Health and SafetyHealth and Safety Executive

Integrating Waste Management PracticablyPracticably

Within the Nuclear Industry Lifecycle, Nationally and Internationally

DECOM12, Manchester, 27th June 2012

Neil Blundell, ONR Officer for International Strategy and Coordination

Health and SafetyHealth and Safety Executive

The views presented here are developing thoughts within the Office for Nuclear Regulationthoughts within the Office for Nuclear Regulation

and not Official Views of the Organisationor HSE

Structure of the Presentation

• What is the UK policy for radioactive waste management and its importance to operators and fundingits importance to operators and funding

• Regulatory requirements for waste management

• New European DirectiveNew European Directive

• Waste management planning and the link to Funded Decommissioning

• Integration of waste management in the UK

• Challenges for the future

Basic PolicyBasic PolicySafety and Environment

UK Government’s basic policy is to ensurepolicy is to ensure adequate statutory powers and other measures to protect people and the natural

i t f h f lenvironment from harmful levels of radioactivity

What is Waste?

Definition of Waste• It is the decision of the owner of any

di ti t i l t h th th iradioactive material as to whether there is any foreseen use and hence whether it is radioactive waste

• Regulatory control is the same under nuclear licensing whether or not it is declared as waste – hence the type and level ofwaste – hence the type and level of regulatory control does not depend on such decisions by the owners

Government Policy : yAdoption of Waste Management Hierarchy

• Why should it interest

MOST PREFERABLE

Why should it interest the Operator?

• Waste costs

Reduce

RWaste costs• Avoid waste creation• Need a disposal R l /

Reuse

• Need a disposal route

• Disposal Routes

Recycle / recover

Disposal Routes have finite capacity or do not yet exist LEAST PREFERABLE

Prepare for disposal

LEAST PREFERABLE

Fundamental Principle• Aim: Reduce the quantity of radioactive waste• How: By carefully managing the sources of that waste• P i i l Th l t th l d t di• Principle: The less you create, the less you need to dispose

Thi kThink ‘Source of Waste’Source of Waste

not ‘Waste’

SafetyRegulatory Bodies

SafetyIncluding Radioactive Waste

Management on Nuclear Sites and RMT

Environment

Joint WorkingJoint Working

Joint Regulation• Interdependencies in Spent Fuel and Radioactive Waste Management• The handling treatment, storage and reprocessing of spent fuel, and the

management of radioactive waste are all prescribed activities under NIA65. g p

• ONR Transport programme regulates transport

• The environment agencies (EA and SEPA) require prior authorisation, under EPR10 and RSA93, before radioactive waste is disposed of.

• ONR internally coordinate via a Memorandum Of Understanding, at present to ensure consistent and complementary regulation with transport and with p y g pthe environment agencies in England, Wales and Scotland

National Legal Requirements

Accumulation of Radioactive Waste• Licence Condition LC32 requires licensee to ensure that the rate of production

and total quantity of radioactive waste accumulated on the site is minimised andand total quantity of radioactive waste accumulated on the site is minimised and adequate records are made.

• The environment agencies include a condition in all disposal authorisations that i BPM t b d t i i i th ti it (f li id d t )require BPM to be used to minimise the activity (for liquid and gaseous wastes)

and the volume and activity (for solid wastes) of any radioactive waste generated.

Restrictions on Nuclear Matter on the Site• The purpose of LC4 is to ensure that the licensee carries out its responsibilities

to control the introduction and storage of nuclear matter on the licensed siteto control the introduction and storage of nuclear matter on the licensed site (nuclear matter being fuel, sources, radioactive waste, etc., as defined by NIA65).

• Li diti 17 li ill b

Recent Changes to Licence Conditions• Licence condition 17 - licensees will be required expressly to “establish and implement management systems that give due priority tomanagement systems that give due priority to nuclear safety”.

• Licence condition 36 - places an express duty on the “licensee to provide and maintain adequate financial resources”, as well as adequate human resources as previouslyadequate human resources as previously.

Legal Requirements and link with IWS

• Joint regulatory guidance on radioactive waste management ‘http://www.hse.gov.uk/nuclear/wastemanage.htm’

• The Joint Guidance was issued for trial during 2009 and essentially repeats the• The Joint Guidance was issued for trial during 2009 and essentially repeats the philosophy proposed in original discussions with Sellafield Ltd in 2004/5 in a more comprehensive manner.

• It expands the regulatory expectations on the use of relevant good practice in waste• It expands the regulatory expectations on the use of relevant good practice in waste avoidance, minimisation, management and disposal. The guidance seeks to see effective use of waste minimisation, characterisation and segregation. It emphasises the need to be transparent, systematic and optimised.

• It provides advice on the concept of an Integrated Waste Strategy (IWS)

• Significantly the guidance aims to inspire ownership of the IWS by the Licensee as not being a regulatory tool but a device that enables a dutyholder to understand and controlbeing a regulatory tool but a device that enables a dutyholder to understand and control its waste from cradle to grave and thus deliver safety at a minimised cost.

