Category Archives: Infrastructure and methodologies for the. justification of nuclear power programmes

Occupational protection at nuclear power plants (NPPs)

Occupational radiation protection at NPPs is internationally governed by the ILO Convention 115 (ILO, 1960), by the BSS (IAEA, 1996a, 2011) and by specific guidance on occupational radiation protection (IAEA, 1999a) and on assessment of occupational exposure due to intakes of radionuclides (IAEA, 1999b) and to external sources (IAEA, 1999c). These are fully based on specific ICRP recommendations (ICRP, 1997b). A wide interna­tional consensus exists in this area (IAEA, 2003b) and its international regulation (Gonzalez, 2003b).

In short, the international accord establishes that all those persons engaged in work at NPPs are in principle considered occupational exposed workers, although the occupational protection standards apply in toto only to those performing work in controlled areas. Those organizations that employ them should be considered as employers. Both workers and employ­ers should be subjected to responsibilities established in the occupational radiation protection normative.

Employers shall be responsible for protecting the workers and complying with any relevant requirements of the occupational radiation protection standards, ensuring in particular that the occupational exposures be limited as specified in the relevant requirements and that occupational protection and safety be optimized in accordance with the relevant requirements.

Employers should also ensure that decisions regarding measures for occupational protection and safety be recorded and made available to the workers through their representatives where appropriate. They should establish policies, procedures and organizational arrangements for protec­tion and safety for implementing the relevant requirements, with priority given to measures for controlling occupational exposures.

Employers are also responsible for providing the following:

1. Suitable and adequate facilities, equipment and services for protection and safety, the nature and extent of which are commensurate with the expected magnitude and likelihood of the occupational exposure

2. Necessary health surveillance and health services, providing appropri­ate protective devices and monitoring equipment and arranging for its proper use

3. Suitable and adequate human resources and appropriate training in protection and safety, as well as periodic retraining and updating as required in order to ensure the necessary level of competence, keeping records of the training provided to individual workers

4. Adequate records of occupational exposure

5. Consultation and cooperation with workers with respect to protection and safety, concerning all measures necessary to achieve the effective implementation of requirements

6. Necessary conditions to promote a safety culture

7. In consultation with workers, writing rules and procedures as are nec­essary to ensure adequate levels of protection and safety, including values of any relevant dose level that require investigation or specific authorization and the procedure to be followed in the event that any such value is exceeded, and making such rules and procedures and the protective measures and safety provisions known to those workers to whom they apply

8. Supervision of any work involving occupational exposure and taking all reasonable steps to ensure that the rules, procedures, protective measures and safety provisions be observed

9. For all workers, adequate information on the health risks due to their occupational exposure, adequate instruction and training on protec­tion and safety, and adequate information on the significance for pro­tection and safety of their actions

10. For female workers, appropriate information on (i) the risk to the embryo or foetus due to exposure of a pregnant worker; (ii) the impor­tance for a female worker of notifying her employer as soon as she

suspects that she is pregnant; and (iii) the risk to an infant ingesting radioactive substances by breast feeding.

Employers should ensure that workers exposed to radiation from sources that are not directly related to their work receive the same level of protec­tion as if they were members of the public. They should obtain, as a pre­condition for engagement of workers, the previous occupational exposure history of such workers and other information as may be necessary to provide protection and safety.

They should also be transparent with the information. In fact they should take such administrative actions as are necessary to ensure that workers are informed that protection and safety are integral parts of a general occupational health and safety programme in which they have certain obli­gations and responsibilities for their own protection and the protection of others, and in particular record any report received from a worker that identifies circumstances which could affect compliance, and shall take appropriate action.

As far as recording is concerned, employers should arrange for the assess­ment of the occupational exposure of workers, on the basis of individual monitoring where appropriate, and ensure that adequate arrangements be made with appropriate dosimetry services under an adequate quality assur­ance programme. They should also arrange for appropriate health surveil­lance based on the general principles of occupational health and designed to assess the initial and continuing fitness of workers for their intended tasks. Finally, they should maintain exposure records for each worker, which shall include (1) information on the general nature of the work in the response involving occupational exposure; (2) information on doses, expo­sures and intakes at or above the relevant recording levels and the data upon which the dose assessments have been based; (3) when a worker is or has been occupationally exposed while in the employ of more than one employer, information on the dates of employment with each employer and the doses, exposures and intakes in each such employment; and (4) records of any doses, exposures or intakes due to other emergency interventions or accidents, as well as providing for access by workers to information in their own exposure records and for access to the exposure records by the supervi­sor of the health surveillance programme, facilitating the provision of copies of workers’ exposure records to new employers when workers change employment, and preserving such records during the worker’s working life and afterwards at least until the worker attains or would have attained the age of 75 years, and for not less than 30 years after the termination of the work involving occupational exposure.

