IAEA Final Report on Recycling of Removed Soil etc. Arising from Decontamination Activities (Vol. 3)

Hello, everyone. My name is Daichi, an expert providing the information about the radiation issues in an easy-to-understand manner.

With regard to the IAEA review for volume reduction and recycling of removed soil arising from decontamination currently promoted by the national government, this article covered the background etc. for the review implemented by the IAEA, and this article covered the overall evaluation made by the IAEA.

In this and the following articles, the contents of reviews, which are described in each Chapter, are elaborated in detail based on my personal understanding.

In this article, ‘Chapter III: Regulatory aspect’ in the final report will be covered.

In other words, for example, the following questions will be responded.

-　What is the ‘Regulatory aspect’ in the final report on recycling of removed soil etc. arising from decontamination activities?
-　What kind of evaluation did the IAEA final report made for the ‘Regulatory aspect’?

Table of contents of this article

IAEA Final Report on Recycling of Removed Soil etc. Arising from Decontamination Activities (Vol. 3)
What is the ‘regulatory aspect’ mentioned in the IAEA final report?
Evaluation written in the ‘Chapter III: Regulatory aspect’
- Section III.1 Overall process
- Section III.2 Justification of the managed recycling and the final disposal
- Section III.3 Application of optimization of radiation protection
- Section III.4 Development of the ministerial ordinance and the technical guidelines for the managed recycling
- Section III.5 Independence of regulatory functions
Summary

I have been involved with the radiation-relevant issues, like the policy on the decontamination activities and the management of the Interim Storage Facility, after the accident of the Fukushima Daiichi Nuclear Power Plant in 2011.

I received a doctorate in the field of radiation, while working in Fukushima.

IAEA Final Report on Recycling of Removed Soil etc. Arising from Decontamination Activities (Vol. 3)
What is the ‘regulatory aspect’ mentioned in the IAEA final report?
Evaluation written in the ‘Chapter III: Regulatory aspect’
Summary

IAEA Final Report on Recycling of Removed Soil etc. Arising from Decontamination Activities (Vol. 3)

Now, let’s take a look at the contents of the ‘Chapter III: Regulatory aspects’ of the final report.

What is the ‘regulatory aspect’ mentioned in the IAEA final report?

You might not be familiar with the word ‘Regulatory aspect’, but to make the long story short, it can be understood, that it means an institutional arrangement for the managed recycling and final disposal.

Specifically, it includes not only the Act on Special Measures concerning the Handling of Pollution by Radioactive Materials (the Act on Special Measures) (in Japanese), relevant cabinet orders, ministerial ordinances, documents like guidelines, which are the basis for implementation, but also organization structure and management methods.

Revision of the ministerial ordinace of the Act on Special Measures, and development of the technical guidelines are supposed to be implemented by the end of FY2024, in preparation for the large-scale managed recycling projects to be carried out in FY2025 onward, this is repeatedly mentioned in the final report.

Evaluation written in the ‘Chapter III: Regulatory aspect’

In the following parts each evaluation item is elaborated, but for the sake of convenience, alphabets (i.e., a,b,c…) are added at the beginning of each item (there are no alphabets in the actual report).

Section III.1　Overall process

a. Considerable progress in the consideration of the regulatory aspects has been made, in line with the eight steps (Figure I) and the Technology Development Strategy for the managed recycling and the final disposal of removed soil and waste.

It is also touched upon in the final report, but the ‘eight steps’ represents the future direction toward completion of the final disposal outside Fukushima Prefecture, which is decribled in the measures for the Interim Storage Facility (August 8, 2014) (in Japanese).

These eight steps can be roughly divided into two parts: Steps 1-4 are creation of basis, including the technology development, necessary to realize the final disposal, and Steps 5-8 are specific measures, including selection of candidate sites and construction of the final disposal sites.

Here it is evaluated, that considerable progress has been made for the regulatory aspect, in line with these procedures.

In other words, it can be said that the Steps 1-4 will be completed by the end of FY2024, and the Steps 5-8 will be initiated in FY2025 onward, taking account of the fact that the projects are supposed to be implemented in larger scale in FY2025 onward.

b. The team of experts notes with appreciation that the MOEJ will review and consolidate by the end of FY2024 the findings of the demonstration projects and consideration of volume reduction treatment options to develop the ministerial ordinance and the technical guidelines for the managed recycling and the ministerial ordinance for the final disposal, taking into account the expected quantities and activity concentrations of the removed soil and waste.

