TECDOC Presentation from WG 1: Enhancing Regulatory … Documents/Meetings… · TECDOC – Presentation from WG 1: Enhancing Regulatory Infrastructure Vladimir Romanov Moscow, Russian

RSLS-International Technical Meeting on Regulatory Control of Nuclear Legacy Sites and Waste Management 09 – 13 February 2015 - Vienna, Austria

TECDOC – Presentation from WG 1: Enhancing Regulatory Infrastructure

Vladimir Romanov Moscow, Russian Federation

Federal Medical Biological Agency of Russia


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Objective

To study and summarize experience of the regulatory bodies when planning and implementing the process of the regulatory supervision of nuclear legacy sites, and to develop recommendations on enhancing regulatory infrastructure


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Work organization (2011-2015)

Development of the questionnaire to assess the state of the national legacy regulation

Analysis and summary of materials provided by the RSLS member-states in their filled questionnaires

Development of the resume on the national strategy of the legacy regulation taking into account the questionnaire-based information

Generalization of the experience in the regulatory supervision of legacy sites using development of the normative-and-methodical framework in the Russian Federation and some other countries as an example

Development working materials of our Working Group to be included in IAEA TECDOC


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The Questionnaire to assess the state of the national legacy regulation

Questionnaire consist of 35 questions and covering the following 8 modules:

Legislative and governmental responsibilities

Responsibilities and functions of the regulatory body

Organization of the regulatory body

Authorization by the regulatory body

Review and assessment

Inspection and enforcement

Development of regulations and guides

Specification of nuclear legacy sites in your country


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IAEA documents

When preparing the Questionnaire, we took into account the relevant IAEA documents:

GS-R-1. Legal and governmental infrastructure for nuclear, radiation, radioactive waste and transport safety : requirements - IAEA, 2000

GSR Part 1.Governmental, legal and regulatory framework for safety - IAEA, 2010

WS-G-5.1 Release of sites from regulatory control on termination of practices :safety guide - IAEA, 2006


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RSLS member states filled the questionnaires (1)

RSLS member

state

Responding organization

UK RSR

Hungary National Research Institute for Radiobiology and Radiohygiene Frederic Joliot

Curie

Russia Federal Medical Biological Agency, Russian Federation

Bulgaria National Centre for Radiobiology & Radiation Protection

Norway Norwegian Radiation Protection Authority

Ukraine State Nuclear Regulatory Inspectorate of Ukraine Department of Radiation

Safety & Ukrainian Scientific and Research Institute for Hydrometeorology

Romania Romanian National Commission for Supervision of Nuclear Activities

USA U.S. Department of Energy Office of Legacy Management

Brazil Brazilian Commission of Nuclear Energy


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RSLS member states filled the questionnaires (2)

RSLS member state Responding organization

Tajikistan Nuclear and Radiation Safety Agency

Uzbekistan State Inspectorate "Sanoatgeokontexnadzorat" under the Cabinet of Ministers

Kyrgyzstan State Agency on Environmental Protection and Forestry under the Government

China Radioactive Waste Management Department, China Institute for Radiation Protection

Iraq

Zambia

Niger Ministry of Mines and Industrial development Direction of Mines

France French nuclear safety authority

Germany Sdchsisches Staatsministerium Umwelt und Landwirtschaft Archivstrasse

Australia ARPANS & Australian Government Department of Sustainability, Environment, Water,

Population and Communities

Belgium


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Types of legacy in the RSLS member states (1)

Country The presence of the uranium legacy The presence of the nuclear legacy

USA Yes Yes

UK No Yes

Bulgaria 3 sites No

Russia Yes Yes

Hungary 1 uranium mining and milling site No

Norway No No

Romania 50 uranium deposits, only two large No

Kyrgyzstan 6 sites No

Ukraine Dneprodzerzhinsk, Zheltye Vody,

some other old mines and sites

Areas affected by the accident at

the Chernobyl NPP


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Types of legacy in the RSLS member states (2)

Country The presence of the uranium legacy The presence of the nuclear legacy

China 6 uranium mining and milling facilities No response

Uzbekistan 6 sites No

Tajikistan 10 sites No

Niger No No

Zambia No No

Australia 2 sites 3 nuclear weapon test sites

Brazil 3 sites

Iraq Yes No

Germany Yes

France About 80 and 250 mining sites


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Resume Types of legacy in the RSLS member

states

Data for 19 countries


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3 main areas to be analyzed:

1. The state of the legislative and governmental framework to regulate radiation safety of legacy sites and facilities

2. The infrastructure and responsibilities of the regulatory body

3. The governmental programmes on remediation of legacy sites and facilities


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Section 5.1: Working Group 1 “Enhancing the Regulatory Infrastructure”

Annex III “WORKING GROUP I” of TECDOC describe both the Questionnaire and key features of Member State compiled responses in detail


