Horst Monken-Fernandes Waste Technology Section NEFW

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Horst Monken-Fernandes Waste Technology Section NEFW Determination of Site End-State in Environmental Remediation – The IAEA ENVIRONET-DERES Project Environet Plenary Meeting Vienna, 05 – 07 December 2017 This is a topic that has become of extreme relevance and interest to MS’s. The idea of this presentation, that can not be extensive due to time limitations, is just to give a favour of how WTS is responding to this demand that was also highlighted in the Madrid Conference last year. Will not go through all the slides, but they can be used as a reference for further discussions. Horst Monken-Fernandes Waste Technology Section NEFW

Project objectives are: The IAEA DERES-Project Decommissioning and Environmental Remediation End-States This topic has been suggested during the 2014 Plenary Meeting of the Environet So far 2 CM’s and 1 TM have taken place. Core group Canada, France & Germany, Norway, USA, UK. Draft report available. Shared with ICRP Task Group 98 (which is considering the application of ICRP Recommendations to exposures resulting from contaminated sites from past industrial, military and nuclear activities) and NEA-OECD Expert Group on Legacy Management Project objectives are: Raising awareness of the importance of a consistent determination of end-states for the ultimate success and sustainability of ER efforts Gain an overview of the international state-of-the-art in End State selection Provide participants with approaches to determine and reach consensus on end-states through a decision making process and make sure these tools and approaches are of practical relevance and applicability Now the DERES project. The initial working title was Definition of Environmental remediation Site End-States but representatives from UK and France pushed for the cosndieration of site under decommissioning. Focus on the 3 objectives of the project. Mention the working groups DERES is articulated with. WATEC 2017

Definitions Term Proposed Definition End-State End-Point End-Use A predetermined criterion defining the point at which a specific task or process is to be considered completed. Used in relation to decommissioning activities as the final state of decommissioning of a facility; and used in relation to remediation as the final status of a site at the end of activities for decommissioning and/or remediation, including approval of the radiological and physical conditions of the site and remaining structures. End-Point A predetermined criterion defining the point at which a specific task or process will be considered completed. This usage often occurs in contexts such as decontamination or remediation, where the end point is typically the level of contamination beyond which further decontamination or remediation is considered unnecessary. Such criteria are often calculated on the basis of a level of dose or risk that is considered acceptable. End-Use In a broad sense it is the application or function for which something is designed or for which it is ultimately used. In more specific terms it is the use to which the land is put in the future after the decommissioning/clean-up has finished. Clean-up (not a direct synonymous of remediation) The removal of a chemical substance or hazardous material from the environment to prevent, minimize or mitigate damage to the public health, safety or welfare, or the environment that may result from the presence of the chemical substance or hazardous material. The clean up is carried out to attain specified clean up criteria Reference Level Represents the level of dose or risk above which it is judged to be inappropriate to plan to allow exposures to occur, and below which optimisation of protection should be implemented. Limit The value of a quantity used in certain specified activities or circumstances that must not be exceeded One main point to be addressed is some sort of harmonization of terminology. In the DERES project that I will talk about little latter this has become really a relevant issue. Just refer to End-State definition.

End-state on Environmental Remediation When we start planning an environmental remediation project, we need to understand what we are trying to achieve End-State describes the physical conditions to be achieved that make intended future use of the site possible and are appropriately protective of people and environment WATEC 2017

The end state criteria is specified in the final decommissioning plan But also needed in Decommissioning (from IAEA GRS Part VI - Decommissioning of Facilities Decommissioning actions are considered completed when the approved end state of the facility has been reached; This end state is a result of conducting decontamination and/or dismantling, management of waste and cleanup, leading to the release of the facility from regulatory control with or without restrictions on its future use The end state criteria is specified in the final decommissioning plan It is the responsibility of the licensee verifying that end state criteria have been met by performing a final survey Decommissioning end state shall not impose undue burdens on future generations The regulatory body shall review the final decommissioning report and shall evaluate the end state to ensure that all regulatory requirements and end state criteria, as specified in the final decommissioning plan and in the authorization for decommissioning, have been met. If the approved decommissioning end state is release from regulatory control with restrictions on the future use of the remaining structures, appropriate controls and programmes for monitoring and surveillance shall be established and maintained for the optimization of protection and safety

