Joint Convention Questions Posted To Belgium in 2015 Q.No Article Ref. in National Report 1 Planned Activities XI.C.1.d, p.127 Question/ It was noted in the National Report that the 2014 inspection programme developed Comment by FANC included an inspection campaign on the management of radioactive waste in Class I facilities (Nuclear) and in other lower risk facilities as some difficulties with operators were encountered. [Country] is interested to know what were the general findings and summary of this particular focused inspection programme? Answer The inspection campaign took place in the nuclear facilities producing most of the radioactive waste. This inspection campaign reviewed the whole process of radioactive waste management in Belgium and identified some areas for improvement for the licensees, the regulatory body and ONDRAF/NIRAS. It confirmed that all the major radioactive waste producers (nuclear power plants, research reactors, reprocessing facilities…) have set up a radioactive waste management system which enables them to keep a fairly complete inventory of the radioactive waste present in their facility, as requested by the GRR-2001, and to ensure that the waste is properly treated. However, some areas for improvement were identified: The radioactive waste management system should prevent duplication of inventories, and ensure the actual removal of radioactive waste. For new initiatives (modification, project, experiment…), the licensee shall specify, in the early phase, how and by whom the generated radioactive waste will be managed, i.e. by the licensee itself or by ONDRAF/NIRAS. In agreement with the current definition of radioactive waste, some licensees do not consider unused materials as radioactive waste and hence, on some sites, a large quantity of such unused material is present. The installations for the storage of radioactive waste are often undersized compared with the amount of waste that is generated from operational activities. This might create problems in cases of unavailability of treatment installations for such materials or for unavailability of transport. Sometimes “exotic” waste is present for which no solution for the processing of it is available. The operator, together with ONDRAF/NIRAS, should develop a processing solution for this kind of waste. At present, most “small-scale” radioactive waste producers have not concluded agreements (contracts, conventions…) with ONDRAF/NIRAS. Some of the aforementioned issues are addressed in a proposal of Royal Decree dealing amongst others with inventory keeping, waste storage and the capacity for it, transfer of authorisation, availability of an agreement with ONDRAF/NIRAS before start-up of operations, decommissioning and treatment of the hereby generated wastes. Q.No Article Ref. in National Report 2 Planned Activities Section K, page 127 Question/ Action XI.C.1.d) regarding the inspection campaign targeted on waste Comment management. Could Belgium summarises the lessons learned so far?. It is there a procedure to carry out this kind of inspections? Has the campaign developed in 2014 included the spent fuel management at nuclear power plants? If not, is there a similar campaign planned in the next future? Answer Please see answer to question 1. Spent fuel management was not included in the scope of the inspection campaign and no inspection campaign on this topic is planned in the short term. The safety of spent fuel management at nuclear power plants is monitored on a regular basis by Bel V. Q.No Article Ref. in National Report 3 General Page 2 (also page 92) Question/ What is the expected timing for a policy decision on high-level and long-lived Comment waste disposal? What additional work may be required to assist this policy decision? Answer The law of 3 June 2014 transposing the European Directive 2011/70/Euratom specifies that national policies and national programme have to be proposed by ONDRAF-NIRAS and approved by the Federal Government considering FANC advice. The Federal Government has announced in its governmental declaration of October 2014 that a policy decision will be taken. No timing has been indicated. We will report on the actual situation at the review meeting. Q.No Article Ref. in National Report 4 General K, Page 114 Question/ How much of the country is underlain by this type of clay? Comment Answer Large part of northern Belgium is underlain by this type of clay. No formal delineation of potentially suitable zones has yet been made. Q.No Article Ref. in National Report 5 General B, 16 Question/ For how long is interim storage of Category B and C waste envisaged? Comment Answer For category B waste interim storage is envisaged till the moment a deep repository is operational (not before 2035). For category C waste an interim storage period of 60 years is envisaged for cooling of the heat-emitting waste, before disposal in clay can be realised (not before 2070). Q.No Article Ref. in National Report 6 General B, 17 (II.B.2.b)7.b) Question/ What guarantees are in place for waste producers that they will not overpay for Comment interim waste storage if there is delay in establishing disposal facilities for Category B and C waste? Answer There is no guarantee that the producers will not have to pay more if there is delay in establishing disposal facilities. Q.No Article Ref. in National Report 7 General Pages 25-26 (IV.B.3) Question/ Will timeframes for UMICORE’s long-term management plan be set out in the Comment second waste plan? What level of community engagement is expected? Answer The aim of the second waste plan is for ONDRAF/NIRAS to propose a long-term radioactive waste management policy to the Federal Government, after a Strategic Environmental Assessment procedure (as required by law), including public consultation steps and asking the advice of the Federal Agency for Nuclear Control. Community engagement will be a specific point of attention, as it already was in the past, when a local platform of dialogue and communication in the municipality of Olen was created that was operational in the period 2004 – 2008. Q.No Article Ref. in National Report 8 General Page 32 (V.B.3.a) Question/ Other than Luxemburg, how many countries have approached Belgium to discuss Comment the long-term management of their waste? What is the Belgian process for reviewing consignment applications from other countries? Answer No other countries have approached Belgium. The Belgian government has exceptionally, and due to the small quantities, accepted to treat and take in charge the radioactive waste coming from the Grand Duchy of Luxemburg. Q.No Article Ref. in National Report 9 General Page 33 (V.B.3.a) Question/ What is the process for consigning waste that has not been detailed in the waste Comment plan (e.g. unwanted accumulations) to ONDRAF/NIRAS? Answer In case that unwanted accumulations should occur, the safety authority FANC can oblige the waste owner, for reasons of facility radiological safety, to declare the accumulated radioactive waste to ONDRAF/NIRAS for transfer to ONDRAF/NIRAS. New legal elements are also in preparation to enhance the regulatory means and mechanisms to avoid such situations. In addition, the FANC and ONDRAF/NIRAS organise common inspection campaigns in nuclear facilities to control and assess situations in order to avoid such unwanted accumulations of radioactive waste. Q.No Article Ref. in National Report 10 General I.B.3.a, p5 Question/ Using advanced decontamination techniques Belgoprocess realised to minimize the Comment amount of radioactive waste to less than 5 % of the total quantity of produced materials. What are advanced decontamination techniques? What