1 Introduction to safety case and safety assessment: purpose and content of safety case Ian Crossland Crossland Consulting

2 Scope of the presentation What is the safety case? What issues exist in application to near surface disposal in Ukraine?

3 What does the literature say? “A safety case is the synthesis of evidence, analyses and arguments that quantify and substantiate a claim that the repository will be safe after closure and beyond the time when active control of the facility can be relied on” (NEA, 2004) Discussion of this description is limited to technical considerations, and some consideration of management (i.e. quality assurance) This can be viewed as a “well done” safety assessment

4 Is that all there is? Adequate regulatory oversight Financial surety Adequate and continuing funding Stakeholder interactions

5 Cornerstones (legs) of the safety case

6 Components of the legal leg Independence of regulator and operator Enforcement powers of regulator National regulations for waste management framework Specific regulations for waste disposal Stakeholder outreach – may be prescribed in law All these establish the framework for disposal

7 Components of the financial leg Adequate operational funding –Establish a waste fund –even before the disposal occurs for (say) R&D –Funding of institutional control –Potential funding for remedial actions –May address needs for reversibility

8 Components of the managerial leg Technical competence of operator and regulator Quality assurance and control Adequate resources –Human resources –Infrastructure and equipment Documentation Corrective actions Stakeholder interactions

9 Components of the technical leg Key issue of understanding the site and the basis of safety achieved through safety assessment and the associated activities –Safety assessment integrates many technical activities (eg characterization) –Allows risk-informed decisions about all technical elements of the assessment –demonstrates safety Site selection, facility construction, operation and closure Institutional control –Monitoring for public acceptance

10 Evolution of elements of the safety case in time

11 Summary of what the safety case is At a simple level, a good safety case consists of meeting the regulatory requirements and recommendations Specifically, demonstration of adequacy in terms of –meeting the legal requirements –financial measures –management systems –technical issues - key issue of adequate understanding of the basis of safety Importance of safety culture Deficiencies in safety cases can be traced to deficiencies in legal, financial, managerial, or technical approaches

12 What does this mean for near surface disposal in Ukraine? Legal and regulatory Financial Managerial Technical

13 Legal and Regulatory Issues National regulatory structure in place –prescriptive and conservative regulations make near surface disposal of RAW difficult –WAC for Ukraine wastes more restrictive than for similar facilities in Spain and France –Seemingly, no recognition of special status of Exclusion Zone Institutional control –100 years passive years active –could it be longer if linked to control of Exclusion Zone?

14 Financial Issues Financial issues are always at the center of decision making in waste management –Even extensive and expensive site characterization programs can result in significant residual uncertainties But for Ukraine the issue is especially difficult: –financial restrictions –a large remediation and decommissioning programme –no revenue streams for legacy wastes Clear need for –prioritization across all activities (do what is important) –optimization within activities (do it cheaper) –recognition of special status of the Exclusion Zone –funding mechanism needed to ensure it will not happen again with current and future NPPs

15 Managerial Issues Need for well-organized and competent operator –safety culture - good understanding of the key issues to highest level –well developed management systems (eg procedures) –training programmes Need for well-organized and competent regulator –clear understanding and guidance –clear interfaces between different regulators –training programmes Long term programmes – need for succession planning

16 Technical Issues Limited funds and previous Soviet practice lead to limited site characterization –How much site characterization is enough? –This issue is not unique to Ukraine –Decisions about all disposal facilities rely on limited data Strong reliance on the engineered barrier performance –Common to all near-surface disposals –How much assurance is enough? Special difficulty for Chernobyl accident wastes of waste characterisation –cannot link the radionuclide vector to a specific waste stream –therefore large uncertainties in radionuclide vector

17 Summary Key elements of the safety case are technical, legal, managerial, and financial All of these elements must be addressed to give confidence in safe disposal Key issues –appropriate regulation and recognition of special status of EZ –wider understanding of basis of safety of near surface disposal –prioritization/ optimization –training / capacity development –succession planning