10 May 2013

TERMS OF REFERENCE (DRAFT)

Consultants’ Meeting to further develop the guidance document on management of large amounts of radioactive waste after an emergency situation

3-7 June 2013

1. Background

A large number of areas in the world have been affected by radioactive contamination caused by a wide variety of incidents, accidents and past activities involving nuclear facilities. Many of these incidents, accidents, and past activities have resulted in the production of large amounts of radioactive waste as the result of remediation of those areas. Such waste requires proper management until final disposal can be completed. A need has been established for additional guidance with regard to the management of large amounts of radioactive waste after an emergency situation. Experiences and lessons learned from past nuclear accidents, especially the two International Nuclear Event Scale Level 7 events that have occurred at the Chernobyl NPP in Ukraine in 1986 and at the Fukushima Dai-ichi NPP in Japan in 2011 demonstrated the need and importance for providing guidance for the planning for the management of large quantities of radioactive waste following emergency situations.While there has been considerable progress made in the remediation of contaminated areas in many countries, internationally accepted guidance for the management of large amounts of radioactive waste produced by remediation following an accident has not been issued as yet.Under this recognition, the IAEA initiated an activity in 2012 to develop a guidance document on management of large amounts of radioactive waste after an emergency situation. This document is intended to be used as a supplemental document for related IAEA Safety Standards (WS-G-3.1[1] etc.) focusing on providing ideas, guidance, and lessons learned from past experience for the management of large amounts of radioactive waste generated from:

Remediation activities performed immediately after incidents and accidents in the affected area that are mixed with waste from the emergency exposure situation / existing exposure situation

Remediation activities performed after incidents and accidents / remediation activity in areas contaminated by past activities.

Taking lessons from these past experiences into account, this publication addresses these issues with the following aims:

Reduce radiation exposure and resultant risk to the public and workers during the remediation activity by introducing a simple and effective licensing framework and methodology to accelerate the licensing process, and

Reduce radiation exposure and resultant risk to the public and environment in the future by identifying important considerations in the decision making processes for radioactive waste management in mixed emergency exposure situation / existing exposure situation zones after incidents and accidents.

1

10 May 2013

2. Objective of the Consultancy

In order to develop the document, the IAEA organized two consultant meetings so far in October 2012 and February 2013. The current proposed document outline is attached as ATTACHMENT I and II. The objective of this consultant meeting in June 2013 is to (1) to discuss issues and lessons learned from the Chernobyl NPP accident related to the safety of management of large amount of radioactive waste; (2) to continue drafting the document focusing on the safety of radioactive waste management after emergency situations, appropriate licensing process, and development of a safety case; and (3) to discuss a work plan for future activities and identify additional needed information to finalize the document.

3. List of questions to Ukrainian ExpertsThe list below gives major points of interests expected to be addressed during presentations from Ukraine and following discussions:

Facts on the activity during the first year after the accident (acute phase / post-accident phase)?

o During the initial phase (approximately first one year from the accident) : Was there any existing planned organization to cope with a nuclear

accident, contamination of territories outside the nuclear facilities since before the accident (even if incomplete or off-scope)?

No pre-planned organization existed for waste management. How were the roles of stakeholders defined and were the organizations set

up in order to cope with activities after the accident (onsite activities / activities in the exclusion zone/ radiation protection of local people /decontamination outside the exclusion zone)?

The involvement of stakeholders was small at first with regard to radioactive waste management. Then the accident influenced the relationship between the government and local communities (change in social perception). As a consequence, it became more important to involve local communities to the recovery process. Nowadays, training of local people for radiation protection is contributing a lot for ensuring safety of the local communities.

How many people have been trained / educated? Who does the training? Objective of the training? (A table with this data will be provided by Mykola Proscura)

How long did it take to set up roles and organizations for coping with those activities after the accident?

A bout half a year. In early 1987, the first enterprise was organized to cope with RWM. In 2010, the system was re-organized in current form. Before the establishment of the first enterprise, most of the activities were performed under military order (not taking into account of interdependencies of RWM). Then after organizing it, it started to work in more organized manner.

2

10 May 2013

Buryakivka was designed in a year. The scale was for 30 trenches, and more than 10 were used during the first year. Not enough data on waste characteristics was collected, and preservation of what was collected was not fully preserved, for waste disposed in first years.

IMPORTANT TO COLLECT & PRESERVE DETAILED RECORDS in order to develop /support the safety case for disposal facilities !

What was a role of local communities, local governments, and federal governments during this phase?

Early in emergency phase, response was essentially from the central government of the Soviet Union; a special government commission was established that included nuclear experts and involved local authorities. This commission was a decision-making body, and there were additional advisory groups. This commission utilized military experience and information from experts; all response (including military) was directed by this commission. Later, local communities became more involved in management of waste management activities.

What policies and action plans existed since before the accident? There were emergency plans for NPPs, but the scale of this

accident was much larger than planned for. There were only simple plans for waste management activities following such accidents.

Did those existing policies and actions plans contain a specific item on waste management from remediation of contaminated territories ?

( Policies and plans for waste management following a NPP emergency were focused on decontamination and waste packaging, but not waste management beyond this)

What policies and action plans did the decision makers set up additionally in order to cope with the accident regarding waste management and radiation protection?

Surveys of contamination (aerial and ground surveys) to provide basis for remediation and waste management activities were performed quickly following the emergency event. Started with aerial gamma, but this did not provide sufficient detail. Then used ground transects (12 sectors, 5-km radius increments) including vertical sampling (to provide soil depth to be removed). These were established in first year. Second mapping in 1998-2000 was more accurate (maps published today are from this second mapping).

Storage sites; PTLRW were used to quickly isolate and shield waste.

Rapid recognition that a waste disposal facility was required; one was quickly designed and constructed (Buryakivka disposal facility). Selection criteria were that this disposal location must be within the Chernobyl zone; that is must have a minimum thickness

3

10 May 2013

of the vadose zone, and that it maximize the distance from rivers. Research was done to examine speed of migration for Sr90 and Cs137 to the Priyat River for this location.

Initially, the military conducted decontamination activities. Early there was lack of experience/knowledge for decontamination.

Waste sorting was based on dose rate, not detailed waste characteristics, in early phase.

In first phase, it was decided very quickly to create three different waste storage types (Buyakivka, Podlensnky, and 3rd type) – these do not directly correspond to current waste criteria.

Policies: o Zoning – different waste management activities in different

zones; zones change with timeo Actions to reduce contamination have different purposes at

different times. Were those policies and action plans reviewed and adapted to incoming

data from the field and how it was done? Strict management with significant military involvement early Administration of the Exclusion Zone created in 1991 (committee

for Ukrainian involvement prior to independence) c With independence, the Ukrainian government created an agency

for management of the exclusion zone… (applies to later phase)

Was there a specific team in charge of reviewing the progress of such action plans and how was it done?

Mykola will provide… Were the ad hoc action plans efficiency reviewed after this short period of

time ? Mykola will provide…

How did you communicate with local people and local governments? Top-down, limited communication

o After the first year since the accident up until now DDid the authorities determine a defining moment where the acute phase

was over? Transition to stabilization phase was not mentioned in official

documents, each has different definitions. Basically, it was considered as the time when short-lived nuclides decayed and civil enterprises started working. Then a committee was established (date?) to discuss countermeasures to cope with situation were prepared including risk assessment of many activities.

4

10 May 2013

Were there any modification on the organization structures and/or roles on them during the emergency phase and post-accident phase?

I n 1987-1988, a specific enterprise was organized to cope with RWM. Since then, RWM started to be performed in more efficient, safe and planned manner.In 1991, the administrative agency on the exclusion zone was created, which was officially mentioned in the legislation. There was a separate division for ChNPP activities in the ministry of Chernobyl affairs.In 2010, the organization was re-organized in current form (State Agency) under the cabinet office, which is coordinated by Ministry of Ecology.

How did you define the roles of stakeholders / set up organizations in order to cope with various long-term activities (onsite activities / activities in the exclusion zone/ radiation protection of local people/decontamination outside the exclusion zone)?

In the first year, local authorities were protection of people (evacuation, radiation protection etc.) The responsibility for survey and mapping was added later. Decision on the necessity of the decontamination was made by the central body, the local authorities also participated in the discussion. Prioritization of decontamination activities were also discussed there. Financial issues were also discussed there. The local authorities also participated in the discussion to find collection points for decontamination waste. (Primary responsibility on decision making was on the central body)

What was a role of local communities, local governments, and federal governments?

