1. Identification

1.1 Country Name: IRAQ

Table 1: Current decommissioning situation

Names of facilities
Facilities still requiring a decommissioning plan / Russian Radioisotopes Production Laboratory
Facilities having a decommissioning plan / Tammuz-2 Reactor
Facilities with a decommissioning plan reviewed by the regulator / Tammuz-2 Reactor
Facilities shutdown (Destroyed) and awaiting decommissioning / 1- IRT-5000 Research Reactor
2- Radiochemistry Laboratory
Facilities being under decommissioning / Tammuz-2 Reactor

1.2 Current Licensee and Regulatory body:

The Ministry of Science and Technology (MoST) is the operator of the nuclear facilities in Iraq. The Iraq Decommissioning Programmeis carried out under the responsibility of the MoST/Iraqi Decommissioning Directorate(IDD). MoSTis also the radioactive waste management operator in Iraq.

The Iraqi Regulatory Body for decommissioning and radioactive waste management is the Radiation Protection Centre (RPC) a part of Iraq’s Ministry of Environment (MoEN).

The responsibilities of IDD are:

- Establishing a decommissioning strategy and preparing and maintaining the Decommissioning Plan(DP) and all the support plans and reports for all nuclear facilities under decommissioning;

- Establish a waste management strategy for decommissioning facilities;

- Managing the decommissioning project and ensure that it is carried out safely;

- Identifying an acceptable destination for all waste arising from decommissioning;

- Performing appropriate radiological characterization for all nuclear facilities under decommissioning and radiological surveys on site and surrounding areas, as necessary, in support of decommissioning;

- Keeping records and submitting reports as required RPC;

- Performing safety assessments and environmental impact assessments related to decommissioning;

- Build the technical capacity, to Ensuring that properly trained, qualified and competent staff are availablefor the decommissioning project;

- Prepare all the required equipments and instruments for decommissioning activities;

- All the support contactors must be under supervision of the operator and have to get a license from the Regulatory Body to execute any decommissioning activity;

- Execute the pretreatments and minimization for all the radioactive waste generated from decommissioning activities inside the project site;

- Execute all the decontamination and dismantling activities for all the nuclear facilities under decommissioning;

- Establishing a quality assurance programme as part of the management system;

- Verifying that end state criteria have been met by performing a final survey.

An essential element of the national legal framework is the presence of a regulatory body with the legal powers and technical competence necessary to ensure that any activities or practices are carried out in a safe and secure manner.

The Regulatory Body/Radiation Protection Centre (RPC) is independent of operator;

RPC is an independent regulatory body for the control of activities and practices provided for in the law. The RPC exercise its authority and power under the supervision of the Ministry of Environment.Inits regulatory decision-making, RPC is free from interference by operators and other Government departments or ministries.

The responsibilities of RPC are:

-Establishing criteria and the timeframe for the process of authorization fordecommissioning;

-Establishing requirements for conducting radiological surveys fordetermining levels of contamination at the facility;

-Establishing requirements relating to the safety, protectionof workers and the public, and protection of the environment during thedecommissioning of facilities, including criteria for clearance of materialfrom regulatory control;

-Establishing requirements for planning for decommissioning, including:

  • Specification of the typical content of decommissioning plans andsupporting documents for review or approval;
  • Establishment of the review process for decommissioning plans andsupporting documents;
  • Review of the initial decommissioning plan and updates, review andapproval of the final decommissioning plan and supporting documents,and review and approval of updates after the final decommissioning planhas been approved;

-Providing interested parties with an opportunity to comment on the finaldecommissioning plan and supporting documents before their approval, onthe basis of national regulations;

-Inspecting and reviewing decommissioning actions and taking enforcementactions in the case of non-compliance with the national legal and regulatoryframework, or with the authorization or licence conditions and safetyrequirements established by the RPC;

-Promoting a safety culture in order to encourage a questioning and learningattitude towards safety, and to discourage complacency;

-Establishing requirements for the collection and retention of records andreports relevant to decommissioning, and for preserving information aboutthe activities that have been conducted at the site;

-Evaluating a decommissioned facility in its end state and deciding whetherthe conditions have been met to allow the termination of authorization fordecommissioning;

-Terminating the authorization for decommissioning when the licensee hasdemonstrated that the approved end state has been met.

2. Legal and Regulatory Aspects

2.1 From 2006 until 2008, all parties in Iraq involved in the regulatory control of nuclear radiation safety worked intensively with the USNRC, and the IAEA in developing the draft nuclear law for Iraq, the "Ionizing Radiation Control Law". The intention was to replace all previous legislation in this field and form a single regulatory body.

During this period the experts also developed a comprehensive set of regulations for implementation under the new nuclear law. Topics included radiation protection, decommissioning, waste management, waste disposal, and safe transportation. The regulations were translated into Arabic, and await the formal issue of the new law. However, the General Requirements for Radiation Protectionand Licensing were formally issued by the RPC under the authority of the existing Law No. 99 and the Council of Ministers’ Order.

Decommissioning Regulation No.1 for 2014,andrequirements for exemption and clearance were also issued, based on IAEA standards.