On their side, workers shall be responsible for following any applicable rules and procedures for protection and safety specified by the employer and using properly the monitoring devices and the protective equipment and clothing provided. They should cooperate with the employer with respect to protection and safety and the operation of radiological health surveillance and dose assessment programmes and provide to the employer such information on their past and current work as is relevant to ensure effective and comprehensive protection and safety for themselves and others.

Workers should abstain from any wilful action that could put themselves or others in situations that contravene the requirements. The should accept such information, instruction and training concerning protection and safety as will enable them to conduct their work in accordance with the require­ments of occupational radiation protection standards. Finally, they should be reporting to the employer, as soon as feasible, circumstances that could adversely affect compliance with the standards, if for any reason a worker is able to identify such circumstances.

It is interesting to note that according to the international labour norma­tive, conditions of service of workers shall be independent of the existence or the possibility of occupational exposure. Special compensatory arrange­ments or preferential treatment with respect to salary or special insurance coverage, working hours, length of vacation, additional holidays or retire­ment benefits shall neither be granted nor be used as substitutes for the provision of proper protection and safety measures to ensure compliance with the requirements of the relevant occupational radiation protection standards.

As indicated heretofore, a female worker should, on becoming aware that she is pregnant or if she is nursing, notify the employer in order that her working conditions may be modified if necessary. The notification of pregnancy or nursing shall not be considered a reason to exclude a female worker from work; however, the employer of a female worker who has notified pregnancy or nursing shall adapt the working conditions in respect of occupational exposure so as to ensure that the embryo or fetus, or the nursing infant, is afforded the same broad level of protection as required for members of the public. Taking account the above requirements and the unavoidable uncertainties surrounding accident-response measures, in practice it might be unfeasible to occupy female workers in those condi­tions as emergency responders undertaking life-saving or other urgent actions. Under these circumstances, employers shall make every reason­able effort to provide such potential workers with suitable alternative employment.

The general dose limits for occupational exposure have been described before. In more detail, the ‘normal’ occupational exposure of any worker shall be so controlled that more of the following limits be exceeded:

• An effective dose of 20 mSv per year averaged over five consecutive years

• An effective dose of 50 mSv in any single year

• An equivalent dose to the lens of the eye of 150 mSv in a year

• An equivalent dose to the extremities (hands and feet) or the skin of 500 mSv in a year. (The equivalent dose limits for the skin apply to the average dose over 1 cm2 of the most highly irradiated area of the skin. Skin dose also contributes to the effective dose, this contribution being the average dose to the entire skin multiplied by the tissue weighting factor for the skin)

• In special circumstances, the values for the single-year effective dose can be duplicated.

For ‘abnormal’ situations that may occur if an accident happens at an NPP, special conditions might be employed for volunteers engaged in recov­ery operations. For workers undertaking rescue operations that involve saving life, no dose restrictions are recommended in principle if, and only if, the benefit to others clearly outweighs the rescuer’s own risk. Otherwise, for rescue operations involving the prevention of serious injury or the development of catastrophic conditions, every effort should be made to avoid deterministic effects on health — by keeping effective doses below 1000 mSv to avoid serious deterministic health effects, or below 500 mSv to avoid other prompt health effects (the latter criterion leaves a margin for error in avoiding deterministic effects because of the possible difficulty in determining the exact exposure conditions immediately after an unex­pected abnormal situation and the possibility that the workers concerned may not have the level of training or experience usually required for responding to such an unexpected situation). For workers undertaking other immediate and urgent rescue actions to prevent injuries or large doses to many people, all reasonable efforts should be made to keep doses below 100 mSv of effective dose.

For emergency actions undertaken by workers engaged in recovery oper­ations, the doses received should be treated as part of normal occupational exposure and the ‘normal’ occupational dose limits apply, namely a limit on effective dose of 20 mSv/year, averaged over five years (100 mSv in five years), with the further provision that the effective dose should not exceed 50 mSv in any single year, and annual equivalent dose limits of 150 mSv for the lens of the eye, 500 mSv for the skin (average dose over 1 cm2 of the most highly irradiated area of the skin), and 500 mSv for the hands and feet.

