Situation of IAEA work concerning protection of the environment

1. Situation of IAEA work concerning protection of the environment EC PROTECT Workshop Aix en Provence, France 14-16 May 2008

2. IAEA and the protection of the environment • International Basic Safety Standards revision process: • Oslo: “Considering the need of a requirement to take into account the impact on non-human biota for different possible purposes in line with recent considerations made by ICRP”. • Aix: Draft 1.0 ready to go to 5 Standards Advisory Committees (since Feb 2007,7 Experts Drafting Meetings, 1 Member States Technical Meeting, 3 Cosponsors review and drafting Meetings, 1 Advisory Committee review Meeting) • >300 international experts from MS and Organizations involved.

3. Revision of BSS SS115 International Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Source Status of revision: draft 1.0 International Cooperation with WHO, PAHO, FAO, ILO, OECD/NEA, EC, UNEP, ICRP, IRPA

4. International Basic Safety Standards and the protection of the environment (Draft 1.0) • Notwithstanding the importance of the work being done under the ICRP, ICRP 103 does not constitute a basis for new detailed requirements. • Rationale: • It is a preliminary approach to fill a conceptual gap in the system of radiological protection and, • a framework to progress in the acquisition of knowledge and information which could be used in the future to define a system of protection of the environment complementary with the existing systems to radiation protection of humans.

5. International Basic Safety Standards and the protection of the environment (Draft 1.0) • The aim of radiation protection of the environment is to protect ecosystems against radiation exposure that would have adverse consequences for populations of a living species. • The present system of radiation protection generally provides appropriate protection of ecosystems in the human environment against harmful effects of radiation exposure. • There are expectations that this be demonstrated, rather than assumed. This would be accomplished through an environmental assessment, which identifies the target(s), defines the appropriate criteria for protection, assesses the impacts, and compares the results of the available protection options. • The methods and criteria for these assessments are still being developed and will continue to evolve and improve.

6. International Basic Safety Standards and the protection of the environment (Draft 1.0) • Radiation impacts constitute only one type of impact, and may, in most cases, not be the dominant impact. • Radiation protection of the environment is to be viewed within the broader context of assessing all of the impacts to the environment.  • These standards would clearly identify protection of the environment as an issue to be assessed, while leaving flexibility to incorporate the results into the appropriate decision making processes.

7. International Basic Safety Standards and the protection of the environment (Draft 1.0) • Two different approaches: • Planned exposure situations: • “The regulatory body shall ensure that the authorized discharge limits account for the results of an appropriate assessment of the environmental impact” • Existing exposures situations: • A component in the optimization process required for any protective or remedial action (together with economical, social, and other factors)

8. Comments to PROTECT Deliverable 5B Draft EC PROTECT Workshop Aix en Provence, France 14-16 May 2008

9. Background • The IAEA acknowledges that the radiological situation of the environment due to authorized activities or installations in accordance with the current international regime is not a concern (UNSCEAR 1996 and update 2008). • The IAEA understands that, while there are expectations to improve the assessment of the impact on the environment, this, unless justified, will not necessarily result in a new regulatory framework with major changes, particularly for planned exposures situations.

10. PROTECT Deliverable 5B Draft • The PROTECT work is a major contributor to the process of considering the way to demonstrate (rather than to assume) protection of the environment from radioactive environmental stressors. And where necessary, to consider remediation.

11. PROTECT Deliverable 5b Draft • IAEA shares the view on the need to improve the assessment tools and have benchmark reference criteria; and recognize the work done within PROTECT and some conclusions of D5bD. • However, the IAEA understands that there are no clear indications in D5bD (or elsewhere) on the validity to apply at this stage the discussed assessment tools and reference criteria within a regulatory context for the control of discharges.

