Regulation of Safety in Management of Legacy Radioactive Waste

The land management system in the area of radioactive waste storages and tailings requires improvement, including identifying the owner of legacy facilities and wastes, defining rules and requirements for sanitary zones, conducting remediation, institutional monitoring and creating funds to finance safety measures. It is also necessary to establish a network of radioecological monitoring of environmental pollution by radioactive substances at uranium heritage sites. Inherited RW in the Kyrgyz Republic is comprised of the following:

 A radioactive waste storage facility in Bishkek (RWSF); and

 Thorium- uranium-tailings and mining dumps, which are under the responsibility of the MES, «KGRK»

OJSC, «Astra KCHMZ» and «TK Geo Resource» CJSC in Orlovka. In total there are 38 tailing piles and 37 dumps of rocks, of which the MES is responsible for 33 tailing piles and 27 dumps of rock.

The RWSF specializes in the storage of orphan and spent or waste SIR. There is no disposal facility in the country. Between 2012-2018 there were 584 SIR stored in the RWSF. According to the Priority Action Plan [6], the RWSF began work in 2018 on the transfer of archive records of sources to electronic form.

In the current Technical Regulations on Radiation Safety [12], there is no provision on the need to develop a national policy and strategy for RW management. Thus, regarding the legacy RW remaining after the closure of the former USSR uranium production facilities, the main tasks of the SRCEPES are:

 development of a strategy for managing sites with RW, which will take into account the threats identified in the country for the period 2009-2019 (i.e., increasing the capacity of sites, increasing the capabilities of personnel, developing local programs for each site, developing anti-radon protection programs, creating a single monitoring base, management of sanitary protection zones etc.); and

Figure 10. Completion of the remediation at Kaji-Sai tailing pond (strengthening of the slopes of the storage, construction of a new dam, construction of a mudflow allotment, surface restoration), March 2019

 development of a Regulation on the Unified State System of Radioactive Waste Management (considered in the draft of the new Law “On Nuclear and Radiation Safety”).

The main concerns of the MES in relation to the jurisdictional tailings and mining dumps are currently:

 measures to prevent emergency situations [18-20]; and

 remediation of uranium legacy sites see example in figure 10.

It should be noted that the Technical Regulations on Radiation Safety [12] have the following disadvantages in the context of radioactive waste management:

 There are no safety requirements that apply to existing exposure situations and specifically irradiation caused by radioactive contamination of territories with residual radioactive material resulting from activities in the past that have never been under regulatory control or that have been covered by regulatory control but not in accordance with the requirements of current regulations.

 There are no safety requirements that apply to nuclear or radiation emergencies after the announcement of the end of the emergency exposure situation.

 There is no list of practices and sources for which exposure is classed as an existing exposure situation.

 There are no requirements on assessing identified existing exposure situations in order to determine the types of occupational exposure and public exposure requiring attention from the point of view of radiation protection.

 There are no safety requirements that apply to existing exposure situations and:

 carrying out remediation work, including the removal of sources of contamination / alteration of exposure pathways and management of radioactive waste generated

 identifying the person or organization responsible for any control measures after the completion of remediation activities

 introducing, if necessary, certain restrictions on the remediated territory in order to control access by unauthorized persons, removal of radioactive material or use of such material, including its use in consumer goods, or future use of the territory, including the use of water resources and its use to produce products or animal feed, as well as the consumption of food products produced in the territory.

 There is no requirement to provide justification for remedial and protective measures and to optimize the protection and safety of the population in situations of existing exposure.

 There is no requirement for the Government to ensure that measures are taken to identify persons or organizations responsible for territories with residual radioactive material, to develop and implement remediation programs, and, where appropriate, to take control measures after remediation; for implementing a proper radioactive waste management strategy.

 There is no requirement for the persons or organizations responsible for the implementation of remediation measures:

 to be responsible for all aspects of protection and safety, including conducting a safety assessment

 to prepare and submit to the regulatory body or other relevant competent authority for approval a remediation action plan supported by the results of safety assessments

 to ensure that work is carried out, including the management of the generated radioactive waste, in accordance with the remediation plan

 to regularly monitor the territory during the implementation of remediation measures to check levels of radioactive contamination, check compliance with the requirements for radioactive waste management and detect any unforeseen radiation levels and make appropriate adjustments to the recovery plan after they are approved by the regulatory body or other relevant competent

authority;

 to conduct radiological surveys after the completion of remediation measures in order to confirm the fulfillment of the conditions for achieving the final goals defined in the recovery plan; or

 to prepare a final report on the implementation of remediation measures and submit it to the regulatory body or other relevant competent authority.

 There is no requirement that, after completion of remedial actions, the regulatory body or other relevant competent authority:

 considers, makes changes as necessary and formally establishes the type, scope and duration of any measures after remediation control, previously defined in the plan of remediation measures, with due regard for residual radiation risks; and

 periodically reviews the conditions in the remediated area and in appropriate cases alters or cancels any restrictions.

 There is no requirement, after completion of remediation measures, to ensure the development and implementation, within the period of time required by the regulatory body or other relevant competent authority, of an appropriate program providing for any necessary monitoring measures to verify the long-term effectiveness of the remediation measures taken in territories requiring the application of control measures after remedial measures have been completed.

4.6.2 Regulation of Safety in Management of Disused Sealed Radiation Sources Declared as