It should be re-emphasized that those rescuers undertaking actions in which the dose may exceed 100 mSv of effective dose should be volunteers, and should be well prepared for dealing with the aftermath of a radiation emergency, i. e., they should be clearly and comprehensively informed in advance of the associated health risk and, to the extent feasible, be trained in the actions that may be required, including the use of protective measures.

‘Atoms for peace’

In August 1945, shortly after the June 1945 signing of the UN Charter by the Heads of State, two atomic bombs were dropped on the Japanese cities of Hiroshima and Nagasaki, bringing an end to World War II. Subsequently, fears arose that atomic weapons could spread, and with them the potential for mass destructive power never before seen on such a scale.

With international attention focused on the atom, on 8 December 1953 before the 470th Plenary Meeting of the UN General Assembly, US President Eisenhower delivered an address titled ‘Atoms for peace’.[22] During the course of his speech, he stated:

I therefore make the following proposal. The governments principally involved, to the extent permitted by elementary prudence, should begin now and con­tinue to make joint contributions from their stockpiles of normal uranium and fissionable material to an international atomic energy agency. We would expect that such an agency would be set up under the aegis of the United Nations.

Disposal of spent nuclear fuel and waste from reprocessing

Spent fuel and high-level waste from reprocessing is highly radioactive and remains dangerous for thousands to hundreds of thousands of years and will require isolation in a deep geological repository. Also the ILW from reprocessing will require disposal in a geological repository. So far no such repository has been built. There is, however, an international consensus among the experts that disposal in a deep geological repository can be made in a safe way and that the long-term safety can be assessed (NEA, 1999a, 1999b, 2009; Witherspoon and Bodvarsson, 2006). Several countries are developing the design for a deep geological repository and are in the process of looking for a suitable site. Good progress is being made in Finland, France and Sweden. Finland and Sweden have decided to dispose of the spent fuel directly. Sites have been chosen and the licence is under prepara­tion. Operation is foreseen to start shortly after 2020. France will dispose of high-level vitrified waste and other long-lived reprocessing waste at depth in a clay formation in eastern France. The detailed siting is going on and operation is planned for around 2025. The progress of all these three projects will be very important as it will show the feasibility of disposal irrespective of whether the fuel is reprocessed or not.

The principles employed for geological disposal are fairly simple. The waste, which in itself is a solid that is resistant to dissolution and leaching, is placed in a tight container that is designed to remain tight for a long time and the container is placed in an environment that is benign for keeping the tightness. To ensure the latter, the siting looks for a geological medium that can be expected to remain mechanically and chemically stable for the long time periods required. In particular the chemical processes at depth, with small water movements, are very slow.

The safety of waste disposal is based on the multibarrier principle, i. e. the waste shall be surrounded by several barriers that are functioning inde­pendently of each other. This means that if one barrier fails, or our knowl­edge of the processes affecting the integrity of that barrier is not correct, the other barriers will ensure the long-term safety.

In Fig. 14.9 the disposal concept (KBS-3) developed in Sweden and Finland is shown. The spent fuel is encapsulated in copper canisters that are stabilized by an internal iron structure. The waste canisters are placed in boreholes at the bottom of tunnels at about 500 m depth in the granitic rock found in Sweden and Finland. In the boreholes the canisters are sur­rounded by bentonite clay, which provides a mechanical and chemical pro­tective buffer. At the end also the tunnels are backfilled with a mixture of bentonite and sand. This is the system that will be used for the first geologi-

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14.9 Schematic presentation of the KBS-3 disposal system for spent nuclear fuel to be implemented in Finland and Sweden (© SKB, illustration by Jan M. Rojmar — Grafiska Illustrationer).

cal disposal facilities that are considered in these countries for disposal of spent nuclear fuel. The barriers are:

• The fuel matrix itself, in which most of the radioactive elements are part of the matrix and are released only when the matrix is dissolved or cor­roded. The dissolution/corrosion rate is very low in the kind of water existing at the repository depth.

• The copper canister, which is highly corrosion resistant in the chemical environment created by the bentonite and the reducing groundwater at the repository depth. The iron structure in the canister ensures the mechanical stability of the canister against the pressures found at depth from the rock, the groundwater and the swelling bentonite clay.

