IRRS mission in Greece V. Kamenopoulou Greek Atomic Energy Commission IRRS Liaison Officer www.eeae.gr www.gaec.gr

The outcome: IRRS Mission report 28 Recommendations 10 Suggestions 8 Good practices Relevance with the self-assessment findings

Responsibilities and functions of the Government R1 The Government should develop a consolidated statement that sets out the national policy and strategy for safety. R2 The Government should ensure that the persons or entity with responsibilities for the implementation of regulatory requirements are explicitly specified. R3 The Government should provide for a graded approach in the implementation of the regulatory framework. R4 The Government should establish and maintain a national policy and strategy for radioactive waste management including provisions for the decommissioning of facilities, management of radioactive waste and related financial provisions. R5 The Government should expressly assign the prime responsibility for safety to the person or organization responsible for a facility or activity within the legal framework for radiation safety. S1 The Government should consider conferring legal authority to strengthen GAEC’s powers of enforcement.

Responsibilities and functions of the Government GP1: The team noted the strong commitment of GAEC to the training of medical physicists in radiation protection Inter – University Postgraduate Course in Medical - Radiation Physics 60 hours of theory and practical exercises in radiation protection exams in front of a Committee of MoH in radiodiagnosis, radiotherapy, NM and radiation protection

Responsibilities and functions of the regulatory body R6 GAEC should provide for a further operational separation between technical services and the regulatory function to minimize the potential for conflicts of interests. R7 GAEC should implement a systematic training program on the basis of an analysis of the necessary competence and skills for the regulatory body.

Responsibilities and functions of the regulatory body GP2: The team acknowledges the excellence of the national database system for radiation protection maintained by GAEC GP3: The team acknowledges the excellence of the Annual Report published by GAEC Relational data base including: data regarding the laboratories using or producing radiation, such as administrative issues, equipment, radiation protection, inspection results; the inventory of the radiation sources; data for transport and distribution of radioisotopes; the National Dose Registry, where information related to occupationally exposed workers and the registered doses are kept; data about the qualification and training on RP; the environmental radioactivity measurements results; the results from electromagnetic fields, in situ inspections and measurements.

Management system of the regulatory body R8 When developing the integrated management system, GAEC should ensure that it is aligned with GS-R-3. R9 GAEC should foster staff commitment to the quality systems and to the integrated management system. R10 GAEC should make sufficient resources with the appropriate authority available when developing and implementing the integrated management system. R11 GAEC should include a specific process for the management of organizational change in the integrated management system. R12 GAEC should explicitly address safety culture in the integrated management system. S2 GAEC should consider preparing a plan for the development and implementation of the integrated management system. S3 The Government should consider establishing specific processes for the management of organisational change across all competent authorities dealing with radiation safety

Authorization R13 GAEC should further develop guidance on the format and content of the documents to be submitted by the applicant in support of an application for licensing of facilities and activities. R14 GAEC should improve the implementation of a graded approach in the authorization process. R15 GAEC should enforce the licensing requirements for all facilities at NCSR “Demokritos”, including the interim storage facility. S4 GAEC should consider improving the coordination with Prefectures to avoid delays in the licensing renewal process which can result in facilities operating without a valid license. S5 GAEC should consider revising its licensing approach in order to include conditions, limits and controls on licenses and or certificates of compliance.

Review and assessment R16 GAEC should document the procedure to review and assess the safety assessment reports that demonstrate the safe operation of the facilities and activities.

Inspection R17 GAEC should provide inspection results officially to the operator of the NCSR “Demokritos” waste storage facility, and ensure that the inspection findings are addressed. S6 GAEC should consider reducing the influence of the license renewal process on the inspection programme.

Enforcement R18 GAEC should formalize its enforcement policy in line with a graded approach and incorporate it into the integrated management system.

Regulations and Guides R19 GAEC should prepare updated Radiation Protection Regulations to bring them in line with the current IAEA Safety Requirements for submission to the Government. R20 GAEC should establish safety requirements for decommissioning of facilities and pre-disposal management of radioactive waste. S7 The Government should consider adopting a more flexible hierarchy of Radiation Protection Regulations. S8 GAEC should consider incorporating a waste classification scheme into its regulatory system.

Emergency and response R21 GAEC should liaise with relevant organizations, to conduct the assessment of hazards at the national level in accordance with GS-R-2.

Emergency Preparedness and Response GP4: GAEC’s real time monitoring of radioactivity levels at various locations in the country by means of a network of telemetric stations contributes significantly to identifying the initial phase of a potential radiation emergency due to events within or outside the country -24 stations (γ dose rate, aerosols) -GAEC web site, EURDEP GP5: GAEC has successfully advocated the inclusion of the radiation protection course, which covers the recognition of radiation injuries, into the basic curricula for medical doctors. -1st year of medical school, 40h (radiation physics, radiobiology, dosimetry, RP)

Transport R22 GAEC should collaborate and coordinate with other Greek authorities with assigned competence for the transport of radioactive material to: facilitate the timely and effective exchange of information; and enable effective coordination of regulatory functions. R23 GAEC should review, develop and strengthen its capacity for review and approval of package and material designs R24 GAEC and other transport competent authorities should implement appropriate, coordinated, compliance assurance programmes. S9 The Government should consider revising its regulatory framework for the transport of radioactive materials to provide for a contemporary set of requirements which are fully consistent with the international regulatory framework

Control of medical exposure R25 GAEC should ensure that all health professionals with specific duties in relation to the radiation protection of patients have adequate education, training and competence in radiation protection. R26 GAEC should verify that no person incurs a medical exposure unless there has been an appropriate referral. R27 GAEC, in collaboration with the Ministry of Health and the relevant professional bodies, should complete the process for the determination of national DRLs for all diagnostic procedures.

Control of medical exposure GP6: In 2011, referral criteria were published by the Hellenic Radiological Society based on European Guidance.

Occupational Radiation Protection GP7: Greece has developed the technical capability to perform biological dosimetry in case of overexposures. Laboratory of Biological Dosimetry: used in case of overexposure or suspected overexposure

Environmental monitoring – public protection GP8: GAEC requires the scrap metal industry and the customs authorities to establish portal monitoring. steel industries obliged by Law (1999) to install portal monitoring. fixed radiation monitors at 3 main land borders, International Athens Airport and Piraeus Seaport. Portable detectors for secondary inspection. portable radiation detection equipment for use by Customs at 26 additional points of entry.

Control of chronic exposure and remediation R28 GAEC should ensure clear separation of its regulatory functions from any advisory actions given to the operator for existing exposure situations and remedial actions.

Thank you for your attention Greek Atomic Energy Commission P.O Box 60092 Agia Paraskevi 15310, Athens T: +30 210 650 6700, F: +30 210 650 6748 E: info@eeae.gr www.gaec.gr facebook.com/eeaegr twitter.com/#eeaegr