Different Regulatory Framework for D&ER In existing exposure situations Reference Levels assume any value between 1 – 20 mSv/y. Optimization is to be applied ICRP Publication 103 This slide illustrates that the framework for site release in a decommissioning process is quite different from what could be achieved during remediation of existing exposure situation. In our discussions it has been evoked that the intended end-states in the decommissioning process might not be easily achieved or if technically possible at a very high cost. Questions on the sustainability of such end-states have been raised. SUGIYAMA, D. IEM-IAEA (2013) IAEA Safety Guide No WS-G-5.1

Draft Report to be further developed and consolidated in 2018; Outcomes Draft Report to be further developed and consolidated in 2018; e-learning module produced and will be available soon in Environet web-space in Connect

End-State x Future Use of the Land End state equates to the quality of land, buildings and structures left behind when the clean-up programme is completed. “Quality” means the degree of any residual radioactive or chemical contamination or other risks such as any remaining structures and physical features. Deciding on end state is not the same as deciding on the future use of the land but the two issues are closely related. Many future uses will only be possible if a particular end state is achieved. Important to distinguish between end-state and future use. Particularly interesting is the perspective of a TWG of NEA as you can see in red in the bottom of the slide. “Minimisation of one detrimental impact is always likely to result in something else not being minimized. Hence the need for holistic view of optimisation.” NEA 7305, 2016.

Two broad choices for the end-state The end state allows the site to be delicensed and used for any reasonably foreseeable purpose*. For example, the fence is removed and the land is used for housing, amenity and business development of some type. The end state is not clean enough to permit delicensing. Future use remains restricted to operations on a nuclear licensed site and subject to strict operating and security controls. In these circumstances much of the land might effectively fall into disuse. On sites undergoing decommissioning two options can be achieved – the full delicensing of the site or the imposition of some restriction. WATEC 2017

Some examples – Harwell - UK End-State - The Harwell Local Stakeholder Group recommends that the End State for Harwell should be a 100% delicensed site by 2020.” This applies only to the NDA designated part of the campus, which is historically the nuclear licensed area associated with UKAEA Delicensed” - the site should have no areas with a Nuclear Site Licence issued under the Nuclear Installations Act. End Use - The use to which the land is put in the future after the NDA has finished its business” This slide just depicts the intended evolution of the decommissioning of Harwell facility in UK. Harwell in Oxfordshire is seen as the birthplace of the UK nuclear industry. Opened in 1946, it became Britain’s Atomic Energy Research Establishment housing the most advanced radiochemistry laboratories in the world and allowing the safe handling of a wide range of radioactive materials. Harwell’s nuclear reactors and research facilities were built during the 1940’s, 50’s and 60’s and continued to operate until the 1990’s. Evolution of the Licensed Site Area from 2006 to the End State in 2024.

Remediation and reuse objectives are not always aligned (1) Remediated sites should be reused in a way that best serves the community, local and broader economy, and environment. Remediation and site reuse should be considered as a single, interlinked process, not as independent activities. As such, remediation and reuse practitioners should work together, establishing partnerships to share knowledge and resources. A framework for the effective integration of remediation and reuse should be developed that describes a “cradle-to-grave” process to ensure the “best practical use” throughout the project (remediation and reuse) life cycle. In terms of remediation the pursue of reuse of the site is envisaged whenever possible. Therefore reuse and remediation are intertwined. Remediation of Fukushima off-site areas gives us a good example of how these concepts work hand in hand. Remediating the land without recovering appropriate infrastructure is not enough. An issue to be addressed is: How can the remediation of the site deliver value?