• The bentonite clay, which reduces the inflow of corrodants from the ground water to the canister and also ensures that the outflow of radio­nuclides from the fuel, if the tightness of the canister is broken, is very slow. The bentonite also has a chemical buffering effect, keeping a stable pH.

• The surrounding rock, which has a low water flow and ensures that the transport of corrodants to the bentonite buffer and the canister is slow. The rock also provides mechanical stability around the canister. Finally the rock acts as a filter if the tightness of the canister is broken and radionuclides are transported out from the fuel through the canister and the bentonite. The filtering function has two components. First, the trans­port of water is very slow, thus providing time for radiological decay of the radionuclides, and second, the transport is further delayed by chemi­cal adsorption of the radionuclides at the surfaces of the cracks through which water and radionuclides are transported.

Similar disposal systems are being being considered in other countries but have to be adapted to the specific geological settings chosen and to the waste forms. Different geological media are being considered in different countries. In addition to hard rock like granite, also clay and salt formations as well as sedimentary rocks are being investigated. As noted above, a clay formation has been chosen in France, for example, and disposal in salt has been the main line of investigation in Germany. Also different canister materials are being considered.

The disposal of ILW could in principle be based on a simplified version of the basic principles for HLW disposal, as the main concern for this waste could be human intrusion disposal at less depth, e. g. 100 m is considered for ILW. A repository for ILW has been in operation in the USA since the mid-1990s. It is the Waste Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico. Here the waste is disposed of in a dry salt formation in large salt rock chambers that are subsequently backfilled with crushed salt (Fig. 14.10). Another ILW repository is under construction in Germany at the Konrad mine.

An important component in the development of a deep geological dis­posal facility is the study of different technologies and processes in under­ground research facilities. Several such facilities have been developed around the world, e. g. the HADES facility in clay in Belgium, the URL in granite in Canada, the Aspo laboratory in granite in Sweden, and Grimsel in granite and Mont Terri in claystone in Switzerland.

Waste disposal is not only a technical question, it is a highly political and societal question and requires a strong commitment from society as well as from the industry. In several countries there have been political setbacks delaying programmes. The most spectacular ones have been in Germany and the USA. In Germany the development towards a repository in the Gorleben salt dome was well underway in the 1990s when it was halted by a political decision on a 10-year moratorium to investigate alternatives. At the time of writing this book (September 2010) discussions are underway to resume the work in Gorleben. In the USA a decision was made several

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14.10 The Waste Isolation Pilot Plant uses a continuous miner to carve disposal rooms out of the Permian Salt Formation, nearly a half mile below the surface (© US DOE).

years ago to develop a repository at Yucca Mountain in Nevada. Following many years of costly investigations and the preparation of an extensive licence application, a political decision was, however, made in 2009 to bring the project to a halt, although at the time of writing the final fate of Yucca Mountain is not yet determined. These examples show that politics can easily cost much more than engineering.

Balancing economic benefits and environmental impacts at a local level

At a local level, the social impacts of the nuclear industry result, on one hand, from the significant economic benefits the industry brings (such as direct and indirect employment, and the building of high value skills) and, on the other hand, from environmental consequences, which are difficult to weigh (such as effects on human health, time required to confine radioac­tive waste, accident risks, etc.). All these elements are addressed in a very detailed way in the NEA report Risks and Benefits of Nuclear Energy (NEA, 2007, pp. 56-73). As the report stresses, there is no consensus on the social impacts of nuclear power, and any indicators considered are partly intuitive and partly resulting from discussion between stakeholders.

In terms of local employment, both direct and indirect employment need to be considered: direct employment during construction (5-10 years), operation (about 60 years) and dismantling (several decades), and indirect employment resulting from local development, notably commercial and education infrastructures, and from the supply chain if it is localized in the country. There are no global statistics regarding local employment resulting from the nuclear industry, and figures can vary greatly from one country to another depending on existing national and local skills, and on the govern­ment’s and the operator’s human resources policy.

