DOE OSTI2019
European basic safety standards require that exposure of humans to the potentially harmful effects of ionising radiation are optimised so that they are as low as reasonably achievable, taking account of economic and societal factors. In the United Kingdom the responsibility for ensuring that exposures to humans are optimised is split between two regulatory functions. The Office of Nuclear Regulation regulates exposures to workers in all scenarios and to members of the public in the event of an accident. Environmental regulators in each of the four nations comprising the United Kingdom regulate exposures to members of the public from normal operations. Since the early 1990's, all permissions granted to nuclear sites in the UK for the discharge/disposal of radioactive waste to the environment have contained conditions requiring holders to demonstrate that they minimise the generation of radioactive waste, apply appropriate abatement and discharge/dispose of it in a way that minimises impacts on members of the public and the environment. For many years, the industry standard for providing this demonstration, which was heavily influenced by regulatory expectations and feedback, was to undertake one or a series of multi-attribute decision assessments (MADA). Wood's team of environmental specialists has been involved in undertaking such MADA studies for many years. Since the mid-2000's, our team has become increasingly aware of some of the limitations of undertaking MADA to demonstrate environmental performance for large scale new nuclear build projects and, in particular, the next generation of new nuclear power stations that are being planned and implemented in the UK. We have collaborated with the vendors of reactor technologies, the prospective/owner operators of new nuclear power stations and the developers of new facilities on existing sites to develop an alternative approach to demonstrating environmental performance. Our alternative approach comprises three main pillars which are summarised as: - Evolution - benefit from progressive improvements, operational experience and recent permitting activities. Our alternative approach uses the claim, argument, evidence approach which is commonly used for nuclear safety cases and which allows us to 'tell the story' of how environmental performance has been achieved. We have successfully deployed this approach for all new nuclear power stations proposed in the UK. - Integration - ensure that optimisation is integrated into the project programme and forms part of the 'big picture'. Our alternative approach allows environmental performance to be managed better throughout the life cycle of the project and ensures that our outputs are 'living' documents and do not 'sit on the shelf'. We have successfully demonstrated how this can be applied during rationalisation of major schemes and significant design changes on nuclear new build projects. - Opportunity - identify the best time to deliver elements of the programme. Our alternative approach aims to minimise the overall time, trouble and costs associated with demonstrating environmental performance by ensuring that decisions are made at the time when they offer greatest benefit and by minimising unnecessary rework. Our advice has helped to reduce the project costs and minimise delays associated with regulatory queries and interventions. This paper describes the journey that we have taken with our clients in developing our alternative approach to demonstrating environmental performance. We explain the UK regulatory context and explore the need for change. We present a number of case studies related to new nuclear power stations and other new facilities on existing nuclear sites that demonstrate the successful application of our alternative approach. We provide examples of how we have successfully implemented the outputs of our alternative approach into project and corporate management arrangements. Finally, we examine feedback from clients, regulators and other interested parties to propose future refinements. (authors)
12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