Application of Radioactivity and the Law to Contaminated Land and Demolition Projects

1. Gareth Walker, BSc, PhD, MRSC Application of Radioactivity and the Law to Contaminated Land and Demolition Projects

2. Contents • Introduction to legislation • Introduction to contamination land assessment, and demolition & decommissioning projects • Three case studies

3. 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)

4. Why Undertake an Assessment? • Obligation & Liability management • Obligated to comply with legislation • If they fail to comply, are they liable? • What is the extent of the liability?

5. Types of assessments • 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

6. Case Studies • Contaminated land assessment • Sellafield characterisation • Working in partnership with Serco Assurance • Radiological risk assessment at Hunterston A • Demolition and decommissioning assessment • Waste management during decommissioning and demolition at Bradwell

7. Considerations Prior to Contaminated Land Assessment • Aim of the assessment Contaminant Source Pathway Receptor • Leads to a potentially significant pollutant linkage • Does the pollutant linkage represent an unacceptable risk?

8. Sellafield

9. Drilling at Sellafield – Overview • 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

10. Characterisation at Sellafield • 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

11. Drilling at Sellafield

12. Summary - Sellafield • 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

13. Radiological Risk Assessment - Overview • 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

14. Radiological Risk Assessment - Overview • 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?

15. Radiological Risk Assessment – Part IIA • Contaminated Land Report (CLR) -11 framework followed to assess risk • Tiered approach • Phase 1 completed in early 1990s • Characterisation completed • Areas of Potential Concern (APCs) identified • Potentially significant pollutant linkages identified • Generic qualitative risk assessment (GQRA) • Conservative approach • Screens each APC through risk assessment process – further work required?

16. 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

17. Radiological Risk Assessment – Part IIA DESCRIPTORS FOR SEVERITY OF CONSEQUENCE OF CONTAMINANT SOURCE-RECEPTOR LINKAGE

18. Radiological Risk Assessment – Part IIA DESCRIPTORS FOR PROBABILITY OF CONSEQUENCE OCCURRING

19. Radiological Risk Assessment – Part IIA DESCRIPTORS OF Risk significance RISK = SEVERITY X LIKELIHOOD

20. Radiological Risk Assessment – Part IIA • Apply to each individual APC • This will define: • Is more work required? • What work is required? • When can you stop?

21. 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 • 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

22. Considerations Prior to Demolition and Decommissioning Assessment • 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

23. Waste Classification • Waste classification and fate • 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

24. Waste Management During Decommissioning

25. Waste Management During Decommissioning

26. Waste Management During Decommissioning

27. Waste Management During Decommissioning

28. Waste Management During Decommissioning

29. Waste Management During Decommissioning - Summary • 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

30. Summary • Obligation and liability management • Legislation – grey areas; overlap; changes • On-site as opposed to off-site • Complex sites • Long histories; many stakeholders • Pollutant linkages • Characterise; Assess; Mitigate • Waste management • During characterisation • During remediation • During demolition & decommissioning

31. Acknowledgements • Sellafield contaminated land team • Hunterston A (Magnox North & Hugh Richards) • Bradwell (Magnox South)

32. Gareth Walker, BSc, PhD, MRSC Application of Radioactivity and the Law to Contaminated Land and Demolition Projects