As explained in this article, achievements of technology development etc based on the Technology Development Strategy for Volume Reduction and Recycling of Removed Soil and Waste under Interim Storage are supposed to be compiled by the end of FY2024, with a view of full-scale implementation of the managed recycling in FY2025 onward.

Here two ministerial ordinances are separately written like ‘the ministerial ordinance for the managed recycling’ and ‘the ministerial ordinance for the final disposal’, but in fact, I think that the Ministerial Ordinance of the Act on Special Measures concerning the Handling of Pollution by Radioactive Materials (in Japanese) will be amended, and within the ministerial ordinance, specific approach for the managed recycling and final disposal will be separately described.

c. The MOEJ should complete the treatment (volume reduction) options study in good time to input into future policy.

It is described in the Section ‘IV.3 – Technologies for volume reduction’, but currently a variety of technologies for volume reduction are under consideration to reduce volume for the final disposal.

Basically, these achievements are supposed to be compiled by the end of FY2024, therefore I think that it is here advised that the consideration for options needs to be also completed in the near future, toward the completion of the final disposal by March 2045.

Section III.2 Justification of the managed recycling and the final disposal

d. The justification of the managed recycling and the final disposal of removed soil and waste described by the MOEJ is consistent with IAEA Safety Standards (SF-1, Principle 4).

This ‘justification’ is elaborated in this article, but it is one of the three radiation protection principles, and also one of the most important concepts when handling radioactive materials.

To make the long story short, this is the concept that radiation can be used as long as the actions yield sufficient benefits to outweigh the detriments, and this concept of course can be applied when handling radioactive materials arising from the accident of the Fukushima Daiichi Nuclear Power Station.

It is described in the final report, but the benefits here obtained with these approaches will include, for example, reduction of radiological risk to people in the affected areas, contribution to reconstruction of the affected areas through lift of evacuation orders.

On the other hand, the detriments here will include radiation exposure to workers involved with the projects, factors which are not directly relevant to radiation protection, like human resources, economic and social costs necessary for transportation and management of the removed soil.

Here it is evaluated, that the benefits brought by efforts of recycling and final disposal of removed soil containing radioactive materials outweigh the detriments yielded by the efforts, and it worths dealing with it.

By the way, the ‘SF-1’ is the ‘Safety Fundamentals-1’, one of the Safety Standards, as covered in this article.

This is the concept to be prerequisite for the projects and I think this is a very important evaluation.

e. Identifying removed soil that is suitable for the managed recycling is consistent with the IAEA Safety Standards (SF-1, Principle 7) to minimise the generation of radioactive waste to be disposed of.

The ‘SF-1’ means the Safety Fundamentals, as described in the above point d.

This Safety Fundamentals include 10 principles, and here it is evaluated, that approches for the managed recycling is consistent with the concept, ‘The generation of radioactive waste must be kept to the minimum practicable level by means of appropriate design measures and procedures, such as the recycling and reuse of material.’, which is described in the principle No.7: Protection of present and future generations.

Section III.3 Application of optimization of radiation protection

f. The team of experts emphasises that optimisation of radiation protection is the process of determining what level of protection and safety would result in the magnitude of individual doses, the number of individuals (workers and members of the public) subject to exposure and the likelihood of exposure being as low as reasonably achievable, economic and social factors being taken into account. This is about considering the overall impact, not just the dose. Therefore, it takes into account the prevailing circumstances (e.g., environmental, technical, safety, social, monetary cost etc) to determine the option that lowers overall impacts as much as possible.

This is also elaborated in this article, but ‘the optimization’ of radiation protection is one of the three principles of radiation protection, and one of the most important concepts when handling radioactive materials.

This point elaborates the optimization of radiation protection (and safety), rather than providing an evaluation.

This ‘optimization’ is touched upon in this article, but to put it more simply, it means that dose needs to be as low as reasonably achievable (ALARA), not only taking account of radiation protection, but also other factors (e.g., social and economic factors).

In the final report, it is explained that this ‘optimization’ is a process to determine criteria or level for radiation protection, and the ‘ALARA’ is the result determined through the process.

g. The dose criterion of the additional effective dose of 1 mSv per year is an appropriate criterion for the managed recycling of removed soil and it is appropriate to use the recycled soil under proper management to meet the 1 mSv per year.

With regard to this recycling project, additional dose to workers and people around the sites, which attribute to the project is supposed to be 1mSv or less.

As explained in this article, annual dose to a Japanese person is on average around 6mSv (of which around 2.1mSv from natural sources).

Therefore, some people might feel that 1mSv is a relatively big dose, but actual dose to workers for 8 months involved with farmland development were 0.096～0.143mSv.

