Ian Crossland Crossland Consulting Ltd

1. Overview of model regulations for borehole disposal of disused sealed radioactive sources Ian Crossland Crossland Consulting Ltd School of Drafting Regulations for Borehole Disposal of DSRS

2. Outline/ Contents • A systematic description of a draft IAEA document containing model regulations for BDC disposal of DSRS 2

3. Main references Draft prepared at a consultancy meeting 5-9 Oct 2015

4. Objective of the document Provide States with model regulations covering pre-disposal and disposal of radioactive waste, especially DSRS, using the BDC. Focus on: • establishing and maintaining regulatory control; • achieving and maintaining safety; • defining responsibilities of principal parties

5. STRUCTURE OF THE MODEL REGULATIONS • PART 1 - GENERAL PROVISIONS (11) • PART 2: LICENCE APPLICATION, RECORD KEEPING AND REPORTING (7) • PART 3: SAFETY MANAGEMENT (3) • PART 4: SAFETY OBJECTIVES AND THEIR ACHIEVEMENT (10) • PART 5: PLANNING AND PREPARATION OF BDC DISPOSAL (6) • PART 6: IMPLEMENTATION OF BDC (7)

6. PART 1 - GENERAL PROVISIONS Article 1: Entry into Force Article 2: Purpose Article 3: Scope Article 4: Definitions and Abbreviations Article 6: Responsible Parties Article 7: Regulatory Inspection of Premises and Information Article 8: Non-Compliance and Accidents Article 9: Enforcement Article10: Applicability of other Regulations and Requirements, and Resolution of Conflicts Article 11: Additional Requirements Article 12: Interpretation

7. 1.2 PURPOSE • The model regulations aim to • Identify the basic safety requirements when preparing for and implementing the BDC • Respect relevant international commitments • Place a duty on licensees to take additional actions, as necessary, to protect the health and safety of people and the environment.

8. 1.3 scope • Limited to the licensing of the disposal of radioactive waste using the BDC, including • safety of people and the environment; • pre-disposal, operational and post-closure periods; • radiological and non-radiological considerations. • Covers siting, planning and preparation for BDC disposal. In particular: • Waste characterization • Waste processing • Waste storage • Site characterization • Construction, operation and closure of the BDC facility. • Model regulations allow for the possibility that a would-be operator may be already authorized to manage DSRS

9. 1.6 RESPONSIBLE PARTIES • Principal parties: (1) licensee, who always has prime responsibility for safety; (2) employers of workers, in relation to occupational exposure; (3) those dealing with emergency or existing exposure situations. • Other parties: (a) Providers of equipment and software; (b) Radiation protection officers; (c) Qualified experts or any other party to whom a principal party has assigned specific responsibilities; (d) Workers other than workers listed in (a)-(c)

10. PART 2: LICENCE APPLICATION, RECORD KEEPING AND REPORTING Article 13: General Obligations Article 14: Requirements for Notification Article 15: Requirements for Authorization by Licence Article 16: Responsibilities of Licensees Article 33: Inventory and Records Article 42: Emergency Plan Article 43: Physical Protection and Security

11. 2.13 general obligations and 2.14 requirements for notification • Implementation of BDC is limited to authorised persons • Any legal person wanting to implement the BDC must notify the regulatory body and supply the required information (yet to be developed) • This legal person may then be required to apply for an approval to proceed further

12. 2.15 Authorization by licence Main components of licence application (i) Demonstration of safety (safety case); (iii) Emergency plan; (iii) Demonstration of adequate resources to satisfactorily complete the disposal  Licence application shall address all elements of BDC waste management including Waste characterization - conditioning/ containerization – storage - design, manufacture and handling of containers - site characterization – borehole design and construction – waste emplacement - borehole closure – decommissioning -institutional control - environmental monitoring etc

13. 2.16 responsibilities of licensees A very long list including • Licensee’s responsibility for safety • Submission of comprehensive safety case • Adequate understanding of basis of safety • All activities to conform with licence and safety case • Naming of suitably qualified competent legal persons • Operating procedures within a management system • Arrangements for learning from incidents & accidents • Defence in depth • Adequacy of structures, systems and components, including software • Prevention of accidents, mitigation of consequences, training of workers • Application of good engineering practice • Etc

14. 2.33 inventory and records • Inventory of all radioactive material • Could include RW other than DSRS • RW to be disposed • Records of • doses from occupational exposures; • relating to facilities and activities; • events, non-compliances, non-routine releases; • issues relevant to decommissioning & closure; • testing of instruments and safety systems as required by the Regulations. • Information provided to Reg Body as required

