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Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
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Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
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Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
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Page 127
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
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Page 128
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
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Page 129
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
×
Page 130
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
×
Page 131
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
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Page 132
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
×
Page 133
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
×
Page 134
Suggested Citation:"7 International Approaches to Clearance." National Research Council. 2002. The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities. Washington, DC: The National Academies Press. doi: 10.17226/10326.
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Page 135

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7 International Approaches to Clearance THE GLOBAL CONTEXT Import-export activities involving recycled materials have increased greatly with the growth of international trade over the past several decades. This is particularly true for metals such as steel in which recycled material constitutes a significant fraction of the total production. It is also true for metals with high intrinsic value such as aluminum, copper, and nickel. Scrap metal is actively traded worldwide, and the amounts in international trade are measured in mil- lions of metric tons per year. The United States imports about 3 million metric tons of scrap steel per year. Both the European Union (KU) and the United States are concerned about imports of steel scrap containing radioactive material (see Box 7-1~. The amount of scrap steel employed in making steel varies markedly with the process, but on the average, scrap represents a significant component of the charge for a furnace. The percentage of recycled material is also significant for some other metals such as aluminum, copper, and nickel. These high percent- ages reflect both the inherent potential for metals to be recycled repeatedly at a cost competitive with producing metal from raw materials, which is higher than for most other materials, and the actual practice in metals production worldwide. Appendix D summarizes the work on slightly radioactive solid material (SRSM) clearance standards by various entities within the United States, as well as major international efforts. Specifically, Appendix D discusses the following documents developed by international organizations: (1) IAEA Safety Series 89; (2) EC Radiation Protection 89; (3) International Commission on Radiological Protection Publication 60; (4) reports of the United Nations Scientific Committee 125

26 THE DISPOSITION DILEMMA on the Ettects of Atomic Radiation; and (5) European Union Basic Safety Stan- dards. National and international concerns about potential problems of radioactive contamination associated with recycled metal have increased during the past decade. Several international agencies are addressing the problem, including the International Atomic Energy Agency (IAEA), the United Nations Economic Commission for Europe, and the European Commission (EC). At present, no international or national registries of missing radioactive sources are available to the recycling industry to indicate when such sources are lost or stolen and where they may enter the recycling chain. To address concerns about the import-export of metal scrap with undetected levels of radioactivity above clearance limits, the Team of Specialists on Radioactive Contaminated Scrap Metal, United Nations Economic Commission for Europe, has proposed the following (UNECE, 2001~: · The regulatory framework associated with the clearance of material should include provisions for prior notification to the receivers of the material of the origin of this material and the regulatory framework under which it is released. · When materials contaminated with naturally occurring radioactive mate- rials (NORM) are released according to a national regulatory framework, such information should also be forwarded. · As part of the "contractual" provisions, this information should be con- veyed with the released material to the successive suppliers and buyers of the metal scrap.

INTERNATIONAL APPROACHES TO CLEARANCE 127 The European Union has been establishing standards and methods of control for SRSM within Europe. Many EU countries possess nuclear power reactors and nuclear fuel cycle facilities. As these facilities are decommissioned, scrap metals and concrete are cleared from regulatory control. Some of these materials are released for restricted uses, but others are released to general commerce. The amount of potentially clearable metal from all categories of EU facilities is esti- mated at 12,700 metric tons per year, although this estimate increases to about 40,000 metric tons by 2020 from commercial power plants alone (EC, 1998b). Different clearance procedures for the release of SRSM metals are currently in use among EU countries. Delayed release and dilution have been standard practice in some. For example, 14,000 metric tons of contaminated steel scrap has been melted at a dedicated melting facility operated by Siempelkamp (Krefeld, Germany). Although most of this recycled scrap metal has been used in restricted applications, 2,000 metric tons has been released for unrestricted use. The con- tamination limits in Germany for unrestricted reuse are expressed in becquerels per gram for each radionuclide (e.g., cobalt-60 is 0.1 Bq/g). The EU member nations are in various stages of developing detailed regula- tions to implement the controlling directive from the EU Council (EU,1996), as discussed in the next section. Japan is developing similar regulations and has ongoing discussions among government organizations. Table 7-1 summarizes international activities and the status of clearance standards for SRSM in a num- ber of countries for which the committee was able to obtain information. Activi- ties of the Department of Energy (DOE) and the U.S. Nuclear Regulatory Com- mission (USNRC) are included in Table 7-1 for comparison. Generation of radioactive material outside the United States is not limited to EU member states or to commercial nuclear power operations and decommis- sioning. Nuclear weapons development has occurred in many countries over the past 60 years. China, India, and Pakistan are known to have developed and tested weapons. Clearly, radioactive materials containing significant quantities of long- lived radionuclides are located around the world. Documentation regarding radioactive material contamination exists for re- publics of the former Soviet Union, which produced 55,000 nuclear warheads during the Cold War. The Soviet Union, and later Russia, produced uranium and plutonium for nuclear weapons at three closed atomic cities Ozersk, Seversk, and Zheleznogorsk which were founded to produce weapons-grade material and reprocess civilian nuclear fuel. Some of these materials may enter commerce as SRSM if cleared from one or all of these countries involved in the develop- ment of nuclear weapons, nuclear power, and other uses of radioactive materials in industry, medicine, and research. For general information on radioactive waste management activities, the International Nuclear Societies Council (INSC) recently published an overview of radioactive waste management activities in countries with INSC member soci-

