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