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The state of the legislative and governmental framework to regulate radiation safety of

legacy sites and facilities (1)

The legislations of some states (USA, UK, Bulgaria, Kyrgyzstan, Germany, and France) include the specific provisions on nuclear or uranium legacy

In the majority of national legislations do not include such provisions

Despite that the available legal framework of nuclear and radiation safety regulation promotes the activity for the purpose of the legacy regulation

In all countries replied, the law establishes that the objective of the radiation safety is protection of individuals, members of the public and environment against radiation hazards both today and in future


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3 types of approaches:

The first: to adopt the special law on the specific type of the legacy (there is a law on “The Tailings and Mining Dumps” in Kyrgyzstan)

The second: To introduce the “existing exposure situation” term in the current radiation safety legislation, which will include, among others, sites contaminated following accidents and past activities of radiation facilities

The third: To carry out remediation of the nuclear and uranium legacy in compliance with the Government statements (Hungary is an example, where the remediation of the uranium facility in Pecs is carried out in accordance with the special Government Statement)


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The legislative framework established one or several regulatory bodies to assure radiation safety, including that at the nuclear legacy sites

In case of several governmental authorities, their responsibilities are statutory

In some states, the regulatory body is not statutory

For example, both Tajikistan and Hungary has the only regulatory body, which supports the common Government Policy for all radiation hazardous facilities.

There are several regulatory bodies in Russia and UK Their interaction is performed according to the “Interaction Agreement” or other similar documents


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The following provisions are statutory:

The independence of the regulatory body activity

The responsibility and obligations in respect of funding for the management of radioactive waste, that of nuclear legacy, decommissioning

The priority of the international obligations

The involvement of the public and other agencies in the regulatory process

The liability of the operator for radiation safety at legacy sites and facilities


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Resume Legislative and governmental framework

Data for 20 countries


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2. The infrastructure and responsibilities of the regulatory body (1)

Responsibilities of the regulatory body:

To develop safety principles and criteria

To establish regulations and to issue guide documents

To require operators to assess the safety

To visit the site or facility for the purpose of inspection

To impose sanctions in case of radiation safety violations

Independently notify the public about the regulatory process, to inform about the current requirements

Provide other state bodies, organizations, as well as the public, with information about the incidents

Liaise with regulatory bodies of other countries and exchange of regulatory information


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2. The infrastructure and responsibilities of the regulatory body (2)

Problems concerning to execution of supervision functions:

a lack of sufficient technical or functional capacities, required to fulfill the responsibilities for the review and assessment or inspection

there is no exact policy, safety principles and associated criteria as a basis for regulatory actions related to the nuclear legacy

there is no structure of regulatory documents

are no documents on the organization, inspection and clearance of audit results


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Resume The infrastructure and responsibilities

of the regulatory body Data for 20 countries


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3. The governmental programmes on remediation of legacy sites and facilities

Country The availability of the

national programme

Country The availability of the

national programme

UK + Uzbekistan +

Hungary + Kyrgyzstan +

Russia + China +

Bulgaria + Iraq +

Norway + Zambia -

Ukraine + Niger -

Romania + France -

USA + Germany +

Brazil - Australia +

Tajikistan +


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SECTION 2 TECDOC Summary of the regulation in state that apply

to legacy site (1)

1. In the majority of states, there are authorities responsible for the radiation safety regulation at nuclear and uranium legacy sites

2. Generally, regulatory bodies have powers and functional capacities. In some states organization of regulatory work of the regulatory bodies, which determines the safety principles and criteria for its assessment in terms of radiation safety regulation at legacy sites, is insufficient

3. Question on review of technical documentation by the regulatory body results in different reactions of the responders, because of the presence of several authorities


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SECTION 2 TECDOC Summary of the regulation in state that

apply to legacy site (2)

4. Poor development of methodical basis (regulations and guide documents) of legacy sites is obvious; so frequency of inspections at legacy sites under control is low

5. Does the regulatory body take into account safety standards and recommendations accepted internationally? – YES. However, a question arises concerning the effectiveness of their implementation in respect to legacy sites

6. The following states: USA, UK, Hungary, Bulgaria, Tajikistan, Uzbekistan (draft), Romania, China, Russia, Ukraine, Kyrgyzstan, Australia – have national programs on remediation of legacy sites


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SECTION 2.1 TECDOC DIFFERENT TYPES OF LEGACY SITES (1)

In the Russian Federation, there is no official definition of “legacy site”, however, there is a statutory concept “contaminated part of area to be remedied” in the current legislation. “Radioactively contaminated part of the site means such part of the site, which is hazardous for the public health and environment, to be subject to remediation after radioactive contamination due to manmade activity or locating especially radiation hazardous objects at this part of the site after their decommissioning”

