Master List of MS Comments DS447 SG Predisposal Management of Radioactive Waste from Nuclear Fuel Cycle Facilities Type MS No. Para/Line No. Proposed new text Reason Accept Accepted, but modified as follow Reject Reason for modification Gen AUS 1 General No comments X Sc/Str FIN 6 General DS447 is almost identical with the document DS448. The consistency of these guides should be verified. X Sc/Str GER1 1 General As already requested in our statement to the previous draft version of DS447 dated 25 March 2013, it should be examined closely whether the Draft Safety Guides DS447 and DS448 can be combined and merged into one publication. This publication should contain sections dealing with more general recommendations like radiation protection, roles and responsibilities, management system, general safety considerations; one section dealing with lifecycle safety considerations specific for the predisposal management of radioactive waste arising from nuclear power reactors and research reactors; one section dealing with lifecycle safety considerations specific for the predisposal management of radioactive waste arising from nuclear fuel cycle facilities. Furthermore, it should be considered whether the Draft Safety Guide DS454 “Management of Waste from the Use of Radioactive Materials in Medicine, Industry, Research, Agriculture and Education” (revision of WS-G-2.7) can also Even in the actual revision of the two drafts there still remain a lot of common features for the predisposal management of radioactive waste arising from nuclear reactors and fuel cycle facilities. Almost all paragraphs in DS447 contain general recommendations for predisposal waste management. There are only a few paragraphs and appendices that are specific to predisposal management of radioactive waste arising from nuclear fuel cycle facilities. In DS447 and DS448, there are a large number of paragraphs whose text is more or less identical. On the other hand, a couple of paragraphs differ in text (e.g. Para 6.1 in DS447 and DS448) or in the assignment to subsections (e.g. Para 5.2 of DS447 corresponds to Para 3.26 of DS448), but unmotivated. In summary, there are no obvious reasons to be recognized for the preparation of two separate Safety Guides on this issue. X
be included in this publication. GER1 2 General If it is agreed by the competent Safety Standards Committees to maintain two separate Draft Safety Guides (DS447 and DS448) on predisposal management of radioactive waste, the wording in both documents should be made completely identical for all parts in which the issues addressed are applicable in the same way to both kinds of wastes. In the current draft versions, there are recommendations or statements in one document which are missing in the other document though they are applicable to both kinds of wastes. It is not apparent why those differences exist. X clar IRQ 10 General It is suggested that a new section is added to describe the general requirements of quality assurance. Radioactive waste management requires planned and systematic actions to satisfy a priori requirements for quality. X Ch 4 addresses Management Systems, which supersedes/ includes concept of QA clar JAP 7 General The following words should be defined. the waste generation facility (in 4.11) the waste generating facility (in 4.17) a facility that generates radioactive waste (in 5.2) (Example) 4.11 The interdependences between the waste generation facility the waste generating facility, predisposal radioactive waste management facility and the (existing or anticipated) disposal facility should also be defined. It would be better for them to use same words. Will review for consistency w Safety Glossary: “waste generator: The operating organization of a facility or activity that generates waste. For convenience, the scope of the term waste generator is sometimes extended to include whoever currently has the responsibilities of the waste generator...” gen SWE 1 General Sweden has no comments X Sc/Str UK 1 General Several UK organizations believe that DS447 and DS448 should be merged into a single Safety Guide. ● The principals and standards applied to the management of radioactive wastes should focus on X