To consider the French case, the civil nuclear sector employs about 150,000 people, including about 26,000 EDF (Electricite de France) employ­ees, about 20,000 employees from other companies who work on the main­tenance of the 58 plants, and about 55,000 employees of other big companies (Areva, CEA, Andra). To these can be added about 50,000 employees of subcontractors, including those involved in construction, dismantling or maintenance of the plants, and more generally those working for service providers. All branches of engineering are involved, at different levels, including technicians, engineers, researchers, etc. To take the example of EDF’s Flamanville site (with two PWR plants in operation — Flamanville 1 and 2 — and one 1600 MWe EPR under construction — Flamanville 3), in 2009, there were 850 permanent jobs (650 EDF, 200 subcontractors), 1800 people working during the plant outages for scheduled maintenance and refuelling, about 40 trainees, and about 100 indirect jobs (trade, catering, security etc.). Construction of Flamanville 3 is scheduled to take place between 2007 and 2014, with 3300 employees on site (40% of whom are local staff, while 60% have been moved in). After 2014, there will be 300 EDF employees on site, 150 subcontractors, and about 900 people for main­tenance work during scheduled outages.

The operator has concluded agreements with local communities and local employment organizations, in order to facilitate the gathering of informa­tion on local companies, inform employment players of job offers and bids, orientate international and national companies to local employment, and increase local employees’ training. There is also a plan to help with retrain­ing after the building process is completed. Indeed, the operators’ strong involvement in local development, especially in employment, is the main lever of their public acceptance. This is one of the reasons why it is easier to rebuild a new nuclear plant on an existing nuclear site than it is to find a new site: the nuclear industry is viewed by neighbouring populations as a real asset for local development.

With regard to environmental impacts at the local level, impacts on human health during normal operation of a plant have to be considered, together with the potential effects of major accidents and the time required for radioactive waste confinement.

Several studies have made a comparison between different energy sources regarding the health impacts of normal operation and have shown that nuclear power, along with renewable energies, has the lowest health impact. See, for example, the mortality associated with normal operation of German energy chains in 2000 (Hirschberg et al, 2004). It appears to be clear that nuclear, wind and hydro have the lowest mortality, natural gas and solar photovoltaics are higher, and oil and coal have the highest rate of ‘years of life lost’.

The standards for emission of liquid or gaseous effluents include very significant safety margins, so that the human health impacts of a nuclear plant in normal operation are lower than the radioactive emissions found in granite regions, or experienced during a long flight. The standards of authorized emissions have been defined at the international level by UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation). These standards are applied in national regulations. There is a strict control of radioactive emissions from different points of a plant and in its vicinity, and in most countries such data are published by safety authorities and available to the public. Some controversies remain about the low-dose impact of radioactivity on health, which raise epistemological difficulties: how can we prove that there is ‘no effect’? All we can do is show that no link has so far been observed between normal emissions and mor­bidity. Outside normal operation, there have been controversies about the emissions from the Chernobyl accident, and it will take time to assess the emissions from the Fukushima accident and their impacts on the environ­ment. (It needs to be underlined here that the Fukushima accident was a consequence of the combination of an earthquake and a tsunami, and, at the time of writing, there have been no deaths due to radiation in Fukushima. However, the Fukushima accident will of course lead to a global assessment of safety requirements and emergency planning and organization. The Three Mile Island (TMI) accident in 1979, which was a technically severe accident, entailed no health impact on the population.)

Many studies have already been implemented and will yet be imple­mented to estimate the impact of the Chernobyl accident on human health. It is impossible to make a precise estimation because ‘radiation-induced cancers are not all distinguishable from those due to other causes’. And, moreover, other pathologies may also have been caused by radiation. A study published in 2005 by the Chernobyl Forum (an international expert group gathering together several UN agencies including IAEA and UNSCEAR, the World Bank group, Belarus, Ukraine and the Russian Federation) distinguishes three populations exposed to different levels of radiation: ‘emergency and recovery operation workers who worked at the Chernobyl power plant and in the exclusion zone after the accident, inhabit­ants evacuated from contaminated areas, and inhabitants of contaminated areas who were not evacuated.’ It concludes that ‘the highest doses were received by emergency workers and on-site personnel, in total about 1000 people, during the first days of the accident, ranging from 2 to 20 Gy, which was fatal for some of the workers. Effective doses to the persons evacuated from the Chernobyl accident area in the spring and summer 1986 were estimated to be of the order of 33 mSv on average, with the highest dose of the order of several hundred mSv’. It estimates that ‘among the 600,000 persons receiving more significant exposures, the possible increase in cancer mortality due to radiation exposure might be up to a few per cent’. Significant increases of thyroid cancers have been diagnosed among those who were children or adolescents at the time of the accident. This report concludes also that the socio-economic effects of Chernobyl in the contaminated areas should also be as soundly analysed as the health effects. There is no doubt that these are even more difficult to quantify than the health effects.