kinds of second wastes are produced during decontamination? What is the total amount of second wastes? Answer The figure of 5% is based on the total amounts of metals and concrete produced and released from decommissioning of the former Eurochemic pilot reprocessing plant till 2012-2013. Depending on the kind of material (metal or concrete) and the potential risk of contamination after dismantling and decontamination (intrinsically not-contaminated or a fraction is still contaminated) the following installations are used for free release purposes: A. The abrasive blasting installation (decontamination facility) is used to remove a thin layer from contaminated metal components and concrete objects: % release ~70% B. The concrete crushing and sampling installation (in fact not a facility for decontamination) and is used as the final measurement of intrinsically notcontaminated concrete before unconditional release of concrete debris: % release ~99% C. The "Concrete Spec" installation (in fact not a facility for decontamination) is used to separate the contaminated part from the non-contaminated part of concrete debris: % release ~70% For A+B+C (metals and concrete): o Processed : 10984 ton o Unconditionally released: 10347 ton o % release ~94% A1. Results after 5 years of experience in abrasive blasting of metal material At the end of May 2001, after 6 years of operation, 523 tons of contaminated metal has been treated. About 12 tons of metal grit was required to obtain the result as indicated. During the operations an additional 7 tons of protective clothing was produced as secondary waste, bringing the total amount of secondary waste production at 3.6 %. A2. Decontamination of concrete blocks in the abrasive blasting installation 130 tons of concrete and heavy concrete blocks were decontaminated in the abrasive blasting installation. The total amount of secondary waste produced was 16 tons, including grit material and material removed from the concrete surfaces as a result of the decontamination process. During the operations an additional 360 kg of protective clothing was produced as secondary waste, bringing the total amount of secondary waste production at about 13 %. Q.No Country Article Ref. in National Report 11 General I.B.3.b, p5 Question/ The objective of the decommissioning of BELGONUCLEAIRE MOX fuel Comment fabrication facility is to reach the unconditional release of the buildings and of the site by the end of 2015 What are the specific requirements about the unconditional release in Belgium? Answer Reference clearance levels as mentioned in the RP113 publication were used for surface measurements. For volume samples of building materials, the values described in the Belgian regulations (article 35 of the GRR-2001) for clearance of solid radioactive substances are used. Concerning the unconditional release of sites, no generic clearance levels are defined up to now. Clearance levels are defined by the use of exposure scenario’s and site models developed by the licensee and to be approved by the FANC on a case-by-case basis. Q.No Article Ref. in National Report 12 General I.B.3.c, p6 Question/ Following review of the license application by the FANC and the Scientific Comment Council, and following consultation of the local authorities, the decommissioning license was granted by Royal Decree in May 2012. How many licenses need to be applied during a nuclear facility decommissioning? Answer What are the related requirements of each license application? The termination of activities itself don’t need a license. However, for performing preliminary decontamination and/or other preparation works during the period between the end of operation and the dismantling, the operating licence may be amended either on request of the licensee and/or on the initiative of the FANC. A (unique) specific license is required for the dismantling of one or more installations of a nuclear facility. Usually, the license conditions include the WENRA safety reference levels on decommissioning, a particular authorisation for clearance of materials from the dismantling operations and possibly additional administrative requirements such as holdpoints between the dismantling phases. At the end of the dismantling operations, a royal decree is needed to remove the facility from the list of nuclear installations. This decree is granted on the basis of a final dismantling report which includes a radiological characterisation of the site. Q.No Article Ref. in National Report) 13 General I.B, p9 Question/ Is there any broken spent fuel unloaded from Doel plant? Comment If there is, how to consider about the containment of the radioactive material? Answer There are some leaking fuel elements in the ponds of Doel power plant. The chosen solution to manage these materials is to extract the damaged rods from the assemblies and to encapsulate them in leaktight canisters. Q.No Article Ref. in National Report 14 General XII.C.1, p129 Question/ The building 136# is equipped with a complex ventilation system. The air renewal Comment rates are 4-33/hours for the storage bunkers 140/141 and the difference of the air renewal rates is larger. What situations is the different air renewal rates used in? Answer The building 136X is equipped with an emergency cooling system designed for time-limited cooling operation while ensuring no structural damage to the waste canisters and the building. The air renewal rates are adjusted in function of the thermal load. As the canisters cool the renewal rates will also decline. Q.No Article Ref. in National Report 15 General XII.C.1, p145 Question/ In figure 24, the drums are stacked 4-high in bunker, fixed measures are not used. Comment What is the consideration about the affection of the earthquake to the stacked drums? Answer A study on the behaviour of various types of stacked drums during an earthquake is pending. Preliminary results indicate that up to intermediate level earthquakes no significant damage (i.e. no falling drums) is to be expected. Q.No Article Ref. in National Report 16 General XII.C.6, p153 Question/ In building 155#, there are non-standard packages. Please give more information Comment about the packages just like the information given in Table 8. How to treat the nonstandard packages and the waste in these packages subsequently? Answer The building 155 is only used for the storage of conditioned waste. The packages currently stored in this building are : Packages Material Matrix 400 ℓ Steel Bitumen, cement and cover overpack 700 ℓ Steel Cover overpack The non-standard packages (the last four packages mentioned in table 9 on page 153) are not yet stored in building 155. These packages are subject of (near) future projects. The waste in the packages stored in building 155 is no longer subjected to further subsequent treatment. Q.No Article Ref. in National Report 17 General XII.A, 137 Question/ What technology is preferred in Belgium for condition (solidification) sludges and Comment ion exchangers to be meet acceptance criteria for disposal? Answer Due to the discovery of a gel like substance on the surface of the immobilization matrices of conditioned waste packages containing concentrates and ion exchange resins from nuclear power plants, all treatment and processing of this waste type is currently under review. The sole treatment and processing methods which are still qualified by ONDRAF / NIRAS, is a cementitious matrix on basis of CEM II/A 42,5 N LA. This method is used by the Tihange nuclear power plant. Q.No Article Ref. in National Report 18 General XII.B, 137 Question/ What results are reached of final products of conditioning sludges and ion Comment exchangers with regard to their mechanical stability and leachibility ? Answer The Waste Acceptance Criteria issued by ONDRAF / NIRAS generally specify: - For the primary packaging: “6.2 Mechanical resistance The primary packaging must comply with all criteria, and in particular the drop test and the stacking test, required for a type 2 industrial transport package (type IP·2), as defined in the international transport regulations "IAEA Safety Standards Series TS-R-l : Regulations for the safe transport of Radioactive Material 2005 Edition" (see § 622 of TS-R-l). The maximum mass of the primary package must be taken into account for the drop test.” - For the primary package: “8.7 Criteria governing the mechanical strength of the primary package 1. The primary package may not be deformed and must retain its integrity under the stresses to which it is subjected during transport and interim storage. 