NORM Under the Perspective of the Radioactive Waste

NORM Under the Perspective of the Radioactive Waste Division of CNEN DIREJ/DRS Ailton Fernando Dias Divisão de Rejeitos Radioativos – DIREJ Diretoria de Radioproteção e Segurança Nuclear – DRS Comissão Nacional de Energia Nuclear – CNEN ailton. dias@cnen. gov. br

Legal and Regulatory Framework CNEN´s STRUCTURE

Legal and Regulatory Framework CNEN´s STRUCTURE Regulatory Liabilities

Regulatory Bodies Involved in NORM from Oil E&P in Brazil IBAMA – Brazilian Institute for Environment and Renewable Natural Resources ENVIRONMENTAL LICENCE for radioactive waste storage and disposal facilities ANP – National Agency of Petroleum, Natural Gas and Biofuels REGULATORY FRAMEWORK FOR THE DECOMMISSIONING OF SUBSEA ASSETS: assignment matrix of the national regulatory bodies such as IBAMA, Brazilian Navy and CNEN MPT – Labor Public Ministry “OURO NEGRO” OPERATION: Cooperation among MPT, IBAMA, Labor Auditors and CNEN in order to protect workers in offshore oil and gas E&P facilities and to control exposure due to the presence of NORM

Regulatory Bodies Involved in NORM from mining and milling in Brazil * * Except Uraniun mining and milling follows specific licensing process of the nuclear fuel cycle regulations From DIMAP presentation

Legal and Regulatory Framework Responsabilities of the RADIOACTIVE WASTE DIVISION - DIREJ/DRS: • To control the radioactive waste management of nuclear and radioactive installations; • To authorize the sitting, construction, operation and decommissioning/closure of storage and disposal facilities for radioactive waste.

Legal and Regulatory Framework FEDERAL LAW 10. 308 (2001) • (Initial) Storage Facilities: intended for (initial) storage, whose legal responsible is the holder of the facility, licensed by CNEN. • (Intermediate) Storage Facilities: intended for (intermediate) storage, whose legal responsible is the Research and Development Directorate (DPD) of CNEN, holder of the facilities. The research institutes of DPD/CNEN are authorized by DRS/CNEN. • Final Disposal Facilities or Repositories: intended for disposal of radioactive waste (without the intention of retrieval), according to the criteria established by DRS/CNEN (NN-8. 02). IT IS NOT ALLOWED Ocean Islands Continental Shelf Brazilian Territorial Waters

Legal and Regulatory Framework REGULATION - CNEN NN 8. 02 (2014) • Meets the obligations stablished by Law 10. 308/2001. • General criteria for the Licensing of Storage and Disposal Facilities for Low and Intermediate Level Radioactive Waste (LILW). • Classification of Radioactive Waste according to the level and nature of radiation and the corresponding half-life. • The standard applies to the licensing of storage facilities for radioactive waste including those from Classes 2. 2 and 2. 3, once packaged.

Legal and Regulatory Framework Category Radioactive Waste Classification (CNEN-NN-8. 01 and CNEN-NN-8. 02, 2014) Characteristics Disposal Option 0. Exempt waste Activity levels equal or bellow the exemption limits which are based on a maximum annual dose to members of the public of less than 0. 01 m. Sv. 1. Very short lived waste (VSLW) Waste containing radionuclides with halflives of the order of 100 days or less, with Stored for decay. activity concentrations above the clearance levels. 2. Low and Intermediate level waste 2. 1 - Short lived No radiological restriction Activity levels above exemption limits, with half-lives greater than 100 days and heat generation equal or below 2 k. W/m 3. Waste containing radionuclides with halflife of less than about 30 years to beta/gamma emitters, with a limit of 370 Bq/g on average and up to 3, 700 Bq/g for individual packages for long lived alpha emitters. Near surface repository. 2. 2 Containing naturally occurring radionuclides from the extraction and processing oil operations Waste containing radionuclides from the decay series of Uranium and Thorium with activity concentrations above the clearance levels Near surface or geological repository – to be defined by the Safety Assessment analysis. 2. 3 Containing naturally occurring radionuclides from the mining or processing of ores and minerals Waste containing radionuclides from the decay series of Uranium and Thorium with activity concentrations above the clearance levels. Near surface or geological repository – to be defined by the Safety Assessment analysis. Long lived radionuclide concentrations exceeding limitations for short lived waste. Geological repository 2. 4 - Long lived 3. High level waste Heat generation above 2 k. W/m 3 and long lived alpha emitting radionuclide concentrations exceeding limitations for short lived waste (2. 1). Deep geological repository

Legal and Regulatory Framework Class 2. 2 Radioactive Waste • Waste containing naturally occurring radionuclides from the oil E&P operations (inlay/incrustation and oily sludge) are regulated by DIREJ/DRS. Class 2. 3 Radioactive Waste • Waste containing naturally occurring radionuclides from the mining or processing of ores and minerals are regulated by DIMAP/DRS.

Legal and Regulatory Framework Licensing requirements to Storage Facilities for LILW - Class 2. 2 and 2. 3 ANEXO II SPECIFIC REQUIREMENTS FOR THE SAFETY ASSESSMENT REPORT FOR STORAGE FACILITIES: 2. 1, 2. 2, 2. 3 and 2. 4 RADIOACTIVE WASTE CLASSES (PACKAGED only) § 3º The regulation applies to the licensing of storage facilities for Class 2. 2 and 2. 3 provided they are packaged (not bulk).

Legal and Regulatory Framework Licensing process for a storage or disposal facility for RW (DIREJ) • Nuclear Licensing (CNEN NN 8. 02) • Environmental Licensing (IBAMA) • Site Approval; Site Selection • Prior License (LP); • Authorization for Construction; Construction • Installation License (LI); Operation • Operation License (LO). • Authorization for Operation; • Authorization for Decommissioning/Closure. Decommissioning/ Closure

NORM Management challenges • Currently the licensing process for NORM storage facilities is prolonged (time-consuming) and relatively complex (many requirements to be met by operators at each stage); • Interim storage facilities managed by operators may be prolonged due to lack of viable/economic disposal options; • Exporting NORM waste has become a viable option for the operator, as long as it receives the consent of the regulatory bodies (CNEN and IBAMA); • Development of NORM waste infrastructure in the country, including disposal sites; • Implementation of national policies may be a challenge: need to assess the current infrastructure in the country and technical expertise for NORM waste/treatment and analytical characterization; • Establishment of a technical guidance document to help implementation strategies for technically preferable disposal options.

Thank you! ailton. dias@cnen. gov. br