The social impact of waste confinement, at the local scale, is also a very controversial topic. The ‘Not In My Back Yard’ (NIMBY) syndrome applies more to waste storage or waste disposal than to nuclear plants, for several reasons. It is difficult to link these facilities to employment, as they do not produce any goods, and employment benefits are limited. Moreover, as will be shown below, a lot of people think that there are no satisfactory solutions for storing High Level Long Life (HLLL) waste, so they fear that a waste disposal plant could entail health consequences for neighbouring inhabit­ants, and could have a negative impact on the region’s image and on local products. Added to this, the time-scale involved with HLLL waste manage­ment — millions of years — seems beyond our human comprehension. For philosophical reasons it is very difficult to build confidence about waste management near disposal sites. People think that being given economic compensation is an attempt to buy their acceptance. It seems that strong operator and stakeholder involvement, from the beginning of a project of waste storage or disposal, can ensure better public acceptance of the shared burdens and benefits of steady-priced and cheap electricity. Some interest­ing experiments in this regard are being implemented in Bure, in north­eastern France, in the area surrounding a geological disposal research laboratory. There, all the radioactive waste producers have been involved in developing local employment opportunities by transferring renewable energy technologies to the area, in parallel with the R&D work being carried out on radioactive waste management. This helps to illustrate the share of responsibility between different regions in French energy policy: the regions which accept radioactive waste disposal benefit from technology transfers to develop also renewable energy sources.

Whatever the technical options considered, it would seem absolutely necessary for newcomer countries to think of a waste management policy right from the moment of the first opportunity study made when launching a nuclear programme, since the waste management question will be raised by their opponents anyway, and then taken up by public opinion at large. It is important to answer public concerns regarding intergenerational responsibility, which is one of the main issues of sustainable development. The goal of such a policy is to avoid passing on unsolvable problems to future generations. Today, several satisfying and secure options exist for managing different categories of radioactive waste (see Chapter 14), includ­ing HLLL waste, using geological disposal. The ‘problem’ of waste manage­ment is no longer a technical one but rather a psychological and political issue for local populations.

To conclude this section focused on the ‘social impacts’ of a nuclear pro­gramme, it appears that such impacts are still misunderstood, partly because of an ignorance of scientific matters, partly because of the ‘original sin’ of nuclear power, and partly because there is no link between statistics con­cerning risk and intuition, or gut feeling. A better knowledge of the techni­cal and economic facts and figures of nuclear power versus other power sources is a necessary (though not always sufficient) condition to obtain better public acceptance.

Waste licensing

Any disposal of non-radioactive waste (including excavation materials arising from construction) on a nuclear site will require an environmental permit issued by the EA under the Permitting Regulations 2010 and Part 2 of the EPA 1990 (see Section 33(1)(a)). Operators are prohibited from treating, keeping or disposing of controlled waste or extractive waste in a manner likely to cause pollution of the environmental or harm to human health. A duty of care is imposed on those in possession of waste requiring them to take all reasonable measures to, among other things, prevent the escape of waste from their control and secure that waste is only transferred to authorised persons. Like the other environmental permits issued under the Permitting Regulations 2010, the EA will be able to control the waste disposals through the conditions imposed, and to take enforcement action under Part 4.

Recognising the unique and hazardous characteristics of nuclear waste, the UK operates a separate regulatory regime which is much more stringent than in other areas of environmental regulation. The accumulation and disposal of radioactive waste requires an authorisation granted by the EA under the Radioactive Substances Act 1993 (RSA 1993). A disposal includes those directly into the environment, for example discharges to air, water and land, as well as transfers to other sites for disposal (which includes treatment). The EA is obliged to consult with a number of bodies before granting an authorisation, including the HSE and ‘such local authorities, relevant water bodies or other public or local authorities as appear. . . to be proper to be consulted’ (Section 16(5); see also Section 18). Under the RSA 1993, the Secretary of State has retained key powers and can direct the EA to grant (with or without conditions), refuse, vary, cancel or revoke applications, and can require certain applications to be determined by him or her. The RSA 1993 regime offers different levels of regulatory control, from local authorities through to the Secretary of State, to ensure that environmental impacts are adequately reflected in radioactive waste man­agement decisions. In order to ensure compliance, the EA has the power to issue enforcement and prohibition notices, and operators in breach of their authorisations could face an unlimited fine. There is also the possibility of up to five years’ imprisonment where it can be proved that an offence has been committed, with the consent, or by the neglect, of an officer of a corporate body.

