ML20206S075
| ML20206S075 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1999 |
| From: | Meck R, Nelson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jim Hickey, Trottier C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| NUDOCS 9901280074 | |
| Download: ML20206S075 (50) | |
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' January 22, 1999 1 MEMORANDUM TO: John W. N. Hick;y, Chilf Low-Lov:1 Wist) cnd D: commissioning Projects Branch Division of Waste Management, NMSS i Cheryl A. Trottier, Chief Radiation Protection and Health Effects Branch Division of Regulatory Applications, RES FROM: Robert A. Nelson, Chief [0RIGINAL SIGNED BY:]
Low-Level Waste and Regulatory ;
Issues Section :
Low-Level Waste and Decommissioning l Projects Branch !
Division of Waste Management, NMSS Robert A. Meck, Senior Project Manager [0RIGINAL SIGNED BY:] )
Radiation Protec'. ion and Health l Effects Branch i Division of Regulatory Applications, RES l l
SUBJECT:
TRIP REPORT-INTERNATIONAL ATOMIC ENERGY AGENCY TECHNICAL COMMITTEE MEETING ON DRAFT SAFETY GUIDE NS33,
" PROVISIONS FOR OMISSIONS FROM THE REGULATORY CONTROL OF RADIATION: APPLICATION OF THE CONCEPTS OF EXCLUSION, /
EXEMPTION, AND CLEARANCE" On December 14 - 18,1998, Robert Nelson and Robert Meck attended the subject meeting in Vienna, Austria. The purpose of the meeting was to revise IAEA Safety Series No. 89,
" Principles for the Exemption of Radiation Sources and Practices from Regulatory Control," to
. include the concepts of exclusion and clearance and to expand the concept of exemption. A report of the trip is attached. I
Attachment:
As stated cc: Mary E. Clark, US EPA 8@ ~
CONTACT: R. Nelson, DWM/NMSS 311:415-7296 DISTRIBUTIONbl FM:LLDP r/f NMSS r/f RJohnson CPaperiello MVirgilio JGreeves JHilonich RH'auber DCool CJones JCraig PUBLIC i l S:\DWM\LLDP\RAN\lAEA-MEM.WPD; S:\DWM\LLDP\RAN\lAEA-RPT.WPD (ATTACHMENT) ;
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NAME RNekso /cv beck CTrottier Jhey DATE l /il /99 l / d /99 I/40/99 //J/99 OFFICIAL RECORD COPY ACNW: YES X NO _ Category: Proprietary _ or CF Only _
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,j L s* NUCLEAR REGULATORY COMMISSION
'C WASHINGTON, D.C. 2055tKm1 is
- January 22, 1999 <
MEMORANDUM TO:- John W. N. Hickey, Chief Low-Level Waste and Decommissioning Projects Branch Division of Waste Management, NMSS l
Cheryl A. Trottier, Chief )
i- Radiation Protection and Health l Effects Branch Division of Regulatory Applications, RES FROM: Robert A. Nelson, Chief .
Low-LevelWaste and Reg lator)/
Issues Section Low-Level Waste and Decommissioning Projects Branch -
Division of Waste Management, NMSS Robert A. Meck, Senior Project Manager Radiation Protection and Health Effects Branch Division of Regulatory Applications, RES l
SUBJECT:
TRIP REPORT-INTERNATIONAL ATOMIC ENERGY AGENCY TECHNICAL COMMITTEE MEETING ON DRAFT SAFETY GUIDE NS33,
- PROVISIONS FOR OMISSIONS FROM THE REGULATORY CONTROL OF RADIATION: APPLICATION OF THE CONCEPTS OF EXCLUSION, EXEMPTION, AND CLEARANCE" On December 14 - 18,1998, Robert Nelson and Robert Meck attended the subject meeting in Vienna, Austria. The purpose of the meeting was to revise IAEA Safety Series No. 89, l
" Principles for the Exemption of Radiation Sources and Practices from Regulatory Control," to include the concepts of exclusion and clearance and to expand the concept of exemption. A
. report of the trip is attached.
Attachment:
As stated l cc: Mary E. Clark, US EPA l
l CONTACT: R. Nelson, DWM/NMSS 301-415-7298 i
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/ TRIP REPORT DATES: ' December 14 - 18,1998 PLACE: International Atomic Energy Agency (IAEA) I Vienna International Center Vienna, Austria ,
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SUBJECT:
TECHNICAL COMMITTEE MEETING ON DRAFT SAFETY GUIDE NS33, j
" PROVISIONS FOR OMISSIONS FROM THE REGULATORY CONTROL OF RADIATION: APPLICATION OF THE CONCEPTS OF EXCLUSION, i EXEMPTION, AND CLEARANCE" l PARTICIPANTS :
FROM U.S.: Mary E. Clark, EPA l Robert A. Meck, NRC Robert A. Nelson, NRC :
PERSONS CONTACTED: See Attachment A i l
PURPOSE: To revise Safety Series No. 89, " Principles for the Exemption of Radiation Sources and Practices from Regulatory Control," to include the concepts ,
of exclusion and clearance and to expand the concept of exemption. The revision would be constrained by definitions and principles established in >
the IAEA Basic Safety Standards (BSS).
l DISCUSSION: l l
Note: The usage of the terms exclusion, exemption, clearance, and authorized use, within the '
context of the BSS and this safety guide, is explained in Attachment B to this report.
a Summarv of Proceedinas 1
- 1. After brief introductory remarks by Z. Domaratski, Deputy Director General, Department of Nuclear Safety, end L. Baekelandt, the Session Chairman, Messrs. Linsley and Mason provided general information, background information on the development of the draft safety guide, and a summary of the content of the draft document. In addition, a list of I preliminary issues was presented. However, this list was not used as a basis for further discussion. The first day concluded with presentations on the following topics by the contributing authors of the draft guide. A copy of the draft guide is provided as .l' Attachment C for reference.
+ Concepts and terminology
- Application of the exclusion concept Clarification of terms (e.g., clearance and authorized use)
.' ATTACHMENT i l
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t How to accommodate naturally-occurring radioactive material (NORM)
Exemption in intervention situations Copies of the briefing materials were not made available.
Other planned documents in this area include:
A Safety Guide on " Management of the Removal of Control of Materials from Regulated Activities"(a revision to IAEA-TECDOC-855)
A Safety Report on experiences with the clearance concept.
At the conclusion of the first day's meeting, the chairman announced that he planned to hold a section-by-section review of the draft guide during the second day.
After the conclusion of the first day's meeting, the U.S. participants caucused to develop a list of issues and comments that should be raised in the upcoming deliberations.
- 2. As planned, the second day opened with a discussion of the draft document. Section 1 of the draft guide was incomplete. Notably, the objectives and scope subsections had not been drafted. U.S. Nuclear Regulatory Commission (NRC) staff questioned the scope and a protracted discussion ensued which was focused on NORM in relation to exclusion and exemption. As a result of this discussion, the chairman proposed supplementary notes on the basic concepts of exclusion, exemption, and clearance.
These notes formed the basis for the afternoon's discussion. The group appeared to reach consensus on the guide's application to NORM as follows.
NORM in unmodified concentrations in most raw materials: apply the exclusion concept The processing of NORM is considered to be a practice (not unamenable to control) that:
a Can be exempted on the basis of trivial doses / risk or on the basis of optimization; and b can be regulated; in that case, a graded approach is to be applied Clearance applies only to material within a regulated practice.
The South African delegation was particularly concerned about the application of the safety guide to NORM "in unmodified concentrations" and their mining operations.
An extended discussion of exclusion then took place, which focused on the meaning of
" essentially unamenable to control" as used in the definition of exclusion in the BSS. The second day ended with the chairman's proposal to revise his notes on exclusion. These revised notes would form the basis for discussions the following day.
Contrary to the original plan to conduct a section-by-section review, the second day's agenda consisted of a discussion of the basic concepts of exclusion, exemption, and, to a lesser extent, clearance, with no clear consensus obtained.
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- 3. A discussion of the chairman's new proposal regarding exclusion, exemption, and clearance dorninated the agenda for the morning of the third day. After extensive discussion, the participants generally agreed with the principles and criteria for exclusion and exemption, as presented in subsections 3.2 and 3.3 and subsections 4.5 - 4.7 l respectively of the draft guide.
The chairman divided the participants into three working groups, one group for each of the concepts of exclusion, exemption, and clearance. The chairman's direction (terms of ,
reference for the working groups) is provided as Attachment D. Robert Meck, NRC 1 Office of Nuclear Regulatory Research (RES), served as the leader for the exemption working group. Mary Clark, U.S. Environmental Protection Agency, participated in the exclusion group, and Robert Nelson, NRC Office of Nuclear Material Safety and Safeguards, participated in the clearance group.
- 4. The plenary session reconvened on Thursday morning with brief presentations by each working group leader. The progress of the groups was mixed. After the brief plenary session, the working groups reconvened to complete the chairman's tasking. j 1
The plenary session remnvened late Thursday afternoon and the working group results for the test cases were :sented. For the vast majority of the test cases, the working group results were in general agreement concerning the means by which the test case could be removed from regulatory control.
- 5. The plenary meeting continued on Friday with each working group leader presenting and discussing the revised decision chart and discussing significant issues raised in the review of the text of the draft guide.
The chairman concluded the meeting by noting that the draft document was in good condition but needed further guidance on:
Exemption in intervention situations i Post-cleanup situations Applications to situations involving NORM How to apply the principles of optimization to exemption.
I The chair reported that the next revision (draft 5) to the safety guide should be completed in three months at which time it would be forwarded to the advisory committees and then distributed to the member states for comment.
B. Comments and Observations l
- 1. The meeting was widely attended with representatives from most of the western European countries, Australia, Canada, Israel, Japan, Russia, the S!ovak Republic, South Africa, the European Commission, the International Labour Office, and the Nuclear Energy Agency. The large number of participants was far more than expected by the chairman and contributed to the initial slow pace of the proceedings.