3 levels; local communities, local governments, federal government. 3 times, regulations changed (1 Soviet, 2 Ukrainian). Roles have evolved as government organizations have changed.

What kind of policies and action plans did the decision makers set up additionally for long term management?

There were 3-yr, 5-yr programs – not executed completely but were developed and followed. These plans were not very detailed. 1-yr activities were more detailed. Ministry developed detailed plans for waste management. Starting 2000, separate program was developed focused on waste management, approved by government. Several ministries agreed upon plans and executed these. Over past five years a new state program was developed. Adoption international standards, multinational involvement (e.g. Vektor complex).

Basically improvement was done by adoption of international standards, not from lessons from field activities (applies to later phase)

5

10 May 2013

Were those policies and action plans reviewed and adapted to incoming data from the field and how it was done?

Was there a specific team in charge of reviewing the progress of such action plans and how was it done?

How did you communicate with local people and local governments? Did it change from the emergency phase?

Specific questions regarding the National Report JC review report on Compliance with Obligations under the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management [2]… might be additionally asked during the meetingQ1　How did you determine (measure and/or calculate?) radioactivity concentration of rad-wastes prior to carrying-in waste storage facility and waste disposal facility? We would also like to know the procedure of measurement during waste stream.

During the first few years, only dose rate was measured and the RN concentration calculated based on this measurement. Later, laboratory analysis added to provide radionuclide specific measurements. Q2 JC report of Ukraine mentioned that “Preservation projects have been developed and agreed for the Pidlisnyy and ChNPP Stage III RWDP created in the first years of the ChNPP accident to prevent degradation of engineering barriers of these facilities and maintain their confining functions until a decision is made on further radwaste management of long-lived and high-level waste stored in the facilities.”

Integrity of the top soil is investigated by visual inspection every once in a half year. Around 30 PTLRWs among 1000 were liquidated in order to enhance safety. Specifically, what concrete countermeasures are you planning to take to prevent degradation of engineering barriers? Q3　Is there any open document about radioactive waste storage facility, disposal facility and waste packages (i.e. structural drawing, pictures and so on) , except for the national report?

Provided by CD

Present situation on waste management - waste from emergency situation (on-site / exclusion zone / living environment)- waste from long-term stabilization / monitoring activities– radioactive waste management in general (legislation / organization and responsibility / facilities / funding etc.)

Objectives, Schedule and Plan for radioactive waste management - who is in charge of setting up the plan? /DONE- who is in charge of the execution of the plan?- who is in charge of the review and assessment of efficiency?- who is in charge of reporting?

6

10 May 2013

-Does the plan rely on priorities such as : the conservation of the industrial capacities / the conservation of the agricultural products/ the minimization of population displacement/ the amount of time between displacement and possible re-allocation of population? Cost of the associated activities (and who pays for the cost?)

What is the end state? How has it been developed? During the emergency phase, did the USSR use certain existing standards (international

and national) regarding waste management and radiation protection? In the post-accident phase, did USSR then Ukraine use international standards? Were

there any needs for revising or establishing new standards? Considering the activities for the past 25years and the current situation, do you feel a need

for a standardized approach (guideline) on waste management after emergency and also a need for new international standards? If so, what kind of standards will be beneficial to be prepared in such document?

What progress has happened in Ukraine in regard to developing safety cases for current and future disposal options for remediation waste or for nuclear cycle waste?

Lessons / advice on what should and should not be done for other countries / possible future accident (e.g. regarding difficulties Ukraine may have encountered in developing the safety cases)

- What do you think were good decisions made by the authorities during the acute phase/during the post-accident phase? Why do you think so?

- Are there some decisions about waste management that turned out to create even bigger issues in the long run and should have been assessed at the time they were taken? Do you think it was avoidable? If so, how do you think it should be have done?

- Do you think existing international standards on waste management can be applied also to emergency and post-accident phase?

- What kind of regulations or standards would be effective and useful if it was prepared prior to the accident?

- What kind of emergency preparedness would have been efficient considering waste management after the accident?

What should be considered when developing a generic safety case for radioactive waste management facility after emergency situation?

Who should consider post-accident waste management preparation, responsibility and execution if needed and who should be in charge of evaluating the needs prior to the accident? (operator /regulator/ local population or?)

TABLES DESCRIBING TRANSITION OF WAC/ WASTE CLASSIFICATIONS etc. WITH NOTES ON RATIONALE WILL BE PROVIDED BY MYKOLA

7

10 May 2013

4. ParticipantsParticipants from outside Ukraine are listed below;Chair:

Ms Grogan Helen (USA) groganha@gmail.com Consultants:

Mr Tichauer Michaël (France) michael.tichauer@irsn.frMs Yamada Mika (Japan) yamada-mika@jnes.go.jp ; mkyamada@mail.goo.ne.jpMr Kurogi Hiroshi (Japan) Hiroshi_Kurogi@env.go.jpMr Nichols William (USA) William_E_Nichols@rl.gov ; wnichols@intera.com

IAEA Scientific Secretariat:Ms. Yumiko Kumano (IAEA) y.kumano@iaea.org

8

10 May 2013

5. Tentative Schedule of Activities

Tentative schedule for the consultant meeting is as follows:Sunday, 2, June Arrival to Kiev

Transportation to the airport and Hotels needs to be arranged by each participant Host organization (State agency of Ukraine on the Exclusion

Zone Management) will take care of transportation from the airport to the hotel

Monday , 3, June 9:00 Depart from hotel Visit to Chernobyl, Chernobyl zone, and storages of RW Ukrainian presentation

18:00 return to Kiev Transportation arranged by the host organization

Tuesday, 4, June 9:00 Depart from hotel

Visit to storage for rad-waste created during territories decontamination Ukrainian presentation

18:00 return to Kiev Transportation arranged by the host organization

Wednesday, 5, June - Friday, 7, June 9:00-18:00 Team discussion / drafting at UkrAtomPribor (Gor’koho str., 152)

Friday, 7, June / Saturday, 8, June Departure from Kiev

Host organization will take care of transportation to the airport

6. ReferencesIAEA Safety Guide “Remediation Process for Areas Affected by Past Activities and Accidents” (No. WS-G-3.1), (2007)

NATIONAL REPORT on Compliance with Obligations under the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management (2011)

9

10 May 2013

ATTACHMENT I.:

Draft Document on the Management of Large Amount of Waste arising from Nuclear Disasters

10

10 May 2013

Contents

1 Background......................................................................................................22 Scope...............................................................................................................33 A New Paradigm for Post-Accident Phases........................................................54 Consequence: Need for Post-Emergency Planning...........................................6

4.1 Safety Case to Integrate New Layer of Defence in Depth...........................64.2 Involvement (Governments, Regulators, Public, Media, interested parties – roles and responsibilities)............................................................................................9

5 Strategy for the Post-Emergency Phase.........................................................105.1 Planning: Bounding the T, S, I, P, W, O Parameters..................................145.2 Setting Further Constraints on the T, S, I, P, W, O Parameters..................155.3 Time Frames (Parameter T).......................................................................165.4 Geographic Frames (Parameter S)............................................................165.5 Existing Infrastructure (Parameter I).........................................................165.6 People (Parameter P)................................................................................175.7 Objectives (Parameter O)..........................................................................175.8 Waste Management (Parameter W)..........................................................17

5.8.1 End Point <.........................................................................................185.8.2 Strategy to Reach (including understanding of waste nature and extent, forecast of quantity of radioactive waste resulting from different activities of remediation) <..............................................................................................185.8.3 Decisions that Enforce Strategy < (waste minimalization, interim storage)

185.8.4 Waste characterization, waste stream, waste management facilities, WAC, monitoring.....................................................................................................18

5.9 Synthesis of Information...........................................................................185.10 Preparedness..........................................................................................19

6 Range of Parameters and Associated Bounds.................................................196.1 Process of Defining, and Refining, End States...........................................196.2 Radiation Protection..................................................................................196.3 Issues associated with boundary definitions.............................................19

7 Waste Management – Being Prepared............................................................207.1 National Policy..........................................................................................207.2 Tasks and Tactics of the Regulator............................................................20

