In April 2010 the Environmental Permitting (England and Wales) Regulations 2010 came into force, repealing, amending and replacing much of the Radioactive Substances Act 1993. This legislation was brought in to deal with the control of radioactive material and disposal of radioactive waste in the UK. RSA93 is still valid in Scotland.
One element of RSA/ Environmental Permitting is the requirement to have a discharge authorisation for any radioactive discharge from a licensed site.
Discharge applications and renewals require an in-depth study of historic, current and proposed discharges. Ultimately, the regulator must be satisfied that any impacts on public health are well within safe limits.
TÜV SÜD Nuclear Technologies has extensive experience in successfully supporting site licensees in their applications for discharge authorisations/permits.
The authorisations/permits are periodically reviewed by the regulator. During the review process TÜV SÜD Nuclear Technologies has provided support to a range of licensees including input to the new nuclear build programme.
One of the key aims of the Nuclear Decommissioning Authority’s Radioactive Waste Management Ltd (RWM) is to ensure that when waste is packaged by waste producers it is in a form which is suitable for safe storage, transport, handling and potential disposal. As part of the process of ensuring that wastes are packaged to appropriate standards, RWM provides advice on proposals for packaging and, where appropriate, is prepared to offer endorsement of such proposals through the issue of a Letter of Compliance (LoC).
TÜV SÜD Nuclear Technologies provides an extensive range of services, relating to the production and management of LoC submissions and their review. We also assist in the development of future waste management strategies including the provision of advice on RWM requirements. We have a number of staff seconded into client organisations and RWM itself supporting the production of LoC documentation.
Examples of our work for NDA RWM:
The assessment of waste packaging submissions from waste producers.
Production of RWM Guidance Notes on a range of subjects including the management of tritium bearing wastes and the use of organic polymers to encapsulate ILW.
Examples of our work for waste producers and site licensess:
Facilitating formal discussions with RWM on waste packaging proposals.
Gathering data required to support the production of waste packaging submissions (e.g. waste inventory studies).
Preparing formal waste packaging submission documents.
Managing interactions with RWM during their assessment of LoC submissions.
Preparing formal LoC submission documents.
Best Practicable Environmental Option (BPEO) assessments look to provide the best strategic option to managing wastes taking into account emissions to the environment as a whole.
Best Practicable Means (BPM) assessments identify the techniques and methods that can be applied to optimise a process, including consideration of environmental impacts such as minimisation of the volumes and activities of wastes created.
Effectively BPM and Best Available Technology (BAT) assessments are synonymous. Both have the aim of balancing costs against environmental benefits by logical and transparent approach to identifying and selecting processes, operations, and management systems to reduce discharges.
Extensive expertise is available within TÜV SÜD Nuclear Technologies on the development of radioactive waste management and decommissioning strategies. This is underpinned by a wide range of experience in completing a variety of assessment studies including BAT, BPEO and BPM studies in support of strategic decision making.
We can also provide specialists who have experience in facilitating decision making conferences, running Multi Attribute Decision Analysis models and workshops ensuring that the process is robust and not influenced by preconceived ideas. These have also included stakeholder engagement for larger studies (e.g. site end state).
The Nuclear Decommissioning Authority (NDA) requires its Nuclear Licensed Sites to produce detailed Integrated Waste Strategies (IWS) that are supported by the development of robust technical baselines.
The main objective of the Technical Baseline and Underpinning Research and Development (TBuRD) is to identify sound baselines to allow the delivery of systematic and progressive reduction of all hazards associated with a nuclear facility. Where research and development is required to support the implementation the required activities are identified and developed into a schedule. The TBuRD effectively informs the client as to the status of the maturity of the process and what needs to be done to get the process developed to the point of implementation.
Since 2006, TÜV SÜD Nuclear Technologies has expanded its capabilities in radioactive waste management through the development, production and delivery of TBuRD documents.
Our methodology is based on a waste led approach, and uses our ‘6 node’ approach for illustrating a waste management process flow. This methodology was created in direct response to lessons learned from previous, problematic legacy waste projects and provides a robust tool for ensuring that a waste compliance focus is applied to jobs where the major outputs are waste packages and waste streams. R&D needs, opportunities and risks are all identified on the diagrams.
TÜV SÜD Nuclear Technologies approach has been consistently praised by both the NDA and the regulators.
Our clients for TBuRD document development include: Magnox Ltd, NDA, RWM (GDF) & Sellafield Limited.
An Environmental Impact Assessment (EIA) looks at the possible impact, whether positive or negative, that a proposed project may have on the wider environment. This incorporates assessment of natural, social and economic aspects. The conventional way of assessing these impacts is to firstly characterise the existing baseline condition then evaluate potential impacts from the development in the short, medium and long term. Opportunities for mitigation are developed in tandem. The purpose of the assessment is to ensure that relevant decision makers consider the ensuing environmental impacts. In the UK Nuclear Sector EIA is required for reactor decommissioning as specified by the Nuclear Reactors (EIA for Decommissioning) Regulations 1999 (EIA-DR).
