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Brian Delaney
Health & Safety Executive's Safety Policy Directorate
SAFEGROUNDS Learning Network Steering Group
The HSE welcomes CIRIA's SAFEGROUNDS project since Health & Safety Executive (HSE) is developing policies in this area.
Regulation of radioactive waste management, including radioactively contaminated land, on nuclear sites is one of the responsibilities delegated by HSE to its Nuclear Installations Inspectorate (NII).
NII attaches conditions to nuclear site licences in the interests of safety and with respect to the handling, treatment and disposal of nuclear matter. Contaminated land can constitute storage of bulk quantities of radioactive waste, in which case nuclear site licence conditions apply. Conditions with particular relevance require adequate arrangements for storage of nuclear matter; record-keeping; safety cases; monitoring, minimisation and containment of wastes.
Some sites have been cleared to green field status, representing no danger, and have been de-licensed. The high standards achieved have been described in Robinson I. F. A nuclear inspector's perspective on decommissioning at UK nuclear sites. J.Radio. Prot. 1999 Vol.19, No.3, p203-212 and Robinson I. F. and D N Simister: A regulatory view of de-licensing at UK nuclear sites. Proceedings of the 6th Society of Radiological Protection International Symposium, Southport, 14 June 1999, Editor M C Thorne, ISBN 07058 1884 9. At the end of dismantling and clearance work, licensees may wish to terminate their period of responsibility so that land can be developed for other uses. The HSE is unable to de-license land containing significant radioactive contamination, but would still press for partial remediation or improved containment to reduce spread of radioactivity, where appropriate. The Health and Safety at Work etc. Act 1974 and Nuclear Installations Act 1965 (as amended) give HSE powers that can be used to this effect.
NII has Safety Assessment Principles (SAPs), see Safety assessment principles for nuclear plants. HMSO 1992 ISBN 0 11 882043 5, which can be readily applied to contaminated land. The priority is for the licensees to prevent soil contamination in the first place, by defence in depth, rather than simply to react after the event. Where contamination has occurred, licensees should demonstrate control by a series of barriers. Contaminated soil should be contained, segregated and characterised. Licensees have to produce adequate safety cases for all operations which may affect safety. Safety cases will be needed for contaminated land, covering storage as well as any remediation work, eventual disposal, and for de-licensing if appropriate. Licensees would be expected to balance risks and benefits associated with remediation work against risks from care and maintenance. Factors that need to be taken into account include minimisation of waste generation, burdens on future generations, and protection of the environment. The presumption should be that, where remediation is reasonably practicable, it should be performed sooner rather than later.
Radioactively contaminated land on licensed sites needs to be included in site-specific strategies for management of radioactive waste and will be included in HSE's future quinquennial reviews of licensees' radioactive waste management and decommissioning strategies. If localised radioactive contamination is found, the licensee should consider removing it. Although capacity is finite, disposal facilities for low level waste can be used for contaminated soil to allow restoration of a site to an acceptable condition. Licensees should also consider other options, since transferring risks and liabilities to another location does not necessarily solve the problem. The overall environmental impact must be acceptable to HSE, which must consult the Environment Agency or Scottish Environment Protection Agency (SEPA) on matters involving radioactive wastes. SAFEGROUNDS will supply information on technologies for remediating or containing contaminated land and will also provide guidance on techniques for characterising land to determine the nature and extent of any contamination. This may augment the existing safeguards which aim to protect the public from the hazards of ionising radiation. A major benefit of the project will be to inform the public and involve them in decisions on the standards that should be set.