8 Waste Collection, Treatment, and Storage in Accident Recovery....................208.1 Activities that Generate Large Amounts of Radioactive Waste.................20

9 Waste Disposal in Accident Recovery.............................................................219.1 Information retention................................................................................259.2 Reversibility and retrievability..................................................................259.3 Relevant examples...................................................................................26

10 Lessons Learned from Past Experiences.......................................................2610.1 Case Studies of Waste Management in Remediation..............................26

10.1.1 Chernobyl..........................................................................................2610.1.2 Fukushima.........................................................................................2610.1.3 United States Production Sites..........................................................2610.1.4 Maralinga..........................................................................................2610.1.5 Uranium Mines..................................................................................2610.1.6 Germany...........................................................................................2610.1.7 United Kingdom Windscale................................................................26

10.2 What to do, and what not to do (with waste)..........................................2610.2.1 During the Emergency Phase............................................................2610.2.2 During the Post-Emegency Phase......................................................26

11

10 May 2013

1 BackgroundA large number of areas in the world have been affected by radioactive contamination caused by a wide variety of incidents, accidents and past activities involving nuclear facilities. Many of these incidents, accidents, and past activities have resulted in the production of large amounts of radioactive waste as the result of remediation of those areas. Such waste requires proper management until final disposal can be completed. A need has been established for additional guidance with regard to the management of large amounts of radioactive waste after an emergency situation. Experiences and lessons learned from past nuclear accidents, especially the two International Nuclear Event Scale Level 7 events that have occurred (namely, the Chernobyl NPP accident in Ukraine in 1986, and the Fukushima Dai-ichi NPP accident in Japan in 2011) demonstrated the need and importance for providing guidance for the planning for the management of large quantities of radioactive waste following emergency situations.

The IAEA is developing a Safety Standard “Remediation Process for Areas with Residual Radioactive Material”, IAEA Safety Standards Series DS468, that will supersede “Remediation Process for Areas Affected by Past Activities and Accidents”, No. WS-G-3.1. DS468 is planned to also address issues involving large amounts of waste with relatively low concentrations of radionuclides that can be generated by remediation activities in greater detail, expanding on the current treatment of this subject in WS-G-3.1. While there has been considerable progress made in the remediation of contaminated areas in many countries, internationally accepted guidance for the management of large amounts of radioactive waste produced by remediation following an accident has not been issued as yet.

This publication focuses on providing ideas, guidance, and lessons learned from past experience for the management of large amounts of radioactive waste generated from:

o Remediation activities performed immediately after incidents and accidents in the affected area that are mixed with waste from the emergency exposure situation / existing exposure situation

o Remediation activities performed after incidents and accidents remediation activity in areas where contamination by past activities may also be required.

Consideration of the lessons learned from previous accidents show the value of accelerating the licensing process and relevant decision making processes in the existing (post-emergency) exposure situation to meet the needs for expedited management for large amounts of radioactive waste management collected across extensive contaminated areas following incidents and accidents.

Consideration of lessons learned from the Chernoybl NPP accident indicate that decision making for waste management should account for the interdependencies with subsequent remedial work, as much as possible, in order to avoid the creation of waste management problems that are extremely difficult to solve in later phases of remediation.

Taking lessons from these past experiences into account, this publication addresses these issues with the following aims:

o Reduce radiation exposure and resultant risk to the public and workers during the remediation activity by introducing a simple and effective licensing framework and methodology to accelerate the licensing process, and

o Reduce radiation exposure and resultant risk to the public and environment in the future by identifying important considerations in decision making processes for radioactive waste

12

10 May 2013

management in mixed emergency exposure situation / existing exposure situation zone after incidents and accidents.

[Insert summary of IEM outcomes here.]

2 Scope(Need to This report addresses OFF-SITE impacts of emergencies; it does not address recovery within the facility itself) – is this indeed the case?

Need to add bit about coordination with emergency arrangements for waste management.

What is in scope:

Focus is on things to do, and things not to do, for waste management beyond the emergency phase.

Address the following types and quantities of radioactive waste:

o Waste generated in the emergency phase,

o Waste generated from remediation of the existing exposure situation (post-emergency phase), which may include:

o Secondary sources (caused by environmental redistribution of wastes through various environmental pathways, e.g., subsurface transport in groundwater, atmospheric transport through dust resuspension, etc.).

Address respective phases for management of wastes (these can overlap, and can have geographic differentiation over time):

o Emergency exposure situation (emergency phase)

o Remediation / existing situation (post-emergency phase)

o Post-remediation – representing a “new normal” end state

Provide considerations for developing minimum standards for waste management including storage and disposal in existing situation.

Recognize that, to be successful, waste management must be conducted in the context of a strategy developed to achieve end-state objectives (radiation protection, social and demographic considerations, timeframe, economic reality, lifestyle and public infrastructure); stakeholder involvement and engagement (communication with interested parties: “what is safe?”).

Waste characterization (properties)

Propose waste management preparedness (pre-accident planning) that would bolster the ability to manage large amounts of radioactive waste following emergencies. This will furnish guidance for the development of appropriate national standards, and will tie to existing safety standard (GS-R-2), including allocation of roles and responsibilities.

Regulatory framework in existing situations (licensing acceleration and allocation of responsibilities)

13

10 May 2013

Recycling / reuse

Address record keeping (and time limit) needs regarding waste management following an accident.

Emphasize that the concept of “clearance” continues throughout the process.

Link to the Graded Approach to safety demonstration (link to Monica’s documents)

Could also consider;

Decay disposal for contaminants with t1/2 < 30 yr

Inside and outside exclusion zone

For the purposes of this document, the phases following an emergency event are deliniated between the emergency event, the emergency response phase, the post-emergency remediation phase, and the achievement of a set of remedial end-points (Figure 1).

Scrub for “accident” to speak instead to “emergency”… post-emergency phase…

ABSOLUTELY ESSENTIAL TO ENSURE TERMINOLOGY CONSISTENT WITH IAEA USAGE HERE.

Note that national govt policy determines when transition occurs from emergency phase to post-emergency phase.

[Insert Time-Phase diagram]

Accident or Incident > Emergency Phase > Post-Emergency Phase > End States Achieved

(> = transitions)

Figure 1. Events and Phases Following an Accident or Incident Event

It is emphasized that there can be, and likely will be, an overlap of waste mangement, post-emergency, and remediation activities in time and space. This overlap is illustrated in the Venn diagram shown in Figure 2.

14

10 May 2013

Post-Emergency

WasteManagement

Remediation

Figure 2. Relationship of Activites in Post-emergency Phase

3 A New Paradigm for Post-Accident PhasesFollowing a nuclear accident, it is already recognized in international standards that necessary actions that must be applied rapidly and efficiently during the emergency response to protect the public from acute consequences. No general consensus exists on the definition of the end of this acute phase, but it is generally accepted that it the acute phase is concluded approximately when the nuclear accident is over and the situation is stabilized (all processes leading to discharges or further accidental situations are under a certain level of control) within the perimeter of the facility. In this report, we identify the actvities that follow this point in time as the post-emergency phase. This time frame starts right after the above mentioned acute phase, and ends when a range of objectives have been met that define an accepted set of end states. Past experience shows that the situations following the emergency phase are diverse and numerous. For example, the situations faced by the population in the territories affected by the Chernobyl NPP accident differ substantially from those faced by the population of the Fukushima Prefecture following the tsumani damage to the Fukushima Daichi NPP. Some of the notable differences in these accidents include: different radiological compositon of the released contamination, different lifestyles of the affected populations, and different spatial distribution of the contamination.

The only conclusion that can be drawn based upon evaluation of these past experiences (by means of compare and contrast) is that there is an inherent lack of predictabilty for post-emergency situations. Even if some stylized accident scenarios could lead to a certain typology of effects, there is a vast number of parameters that cannot be accounted for (e.g., meteorological conditions, actions taken during the acute phase and its duration, availability of the surrounding infrastructures, etc.). A wide consensus does exist, however, as to the high-level objective of the post-emergency phase. This consensus holds that, during this timeframe, actions should to be taken to remediate the effects of the accident (infrastructure building, contamination reduction, population re-allocation, economic recovery, etc.). Management of activities in the post-emergency time frame within the geographic frame affected by the aftermath of a nuclear

15

10 May 2013

accident is targeted as improving people lives, and lessening the impact of the accident on the environment, particularly those resources that are contributors to people’s everyday quality of life (economic resources, cultural resource, transportation resources, habitat resources, power production resources, water resources, lifestyle resources, etc.).