So, it could be expected for the dose to people around the sites to be much lower than that (Reference: The 4th Working Group on recycling of removed soil in the Interim Storage Facility, Material number 2-1) (in Japanese).

When taking account of the relationship between dose and effect on people’s health covered in this article, it can be understood that dose is not the level which makes negative impact on people’s health.

h. The MOEJ’s approach to optimisation, i.e. exploring options for reducing the dose below the dose criterion of 1 mSv per year (e.g., using cover soil) is consistent with the IAEA Safety Standards. The team of experts recognizes that the level of dose to be aimed at through the optimization approach will be determined in consultation with stakeholders such as local residents and municipalities.

Optimization is a concept aiming at reduction of dose as low as reasonably achievable, taking account of economic, societal and environmental factors taking into account.

Therefore, it is here evaluated, that the approach to reduce dose by using cover soil for prevention of soil runoff, is consistent with the IAEA Safety Standards.

Details can be seen in the ‘Principle 5: Optimization of protection’ of the above-mentioned Safety Fundamentals.

In addition, here it is recognized, that the level of dose to be aimed at through the optimization approach will be determined in consultation with relevant stakeholders.

It should be noted that, the level is not something to be achieved only once, but instead something to be repeatedly reviewed, as long as reasonably achievable.

i. The MOEJ should make it clear in their documents that, as stated in the IAEA Glossary, optimisation considers other possible impacts not just the level of dose and, in line with that, the MOEJ should indicate that optimisation does not mean that the dose to members of the public from the project has to be of the order of 10 microSv per year or less. Taking into account more realistic (site-specific) parameter values when designing a structure for the managed recycling, could support optimization.

Here with regard to the optimization of radiation protection and safety, it is stated with the explanation described in the above point f., that it should be indicated, that the level is not necessarily of the order of 10 microSv per year.

This ‘of the order of 10 microSv per year’ correspondents to the additional dose of the ‘clearance’ of radioactive waste, that is, the additional dose which allows radioactive substances totally to be excluded out of regulation and to be distributed into the market like other stuff.

It is described that it should be indicated that the optimization is not something necessarily to aim this clearance level.

Section III.4 Development of the ministerial ordinance and the technical guidelines for the managed recycling

j. The generic safety assessment for the managed recycling is sufficiently conservative, and the approach for derivation of the screening level, which is consistent with established international approaches, is appropriate, therefore the dose criterion can be sufficiently achieved by using the recycled soil of 8,000Bq/kg or less.

Evaluating in advance the amount of dose due to the use of radiation during projects dealing with radioactive materials, is an important procedure to consider the ‘justification’ touched upon in the point d., and the ‘optimization’ touched upon in the point f.

I think that for this recycling project, the dose assessment was implemented and discussed during the Experts Meetings, and here it is described that the approaches for the assessment (e.g., approaches for setting exposure pathways and parameters) are sufficiently conservative (standing on a safer side).

The ‘screening level’ mentioned afterwards, is a value with regard to the recycling of radioactive waste arising from environmental restoration project e.g., after an accident of facility pertain to radioactive materials.

This concept is described in the IAEA General Safety Guide 18 (GSG-18): Application of Concept of Clearance, and needs to be distinguished with the ‘clearance level’ mentioned from the point h.

By the way, the recycling project of soil arising from the environmental restoration projects after the accident of the Fukushima Daiichi Nuclear Power Station, is taken as a specific case study in the GSG-18.

Here it is evaluated, that the dose criterion (1mSv/y) can be sufficiently achieved by using the soil of 8,000Bq/kg or less (screening level).

k. The components proposed by the MOEJ for inclusion in the System for the managed recycling of removed soil (i.e., the ministerial ordinance and the technical guidelines), which includes setting activity concentration of recycled soil, measures to prevent scattering and leakage of the removed soil, monitoring of air dose rate and recording and storage of information on project sites etc., cover the essential elements to ensure safety during the construction and maintenance period.

As aforementioned, achievements of the technology development based on the Technology Development Strategy for Volume Reduction and Recycling of Removed Soil and Waste under Interim Storage are supposed to be compiled, and the amendment of the Ministerial Ordinance of the Act on Special Measures concerning the Handling of Pollution by Radioactive Materials, and the development of the technical guidelines are scheduled by the end of FY2024, toward full-scale implementation of the recycling projects.

I guess that the contents of the ministerial ordinance and the technical guidelines were discussed during the Experts Meetings, and here it is evaluated, that their components cover the essential elements to ensure safety during the construction and maintenance period.

l. The team of experts notes that the MOEJ has already started to consider long term, post-management safety of the recycling projects before implementation, as it is important to perform a long term, post-management radiological impact assessments of the recycling projects, to understand the dose of the potential future scenarios. This will enable the post-management safety to be evaluated, in due course.