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- 2. The discussions could have been more organized had a consensu0 list of issues been developed and used to guide the discussions. As noted above, a list of issues was presented in the introductory briefings but it was never revisited.
- 3. As noted on the second day, the scope of the guide was not included in the draft and the scope was never clearly established during the meeting. This created confusion for the !
clearance working group. The title of the document would lead one to conclude that the l
guide was limited to exclusion, exemption, and clearance. However, during the clearance working group discussions, it was explained by an IAEA staff member that the document was intended to address all approaches to removing material from regulatory control. This would include authorized disposal (as contrasted to regulated disposal) and release after rehabilitation (e.g., decontamination and decommissioning). The draft guide does not address these processes in any depth and this deficiency was reported to the plenary session.
- 4. The working group on clearance also agreed that trivial doses need not be the required l end point for authorized disposal and rehabilitation. The NRC representative on the I
working group used NRC's license termination rule as an example. This comment was reported to the plenary session.
l 5. The definitions for exclusion, exemption, and clearance in the draft safety guide have l been extracted from the BSS and changes to these definitions were not within the scope of this guide. However, the clearance working group discussed the need for a collective dose limit (i.e.,1 person-Sv) for clearance. The group recommended to the plenary l
session that the regulatory authority be allowed flexibility to establish an individual dose limit that would preclude the need for a collective dose analysis.
l 6. The participants were highly interested in the research on individual dose conversion i factors currently being finalized by RES. NRC participants committed to forward copies of the report to IAEA staff as well as other interested participants. Given that IAEA plans to begin a revision to TECDOC-855 early in 1999, the release of the NRC research report is very timely.
C. Related Future Meetinas
- 1. Meeting among lAEA and U.S. DOE, EPA and NRC in Washington, DC, in January or February 1999 on c!ean-up standards 4
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- 2. Consultants' meeting (invited by lAEA) to revise TECDOC-855 on clearance levels in Vienna, Austria,in March 1999.
ATTACHMENTS:
' A. List of Attendees B. Usage of Terms C. Draft Safety Guide
. D.= Terms of Reference for Working Groups i
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.g, l INTERNATIONAL ATOMIC ENERGY AGENCY !
l Department of Nuclear Safety !
Issue No.5: 1998 12-16 i NO TIFICA TION OF AN A GENC)*-SPONSORED AfEETING i Title of meeting: I l TCM to prepare a Safety Guide on the scope of radiation protection requirements i (application of the concepts of exclusion and exemption). '
Date of meeting: 14-18 December 1998 Scientific Secretaries: i l (Meetmg starts at 09:30 hrs) Gordon Linsley, B0719. x22666 E-mail: G.Linsley@iaea.org l Anthony Wrixon, B0770. x22721 l E-mail: A.Wrixon@iaea.org l Place of meeting: Room I, CO2 j (Ext: 461i) Secretary: .
Ms. Nerri Barrios, B0717. Ext. 22702 Meeting No.: 721-J 1.TC.1076 E-mail: N. Barrios @iaea.org l Conference Clerk:
i Ms. Eva Erdei PARTICilMNTS ADDRESS PERIOD i
l; AUSTRALIA l Mr. Brian llOLLAND Australian Nuclear Science 14-18 Dec. !
& Technology Organisation Safety Division New lilawarra Road Lucas lleights NSW 2234 Australia Tel.: +00612 9717 3542 Fax: +00612 9717 9266 l
+00612 9717 3162 e-mail: bhx%ansto. gov.au Mr. Ches MASON Australian Radiation Laboratory Lower Plenty Road n Yallambie Victoria 3085 l
Australia Tel.: +00613 9433 2260 Fax: +00613 94321835 e-mail: ches.masongi1EALTil. GOV.AU l
l ATTACHMENT A L .. - . .. .. - - . .
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BELGIUS1 Mr. Luc BAEKELANDT NlriAS ONDRAF Place Madou 1/25 l
1210 Brussels 1 Tel.: -0032 2 212 1073 Fax: +0032 2 218 5165 e-mail: 1.baekelandt? nirond.be hir. Pascal Di BOODT Physique Head ofIlealth Physics Department CEN/SCK Mol Belgium Tel.: +003214 3328 53 Fax: +003214 3216 24 e-mail: pdeboodt%sckcen.be ,
i Mr. Gilbert EGGERMONT CEN/SCK Mol SCK/CEN Head Office Av. H. Delroux 40 B-1160 Brussels Tel.: +0032 2 661 1983 Fax: +0032 2 661 1958 e-mail: geggermoysckcen.be Mr. Yves NIELS Assistant Waste Manager IRE Institut des radiodidrnents Fleurus, Belgium Tel: +0032 7182 92 98 Fax: +0032 7182 93 98 CANADA Mr. Norman E. GENTNER Health. Chemistry & Environment Atomic Energy of Canada Limited
('halk River Laboratories
('halk River Ontario K0 IJO l Canada Tel.: 4001613 584 331 I ext. 4723 Fax: +001613 5841896 e-mail: gentnern daect ca Mr. Bertrand THERIAULT Atomic Energy Control Board P.O. Box 1046. Station "B" 280 Stater St., Ottawa, Ontario Tel: (613)992-8800 Fax: (613) 995-5086 ;
i email: theriault.bgatomeon.gc.ca 2
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/ FRANCE 1 l Mr. Olivier BRIGAUD
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l DSIN Route du Panorama Schumann BP 83 92266 Fontenay aux Roses Cedex Tel: 3314319 70 01 '
Fax: 3314319 7166 1 t
Email: olivier.brigaud ij industrie.gouv.fr Mr. Philippe llARTMANN EDF-Service de Radioprotection 3, rue de Messine 75384 Paris. Cedex 08 I
France Tel.: +0033144951781 Fax: +0033144951790 e-mail: philippe.hartmann%edf.fr Ms. Agnbsif00RELBEKE CIREA B.P.no.90 92263 Fontenay aux Roses, Cedex I France Tel.: 40033 1 4654 7979 Fax: 40033 1 4654 9536 i
Mr. Jean PIECllOWSKI IPSN/DPilD CEA - B.P. no. 6 92265 Fontenay aux Roses, Cedex France l Tel.: +003314654 8817 l l Fax: +003314654 4610 l GERMANY l Mr. Stefan T HIERFELDT Brenk_Systemplanung Ileider-liof-Weg 23 ;
l D-52080 Aachen Germany j Tel.: +0049 2405 465126 Fax: +0049 2405 465150 e-mail: brenk systemplanung@ t-online.de j I
l Mr. Gnnther SCllALLER Bundesamt flir Strahlenschutz
( Fachgeb. S 3.5 l Ingolstudter Landstrasse 1 l D-85764 Oberschleissheim Germany Tel.: +0049 89 31603115 Fax: +0049 89 31603111 e-mail: gschallerg bfs.de 3
IRELAND Mr. David FENTON Radiological Protection Institute ofIreland 3 Clonskeagh Square Clon3keagh Road Dublin 14 Ireland Tel.: +003531269 7766 Fax: +0035312605797 e-mail: davef@rpii.ie ISRAEL Mr. T. SCIILESINGER llead,llealth Physics Domain Soreg Nuclear Research Centre Yavneh, Israel 81800 Tel.: +00972 8 9434 794 Fax: +00972 8 9434 696 e-mail: tuviaRnde.soreq. gov.il Mr. E. STERN israeli Atomic Energy Commission 26, Rehov Chaim Levanon P.O. Box 7061 61070 Tel -Aviv Israel Tel.: -00972 3 646 2963 Fax: +00972 3 646 2539 e-mail:
ITALY Mr. Luciano BOLOGNA Departmem of Nuclear and Radiological Risk Agenzia Nazionale per la Protezione Dell'Ambiente ANPA Via Vitaliano Brancati 48 00144 Rome Italy Tel.: +00390 6 5007 2806 Fax: 400390 6 5007 2941 e-mail: bologna'sanpa.it Mr. Enrico SGRILLI Depanment of Nuclear and Radiological Risk Agenzia Nazionale per la Protezione Dell'Ambiente ANPA Via Vitaliana Brancati,48 00144 Rome Italy Tel.: +00390 6 5007 2850 Fax: +00390 6 5007 2941 email: sgrilliganpa.it a
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.lAPAN N1r. I tideaki YANIAMOTO Deputy General Manager Radiation Control Division 1 Department ofllealth Physics fokai Research Establishment !
Japan Atomic Energy Research Institute 2-4 Shirakata. Tokai-mura Naka-gun. Ibaraki 319-1195 Japan )
Tel.: 40081 29 282 6324 l Fax: +008129 282 6063 l e-mail: yamaei@ popsvr.tokai.jaeri.go.jp RUSSIAN FEDERATION Mr. Leonid SOUKilANOV All-Russia Scientific and Research Institute fbr Inorganic Materials Rogov str. 5 P.O. Box 369 RU-123060 Moscow Russian Federation Tel.: +007 095190 62 26 Fax.: +007 0951964 252 e-mail: ERA'ilmape.msk.su SLOVAK REPUBLIC Mr.Vladimir JURINA Ministry of Health SR Limbord 2 83105 Bratislava Slovak Republic Tel.: +004217 547 88215 Fax: +004217 547 76142 e-mail: vladimir.jurinag health. gov.sk SOUTil AFRICA Mr. Kim IlODIERNE Manager. Zirconia Business Unit FOSKOR P.O. Box 1. Phalaborwa 1390 South Africa Tel: +2715 798 2346 Fax: +2715 798 2463 Email: zirc@ nix.co.za 5
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Mr. Dennis WYMER Chamber of Mines !