This statement has two consequences:

the management of post-emergency situations is driven by objectives, and

the achievement of these objectives has to take into account the efficacy and the efficiency of the actions undertaken.

Experience gained from major remedial efforts at non-emergency sites, such as legacy nuclear production facilities in the United States of America and legacy nuclear test sites such Maralinga, provide useful insights and implications for application to waste management following emergencies. This experience indicates that waste management programs for widespread radioactive contamination are most successful when conducted within the context of an overall strategy for cleanup. Successful strategies have included these elements: 1) characterization to quantify the amount (volume and radioactivity) and distribution of contamination to be remediated, 2) prioritization of remedition activities to protect critical resources, 3) a well-developed set of end-states with defined time lines for changing the geographic framework and restoring resources to beneficial use. Successful waste management facilities are then explicitly designed and located to support the clearly articulated strategy. Development of waste management outside the context of such a strategy is highly likely to create unanticipated and unnecessary challenges later.

As a result, waste management activities following an emergency must be addressed in the context of a strategy; the development of this strategy is necessary for efficiently managing post-emergency situations. Taking into account the vast number of possible situations that may arise following a nuclear accident, this strategy must be designed as a broad and adaptive approach, rather than as a meticulously defined process, to guide actions to be taken in the post-emergency phase while allowing flexibility for adaptation to the evolution of the situations and the priorities and the interested parties (the population, the regulators, the governments…) and incorporation of new information that arises. The purpose of such a broad and adaptive strategy is to increase both the efficiency and the efficacy of actions in that phase.

4 Consequence: Need for Post-Emergency Planning Add Intro…

4.1 Safety Case to Integrate New Layer of Defence in DepthIn 2011, the Fukushima Dai-ichi NPS were damaged by an extreme tsunami event that was nearly twice as large as was anticipated in the design basis for the accident scenario. The lessons learned from the accident reinforce the need for reconsidering how to address the post-accident phase.

The defence-in-depth concept has been the cornerstone of nuclear safety for the past fifty years. The nuclear safety doctrine concept is expanded further by adding an extra layer of “Emergency Preparedness and Response.” Later, defence-in-depth was codified at the international level (INSAG-10).

In the post-emergency phase, different actions will take place, most of them directed towards the overall goal of reclaiming the land contaminated by the fallout in the aftermath of the accident so as to restore the land to beneficial use.

16

10 May 2013

Therefore, following the recommendations from the IEM (IAEA, 2013), we have incorporated into the nuclear safety basic doctrine of defence-in-depth an extra, outermost layer (See Figure 3) beyond emergency preparedness and emergency response: post-accidental planning and actions to help guide remediation activities following an emergency.

Figure 3. Additional Layer of Defence in Depth

Role of the Safety Case

Arguments of the safety case are required to address safety in activities of the post-emergency phase. Elements to be added to the safety case are:

Integration of relevant information in a traceable and transparent way that demonstrates an understanding of the plan;

Demonstration of the plan by providing reasonable assurance for protects human health and the environment;

Support to decision making in the step by step approach; and

Facilitation of communication between interested parties on issues relating to the system.

The first added element is integration of relevant information in a traceable and transparent way that demonstrates an understanding of the plan. Information will be obtained and knowledge about the plan

17

10 May 2013

and will mature as the project progresses and assessment is carried out in an iterative manner. The plan will contain the information on the following:

Time frame, including: (i) the initiation of remediation activities; and (ii) a limited time period of remediation activities;

Geographic frame, including aspects such as location, buildings, contaminated material, geological and hydrogeological characteristics, type of land-scape (e.g. forest, field and type of soil), climate and atmosphere, the local population, human activities, biota;

Objective, including: (i) the schedule and sequence of the remediation activities; and (ii) the criteria for the end-states of remedial actions

Waste, including: (i) the types of waste (e.g. the origin, nature, quantities and properties of the waste, non-radiological contamination and other hazards, waste stream and the radionuclide inventory); (ii) engineering of waste management, e.g. waste conditioning and packaging, disposal units, engineered barriers, cap or cover of the disposal facility, drainage features); and (iii) the extent and properties of the waste management area disturbed by any excavation;

People, …[ADD DESCRIPTION]

Infrastructure, including: (i) properly trained and experienced staff (human resources); (ii) waste management facilities; and (iii) financial commitments

The second added element is demonstration of the plan by providing reasonable assurance for protects human health and the environment. The demonstration of the plan depends on the arguments in the safety case about the management arrangements for ensuring quality in all aspects of safety related implementation.

The third added element is support to decision making in the step by step approach. The step by step approach adopted for development of the plan provides a basis for decision making relating to the above mentioned information, and will allow the identification of issues that require further attention in order to improve the plan. The step by step apporoach adopted will enable:

Systematic collection and assessment of the necessary scientific and technical data;

Evaluation of possible remediation activities;

Development of waste management plan;

Iterative studies for remediation activities with progressively improving data;

Incorporation of comments from technical and regulatory reviews;

Consultation with the public for specific decision points; and

Political involvement.

The fourth and final added element is facilitation of communication between interested parties on issues relating to the system. Development of the safety case will commence at the inception of the project and will be continued through all steps in post-emergency phase. It will be used to identify research and development needs, to identify and establish end-point, and controls and conditions at the various steps. It will also be the main vehicle of communication with interested parties, in terms of explaining how a reasonable level of end-states will be ensured.

18

10 May 2013

The safety case will need to be presented in a manner that meets the needs of the different interested parties. As far as possible, prior agreement should be achieved through communication with those parties, on what is to be included, assessed and calculated, as appropriate for each step of development for the plan and for the relative level of hazard associated with remediation activities.

The Safety Case Argument in Remediation

The safety case will be developed as the plan progresses and will be used as a basis for decision making. The context for each revision of the safety case will be set out clearly and will be updated as necessary and appropriate for subsequent revisions of the safety case.

For each revision of the safety case, the implementer should provide a clear description of its purpose, which, depending on the stage of development of the plan, could include:

The initial ideas for the plan to identify each contaminated area

Demonstration of the plan

Identification of safety related issues to be addressed by research and development programs

Definition or revision of end point and conditions

Input to monitoring and data

Periodic re-assessment, as required by law or regulation

Application to extend or upgrade the remediation activities and/or waste management facilities

Determination of whether remedial action is necessary (definition or revision of end-state)

4.2 Involvement (Governments, Regulators, Public, Media, interested parties – roles and responsibilities)

The safety case, which is a significant input for the above-mentioned strategy for the post-emergency phase, is the responsibility of the implementer. It is emphasized that (i) the design of the safety case requires the involvement of all interested parties, (ii) other major inputs to the strategy that go beyond demonstration that the facility is safe must be provided by off-site actors (e.g., government, regional decision makers, affected public, …).

Early involvement of all interested parties is essential to the process of building confidence in the plan. A key consideration is that interested party involvement should take place within an open and transparent framework for consultation, with clearly defined rules of procedure (e.g. dialog). The process for involvement of interested parties should be set out in the safety case.

Communication implies that the safety case will be documented in a clear, open and unbiased way that, for example, recognizes the plan that provide safety benefits and risks including costs. The aim should be to provide clear information mentioned above, in order to inform decision makers. To increase transparency, it may also be appropriate to make the safety case documentation available to the public and to ensure that it is prepared in a manner and at a level of detail that is suitable for the intended audience.

The regulatory review of the plan may be conducted by the regulatory body with or without support from external organizations, but the results of the review of the plan are the responsibility of the regulatory body.

19

10 May 2013

5 Strategy for the Post-Emergency PhaseReview of the diversity of experiences with past accidents that resulted in offsite nuclear contamination strongly emphasizes that the one central certainty is that future accidents will differ substantiallly from past ones in many important respects. Nevertheless, consideration of experience with past accidents suggests that a broad strategic approach could provide a useful framework for increasing both the efficency and the efficacy of actions taken for the management of large quantities of radioactive waste in the post-emergency phase.

