Practical Implications of changes to the Exemption Orders for Project Teams

1. Practical Implications of changes to the Exemption Orders for Project Teams Alan Fisher, on behalf of The Clearance and Exemption Working Group

2. Clearance and Exemption Working Group • An advisory group established under the Safety Director's Forum • Members include representatives of BNG, Energy Solutions, DSTL, MoD, British Energy, UKAEA, NPL and EA • In 2005, CEWG produced the Nuclear Industry Code of Practice on Clearance and Exemption Principles, Processes and Practices (NICoP) • NICoP helps to interpret the application of relevant legislation (mainly RSA 93 and SoLA / PSRE Exemption Orders but also refers to IRR 99 and Transport Regulations) • Provides practical advice on demonstrating compliance with legal limits • Establishes a common management framework • Provides guidance on Best Practice Arrangements in the absence of legal obligations

3. Clearance and Exemption Working Group • Evidence that the NICoP is widely implemented within the UK nuclear industry, particularly for waste management • A widely respected standard whose application helps demonstrate that materials with potential radioactive contamination may be released from regulatory control in a manner that is • Legal • Defensible • Responsible • Many nuclear operators using the Code of Practice as a reference for demonstrating that certain waste materials may be disposed to landfill or may be recycled for further use

4. Implications of changes to the Exemption Orders • NICoP will have to be revised • References to Exemption Orders and legal limits will require to be updated • Most of the existing text will remain unchanged • Principles (same) • Management Systems (same) • Legal interpretation (changes) • Demonstration of compliance with legal limits (some changes)

5. Exemption Order Review Process • CEWG welcomes review of Exemption Orders • Existing concerns regarding RSA 93 Schedule 1 plus SoLA and PSRE Exemption Orders • Legal limits often difficult to interpret • No obvious basis for the limits • Limits do not account for effects of different radionuclides on human health • Solubility requirement unclear • Conflicts between specific activity limits for clearance of materials and RAM Transport / De-licensing limits • Acceptable averaging volumes unclear

6. Exemption Order Review Process • CEWG supports option to totally rewrite SoLA Exemption Order along the lines of radionuclide-specific system as per guidance in IAEA RS-G-1.7 • Developed for use internationally • Would help UK government defend stance on exempt materials • Based on accepted scientific evidence regarding relative health effects of different radionuclides • Already implemented within EU • Principles of Exclusion, Exemption and Clearance already defined, and agree with NICoP

7. Exemption Order Review Process • CEWG concerns regarding how the government review process might choose to incorporate IAEA advice • UK government should not impose an upper limit on radionuclide specific activities for exemption (e.g. 0.4 Bq/g) • Incorporation into RSA 93 Schedule 1 inappropriate since exclusion and exemption are different concepts • Incorporation of radionuclide-specific exemption limits in Schedule 1 could also lead to conflicts between Exempt and Authorised Processes

8. Day to Day application of SoLA by nuclear licensees • Reactor steel uniformly activated to 0.4 Bq/g with 60Co likely to comply with SoLA Exemption Order, and may legally be released for recycling • Unlikely that a responsible operator would ever choose to do this because of the radiation dose rates involved • Would certainly trigger alarms on Recycling Yard’s Vehicle Monitor!

9. Day to Day application of SoLA by nuclear licensees • Mixture of radionuclides in materials • E.G. Radionuclide fingerprint comprising: • 10% 60Co* • 21% 137Cs* • 19% 90Sr* • 45% 241Pu • 5% Pu (alpha emitters) • Measure one attribute of the waste and apply a radionuclide fingerprint to establish activities of all other species and derive overall specific activity for assessment against SoLA * Measurable using beta probe

10. Effect of applying IAEA limits • For a typical fission product radionuclide fingerprint • 10% 60Co • 21% 137Cs • 19% 90Sr • 45% 241Pu • 5% Pu (alpha emitters) • Overall specific activity limited to 0.18 Bq/g, 0.018 Bq/g of which is 60Co • 60Co still measurable with conventional instruments at these limits

11. Effect of applying IAEA limits • Activated steel with 10% 60Co and 90% 55Fe • IAEA figures limit overall specific activity to 0.999 Bq/g, 0.09 Bq/g of which is 60Co • Under SoLA, 60Co would be limited to 0.04 Bq/g for this fingerprint • Tritiated concrete: 100 Bq/g cf 0.4 Bq/g!

12. Conclusion • Nuclear industry tends to take a practical approach to the interpretation of SoLA • Revision of SoLA is of key importance to CEWG and project teams • CEWG considers radionuclide-specific limits for SoLA is a sensible way forward • Review process should not seek to lower individual specific activity limits without sound scientific justifiation

13. Workshop • CEWG hosting a workshop on implementation of the NICoP in Liverpool next February • 1.5 day event to explore practical issues regarding the release of materials from regulation under RSA ’93 and implementation of the NICoP • Seeking to engage nuclear operators, regulators, stakeholders, NDA, DEFRA and the non-radioactive waste management industry • Fliers distributed to BNES members also available from Alan Fisher