Application of Radioactivity and the Law
to Contaminated Land and Demolition
Projects
Gareth Walker, BSc, PhD, MRSC
Contents
June 27, 2016

Introduction to legislation

Introduction to contamination land
assessment, and demolition &
decommissioning projects

Three case studies
2
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)
June 27, 2016
3
Why Undertake an Assessment?

June 27, 2016
Obligation & Liability management

Obligated to comply with legislation

If they fail to comply, are they liable?

What is the extent of the liability?
4
Types of assessments
June 27, 2016

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
5
Case Studies

Contaminated land assessment

Sellafield characterisation



Radiological risk assessment at Hunterston A
Demolition and decommissioning assessment

June 27, 2016
Working in partnership with Serco Assurance
Waste management during decommissioning
and demolition at Bradwell
6
Considerations Prior to Contaminated Land
Assessment

Aim of the assessment
Contaminant
Source
Pathway
Receptor
June 27, 2016

Leads to a potentially significant pollutant linkage

Does the pollutant linkage represent an
unacceptable risk?
7
Sellafield
June 27, 2016
8
Drilling at Sellafield – Overview
June 27, 2016

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
9
Characterisation at Sellafield
June 27, 2016

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
10
Drilling at Sellafield
June 27, 2016
11
Summary - Sellafield
June 27, 2016

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
12
Radiological Risk Assessment - Overview
June 27, 2016

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
13
Radiological Risk Assessment - Overview
June 27, 2016

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?
14
Radiological Risk Assessment – Part IIA

Contaminated Land Report (CLR) -11 framework
followed to assess risk

Tiered approach





Generic qualitative risk assessment (GQRA)


June 27, 2016
Phase 1 completed in early 1990s
Characterisation completed
Areas of Potential Concern (APCs) identified
Potentially significant pollutant linkages identified
Conservative approach
Screens each APC through risk assessment
process – further work required?
15
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
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16
Radiological Risk Assessment – Part IIA
DESCRIPTORS FOR SEVERITY OF CONSEQUENCE OF CONTAMINANT
SOURCE-RECEPTOR LINKAGE
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17
Radiological Risk Assessment – Part IIA
DESCRIPTORS FOR PROBABILITY OF CONSEQUENCE OCCURRING
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18
Radiological Risk Assessment – Part IIA
DESCRIPTORS OF RISK SIGNIFICANCE
Likelihood:
Severe
Moderate
Potential
consequence:
Mild
Negligible
Very
likely /
certain
Likely
Very High Very High
Unlikely
Very
unlikely
High
Medium
High
High
Medium
Medium
Low
Medium
Medium
Low
Very low
Low
Low
Very low
Trivial
RISK = SEVERITY X LIKELIHOOD
June 27, 2016
19
Radiological Risk Assessment – Part IIA
June 27, 2016

Apply to each individual APC

This will define:

Is more work required?

What work is required?

When can you stop?
20
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

June 27, 2016

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
21
Considerations Prior to Demolition and
Decommissioning Assessment
June 27, 2016

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
22
Waste Classification

Waste classification and fate





June 27, 2016
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
23
Waste Management During Decommissioning
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24
Waste Management During Decommissioning
June 27, 2016
25
Waste Management During Decommissioning
June 27, 2016
26
Waste Management During Decommissioning
June 27, 2016
27
Waste Management During Decommissioning
Waste Management During Decommissioning
- Summary
June 27, 2016

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
29
Summary

Obligation and liability management
Legislation – grey areas; overlap; changes
 On-site as opposed to off-site

June 27, 2016

Complex sites
 Long histories; many stakeholders

Pollutant linkages
 Characterise; Assess; Mitigate

Waste management
 During characterisation
 During remediation
 During demolition & decommissioning
30
Acknowledgements
June 27, 2016

Sellafield contaminated land team

Hunterston A (Magnox North & Hugh Richards)

Bradwell (Magnox South)
31
Application of Radioactivity and the Law
to Contaminated Land and Demolition
Projects
Gareth Walker, BSc, PhD, MRSC