TÜV SÜD Nuclear Technologies would normally propose the following project elements:
Definition of candidate decommissioning site baseline and Environmental Risk Register
Detailed review of existing relevant company information
Detailed review of other available information sources
Information Gap Analysis
Further specific studies to address information gaps
Development of mitigation measures for identified impact
- Development of EIA taking into account: Best Practice EIA Assessment Principles and Practice, interface with other legislation and national policies & key stakeholders
Typically the EIA would address the following topic areas:
- Site and Locality
- Landscape and Visual Impact
- Management of Potentially Contaminated Land
- Terrestrial Ecology
- Marine Ecology/Coastal Management
- Waste Management
- Discharges and Emissions
- Social & Economic Impacts
We have first-hand experience of EIA-DR as applied to the decommissioning reactor fleet in the UK and have delivered enabling studies for currently operational stations prior to their planned decommissioning.
An Environmental Management System (EMS) refers to the management of an environmental programme in a comprehensive, systematic, planned and documented manner. Typically an EMS does the following:
Serves as a systematic tool to manage and improve environmental performance
Addresses immediate and long-term impacts of products, services and processes on the environment
Gives order and consistency for organisations to address environmental concerns through the allocation of resources, assignment of responsibility and ongoing evaluation of practices, procedures and processes
- Focuses on continual improvement of the system
TÜV SÜD Nuclear Technologies can provide services to assist in the identification and reduction of environmental impacts and can assist organisations in working towards the attainment of ISO 14001 environmental accreditation.
Our services include:
Establishment of environmental policies
Determination of the environmental aspects and impacts of products/activities/services
Planning and implementation of environmental objectives and measurable targets
Checking and corrective action
The safe transport of radioactive material is governed by various national and international regulations that are based on the International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive Material. Where non-routine shipments of radioactive material are planned, including the transport of waste packages, a detailed process of package design and assessment is required.
TÜV SÜD Nuclear Technologies has many years experience in production and assessment of documentation for the handling, storage and transport of radiological materials.
We have detailed knowledge of IAEA Transport Regulations, have been involved in developing the Nuclear Decommissioning Authority Radioactive Waste Management Directorate (RWM) Generic Waste Package Specification and have undertaken Transport Package Safety Assessments on behalf of the RWM.
TÜV SÜD Nuclear Technologies are supported by its Parent organisation TÜV SÜD, who have extensive experience preparing Transport Package Design Safety Reports for Competent Authority Approval in Germany. This has included assessments of:
- Heat removal, tightness and integrity
- Incident studies e.g. aircraft crash
- Impact, thermal and structural analyses of packages
- Impact evaluation of impact drop heights
Technology Road Maps (TRMs) are a strategic tool used to identify and manage those technology development activities required for the delivery of a new product, process or emerging technology.
TRMs show the operations required to meet strategic objectives and the R&D associated with underpinning those operations. A key feature of TRM’s is that all tasks are arranged against a timeline in order to show the ‘WHY’ (strategic objective), ‘WHAT’ (R&D tasks) and ‘WHEN’ (schedule) of work. Non-baseline work (opportunities) and decision points can also be easily articulated on the diagram to show a clear picture of all the requirements and options associated with achieving the strategic objective. TRM’s allow for complex, interconnected strategies and development programmes to be captured in a form which is easily communicated to stakeholders.
TRM’s are used by a diverse range of international businesses to ensure that their business strategies are successfully implemented and to ensure delivery of new products ahead of competitors.
TÜV SÜD Nuclear Technologies have integrated two processes to provide clients with a robust, holistic, integrated and planned approach for the delivery of technology development to meet their challenges.
For decommissioning challenges, we apply our waste led approach, illustrated through our ‘6 node‘ wiring diagrams to identify the baseline process together with the development needs, opportunities and risks. This structured approach clearly identifies the research and development requirements for the implementation of the process. We work closely with our clients to ensure that the process is set in the broader context of BPEO/BPM/BAT before developing the strategy for delivery. Cognisance is taken of the broader business context, availability of funding and analogous development activities. Development of the TRM is then used to illustrate and plan all of the development activities against a timeline to ultimately deliver against the strategy.
TÜV SÜD Nuclear Technologies have supported Sellafield Ltd in the development of their TRMs for a number of research and development programmes required to support both the ongoing operations and the decommissioning activities of the Sellafield site.
After discharge from a reactor, spent irradiated nuclear fuel is highly radioactive and invariably is first sentenced for a period of pond storage which allows for decay of short lived high energy gamma emitters and uranium isotopes.
Dealing with spent irradiated fuel is a complex conundrum of technical, political and socio economic factors and, internationally, different governments follow varying policies. Broadly the options available are to:
Reprocess the fuel to recover the uranium and separate the fissile plutonium. The remaining actinides and fission products are contained within passively safe waste forms such as glass
To continue storage above ground either in ponds or dry within casks or vaults
To develop concepts for the disposal of spent fuel - ultimately burial deep underground
To place the challenge in context, according to figures published by the International Atomic Energy Agency at the end of 2004 the total amount of spent fuel discharged from reactors worldwide was about 276,000tHM (tonnes Heavy Metal) of which 33% had been reprocessed. The remaining 67% was held in storage of which 90% was in ponds and the remaining 10% in dry storage.
TÜV SÜD Nuclear Technologies personnel have a broad and in depth perspective of the issues associated with the management of spent irradiated fuel and the technical solutions to these challenges.
We have extensive experience and understanding of wet fuel storage operations and of reprocessing facility operations. This includes the treatment and passivation of the subsequent waste streams. We also have extensive knowledge of advanced reprocessing technologies.
We are able to support our clients in their development of spent fuel management strategies and planning. This is performed without bias and prejudice and with a thorough and in depth understanding of the challenges that are faced.