P.O. Box 61809 Marshalltown 2107 South Africa Tel: +2711498 7335 Fax: +2711498 7429 Email: du3 mer a bullion.org.za Mr. Sietse VAN DER WOUDE Council lbr Nuclear Safety P.O. Box 7106 Centurion 0046 South Africa Tel: +2712 6635500 Fax: +2712 663 5513 Email: standerwffens.co.za SPAIN Mr. David CANCIO CIEMAT Environmental Radiological Impact Avenida Complutense 22 Madrid. Spain Tel: +34 (91) 346-6628 Fax: +34 (91) 346-6121 email: cancioeciemat.es SWEDEN Mr. Magnus WESTERLIND Swedish Radiation Protection Institute S-171 16 Stockholm Sweden Tel.: +0046 8 729 7100 Fax: +0046 8 729 7108 e-mail: magnus.westerlindW.ssi.se
( Also as Observer for the International Commission on Radiological Protection)
SWITZERLAND Mr. J. IlAMMER Swiss Federal Nuclear Safety inspectorate Cll-5232 Villigen HSK Tel.: +4156 310 39 54 Fax: +4156 310 39 07 e-mail: hammerQ hsk. psi.ch UNITED KINGDOM Mr. John COOPER National Radiological Protection Board Chilton. Didcot. Oxon OX11 ORQ United Kingdom Tel.: +00441235 831600 Fax: +00441235 833 891 l' e-mail: john.coopergnrpb.org.uk 6
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Mr. lain DEVINE BNFL Magnox Generation Berkeley Centre Berkeley. Gloucestershire GLl3 9PB Iel: -00441453 SI3496 Fax: -0044 1453 813463 Email: irderine2ilmagnox.co.uk Mr. Chris WILSON Radioactive Substances Division Department of the Environment i Transport and the Regions ;
4'F7 Ashdown flouse 123 Victoria Street London. SWlE 6DE Tel.: +0044171890 6273 i Fax: !
+0044171890 6289 e-mail: chriswilson $compuserve.com l UNITED STATES OF AMERICA ;
Ms. Mary E. CLARK Assistant Officer Director U.S. Environmental Protection Agency Office of Radiation and Indoor Air MC 660lj Washington. DC 20460 Tel: 001202 564 9348 Fax: 001202 565 2043 Email: clark.maryegepa. gov Mr. Robert NELSON Chief LLW and Reg. Issues Section US Nuclear Regulatory Commission Mail Stop T7F27 11555 Rockville Pike, Rockville MD 20852 - 0001 United States of Ametica Tel.: +001301415 7298 Fax: +001301415 5398 e-mail: ranii nre. gov Mr. Robert A. MECK U.S. Nuclear Regulatory Commission Mail Stop '19C24 11555 Rockville Pike Rockville. MD 20852 Tel: (301) 415 5389 Fax:(301)4155385 email: ram 2%nrc. gov 7
1 El'ROPEAN COMMISSION Mr. Augustin JANSSENS Directorate General XI Environment. Nuclear Safety and Civil Protection Directorate U XI.C.) - Radiation Protection Plateau du Kirchberg .
L-2920 Luxembourg Oflice: WAG C/353 Tel.: +00352 430136395 Fax: -00352 4301 36280 e-mail: augustin.janssens7f dgl 1. cec.be INTERNATIONAL LAllOUR OFFICE i
Mr. Shengli NIU Occupational Safety and llealth Branch I Intemational Labour Office (ILO) ;
4, route des Morillons l
Cil-1211 Geneve 22 SWITZERLAND Tel.: +004122 7996 708 Fax: +004122 7996 878 i e-mail: niuliilo.ch i
Mr. Paul FOSTER Adviser. Occupational Safety and IIcalth Branch i' Radiation Protection International Labour Oflice 46 Caesar Close Roman Way, Andover 1lants SP10 5JR Tel.: +00441264 361862 Fax: +00441264 361862 e-mail: foster 1iilo.ch NUCLEAR ENERGY AGENCY (OECD/NEA)
Mr. Shankar MENON Menon Consulting AB Fruungsgatan 25 F S-61130 Nyk6 ping Tel: +46155 2106 97 Fax: +46155 21 16 90 Email: shankar.menong menon-consulting.se 8
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~ Mr. Anthony Wrixon llead, Radiation Safety Section Room B0770: Ext. 22721 Mr. Dominique Delattie Waste Safety Section Room B0701, Ext. 22009 i i
Mr. Dennis Reisenweaver . Waste Safety Section l Room B0715; Ext. 22852 l
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t USAGE OF TERMS l
" Exclusion" refers to exposures to ionizing radiations that regulations do not address, because they are unamenable to control.
" Exemption" implies that a human activity that uses a radioactive source or exposure has been considered by competent regulatory authorities to be justified and of small enough risk to be allowed without further regulation.
" Clearance" refers to materials or equipment that have been under radiological control and are released from further radiological controls on the basis that the potential doses are trivial.
" Authorized Use" applies to the introduction of materials, equipment, lands, or structures into the general commerce without further radiological controls, in cases where the potential doses are greater than trivial.
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Attachment B 1 I
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-IAEA SAFETY STANDARDS SERIES PROVISION FOR OMISSIONS FROM THE REGULA TORl' CONTROL OF RADIA TION:
APPLICA TION OF THE CONCEPTS OF EXCLUSION, EXEMPTION AND CLEARANCE DRAFT SAFETY GUIDE li'ORKING ID NS33 INTERNATIONAL ATOMIC ENERGY AGENCY VIENNA DRAFT 4 - 26 October 1998 ATTACHMENT C
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Draft Saferv Gmde l'rouston for Omissions fne the Regulators Corstrol of Radiahon Apphcatsm of the Concepts of E ulusion, I semphon and Clearance
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2 DRAIT 4 Ches Mason /1998-10-26
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- thaft 11/cn Gwde Prostsion for Omisarons from the Regulatory Contr.il of Radiation Apphcation of the Concepts ofI scluwm iTempt <qi and Ulcarance CONTENTS l 1
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DRAIT 4 - Ches Mason'1998-10-26 3
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Draft Safcri Guide Provmon for Omiwne from the Regulatat3 Control of Radiation Appbcation of the Concers , of ih'lusion. I semption and Clearance
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Draft Lfer, Gmde Prm mon for t pmmiom from the Rerut.itors Control of Radiauon Appheauon of the Concepts 011 Acluuon. I semptnin and Clearanse r
- 1. INTitODUCTION -
BACKGROUND 1.1. The International Basic Safety Standards for Protection against Ionizing Radiation and fbr the Safety of Radiation Sources' (BSS) lays out in a regulatory style a comprehensive set of requirements which must be met to ensure that human activities which insolve, or may involve. exposure to radiation are conducted safely. For many such activities there is universal agreement that regulation is required, but in circumstances where the anticipated exposures to radiation are very low or where no effective regulatory instruments can be applied, regulation may not be justified because its cost would exceed any cm <>quential benefit. The purpose of this Sa/ety Guide is to clarify the distinction between activities which require regulation and those that need not and to provide guidance on how to meet the relevant requirements of the BSS. It is both a revision and an extension of Safety Series No.89: ' Principles for the Exemption of Radiation Sources and Practices from Regidatory Control' 1.2. Over the years. a considerable literature has evolved on establishing the criteria for application or relinquishment of regulatory controls and many terms and phrases have been employed therein, such as: ' exemption'. ' clearance', ' exclusion', ' release', ' discharge', and
'below regulatory concern'. These terms have not always been used consistently by different 1
authors or organizations. One of the essential purposes of this Safety Guide, therefore, is to clarify its use of relevant technical terms and the concepts to which they refer. It is hoped that this may promote, in time, an international consensus on terminology and a consistent usage.
OBJECTIVE i
1.3.
SCOPE STRUCTUIE DRMT 4. Ches Mason 1998-10-26 $
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- l ora un %.& nomn,n er o,mssionoroin o,e necen n,nu ,
ol R3131b,fi Application ot'aic ( <intepis of I witnion.1 seriiption anill lcarans e l l
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- 2. CONCEPTS AND TERMINOLOGY j l
l OMISSION FROM REGUI.AT ORY CONTROL.
2.1. The Basic Safety Standards establish basic requirements for protection against the risks l associated with exposure to ionizing radiation. Radiation occurs everywhere in the environment.
and radiation which cannot be attributed to current human activities is known as background l
radiation. Human activities that add radiation exposure to that which people normally incur due to background radiation. or that increase the likelihood of their inemring exposure, are termed .
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' practices' in the Standards. Human activities that seek to reduce existing radiation exposure. I which is not part of a controlled practice, or the existing likelihood of incurring exposuce, are termed ' interventions'. The Basic Safety Standards provide the basis for a regulatory system for the control of radiation: one part of the system applies to practices. another to interventions. I 2.2. One purpose of a regulatory system is to ensure appropriate implementation of the Standards. Some practices require a greater degree of regulatory control than others in order to achieve an appropriate level of protection. that is to keep the increase in exposure within acceptable bounds. Some situations of existing radiation exposure require more extensive I intervention action than others in order to reduce doses to an acceptable level. In both cases, regulatory effort should be tailored to the circumstances by focussing on areas uhere real benefits can be obtained.
2.3. In some cases, practices and pos;ible intervention situations may be omitted from regulatory control. The full regulatory system does not need to be applied to practices that give rise to radiological risks that are not of regulatory concem. Similarly, it is clearly not efficient or desirable for the scope of regulations to cover situations of existing exposure where it would be impracticable to reduce doses. There are two regulatory concepts and related procedures for deciding when the requirements of the Standards need not be applied: ' exclusion' and
' exemption'. These tenns are concerned with leaving things outside the requirements of regulations; that is. with not bringing them under regulatory control. A further term ' clearance'
- is closely related to exemption and is concerned with releasing things from regulatory control.
These concepts are explained below.