2. For the criterion concerning the resistance to stresses to which it is subjected during interim storage, the primary package must resist a stress originating from a "one-an-one" or "one-an-two" stacking, maximum 6 layers high. 3. The primary package must be designed and manufactured to retain its integrity under the stresses to which it is subjected when removed from storage and taken” - For the waste form : “7.3 Compressive strength of the waste form The waste form must have a minimum average compressive strength of 20 N/mm2 at the moment of transport. The test procedure to determine the compressive strength, to be approved by ONDRAFfNlRAS, must be included in the "qualification file". 7.6 Leaching The encasing capacity of the immobilization matrix shall be demonstrated by a leach test. The test method must be described in the "qualification file". The results of this test are indicative.” The leaching test and criteria is currently under revision. Q.No Article Ref. in National Report 19 General Sec.K-XI.A,XI.B,XI.C:p.113-130/XI.A,XI.B Question/ According to the new Guidelines regarding the Form and Structure of National Comment Reports (INFCIRC/604/Rev.3 Draft 3), Belgian Section K has been properly written up and includes in detail all challenges of Final Plenary 21 May 2012. Answer Thank you for your comment. Q.No Article Ref. in National Report 20 General I.B.2, p.3 Question/ Immobilization in cement is commonly used for conditioning of concentrates and Comment ion exchange resins. Could you please, provide some further information, with respect to the specific causes of the gel-like material formation and also for the safety implications of this phenomenon on operational safety of the interim storage and on the safety of final disposal? Answer In March 2014 ONDRAF / NIRAS organized an ‘International Expert Panel on waste drums showing gel formation’. The experts have different backgrounds and fields of knowledge and are linked to different institutes. The panel represents a mix of non-nuclear institutes (universities), ONDRAF / NIRAS peer organizations and nuclear research facilities. Based on the information available (observations from inspections and experimental results available so far) the experts believe it is a very credible hypothesis that [an] Alkali-Silica Reaction (ASR) is [at] the origin of the observed gel formation. The high amounts of sodium hydroxide added to neutralise the waste stream and the siliceous coarse and fine aggregates [used during the production of the matrix] are probably the root causes. The high temperature at which the concrete was poured and the highly variable composition of the waste stream rich in sodium salts (chloride and sulfate) have also likely contributed to the gel formation. It is however not a ‘classic’ ASR process in the sense that the gel composition is outside the usual ranges reported in the literature, its production seems in some cases to be very rapid and boron might be involved in the gel formation or its stabilisation. As for the operational safety of its interim storage facilities, ONDRAF / NIRAS concludes that the waste packages showing gel formation do currently not pose a safety risk. For the long term management point of view, ONDRAF / NIRAS deems the affected waste packages as not suitable for disposal in neither a surface nor a deep repository. See also the answer to question 36. Q.No Article Ref. in National Report 21 General I.B.3.d, p.6 Question/ In your report it is stated that Ghent's University Health Physics Department Comment "remains fully functional and has been expanded to deal with the increased work in waste management and clearance resulting from the dismantling activities. " Could you please provide more information regarding the expansion of the Health Physics Department, for example, regarding the increase in staff number, the new expertise needed and its dismantling-specific duties? Answer In order to cope with the increased workload in waste management and clearance resulting from the dismantling of reactor Thetis, the Health Physics Department has taken the following steps: - purchase of a mobile gamma-spectrometer, to enable measurement of all produced waste during dismantling operations. - increase of staff by employing one FTE during 5 years for: o calibrating the ISOCS equipment, o Monte-Carlo calculations of the different solid waste categories in standard 200l waste barrels (metal, concrete, asbestos, low-density waste for incineration), o standard measurement of sampled liquid waste, o performing the ISOCS measurements of all waste produced during dismantling (> 800 barrels). - the Health Physics Department (3 people) performed continuous on-site radiation protection measurements and triage of all produced waste during the dismantling. Although this significantly increased the workload by about 50 %, it enabled immediate actions to be taken on the floor when problems arose (since all people responsible were available on the spot), and avoided delayed triage of produced waste, thus keeping the working area free of debris. Q.No Article Ref. in National Report 22 General II.B.2.b), 7c , p.18 Question/ In your report it is stated that "On request of ONDRAF/NIRAS, the waste Comment producers have started to pay for future storage and disposal services from 1985 onwards." Could you please specify what portion of this fund comes from nuclear energy sector and what from the producers of institutional waste (i.e. medical, industry, research)? Answer Roughly 50-50%. Q.No Article Ref. in National Report 23 Article 4 VII.A.1.b), p75£»VII.A.1.c), p76 Question/ On the site of Doel and Tihange, the intermediate storage buildings as well as the Comment installations and systems integrated in these buildings have been designed and built according to the safety principles, the general design criteria, and the building standards in force at the time when the nuclear power generating units were designed and built. The designing of these buildings complies with the provisions set out in the GRR-1963, now replaced by the GRR-2001 Is the performance of the building necessary to comply with the requirements of GRR-2001? If yes, but the requirements of GRR-2001 are not met, what measures have been taken? Answer Design criteria in GRR-1963, as well as in GRR-2001 mainly address radiation protection and organisational aspects. Design bases are defined in the safety report which is an integral part of the authorisation. The PSR specifically verifies the safety level of the installations wrt the existing authorisation and with new legislation. An appropriate action plan may be set up to address shortcomings in the design. Q.No Article Ref. in National Report EBL/IA(NBI)/NIRAS 24 Article 4 VII.A.1.c) (2), p77 Question/ On the Doel