Progress through the post-emergency phase can be characterized by the state of a vast number of dynamic and interrelated parameters (time, space, objectives, waste, infrastructure, and people). The magnitude and consequences of such accidents vary greatly as demonstrated by comparison and contrast of past accidents. It is therefore impractical to attempt to manage the range and bounds of the consequences of events that, by definition, represent extraordinary, unexpected events (or combination of events) that result in breaching of the outermost layers of the defence-in-depth strategy. For this reason, advance planning to for management of such events by means of what might be thought of as a tactical approach, through a comprehensive classification and categorization scheme (for example, the features-events-processes methodology) is impractical. Instead, a broad, adaptive strategy is needed that sets goals concerning the protection as well as the recovery of human health and the environment. The objective of this adaptive, strategic approach is to minimize further degradation, as well as to efficiently expedite the recovery of, valued resources in a prioritized manner. It is acknowledged, and anticipated, that accidents involving nuclear facilities may well not be completely recoverable as some resources will be devoted to long-term waste disposal. Waste disposal represents one aspect of the end state, with the objective to minimize geographic frame and time frame devoted to that end.

This strategy should be viewed as managing a continuously-changing and iterative process where actions are planned, objectives are pursued, actions are undetaken, and assessment of the results of those actions are made. As this strategy is implemented, continuous progress is made towards the general objective of improving people’s lives.

Moreover, this strategy has to be applied to various and diverse situations. Considering the vast number of possible situations and their evolving nature over time and space, post-emergency situations can be roughly defined by these six categorical parameter sets:

TIME (T)

SPACE (S)

INFRASTRUCTURE (I)

PEOPLE (P)

WASTE (W)

and of course, OBJECTIVE (O)

The definition the post-emergency phase is the sum of these particular situations that we symbolize with their main parameters: [T,S,I,P,W,O]. Let’s take a generic illustration.

Before the accident, the geography would look like:

20

10 May 2013

During the emergency phase, perimeters are set up to protect the population (evacuation areas, with different policies applied):

The black shapes could represent spatial perimeters where population has been evacuated, the green ones where contamination is present in the environment but population still present, the red one symbolizes the degradation of existing infrastructures. At that point, the situation is controlled by T, S, I and P parameters

When post-emergency actions start, including remediation of land and recovery, the combination of space and time parameters could evolve as following:

21

urban areas

nuclear facility

rural areas

natural environments (forests, rivers…)

infrastructures(roads, bridges…)

infrastructures(schools, administrations…)

10 May 2013

Objectives are set in such a way that some areas are selected for performing actions of contamination reduction (urban or rural or natural, for instance the green dashed areas) or that the evacuation perimeters evolve and allow the reallocation of population (black ellipse). It is crucial to consider that these objectives are time, space, infrastructure, people dependent, therefore there is no single methodology to select the right decision: every situation will be different and require a system that holistically takes into account the most up-to-date information coming from the field, even if it is incomplete. For every situation, an objective (O) can be set, therefore the situation can be represented as a combination of T, S, I, P, O main parameters.

When remediation actions start, radioactive waste is being produced (orange W). As soon as these wastes appear on the map, the remediation situation evolves and incorporates a new dimension: waste management. In fact, the peculiarity of some emergency situations can be the emergence of large quantities of radioactive waste, which require a specific attention and in turn have a tremendous impact on the description and evolution of the post-emergency situations. The post-emergency situation is then controlled by T, S, I, P, O and W parameters.

Over time, situations evolve and (T, S, I, P, W, O) parameters are bound to change. For instance, the infrastructures are recovering, thanks to civil works performed on the field. Moreover, the W parameter

22

10 May 2013

could lead to a policy where contamination in one of the green dashed areas would be removed to a certain extent, and the induced waste transferred to a waste management facility (blue W): depending on the adopted policy and the induced waste streams (see paragraph XXXXX), it could be a waste treatment, conditioning, storage, disposal.. facility.

From this schematic representation of post-emergency situations, some preliminary conclusions can be drawn:

As situations constantly evolve, driven by a set of numerous constraints that are embedded into the (T, S, I, P, W, O) parameters, their ever-changing nature imposes to define fluid strategies that allow room for change and constant adaptation; and

These strategies involve a chain of decisions based on the information that qualify the set (T, S, I, P, W, O). In fact, it is recalled that these strategies are meant to make the actions performed on the field efficient, towards a general goal, therefore they need to constantly reassess their input data in order to adapt the objectives and the subsequent actions they wish to implement on the field; and also

A key concept is that remediation during the post-emergency phase is targeted against achievement of end states that represent a “new normality”: a state of things that will differ from those prior to the accident, yet acceptable in terms of safety and quality of life. These end states encompass a great number of variables that are time, space, people and infrastructure dependent. Moreover, they should be desirable for the people and achievable within the given constraints (timeframe, cost, available techniques and personnel, etc.);

The post-emergency phase can be envisioned as a series on concurrently running actions on the field (T, S, I, P, W, O), and their results recorded as the sum of the accumulating end-states. These end states represent then an evolution of geographic frames across the time frames from the initial post-accident state through interim states to final end state.

5.1 Planning: Bounding the T, S, I, P, W, O ParametersAs stated above, T, S, I, P, W, O parameters are evolving constantly during the post-emergency phase: objectives are revised, timeframes are reevaluated to take into account new priorities or new information, etc. The whole point of trying to opt for a fluid and adaptive strategy for post-emergency planning and action is about streamlining and efficiently showing the progress being made for the population and the environment. Thus, planning before the accident is particularly difficult since it has to adapt to the actual situation. The planning process with regard to the safety of nuclear facilities is discussed in the following chapter. Yet, the situation itself evolves as information becomes more and more precise. For instance, it is recalled that in the first days after the Fukushima accident, a coarse mapping of the radioactivity in the Fukushima prefecture was made public, as the basis for the first zoning decisions made by the Japanese authorities (evacuation, restrictions of food stuff use, etc.); of course, this mapping could not be precise and the zoning was refined during the following weeks, as measurements and on-site contamination mapping were brought to light in order to zero in on a spatial distribution of zones and policies associated to these zones:

<insert map of Fukushima prefecture with colored zones>

23

10 May 2013

This early action of mapping can be seen as a typical post-emergency activity limited in time (‘as quickly as possible’), space (at the broad scale of the region), infrastructure (administrative boundaries, transportation network…), people (the inhabitants of the upcoming zones), and objective: form the basis for a preliminary assessment of the contamination of the environment at the regional scale in order to take primary decisions for the protection of the population and the planning of the upcoming activities.

This example shows that post-emergency activities are planned and performed in order to:

identify boundaries for the T, S, I, P, W, O parameters,

reduce uncertainty associated to these boundaries, and to

make decisions on the management of parameters.

Eventually, the degrees of liberty of each sextuplet T, S, I, P, W, O, for each dimension of the post-emergency activities, will be cut down and the situations will be more and more stabilized.

5.2 Setting Further Constraints on the T, S, I, P, W, O ParametersIt has been emphasized that the activities of planning prior to the accident and immediately after the accident are paramount to the streamlining and efficiency of the post-emergency activities. This planning goes through the definition of a highly adaptive strategy. However, the number of variables for each parameter can be so overwhelming at the planning phase that a first step can be performed, in order to constrain these parameters with a sufficient knowledge of some available date. This step is – again – all about optimizing the efficiency of the post-emergency activities. In particular,

T: even if it is almost impossible to predict if, how and to what extent the next nuclear accident will occur, its evolution is highly predictable: for instance, a NPP accident always implies a breach in the barriers, with a certain kinetics, based on a intimate knowledge of the failure modes of the facility. Therefore, a detailed knowledge of accident scenarios could be used to highlight stylized discharges scenarios and their impact, with a consideration to meteorological conditions. These typical emergency preparedness set of measures could be extended to the early post-emergency phase in order to get a rough idea of the outcomes of the emergency phase;

S: geographic data is paramount to identify as much as possible the various environments where contamination could occur;

P: demographic, sociologic and lifestyle data have to be gathered and interpreted to inform as much as possible the strategy that will be adopted and ensure its ability to address the real situations faced by the population;

I: the knowledge of existing infrastructure for future actions (transportation networks, machinery, public service, etc.) might help gaining time and efforts in the early phases of the post-emergency phase;

W: since all nuclear facilities are different and operated differently, every discharge from a nuclear accident would be different as well. However, for each facility, it is possible to unveil, from accident scenarios, the source term(s) that could eventually be discharged during the emergency phase. A rough knowledge of the induced contamination before the accident will undoubtedly help the decision makers during the early post-emergency phase;

Later on, this document discusses the policies (O) that emerge from the adoption of a strategy for post-emergency planning and performance.