Remediation and reuse objectives are not always aligned (2) All remediation and reuse stakeholders should be involved at the beginning of the remediation process where feasible. How can the remediation of the site deliver value? Developers should implement innovative development opportunities and consider sustainable remediation as a means of converting historically dormant sites to beneficial reuse. Stakeholders, from remediation practitioners to developers and from the local community to financers, should receive guidance on the value proposition associated with the highest and best reuse of a site. Measures undertaken to minimize risk to human health and the environment during site remediation and reuse should also be appropriately communicated to these stakeholders.

End-states and land re-use in former uranium mining sites: specifics Remediation of uranium mining sites is unavoidably connected with long-term thinking The retention of wastes on (part of) a site may not allow (full) release for unrestricted use The end-state of (at least part of) these sites is likely to be connected with some form of institutional control for prolonged periods of time The expression ‘long term’, in essence and in human time-scales, effectively means ‘indefinitely’ Skip this one WATEC 2017

Position of the International Community The report focus on the concept of “Sustainable Remediation”. It suggests that: following a sustainable remediation approach; it is not always optimum to remove all contamination, or to clean up sites to be fit for any use. And that the optimal remedial approach may be to include administrative controls (long-term stewardship) to break the pollutant linkage These considerations have great impact on the overall end-state selection Some efforts are being developed by the international community. IAEA had the chance to contribute to this piece of work in which the concept of Sustainable remediation has been addressed.

UK-NDA Approach The NDA is also working in the direction of producing to “outline an approach to explore and make an informed and transparent decision on what is the end-state for a site”. We are also working with close cooperation with UK-NDA that is developing a Guide that is intended to be aligned with the outcomes from the DERES Project. WATEC 2017

Drivers and Constraints on choosing end-state In addition to the views of stakeholders, decisions on end state and the future use of land are constrained by environmental legislation, by statutory planning policy, and by decisions that have already been made on the future use of the land. Whether the site remains licensed or not it would still be necessary to clean-up so that no significant harm to the environment or risk to the public remained. If any material that is a radioactive substance or waste is intended to be left in the land it might be needed to demonstrate that this was the Best Practicable Environmental Option and the best long-term management arrangement. It is obvious that stakeholder views are important and will be an important factor on the decision making process. We have heard about risk-perception and risk communication but as we are working in the frame of another project – The Cider project – this process goes beyond risk perception and risk communication (these things are really part of a broader decision-making process) and getting stakeholders involved and postively contributing to the process is a real challenge. Is consensus always possible?

End-State Determination Process Important to engage with stakeholder throughout the process End-state decision might be revisited. This leads to iterative process  very time consuming, laborious and expensive

Identifying and Evaluating End State Options WATEC 2017

Interim State Determination If a suitable End-state option that satisfies known constraints and drivers cannot be identified, and interim state may be defined as a temporary solution

Conclusions The international community is particularly concerned with the issue of site end-state in both D&ER. The IAEA was tasked to “… to explore the experiences made in the MS’ so far in the definition of end states for D&ER, in order to develop strategies for such projects”. WATEC 2016 IAEA D&ER Conference (Madrid, 2016): “The Conference further recommended that additional consideration be given to establishing international guidelines for post-accident recovery: in the aftermath of an accident it is too late to begin planning and establishing levels such as reference levels, end states and strategies, waste management and disposal strategies At the national level, different countries undertaking major D&ER programmes are developing guidance in this direction e.g. UK-NDA Major consideration will need to be given to prevailing regulatory requirements The concept of Sustainable Remediation is an important driver to the discussions Strong stakeholder engagement process is needed

Acknowledgment Appreciation for the contribution to this presentation given by: Christian Kunze IAF/Dresden –Germany (Chair of DERES Project) Malgorzata Sneve – NRPA (Norway) Kim Baines (UK-NDA) Keith Cunningham (Saskatchewan Ministry of the Economy – Canada)

Next DERES Meeting 19 – 23 March 2018 IAEA HQ’s Vienna You are Welcome

Thank you! Thank you!