INTERVENTION AND EXCl.USION 2A. Interventions are actions intended to reduce or avert exposure, or the likelihood of exposure, to sources that are not part of a practice or which are out of control as a consequence of an accident. However, some exposures to radiation are part of the natural human
(, DRV I 4 - Ches Wwn'1998-10-26
~
cs i Draft Listn Gwdc Pnwmon for Onmsums from the Repubton ( ontrol uf Radiatum Appinatmn of the ( oncept, of I xduuon i sempmm and t learan.c l
l l .
l l environment and it is not practicable to reduce them. Examples include exposures from cosmic l radiation at the earth's surface and exposures from potassium-40 in the body. Exposures of this l kind are regarded as unavoidable and. most importantly, it is usually not practicable to control )
them through regulation. The deliberate omission by a Regulatorv Authority of a particular category of exposures (including potential exposures) from regulatory control on the grounds that they are not considered amenable to control through regulation is called exclusion in the j Standards. Such exposures are called excluded exposures. (
)
2.5. People may receive exposures from several different sources, both natural and man-made. The regulatory system may need to be applied differently to each component of exposure. l Figure 2 Section 3, provides guidance on deciding whether a component of exposure should be: l
. excluded from the requirements of the standards, e treated as arising from a practice, or i e dealt with by applying the requirements for intervention.
2.6. If the exposure is being caused by a current human activity that lies within legal jurisdiction, in such a way that it adds to the exposure that would othenvise have been received.
it should be dealt with as arising from a practice. That is, regulatory controls should be applied to the practice that causes it. Note that inhabiting the natural environment is not considered a l practice, so that, for example, moving from a region of low natural background radiation to a higher background area is not a practice. Building dwellings and living in them are not considered to be practices. [Ilowever. new buildings should be constructed to ensure that relevant action levels are not exceeded (see below).]
2.7. If the exposure is not treated as arising from a practice, it may be excluded from regulatory requirements or dealt with by intervention. This is the case, for example, when the exposure already exists at the time of deciding how to apply the Standards and cannot be attributed to an identinable practice. Such exposures are called ' chronic' exposures and are characterized by persisting in time without being maintained by human action. The key to determining whether a component of exposure may be excluded is whether or not it is amenable to control. if there are no reasonably practical means of reducing it, such that any regulatory requirements would be pointless, it may be excluded from the regulatory system. The component of exposure arising from cosmic rays at the earth's surface is excluded, for example, as is the component arising from potassium-40 in the body.
2.8. Chronic exposures that are amenable to control should be dealt with by applying the requirements for intervention. The borderline between what may be regarded as amenable to control and what is not is not clear cut. There will be cases in which it may be physically possible to reduce exposures, but to require such reduction through regulation would be DRAl"r 4 - Ches Mason 1998-10-26 7
s.
~
Draft .W/cn Gmde Prouston tar Omnwms imm the Regulatan t ontrol of Radialian Apphtation et the t onocpb of I ulusmn I semptun and Clearance impractical or cause unreasonable costs. A practical way to clarify.the regulatory position in I
such circumstances is to make use of action levels. An action level is the value of a specified measurable quantity above which a specified action should be taken. Most commonly the temi ,
is used to mean a level of dose rate or actisity concentration above which remedial actions or l protective actions should be carried out. Action levels are specified in the Standards for protection against radon exposure, for example. 1 urther guidance on dealing with chronic exposures and intervention is given in the Safety Guide xxxxx.
2.9. Exposures below the action level are nonnally excluded from the requirements of the Standards. In the case of occupational exposure to radon, for example, if the exposure is incidental to the work, the exposure is excluded provided it is below the appropriate action level.
In the case of public exposure, in circumstances where action levels have been exceeded and where optimized intervention measures have been taken to reduce doses, the residual exposures which remain after the intervention has tenninated are excluded from further requirements of the 1
Standards. l l
l 1
i PRACTICES AND EXEMPTION :
i 2.10. Some practices cause greater exposmes than others. Clearly, there is some point towards the lower end of the spectrum of doses caused by practices below which it makes no sense to apply regulatory requirements. The cost of regulation would exceed any benefit from a marginal reduction in doses. The point at which practices, or sources within practices, could be left outside the regulatory requirements, through ' exemption', corresponds to a level of radiation risk that is considered trivial.
Trivial doses .
2.11. One approach to establishing a level of radiation risk that is 'sufficiently low as to be of no regulatory concem' is to develop the concept of trivial risk. This approach was followed in the previous Agency guidance on this topic (SS89). There appears to be agreement amongst many authors that, in considering a particular practice as a candidate for exemption, it is appropriate to apply the concept of trivial level of risk, or dose, in a purely individual-related assessment. That is, very small doses and the corresponding minute risks should not be of any concern for the individual or for the regulator (Ref SS89, RP65).
2.12. There are two main approaches that can be considered when deciding whether a level of dose or risk is triviah firstly, choose a level of risk, and the co Tesponding dose, which is of no g DRAI 14 - Ches Mason'1998-10-26
C,~
- Drall Lfra Gwde Promum for Ommions from the Regulaton ( ontn.1 l of Radialmn Apphtanon of the concept < et I ulowm. hen: phon and Clearance J significance to individuals; secondly, use the exposure to natural background, to the extent that it is normal and unavoidable, as a relevant reference level.
l 2.13. In the first case, it is widely recognised that values ofindisidual risk which can be treated as insignificant by the decision maker correspond to a level at which indisiduals who are aware ;
of the risks they run would not commit significant resources of their own to reduce these risks.
It is likely that few people would commit their own resources to reduce an annual level of risk of ,
death of 10"' and levels at risk below this are held to be trivial (refs to substantiate this l statement). Taking an annual level of risk of death which is held to be of no concern to the !
4 #
individualof10 to 10 and a rounded risk factor for fatal cancer fbr the general population of 5 ,
x 10-2 gy-i, the level of trivial effective dose would be in the range 20 pSv to 2 pSv.
2.14. In the second case, natural background radiation has been estimated to give, on average, l
an individual dose of about 2 mSv per year (ref UNSCEAR). This average conceals wide j variations, with annual doses up to a factor of at least ten higher depending upon the location.
Individual members of the public do not generally take account of the radiation exposure to natural background radiation when considering moving from one part of a country to another, or when going on holiday. Thus. a level of dose that is small in comparison with the variation in natural background can be regarded as trivial. A level of efTective dose of the order of a few i percent of natural background, i.e.20-100 pSv per year, has been suggested (ref SS89).
2.15. Taking these considerations together, a level of individual radiation dose, regardless of origin, is likely to be regarded as trivial ifit is of the order of 10 pSv per year or less. This level of dose corresponds to 1% of the annual dose limit for members of the public given in the Standards.
Exemption 2.16. Practices or sources within practices may be exempted from the requirements of the Standards, with the exception of the requirement for justification, provided the Regulatory Authority is satisfied that the practices or sources meet the principles and criteria for exemption specified in the Standards. Maintaining the requirement for justification is important; exemption should not be used to allow unwarranted or frivolous use of radionuclides or radiation sources.
Furthermore, the fact that an exempt practice or source nevertheless has to be justified means l that it is wsthin regulatory pursiew. He exemption is from the procedural aspects of regulatory control.
2.17. The general principles for exemption provided by the Standards are given in Paragraph 4.5 and the corresponding criteria for exemption without funher consideration are DRAI T 4 - Ches Mason 1998426 9
Diatt u n 6mde housun for (inuwens tom the Perulatan Connel of Radiation Apriscation of the concepts et I tu luonn. I semption and ( Icarante )
given in Paragraph 4.6. The Standards include, in Schedule 1, levels of activity and activity concentration such that sources at or below such lesels - or practices using only such sources -
can be granted exemption without further consideration. These levels are called exemption levels and were derived using the criteria described above by modelling a number of possibR exposure scenarios, using conservative assumptions. Ihey are appropriate for moderate quantities of radioactive material and allow the Regulatory Authority to simplify decision making in the majority of cases. For bulk quantities of material, the Regulatory Authority may need to take further considerations into account before granting an exemption. Figure 3. Section 4 gives guidance on deciding when a practice, or source within a practice, may be exempted from the requirements of the Standards.
2.18. In certain circumstances, other considerations could be taken into account in deciding whether to exempt a practice or source within a practice, such as whether any reasonable control procedures can achieve a significant improvement in radiation protection (ICRP60). The fact that a practice just fails to meet the criteria for exemption without further consideration does not necessarily mean that all aspects of the regulMory system should be imposed. The Regulatory Authority may be satisfied that the general principles for exemption are satisfied and that exemption, or some measure of exemption, is the optimum regulatory option. The degree of imposition of regulatory requirements should be linked to the anticipated benefits in radiological protection terms. Thus, in cases where the Regulatory Authority is confident that radiation protection is optimized, including compliance with any relevant dose constraints, and that specific regulatory requirements would not achieve any improvement in protection, and that there is little likelihood that these circumstances could change, it could grant exemption from those requirements of the Standards.
PRACTICES AND CLEARANCE 2.19. Sources, including substances, materials and objects, within notified or authorized practices may be released from further requirements of the Standards, subject to complying with clearance levels approved by the Regulatory Authority. A clearance level is a level of activity or activity concentration such that materials at or below such levels can be granted clearance. The clearance concept is different from the exemption concept, since the materials subject to clearance are already under regulatory control until the Regulatory Authority clears them. It is the responsibility of the Regulatory Authority to establish requirements for clearance and to verify compliance with the requirements.
2.20. Cleared sources and materials have no further regulatory controls applying to them; they are outside the regulatory system. Thus, the doses or risks associated with the subsequent use or 10 DRAI T 4 - Ches Masore199R.1046
-. - .. I
l O.