Integrated Waste Strategy

Restating some of the guidance in simplistic terms :

Integrated Waste Strategy

Restating some of the guidance in simplistic terms :-

• An IWS should define a structured approach which is consistent with relevant good practice

• Apply to the management of all the wastes over the whole lifecycle of the site

• Comply with the law

• Be consistent with Government policy and regulatory expectations

• Apply Waste Management Hierarchy

• Adeq atel control ha ards of astes and act to red ce them• Adequately control hazards of wastes and act to reduce them

• Identify all radioactive wastes on and assigned long-term management and/or disposal routes.

Integrated Waste Strategy – VisionIntegrated Waste Strategy Vision

Vision • A UK wide Integrated Waste Strategy that demonstrates that UK radioactiveA UK wide Integrated Waste Strategy that demonstrates that UK radioactive

waste accumulation is ALARP and disposals compliant with the regulation of the respective Environment Agencies

The UK nuclear industry is very

lcomplex

Simplistic Fuel Cycle? – Waste CreationSimplistic Fuel Cycle? – Waste Creation Throughout

UOC f i i

U3O8 purification UO3 conversion to UF4 t U M t l

SPRINGFIELDS

UOC f i i

U3O8 purification UO3 conversion to UF4 t U M t l

SPRINGFIELDS

UOC from mining and conversion to UO3 via solvent extraction

d TDN

UO3 conversion to UF4 using HF

UF4 to U Metal

U metal to PuO2 to MOx Fuel

UOC from mining and conversion to UO3 via solvent extraction

d TDN

UO3 conversion to UF4 using HF

UF4 to U Metal

U metal to PuO2 to MOx Fueland TDN

UF4 to UF6 using F2

Magnox and other Fuel

Effluents to Treatment

2

Plutonium Finishing

Urani m Finishing to

SELLAFIELDand TDN

UF4 to UF6 using F2

Magnox and other Fuel

Effluents to Treatment

2

Plutonium Finishing

Urani m Finishing to

SELLAFIELD

UF6 conversion to UO2 via IDRF l

HA Raff to HALES and WVP

Processes Uranium Finishing to Produce UO3

UF6 conversion to UO2 via IDRF l

HA Raff to HALES and WVP

Processes Uranium Finishing to Produce UO3

UF6 enrichment

IDR process

UO2 to FuelReactor

Spent Fuel to Cooling and Reprocessing

Fuel Dissolution & Solvent Extraction CAPENHURST

UF6 enrichment

IDR process

UO2 to FuelReactor

Spent Fuel to Cooling and Reprocessing

Fuel Dissolution & Solvent Extraction CAPENHURST

UO2 to FuelFresh Fuel to Reactor

UO2 to FuelFresh Fuel to Reactor

• Until recently 42 with 2 of

Nuclear Sites• Until recently 42 with 2 of

these multi-plant sites

• Also now have Studsvik, CumbriaCumbria

• 1 operating LLWR in Cumbria

• 1 new LLW facility for1 new LLW facility for Scotland

• No Geological Disposal Facility yetFacility yet

• Government indicates possibly 10 new reactor sites

Only a Portion of the Whole UK RadioactiveOnly a Portion of the Whole UK Radioactive Waste Inventory

Nuclear Industry is the dominant component in the UK but we also have to take account of :-

• Radioactive materials that may become waste (e.g. unusable uranium, plutonium)

• Highly Active Sealed Sources

O h S• Orphan Sources

• Medical Waste

• Contaminated Flora and Fauna

• Some predominantly LLW set down in LLW Strategy http://www.nda.gov.uk/documents/upload/UK-Strategy-for-the-Management-of-Solid-Low-Level-Radioactive-Waste-from-the-Nuclear-Industry-August-2010.pdf

However not NORM (regulated under other UK laws)However not NORM (regulated under other UK laws)

I t ti l Di iInternational Dimension

European Spent Fuel and Radioactive Waste Managementand Radioactive Waste Management

Directive

Waste Directive - Subject

• COUNCIL DIRECTIVE 2011/70/EURATOM of 19 July 2011

• establishing a Community framework for the responsible and safe management of spent fuel and radioactive waste

• ..to avoid imposing undue burdens on future generations.

• It ensures that Member States provide for appropriate national arrangements for• It ensures that Member States provide for appropriate national arrangements for a high level of safety in spent fuel and radioactive waste management to protect workers and the general public against the dangers arising from ionising radiationradiation.

• It ensures the provision of necessary public information and participation in relation to spent fuel and radioactive waste management while having due

d t it d i t i f ti iregard to security and proprietary information issues.