15. PART 3: SAFETY MANAGEMENT Article 22: Management System Article 23: Safety Culture Article 24: Qualified Experts, Radiation Protection Officers and Radioactive Waste Management Officers

16. 3.22 MANAGEMENT SYSTEM Many requirements including • Safety to be given top priority within the management system • A commitment to safety at the highest levels of the organization • Application of the graded approach • Prompt identification, reporting and correction of problems / deficiencies • Clear lines of authority and allocation of responsibilities; • Clear and effective lines of communication within the organization. • Quality assurance programme that includes programme review, external audit, record keeping etc • Procedures to enable learning from experience • Establishment of safety culture.

17. 3.23 SAFETY CULTURE Many requirements including • Commitment to protection and safety at all levels of the organization; • Common understanding of safety culture; • Wide participation in the development and implementation of policies, rules and procedures; • Accountability of the organization and of individuals; • Open communication • Questioning and learning attitude and discouraging complacency • Continued development and strengthening of safety culture.

18. 3.24 QUALIFIED EXPERTS If required by the RB the licensee will provide suitably qualified and experienced experts on • licensing • radiation protection (the RPO) • radiation safety (RPO may fill this position if the practice is relatively low risk) - Regulatory body to be informed regarding the arrangements for these three positions • Radioactive Waste Management Officer. This person may act as the qualified expert in radiation safety if the practice is relatively low risk)

19. PART 4 SAFETY OBJECTIVES AND THEIR ACHIEVEMENT Article 20: Fundamental Safety Objective Article 21: Optimization of Protection and Safety Article 27: Non-Radiological Impacts Article 29: Preparation and use of Safety Case and Assessment Article 30: Safety Case Article 31: Safety Assessment Article 32: Monitoring, Testing and Verification of Compliance Article 18: Investigations and Feedback of Operating Experience Article 34: Interdependences and Interactions Article 36: The Period after Closure and Institutional Controls

20. 4.20 fundamental safety objective To protect people and the environment via three main directions: (a) To control radiation exposure of people and releases of radioactive material to the environment; (b) To restrict the likelihood of events that might lead to a loss of control over a radioactive source ie prevention of accidents/ incidents; (c) To mitigate the consequences of such events if they were to occur.

21. 4.29-31 SAFETY CASE & SAFETY ASSESSMENTS Long list of requirements including Safety case to be comprehensive; to be prepared early and progressively developed; to allow for updating in light of modifications, emerging issues etc; to provide multiple safety functions; to give assurance of constructability and operability….. Safety assessments to identify ways in which exposures could be incurred; to assess doses and risks; to determine limits controls and conditions including waste acceptance criteria (WAC); to follow ISAM methodology; highlight deviations from “standard BDC”; provide assurance that WAC will be complied with.

22. PART 5: PLANNING AND PREPARATION OF BDC DISPOSAL Article 45A: General Provisions Article 47 Sequential development Article 44: Characterization of waste Article 45B Conditioning of DSRS Article 45C Containerization of waste Article 46: Storage of Conditioned and Containerized waste

23. 5.45A GENERAL PROVISIONS • Early conditioning to produce passive waste form • Containerizing of conditioned waste to produce a disposable waste package • Graded approach • Plan for dealing with secondary waste

24. 5.47 SEQUENTIAL DEVELOPMENT

25. PART 6: IMPLEMENTATION OF BDC DISPOSAL Article 50: Site Characterization Article 51: Site- and Inventory-Specific Design Article 56: Construction Article 58: Operation Article 62: Closure Article 63: Decommissioning Article 64: Institutional control

26. 6.64 INSTITUTIONAL CONTROL • A possible end-point is restricted release of the facility or site from regulatory control (e.g. de-licensing but with requirements for ongoing monitoring) • Controls are then applied to guarantee safety: these to be approved by the regulatory body • Responsibilities to be clearly assigned for (i) implementing and maintaining institutional controls and (ii) responding to any issues that may arise

27. Summary • Model regulations now exist to control the development and implementation of the BDC. Will probably be published as a TECDOC • These build on, but avoid repeating, existing model regulations in TECDOC 1732. Also SSR-5 and SSG-1 • Takes a non-prescriptive approach. This provides flexibility but places a greater burden on the licensee to fully understand what he/ she is doing • Much will depend on the quality of the safety case and the effectiveness of the management system

28. Thank you!