IAEA International Atomic Energy Agency

Environmental Remediation

National Policy,Strategy

and

Regulatory Process

as Applied to Legacy Sites

Russel Edge

Decommissioning and Remediation Unit

Division of Radiation ,Transport and Waste Safety

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

4th Annual Technical Meeting

Vienna Austria

22 - 24 October 2013

IAEA

Definition from IAEA Safety Glossary

• Remediation • Any measures that may be carried out to reduce the

radiation exposure from existing contamination of land

areas through actions applied to the contamination itself

(the source) or to the exposure pathways to humans.

• Complete removal of the contamination is not implied.

• The more informal term cleanup is also used. If used, it should be

used with the same meaning as remediation, not to attempt to

convey a different meaning.

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Where can remediation situations

occur?

During all parts of the nuclear fuel

cycle:

Front end – uranium mining and

milling.

Plant operations – any nuclear

installation can have

accidents/process upsets that can

create contaminated soils and

water.

Back end – if wastes, and facilities

after their operating life, are not

properly cared for.

• Legacy facilities are a particular

challenge.

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Factors Relevant For Remediation

Planning

• National policies

• Regulatory framework

National and local levels

• Public attitudes and perceptions

• Cultural and ethnic traditions

• Organizational structures and responsibilities

• Problem site identification and characterization

• Ecological impacts

• Human health impacts

• Economic and social impacts

Implementation resources (economic, technical, etc.)

• Management of wastes

IAEA

IAEA Safety Fundamentals

Top level policy document of the

IAEA Safety Standards Series:

• – States basic objectives, concepts and

principles;

• – Comprised of 10 safety principles;

Principle 2: Role of government.

• An effective legal and governmental

framework for safety, including an

independent regulatory body, must be

established and sustained.

Principle 7: Protection of present and

future generations. People and the

environment, present and future, must be

protected against radiation risks.

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Governmental, Legal and Regulatory

Framework for Safety-No. GSR Part 1

• Requirement 1: National policy

and strategy for safety

The government shall establish a

national policy and strategy for

safety, the implementation of

which shall be subject to a graded

approach in accordance with

national circumstances and with

the radiation risks associated with

facilities and activities, to achieve

the fundamental safety objective

and to apply the fundamental

safety principles established in the

Safety Fundamentals.

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Governmental, Legal and Regulatory

Framework for Safety-No. GSR Part 1

National policy and strategy

for safety shall express a long

term commitment to safety.

The national policy shall be

promulgated as a statement

of the government’s intent.

The strategy shall set out the

mechanisms for

implementing the national

policy.

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GSR Part 1 (cont)

In the national policy and strategy, account shall

be taken of the following:

(a) The fundamental safety objective and the fundamental

safety principles established in the Fundamental Safety

Principles;

(b) Binding international legal instruments, such as

conventions and other relevant international instruments;

(c) The specification of the scope of the governmental, legal

and regulatory framework for safety

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GSR Part 1 (cont)

(d) The need and provision for human and financial

resources;

(e) The provision and framework for research and

development;

(f) Adequate mechanisms for taking account of social

and economic developments;

(g) The promotion of leadership and management for

safety, including safety culture.

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Safety Standards related

10

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Policy and Strategy Considerations

• A typical policy should take

into account the national

legal framework and

institutional structure and

applicable international

conventions while

providing for the allocation

of responsibilities and

resources in addition to

safety, security objectives

and public information and

participation in the decision

making process.

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Policy and Strategy Considerations-2

• The strategy reflects and elaborates the goals and requirements set out

in the policy statement.

• Based upon detailed information on the current situation in the country

(organizational, technical and legislative).

• The technical solutions proposed for the remediation of sites in the

country should be politically, technically and economically feasible.

• When selecting a set of technological procedures, an appropriate end

point must be identified, usually a suitable end state.

• The steps in formulating and implementing the strategy include :

• selecting the technical procedures,

• allocating the responsibility for implementing the identified procedures,

• establishing supervisory mechanisms and;

• developing implementation plans.

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Principles for Remediation

• Justification of undertaking remediation;

• Optimisation of the protection for the

remedial actions;

• Providing appropriate protection of future

generations and the environment;

• Providing efficiency in the use of resources;

• Providing open and transparent interactions

with stakeholders

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Why is a Remediation Policy Needed ?

• An established remediation

policy is essential for

establishing the core values on

which remediation be based.

• Environmental remediation

policies will set the nationally

agreed position and will give

visible evidence of the concerns

and intent of the country.

• The formulation of a national

policy will encourage the

establishment of a legal

framework for ensuring coherent

and consistent remediation

approaches.

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Initial considerations

• National legal framework and institutional structure

• Existing (environmental) Legislation and Rules to

be applied in the specific case of contaminated

sites;

• Existing Waste Management legislation;

• Need for involvement of stakeholders and the

public;

• The availability of a funding system.

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Remediation-Specific Safety Requirements

• WS-R-3 (2003) provides

safety requirements for

remediation.