Waste DirectiveWaste Directive – Scope and Some Obligations

This Directive shall apply to all stages of:

• (a) spent fuel management when the spent fuel results from civilian activities;

• (b) radioactive waste management, from generation to disposal, when the radioactive waste results from civilian activities.

National frameworkNational framework

• (g) national requirements for public information and participation;

• (h) the financing scheme(s) for spent fuel and radioactive waste management in(h) the financing scheme(s) for spent fuel and radioactive waste management in accordance with Article 9.

Waste Directive – Article 9

Article 9 : Financial resources

• Member States shall ensure that the national framework require that adequate financial resources be available when needed for the implementation of national programmes referred to in Article 11, especially for the management of spent fuel and radioactive waste, taking due account of the responsibility of spent fuel and radioactive waste generators.

Waste Directive – National Programme

• Each Member State shall ensure the implementation of its national programme for the management of spent fuel and radioactive waste (‘national programme’), covering all types of spent fuel and radioactive waste under its jurisdiction andcovering all types of spent fuel and radioactive waste under its jurisdiction and all stages of spent fuel and radioactive waste management from generation to disposal..

Waste Directive – Contents of nationalWaste Directive – Contents of national programmes

• The national programmes shall set out how the Member States intend to implement their national policies referred to in Article 4 for the responsible and safe management of spent fuel and radioactive waste to secure the aims of this Directive, and shall include (all of thefuel and radioactive waste to secure the aims of this Directive, and shall include (all of the following) in particular for this presentation:

• (c) an inventory of all spent fuel and radioactive waste and estimates for future quantities, including those from decommissioningg g

• (d) the concepts or plans and technical solutions for spent fuel and radioactive waste management from generation to disposal

• (e) the concepts or plans for the post-closure period of a disposal facility’s lifetime(e) the concepts or plans for the post-closure period of a disposal facility s lifetime, including the period during which appropriate controls are retained and the means to be employed to preserve knowledge of that facility in the longer term;

• (h) an assessment of the national programme costs and the underlying basis and(h) an assessment of the national programme costs and the underlying basis and hypotheses for that assessment, which must include a profile over time;

• (j) a transparency policy or process …….

Some LinkagesSome Linkages National –International - FDP

• Both nationally and internationally there are requirements for licensing, regulation and waste hierarchy

• National and now European Requirements seek integration of managementNational and now European Requirements seek integration of management

• Integration delivers the minimisation of accumulations and thus the scale of the year on year management of material before disposal. Equally the burden of post closure monitoring is reduced as the inventory the needs monitoring is reduced.monitoring is reduced as the inventory the needs monitoring is reduced.

• All of these require funding and the information gathered to deliver these have (as an element) a Funded Decommissioning Plan

• European directive and in separate areas the national legislation requires UK to• European directive and in separate areas the national legislation requires UK to demonstrate integration of waste management and that it is adequately resourced and funded, transparent, programmed and there is public involvement

• There is a need to demonstrate disposal routes and post closure managementThere is a need to demonstrate disposal routes and post closure management

• Integration of the national picture would point towards some central governance for UK

Reflections on Interdependencies -pTransportation and Timescales

DounreayDounreay

• 29,145 miles (46,904 km) of main roads, 2,173 miles (3,497 km) of motorways

• The National Rail network of 10,072 route miles (16,116 km) in Great Britain

LLWR • 400 miles Dounreay to LLWR

• 400 miles Dungeness to LLWR

• Passes through major cities

• A challenge for ILW?

• Estimates have suggested 20• Estimates have suggested 20 transports per day for 100 years to the GDF

Dungeness

Waste Facilities and AgeingWaste, Facilities and Ageing

Uncorroded [Swarf]

We want this For 100 years

Uncorroded [Swarf]

We want this For 100 yearsNot this

Operators and policy need to recogniseSignificantly Corroded Fully Corroded

Operators and policy need to recognise

PRE-DISPOSAL WASTE MANAGEMENT

Some Safety Case Expectations for WasteSome Safety Case Expectations for Waste Management

• Auditable• Evidence-based approachEvidence based approach• Transparent• Clear• Clear• Strategic and Planned• Managed• Optimised and Minimised (LC32)• Integrated• Delivered

Integrated Waste Strategy – ChallengeChallenges

• Waste quantities, particularly Legacy Waste are not 100% defined

Integrated Waste Strategy Challenge

• Implementation – the policies and guidance exist but it takes time to have effect

• Integration of individual waste management strategies to create a coherent whole – a single focus point or ownerwhole a single focus point or owner

• The generators gathering the right data at the right time and maintaining it

• Delivering effective sustainable waste management for 100+ years

• Using interim storage to advise, manage and clarify the position for the GDF

Treatment Incl. DisposalDirect Dispose where possible

GenerationTreatment Incl. Characterise , Separate, condition, package

Interim Storage to manage, understand and potentially further condition

Disposal

further condition

Information Flow to inform and guide the efforts to manage from the beginning

QuestionsQuestions