Remediation

- A Time for Learning

- A Time for Action

presented by Mark Bassett, Sellafield Programme Director

on behalf of Mike Weightman, Chief inspector ONR

Health and SafetyExecutive

Remediation

Where hazards exist from:

• past operations; or

• accidents;

remediation is necessary.

Remediation is about TAKING ACTION to reduce the risk and hazard to an acceptable level

A time for learning

Problems of remediation are not unique to any country

No country can claim to have all the answers

We need to learn from each other

IAEA has a role in facilitating this learning.

Lessons from Fukushima

There has been excellent remediation progress made at Fukushima.

What lessons can we learn?

Remediation Regulation

Remediation requires a different regulatory approach to normal operation.

Delaying action until all questions have been answered may result in the situation deteriorating

• This requires flexibility in approach and

• A dynamic responsive regulator

UK ExperienceMany examples of successful remediation:

Four research/isotope production reactors and areas of existing licensed sites, e.g. Winfrith and Harwell

Also examples of very slow remediation:

Windscale >50 years after the accident

Sellafield legacy ponds and silos

(© Sellafield)

Ageing asset degradation and care are key issues

Before

After

Sellafield - Capenhurst

Before

After

Sellafield - Capenhurst

Before

After

Sellafield - Capenhurst

Before

After

Sellafield - Capenhurst

© Magnox

© Magnox

Why do remediation delays occur?

Many potential reasons, e.g.

• Inappropriate funding

• No incentivisation

• Uncertainty (waste, asset condition and technical)

• Poor costing

• Over analysis (“paralysis by analysis”)

• Lack of appropriate waste storage or disposal routes

• Over regulation and too stringent clean up levels

• Lack of necessary skills or equipment

• Lose sight on the urgency of doing something – passive acceptance

• Time consuming bureaucracy

What can regulators do?

We don’t offer a solution but we do want to prompt discussion.

What we can do is ensure that we are not a source of delay through over regulation and provide regulatory support where appropriate.

Fit for Purpose Safety Cases

Is it better to await a fully developed safety case than to act now?

How much analysis is necessary for a safety case to be fit for purpose?

How can we mitigate risks if we act now?

How do we deal with uncertainty?

How should ALARP be applied?

Step by Step Hazard Reduction

It may be some time before the desired end state can be reached.

Can we achieve some interim states that achieve some hazard reduction, for example by conditioning wastes into a more passive form?

Balancing Risks

Should we accept increased short term risk in exchange for longer term increased safety?

If so, how much more risk?

Other Considerations

Can we legitimately and safely increase doses to workers involved in remediation?

Do we need to invest in new plant to replace plant where the old plant has too much risk and before the waste has a disposal route?

Conclusions

The longer we wait to act in remediation, the more difficult the problems become

Regulators and regulations must not become part of the problem by causing unnecessary delays

We cannot afford to ignore the opportunities to learn from each others’ experiences.

Remediation

- A Time for Learning

- A Time for Action

presented by Mark Bassett, Sellafield Programme Director

on behalf of Mike Weightman, Chief inspector ONR

Health and SafetyExecutive