Plans, Safety Cases and Decommissioning Plans. edit UK 5 General N/A The document would benefit from a general editorial review, due to some basic shortcomings in grammar and the same points being unnecessarily repeated. X Inte Z Iran 1 General Somewhere it should be mentioned that a challenge derives from the shared responsibilities at national level by the waste generators, the waste management operating organizations and the regulator, regarding the implementation of the safety measures and the definition and implementation of a well-structured and optimized waste management strategy. Comment made during 3Q 2103 Asia Regional mtg of the Joint Convention X Inte Z Switz 1 General As I understand, the final goal is to merge the transport & storage safety cases of the DPC into a single document, right? Does this mean that the competent authority of the country of origin which issues the transport license will also take into consideration in its assessment the interim storage conditions in order to ensure for transportation of the DPC at the end of the assumed interim storage duration, without a need for re-licensing? In the given case it should be considered to state in the transport license which storage conditions and ageing effects have exactly been taking into account and assessed, since these boundary conditions may differ from Topic W.11.2 "Feedback from the Joint Working Group on Integrated Transport and Storage Safety Case for Dual Purpose Casks". message from the WASSC member of Switzerland, on the suggestion to extend the ageing management programme from DPC to HLW casks, and also sharing with Monika, as the DPC for HLW perhaps might be taken into account in a WS document. As this suggestion does not fit to the scope of the document on DPC
waste its generation up to (but not including) disposal, including waste processing (pretreatment, treatment and conditioning) as well as storage and transportation. edit UK 9 1.05 P. 02 footnote The operator is the generator of radioactive waste and includes……… To improve the grammar of the sentence. X edit GER3 4 1.08 1st sentence:“… when no disposal facility has been established, reasonable assumptions have to be made about the likely disposal option.” Wording. X clar UK 12 1.08 In cases where …. Wastes are to be stored for long periods of time, precautionary and properly justified assumptions will have to be made….. It is highly important that any assumptions made regarding anticipated future acceptance criteria at a disposal facility are precautionary and properly justified. The guide could also mention that similarly conservative assumptions should be made about the timescales in which a disposal facility will be made available. X See response to Germany Comment No. 4 edit IRQ 2 1.09 Line 1 Add the word “will” to precede the word “supersedes” to become “This safety will supersede those parts of following safety standards…” Till the publication already be finished of this draft. X Once published, this SG will supersede WS-G-2.5 and WS-G-2.6. edit UK 8 1.09 line 4 Delete hyphen and move closing bracket from end of paragraph to here To improve the grammar and clarity of the paragraph. X UKR 2 1.09, p. 2 1.12, p. 3 It is stated in ¶ 1.9 that this Safety Guide … provides recommendations on the predisposal management of radioactive waste generated by nuclear fuel cycle facilities (excluding nuclear power plants The inconsistency should be eliminated. The scope of the Safety Guide should be clarified. X
clar GER2 7 1.14 last sentence: “Spent fuel that is transferred to destined for reprocessing facilities is not considered radioactive waste.” The intended use is decisive for the classification of spent fuel (either radioactive waste or a future energy resource), not the physical act of a transfer to a reprocessing facility. X edit GER3 6 1.14 2nd sentence: “These are dealt with in the Safety Guides WS-G-6.1, Storage of Radioactive Waste [10] and SSG-15, Storage of Spent Nuclear Fuel [11].” To be consistent within this list (citation of the relevant Safety Guides either with or without their titles). X IRQ 3 1.167 This paragraph is better to be omitted. Because this draft is not concern with physical protection of materials. X Text was agreed with NSCGC edit GER3 8 1.17 2nd sentence: “Recommendations and guidelines on nuclear security arrangements at nuclear facilities and of radioactive material are provided … in publications in the IAEA Nuclear Security Series, such as IAEA Nuclear Security Series No. 14 [14].” Simplify wording. X IRQ 6 2 General exemption criteria for predisposal waste management practices should be included. Identify the need for optimization of radiation protection and safety measures. X UK 15 2.02 “The Safety Requirements, GS-R-3, The Management System for Facilities and Activities, requires both the regulatory body and the operator to establish a management system….” The UK’s non-prescriptive regulatory regime implies that establishment of the management systems that ensure safety is purely the responsibility of operators. The independent regulatory body is responsible for setting out the goals that such management systems should achieve, without being proactively involved in the establishment of those systems. “The Safety Requirements, GS-R-3, The Management System for Facilities and Activities, requires both the regulatory body and the operator to the establishment of a management system….” X DS456, Leadership and Management for Safety (revision of GS-R-3), is applicable to the operation as well as the regulation of facilities.