24

10 May 2013

One of the main consequences emerging from this discussion on a strategy for outlining post-emergency activities is that planning prior to the accident could multiply the chances that the adopted strategy will be adapted and efficient throughout the post-emergency phase. Good planning is particularly crucial in its early days or weeks, where activities and progress have to surface as much as possible.

5.3 Time Frames (Parameter T)Time criteria should be defined in the same way as well as for emergency planning. The reference with emergency RW is a part of activity on liquidation of failure and its consequences. The analysis of a situation with emergency RW the forecast of quantity and planning of the reference with ERW should begin with the first hours of works on failure liquidation. Before failure the emergency plan with the account (Section X) RWM with such waste should be developed beforehand. First of all, it concerns initial stages and transition to a restoration stage. Final time criteria (termination) should be defined by the termination of emergency works on installation, the activity termination on ремедиации. Proceeding from the strategy of the reference accepted in the country with RW the conditional termination of works with ERW can be when all ERW are placed in storage or diposal facilities. It is preferable that this activity would come to the end with a safe, final diposal.

Besides, there can be the intermediate important time parametres, for example approaching high water on the river located in it earlier, the lost wood which burns pollutes air, necessity of maintenance of safe works of other crash teams.

5.4 Geographic Frames (Parameter S)[defining criteria]

Geographic frames will be defined based on the nature and extent of off-site contamination resulting from the emegency event evaluated against applicable radiation safety standards, radioactive waste classification standards, remediation strategy, distribution of essential pollution in rather pure territories, infrastructure and equipment used to transport emergency radioactive waste, siting of collection, storage, and disposal facilities, and social factors as well.

Geographic frames will change throughout the post-emergency phase and will need to be periodically reconsidered based on monitoring and remediation progress. This evolution of geographical frames is necessary to provide the basis for planning of radioactive waste management activities, especially with regard to the selection and location of installations for processing, storage, and disposal of emergency radioactive waste.

Should beat processes of migration of radioactive materials and formation secondary RW are considered

5.5 Existing Infrastructure (Parameter I)Economic resources (food production, industrial production, mineral resource production, etc.), cultural resource (e.g., religious sites), transportation resources, habitat resources, power production resources, water resources, lifestyle resources (e.g., recreational access)

Can / it is necessary consider and an infrastructure which is in other departments (army, armies of other countries, rescuers, fire) and the population which can be involved in works on remediation.

25

10 May 2013

Infrastructure for manufacturing of the necessary equipment for the reference with ERW (factories, technological and, design and research structures).

Local resources (clay, building materials, … a local industrial infrastructure).

The infrastructure which incorporates elements of the reference from the RW, and possibility of attraction for auxiliary actions (transport, physical protection, training …) should be considered and analysed.

Natural infrastructure which can temporarily or constantly used for the reference from the RW.

Infrastructure within the limits of the International cooperation?

The reference from the RW is desirable for constructing so that to minimise influence on a local infrastructure and not to admit negative influence on the population or to minimise it (radiating, psychological, economic).

At all actions under the reference from the RW and to use an infrastructure and interaction with local population the national legislation on radiating protection, insurance should be considered, etc.

5.6 People (Parameter P)[Discuss societal and lifestyle values: examples include resources with religious and/or cultural importance, resources with recreational value, etc.]

5.7 Waste Management (Parameter W)(make clear that we are suggesting a system for management of waste)

26

10 May 2013

Figure 4. Iterative, Adaptive Process for Post-emergency Phase Activities

5.7.1 End Point <

5.7.2 Strategy to Reach (including understanding of waste nature and extent, forecast of quantity of radioactive waste resulting from different activities of remediation) <

5.7.3 Decisions that Enforce Strategy < (waste minimalization, interim storage)

5.7.4 Waste characterization, waste stream, waste management facilities, WAC, monitoring

5.8 Objectives (Parameter O)Objectives, or end states, are used to define objectives with respect to time frames and geographic frames.

Priorization; identify critical resources to protect (e.g., rivers, water supply, …) so that remediation can be prioritized.

27

Parameters

Strategy

Decisions

Parameters of the Action

DO: conduct the action

Evaluation (loop)Plan

T S O W I P

End Point

10 May 2013

Interim versus final end states – relation to time frames

Cultural values, lifestyle values, economic recovery,

Public (stakeholder) involvement in identifying, selection of end states

Define end states with respect to time frames, geographic frames, existing infrastructure and people…

5.9 Synthesis of Information[leading to a need for setting policies; time, space, objectives, waste, infrastructure]

It is necessary to overestimate really the national policy in sphere ERW

It is necessary to specify the roles and responsibiilties of state structures of management, regulation, operators of installations under the reference from the RW, local authorities and other participants.

The information on the parameters [time, space, objectives, waste, people, infrastructure] must be synthesized to specify end points. Information synthesis should become the basis for creation and specification of plans under the reference from the RW and the international cooperation (especially where transboundary contamination occurs) and communication with affected populations, including in neighbouring nations.

Creations and specification of programs for remediation, national programs/plans under the reference from the RW can include short-term, priority and long-term plans depending on a situation in a zone of pollution and socio-economic factors in the country. These actions of different programs should be considered in interaction.

Information synthesis can give the chance an independent situation assessment experts in the country and behind its side-altars, including the competent international organisations.

Documenting and timely exchange of the synthesised information with necessary participants

Information protection.

Physical protection RW (in particular, objects of type storages "Podlesnyj" in the Chernobyl zone) where can be fragments nuclear materials

To a paradigm? Or the separate paragraph: it is desirable to organise works on a siti so that fragments of the destroyed fuel did not get to storehouses RW in an EZ

5.10Preparedness[anticipate; what we can prepare for, with recognition of limited ability to forecast]

Actions and prioritization…

6 Range of Parameters and Associated Bounds

6.1 Process of Defining, and Refining, End States(high-level objectives with respect to time, space, objectives, waste, infrastructure, and people) for each phase [concept that preliminary definition will undoubtedly change over time]

28

10 May 2013

6.2 Radiation Protection

6.3 Issues associated with boundary definitions (common to all; environmental transport [hot spots needing urgent response])

[combinations and interactions of parameters (time, space, objectives, waste, infrastructure, and people) – these are fluid and iterations are necessary]

7 Waste Management – Being PreparedIntro…

7.1 National Policyo Incorporate material from IEM here…

o Gerad’s suggestion of the establishment of contingency WM facilities at/near the location of NPPs in preparation for waste characterization, treatment, and storage.

o Preparation to identify temporary storage facilities.

7.2 Tasks and Tactics of the RegulatorConsider:

o The main priority for the regulator in post-accident recovery is to facilitate safe and timely realization of post-emergency and remediation actions (“not to act as the policeman”)

o Balance regulation of risk against need for urgent action (“perfection is the enemy of good enough”)

o The minimal requirements for accelerated licensing of waste management facilities and activities.

o Pre- and post-accident training by the regulator of emergency workers for appropriate waste management practices in the post-accident phase.

o Licensing process for storage activities.

o Experience of regulatory actions and lessons learned from past remediations (what worked, what didn’t)

o

8 Waste Collection, Treatment, and Storage in Accident Recovery

Text.. (complementary to Chapter that follows)

29

10 May 2013

8.1 Activities that Generate Large Amounts of Radioactive WasteThe following list is merely meant to capture the range of waste streams that may need to be addressed. Question to Agency: does the scope of this document include onsite and offsite waste, or only offsite (of concern to public stakeholders).

o Activity with building designs NPP.o Activity on a stop of reactors (e.g., dumping of sand), or cooling (e.g., by use of sea

water).o Activity on maintenance of safe workplaces for the emergency personnel.o Decontamination of nuclear blocks and a site. (D&D?)o D@D infrastructure operation NPP (e.g. pond-cooler ChNPP - S=22 km.).o The work on a platform (for example building of "Shelter", or a construction of new

buildings) - considerable quantity RW - the polluted soils, building materials (nx 1000 cub. m) which go on storehouses and installations in an exclusion zone

o The polluted technics (vehicles, aircraft, etc.) and tools from a site.o Decontamination of settlements and civil infrastructure.o The reference with agricultures and a foodstuff, and animals.o The reference with water objects and activity on their protection.o Decontamination of the rural areas (agricultural, forested, etc.).o Secondary (from burning, products treatment deactivations of district and transport,

processing or destruction of the polluted agricultural products, readjournment of radioactive materials, accumulation at use of the polluted forages in animal industries …).

o The polluted building materials of houses from which inhabitants are settled out or were formed of the technogenic or natural accidents accompanying failure on the atomic power station and have thus received radioactive pollution.