[) raft L/cr> Gmde Prousam for ommum from the Rtrulaton Control of Radiatum Appbcation of the ConcerS ofI ulusum liemrtion anJ t kmanse disposal of the materials should be sufficiently low as to be of no regulatory concem. which in this context is taken to mean that they should be trisial (cf. Para. 2.1 D. In this sense, clearance is the inverse of exemption. It follows that clearance lesels should take account of the exemption criteria specified in the Standards. and that for moderate quantities of material clearance levels should match exemption levels. For bulk quantities of material, clearance levels
- may be lower than exemption levels. The clearance level for any radionuclide should not exceed the exemption level for that nuclide, in order to avoid situations where material is released from regulatory requirements under one rule only to re-enter under another due to exemption levels being exceedea. Figure 4, Section 5, gives guidance on deciding when materials may be cleared from within regulated practices.
OTilER MECHANISMS FOR RELEASE OF RADIOACTIVE MATERIALS 2.21. When dealing with release of radioactive materials, clearance is just one of the possibilities. Where no further use fbr the material is foreseen, it may be sent to an authorized disposal facility, or it may be discharged into the environment within a management system which includes the concept of authorized release. If the material has potential value, it may be dealt with through the process of authorization for further use or recycling. In these cases, the risk is not necessarily trivial, whereas the concept of clearance applies when the risk is trivial. l The terms ' authorized discharge'
- authorized disposal', ' authorized use' and ' authorized transfer' are described further below in order to clarify their usage and avoid confusion with the concept of clearance. Guidance on their application, however, will be found elsewhere (refs). j 2.22. Radioactive wastes in liquid or gaseous form may be released to the environment through authorized discharge. While direct control over the discharged material is lost, the process of release to the environment is kept under regulatory control. Control is carried out at the point of discharge and surveillance may be performed in the environment dependmg upon i 1
the assessed level of risk. Under the terms of the authorization, conditions may be imposed on the form of the material, the rate at which it may be released, the ambient meteorological and environmental conditions required for discharge, and so on. For example, it may be possible to release liquid material to sewage or local waterways under controlled conditions of concentration and release rate; environmental monitoring can confirm that any possible radiological consequences continue to be acceptably small. ]
i 2.23. Regulatory control of materials intended for re-use or recycling, but which do not meet l
! the criteria for clearance, may be relinquished when such use is authorized by the Regulatory Authority and when the authorized use has been verified. That is, control of the material is retained until it has been established that it has been used for the purpose for which the t)RAIT 4 - Ches Mason'19410-26 ))
D,
- lisatt Safets Gwde Promon for onmuons from the Regulatory comrol of Radiatmn Appbcation of the Conceph of I uluuon i setnption and Clearance 1
authorization was given. For example. it may be acceptable to use overburden from a uranium i
mine as construction material for road foundations. The road builder would be required to give i an undertaking that the material would be used only for the apprmed purpose, and could, in I
principle, be subject to regulatory control until the road has been constructed and the authorized use verified. It is implicit in the concept of. authorized use that, in making a decision. the Regulatory Authority will take into account the likelihood and implications of other uses being j made of the material in the future. An example of authorized recycling might be the release fbr j sale. on d, commissioning. of cleaned and re-usable components of a uranium mill to another industrial application, such as a non-uranium mineral extraction plant. 1 2.24. Authorized discharge and authorized use require the optimization of protection, subject l
- to dose and risk constraints. They also require a priori assessment of the scenarios of exposure.
They allow the a posteriori verification of these assessments. Detailed guidance on regulatory control of discharges is given in SSxx.
2.25. Radioactive materials may always be transferred from one regulated practice to another, with the approval of the Regulatory Authority.
2.26. The relationships between clearance, authorized discharge, authorized use and retention I
of regulatory control are illustrated in Figure 1. The upper part of the diagram represents a i 1
region where materials may be cleared because exposures are estimated to be trivial and not
]
worth regulating. The lower part of the diagram represents the region where regulatory control of materials must be retained because the risks arising from lack of control are regarded as unacceptable. The central part of the diagram represents a region where a regulated practice may be authorized to release certain materials under specified conditions.
l I
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{2 DRAFT 4 - Ches Mason.1998-10-26
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Drafi Saktr Gmde Promion for Onmons from the Regulators Control of Radiation Appheation of the Concepts of I sclusion i semption and Clearance 9
Waste materials Materials which may .
(no further use foreseen) be used or recycled
__ _____.__a_.
- i Clearance of matenals from regulatory control clearance clearance (Treat as normal (Unrestncted refuse /ef6uent) use/ recycling)
Controlledrelease of materials I .f from a regulatedpractice Regulated
- N* authon. zed authorized " PractI
- use pos.
(Restricted use/ recycling.
discharge gases!
Controls apply untilthe
. (Regulatory controls apply, and continue to apply, to the process) authorized use is verified) ,
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m eM un _ d.isposal P transfer jy@ c y ' ' 7.Q (To awaste man- 4). d (To another [-[i y.4lm~ d. pradice) F~~'I" pp f . _a. . j., f. gy 3 gernent facility 4q d,b.p.C.,.;g, ,g. g Figure 1. Regulatory processes for dealing with relinquishment or transfer of rc gulatory responsibilities for radioactive materials.
2.27. There is another situation in which the term ' clearance' is used. The final stage in the cessation of a practice at a particular location is the release of land and/or buildings from regulatory requirements. There are two possible regulatory processes: clearance and authorized termination of responsibility. Clearance may be the more desirable option for reasons of public acceptability, but application of clearance criteria may not always be the appropriate strategy. For example: application of clearance criteria to the release of land previously occupied by a practice that had been discharging radionuclides to the environment (through authorized discharge) might lead to situations where the land would need to be decontaminated to lower levels than the surroundings where some of the discharged material remains and where it is considered acceptable. Such a situation could be dealt with by authorized termination of responsibility, making use of appropriate, optimized criteria for i
DRAFT 4 - Ches Mason /199840-26 13
~
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Draft Safcts Garde Pnniston for Omimons from the Regulatory Control of Radiatum Application of the Conecpts ofTsclusion,I gemption and Clearance residual radionuclide concentrations and quantities, in much the same way that the concept of authorized discharge is applied.
EXEMPTION IN INTERVENTION SITU.4TIONS 2.28.
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]4 t)RAI'T 4 - Ches Mason'1998-10-26
i Draft .W!cr> Gmde Prouuon far < trnimons from the Regulator 3 c4Hitrol i of Radiation Application of 11 e ( oncern of I uluuon i semption and ( learance l
1 \
- 3. EXCIESION OF EXPOSURE i GENERAL l
3.1. Some exposures to radiation are part of the natural human environment. Examples include exposures from cosmic radiation at ground level and exposures from potassium-40 in !
the body. Exposures of this kind are essentially unavoidable. Recognizing that such exposures are for all practical purposes not controllable. the llSS treats them as ' excluded' )
1 from the regulatory requirements (BSS: Paragraph 1.4.).
PRINCIPLES AND CRITERIA l
l 3.2. The principle which applies when deciding to exclude exposure from the regulatory '
system is that the exposure must be essentially unamenable to control. The phrase essentially unamenable to control' is taken to include both exposures that cannot be significantly reduced 1 4
by reasonable physical means and exposures that are commonplace in the natural human environment and for which legal requirements for control would entail an unjustifiable expense of social resources. For example, exposures from cosmic rays at ground level fall into the first category; exposures from radon in dwellings fall into the second, provided that the action levels for intervention for radon exposure are not exceeded (BSS: Schedule VI).
Exposures which arise from human activities involving manufactured radioactive sources and l
radiation generating equipment, are not excluded from regulation, as it is possible to control i them.
I I
3.3. The concept of exclusion applies to exposures and not to sources or practices giving rise to the exposures. For example, workplaces in hospitals where medical radiography is !
practised are subject to regulatory control, but the component of exposure received by the l
hospital workers from radon in the air is normally excluded from their dose assessments. i l
I APPLICATION 3.4, The decision making process for exclusion of exposure is illustrated in Fig.2. If the human activity under consideration is intended to reduce existing exposures. it is a case of intervention; otherwise it should be treated as a practice (Box A).
3.5. For intervention situations,if there are no reasonable means to reduce the exposure or the exposure is below any relevant action levels. it may excluded from regulatory requirements (Boxes B and C). Exposures above the action level should be reduced through DRAf"I 4. Ches Mason 1941026 15
i
%. " i Draft L/cn Gm.k housion for ( >mrwinns from the Reputaten Contral \
i of Radiation Applicalmn of the Concer.s ot'l uluuon. I semption and t learante intervention until compliance with the action level is achieved. after which the residual '
i exposure may be excluded from funher regulatorv requirements.
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human acrvity wtisch ish Treaf as prachce the e@osu'e No onder considerativ to mourg s p
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- No reasonable physscal yg ecosure l means to reduce flirecify related i The eqx4ure e @05d'e' 10 the *0'k7 Wl l i
may be I escluded Yes No l from I regulatory _,h reqwrements C F No is the is th, regwrements Ye e9Dsute abose egongre aboe y an, anpiscanie a on ie s> S ihe .orip,. e aamn + ,, /
L a-. for oCCupallong e+osure ano
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Figure 2. Decision chan for exclusion of exposure from regulatory control 3.6. Radon in workplaces merits a special mention in the context of exclusion. Radon is present naturally in all buildings and workplaces, regardless of whether work with radiation takes place in them, and it is normally regarded as part of the natural working environment and outside regulatory control. Ilowever, exceptions occur on two grounds: (a) if the radon levels in a workplace are unacceptably high and are not reduced below the relevant action level by intervention, then the doses received should be included in the worker dose assessments (Box F), and (b) if the exposure arises directly from a practice which releases radon to the workplace environment, such as the mining of uranium, then the exposure from radon is considered to be occupational exposure (Box E).
16 DRAIT 4 Ches Mason /1998-10-26
Dratt L/etr Umde l'ros mon for Omnsions from the Regulaton ('ontrol of Radianon Apphcation of the G nteph of I wlumn. I semption and Ocarante
- 4. EXEMPTION OF PRACTICES GENERA!.
