Application of Radioactivity and the Law to Contaminated Land ...

Application of Radioactivity and the Law to Contaminated Land ...

Application of Radioactivity and the Law to Contaminated Land and Demolition Projects Gareth Walker, BSc, PhD, MRSC Contents February 6, 2020 Introduction to legislation Introduction to contamination land assessment, and demolition & decommissioning projects

Three case studies 2 Overview of Legislation Main legislation for this presentation Nuclear Installations Act 1965 Radioactive Substances Act 1993 Including Exemption Orders Ionising Radiation Regulations 1999 Environmental Protection Act 1990, Part IIA Site Waste Management Plan Regulations

2008 DEFRA policy on Low Level Waste Management (2007) February 6, 2020 3 Why Undertake an Assessment? February 6, 2020 Obligation & Liability management Obligated to comply with legislation

If they fail to comply, are they liable? What is the extent of the liability? 4 Types of assessments February 6, 2020 Will be focussing on contaminated land and demolition/decommissioning assessment

Assessed through Contaminated land characterisation Risk assessment Remediation options and cost assessments Waste management Materials characterisation 5 Case Studies Contaminated land assessment Sellafield characterisation

Radiological risk assessment at Hunterston A Demolition and decommissioning assessment February 6, 2020 Working in partnership with Serco Assurance Waste management during decommissioning and demolition at Bradwell 6 Considerations Prior to Contaminated Land Assessment

Aim of the assessment Contaminant Source Pathway Receptor February 6, 2020 Leads to a potentially significant pollutant linkage Does the pollutant linkage represent an unacceptable risk? 7

Sellafield February 6, 2020 8 Drilling at Sellafield Overview February 6, 2020 Installation of boreholes Vertical holes (up to 60 m) Understanding ground profile (geology) Collection of soil and groundwater samples Spatial understanding from soil analysis

Contaminant transport Source identification and understanding Pollutant linkages (radiological and chemical) Conceptual model building 9 Characterisation at Sellafield February 6, 2020

Elements of legislation driving this project NIA65 RSA93 IRR99 Drilling boreholes into land with unknown concentrations, isotopes and forms of radioactive contamination Fission products Daughter isotopes Chemical properties Mobility by dissolved phase/colloidal transport 10 Drilling at Sellafield

February 6, 2020 11 Summary - Sellafield February 6, 2020 Worker safety paramount drillers, engineers and general site staff Must maintain nuclear and environmental safety Source terms must be defined

Pathways and receptors must be defined Potential liability relating to contaminated land must be understood 12 Radiological Risk Assessment - Overview February 6, 2020 Hunterston A is in the process of decommissioning and moving towards de-licensing parts of the site

Driver is to put the site into a care and maintenance period Assessment of risk to people and the environment arising from land quality issues at Hunterston A Through this assessment, understanding the liability associated with potentially contaminated land 13 Radiological Risk Assessment - Overview

February 6, 2020 Used land quality data gathered between 2000 and 2008 Review of data and comparison to current legislation NIA65 RSA93 EPA90, Part IIA Guidance (statutory) Establish the extent of risk, if any, to people and the environment Does the site have a liability it needs to address?

14 Radiological Risk Assessment Part IIA Contaminated Land Report (CLR) -11 framework followed to assess risk Tiered approach Generic qualitative risk assessment (GQRA)

February 6, 2020 Phase 1 completed in early 1990s Characterisation completed Areas of Potential Concern (APCs) identified Potentially significant pollutant linkages identified Conservative approach Screens each APC through risk assessment process further work required? 15 Radiological Risk Assessment Part IIA Developed a qualitative risk table Based on the MoD Defence Estates methodology,

and input from other consultancies to Defence Estates In consultation with Magnox North Assesses pollutant linkage based on Magnitude of potential consequence (i.e. Severity) Magnitude of probability (i.e. Likelihood) RISK = SEVERITY X LIKELIHOOD February 6, 2020 16 Radiological Risk Assessment Part IIA DESCRIPTORS FOR SEVERITY OF CONSEQUENCE OF CONTAMINANT SOURCE-RECEPTOR LINKAGE

February 6, 2020 17 Radiological Risk Assessment Part IIA DESCRIPTORS FOR PROBABILITY OF CONSEQUENCE OCCURRING February 6, 2020 18 Radiological Risk Assessment Part IIA DESCRIPTORS OF RISK SIGNIFICANCE Likelihood: Very likely / certain Severe

Very High Moderate Potential consequence: Mild Negligible Likely Unlikely Very unlikely High Medium

High Very High High Medium Medium Low Medium Medium Low Very low Low

Low Very low Trivial RISK = SEVERITY X LIKELIHOOD February 6, 2020 19 Radiological Risk Assessment Part IIA February 6, 2020 Apply to each individual APC

This will define: Is more work required? What work is required? When can you stop? 20 Radiological Risk Assessment - Summary

Using this risk assessment approach allowed: An assessment that is compatible with current law and guidance England & Wales human health only Scotland also, water and ecological environments February 6, 2020 Significance of pollutant linkages to be assessed in a consistent manner across the NDA land-holding Potential contaminated land liability to be better

understood, more readily prioritised and therefore managed 21 Considerations Prior to Demolition and Decommissioning Assessment February 6, 2020 Legislation and guidance requires quantification of waste and materials for site-wide Integrated Waste Strategy (IWS) or Site Waste Management Plan (SWMP) The correct characterisation of items and materials will form part of an IWS or SWMP

Location and extent of chemical and radioactive contamination must be identified 22 Waste Classification Waste classification and fate February 6, 2020

Intermediate Level Waste remains at site creating the waste Low Level Waste shipped to the LLWR at Drigg Very Low Level Waste hazardous waste landfills with RSA93 licence Exempt waste no regulatory control; free release All waste removed from the site must be, as far as is reasonably achievable, re-used or recycled, with minimum final disposal 23 Waste Management During Decommissioning February 6, 2020 24

Waste Management During Decommissioning February 6, 2020 25 Waste Management During Decommissioning February 6, 2020 26 Waste Management During Decommissioning February 6, 2020 27 Waste Management During Decommissioning

Waste Management During Decommissioning - Summary February 6, 2020 Context for determination of a site strategy for the management of decommissioning wastes and items is determined by Site Waste Management Plan regs Previously required an IWS (EGG01) Waste management plans should be developed with appropriate regulatory and stakeholder involvement and should take into account current best practice e.g. Nuclear Industry Code of Practice

Current decommissioning policy for nuclear sites in under review SD:SPUR / SAFESPUR / SAFEGROUNDS / CoRWM 29 Summary Obligation and liability management Legislation grey areas; overlap; changes On-site as opposed to off-site February 6, 2020 Complex sites

Long histories; many stakeholders Pollutant linkages Characterise; Assess; Mitigate Waste management During characterisation During remediation During demolition & decommissioning 30 Acknowledgements February 6, 2020

Sellafield contaminated land team Hunterston A (Magnox North & Hugh Richards) Bradwell (Magnox South) 31 Application of Radioactivity and the Law to Contaminated Land and Demolition Projects Gareth Walker, BSc, PhD, MRSC

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