9 Waste Disposal in Accident RecoveryRadioactive waste is material with an activity content or concentration above a predefined level, for which no further use is foreseen. Disposal is the recognised end point for the management of radioactive waste under a hierarchy of waste controls; however, storage of some wastes for periods of tens of years is often necessary.

During planned situations, the hierarchy of waste controls for ensuring safety of people and the environment is well detailed in the IAEA Safety Standards, starting with the Fundamental Safety Principles [SF-1, IAEA 2006], through the Safety Requirements that deal with the mandatory criteria for safe management, storage and disposal of radioactive waste [SSR-5 Disposal of Radioactive Waste, Specific Safety Requirements, IAEA 2011], to the corresponding guidance on meeting the requirements, found in the Safety Guides [e.g. DS356 Near Surface Disposal of Radioactive Waste, IAEA draft SG]. In the IAEA system of radioactive waste safety, waste is classified according to the appropriate disposal path for its safe disposal [GSG-1, IAEA 2010]. Safety of all disposal is demonstrated by means of a detailed safety case [SSG-23 The Safety Case and Safety Assessment for the Disposal of Radioactive Waste, IAEA 2012].

30

10 May 2013

In the process of remediation following a nuclear or radiation accident, waste is inevitably produced during both the emergency phase and in the post-emergency existing phase. This waste takes many forms, including contaminated building materials and soil, and often involves dealing in huge volumes not usually encountered in normal life. A natural inclination during these recovery phases, both with emergency and clean-up workers and the affected public, is to deal with this waste quickly by use of expeditious burial. The principle of “out of sight, out of mind” is a strong driver at such times.

With this in mind, two important priorities are apparent in dealing with radioactive waste in an accident recovery situation. Speedy disposal is important for the well-being of the people affected. However, this must be accomplished in ways that do not appreciably compromise the safety outcomes compared with those expected from waste disposal in planned situations. Indiscriminate burial of undifferentiated waste, attractive as it may seem when faced with the consequences of a significant accident, is not an option. On the other hand, following the conventional practices and timelines for developing disposal facilities under planned circumstances, and for demonstrating their safety, takes substantial time (many years) that is not practicable or ideal in accident recovery.

Whether radioactive waste arises from a planned activity or from remediation of an existing situation, there are two inalienable principles applicable in all cases. The end point is disposal of the radioactive waste (not indefinite storage), and safety of people and the environment cannot be compromised. The rest of this Section deals with the differences with disposal of radioactive waste in an existing situation from the vastly more structured situation of a planned activity. Suggestions, based on current and past experience, are given here that may help in finding practical, quick and acceptably safe solutions to the disposal dilemma following a significant accident.

As part of the remediation planning that is current international best practice [IEM report, IAEA 2013] and should be undertaken by all countries that are at risk of a significant nuclear or radiation accident, the following can be considered in order to facilitate waste disposal and in developing a policy for disposal when faced with remediation of existing situations:

the division of responsibilities amongst those with a role in waste management and disposal in accident recovery [government(s), project manager, operator(s), regulator(s), affected public and interest groups, etc.];

the development of an appropriate national waste classification scheme;

have in place national policies of exemption and clearance, and means to implement them;

determine a policy on the use of industrial waste disposal sites for handling appropriate remediation waste arisings, including the identification of where such facilities are located;

consideration of the characteristics of sites that would be appropriate in quickly establishing a required near-surface disposal facility;

development of the generic components and methodology that could be put in place and would help in accelerating the licensing phase for disposal facilities (it may be useful for the IAEA to develop guidance);

potential methods and technology available for implementing waste disposal solutions;

determination of and undertaken consultation on possible criteria (radiological, societal, demographic, etc.) to define the end-points for radioactive waste disposal following an accident;

31

10 May 2013

and

consultation with all stakeholders on all of the above planning.

When the waste is totally or very substantially comprised of short-lived radioactivity (t½ ≤ ca. 30 y), disposal in near-surface disposal facilities (in accordance with the guidance in DS356, IAEA 2004) is a viable option, allowing the waste to substantially decay away over a period of several hundreds of years, during which institutional controls over the facility are generally feasible and economically practicable.

Often in an existing situation, the waste arising from remediation will contain significant amounts of long-lived radionuclides (e.g. uranium, plutonium, fragments of nuclear fuel or of spent fuel, technetium-99) and thus will not meet the IAEA requirements for near-surface disposal. Such long-lived waste, when it arises under planned activities, is only suitable for geological disposal based on the safety case and what are considered appropriate and realistic periods and forms of natural and engineered barriers and of institutional controls.

It is a given that in any nuclear or radiation accident in the foreseeable future, geological disposal structures will not be available or able to be quickly established to deal with disposal of the possible large amounts of waste needing to be dealt with in the recovery.

The options are thus fairly straightforward:

do nothing (i.e. acknowledging that suitable geological disposal structures are not available, to leave the waste arising from the accident in situ);

collect the waste and store it indefinitely;

dispose of the waste that arises from recovery of the contaminated lands, in near-surface structures with good understanding of the safety-case deficiencies and invoking all the plans and creative ideas for addressing the recognized deficiencies into the future.

The first option, do nothing, may be appropriate in certain, fairly limited, circumstances, such as where the accident or existing waste is in an uninhabited area where there are no societal or lifestyle imperatives for quick actions. Time can be taken with appropriate institutional controls in place to consider all options, and to develop considered plans. Other possibilities are to deal with the waste in situ, such as by mixing with fresh (uncontaminated) soil and/or revegetation programs.

To store the waste indefinitely, if indeed (based on the nature and likely vast amounts) possible, places all the burdens on future generations, with all the concomitant problems that make indefinite storage an unacceptable option in planned situations. In particular, the safety case demonstrates the safety deficiencies and economic burdens of long-term storage. As well as the risks involved in inevitable multiple-handling of long-term stored waste, there are risks that future generations may be left with a decaying waste store for which they have inadequate knowledge.

Near-surface disposal of waste that contains long-lived radionuclides, arising from an accident recovery, is far from ideal but is often the alternative we are left with. We are inevitably in a far from ideal situation following a major nuclear or radiation accident, and neither the resulting environmental contamination, generally extensive, nor the practical options for disposal are to our liking. We must act and choose the appropriate “lesser of the evils” based on good pre-accident planning and extensive public consultation and building of trust in the decision-makers.

32

10 May 2013

Things to consider in developing the safety case for near-surface disposal of waste arising from an accident include:

longer period of institutional control (need to be maintained as long as possible, and endeavours made to pass this need on to future generations);

the viability of an exclusion zone, both in the present and extending on into the (distant) future;

information retention of the site and its contents are critically important (some thinking on means of doing so is provided below);

the importance of credible intrusion scenarios, both now and in the future, and current means for mitigating the probability and consequences (barriers, controls);

the difficulties in predicting the impacts of climate change, geology changes and geo-hazards over the geological timeframes under consideration;

inclusion in the design of the disposal facility, strong elements of reversibility and retrievability principles;

building in flexibility (e.g. assumptions and understandings may change regarding the impact of radioactivity on the biosphere, hence regulation and even post-closed facility design may require modification in the distant future; technological advances may make recovery of security/proliferation-sensitive materials feasible, or provide the means to incorporate impenetrable barriers, etc.); and

acceptance that some problems associated with the disposal facility remain to be addressed into the future, but that the existence of the facility has enabled a significant recovery in terms of health and lifestyle of people and the environment affected by the accident.

The safety case for near-surface disposal of short-lived waste is staged to reflect the lifecycle phases of the facility.  It is accepted that for long-lived waste, institutional controls cannot be guaranteed over the period in which the waste is hazardous to people and the environment.  However, institutional controls can probably be guaranteed over shorter timeframes, such as between potential licence renewals in the post-closure phase.