In 2011, the Government of Iraq through the General Secretariat for the Council of Ministers issued a note verbal to all Iraqi Ministries and institutions, including the Higher Judicial Council, identifying the RPC as the official authority responsible for licensing and oversight of all radioactive material, including decommissioning and radioactive waste activities

According to the Prime Minister’s order No. 169 and the Cabinet Resolutions of 2011, the Council of Ministers approved the formation of a new national authority to control nuclear and radiation in Iraq within the Ministry of Environment (MoEN). On that basis a draft Law on National Nuclear and Radiological Regulatory Commission was prepared in 2012. The draft law, agreed by the Council of Ministers and Prime Minister's Office, was submitted to the State Consultative Council and recently approved. This final draft was submitted to the Parliament for approval which is due in 2015.

2.2. Iraq has not participated in the “Legal and Regulatory Aspects of Decommissioning”workshop, which was held Manila, Philippines in 2006. However, in particular, the following aspects are influenced by the participation in the later R2D2P workshops:

(i) Allocation of responsibility of licensee and regulatory body for decommissioning,

(ii) Development of decommissioning regulations,

(iii) Establishing a clearance and the release of buildings and sites.

3. Decommissioning Planning

The decommissioning plan (DP) in place.

The DP established in 2011 and amended in 2012 according to visit Romania in 2011 and following the safety report series No. 45 after that DP was discussed with RPC and IAEA experts through two meeting in Vienna in 2012.

The DP influenced by the Romanian DP in chapter Waste Management and Decommissioning Technique (remote control technique), also we get advantage through the discussion in workshop R2D2 in Romania IN 2011.

3.2 There are five versions issued of Tammuz-2 Reactor DP according to the conditions of our facility status (the facility was completely destroyed in Gulf war) and also according to the Regulatory Body (RPC) and the IAEAexpert comments and recommendations to follow-up the decommissioning requirements and aspects.

3.2.1 Radiological characterization has been done in 2011 for the site by the instruments which were available at that time. In 2013 we get more sophisticated instruments, so we repeat the characterization for same places like the reactor core and get more accurate measures. Iraq does not participate in workshop of characterization in 2007.

3.2.2 Cost estimating and scheduling are integral parts of the decommissioning project from the concept to final completion, and they are linked concurrently, so any change that occurs to the cost will affect the schedule and vice versa. An accurate cost estimate and schedule provide a useful tool to track costs and project trends.

The director of the IDD is responsible for developing, submitting and managing all budgeting and legislative requests necessary for decommissioning as part of the IDP. The IDD are responsible for appropriate and timely budget submissions to ensure that required funds for decommissioning are consistent with project costs estimating and schedule. The IDD is funded by the Iraqi government.Therefore, In Iraq we don’t have problem with funding because it’scentral by the Iraqi government, and all the decommissioning process done by the operator only (without using local or external contractors).Iraq does not participate in workshop of cost estimate in 2009.

3.2.3 Safety assessment report of Tammuz-2 Reactor was influenced by R2D2 workshop in Denmark 2010 through visiting a research reactor and the scientific discussions at that workshop which really help us in writing the plan and the report of Safety Assessment and especially in Risk classification associated with dismantling of Tammuz-2 Reactor. The safety plan and report was discussed with the Regulatory Body and experts of IAEA through the two meeting in 2012.

3.2.4 The Radioactive Waste Treatment and Management Directorate (RWTMD) is a part of MoST and responsible for waste management and establish and operate a system for collection, characterization, transport, storage and processing of all radioactive waste related to the decommissioning program in Iraq.The RWTMD and IDD had agreed upon the working principals of management of the radioactive waste. So, the waste of Decommissioning of Tammuz-2 Reactor integrated into decommissioning activities. Since the reactor was operated for a limited time and because of low power of the reactor (500 MW), the total operation is 1 MWD, most of the generated waste are cleared and released except some core components which are very low level waste. The produced radioactive waste in the decommissioning of Tammuz-2 Reactor are managed and packaged according to the waste accepting criteria (WAC), and transferred to the RWMTD.

3.2.5 The QA department at IDD is responsible for establishing Record Management and Quality Management system and procedures to control all decommissioning activities especially those that have impact on the health and safety of workers, the public, and the environment.However, it is important to mention here that building the capacity in this regard is very important due to the lack of experience in this field

(Up to now IDD don’t have Record Management and Quality Management system).

3.3 The DP was reviewed by the Regulatory Body (RPC) more than four times and after many meeting with RPC, IDD get the license for the DP.

3.4 The preparing of Tammuz-2 Reactor DP was started at 2011 and the license was approved in 2013 by the Regulatory Body RPC.

4. The implementation of Tammz-2 reactor DP was started since 2013 and now the implementation is in phase-4 from six phases.

- Up to now the progress in line with DP.

- The implementation has been influenced by R2D2 by using the techniques of wire cutting diamond for cutting the walls of the hot cells.

- The Regulatory Body oversight as inspections during implementation all the activities of decommissioning.

5. IRT-5000 Reactor is the next project to be decommissioningwill be done in the near future by contract with international company specialist in this field.

6. Nothing.

7. Iraq have got a lot of useful information and knowledge about decommissioning projects for reactor specially, while in the beginning we don’t have any idea or experience about the research reactor decommissioning.

It was justified to spend the money and time for execution of the R2D2 project workshop to get and exchange the experiences between the participants.