ARGUMENTOS EN FAVOR DE LA REPUGNANCIA: DEVLIN, KASS, M ILLER, KAHAN

The national disposal research programme OPERA (see section B of the present report) addresses the issue of institutional controls and makes proposals on the types of institutional control necessary, taking into account the prolonged retrievability of the waste from the repository. It is, however, not expected that the recommended institutional controls will lead to significantly different cost estimates.

Article 23. QUALITY ASSURANCE

Each Contracting Party shall take the necessary steps to ensure that appropriate quality assurance programmes concerning the safety of spent fuel and radioactive waste

management are established and implemented.

23

Quality Assurance

General

Due to the limited size of the nuclear industry, it was not cost-effective to develop a specific national programme of QA rules and guidelines. As a result, initially the IAEA SS QA Series No. 50-C-Q was chosen to provide the basis for the QA programme in the Netherlands. The No. 50-C-Q has been replaced by IAEA GS-R-3 “The management

system for facilities and activities”. The implementation of GS-R-3 has been completed at the NPP Borssele and at COVRA this process is well underway and will be concluded in 2015. It is anticipated the GS-R-3 will be replaced by another IAEA guide, considering the development of the (still draft) DS-456 guide.

At COVRA, provisions from the industrial standards NEN-ISO 9000 – 9004 have also been implemented.

The RB is in the process of drafting a requirements document on Management and Organisation, which is based on DS-456 and SSR 2/2. It is expected to be published and implemented in 2016.

Regulations

The Integrated Management System (IMS) of COVRA is part of the operating licence and hence is binding for the LH. Those parts of the IMS that apply specifically to design and construction of the installations and to the safe operation of the spent fuel and waste management facilities require prior approval from the KFD.

Specific elements of the IMS of COVRA

The core of the system is the Integrated Management System Manual. This IMS Manual contains:

 Policy statements;

 The values and expectations of senior management;  A description of the structure of the organization;

 A description on how the management system complies with the requirements imposed on the organization;

 A description of the processes as well as supporting information that explain how work is to be prepared, reviewed, carried out, recorded, assessed and improved. With regard to the acceptance criteria for vitrified waste it is worth to mention that the specifications were drawn by the reprocessing facilities and approved by the operators of the NPPs and the RB. These specifications were used – among other things – as input for design and licensing of COVRA’s HLW facility. These specifications include guaranteed parameters for contamination and radiation levels, heat load and chemical composition. Before shipment from the reprocessing site to COVRA, all relevant data and product files are provided and checked, compliance with transport regulation is assured, and the canisters are witnessed by COVRA and the NPP operator. Upon arrival at the COVRA site a second check is performed.

Article 24. OPERATIONAL RADIATION PROTECTION

1. Each Contracting Party shall take the appropriate steps to ensure that during the operating lifetime of a spent fuel or radioactive waste management facility:

(i) the radiation exposure of the workers and the public caused by the facility shall be kept as low as reasonably achievable, economic and social factors being taken into account;

(ii) no individual shall be exposed, in normal situations, to radiation doses which

exceed national prescriptions for dose limitation which have due regard to internationally endorsed standards on radiation protection;

(iii) measures are taken to prevent unplanned and uncontrolled releases of radioactive materials into the environment.

2. Each Contracting Party shall take appropriate steps to ensure that discharges shall be limited:

(i) to keep exposure to radiation as low as reasonably achievable, economic and social factors being taken into account; and

(ii) so that no individual shall be exposed, in normal situations, to radiation doses which exceed national prescriptions for dose limitation which have due regard to internationally endorsed standards on radiation protection.

3. Each Contracting Party shall take appropriate steps to ensure that during the operating lifetime of a regulated nuclear facility, in the event that an unplanned or uncontrolled release of radioactive materials into the environment occurs, appropriate corrective measures are implemented to control the release and mitigate its effects.

24.1 (i)

ALARA

As has been stated before in the text on Article 19 of the Convention, the basic

legislation on nuclear activities in the Netherlands is the Nuclear Energy Act. A number of decrees have also been issued, containing more detailed regulations based on the

provisions of the Act. The most important decrees for the safety aspects of nuclear facilities and the radiation protection of the workers and the public are:

 the Nuclear Installations, Fissionable Materials and Ores Decree (Bkse);  the Radiation Protection Decree (Bs).

The Bkse requires the LH of a nuclear facility to take adequate measures for the protection of people, animals, plants and property. Article 31 of the Bkse states that a licence must contain requirements aimed at preventing the exposure and contamination of people, animals, plants and property as far as possible. If exposure or contamination is unavoidable, the level must be as low as is reasonably achievable (ALARA). The number of people exposed must be limited as much as possible, and the LH must act in accordance with the individual effective dose limits.

The Bs states that these activities must be carried out by or under the responsibility of a person with sufficient expertise, subject to the judgement of the RB. This expert should occupy a post in the organisation such that he or she is able to advise the management

of the facility in an adequate way and to intervene directly if he or she considers this to be necessary.

Written procedures must be available to ensure that the radiological protection measures which have to be taken are effective and that the above-mentioned expert is properly informed. Full details of these conditions are given in the Bs, which also lays down more specific requirements on the protection of people and the environment from radiation. Throughout the Bs the concept of ALARA is used and it is required to be applied to all exposures and discharges as well as to disposal of radioactive waste.

The above requirements also apply for the holder of a licence for practices with radioactive materials.