Variations according to contract approach

As regards the turnkey approach, no matter how detailed the description of the bidder’s scope of supply in the SS document, it is highly advisable for the owner to protect himself with a ‘completeness clause’ clearly stating that the bidder is requested and shall therefore be committed to delivering a licensable and functionally complete plant, including all the services, structures, systems and components required for the plant to operate safely in accordance with the applicable codes, standards and regulatory require­ments of the country and in compliance with the owner’s technical require­ments as laid out in the BIS.

When the owner has opted for the split-package or multi-package approach, redacting the SS document becomes a more complex undertak­ing to ensure that each plant scope item is clearly assigned either to the owner or to one of the package suppliers. Following are some practical recommendations:

1. A SS document should be prepared specifically for each individual large package (e. g. NI, TI, BOP, civil works) making up the complete plant. This SS document shall describe the scope of supply of the owner, that of the supplier and that of other participants for each specific large package.

2. As there will be several package suppliers, the overall responsibility of defining the scope limits (terminal points) for each package, of integrat­ing all packages, of coordinating the various suppliers, and of managing and resolving interfaces among project participants remains with the owner.

3. In addition to the establishing the scope of supply and services of the owner, the SS document for each package shall clearly specify who is responsible for the performance of the following tasks referring to the overall project, which are not included in the scope of any of the indi­vidual packages:

• Overall project management

• Overall project schedule management

• Overall site management

• Overall plant commissioning management

• Licensing support coordination of the entire plant

• Management of interfaces between package suppliers

• Overall plant performance guarantee.

It is understood that each package supplier will be responsible for the project management, scheduling, construction and commissioning of his own package. Different package suppliers, as well as all other partici­pants in the project, should be given a clear understanding of who will take overall responsibility for the management and integration of the various packages that make up the complete plant. The owner may decide to keep for himself the performance of these tasks for the entire project or he may hire an architect-engineering firm to perform these services. The latter, acting as the owner’s engineer, will be responsible for overall management and integration of all packages on behalf of the owner.

4. Here again, the IAEA account system (IAEA, 2000) (or any other equivalent account system) provides guidance for the systematic check­ing of proper assignment to the owner, supplier or other project partici­pant of all items that should be included in the scope of each package, and to ensure that no item has been overlooked.

5. It is good practice for the SS document to include a requirement of ‘functional completeness’ for the structures, systems and components constituting the package, that is, all piping and cables installed, all con­nections completed, and all fluids (oil, water, air, gases) delivered to the terminal points at the interfacing conditions agreed, which means that all systems and components should be fully operational.

Regulatory documents for commissioning and operation

The overall objective of commissioning is to prepare the SSCs for opera­tion. This involves verifying that the SSCs meet their design requirements for safety and performance, for both individual structures and components and integrated systems. These requirements cover normal operation, antici­pated operational occurrences, and design basis accidents. Verifying the design provisions for management of accidents beyond the design basis can also be done at this stage, as far as it is feasible. There is some overlap between construction and commissioning since some SSCs may be commis­sioned before completion of the entire plant. (The various aspects of com­missioning and related activities are considered at length in Chapter 22).

There are several steps during commissioning that may require regula­tory approval. The introduction of fissile material into the plant is an impor­tant event and is considered in some cases to be the first point where regulatory decisions are required. Since commissioning is performed typi­cally over a few months, the licensee and the RB must both be prepared for an intensive period of activity. Besides planning and organizing its own activities, the licensee should ensure that the RB establishes and commu­nicates a detailed plan outlining how it will review the commissioning work, the nature of the required approvals and hold-points, and what information is required to be submitted by the licensee at each hold point. For example, the licensee should understand the clearances that the on-site regulatory staff can issue at the various stages of commissioning, and the submissions that are required to ensure such clearances. The licensee must also be sensi­tive to the fact that results of commissioning could lead to further refining of the regulatory requirements for plant operation, for example in its oper­ating procedures and in-service inspections requirements.