site, an intermediate storage in the building SCG was constructed for Comment interim dry storage of spent fuels from NPPs Doel 1-4. The containers are dualpurpose for both storage and transportation. How long is the designed lifetime of the containers? How long is the duration of interim storage? What will be done when spent fuel storage period beyond the designing interim storage duration? Answer The design life time of the containers is of 40y. The duration of the interim storage isn’t yet clearly defined. The ageing of the casks is monitored and so far no indication has been found that the 40y lifetime of the casks could not be extended. Q.No Article Ref. in National Report 25 Article 4 D, pg. 134 Question/ The "Reference Framework for the long-term management of all radioactive waste Comment in Belgium" will be issued by ONDRAF/NIRAS by the end of 2014. Please elaborate on the Reference Framework at your National Country Presentation at the Fifth Review Meeting. Answer This will be elaborated during the review meeting. Q.No Article Ref. in National Report 26 Article 5 G, 79 Question/ Does the update of the safety review take in consideration Operational experience, Comment including international feedback experience? Answer Yes. In 2007, the FANC has required that the future safety reviews of all nuclear units, including waste facilities and spent fuel storage facilities, are carried out by using the IAEA Safety guide NS-G-2.10 (now SSG-25). Operational experience, including international feedback experience is a safety factor (N° 9) listed in the SSG-25 Safety Guide. Q.No Article Ref. in National Report 27 Article 6 G, 83 Question/ ‘Due to the population density in the vicinity of the sites, and also considering the Comment impact that the local industrial activities may have on the power stations, specific requirements were adopted’ How do you control the development around the nuclear installations? Answer Thanks to a cooperation agreement between the federate State, the Flemish Region, the Walloon Region and the Brussels Capital Region of 21 June 1999 on the control of major accidents involving dangerous substances, the FANC has an advisory competence with regard to any new license related to existing or new branches of a facility containing involving dangerous substances and which are located within a radius of 2 km from the nearest boundary of a Class I facility. In this way, the FANC can ensure that the safety of the nuclear facilities is not endangered by additional industrial activities Q.No Article Ref. in National Report 28 Article 7 p. 88 (Section G) Question/ Spent fuel management Comment Spent fuel arising from the Doel NPP is stored in casks in the spent fuel containers storage building (SCG). Is it allowed to store defective fuel there? What is the repair concept for a leaking cask? Answer Leaking fuel assemblies are not allowed to be loaded in the casks. The leaking rods are extracted from the fuel assemblies and conditioned enabling their loading in the dry storage casks. See also answer to question 13. Q.No Article Ref. in National Report 29 Article 7 Subsection VII D 1, page 85 and 88 Question/ Point (3) regarding the new intermediate storage building at Doel NPP (SCG) Comment mentions the consideration of the airplane crash within the category 4 of accidents. Could Belgium provide information on how this accident has been considered in the safety evaluation of this building? Answer The intermediate storage at Doel NPP provides protection against aircraft crashes through the design and construction of the dry storage casks. The building itself is not designed to provide this protection. Q.No Article Ref. in National Report 30 Article 9 p. 135 (Section L) Question/ Stored spent fuel Comment The report says: “Any possible effort is paid to guarantee the extended life of the stored SF elements and to investigate information regarding the best practices abroad and experience gained in countries” Could Belgium please provide more specific information about these actions? Answer The storage conditions of the spent fuel are well controlled. The water chemistry of the centralised storage pool is closely monitored. Cavity of the dry storage casks is filled with He. A regular literature survey on storage experience is performed as well as exchanges in specific working groups of cask users. Q.No Article Ref. in National Report 31 Article 10 Section K: XI.A.1.a): pp. 113 to 114 Question/ The federal government has not yet taken a policy decision on the basis of Comment ONDRAF's Waste Plan, and no decisions have been taken at this moment w.r.t. the statute of the spent fuel (reprocessing or direct disposal). Could Belgium give information on when a decision should be made? Answer See the answer to question 3 Q.No Article Ref. in National Report 32 Article 11 B, page 15 Question/ In its Waste Plan, ONDRAF/NIRAS proposes that high-level and/or long-lived Comment radioactive waste will be disposed of in a unique repository located at depth in a poorly indurated clay formation on the Belgian territory. The development and implementation for this solution should take into due consideration societal conditions linked to reversibility, retrievability, control and knowledge maintenance and transfer. Are there already ideas regarding reversibility and retrievability of the radioactive waste for the consultation with the stakeholders. If yes, could Belgium describe the key aspects of it? Answer The law of 3 June 2014 transposing the European Directive 2011/70/Euratom specifies that the disposal of radioactive waste may not prejudice retrievability. Conditions related to reversibility and retrievability will be fixed in the national policies to be approved by the Federal Government (see also answer to question 3). We will report on the actual situation at the review meeting. Q.No Article Ref. in National Report 33 Article 11 VII.A, 93 Question/ What are your opinions with minimization of production of solid radioactive Comment waste? What technologies you prefer for such minimization in Belgium? Answer The first step in minimization is the prevention and reduction of the amount of solid radioactive waste initially produced. NIRAS encourages a prevention and recycling policy at the waste producers sites. When waste is produced, the second important step is the identification and the sorting (for example separating combustible and non-combustible materials). Combustible waste can be incinerated in the CILVA-installation yielding in a high volume reduction factor. Besides incineration, supercompaction is frequently used as a minimization technique. Q.No Article Ref. in National Report 34 Article 11 Sec.A:I.A. p.2 / Sec.K: XI.A 1.b) p.114 Question/ No policy decision for the long-term management of high-level and/or long-lived Comment radioactive waste has been taken till now (September 2014). Coud Belgium give information on when a decision should be made? Answer See answer to question 3. Q.No Article Ref. in National Report 35 Article 12 H, page 95 Question/ In 2003, ONDRAF/NIRAS and Belgoprocess started a visual inspection Comment programme for all the stored conditioned waste drums. In total, 40412 conditioned waste packages were inspected. In case of observations of non-conformities with the waste acceptance criteria (e.g. degradation of waste packages due to corrosion phenomena) specific measures are taken. How many waste packages did not fulfil the WACs? Which measures will be taken for these waste packages in detail? Answer In 2003, ONDRAF/NIRAS launched an inspection programme to draw up an inventory of the physical state of the temporarily stored conditioned radioactive waste