12. PROTECT Deliverable 5B Draft • Apart from some observations to the draft regarding the regulatory applicability, IAEA particularly understands that concepts around Figure 1, page 19/48, are incorrect, because a tool applicable for screening purpose is mixed in a regulatory scheme, leading to confusion and potential misuses. • Furthermore, the scheme proposed differs from the system for protection of the man (as in ICRP 103).

13. PROTECT Deliverable 5B Draft • Nevertheless, the IAEA recognizes the use of any valid screening index and state of the art models and parameters but without affecting other relevant international safety principles for protecting people and the environment, like, for instance, the Principle of Optimization of the Protection (for more details, please see, Fundamental Safety Principles, IAEA SF No 1, Vienna 2006, Para. 3.21 to 3.24 ).

14. IAEA Conclusion: • Results from PROTECT should be seen as an improvement in the methods to demonstrate (rather than assume) the degree of environmental protection under the existing protection system and a step forward that may serve to define, in the future, an expanded system of environmental protection and if needed an applicable regulatory approach, which are being studied and discussed by the international community,.

15. Observations to the D5bD (examples) • Page 7, first para. IAEA does not share the statement on the focus of the work being done. E.g. Maybe a better definition could be: To date the focus has been on improving modeling, identifying data needs, trying to define a system of protection similar to that for man and considering other environmental stressors; regulatory assessment is still away. • Page 7, second para. Comparison of Doses rates to a criteria is one of the indicators regulators should use, but not the only one. Not only the derivation of benchmark values must have a transparent justification, also the comparison and correspondent decision procedure. • Page 8, para. After bullets: ICRP clearly indicate that DCLs are preliminary and that no limits can be recommended at this stage for regulatory purposes. • Page 9 Protection Goals, there are problems in the considerations of goals for protection and the applicability in a regulatory process. • Page 9, para fourth, problems with the definition of ‘population’; whether for research purposes the definition could be adequate, for regulatory purposes this definition is incomplete :e.g. the population of regulatory interest could be totally different. • Page 11, A measurable protection goal?: the needs of regulators are not clearly discussed e.g: apart from comparing results to protection goals, regulators should compare effects of alternative options. The use of numerical dose criteria at this stage is full of uncertainties and lack of knowledge. • Page 13, Deriving a benchmark. The IAEA does not agree with the discussions. It seems that previous approaches (methods and criteria) used by IAEA, UNSCEAR and ICRP (including for the protection of man) where criticized in order to valorize the need of a more formal and les vague approach for non-human. There is a confusion on the target of protection and the tools to ensure that the protection is achieved and a lack of discussion on the high degree of uncertainties.

16. IAEA Fundamental Safety Principles:Optimization of the Protection Protection must be optimized to provide the highest level of safety that can reasonably be achieved. • 3.21. The safety measures that are applied to facilities and activities that give rise to radiation risks are considered optimized if they provide the highest level of safety that can reasonably be achieved throughout the lifetime of the facility or activity, without unduly limiting its utilization. • 3.22. To determine whether radiation risks are as low as reasonably achievable, all such risks, whether arising from normal operations or from abnormal or accident conditions, must be assessed (using a graded approach) a priori and periodically reassessed throughout the lifetime of facilities and activities. Where there are interdependences between related actions or between their associated risks (e.g. for different stages of the lifetime of facilities and activities, for risks to different groups or for different steps in radioactive waste management), these must also be considered. Account also has to be taken of uncertainties in knowledge. • 3.23. The optimization of protection requires judgements to be made about the relative significance of various factors, including: —The number of people (workers and the public) who may be exposed to radiation; —The likelihood of their incurring exposures; —The magnitude and distribution of radiation doses received; —Radiation risks arising from foreseeable events; —Economic, social and environmental factors. The optimization of protection also means using good practices and common sense to avoid radiation risks as far as is practical in day to day activities. • 3.24. The resources devoted to safety by the licensee, and the scope and stringency of regulations and their application, have to be commensurate with the magnitude of the radiation risks and their amenability to control. Regulatory control may not be needed where this is not warranted by the magnitude of the radiation risks.