4.1. Practices or sources within practices may be exempted from all or some of the requirements of the Basic Safety Standards. The purpose of exemption is to avoid expending resources on radiation protection in areas where little benefit would be achieved, i.e. where the radiological impact is sufficiently low as not to warrant regulatory control. The resources may be those of the regulator, those of the party which may be subject to regulation (principal pany: see BSS, Paragraph 1.6) or, more commonly, both. l l
4.2. Two cases may be distinguished:
a) the individual and collective dose or risk resulting from the exempted practice or source are trivial, and therefore it would be a waste of resources to impose control measures aimed at a funher reduction of the radiological impact when those resources could be put to a more beneficial use; and b) the individual and collective doses or risks from ajustified practice are not necessarily trivial, but no reasonable control procedures can achieve a significant improvement in radiation protection i.e. radiation protection, taking into account what it would cost to apply regulatory controls, is already optimized without the need for regulation.
4.3. Exemption is intended for practices which are inherently safe and should not be used if there is a possibility of scenarios leading to doses in excess of those specified in granting the exemption. The formulation of exemptions from regulatory control should not allow the circumvention of controls that would otherwise be applicable by such means as deliberate dilution of material or fractionation of a practice.
4.4. It must be kept in mind that exemption of a practice or a source from regulatory control must be seen in the context of the dose limitation system set out in the BSS.
Therefore, applying the principle of justification of a practice. the Regulatory Authority may wish to prohibit certain uses of radiation sources even if the associated doses are trivial, e.g.
for frivolous uses, or in cases where solutions not requiring the use of a radiation source are equally effective.
l l
DRAll 4 - Ches Mason'1998-10-2(> ]7
g s !
l> raft safer) Gmde Preuuon for ()mnmen from the Regulahn t ontrol !
of Radiahon Appbcahon of the contcpis et i scluuon i sempuun and ( learame PRINCIP11S AND CRITERIA l
4.5. The essential principle for exemption of a practice from regulatory control is that the risks it may cause are so small that it is not worth the cost of regulating them. As set out in the BSS (Schedule I, Paragraph I-2). the generalprinciples for exemption are that:
(a) the radiation risks to individuals caused by the exempted practice or s<mrce he
{
sulficiently low as to be of no regidatory concern: '
th) the collective radiologicalimpact of the exemptedpractice or source he sufficiently low as not to warrant regulatory corural under the prevailing circumstances; and (c) the exempted practices and sources be inherently safe, with no appreciable
\
likelihood ofscenarios that could lead to afailure to meet the criteria in (a) and (b).
Criteria for exemption on the basis of trivial risk l 4.6. The BSS gives quantitative criteria (Schedule 1, Paragraph 1-3) for exemption on the basis of trivial risk, which allow the Regulatory Authority to reach a decision with a minimum of necessary deliberation. A practice or a source within a practice may be exempted without ,
further consideration provided that thefidlowing criteria are met in allfeasible situations:
(a) the effective dose expected to be incurred by any member of the pubhc due to the 1
exemptedpractice or source is ofthe order of10 pSv or less in ayear, and 1 (b) either the collective elkctive dose commined by one year ofperformance of the practice is no more than about 1 man.Sv or an assessment for the optimi:ation of protection shows that exemption is the optimum option. ;
1 Criteria for exemption on the basis of optimization i 1
4.7. If the criteria for exemption without further consideration are not met, a practice or source may nevertheless be exempted as long as the principles for exemption (Paragraph 4.5) are satisfied. In this case, the Regulatory Authority should assess the radiation risks caused by the practice, including the collective radiological impact, and the cost of regulation. To grant an exemption, the Regulatory Authority should make a determination that neither individual I doses nor collective doses warrant control through regulation, and that there is little likelihood l
l that these circumstances will change.
I l APPLICATION l
I l
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]8 DRAI'14 Ches Masore199N-10-26 l
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- litatt bien umh Prouuan for Omnuons Hom the Regulaton Omtml of Radsation Apphcation of the concepu ofI wluuon. I wmpwm and citaran*
.=
4.8. In the context of exemption, it is appropriate to note the definitions of the terms practice and source. A practice is defined in the llSS as:
Any human activity that introduces additional sources of exposure or exposure pathways or extends exposure to additional people or modilles the network vi exposure pathuays from existing sources. So as to increase the exposure or the liicelihood ofexposure ofpeople or the number ofpeople exposed The size, scope and time duration of what is considered as a practice can vary dependmg on 1 l
the purpose of the practice and the kind of radiation protection assessment or regulatory action ,
applied to it. A source is defined in the BSS as: '
Anything that may cause radiation exposure, such as by emitting ionizing radiation or releasing radioactice substances or materials. For example, materials emitting radon are sources in the environment, a sterili:ation gamma irradiation unit is a source for the practice of radiation preservation of food, an X ray unit may be a source for the practice of radiodiagnosis, and a nuclear pou er plant is a source for the practice of generating electricity by nuclear power. A complex or multiple installation situated at one location or site may. as appropriate. be considered a single source for the purposes ofapplication of the Standardt Thus, within a practice, the radioactive materials or the equipment emitting radiation or containing radioactise materials are the sources. An installation producing or using radioactive material may also be a source.
4.9. Exemption is normally applied to practices; however, in some cases the exemption principles may be applied to single sources within practices. For example, a research l
laboratory in which radiation sources or radioactive materials are used may require regulatory control, but low-activity sealed sources used to test or calibrate radiation detection equipment in the laboratory may be exempt from regulatory requirements, provided they meet the exemption criteria.
4.10. When a practice is being considered for exemption, all facets of that practice, including a consideration of radioactive wastes, should be taken into account. All aspects of the practice would then be exempted from the regulatory requirements, apart from its initial justification. Consequently, when putting the concept of exemption into effect, the scope of each practice should be carefully defined. The use in buildings of smoke detectors containing Am-241 may be defined as a practice, for example, and may be exempted, while the manufacture of smoke detectors is a separate practice which would not be exempted.
Similarly, the sale and subsequent use of opthalmic glass containing thorium may be exempted, while the practice of manufacturing such glass may not.
DitAl'T 4 - Ches Ma. son 1998 10 26 ]9
- _- _. .. .. . . -. -- . - , _ ~ ~ .. -. -
Draft Safer) Gwde Prouuon for Onuwons Innn the Regulaton Control of Radianon Appheat on of the Conce,xs of I ulusinn. r sempnon and Clearanec
.i l 1 1
Application of Exemption on the basis of trivial risk !
1 1
(Paragraphs I.1I and 112 below are taken thnn SSM section fr2. as sugge.sted at the last .
\
CSM; they will need editing a little tofit tiddy into the new docta::ent. ) l 4.11 It is important clearly to define the terms of the exemption so that regulatory authorities and persons in possession of exempt material have a common understanding about I what is exempted. Exemption levels are rarely, if ever, expressed in terms of individual or i collective dose, since it is not practical to measure these parameters at the operational level. l Rather, exemptions should be expressed in terms of derived quantities that are directly ;
measurable so that compliance with the provisions of the exemption can be determined. I or ,
1 example, exemptions related to waste streams or recycle scrap [we would now use clearance for these) are usually expressed in terms of concentrations of specific radionuclides. In the !
case of consumer products containing radioactive materials, the exemptions are often in terms of total activity of a specific radioisotope in the product. !
i i
4.12 Approaches to setting the derived quantities using models may involve either an iterative process, whereby representative values of these quantities are selected and modelling ;
is carried out to demonstrate compliance with chosen criteria, or a normalization process, in i which doses are computed corresponding to a unit exempt quantity, which subsequently leads to the evaluation of the total amounts of sources that may be exempted in a given practice in j compliance with the chosen criteria. In both cases, the ultimate fate of the sources involved, i 1
and their likely re-utilization, must be adequately covered. I 1
4.13. Schedule 1, Table I-l. of the BSS (Should we reproduce Table 11 in this Guide?)
provides generic radionuclide-specific levels in terms of total activity and in terms of activity concentration, that allow the exemption of practices without further consideration from the requirements of the Standards, including those for notification, registration or licensing. These levels were derived on the basis of a suite of exposure scenarios that consider possible uses, and associated disposal pathways, of radionuclides. Accident scenarios were also considered, the limiting dose being set at I mSv per year of operation of the practice. It must be noted that these values were derived for a moderate quantity of material. The most restrictive case was taken to derive the generic exemption level.
4.14. However, alternative exemption levels may be established by the Regulatory Authority on the basis of other scenarios that represent the particular conditions under consideration, as long as the exemption criteria are met. The authority will need to take account of the probability and severity of possible consequences of accidents or misuse. Such consideration 2() DRAIT 4 - Ches Mason 19981046 I
N. * #
Draft brity Gule l'rowon for ( Hntumm trum the Regulator) ( ontrol et RaJ6aton Application of the Concepts of I uluuon I semption and Ulcarante may contra-indicate the exemption of a practice even ifit gives rise to very small doses under normal conditions. .
4.15 The process for determining whether to grant an exemption is illustrated in Fig. 3 as a decision chart.
For efficient application, the Regulatory Authority should use a hierarchy of criteria. as indicated: clear-cut cases where radionuclide concentrations or quantities are very low (Paragraph 4.13) require minimal regulatory effort and inay be exempted without further consideration (Box A). Cases in which the exemption lesels are not met need some additional evaluation by the Regulatory Authority, but as long as the Regulatory Authority is satisfied that the exemption criteria are met (Paragraph 4.6). exemption may be granted without any further consideration (Box B).
4.16.
Conditions may be attached to exemptions by the Regulatory Authority. They may relate to the physical or chemical form of the source and would ensure a priori that the exemption criteria are met (Box C), even though, for example, the amounts of radionuclides involved exceed those given in Schedule 1, Table 1-1 of the BSS. It is important to note that the conditions do not imply the need for any continuing regulatory surveillance.
4.17. Exemption may be applied not only to radioactive material within a practice, but also to radiation generators in which no radioactive substances are incorporated. Such provisions are stipulated in Schedule I of the BSS (Reproduce them here?).