packages. The inspections started early May 2003 and were concluded by the end of December 2010. About 4% out of a total of 40412 packages were found not to be in conformity with the waste acceptance criteria. In function of the observed non-conformities, specific actions have been defined: • Cemented conditioned waste: external corrosion phenomena without loss of confinement. A follow-up for these packages takes place provided that these phenomena do not increase the safety risks for the storage building. • Heterogeneous bituminized conditioned waste packages (LLW): these packages mainly show distortions and bitumen overflow owing to internal gas production. The following reference solution was chosen for these packages: placing the packages in an exterior packaging without immobilizing them and after removing the bitumen that may have overflown; punching (puncturing) of the bitumen package lid in order to avoid distortions and bitumen overflow in the exterior packaging in case of gas production and, consequently, overpressure in the package; closing of the exterior packaging by a lid equipped with a microfilter; once placed and stored in an exterior packaging, a number of test packages will be regularly inspected in order to verify in particular the possible overflow of bitumen in the packaging. The current disposal concept consists of post-conditioning these bituminized waste in concrete monoliths specifically designed for geological disposal. Q.No Article Ref. in National Report 36 Article 12 Sec. A: I.B.2 p.3/Sec.K:XI.C.2.a)-p.128 Question/ During a routine inspection of conditioned low-level waste packages, a yellow gelComment like material was found on the outer surface of the lid of a waste package. This waste package, a 400-liter drum with borated evaporator concentrate immobilized in concrete and produced in 1995 by the nuclear power plant of Doel1 was taken out of interim storage and opened by way of removing the lid. The gel-like substance was found on the whole of the surface of the concrete matrix. An alkali-silica reaction (ASR) has been identified as the most likely root cause for this phenomenon. How could Belgium explain that there is no such reaction in other packages? Answer The waste packages exhibiting gel formation at the surface of the conditioning matrices were all produced by the Doel nuclear power plant. The addition of sodium hydroxide in excess to neutralise the boric acid present in the waste stream, and the reactive siliceous coarse and fine aggregates used during the production of the concrete matrix are probably the main cause of the ASR. The problem was also likely exacerbated by the presence of borate, the high temperature at which concrete was poured and by the highly variable composition of the waste stream rich in sodium chloride, sulfate and other salts. The current treatment and conditioning process used by the Tihange nuclear power plant do not use aggregates but only pure cement. This may explain the absence of any visible gel formation in the inspected waste packages coming from the Tihange nuclear power plant. However, all treatment and conditioning processes in Belgium are currently under review in order to assess the potential risk of ASR and other adverse effects. See also answer to question 20. Q.No Article Ref. in National Report 37 Article 12 p. 95 (Section H) Question/ Visual inspection programme Comment In 2003, ONDRAF/NIRAS and Belgoprocess started a visual inspection programme for all stored conditioned waste drums. During the programme that was finalised in 2010 about 40,412 conditioned waste packages were inspected. Can you give some information about the outcome of this programme? Does the new programme refer to the same waste packages? Is bituminised waste qualified to fulfil the acceptance criteria for disposal in Belgium today? Answer See answer to question 35 Q.No Article Ref. in National Report 38 Article 12 II.B.2.b, p.18 Question/ Noting that an insolvency fund has been set up in order to mitigate the Comment consequences of bankruptcy or insolvency of a waste producer and in the case a polluter cannot be identified, the cost would be recovered from the insolvency fund. Acknowledging that the professional federations from the metal sector, the waste treatment and the recycling sectors have signed the agreement regarding the tracking and management of radioactive material and objects outside of the nuclear sector, Ireland is interested to know if this agreement led to the recovery and declaration of more orphan sources as expected? Answer Yes, we can see a clear increase of the quantity of collected orphan sources. We will report on the experiences at the review meeting. Q.No Article Ref. in National Report 39 Article 13 ¢ø.C.2b, p102 Question/ It is mentioned that the repository at Dessel will provide a solution for disposal of Comment the Belgian Category A waste. Is there a sitting criteria of waste repository for category A waste in Belgium? If there is, what is the content of the criteria? Answer No formal siting criteria have been formulated for siting the surface disposal facility for category A waste. ONDRAF/NIRAS has applied in the past 5 geological & hydrogeological criteria to identify potentially suitable sites. As the Dessel site (where the surface disposal facility is intended to be constructed) was a candidate site a “system approach” has been followed: design modifications have been introduced to take account of less favourable site characteristics, e.g. with respect to efficiently monitor in the environment the good function of the disposal facility. Q.No Article Ref. in National Report 40 Article 16 H, pg. 113 Question/ The knowledge preservation of the different parties involved in the construction or Comment in the modification of the installations must remain available throughout the operational phase to address any safety-related problems. Please elaborate on how this knowledge is maintained throughout operation of the facility. Answer When a new installation is built, the licensee will ensure that all construction records of the installation are preserved in a so-called “construction file”. This construction file contains all technical and safety-related information on the installation and is based on information from the engineering firm involved & manufacturers. During the commissioning of a new installation, a check is made that all necessary documents have been included in this construction file. A similar process is to be used when modifications are done to installations. The licensee has to document all information on the modification in a so-called “modification file”. As part of the commissioning of each modification, this file is checked on their completeness. These files are part of the document management system of the licensee and in this way should remain available throughout the whole operational phase. Q.No Article Ref. in National Report 41 Article 19 E, page 32 Question/ The residues originating from industrial activities using natural radioactive Comment materials belongs to the competences of ONDRAF/NIRAS, once the FANC has classified them as radioactive waste for reasons of harmfulness for public health. Which quantities of NORM waste, which are treated as radioactive waste, arises in Belgium? Answer At the moment only very limited quantities of NORM waste (order of magnitude a few m³) are managed as radioactive waste. The assessment (on the basis of the regulatory elements to be developed) of how to manage in the long term the large quantities of NORM still has to be done. ONDRAF/NIRAS report “Reference framework for the long-term management of radioactive waste in Belgium” constitutes