atw 2018-09v3

inforum

atw Vol. 63 (2018) | Issue 8/9 ı August/September

478

AMNT 2018

optimisation to be used by the regulator.

However, there were some requirements

on persons starting a new

practice to analyse whether dose

constraints were useful for this practice,

and to document this analysis

and, if asked, provide the analysis to

the authority.

Next, Dr Jack Valentin (independent

consultant, Sweden, former

­Scientific Secretary of the ICRP,

former senior radiation protection

regulator in Sweden) gave a presentation

on Implementation of the EU

BSS Directive in Sweden. First, Jack

Valentin outlined the genesis of the

new radiation protection requirements,

particularly the role of the

International Commission on Radiation

Protection (ICRP) and its

Recommendation no. 103 which was

the basis for the BSS Directive.

He highlighted four essential new

features of ICRP 103: The focus on the

exposure situation (planned/emergency/existing),

not the process

(practice/intervention); the optimisation

of radiological protection in all

exposure situations; the modulation

of optimisation using dose and risk

constraints, and finally, enhanced

protection of the environment by

maintaining biodiversity and ecosystems.

Interestingly, Jack Valentin

highlighted two issues where the BSS

Directive – and, as a consequence,

Swedish legislation and regulation –

was not fully in line with ICRP 103.

One concerned dose limits for occupational

exposure where the Directive

fixes an annual dose of 20 mSv with

no automatic averaging over five years

as had been the case before. As Jack

Valentin pointed out, averaging over a

5-year period facilitated the operator’s

optimisation of protection; for

example, in the case of rare major

jobs, the lowest collective dose was

achieved if a few specialists took

relatively high individual dose.

Concerning emergency worker dose

levels, whereas ICRP did not introduce

any dose limit for a life-saving

informed volunteer, relying instead on

an individual risk/benefit assessment,

the Directive featured a dose limit of

500 mSv. In Jack Valentin's view,

inexperienced rescue leaders might in

future be likely to omit life-saving for

fear of transgression (although doses

will rarely be higher than 500 mSv).

He next depicted the implementation

of the BSS Directive in Sweden

on three levels: the 2018 Radiation

Protection Act, the 2018 Radiation

Protection Ordinance and the 2018

Radiation Protection Regulations

(which have legal force and usually

also include a separate section giving

advice). Like in Germany, these new

or modified texts brought the law fully

into line with the Directive; in some

instances, they use a wording somewhat

different from that of the Directive

(e.g. Swedish law retained the

denomination “activities with ionising

radiation” for planned exposure

situations). And, like in Germany,

there were other reasons for the

legislative and regulatory overhaul

besides the BSS Directive.

When asked about why dose limits

in Sweden were contained in the regulations

rather than in the Act or the

Ordinance, Jack Valentin replied that

this provided some flexibility since

they could more easily be changed. Dr.

Akbarian noted that this was an interesting

viewpoint; she observed the

German view was rather to enshrine

them in legislation because of their

basic importance. Jack Valentin consented

that either view is perfectly

reasonable from its respective angle.

Responding to another comment, Jack

Valentin highlighted the importance

of participation of the public which

had always been a prominent feature

of Swedish nuclear and radiation

protection law and of more general

environmental law.

Next, Dr Edward (Ted) Lazo (Principal

Administrator, Division of Radiological

Protection and Human Aspects

of Nuclear Safety, OECD Nuclear

Energy Agency, Paris) spoke about

The NEA Report on Recycling and

Reuse of Materials Arising from

Decommissioning of Nuclear Facilities.

As Ted Lazo explained, significant

volumes of materials will be gen erated

from decommissioning of nuclear

facilities throughout the world. In

Europe, more than a third of currently

operating reactors were due to be shut

down by 2025. The importance of the

management of slightly contaminated

material was likely to grow and the

inherent value of these materials and

the need to reduce radioactive waste

to be disposed required attention.

However, the international community

was far from a complete

harmonization of the strategies and

regulations on this issue.

In order to rise to this challenge,

the NEA Cooperative Programme on

Decommissioning (CPD) Task Group

on Recycling and Reuse of Material

was created. The Task Group had produced

its first report in 1996; a new

report, updating and extending the

previous one, was released in 2016.

This recent report noted that in the

past two decades, international guidance

had been issued, notably the

IAEA guide RS-G1.7 and several

recommendations of the expert group

under article 31 of the Euratom Treaty.

Still, there was only a limited degree

of alignment of national regulations.

As the report noted, unconditional

clearance – which is normally preferred

to conditional clearance if

possible – is well-regulated in all

countries the report looked at, however

some differences between countries

remained, e.g. in the disposal of

rubble and concrete blocks from

dismantling. For conditional clearance,

in the absence of international

guidance, regulatory systems varied

greatly. As Ted Lazo pointed out, the

BSS Directive may help to achieve

greater consistency.

Generally, as he noted, since the

first report of 1996 a greater consolidation

and alignment of the requirements

to control dose and

exposure to workers, members of the

public and the environment had been

achieved; there was also an increase

in general public awareness but issues

over public acceptability remained.

Education, information sharing and

awareness-raising through direct

and public communications could be

utilized to alleviate many of the fears

surrounding recycling and reuse of

materials. Besides, a well-established

relationship between the nuclear

industry and the recycling industry

could have a considerably positive

effect to ensuring stakeholder and

public acceptance of materials. Ted-

Lazo concluded by saying that numerous

challenges to recycling and reuse

of materials persisted internationally

and that the Task Group felt that

success stories, such as those included

in its report, needed to be shared

internationally to help build consensus

for the safe recycling and reuse of

valuable materials.

Last not least, Dr. Jörg Feinhals

(Head of Project Group “Radiation

Protection and Disposal” at DMT,

Hamburg; Member of the Directorate

of the German-Swiss Association for

Radiation Protection) took the floor on

the topic Necessary Modifications

on Clearance Regulations in Germany

and Switzerland – Comparative

Analysis. Jörg Feinhals first

remarked that comparison between

the two countries is rendered more

difficult by the fact that sometimes

the same (German) word is used

with different meanings – a difficulty

which remarkably cannot arise with

English where there is a common

AMNT 2018

Key Topic | Outstanding Know-How & Sustainable Innovations ı Christian Raetzke

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