 As such, there is scope to consider some appropriately different schemes for a post-closure safety case for long-lived waste, such as:

a requirement for a new, bottom-up safety case to be developed at regular periods of xx years (as a minimum), with associated regulatory licences to be obtained (this is similar to requirements in the petroleum industry); 

a list of criteria that may trigger a new, bottom-up safety case to be developed outside of this cycle;

a specified period of internal review for safety case adequacy - these assessments may simply drive new information to be included as updates to the existing case, or may trigger a new, bottom-up safety case to be developed;

as a living document, the safety case would incorporate new information when available, even if outside these licensing/review cycles;

33

10 May 2013

when complete, the newer, bottom-up safety case would be compared to the previous safety case to ensure that no information is lost.  A new, bottom-up safety case also allows the cumulative impact(s) of new information to be assessed on a regular basis.  Also, deficiencies in previous safety cases are more likely to be captured by a new, bottom-up safety case than in one that is merely updated regularly;

the safety case can specify a period of update/review for electronic information, essentially making document preservation activities a licence condition and thus unlikely to be lost from corporate memory.

9.1 Information retentionStringent preservation of electronic information in accessible formats is required, i.e. protection of information against redundant media (e.g. floppy disks) and file formats (e.g. superseded word processing formats), as well as protection against file corruption (e.g. magnetic desensitisation or computer virus).  This is particularly important for databases in which are stored surveillance data, relevant radionuclide transport models, maintenance records and technical drawings, all of which may need to be referred to in the future and may not be readily stored in hard-copy form.  It is quite possible that advancements in technology will occur more frequently than the need to access such records.   This could result in effective loss of access to the electronic data.  Additionally, programs to preserve and update electronic data in accessible formats are likely to be lost from corporate memories.

Much more… (considerations for future-proofing the information)

9.2 Reversibility and retrievabilityThe principles of reversibility and retrievability acknowledge that development of any disposal facility for long-lived radioactive waste should be open to progress in science and technology, to evolving societal demands and to fixing potential implementation errors. In this regard, selecting technologies that are as reversible as possible is a prudent approach.

Important guidance is provided in the Final Summary Report of the Fourth Review Meeting of the Contracting Parties to the Joint Convention (IAEA JC/RM4/04/Rev.2, 2012) on reversibility and retrievability of radioactive waste from a repository. It was highlighted that justification of retrieval should take into account safety considerations and not only be based on public acceptance.

Reversibility is defined for the purposes of this document as the ability in principle to reverse or reconsider decisions taken during the progressive implementation of a waste store or disposal facility.

Retrievability is defined as the ability (in the case of a waste store) or the ability in principle (for a waste disposal facility) to recover waste or entire waste packages once they have been emplaced in the store or disposal facility. For a waste disposal facility, retrievability denotes making provisions in order, should it be required, to allow retrieval, which is the concrete action of removal of the waste.

Note that retrieval is integral to the whole concept of storage of waste.

9.3 Relevant examplesPractical examples, where waste arisings from existing situations have been disposed in near-surface facilities, are found in the US remediations of former military sites including Hanford, in the clean-up of

34

10 May 2013

plutonium contamination from the former UK atomic test site at Maralinga, and in remediations of legacy uranium mines.

10 Lessons Learned from Past Experiences

10.1Case Studies of Waste Management in Remediation

10.1.1 Chernobyl

10.1.2 Fukushima

10.1.3 United States Production Sites

10.1.4 Maralinga

10.1.5 Uranium Mines

10.1.6 Germany

10.1.7 United Kingdom Windscale

10.2What to do, and what not to do (with waste)

10.2.1 During the Emergency Phase

10.2.2 During the Post-Emegency Phase

35

10 May 2013

ATTACHMENT II.:

Do’s and Don’ts of Managing Large Quantities of Radioactive Waste Following an Emergency (needs to be updated and combined as Section 10.2 of the document)

36

10 May 2013

11 Do’s and Don’ts of Managing Large Quantities of Radioactive Waste Following an Emergency

Most Applicable Lessons from the Level 7 Accidents

Lessons MUST be with expressed with regard to waste management activities. Yumiko says, “we must summarize common aspects of the lessons learned as well as detailing those that are specific to individual cases.” Also, need to specify which time frame(s) the lessons learned apply to.

Chernobyl NPP (1986) - Prior to the Chernobyl accident there was little experience in managing huge amounts of emergency radioactive materials. Operations in disposal of radioactive waste from the Chernobyl NPP accident were conducted under extreme conditions without adequate waste isolation technology, classification and registering of waste (its amount and activity). The possible environmental impact of storage sites was not considered. Even today, the majority of storage facilities require in-depth investigation. However, there is still no state-wide strategy for management of radioactive waste and spent fuel. The laws that have been adopted have no effective enforcement mechanisms.

DON’T: mix liquid waste resulting from the accident in operations tanks. DON’T: Mix liquid emergency RW together with operational liquid (e.g., incorporation

of plutonium in operational liquid storage tanks). DO: The principle at an NPP is to maintain separation of different waste streams, even in

accident remediation. DON’T: Avoid “not organized storage of not organized waste”; indiscriminate collection

and burial of undifferentiated waste. DO: Disposal of waste is the objective (collection, burial in unlicensed facilities is

temporary and does not constitute “disposal”). DON’T: create temporary storage trenches without engineered barriers (these barriers

should function for at least 30 to 50 years, economic imperatives can not be allowed to override waste safety requirements)

DO: Consider long-term (more than 10 to 20 years) ecological consequences DO: where possible, site storage and treatment facilities reasonably close to ERW +RW

(other considerations apply to site selection, especially protection of critical resources) DON’T: Locate waste management installations for processing/deactivation near the edge

of exclusion zones which subsequently may decrease in size as remediation progresses DO: develop emergency plans, with the state and the operator, to provide guidance for

management of large volumes of ERW and for emergency readiness regarding ERW. DO: Ensure availability of trained personnel and scientific and technical support DON’T: Exceed the rated capacities or design life of containers used to isolate waste. DON’T: Infringe on acceptance criteria, even if this is deemed a necessary action by

operators or emergency response personnel (e.g., the #1 & #2 trenches at "Burjakovke" which contain high-level waste)

DON’T: Misuse technology even if decisions are made for sake of expediency (e.g., loading of the large-sized RW in “Burjakovke”)

DO: Fast isolation of large volumes of collected waste in stores and temporary collection points.

37

10 May 2013

DO: Implement a comprehensive monitoring program (that exceeds normal monitoring requirements).

DO: Perform a regulatory re-evaluation of all elements of safety. DO: Involve international cooperation in waste management activities.

Fukushima Dai-ichi NPP (2011) DON’T: Ongoing storage at multiple local collection points may not be ideal; rapid

consolidation in centralized location(s) is recommended. DON’T: Removal of surface soil is not always necessary or the best option. DO: Quick action to characterize and determine limits of contamination DO: Minimize the amounts of waste with appropriate requirements. DO: Use existing landfill(s) wherever possible, for suitable waste, for disposal of

characterized waste. DO: use existing processing facilities (e.g., incinerators) to process suitable waste. DO: Quick action to perform local remediation to allow house owners to resume lifestyle DON’T: don’t wait until an accident has occurred to plan and determine roles and

responsibilities of appropriate agencies. DO: maintain detailed inventory records of collected waste. DO: communicate, rapidly and transparently, to the affected population the issues

associated with waste remediation. DO: Involve international cooperation in waste management activities.

Lessons from Other Remediation Efforts

Maralinga (Former U.K. Nuclear Test Site in Australia) DON’T: Use “Final” lightly – it is a loaded term DO: Consider interaction of the Parameters we identified [T,S,I,P,W,O] was central to

successful cleanup DO: Invite feedback and obtain agreement on criteria with stakeholders NOTE: Every waste management situation differs NOTE: Differences in RNs comprising the waste impact waste management decisions DON’T: Not organized disposal of not organized waste DO: use best technical and scientific talent on the ground – both regulator and operator DO: keep regulator engaged in development of technical information at every step of the

remediation and waste management activities and decision making. DO: manage everything in bits that show progress.

Hanford Site (U.S. Legacy Nuclear Production Facility) DO: Develop a comprehensive waste management strategy that focuses on achieving

defined end-points and protecting critical resources in a prioritized manner. DO: Develop a binding agreement between regulators and responsible parties to define

roles and responsibilities for remediation and waste management to cope with overlapping regulatory authority.

DO: keep regulator engaged in development of technical information at every step of the remediation and waste management activities and decision making.

38