This seems to be a bit difficult, but here the importance of a long-term safety assessment for the recycling project is mentioned.

Radioactivity concentration decreases with time due to decay of radioactive materials.

As explained in this article, in the case of the accident of the Fukushima Daiichi Nuclear Power Station, radioactive nuclides, which are currently remaining in the environment, are Cs-134 and 137.

The half-life of radioactive caesium 134 is around 2 years, and that of radioactive caesium 137 is around 30 years.

Impact of these radionuclides has significantly decreased compared with the time of shortly after the accident, and in the future the remaining radionuclide will be the radioactive caesium 137 with physical half-life of around 30 years.

The time will come far in the future, when the impact of the radioactive caesium will be negligible, so this part mentions the importance of long-term assessment in terms of radiation protection, including estimation of the point of time, as well as the fact that the MOEJ has already started its consideration.

m. The technical guidelines and/or agreements need to be clear which situations and eventualities require the operator of the structures (i.e., public body in principle) to inform the MOEJ and to seek advice, review and agreement from the MOEJ before proceeding with planned action (e.g., to take remedial actions). The agreements should include procedures for prior notification of any change of landforms or use at the project sites to ensure the safety of structures for the managed recycling.

It is written a couple of time in this final report, but the recycling projects are supposed to be implemented under appropriate management of organizations, whose responsibilities are clearly defined in Japanese laws (e.g., public bodies).

Therefore, it is a basic role sharing, that these public organizations etc. implement the projects, and the MOEJ manages the system and provides necessary advises.

Here it is pointed out that the situations and eventualities (management under usual situation and emergency situations like disaster), and procedures how implementors of the projects report the MOEJ and the MOEJ provides with advises etc., should be clearly stipulated in the technical guidelines and agreements developed in the future.

I think that people around the sites have concern not only for measures in ordinary situations but also in emergency situations, like runoff of removed soil inside of constructions caused by a disaster.

Of course, sufficient measures need to taken in advance, to prevent such events from happening, but I think that this point says that countermeasures for unexpected events need to be also considered, which could happen nevertheless.

n. The MOEJ needs to consider the point at which no further management in terms of radiological protection is required. The MOEJ needs to proceed with the consideration process for the end of special attention carefully, in a step-by-step manner, taking the acceptability of operators/people into account.

It is mentioned in the point l., two points above from here, but here the necessity for consideration for the point of time in the future is touched upon, when special attention become unnecessary, because radioactivity decreases over time.

The specific measures for the ‘special attention’ in terms of radiation protection, are not mentioned here, presumably they are, for example, periodical monitoring.

People around the sites might have concern, if the measures will come to an end, therefore, it is pointed out here, that the consideration needs to be proceeded with carefully and in a step-by-step manner.

o. Site-specific agreements should be developed, in conjunction with other stakeholders (e.g., operator of the structure, facility manager, landowner) when the site is identified, and before implementation of the project. These agreements should include the soil acceptance criteria for the project (e.g., allowed activity concentration).

‘The project’ which is mentioned here, is the project for the managed recycling, but it is pointed out, that site-specific agreements need to be developed with stakeholders relevant to the project before implementation.

In the following part it is proposed for a general format for the agreement to be developed.

However, land use, geography and social background vary depending on project sites, therefore, I think it is pointed out that site-specific agreements should be developed according to the situation of each site.

And I think that soil acceptance criteria should be included in the agreements, because soil quality is expected to vary significantly depending on land use (e.g., farmland, road embankment).

p. The ministerial ordinance and/or the technical guidelines should contain technical requirements, and they should also describe management arrangements required to ensure safety, administrative requirements (including records to be kept and displayed) and the importance of communication with local government and local communities (e.g., provision of necessary information about communication in each stage of the project).

As aforementioned, the amendement of the ministerial ordinance and the development of the technical guidelines are expected, which are necessary for the full-scale recycling project, by the end of FY2024.

I think that detailed contents will not be included in the ministerial ordinance, taking account of its nature as a legal document, but in the technical guidelines, which complements the ministerial ordinance, I think that a relatively variety of items can be included.

Here it is pointed out that the management arrangements and the importance of communication should be also contained, other than technical items, which are obviously needed.

q. The importance of public and stakeholder consultation about the managed recycling projects should be enshrined in the technical guidelines, also taking recommendations of the Working Group for measures to secure regional social acceptance for the managed recycling and the final disposal (see Section VI.3) into consideration.

