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

2. Contents Introduction to legislation Introduction to contamination land assessment, and demolition & decommissioning projects Three case studies April 29, 20152

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) April 29, 20153

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? April 29, 20154

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 April 29, 20155

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 April 29, 20156

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? April 29, 20157

8. Sellafield April 29, 20158

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 April 29, 20159

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 April 29, 201510

11. Drilling at Sellafield April 29, 201511

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 April 29, 201512

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 April 29, 201513

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? April 29, 201514

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? April 29, 201515

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 April 29, 201516

17. Radiological Risk Assessment – Part IIA April 29, 201517 DESCRIPTORS FOR SEVERITY OF CONSEQUENCE OF CONTAMINANT SOURCE-RECEPTOR LINKAGE

18. Radiological Risk Assessment – Part IIA April 29, 201518 DESCRIPTORS FOR PROBABILITY OF CONSEQUENCE OCCURRING

19. Radiological Risk Assessment – Part IIA DESCRIPTORS OF RISK SIGNIFICANCE RISK = SEVERITY X LIKELIHOOD April 29, 201519 Likelihood: Very likely / certain LikelyUnlikely Very unlikely Potential consequence: SevereVery High HighMedium ModerateHigh MediumLow MildMedium LowVery low NegligibleLow Very lowTrivial Likelihood: Very likely / certain LikelyUnlikely Very unlikely Potential consequence: SevereVery High HighMedium ModerateHigh MediumLow MildMedium LowVery low NegligibleLow Very lowTrivial

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? April 29, 201520

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 April 29, 201521

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 April 29, 201522

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 April 29, 201523

24. Waste Management During Decommissioning April 29, 201524

25. Waste Management During Decommissioning April 29, 201525

26. Waste Management During Decommissioning April 29, 201526

27. Waste Management During Decommissioning April 29, 201527

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 April 29, 201529

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 April 29, 201530

31. Acknowledgements Sellafield contaminated land team Hunterston A (Magnox North & Hugh Richards) Bradwell (Magnox South) April 29, 201531

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