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Radiation Protection of the Environment Radiation protection of the environment State of the art and IRSN recommendations Report IRSN 2016-03 ABSTRACT France has obligation to transpose into its national legislation no later than 2018 the new EURATOM basic Safety Standards Directive of the European Commission. In this context, pushed by the rapid international developments in the emerging field of radiological protection of the environment, discussions are underway at national level around existing knowledge and methodologies which are or could be used both by operators and by the authorities for assessing the radiological risk to ecosystems exposed to ionising radiation. The French Institute for Radioprotection and Nuclear Safety publishes herein its recommendations to guide the transposition work and to give practical guidance to implement the BSS requirements in the field of radiological protection of the environment. IRSN’s recommendations listed below relate to exposure situations as defined in the revised EU BSS accordingly to the ICRP publication 103 (2007) – planned, existing and emergency. In this document, they are supported by the state of the art and a review of current international practices. General position (R1) IRSN considers that the explicit consideration of protection of the environment from radioactive substances within the existing corpus of international reference documents (e.g., basic safety standards, international conventions, special legislation in some member States) must lead to the adoption of a French position on protecting the environment per se from ionising radiation. Such a position will be useful to technical experts participating in current or future working groups in this field. Recommendations for planned exposure situations (R2) IRSN considers that the inclusion, in France, of the demonstration of protection of the environment from ionising radiation in any project that may impact the environment is perfectly in line with the French Environmental Code and, more specifically, the provisions of Article 91 of French decree No. 2007-1557 on basic nuclear installations. (R3) IRSN considers that the demonstration of protection of the environment from radioactive substances must be integrated into the environmental impact assessment, to the same extent as with the assessment conducted for chemical substances. IRSN recommends that, in France, this demonstration be routinely requested from the licensees of any facility or activity involving controlled environmental releases of radioactive substances that may have an ecological impact. Such demonstration shall be commensurate with the environmental issues. (R4) IRSN recommends using a graded approach consistent with the principle of proportionality to the issues set out in French legislation. Such an approach enables resources and means to be better allocated based on the expected risk and allows efforts to be focused on cases requiring a closer look. (R5) IRSN considers that the tiered ERICA approach, which is compatible with and more operational than the ICRP approach, forms the basis to be followed to explicitly demonstrate protection of the environment during the assessment and control of radiological impacts associated with planned environmental exposure situations, in addition to the approach used for human radiation protection. This approach is used widely in Europe and was adopted a few years ago by a number of nuclear operators in France. It is similar in method and uses the concepts of the ICRP approach whilst providing a tool and associated databases that are regularly updated. (R6) Regarding environmental radiological risk assessments, IRSN recommends having the assessor choose benchmark values that are best suited to the situation under assessment and provide evidence of the source of said values (as is the case with the practices used to assess ecological risk associated with chemical substances). 1 This article indicates that the environmental impact assessment comprises an analysis of the facility’s direct and indirect, temporary and permanent effects on the environment and particularly on public health and safety, the climate, neighbourhood inconveniences due to noise, vibrations, odours or lighting, on sites, landscapes and natural environments, on fauna, on flora and biological equilibria, on crops and on the protection of property and cultural heritage. (R7) IRSN proposes setting up a working group whose objective would be to draft a technical guide describing a standardised and optimum method of using the ERICA approach and tool. This working group shall take into account improvements in international methodologies expected from the ICRP and the IAEA and other such organisations. It is also recommended to train users in the methods