128 TABLE 7-1 International Clearance Status as of May 2001 THE DISPOSITION DILEMMA Surface Clearance Level(s) Country (Bq/cm2) Volume Clearance Level(s) (Bq/g) Belgium Case-by-case France Nuclear power industry: moratorium on generic levels; case-by-case allowed Nonnuclear power industry: case-by-case Germany Nuclide specific, based on 10 ,uSv to a person in a year. Japan No general criteria Case-by-case Nuclear power industry: moratorium on generic levels; case-by-case allowed Nonnuclear power industry: case-by-case Nuclide specific, based on 10 ,uSv to a person in a year (e.g., 0.1 Bq/g 60Co) No general criteria

INTERNATIONAL APPROACHES TO CLEARANCE 129 Basis for Clearance Situation Remarks IAEA TECDOC-855a levels used as reference levels Waste stream analysis, quality assurance, impact study, presentation to public, specific authorization SSK (Commission on Radiological Protection) recommendations. Ongoing discussions among government organizations General regulations are under review for update to Directive 96/29/Euratomb Incorporation of Directive 96/29/ Euratomb for both power and non-power industries is in preparation, planned for mid-2001 Incorporation of Directive 96/29/Euratomb is in preparation Some debate on whether to replace SSK recommended levels with EC RP 122C clearance levels Legislation targeted for 2001 IAEA TECDOC-855 dose criteria are 10 ,uSv to a person in a year, plus collective dose of 1 person-Sv or optimization Ministerial order issued Dec. 31, 1991, requested nuclear industry to implement waste stream analysis Authorized release is possible, though rarely used Generic clearance levels may be required for non- nuclear power very low level waste Updated regulations targeted for fall 2001 Authorized release is possible (e.g., 4 Bq/g 60Co for landfill or incineration; 0.6 Bq/g 60Co for metals to be melted) Clearance of sites based on 10 ,uSv/yr. individual dose Nuclear Safety Commission based clearance calculations on 10 ,uSv criterion. These agree well with IAEA TECDOC-855a with a few exceptions continues

130 TABLE 7-1 continued THE DISPOSITION DILEMMA Surface Clearance Level(s) Country (Bq/cm2) Volume Clearance Level(s) (Bq/g) United Kingdom Case-by-case basis 0.4 Bq/g for non-naturally occurring radionuclides Naturally occurring radionuclides range from 0.37 to 11.1 Bq/g, depending on the nuclide United States DOE suspension of scrap metal for DOE moratorium on metals recycling USNRC: consistent with average USNRC: no general criteria of 0.017 Bq/cm2 for transuranics, 226Ra, and others to 0.83 Bq/cm2 for most pry emitters aIAEA (1996). bEU (1996). cEC (2001). eties.i Although the summary information gives an interesting snapshot of radio- active waste management practices, the document contains no information on procedures for clearing or exempting materials from regulatory control. The committee's statement of work specifically requested a review of EU activities. The EU offers important comparisons with U.S. practices and regula- iThe INSC document is available on the Internet at <http://www2s.biglobe.nejp/~INSC/INSCAP/ Radwaste.html>.

