monitoring at the source (called “source monitoring”)
- monitoring in the environment (called “environmental monitoring”)
- monitoring of individual exposure (called “individual monitoring”)
Published in 2005
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38. Summary Exclusion refers to scope of regulatory control
Exemption refers to practices and sources that give rise to trivial doses exempted from the regulatory control system
Clearance refers to material that gives rise to trivial doses and me removed from the regulatory control system
Discharges are authorized b y the regulatory body
Discharges are controlled (monitoring)
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39. Thank you!