Detail will be explained in the article covering the Chapter VI, but the ‘Working Group on measures to secure regional social acceptance for the removed soil in the Interim Storage Facility’ was established in January 2024, under the Conference on the Technology Development Strategy for Volume Reduction and Recycling of Removed Soil and Waste under Interim Storage.

In the Working Group, discussion has been continued aiming at improvement of social acceptance in regional areas for the managed recycling and the final disposal of removed soil, and in order to consider how communication with the region and regional co-prosperity should be.

In order to promote recycling projects etc., in addition to technical issues, social issues need to be addressed, like co-prosperity of the projects and regions.

Here it is pointed out, that its importance should be stipulated in the technical guidelines, which is scheduled to be developed within FY2024.

r. The technical guidelines should clearly define the procedures for the decision-making, when undesirable events happen.

I think that the ‘undesirable events’ here mentioned, probably assume events, for example, runoff of the removed soil within the construction caused by damage due to natural disaster.

Similar description can be seen in the point m., but it means that specific procedures to address these unexpected events need to be stipulated in the technical guidelines.

In Japan in these years disasters due to earthquakes and heavy rains occur very frequently.

Of course, it would be best that no damage on the structure would happen, but I think that here it says that precautious measures should be fully prepared for these unexpected events.

Section III.5 Independence of regulatory functions

s. The team of experts noted that, following the accident, the status of the MOEJ as both regulator and operator has been appropriate.

After the accident of the Fukushima Daiichi Nuclear Power Station in March 2011, based on the Act on Special Measures, especially in the Special Decontamination Areas （please refer to this article), off-site decontamination activities have been implemented directly by the MOEJ.

The TEPCO also should implement the off-site decontamination activities, which caused the environmental contamination, in light of international standards.

However, actually it hadn’t happened, and I think that there are, for example, a couple of reasons for that as follows:

– Dose reduction of people in the contaminated areas was an urgent issue to be addressed, but the system and manpower of the TEPCO were not enough to decontaminate all of the wide range of areas.
– The national government had a social responsibility, which had promoted the nuclear policy.

Also given these situations, here it could be evaluated that following the accident, the status of the MOEJ as both regulator and operator for the off-site decontamination has been appropriate.

t. Going forward, and in accordance with IAEA SF (Safety Fundamentals)-1, the regulatory function should be independent from the operator function. This could be helpful for enhancement of the long-term safety of the sites, as well as the public and stakeholder confidence. Hence, the MOEJ should demonstrate the independence of their operator and regulatory functions before implementing both the managed recycling and the final disposal in accordance with the ministerial ordinance under the Act on Special Measures.

Among the 10 principles of the Safety Fundamentals elaborated in this article, in the ‘Principle 2: Role of government’, it is stated as follows:

An effective legal and governmental framework for safety, including an independent regulatory body, must be established and sustained.

As described in the point s. one point above, as stated here, it is said that regulatory function should be independent from operational function in the future, even though the status of the MOEJ has been so far appropriate.

It could imply that the time has come for the regulatory function to be independent from the operational function, after over 13 years has passed since after the accident.

And it says here that it could help enhance the long-term safety of the sites, as well as the public and stakeholder confidence.

This could be helpful for enhancement of the long-term safety of the sites, as well as the public and stakeholder confidence.

u. Development of a decision-making procedure will enable the MOEJ to identify the key point at which the independence of the regulatory function is to be demonstrated. Development of management structure within the MOEJ could be one of the options to demonstrate the independence of the regulatory function from the operator function. The MOEJ is considering potential options and they should be further discussed.

Here it is said that it will be clarified, at which point a regulator can perform its function, by developing a decision-making procedure (e.g., Procedure to report from an operator to a regulator and a procedure to advise from a regulator to an operator, in the case of an undesirable events), mentioned in the point r.

One of the options to show its independence is not only letting another organization have the function, but also separating the function within the MOEJ.

In the MOEJ, there are work-units like departments and sections, as well as regional branch offices (environmental regional offices).

I think that this is advice, that however it can be divided, but it needs to be ‘functionally’ clearly separated.

Summary

With regard to the final report of the IAEA Experts Meeting on the managed recycling etc. of removed soil, this article covered the contents of conclusions in the ‘Chapter III: Regulatory aspect’.

It is evaluated that the approaches taken are consistent with the very important concepts of radiation protection described in the IAEA Safety Fundamentals.

However, on the other hand, there are some important points raised toward the future full-scale implmentation including separation of regulatory function from operational function, and it is required to address continuously these issues.

You can read the same article in Japanese here.

Thank you very much for reading this article.

See you next time!