INTERNATIONAL APPROACHES TO CLEARANCE 131 Basis for Clearance Situation Remarks Implementation of Directive 96/29/ Euratomb by incorporation of existing regulations, except disposal of waste is expected in a few months January 19, 2001; memorandum from DOE Secretary (a) Metals recycle only within DOE (b) Moratorium and . . suspension remain (c) Environmental Impact Statement needed before regulations are revised (d) Reuse of lead and lead products Table I of Regulatory Guide 1.86f for surface radioactivity Pending the improved release criteria and information management recycle of scrap metals Pending USNRC decision to establish national volumetric standards Ongoing USNRC study Basis for clearance is 10 ,uSv criterion Exemption orders exist that allow less restrictive clearance levels for naturally occurring radionuclides Other materials and equipment are released under DOE Order 5400.5,d which bases case-by-case approval on criteria of a small fraction of 1 ,uSv in a year and ALARAe Authorized release for disposal is possible on case-by-case basis d DOE (1993a). eALARA = as low as reasonably achievable. fAEC (1974). SOURCE: USNRC (2001b). tory trends, and it is a major trading partner of the United States for recycled materials, particularly metals. CLEARANCE STANDARDS IN THE EUROPEAN UNION Clearance practices in the EU are subject to a directive of the Council of the European Union, Directive Number 96/29/Euratom of May 13, 1996 (KU, 1996~. The subject of this directive is ". . . laying down basic safety standards for the protection of the health of workers and the general public against the dangers

32 THE DISPOSITION DILEMMA arising from ionising radiation." Article 3, Section (2), defines the following exemptions to practices for the control of radioactive material if specified quan- tities or concentration limits are not exceeded (KU, 1996, p. 6~: No reporting need be required for practices involving the following: (a) radioactive substances where the quantities involved do not exceed in total the exemption values set out in Column 2 of Table A to Annex I or in exceptional circumstances in an individual Member State different values authorized by the competent authorities that nevertheless satisfy the basic criteria set out in Annex I; or (b) radioactive substances where the concentration[s] of activity per unit mass do not exceed the exemption values set out in Column 3 of Table A to Annex I or in (c) exceptional circumstances in an individual Member State different values authorized by the competent authorities that nevertheless satisfy the basic criteria set out in Annex I; or (d) . . . [this item deals with sealed sources in devices that exceed the exemp- tion limits but are devices that are approved by a Member State of the KU]; or (e) . . . [this item deals with electrical apparatus that can produce ionizing radi- ation]; or (f) . . . [this deals specifically with cathode ray tubes in x-ray equipment]; or (g) material contaminated with radioactive substances resulting from autho- rized releases which competent authorities have declared not to be subject to further controls. Table A to Annex I, which lists limits by nuclide, is reproduced in Appendix D of this report (see Table D-1~. Annex I contains "Criteria to Be Considered for the Application of Article 3" in exempting a practice from regulatory control. For comparison, tables have been generated using the NUREG-1640 methodology discussed in Chapter 5 of this report assuming a dose level of 10 pSv/yr (1 mrem/ yr) total effective dose equivalent (TEDE). These dose factors are given in Ap- pendix D (see Table D-2) as information for the reader. The relationship between EU values, NUREG-1640 values, and other calculations of dose factors is dis- cussed in Chapter 5. The EU criterion of particular relevance to dose-based clearance standards is Paragraph 3, which allows member states to substitute their own limit values for those shown in Table A of Annex I, provided that both an individual dose limit and a condition on collective dose are met. The exact language of this "exemp- tion" paragraph is included in Box 7-2.

INTERNATIONAL APPROACHES TO CLEARANCE 133

34 THE DISPOSITION DILEMMA In short, two mechanisms exist in the EU for clearing SRSM materials from regulatory control: 1. Materials can be released from regulatory control if the quantities and concentrations of activity per unit mass do not exceed the concentration limits listed in Column 3 of Table A in Annex I. 2. Competent regulatory authorities may use their own assessment process, conforming to the general approach used to derive the Table A values, to decide that a proposed exempting practice is within the principal indi- vidual and collective dose limits. The EC has issued Communication from the Commission concerning the implementation of Council Directive 96/29/Euratom (EC, 1998a) describing how to implement Council Directive 96/29/Euratom (KU, 1996~. With respect to Ar- ticle 3 of the Directive 96/29/Euratom, the communication states: Article (3~2) and Annex I specify the circumstances under which competent authorities may decide that reporting is not required. Member States are al- lowed to deviate from the values in Table A of Annex I in exceptional circum- stances and subject to specified conditions. This EC communication also contains information on how the values in Table A of Annex I were calculated: The exemption levels, which apply to practices, are worked out using scenarios, pathways and formulae presented in the report published by the Commission. (Radiation Protection No. 65, Principles and methods for establishing concen- tration and quantities [exemption values] below which reporting is not required in the European Directive, Luxembourg, 1993.) A related EU directive on shipments of radioactive waste is officially titled Council Directive 92/3/Euratom on the supervision and control of shipments of radioactive waste between Member States and into and out of the Community (OJ L 35, 12.2.92) (KU, 1992). This directive controls the shipment of radioactive materials that have not been exempted or cleared from regulatory control. In addition, the Environmental Directorate of the EC has published the guidance document Radiation Protection 89: Recommended Radiological Protection Cri- teria for the Recycling of Metals from the Dismantling of Nuclear Installations (EC, 1998b), which provides activity standards for both surface and volume contamination of solid materials. These standards have been applied at several facilities in the KU. As indicated in Table 7- 1, EU member nations are in various stages of developing detailed regulations to implement Directive 96/29/Euratom. There is a lack of uniformity of views regarding standards for materials that are candidates for release from further regulatory control, as described in the paper "Management of Slightly Contaminated Materials: Status and Issues" (Pescatore, 2001).