one of the preparatory steps of this assessment. See also the answer to question 25. Q.No Article Ref. in National Report 42 Article 19 V.B.3.b, p33 Question/ The waste producers have to bear the complete cost of the long-term management. Comment By this formula, the waste producers obtain a guaranteed discharge of their waste, but also after the transfer of the waste to ONDRAF/NIRAS they remain accountable for the total cost of the long-term management. What is the mode of the cost paid by waste producers to ONDRAF/NIRAS, one time or several times payments? Answer At the time of the transfer, the producer has to pay in once the tariff covering the complete costs of all activities needed for the management of the waste. Based on the Royal Decree of 25 April 2014 (see I.B.5), with a maximum periodicity of 5years ONDRAF/NIRAS will re-evaluate the tariff and apply it to all the waste – produced and still to be produced- leading to corresponding payments. Q.No Article Ref. in National Report 43 Article 19 Section E, page 33 Question/ The Report says that ONDRAF/NIRAS is entrusted with all the radioactive waste Comment (or all the fissile material) that needs to be disposed of in the future, in exchange of full financial guarantees from the waste producers with the aim to cover the costs of its future management (cf. the Long Term Fund, see below). The waste producers have to bear the complete cost of the long-term management. By this formula, the waste producers obtain a guaranteed discharge of their waste, but also after the transfer of the waste to ONDRAF/NIRAS they remain accountable for the total cost of the long-term management. This is guaranteed by a contractual tariff system that is re-evaluated every ten years in order to determine the remaining cost of the long-term management and by a clause of hidden defects, for which the waste producers remain accountable for 50 years. With this system the population gets the guarantee that the management of the public interest will prevail over private interest. Could you please elaborate whether RW management activities (including RW disposal and decommissioning) of ONDRAF/NIRAS being a public institution are taxed similar to any other commercial nuclear activities? Are there any economic advantages or benefits provided to ONDRAF/NIRAS to support its mission? Answer There is no economic advantage provided to ONDRAF/NIRAS which has to work at cost, without benefice. Radwaste management activities of ONDRAF/NIRAS are taxed similar to any other commercial activities. Q.No Article Ref. in National Report 44 Article 20 Section K: XI.A.1.d) - p.118 Question/ Transparency is a key value of the regulatory body. As such, the different stress Comment test reports and the post stress test national action plan are released in full to the public and media through the FANC website (http://www.fanc.fgov.be). Could Belgium develop how transparency and openness measures are implemented in this context? Answer Since 2011, the Federal Agency for Nuclear Control communicates openly on its website, where information about the Stress-tests is accessible in an online dedicated webpage. Several information meetings for the general public have been organized on demand from the mayors of the areas and committees related to the involved installations. Furthermore, the communication unit of the FANC is available to address the issues of the public of from journalists. Q.No Article Ref. in National Report 45 Article 20 V.C.1, p.41 Question/ According to article 9 of the law of 15 April 1994, the nuclear inspectors are Comment nominated by the King. Ireland is interested to know how does this process work in practice taking into account qualifications, training, experience and competencies. Answer This nomination is the results of two internal (FANC) sub-processes: firstly, recognition as a FANC expert (technical competencies) and secondly, an accreditation as a candidate nuclear inspector (inspection & enforcement competencies). The technical competence requirements of the sub-process "Recognition" are based on requirements of the article 73 of the GRR-2001 which deals with the recognition of “Health Physics experts”. The sub-process "Accreditation" is a complete internal sub-process that is focused on the competencies of the expert on inspection practices and enforcement measures. The sub-process requires a number of training hours in those matters (which is linked with the training program). The FANC expert requests his accreditation to the FANC management committee (composed by the FANC general manager and others FANC department managers). In case of approval, the FANC expert becomes a candidate nuclear inspector and his name is included in the list of nuclear inspectors that is proposed to the Minister and to the King. Q.No Article Ref. in National Report 46 Article 23 VI.E, 61 Question/ Are in Royal Decree also included rules for rescue service? Comment Answer Rules of engagement and guidelines for the first responders and rescue teams are established (Directive of the FANC 17/10/2003). An emergency first responder (or responder subjected to emergency exposure) in emergency situation is any person taking part into the implementation of protective actions aimed to: - rescue persons, - prevent the exposure of a large number of people, - protect a critical (economically speaking, for security or safety reasons…) facility , and during which one of the doses limits for the professionally exposed workers (e.g. 20 mSv) might be exceeded. In that case (Responders subjected to emergency exposure), specific conditions are required (such as to be voluntary) and defined in this FANC Directive. In these circumstances (emergency exposure), an effective dose of 250 mSv should not be exceeded although this is not a strict cut-off. The objective should preferably be limited to 50 mSv by organizing shifts, limiting the intervention time or using shielding. Exceptionally and only for live saving actions it could be possible to exceed 250 mSv but first responders should avoid getting more than 500 mSv but for life saving only. The ALARA principle remains valid. After an intervention emergency workers will be considered as professionally exposed people and benefit of the medical follow-up and information. A working group is preparing supporting materials (documents, training…) based on the list of the various expected missions to be performed by first responders and on the associated conditions to perform them (personal dosimetry, personal protection equipment, derived OIL…). In the post-accidental phase, when the emergency phase is over, the limits for professionally exposed (namely 20 mSv/12 consecutive month periods) will strictly apply for recovery actions. The civil protection will organise the distribution of personal dosimeters to first responders who are not equipped with such devices; they will organize the collect of the dosimeters after intervention, register the exposure value and, if relevant, zero the system for the next user. Doses received by the first responders during the emergency and by people involved in recovery actions will be recorded in the centralised database of professionally exposed workers managed by FANC. Q.No Article Ref. in National Report 47 Article 23 VI. E, 67 Question/ People are informed in case of some extraordinary event by the various channels, Comment for example by TV. How to pass information to the deaf people? Answer An automatic system called BE-ALERT ( http://www.be-alert.be) has been developed to inform the population in case of emergency. People having registered on the webpage providing their coordinates (address and mobile phone