IAEAInternational Atomic Energy Agency

Summary and Overview of TECDOCRussel Edge

Decommissioning and Remediation Unit

Division of Radiation ,Transport and Waste Safety

International Forum for the Regulatory Supervision of Legacy Sites (RSLS)

Technical Meeting

Vienna Austria

22 - 24 October 2013

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CONTENT

1. Regulatory Structure

2. Environmental Impact Assessment and Safety Assessment

3. Professional Development of Regulators

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Background

• Initial input to TECDOC developed by 3 working groups

• Based upon:• IAEA guidance, requirements, other reports• Responses to Questionnaires• Information collected during WS,SV,TM• Best professional judgement

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Introduction

• Recognition of various types of legacies;

• Legacies may share common characteristics:• Unsatisfactory technical condition of the facilities; • Poor characterisation of the situation, loss of records;• Contamination of the environment (rad and non-rad);• Threat of further releases;• Unclear ownership/responsibility;• Lack of long-term site and related waste management

strategies;• Lack of regulatory requirements and guidance to address

abnormal radiation conditions and remediation.

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Regulatory Structure - 1

• Regulatory base starting from overall laws on nuclear and radiation safety and security.

• Specific laws for legacy sites management may be useful in some countries;

• Combined national strategy for waste and legacy management, or if they are separate, developed in coherence with each other; Nationally applied coherent set of requirements and criteria for legacy sites that are protective to human health and the environment, including financial surety;

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Regulatory Structure - 2

• National strategy defining roles and responsibilities; • Regulatory standards for each stage of management,

corresponding to defined end states (i.e. different types of land use);Iterative assessments at each stage;

• Early engagement and regulators’ role in strategy development;• Create a hierarchy of priorities beginning at the national level and

extending to site specific; • Regulatory authorities (experts) should be qualified for adequate

and efficient review of regulatory required documents.

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Regulatory Structure - 3

• Licensing process to ensure regulatory compliance during management of legacy sites;

• Site specific analysis to determine site specific derived standards transparently linked to the set of human health and environmental protection objectives, implemented though license conditions and site specific regulations;

• The site specific analyses should include radiological and non-radiological issues;

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Regulatory Structure - 4

• Guidance documents on application of all of the above;

• Staged intervention, staged

progression of legacy management;

• Post-remediation evaluation

processes to ensure that the remedies put in place for legacy sites remain effective.

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EIA and SA - 1

• Practical application of Safety Assessment and Environmental Impact Assessment procedures, are partly described for some Safety Cases and SA application in IAEA publications. Recognizing a wide variability in national expertise emphasis should be given on EIA and SA methodology and procedures, the IAEA’s ISAM (Improvement of Safety Assessment Methodology) experience can be adopted for legacies of mining and mineral processing operations.

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EIA and SA - 2

• General safety assessment (SA) processes that apply for planned exposure are applicable to existing exposure situations. Regulatory authority may require some special consideration in SA.

• Safety assessment is usually focused on meeting protection measures for occupational exposure or for off-site human exposure resulting from the existing impact of hazards at the legacies or during remediation .

• EIA and SA are considered as the key elements in justification of safe management of the legacy sites and supporting decision making process in remediation planning as well as selecting the remediation options (optimization) .

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EIA and SA - 3

• EIA may help to justify an optimal course of remediation, and SA may serve to control the exposures to workers, the general population and even the affected environment within each step of the remediation.

• SA and EIA are the systematic and interrelated process of evaluating the safety of a legacy site before remediation as well as to be used for quantifying hazards potential impact on human health and the environment during remediation process and after completion of the work.

• SA should be performed in a systematic manner using a graded approach, commensurate with the hazards, the complexity of the facility or activity and the characteristics of the legacies of different types.

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EIA and SA - 4

• Because many legacy sites are old, the site characterization information and data may be dated, missing, questionable, lacking quality assurance, etc Site characterization (SC) is important component of any legacy site assessment.

• SC should include historical aspects, radiological, environment and socio-economic considerations (current industrial activities at the affecting areas, land use et. sat.)

• Additional data analysis may result in revisiting SA and EIA.

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EIA and SA - 5

• The design for site specific characterization programs has to incorporate specific objectives to support SA and EIA.

• Confidence in SA and EIA depends on quality of monitoring data. Therefore QA/QC programs for monitoring have to be established.

• Recent modeling tools for SA and EIA are readily available and can be used for remediation strategy justification.

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Professional Development of Regulators - 1

• A standard training program or skill requirements should be developed for inspectors for legacy related supervision.

• Some technical and basic skills should be prerequisite for inspectors, for example:

• Radiation protection management specific to legacy sites• Curricula and training materials for each type of legacy

• Cross-cutting issues, for example training in knowledge both of radiation and chemotoxic effects on humans and the environment and training in how they are both regulated.

• Use of technical measurement instruments and PPE• Job hazard analysis• Project management• Team building skills• Public and media relations• Negotiation skills• Report writing (including regulatory improvement)• Understanding of regulatory infrastructure • Understanding of SA and EIA

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Professional Development of Regulators - 2

• Recognized qualifications from on-the-job training, including instrument use;

• Refresher training after a period of time is often necessary;

• Multidisciplinary approach to inspections is encouraged and an inspectors team should be tailored to the particular expertise that is needed;

• In addition to well qualified and trained inspectors there should be a mechanism to incorporate findings from legacy site inspections into future regulatory supervision.

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