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Re: clearance thresholds



Hi Marco,



    I am assuming from your note that the readers of the waste management

magazine will mostly be based in Spain.  As such they should be subject to

Spanish laws which have been adopted/implemented to comply with the

(European Union) Council Directive 96/29/Euratom of 13 May 1996.  Under this

directive all member states of the European union were required to put in

place national legislation to comply with the above directive, usually known

(in the UK) as the revised basic safety standards directive.



Much of the contents of the directive 96/29/Euratom was concerned with

occupational exposure and the implementation in Europe of the

recommendations of ICRP 60.



However it also include a requirement for the production of legislation for

the authorisation and clearance for disposal, recycling or reuse of

radioactive substances or materials containing radioactive substances

arising from any practice subject to the requirement of reporting or

authoristation (Article 5, 1, of the directive) i.e ionising radiation

emanating from an artificial source or from a natural radiation source in

cases where natural radionuclides are or have been processed in view of

their radioactive, fissile or fertile properties (Article 2,1, of the

directive).



 Apologies for the previous bit - put simply any clearance of any artificial

radioactivity, or natural radioactivity processed for its radioactive and/or

fissile/fertile properties must be authorised.  EXCEPT  the disposal,

recycling or reuse of such substances or materials may be released from the

requirements of this directive provided they comply with clearance levels

established by national competent authorities.  These clearance levels shall

follow the basic criteria used in Annexe 1 (of the directive) and shall take

into account any other technical guidance provided by the community (Article

5, 2 of the Directive).  This means that Spain should have adopted clearance

criteria to allow the disposal, recycling or reuse of materials containing

artifical radioactivity or natural etc. (see above) to comply with the

directive.



The requirements of annexe 1 are as follows:



a)    the effective dose expected to be incurred by a member of the public

(and this includes all workers who may come into contact with the material

once it has been released e.g. for metals, scrap metal workers, haulage

contractors, foundry workers, workers in manufacturing facilities using the

metals etc.) due to the exempted practice is of the order of 10 microSv or

less in a year.  Marco, this is probably where your 10 microSv value came

from.  (Note in the UK, in the order of 10 microSv was regarded as

approximate i.e. it could be a little higher or lower than this value).



b)    either the collective effective dose commited by one year of

performance of the practice is no more than about 1 manSv or an assessment

of the optimisation of protection shows that exemption is the optimum

option.



In the UK an assessment was undertaken by an independant contractor on

behalf of the government.  This reviwed existing legislation against the new

EU directive.  The conclusion of the review was that there was no need for a

change in the existing clearance level of 0.4 Bq/g for all artificial

radionuclides.  The review found that 330 radionuclides could be assigned to

one of three groups.  The first group would meet the criteria using a level

of 0.1 Bq/g, the second using a criteria of 1 Bq/g and the third using a

criteria of 10 Bq/g.  Given that the directive specified an effective dose

IN THE ORDER OF 10 microSv per year, it was the view that this could be

achieved using a the single criteria of 0.4 Bq/g even though the highest

doses would be in the order of 40 microSv year.  These doses would only

occur if very large quantities of the group 1 materials were released for

disposal, re-use or recycling.



Unfortunately, many other countries in the EU also went and undertook their

own calculations to meet the EU directive.  This means that unfortunately

there is no common set of clearance levels within the EU.  For the purposes

of your article it will be difficult to specify numerical values for these

materials.  The best you could achive is to try and identify what values

were adopted within Spain.  This will at least allow you to identify what

materials can be used, stored handled, treated etc. in Spain before they

require some for of authorisation from the Spanish Environmental Department?

If individauals or companies in Spain wish to import or export to other EU

countries they will also need to comply with the regulations in force in the

country of origin, any countries that the material may transit through and

the final country where the material end up.



Further information can be found in the following publications:

1)    IAEA, 1996.  Clearance levels for radionuclides in solid materials.

IAEA-TECDOC-855, IAEA, Vienna

2)    Working Party of the Article 31 Group of Experts, 1998.  Recommended

radiological protection criteria for the recycling of metals from

dismantling of nuclear installations.  EC report RP89, European Commission,

Luxembourg.

3)  SSK, 1998.  Clearance of materials, buildings and sites with negligible

radioactivity from practices subject to reporting or authorisation.  Heft

16, Gustav Fisher, Stuttgart.



Moving on to your second value of 1 microSv/hr in contact with scrap metals.

I'm unaware of the origin of this figure.  However it is easy to see that

dose rates at this level are unlikely to comply with the requiremnt to

restrict doses to members of the public (that is all individuals exposed

after the

materials have been released) to less than 10 microSv/y.  Although I would

be interested if you could let me know where this value came from.



The final value you mention is 70 Bq/g.  This comes from the definition of

radioactive material given inthe IAEA Transport regulations - Safety series

6 i.e. Radioactive Material shall mean any material having a Specific

Activity greater than 70 kiloBq/kg.



You should be aware that the IAEA transport regulations have been revised

and are now called IAEA TS-R-1 (ST-1), these have been the subject of some

other discussion on the radsafe list recently.  I understand (and hope

others on

the list can confirm) that the new regulations have indivual limits for

individual

radionuclides (both total activity and specific activity) in a table which

identifies

the quantity of material that is "exempt" from the requirements of the IAEA

transport regulations.  However it is important to remember two things,

firstly

these limits only apply to transport, NOT accumulation, storage or disposal,

reuse

recycling, these will have to comply with any relevant national legislation

implemented to comply with the EU Directive.  Secondly you will have to

check which

 values apply in Spain, the country of origin, any countries you may wish to

ship through

and the final destination country.  These may or may not have updated their

national

legislation to reflect the new IAEA transport regulations (see recent

posting

on radsafe "Two Common New Transportation Errors").



I wish I had been able to provide definitive limits for these materials in

Europe,

unfortunatley as you can see EU legislation does not always achieve its

purpose.



Good luck in your task.



Regards

    Julian Ginniver



----- Original Message -----

From: "Marco Caceci" <mcaceci@radal.com>

To: "Radsafe (E-mail)" <radsafe@list.vanderbilt.edu>

Sent: Monday, July 30, 2001 8:22 AM

Subject: clearance thresholds





> Hi:

>

> I am writing a paper for a (Spanish) waste management trade magazine on

the issue of radiation protection.

> This is a non-peer-reviewed article, so if anybody could volunteer to

review it (it is in Spanish) please let me know, I would

> really appreciate...

>

> Presently I find it difficult to locate primary sources and references for

clearance limits and criteria for acceptance of incoming

> materials and products.

> Any expert out there could check these statements and tell me if they are

true? do you have any reference to relevant laws and

> regulations?

>

> to be considered 'non radioactive'...

>

> - underlying criteria is that no member of the public should be subject

(by a product such as recycled aluminum or steel) to a dose

> higher than 10 uSv in a year

>

> - product (such as Al or steel) or raw material (scrap) should emit less

then 1 uSv/h at contact

>

> - product should contain less then 70 Bq/g activity

>

> Thank you in advance...

>

> Marco Caceci

> LQC s.l.

> www.radal.com

> www.chemitech.com

>

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