INTERNATIONAL APPROACHES TO CLEARANCE FINDINGS 135 Finding 7.1. The EU and the IAEA have each established a dose-based standard of 10 pSv/yr (1 mrem/yr) for the clearance of materials from regulatory control. A collective dose standard is also included, expressed as a committed dose equiva- lent of 1 man-Sv per year of exposure of the affected group (100 man-rem total effective dose equivalent per year).2 Finding 7.2. The EU has derived tables using a scenario assessment process against which radioactive solid materials can be evaluated for clearance. Finding 7.3. A body of science, policy, and literature supports the development of the EU safety directives related to radioactive solid material clearance. In particular, the IAEA has developed policy guidance found in Principles for the Exemption of Radiation Sources and Practices from Regulatory Control (IAEA, 1988). 2Provisions exist in the EU safety directives for competent authorities in member states to develop alternative clearance guidance for special or specific circumstances.

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The U.S. Nuclear Regulatory Commission (USNRC) and its predecessor, the U.S. Atomic Energy Commission (AEC), have attempted since the 1970s to give greater uniformity to the policy and regulatory framework that addresses the disposition of slightly radioactive solid material. The issue remains unresolved and controversial. The USNRC has tried to issue policy statements and standards for the release of slightly radioactive solid material from regulatory control, while such material has been released and continues to be released under existing practices. In 1980 the USNRC proposed regulatory changes to deregulate contaminated metal alloys but withdrew them in 1986 and began work with the Environmental Protection Agency (EPA) to develop more broadly applicable federal guidance. In 1990 the USNRC issued a more sweeping policy, as directed by the Low Level Radioactive Waste Policy Amendments Act of 1985 (LLWPAA), declaring materials with low concentrations of radioactivity contamination "below regulatory concern" (BRC) and hence deregulated. Congress intervened to set aside the BRC policy in the Energy Policy Act of 1992, after the USNRC's own suspension of the policy. Subsequent attempts by USNRC staff to build consensus among stakeholder groups as a basis for future policy articulations were met by boycotts of stakeholder meetings, both in the immediate aftermath of the BRC policy and again in 1999 during public hearings on a new examination of the disposition of such materials. The only USNRC standard addressing the disposition of slightly radioactive solid material is a guidance document published in June 1974 by the AEC, whose regulatory authority over civilian nuclear facilities the USNRC assumed upon its creation a few months later in January 1975.

In August 2000, with another examination of this issue under way, the USNRC requested that the National Research Council form a committee to provide advice in a written report. The National Research Council established the Committee on Alternatives for Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities to address this task. The committee's task involved evaluating and providing recommendations on the history of the technical bases and policies and precedents for managing slightly radioactive solid material from USNRC-licensed facilities; the sufficiency of technical bases needed to establish standards for release of solid materials from regulatory control ("clearance standards") and the adequacy of measurement technologies; the concerns of stakeholders and how the USNRC should incorporate them; and the efforts of international organizations on clearance standards. The committee was also asked to examine the current system for release of slightly radioactive solid material from regulatory control, to recommend whether the USNRC should continue to use this system and to recommend changes if appropriate. The committee's fact-finding process included two site visits to waste brokering facilities and nearly 40 invited presentations from the USNRC, the U.S. Department of Energy (DOE), and EPA staff; stakeholder organizations; nuclear industry organizations; and other interested parties.

In conducting its study, the committee first examined the current system of standards, guidance, and practices used by the USNRC and agreement states to determine whether to release slightly radioactive solid material from further regulatory control under the Atomic Energy Act. The committee found that the current, workable system allows licensees to release material according to pre-established criteria but contains inconsistencies such that nuclear reactor licensees can release materials only if there is no detectable radioactivity (above background levels), whereas materials licensees can do so if small detectable levels are found. The committee evaluated technical analyses of the estimated doses of the final disposition of slightly radioactive solid materials. These analyses were conducted by federal agencies and international organizations, including the International Atomic Energy Agency (IAEA), the European Commission, and other groups. The Disposition Dilemma:Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities explains the committee's findings and recommendations.

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