An operating license requires the submission of FSAR based on the PSAR previously submitted for the construction license, as summarized in Table 20.3. However, it includes more information from both the construc­tion and commissioning programmes and may also be impacted by new R&D information and international safety developments that have arisen during the construction period. Obviously, the satisfactory completion of the training and certification of operating staff is an essential milestone for the operating license, and is considered further in Section 20.5.4.

Operational procedures are developed before a plant is transferred from construction to operations. These include procedures that cover normal and off-normal operations, surveillance, maintenance, and emer­gency operations. Emergency operations procedures normally have to be approved by the regulator before issuing the operating license and prior to initial fuel loading. Several other submissions could be required depending on the national licensing processes and FSAR content, as indicated in Table 20.3.

During operation, there will be ongoing requirements to submit various operational reports to the regulator depending on licensing requirements and on the occurrence of any events that impact or have the potential to impact safety. Some of these requirements are discussed in Section 20.5.

Engineering support and design authority

Nuclear power plants are often designed and constructed by groups of companies that come together for a single or a small number of projects. The NPPs that they construct, however, will exist for several decades.

Nuclear power plants by their nature are complex. They are composed of many components and interdependent systems that must operate in a manner that meets the design intent. Over many years of operation the plant will experience many changes, equipment will become obsolete, and physical changes in the condition of materials will occur.

It is incumbent on the operating organisation, therefore, that they main­tain the capability to objectively assess changes in plant condition and performance, appraise design changes and retain the knowledge base to do so. This capability will reside in those bodies of engineering personnel with the knowledge and experience to perform those duties and in the body of design data, drawings and materials acquired from architect engineers at the time of construction. Collectively this corporate intellectual feature is known as the Design Authority. The IAEA publication INSAG-19, Maintaining the design integrity of nuclear installations throughout their operating life, provides further detail.

Benefits of international collaboration

In the above-mentioned report, the NEA suggested that the industry, research institutes and universities need to work together to coordinate efforts better to encourage the younger generation, as well as to develop and promote a programme of collaboration in nuclear education and train­ing, and to provide a mechanism for sharing best practices in promoting nuclear courses between member countries.

International collaboration would bring benefits, such as:

• Sharing costs among different countries, since development of training systems may be too expensive for one nation

• To counter a withering pool of training resources and knowledge

• To harmonize training standards at an international level

• To push initiatives for international skills retention, as well as to attract the next generation of scientists and engineers

• To demonstrate a united global position on future nuclear technology.

Taking into consideration the recommendations from the NEA and being aware of the benefits, some common education and training efforts at inter­national level have already started.

Before discussing those international initiatives, it is necessary to intro­duce one of the most important references in training: the Institute of Nuclear Power Operation (INPO).

Plant commissioning

7.1.3 Preparing for commissioning and start of operation

After the staff have undergone the initial training they should be associated with the experts of the reactor vendor in preparation of commissioning, operating and maintenance procedures and the technical specifications for operation that will include surveillance and in-service inspection schedules and administrative requirements. The O&M staff should also be involved in the process of review of such documents by the regulatory body.

A preliminary safety analysis report (PSAR) of the reactor and support­ing technical documents are provided by the reactor vendor. These docu­ments describe in detail the safety requirements laid down for the design and how the plant is able to meet these requirements under normal operating conditions, upset conditions and design-basis accident conditions. The PSAR also describes the engineered safety features and procedures for operator intervention to control the progression of beyond design-basis accidents and for mitigation of their consequences. The PSAR is a very important document not only for understanding the safety design of the plant but also for obtaining good familiarity with the behaviour of the plant under normal as well as abnormal conditions. The PSAR review together with the progressive review of the results of commissioning will be the basis for the regulatory body to issue a licence for initial fuel loading in the reactor core, first criticality of the reactor, ascension of power in stages and operation at rated power. A thorough study of the PSAR and the support­ing documents by the operating staff and their participation during the review of the PSAR by the regulatory body helps in acquiring good famili­arity with the design and operational safety aspects of the plant. Various modifications implemented during construction and those based on review of the commissioning results are suitably incorporated in the PSAR to produce the final SAR that correctly reflects the as-built plant.

Study of the SAR, the design and operating manuals of reactor systems and the equipment manuals and training on the reactor simulator will form the major component of the training of operating staff. The proficiency of the operating staff should then be checked through a system of getting checklists for individual systems signed by senior engineers, a plant walk­through, a written examination and an oral interview by a licensing board for their formal licensing for NPP operation.