• WS-R-3 is supported by

the safety guide

Remediation Process for

Areas Affected by Past

Activities and Accidents,

IAEA Safety Standards

Series No. WS-G-3.1

(2007)

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Environmental Remediation Process

• Collection and evaluation of site data

• Determination of appropriate criteria

• Decision on remediation requirements and prioritization

• Development of remediation plan

• Public involvement

• Regulatory approval

• Implementation of remediation project

• Post-remediation verification

• Long-term institutional control

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National Priorities of Action

• Large numbers of contaminated sites are present in some

• countries

• Defining national priorities:

• • Preliminary assessment of exposures

• • Ranking of the seriousness of the problems at the

• various sites

• • First assessment of overall remediation requirements

• • Assessment of available resources (financial and other) for a

remediation program

• • Decision about scope and priorities of a remediation program

balancing possible risk reduction and costs incurred

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International Considerations

• Development of a national strategy has to

consider

• • international agreements on the

transboundary movement of wastes

• • international standards and conventions

on waste management practices and

radiation protection in particular in

situations where

• • Sites are close to borders of other

countries

• •Contaminants may move across

borders

• • management activities may cross

borders

• International cooperation may provide

technical or financial assistance

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Provisions Within Regulatory Framework

• Definition of adequate criteria for the whole process

• • Review and approval of remediation programs

• • Granting of permits or other authorizations

• • Funding mechanisms

• • Management of wastes resulting from the remediation

• • Involvement of stakeholders

• • Methods for the assessment of the adequate implementation of

remedial action

• • Keeping of records

• • Imposing of restrictions on the use of areas post remediation

monitoring and surveillance programs (Institutional Control)

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Definition of Remediation Criteria

Criteria required for :

• • the determination of remediation requirements

• • the prioritization of remedial action

• • the definition of remediation goals

Derivation of Criteria

• • Based on general radiation protection criteria

• • Non-radiological hazards possibly also relevant; integrated

assessment with radiological risks is desirable

• • Recommendations of national and international organizations

• • Impact of criteria definition on restoration costs

Options for criteria definition:

• • Generic criteria for all sites of concern

• • Site-specific criteria taking account of varying site conditions

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Organization Implementing the

Remediation

• If the party responsible

for the contamination can

be identified this

organization usually will

be required to perform

and fund the remediation.

• If this is not possible

the government will

have to assume

responsibility for the

remediation.

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Responsibilities of Operator

Retain necessary resources, expertise and knowledge

for remediation and have competent staff

• Perform site investigation programs

• Develop waste management concept

• Prepare remediation plans and all supporting documentation

• Report to regulatory body any safety related information

• Prepare and implement appropriate safety procedures

• Establish emergency planning

• Apply good engineering practice

• Implement quality assurance program

• Implement remedial action according to regulatory requirements

• Keep records and documentation

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Functions of the Regulatory Authority

General functions do not differ from regulating nuclear

installations

Specific emphasis in environmental remediation projects usually

required in some areas:

• High intensity of communication and cooperation with other

governmental authorities (broad range of environmental, social and

economical factors)

• Early and intense public consultation is extremely important (direct

effect of risks and remedial measures on population; land-use very

important for remediation concepts)

• Substantial changes in organization, funding, staff and training may be

required if regulatory body dealing with small-scale radiation protection

problems (sources, medical sector) is now faced with large scale

environmental remediation projects.

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Responsibilities of Regulatory Body

• Define safety criteria for the remediation of contaminated

• sites

• Review and approve remediation programs

• Issue authorization or license for remedial measures

• Review monitoring programs during and after remediation

• Provide control mechanisms for the future land-use

• Review and approve major changes in design, implementation

methods, procedures or equipment

• Assess reports of abnormal occurrences

• Carry out regular inspections and take enforcement actions

• Ensure compliance with legal and regulatory requirements

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Other government agencies may be

involved…

Examples: • Authorities responsible for public liability issues

• Authorities for planning the use of water resources and land

• Authorities responsible for public and occupational health & safety

• Fire protection authorities

• Transport authorities

• Law enforcement bodies

• Bodies with responsibilities for civil engineering structures and

buildings, and electrical and mechanical equipment

• Other bodies with responsibilities for emergency preparedness

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Roles and Responsibilities in remediation

program (1)

1. Recognize need for action government

2. Establish funding government

3. Establish government

1. regulator,

2. remediator/operator

3. long-term monitoring organization

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Roles and Responsibilities in remediation

program (2)

4. Establish clean up criteria regulator

5. Establish regulatory requirements regulator

(license)

6. characterize/ prioritize/develop operator

plan of action

7. Submit detailed plans (prioritized) operator

8. Approve plans regulator

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Roles and Responsibilities in remediation

program (3)

8. Conduct remediation plan operator

9. Submit report of completion operator

10. Approve report of completion regulator

11 Propose long-term care procedures operator

12. Approve procedures regulator

13. Carry out long term care LT caretaker

14. Long term oversight regulator

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Regulatory Process - General

Requirements • Environmental Impact Assessment (EIA) and Safety

Assessment (SA) performed by the operator which are

consistent with regulatory guidance documents and

requirements.

• EIA and SA are input to Remediation Plan

• Review and assessment of remediation plan is based on a

thorough review of the operator’s technical submission by

the regulatory body• General requirements on the

operator’s submission:

• Demonstration of the safety of the proposed activity

• Accurate and sufficient information given

• Technical solutions proposed are proven or qualified by

experience/testing and capable of achieving the required level of safety

Technical solutions will meet remediation criterion

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Resources Required by Regulatory

Authority

• Requirements for resources to effectively handle

environmental remediation programs are in many

aspects not different from other regulatory tasks in

the nuclear field.

• For large scale environmental remediation

programs additional resources may be required in

the following fields: • The review and assessment of environmental remediation concepts

may require additional staff with different qualifications (e.g.

hydrogeology, geophysics, atmospheric science)

• Requirements for funding the regulatory activity may be higher

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Summary

1. A strong regulatory structure is required for safe and

efficient remediation

2. Many similarities and significant overlap

3. A clear authorizing process is an essential tool for

regulatory supervision of remediation projects.

4. Regulatory body provides the requirements and guidance,

inspects during process and verifies compliance with

requirements as documented by operator

5. Operator is ultimately responsible for ensuring safety and

that all requirements are met.

6. An on-going process of communication between the

regulatory body and operator is critical for a timely and

successful remediation project.

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