Remediation of contaminated areas assumes to carry out under the special ecological programmes of remediation


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SECTION 2.1 TECDOC DIFFERENT TYPES OF LEGACY SITES (2)

Within the same section, we proposed to re-phrase one of the reasons leading to generation of legacy sites:

Threat of radioactivity spreading in the environment

When identifying groups of legacy sites to help organize consideration of the regulation, we proposed to include not only sites but also facilities affected by major accidents and incidents


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SECTION 3 TECDOC REGULATORY PROCESSES FOR LICENSING,

DECOMMISSIONING AND REMEDIATION OF LEGACY SITES (1)

3.1 GENERALPROCESSES

We think, the list of IAEA documents, which we can look to assist in dealing with regulatory problems, should also include the following document

WS-G-3.1 Remediation process for areas affected by past activities and accidents: safety guide. IAEA, 2007


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3.1 GENERALPROCESSES (laws, regulations, guides, licensing, inspections, remediation, post closure, remediation plans

Two types of approaches to establishing the legislative and governmental framework for the purpose of the safety regulation of legacy sites and facilities, including remediation are discussed:

The first approach: to adopt the special law or special Government Directive on the specific type of the legacy. For example, in Kyrgyzstan, there is a law on “The Tailings and Mining Dumps”, while in Hungary the remediation of the uranium facility in Pécs is carried out in accordance with the special Government Statement that specified the specific site


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3.2 COUNTRY-SPECIFIC PROCESSES

Russian Federation:

DECOMMISSIONING OF TAILINGS OF THE FORMER URANIUM MINES

Comprehensive engineering and radiation survey of site to be decommissioned

Control (supervision) of the decommissioning implementation

Control (supervision), surveillance after termination of the decommissioning operations

Release of the site from control (supervision)


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SECTION 4 TECDOC SUCCESSFUL PRACTICES FOR MANAGING AND

PREVENTING URANIUM LEGACY SITES

4.2 PREVENTING FUTURE LEGACY SITES

Successful practices for preventing future legacy sites

Establish a requirement to begin decommissioning in a timely, manner and within a short time after cessation of operations

We proposed to clarify, who establishes such specific and enforceable milestones of decommissioning (schedules)? – Operator should make this job within the decommissioning plan. Regulator should make an expert review and approve it


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Annex III “WORKING GROUP I” Analysis of regulatory and methodical

documents on radiation protection of the public during remediation of the legacy

sites (1)

ICRP Recommendations

IAEA documents on remediation of sites

The EC documents of remediation of contaminated areas

National criteria for remediation of radiation contaminated sites: Remediation criteria used by the:

United States of America German

United Kingdom Russian Federation


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Annex III “WORKING GROUP I” Normative-and-methodical documents

on the regulatory supervision of the nuclear legacy sites in the Northwest

Russia (2)

Radiation protection of workers and the public

Criteria and regulations for remediation of SevRAO sites and facilities

Organization of radiation monitoring of the environmental media at the SevRAO area

Requirements for industrial waste

Operational radiological and medical criteria


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Additions (1)

The Russian contribution to chapters (sections) WORKING GROUP SUMMARIES and/or SUMMARY AND CONCLUSIONS and/or TRENDS/ADVICES (NOT RECOMMENDATIONS)

The main areas and trends how to enhance the uranium legacy regulation globally:

Financing and development of special programs for decommissioning of former uranium mines and tailings

Analysis of all available information Explanation to the public / Outreach Adaptation of national legislation in accordance with international

standards Advises to the IAEA Establishing and maintenance of national infrastructure including

analytical laboratories for control and monitoring of remediation of contaminated sites

Potential trends in the international cooperation


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Additions (2)

We gave comprehensive answers to GENERAL QUESTIONNAIRE IAEA TECDOC for Legacy Sites (ANNEX I TECDOC), sent by Drew Persinko in April/June 2014 and Questionnaire of Working Group 3 requesting professional qualification information sent in July 2012

The representatives of Working Group I participated in:

- Technical Site Visit and Workshop on Uranium Legacy Sites in the Southwest United States, USA in Moab, Utah and Grand Junction, Colorado, USA 13 -24 August, 2012

- Technical Site Visit and Workshop on Uranium Legacy Sites Elliot Lake, Canada, April 28 through May 2, 2014

- International Workshop on Regulatory Control of Nuclear Legacy Sites and Waste Management, Moscow, Russian Federation 19 - 21 November 2014


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Conclusion

Reviewed and analyzed the legislative framework of legacy regulation

Review and summarize of the experience accumulated by the regulators of countries having nuclear and uranium legacy, when planning the such legacy management

Analyzed the experience of the regulatory supervision and monitoring of the nuclear legacy

Recommendations on enhancing the regulatory infrastructure and normative and legislative framework of the legacy management


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Thank you for attention