Application of Exemption on the basis of optimization only 4.18. In applying optimization of protection, it should be borne in mind that the implementation of regulatory control may be costly in terms of time and resources for the regulator as well as for the operator. This factor should be included among the parameters considered in the optimization assessment. This assessment should address various possible options for regulatory control. The practice should be considered as suitable for granting an exemption if the result of the assessment shows that exemption is the option that optimizes radiation protection and that the principles for exemption (Paragraph 4.5) are satisfied.
although the individual risks involved are not necessarily as low as implied by the criteria of Paragraph 4.6.
l l
DilAl"I 4 - Ches Mason /199f(-10-26 21 l
f w
,x- " 6 Drzft Sqferr Gaade l'rus nnm for Omissions from the Regulatory ('ontrol of Radiatmn Applicatmn of the i oncepts of I wiusum i sempton and Cicararite a
s i
E s em p tio n (without further c o n sidera tio n) A A fe fr<e
,s T ee., s i e,em ptiori g Nie.eis ei ceesee' The precirce m ay be esempted TfD l' O fn seg ulatory C '"" 8 '
Can doses enceed the g 3 Gebe Stl terse IOf esemptstn ?
Conditional p r e r=r p rio n Ves r 7 The practece m ay t.e C c an ine c e nostoo nant oose eraerse t,e e s em pted mel unGet 5f ecified t'O m Ve8 C o n c itsc a l fe g wielory c oolf oi k A Ne 1F 1 e .,eci,co m u.i t.e .e u sied Regulatory control Figure 3. Decision chart for exemption of justified practices from regulatory control 7.7
. DR AFT 4 - Ches Mason't998-10-26
4 Nv Draft Salm Gmde Prousum lot omissons from the Reculaton Centrol ,
of Radiatum Appbcatum of the Concepts ofI ulusum, laemptum and Clearance l 4.19. In order to be a candidate for this type of exemption. the radiological situation under
}
consideration should be in a state that remains fairly constant with time with no possibility for significant changes in long-term exposure rates. In many situations there will be the possibility of short-term changes in exposure rates, due to say diumal fluctuations in ventilation rates, but these are not signincant provided the annual average remains
' l approximately the same from year to year. There should also be no possibility of an accident or other radiation emergency which could lead to increased exposure.
4.20. The criteria for exemption given in the BSS relate to public exposure. In deciding whether to exempt a practice, the Regulatory Authority must also take note of any occupational exposures which arise. It may be appropriate to exempt certain practices in which occupational exposures are very low and for which radiation protection is alreadv 4 optimized, that is for which the application of regulatory controls would not bring a l significant benefit in protection. l 1
4.21. In the context of occupational exposure, in the stable situations referred to in ;
Paragraph 4.20, reasonably accurate estimations of doses can be made on the basis of simple measurements in the environment and thus any form of personal monitoring in order to l estimate individual doses is likely to be super 0uous. It may be the case that the existence of such a stable radiological situation is a consequence of the application of ccntrols intended for other purposes, for example legislation on the maximum length of the working day, and provided such controls remain in place, their effect in radiation protection terms need not be '
duplicated by the introduction of parallel radiation protection regulatory provisions.
Examples of situations that may be candidates for exemption on this basis are exposures of workers at non-uranium mines.
4.22. In deciding whether any reasonable control procedures can achieve any benefit in radiation protection, an evaluation of the control options together with their associated costs and other detriments will have to be undertaken; the costs of the associated regulatory effort and resource implications will also have to be taken into accomo in undertaking this process it will be important to consider what fraction of the total hem risk to the exposed population arises from the exposure under consideration. For example, in considering whether to exempt exposures of miners from regulatory provisions, it is important to put any proposed l expenditure on radiation protection together with its associated health benefits in the context
! of the health benefits that may be achieved by expending similar resources elsewhere in order to reduce the risk from other hazards to the miners .
4.23. It may happen that within a particular practice some categories of situations meet the requirements for exemption from regulatory provisions whereas others do not. This situation l
l l
DRAIT 4 - Ches Mason'1998-1046 23 l
l Ikatt Xhir Gm k. honuon for Onussons from the Regulatory ( ontrol of Radiation Appbcatmn of the Contceb eli uluunn i semption and Clearante l
i 4
may arise when occupational exposures are exempted but public exposures are regulated. One
\ ;
example could be the practice of mining for precious metals. In this case the exposure of the miners may be exempted on the basis of the principles outlined above but the exposure of members of the public from the ongoing accumulation of waste spoil may be regulated in the sense that the doses should be within the appropriate dose criteria.
4.24. Where members of the public are being exposed from releases of natural radionuclides from a practice tbt has been operating for some years outside a regulatory radiation protection system, a period of time for compliance may be allowed. An exemption may be granted temporarily under the condition that measures are taken to rectify the situation within a given period and that changes that may affect the radiological impact are notified to the regulatory authority. '
4.26. When considering this type of exemption, the Regulatory Authority may wish to set an upper bound to the individual doses; such upper bounds may not be the same for the members l
of the public and for the workers involved. The Regulatory Authority may also choose to implement the exemption by establishing specific exemption levels appropriate to the !
circumstances.
l EXAMPLES i
4.27. Examples of practices that may be candidates for exemption are the use of certain low specific activity radioluminous products and leak testing using small quantities of Kr-85.
Examples of practices that may conditionally exempted include: the use of smoke detectors containing Am-241, on condition that they are manufactured to a specified standard or on condition that the sources are sealed, and the use of radionuclides in biomedical research, on condition that the amounts are less than exemption levels set by the Regulatory Authority for the specific circumstances that apply. l 4.28.
l l
l l
24 DRAI'l 4 - Ches Mason /1998-10-26 l
)
4 * % .1 DrafI Na4 ti Gwde Prowan for Ormworis from the Regulatan ( ontrol of Radiation Arplie.ition of the ( oncer's of I ulusmn I semption and Ulcarance c
- 5. CLEARANCE OF RADIOACTIVE SIATERIALS GENERAL 5.1. Radioactive materials may be remmed trom the system of regulatory control provided the radiological impact of these sources after removal from the system is sufficiently low as not to warrant any further control. Such removal of materials from regulatory control is called clearance.
5.2. It is important to note that the clearance concept is different from the exemption concept, since the materials subject to clearance are under regulatoy control until the Regulatory Authority clears them. It is the responsibility of the Regulator; tuthority to establish the requirements for clearance and to verify compliance with the requirements.
5.3. When dealing with release from responsibility for radioactive materials, clearance is just one of the possibilities. Material may be discharged into the environment, within a management system which includes the concept of authorized release, er the material may be dealt with through the process of authorization for further use or recycling, or where no further use is foreseen, authorization for disposal. In these cases, the risk is not necessarily trivial, w hereas the concept of clearance applies when the risk is trivial.
PRINCIPLES AND CRITERIA 5.4. The basic criteria for determining whether materials under regulatory control should no longer be subject to regulation are identical to the exemption criteria set out in the BSS.
Indeed, they aim at satisfying the same general principles as for exemption. Ilowever, while exemption may be considered on the basis of trivial risk or on the basis of optimization, clearance may only be granted on the basis of trivial risk.
5.5. Materials within a regulated practice may be cleared from the system of regulatory control provided that the following enteria are met in all feasible situations:
(a) the effective dose expected to be incurred by individuals due to the materials cleared in a year is of the order of 10 pSv or less, and (b) either the collective effective dose committed by the materials cleared in one year is no more than about I man.Sv or an assessment for the optimization of protection shows that clearance is the optimum option.
DRAI'T 4 - Ches Mason 1998-10-26 25
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'"h N Dratt Lkr) Gmde Prouston for Omisunns from the Regulatory Control of Radiation Application of the Concepts of1 Aduuori. I semptum and Clearance !
l: .e i The criterion under (a) applies to all individuals, including workers.
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I Geneoc cJoeteilte devels we calculeled on em t
beam shai em dose enterm for cinerence are met
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Clearance - A. sor a mievene scenexm or num tran v ;
Are the materni er aktier from em e=ampaan j levets of T h= == detterme exposure t ,g generic clearance scenenos er assumptxys we used.
4
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'vels esceeded M og coning == genth af mesenet J No j The 2
!' fte does osere for cenerwee are em same se
> matenal may the dose creene km enemphors
- be cleared yes from regulatory i
control I without further 8 consideration Can doses
,, exceed the dose cntena for No clearance27 t
Authorized use Yes The matenal i C D . may be is the Have the - released from malenal to conditions for - regulatory Authonzed Use Control wMn l be re-used,or
'S 't waste runher Yes l Authorized ,,
teen met? . authonzed discharge use has been The inatenal Waste No may be released from i regulatory L
control under Have the the Condelions conditions for of authonzed - ' thonzed Discharp i
discharDe; Yes been met?
regulatory -
( controlof the l procesa for discharge is NO l
l retained T U i i I' i The matenalcannot be released from regulatory control . lt must remain within the regulated regime and j be dealt with by authonzed disposal of J authonzed transfer to another practice ,
i l i t
l 4
l Regulated j i
=
l ll Non-regulated l J
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1 I
i i Fig. 4. Decision chart for release of radioactive materials from regulatory control l-26 DRAFT 4. Ches Mason /1998-10 26
.2 - _ ._. _ _ . _ _ _ - .=. _ _ _ - . . _ . . _
b Draft Lfet> Gnk Prawon for t nmwions from the Regulatory Contral of Radiahon Apphcanon of the Loncepts of I'scluuon i semphon and Llearan.c APPI ICATION General 5.6. Clearance can apply both to materials that are being discarded as waste and to materials intended for further use or recycling. In this context, the term ' material' covers bulk material as well as equipment, objects, solid wastes, collections of small sources, such as smoke detectors, etc. It is implicit to the concept of clearance that materials, once cleved, are subject to no further regulatory restriction or control for the purpose of radiation protection. It is important to verify that no conditions will imply a need fbr subsequent regulatory surveillance, as this cannot then be considered a true removal from regulatory control. Any l conditions should ensure a priori that the clearance criteria are met. Clearance implies I therefbre that the last control of the Regulatory Authority is perfbrmed at the point where the )
material leaves the controlled facility. l (Hliat about building andlands?)
