Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter.
Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.
Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.
OCR for page 125
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
OCR for page 126
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.
OCR for page 127
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-
OCR for page 128
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
OCR for page 129
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
OCR for page 130
OCR for page 131
OCR for page 132
OCR for page 133
OCR for page 134
OCR for page 135
Representative terms from entire chapter:
disposition dilemma
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
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.
