European Council Directive 96/29/Euratom, the so-called Basic Safety
Nuclear spoons, radioactive saucepans
and so on ...
Report from Radioactive Times Volume 3, Number 2, October 1999 (content not updated)
Radioactive Times Vol. 3 #1 reported on the opening of UK government consultation on implementing European Council Directive 96/29/Euratom, the so-called Basic Safety Standards Directive. LLRC has taken a lead in a two year campaign opposing the Directive's provisions for allowing unrestricted recycling and reuse of radioactively contaminated materials.
The consultation by the Department of the Environment, Transport and the Regions closed in June. DETR officials told RaT that they had received 200 responses on a wide range of issues which fill five slim volumes.
They are now "waiting for a clear ministerial steer" from Environment Minister Michael Meacher before issuing a final consultation document showing detailed proposals for changes to the Ionising Radiation Regulations and the Radioactive Substances Act. This is expected just before Christmas - some months behind the expected schedule [STOP PRESS: it is not now expected until the middle of January].
The LLRC submission called on the DETR to keep a tight regulatory framework around the disposal of radioactively contaminated materials, with specific bans on diluting wastes to achieve the "Below Regulatory Concern" thresholds. It offers Mr Meacher a way to block the nuclear industry's preferred and long anticipated option of dealing with contaminated materials from nuclear licensed sites by deregulating them and selling them off for recycling.
The Directive allows the Governments of member states to set their own radioactivity thresholds above which materials may not be deregulated. Europe has advised maximum values, but the Directive gives member states the discretion to set thresholds lower - even at zero. This would require the massive amounts of radioactivity now contained in nuclear reactors and bomb factories to be kept safely locked up. According to NIREX, estimates wastes arising from decommissioning over the next ten years will contain as much radioactivity as 90 Chernobyl accidents, so a cautious approach is fully justified.
Dilution loophole still open
In 1998, following LLRC's protests that the Directive would deregulate even highly contaminated materials if they were diluted with clean materials, the European Commission published Technical Guidance which appeared to rule out such dilution, for metals at least (no guidance on other materials has been published). It laid down that "the Clearance Levels for scrap are not appropriate for metal released after being melted [on a nuclear licensed site]." In other words, only unmelted scrap can be Cleared. The logic of this is that the clearance criteria for scrap metal assume that only a fraction of the scrap in the furnace comes from nuclear sites. But ingots produced in a licensed smelter, such as BNFL installed while they were decommissioning the gaseous diffusion plant at Capenhurst, are made from 100% radioactive scrap. The Guidance concludes that: "Therefore the clearance levels for scrap are not appropriate for metal released after being melted in an authorised facility."
The same clause contains a loophole, however, stating that "nevertheless there are a number of advantages to clearance after melting ... so that the competent authorities can authorise this practice after an appropriate investigation of the radiological consequences."
According to the old view of "radiological consequences" the total amount of radioactivity dumped into the environment is almost irrelevant so long as it is well diluted and widely dispersed. So the Clearance of pre-melted items obviously represents a route for recycling a large proportion of the radioactive waste inventory. This would happen without public knowledge, without democratic consultation, and according to standards which could be changed at any time by a secret committee of EC expert advisers.
LLRC is worried about the DETR's complete silence on this issue and has made strong representations about it.
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