number) will receive, when they are concerned by an emergency, according to their registered preferences a vocal message on their home or mobile phone or a written message by SMS on their mobile, e-mail or fax. SMS is probably the best suited for deaf and hard-of-hearing people. A video is available on this website in sign language to demonstrate how to proceed: ( http://centredecrise.be/fr/content/be-alert-soyez-alerte-en-situation-durgence ) Q.No Article Ref. in National Report 48 Article 24 VI.D,63 Question/ During the receipt, transfer and storage operations the workers are equipped with Comment individual neutron (bubble type detectors and/or electronic dose meters) and gamma dose rate meters. Is there a list of activities or areas with the duty to use personal electronic dosimeter? Who’s responsible for decision making process? Answer For official occupational dose registration, dosimeters recognized by the FANC have to be used in controlled areas. For ALARA purpose, the licensee can decide, based on the risk, to provide the workers with one or more additional dosimeters in order to have a closer follow-up of the doses (for example use of a bubble dosimeter in neighbourhood of neutron sources, personal electronic dosimeter in workplaces with relatively high dose rates). Q.No Article Ref. in National Report 49 Article 24 VI.D, 64 Question/ On a voluntary basis, facilities apply a dose constraint for the individual dose. In Comment practice, for all nuclear facilities, this is about the half of the dose limit. On what basis is the dose constraint set? It is not specific for particular workplaces? Answer The dose constraint is set by the licensee, based on what is feasible according to the ALARA principle. Usually, the dose constraint is set for the whole nuclear facility (which may include different installations). However, the highest doses near to the dose constraint are most of the time only reached in one or more particular installation(s) or workplace(s), and only for a small number of the workers. In addition, the Health Physics Department can fix daily dose constraints. This system allows a closer follow-up of some specific irradiating activities. Q.No Article Ref. in National Report 50 Article 24 VI.D, 64 Question/ The medical examination is at least once a year and each 6 month for the most Comment exposed workers What does mean „most exposed workers“? What are the doses of workers who must undergo a medical examination twice a year? Answer The medical examination is mandatory for the professionally exposed workers, and should take place at least once a year. A medical examination of twice a year can be decided by the medical service and is based on an evaluation of the risk for this worker to receive higher doses during normal operation or due to an incident. There is no direct link between the medical examination frequency and the dose actually received. Q.No Article Ref. in National Report 51 Article 25 G, pg. 81 Question/ The report indicates Belgium decided to conduct stress tests of events of the same Comment nature as took place at Fukushima. What is the status of the implementation of lessons learned for waste and spent fuel storage facilities away from power plants? Answer A “National Progress Report” on the implementation of the action plans resulting from the “stress-tests” for non-NPP facilities, including the waste and spent fuel storage facilities (i.e. Belgoprocess in Belgium) is annually (in December) published on the FANC website, in the folder http://www.fanc.fgov.be/fr/page/stress-tests-nucleaires/1411.aspx. In January 2015, on the 63 actions of Belgoprocess, 21% are closed, 70% are in progress and 9% are completed by the licensee but still require an analysis or an on-site inspection by the FANC before a possible closing. Q.No Article Ref. in National Report 52 Article 26 F1, 71 Question/ What are opinions of ONDRAF/NIRAS with verifying of a creation of financial Comment reserves for decommissioning? Answer Financial reserves for decommissioning present 3 main characteristics: existence, sufficient and availability. Only looking at the existence will not guarantee that they will be neither sufficient nor available. Some additional information, in French, is available in our report http://www.ondraf.be/sites/default/files/Inventaire%20_2013-02-03_%20%20final.pdf Q.No Article Ref. in National Report 53 Article 26 VI.F.2.b, pg. 72-73 Question/ For the funding estimated for decommissioning the various nuclear facilites, Comment including nuclear power, fuel cycle and spent fuel storage facilites, what amount has been collected to fund the decommissioning from the "producer" and what amount is provided by the State? Please explain. Answer Each “producer” is responsible for the funding of his own facilities. The State pays only for his own facilities and for the “historical liabilities”. Q.No Article Ref. in National Report 54 Article 27 IX.Section I, p.109 Question/ It is noted in the National Report that a licence is required for every shipment and Comment that the licence is only granted if it can be demonstrated that the requirements of the international Conventions and agreements are complied with. Ireland is interested to know which editions of the ADR/RID regulations are in force and what the current legal basis or Statutory Instrument is that gives effect to the Modal Instruments. Answer Article 57 of the GRR-2001 (Royal Decree of 21 July 2001, as amended), stipulates that : “Article 57 – Prior licence Shipments of radioactive materials as specified in this chapter shall comply with the provisions of current international agreements and regulations in force that govern the transport of dangerous goods: - the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR); - the Regulation concerning the International Carriage of Dangerous Goods by Rail (RID), appearing as Annex I to the Convention concerning International Carriage by Rail (COTIF); - Technical Instructions for the Safe Transport of Dangerous Goods by Air, issued by the International Civil Aviation Organization (ICAO); - International Maritime Dangerous Goods (IMDG) Code issued by the International Maritime Organization (IMO); - Regulation for the Carriage of Dangerous Goods on the Rhine (ADNR). These shipments shall only be performed if prior licence has been granted by the Agency. … ” New editions of these modal regulations are mandatory in Belgium by transposition of the European Directive 2008/68/CE on the inland transport of dangerous goods, amended every 2 years, and published in the Belgian official gazette. Currently, the latest applicable editions (2015) of the ADR and RID are in force from 1 January 2015 with a transitional period of six months (with the exception of for certain provisions for which the transitional period may be longer). Q.No Article Ref. in National Report 55 Article 27 I, pg. 109 Question/ The report states that licenses have been granted for “[i]mport of disused sealed Comment sources from Luxembourg within the framework of the existing convention between Luxembourg and Belgium.” Are the disused sources imported from Luxembourg pursuant to this agreement sources that were manufactured in Belgium? Does Belgium accept return of disused sources to manufacturers in Belgium generally, or is the return of disused sources from Luxembourg a special case? Answer 1) The disused sources imported from the Grand Duchy of Luxembourg are not necessarily sources manufactured in Belgium. The imported radioactive waste consists primarily of ionization smoke detectors (Am-241 and Ra-226), ionizing lightning rods ( Am-241, Ra-226 and Kr-85) or small disused sources (Cs-137, Sr90, Am-241,…).The importation of this radioactive waste from Luxembourg to Belgium is a special case within the framework of the existing convention between Luxembourg and Belgium. 