5.7. The simplest regulatory mechanism to deal with clearance is to establish clearance levels in terms of activity and activity concentration based on the criteria of Paragraph 4.5, which are equivalent to the criteria for exemption. However, as the generic exemption levels set out in the BSS were calculated assuming only moderate quantities of material, they may l not necessarily be suitable as clearance levels for larger volumes. Generic radionuclide-specific clearance levels may be derived by the regulatory authority from the criteria above, i taking due consideration of all possible scenarios of exposure and the amount of material l involved. If these clearance levels are met, the regulatory decision is straightforward (Fig.4, Box A).
5.8. The Regulatory Authority may also grant a clearance if it is satisfied that the dose criteria (Paragraph 4.5) are met (Fig.4, Box B). The Regulatory Authority may consider deriving clearance levels on a case by case basis for clearly identified streams, including identification of their origin, or implementing the optimization process as set out in Paragraph 4.5(b).
Establishment of derived clearance requirements 5.9. Clearance requirements are rarely, if ever, expressed in terms of individual or collective dose, since it is not practical to measure these parameters at the operational level.
DRAFr 4 - Ches Mason /199810 26 27 I
s Draft Nako Gule Provmon for Omnunns trom the Regulatan contral of Radiauon Appbcanon of the concep s or i uluunn. I wmpoon and i learance l Rather, they should be expressed in temis of derived quantities, either generic or on a case by 1
case basis that are directly measurable so that compliance with the requirements can be verified. The clearance requirements may relate to the total amount of material, to the total activity. to the radionuclide-specific total actiuty and concentrations, to the physical and chemical form of the material subject to clearance and to its origin.
(One sentence on public accepumce issues ?)
l 5.10. The derivation of these practical quantities, generic or on a case by case basis, requires a thorough examination of the possible routes by which humans may be exposed to radiation from the proposed cleared materials, irrespective of how that material is used and where it goes. In considering the pathways by which humans may be exposed to radiation, it will J
always be possible to envisage some circumstances in which exposure may occur but is not certain to occur. These potential exposures should be considered as part of the assessment i process, taking into account their likelihood. ;
i 5.11. Two general approaches may be used :
(a) the derivation of generic clearance levels through a systematic review of the possible routes of exposure and use of conservative assumptions and data, when appropriate, and (b) a case by case approach.
The derivation of generic clearance levels requires consideration of a wide range of situations, including hypothetical situations, and may lead to very low clearance levels. When establishing these derived generic clearance levels. their practicaSility should be kept in mind, including the ability to measure the corresponding parameters in the amount of material considered. The measurement methodologies and their feasibility should therefore be also taken into account.
5.12. No criteria specific to the establishment of clearance levels are set out in the IISS.
Ilowever, they must not be higher than exemption levels in order to prevent ' looping', i.e.
materials being cleared but then, as they would not be exempt, immediately re-entering the regulatory system. Moreover, as the volume of material to be considered could be higher than the volume of material considered in the derivation of exemption levels, the derived clearance levels will often be less than the exemption levels, except in certain circumstances such as the waste arising from medical use of radionuclides.
l 5.13. The case by case strategy may allow for a more realistic approach as regards the characteristics of the material considered for clearance and the possible pathways by which 2g DRAl~I 4 Ches Masonfl99810-26
a4, # Draft Sa/en Gut./e'Provmon for Omwens from Ibc Regulaury control of Radiation Appleation of the concepts fI utuwm I wmption and Clearance e
humans may be exposed to radiation. The practicability of the control may also be adapted to -
the actual situation. In this case it cannot generally be demonstrated that all possible -
scenarios are covered by the application of the derived clearance levels. l'o ensure that cleared materials will meet underlying criteria for clearance, a cautious approach should be l
used. which may involve adopting additional provisions to enhance the probability that the j assumptions about individual and collective doses will not be invalidated and to minimise the possibility of accidents and misuse. Examples of such additional provisions include:
e a constraint on the total activity which may be cleared in a year from a regulated practice; l i
l . the chemical and physical form of the radionuclides permitted in the cleared materials as well as specification of the origin or the nature of the material, e.g. contaminated oil from reactor pumps.
5.14. Where any additional provisions relate to the further use of the materials however, it is necessary to verify that they are complied with and therefore the material cannot be cleared.
Its further use should he subject to authorization by the regulatory authority. !
Verification of compliance l
l 5.15. Once the requirements for clearance are clearly specified, a method should be i established whereby the Regulatory Authority can determine compliance with the clearance 1
l requirements as transfers are made from a controlled status to a situation where no further i regulatory control remains. One practical method to accomplish this objective is to include relevant requirements in the operator's licence. The application for a licence provides the Regulatory Authority with an opportunity to review in advance the procedures and methods by which the licensee will assure compliance with the provisions for clearance.
5.16. The licence can contain specific provisions which also enhance compliance with the requirements for clearance. For example, the licence can contain record keeping requirements which are subject to inspection. The licence can also contain reporting requirements regarding the amounts cleared so that the regulatory authority can monitor the status of the use of clearance, thereby providing data for revalidation of the initial assessment which formed the i basis of the clearance. While not necessarily appropriate in all cases, these techniques can be used in the licensing process to better understand and control the ultimate impact of the use of clearance.
DRAIT 4 - Ches Mason 199 010 26 29
.., . - . . ~ , , . - . - . , , . .. . .
_m . n. . - . - - . - . , . - - ~.~..n..-_.,_~- --
. ;- -k j
' DraR L/en Gmde Prousion for Omiwinns from the Regulator) Contral
'J. -
of Radiation Apphcation of the Concepts of I.Tclusion. (Acmpton and Clearance EXAMPLES Recycling or reuse of materials 5.17. ' Activated .or contaminated materials (steel, aluminium, concrete, etc.) resulting, Ihr example, from decommissioning of nuclear facilities could be recycled or reused without-radiological restrictions if they meet the clearance criteria.
Very low level solid radioactive waste I
5.18. The management of very low level solid radioactive waste, e.g. disposal at a municipal landfill or incineration facility, may be dealt with either through an authorisation process for the disposal or incineration site or through the clearance of the waste. In the latter case, no conditions should apply to the disposal or incineration process. Conditions may apply to the waste streams before leaving the controlled facility, for example the amount of waste cleared in one year, and its radiological and physico-chemical characteristics.-
Material arising from outside the controlled areas of a nuclear facility 5.19. Where the design and operation of a nuclear facility can ensure that materials arising from certain defined zones of the facility, i.e. zones that are not within controlled areas, are ~
. not activated or contaminated as a result of the operation of the facility, those materials may be suitable to be dealt with by clearance.
I I
q i
i 1
i 30 DRAFT 4 Ches Mason /199010-26 I
N
()rall Satch Guide Pros tuon for i> missions from the Regulatitr) Control et Radiation Application of the Concepts ofI ulusion EAcmption and Clearance a
- 6. REFERENCES
' ilss 2
SS89 i
L
[)RAIT 4 - Ches Mason'19410-26 31
. . .- . . - - . . . ~ - - . . - . - - - . . - -- - -- . - - -
Drtft Sq/ro Gmde Provmon for Omissions from the Refutatory Control of Radistuin. Apphcrbon of the Concepts of Exclusion. [:semption and Cicarance
!5
- i l
i l
GLOSSARY t
Exclusion refers to exposures that are essentially unamenable to control and left out of the l regulatory system. ;
l ,
Exemption refers to a determination that a practice, or source within a practice, does not l require regulating because it gives rise to radiation doses or risks that are trivial.
Exemption level !
Clearance refers to materials released from regulatory control on the grounds that the ;
exposures or risks they may cause are trivial. !
Clearance level Authorized discharge refers to the process of releasing liquid and gaseous radioactive effluents from a regulated practice to the environment under controlled conditions based on !
- optimization of protection. 5 Authorized use refers to restricted use or recycling of radioactive materials outside the regulated practice within which they arise, following a radiological evaluation that their +
- subsequent use need not be regulated, even though the criteria for clearance are not met. ;
. Authorized disposal refers to the emplacement of radioactive waste into a waste management facility. !
Authorized transfer refers to the transfer of regulatory responsibility for specified l
- radioactive materials from one regulated practice to another. i
- Authorized termination of responsibility refers to the release by the Regulatory Authority of the legal person responsible for a regulated practice from further regulatory requirements.
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4 i
-, 32' DRAIT 4 - Ches Mason /1998-10-26 i
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TERMS OF REFERENCE FOR THE WORKING GROUPS !
I t I
i i
! -1. Which of the three concepts would apply to the test cases?. Identify difficulties with the proposed concept as set out in the current draft.
l l t
i 2. Which situations / activities could usefully be added as illustrative examples in the
' Safety Guide? t i
I
- 3. ls the relevant decision chart correct and sufficiently illustrative? Make any i suggestions forimprovement, j l
e l 4. Make any suggestions for changes of substance to the text relevant to your group and [
any, additions. j (no detailed drafting required) t f
i 5
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i
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^
i E
\
l I
s ATTACHMENT D I
- v
, , , , . , , , - -, . . ~,, . - - -
. ./P TEST CASES A. Mining and mineral processing
- 1. Mining Uranium
- 2. Mining mineral sands
- 3. Mining gold
- 4. Processing oil and gas
- 5. Mining granite B. Other activities
- 1. Using natural mineralized materials for building
- 2. Using manufactured mineralized materials for building
- 3. Radon SPAS C. Occupational situations
- 1. Tour guide in a cave
- 2. Air crew
- 3. Working in an office 1