and tools in order to coordinate their deployment. Recommendation for existing exposure situations (R8) IRSN considers that the tiered ERICA approach makes it possible to cover existing exposure situations, particularly through its tiered assessment method. To supplement the feedback for these situations, other cases of application similar to the case studies handled within the Mines Joint Expert Group (GEP Mines), may be necessary to reinforce this statement; while including international advances in this field. Implications for environmental monitoring associated with planned and existing exposure situations (R9) Regarding planned exposure situations, IRSN recommends that current environmental radioactivity monitoring practices be reviewed to assess whether the data acquired can be used as additional proof for radiation impact assessments for ecosystems. Additionally, such a review shall also cover the use, for the same purpose, of the results from monitoring practices currently used to monitor the quality of media and biodiversity (e.g., case of the WFD and the MSFD). Regarding existing exposure situations, IRSN recommends supplementing the approach of demonstrating via the environmental impact assessment by implementing a specific ecological monitoring strategy where warranted by the level of exposure to ionising radiation (i.e., accordingly to the conclusions of the radiation risk assessment). Recommendation for emergencies and the post-accident phase (R10) In the event of a major nuclear accident (i.e. Chernobyl- or Fukushima-type), IRSN considers that the priority of the emergency is to protect human populations. During the post-accident phase, protecting the environment may be considered as one aspect to take into account to better manage contaminated areas. This matter could be dealt with by a dedicated working group. In view of the state of the art, the radiological risk assessment method for non- human species must be adapted and the necessary data must be supplemented in order to be able to respond to such situations. The proposed group’s work will extend to environmental monitoring practices. In terms of smaller accidents, attention should also be given to emergencies where protecting the environment would be essential, particularly in cases of accidents/incidents that impact uninhabited conservation areas. KEYWORDS Radiation protection, Environment, Non-human species, Risk assessment, Environmental Impact Assessment, Regulation, Recommendations, France LIST OF CONTRIBUTORS Authors: K. Beaugelin-Seiller, J. Garnier-Laplace Contributors : R. Gilbin, M. Simon-Cornu, M. Baudry, P. Deschamps, J.C. Gariel, J.F. Lecomte, F. Paquet, P. Renaud, M. Schuler LIST OF THE MOST COMMON ABBREVIATIONS USED IN THIS DOCUMENT Where applicable, English abbreviations are followed by their French equivalents. ASN: Autorité de Sûreté Nucléaire – French Nuclear Safety Authority BSS: Basic Safety Standards DCC: Dose Conversion Coefficient DCRL: Derived Consideration Reference Level EIA, EIE: Environmental Impact Assessment EQRS: Évaluation Quantitative du Risque Sanitaire (Quantitative assessment of health risks) ERA, ERE: Environmental Risk Assessment FP: Framework Programme for Research and Technological Development GEP-mines: Groupe d’Expertise Pluraliste sur les sites miniers d’uranium du Limousin (http://www.gep- nucleaire.org/gep) GPRADE: Groupe permanent d'experts en radioprotection, pour les applications industrielles et de recherche des rayonnements ionisants, et en environnement (Permanent Group of experts in radiation protection for research and industry applications of ionising radiation, and in environment) GRNC: Groupe Radioécologie Nord Cotentin (http://www.gep-nucleaire.org/norcot/gepnc/sections/actualites) IAEA, AIEA: International Atomic Energy Agency (http://www.iaea.org/) ICRP, CIPR: International Commission on Radiological Protection (http://www.icrp.org/) IUR, UIR: International Union of Radioecology (http://www.iur-uir.org/en/) NEA, AEN: Nuclear Energy Agency, a specialised agency within the OECD (http://www.oecd-nea.org/) OECD, OCDE: Organisation for Economic Cooperation and Development (http://www.oecd.org/france/) RAPs: Reference Animals and Plants RO: Reference Organisms TEC-DOC: TEChnical DOCuments series reports TRS: Technical Report Series UNEP, PNUE: United Nations Environment Programme (http://www.unep.org/) UNSCEAR: United Nations Scientific Committee on the Effects of Atomic Radiation (http://www.unscear.org/) TABLE OF CONTENT FOREWORD AND ELEMENTS OF TERMINOLOGY ............................................. 9 1 INTRODUCTION ................................................................................10 1.1 BRIEF OVERVIEW OF INTERNATIONAL, EUROPEAN AND NATIONAL LEGISLATION ...................... 10 1.2 MAIN
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