2) In general, Belgium does accept the return of disused sources to manufacturers in Belgium, in accordance with the European Directive 2003/122/Euratom of 22 December 2003 on the control of high-activity sealed radioactive sources. The Directive was transposed into Belgian law by the Belgian Royal Decree of 23 May 2006 amending the Royal Decree of 20 July 2001 laying down the General Regulation for the protection of the public, workers and the environment against the hazards of ionizing radiation. Q.No Article Ref. in National Report 56 Article 28 J, pg. 112 Question/ Belgium has described a removal campaign of waste and disused sources from Comment multiple hospitals. During your National Country Presentation at the Fifth Review Meeting, please describe how effective this removal process was and if there are plans for more activities. Answer We will report on this at the Fifth review meeting. Q.No Article Ref. in National Report 57 Article 32 II.B.1., p13 Question/ Some waste producers have their own processing facilities and they transfer Comment conditioned waste to Belgoprocess site for interim storage and the ownership and related responsibilities to ONDRAF/NIRAS. What is the difference of the fee charged by Belgoprocess between the conditioned waste and unconditioned waste? Radioactive waste is classified as Category A, Category B and Category C. How much will be charged for the disposal of different category wastes? Answer The tariff to be applied for the storage or the disposal of the conditioned waste is the same, per category, conditioned by Belgoprocess or conditioned by the producer. ONDRAF/NIRAS apply an additional specific tariff for the conditioning that occurs at the Belgoprocess site. The tariffs are available, in French, on our site http://www.ondraf.be/content/couverture-des-co%C3%BBts-de-la-gestioncourante . For example, one 200l drum category A waste will be charged for compaction and conditioning of ~3400 €/m³, leading to a conditioned volume of 0.1m³, and 11 600 €/m³ for storage and 37 000€/m³ for disposal. Tariffs for disposal of category B waste start from 92 000€/m³. Q.No Article Ref. in National Report 58 Article 32 II.B.2.b, p16 Question/ The interim storage of the waste constitutes an intermediate level between shortComment term and long-term radioactive waste management . What are the regulatory requirements about the interim storage of radioactive waste in Belgium, for example the requirement of RW storage duration? Answer In Belgian regulation, interim storage facilities are categorized as high risk (“class I “) facilities, , and are subject to the same regulatory (licensing and surveillance) requirements as for fuel cycle facilities and NPPs. Safety requirements are laid down in the royal decree “Safety Requirements of Nuclear Installations” of 30 November 2011. There is no particular requirement on the RW storage duration for the existing interim storage installations, the lifetime of these installations is to be evaluated and justified at each 10-yearly periodic safety review. In addition, the ageing of the installations has to be closely monitored by the licensee. The waste is also inspected to detect degradation/non-conformities. A specific safety regulation proposal for radwaste and spent fuel storage installations, based on the recent WENRA-WGWD safety reference levels, is in development. Q.No Article Ref. in National Report 59 Article 32 IV.B.1., p22 Question/ The incineration unit has a capacity of 7.5 ton solid waste per week. Organic and Comment aqueous liquids containing a lot of organic compounds or complexing agents are incinerated together with the solid waste. What is the capacity of the incineration to organic and aqueous liquids? What amount of ash is produced when 7.5 ton solid waste is incinerated? How to store and condition to the incinerated ash? Answer The incineration capacity of liquids is 1.000 L/week at maximum. The amount of ashes produced depends of the type of solid waste but in general the weight percentage is about 5 to 10 wt%. The ashes are put into 200L drums and are supercompacted (volume reduction factor = 1,25). The supercompacted drums are put into 400L drums which are finally cemented and stored. Q.No Article Ref. in National Report 60 Article 32 Document Question/ Belgian 5th National Report should include an Executive Summary. Comment Answer The structure of the Belgian report complies with the INFCIRC/604/Rev.3 IAEA guidelines. Q.No Article Ref. in National Report 61 Article 32 II.B.2, 15 Question/ According to II.B.2.a) of the National Report, the RW classification which has Comment been adopted by ONDRAF/NIRAS is being used. - Is there any regulatory provision in the law or orders to define the RW classification in Belgium? - The NR mentioned that category A waste could be compatible with surface disposal. How about the relation between other category (category B and C) and disposal option? Answer There are no regulatory provisions in the law or in Royal decrees on the radioactive waste classification categories. ONDRAF/NIRAS classification system is directed at the long-term management of the various waste types. The eventual criteria to distinguish category A waste (surface disposal compatible waste) from category B & C waste, will be principally the disposal activity limits to be defined in the nuclear license for the surface disposal facility. Category B and C waste are intended to go to a deep geological disposal facility. Q.No Article Ref. in National Report 62 Article 32 D, 22 Question/ What is the procedure and practice for inspection and compliance of waste Comment packages stored in waste storage facilities regarding degradation and integrity of various waste packagings? Answer Inspections were performed with a portable camera and with a dedicated semi- automatic rotating installation allowing to take detailed pictures of the inspected waste packages. Criteria have been defined to describe the observation (corrosion, bump...) and to define the adequate response. Results and pictures have been crosscheck by an experimented inspectors to assure homogeneity in the results. Q.No Article Ref. in National Report NIRAS 63 Article 32.1.1 p. 11 - 12 (Section B) Question/ Reprocessing of spent fuel Comment Is the back-end option of spent fuel reprocessing bound to the lifetime of the NPPs? Do you conduct research activities on long-term interim storage of spent fuel? Answer No Please see also answer to question n°30 Q.No Article Ref. in National Report 64 Article 32.2.2 p. 24 (Section IV.B.2) Question/ Doel-1 and Doel-2: operating lifetime Comment On 18 December 2014, the Belgian Government confirmed media reports according to which the operating lifetime of the NPP units Doel-1 and Doel-2, as already proposed in 2009, should be extended by ten years to 2025. This decision, however, is subject to approval by the Federal Agency for Nuclear Control (FANC). On the other hand, the decision to phase out nuclear energy until 2025 should be adhered to. The proposal would mean that the three longest-serving reactors may run 50 years, while the lifetimes of the newer reactors would be limited to 40 years. Could you please quantify the additional amount of spent fuel and radioactive waste arising to be disposed of in Belgium due to the planned lifetime extension? Answer The additional amount of spent fuel arising from a 10y lifetime extension of Doel1 and Doel-2 is expected to reach about 200tHM.
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