instance. clar CAN 9 3.18 (b) change from “…its renewal after expiration” to “its renewal at or prior to expiration…” This would create an unlicensed waste facility if licence is permitted to expire USA 5 3.19, line 3 P. 9 Modify sentence to read: ….to avoid any omissions or unnecessary duplications and to prevent conflicting requirements, as practicable, on the operating organization. In some cases, when multiple regulatory authorities are involved, requirements could be more stringent by one authority than the other due to timing and/or overlap of regulations. CAN 10 3.20 last sent. Change to: “If a facility is shut down and no longer to be used for its intended purpose, a final decommissioning plan and supporting documents shall be submitted to the regulatory body for approval within two years of permanent shutdown, unless an alternative schedule is agreed by the regulatory body. The regulatory body should review the specific decommissioning arrangements in accordance with DS450. Add new text to include regulatory guidance for the review of the final decommissioning plan. COMMENT: Section 3.20 provides regulatory guidance on the level of review on “initial decommissioning plan” which is conceptual. However, the section does not provide any similar guidance for the final decommissioning plan. Consistent wording with DS450 which is referenced. X UK 29 3.20 Delete This paragraph is concerned with the assessment of decommissioning plans and not the management of radioactive wastes. There is adequate relevant guidance on the topic of decommissioning plans in alternative Safety Guides. USA 6 3.20, Line 4 Modify last sentence to read: If a facility is shot down and no longer to be Completeness to ensure compliance with State
Clar UK 35 3.25 “a waste management programme for each facility, integrated with all other relevant programmes” A "facility specific" waste management programme may be insufficient. Cross- site planning is required on multi-facility sites (i.e. integrated site-wide strategies and programmes). Edit UK 36 3.25 line 1 In the case where…. To correct the English as in DS448 CAN 14 3.26 Change ‘At an early state in the lifetime’ to ‘Prior to licensing… Otherwise the timing of this seems to conflict with 3.9? X edit GER3 19 3.26 3rd sentence: “For new facilities, features that will facilitate decommissioning should be taken into consideration at the design stage; such features should be included in the initial decommissioning plan …” last sentence: “For existing facilities without a decommissioning plan, such a plan should be prepared by the operating organization as soon as possible.” Ensure consistency with Para 3.20 of this document as well as with the Draft Safety Requirements DS450 “Decommissioning of Facilities” (revision of WS-R-5), see Paras 7.3 and 7.4 of the final version dated 20 November 2013 (approved at the 34th CSS meeting in November 2013). Clarification with regard to the responsibility for preparing the decommissioning plan. UK 37 3.26 Delete This paragraph is concerned with decommissioning plans and not the management of radioactive wastes. There is adequate relevant guidance on the topic of decommissioning plans in alternative Safety Guides. UK 39 3.26 Consider inserting a para on the safety case as in DS448 Possible omission and consistency with DS448 UK 38 3.26 Insert: The decommissioning plan should be Omission
appropriate mechanisms for ensuring that sufficient financial resources are available to undertake all necessary tasks throughout the lifetime of the facility, including its decommissioning (GSR Part 1) [2].” statements) are provided. Modify wording to emphasize that a requirement (or “shall” statement) is cited here. UK 44 3.34 “Site operators and the owners of radioactive wastes are required to put in place….” This paragraph makes no allowance for the fact the operator may not be the waste owner and that responsibility for provision of finance may rest outside the operator (e.g. NDA and MoD in the UK situation). FIN 1 3.35 P. 14 The operating organization should draw up emergency plans on the basis of the potential radiological impacts of accidents (GS-R-2 GSR Part 7) [24] and should be prepared to respond to accidents at all times as indicated in the emergency plans (See Chapter 7). MS comments are already given on GSR Part 7. Please check whether the reference could be updated. edit GER3 24 3.35 “The operating organization … should be prepared to respond to accidents at all times as indicated in the emergency plans (See Chapter 7 Para 6.82).” Wrong reference is provided. There is no Chapter 7 in this document. UK 45 3.35 Delete This paragraph is concerned with emergency plans and is not specific to the management of radioactive wastes. There is adequate relevant guidance on the topic of emergency plans in alternative Safety Guides. AFG 1 4.01 The designers of security systems should consult with qualified safety experts to ensure that security measures do not compromise the safety of individuals or the protection of the environment. Safety and security shall be comprehensively elaborated. X
USA 33 4.01, P. 52 Modify bullet #4 to read: Concentrations of contaminants in the waste streams including heavy metals such as chromium and vanadium. Completeness to consider other heavy metals contained in the waste stream. IRQ 4 4.01, 4.5, 4.6, 4.17, 4.21, 4.24 Insert “nuclear” before the reference to “security” Terms of the IAEA IND 2 4.02 The operator should assess and manage the interfaces between nuclear security, safety and nuclear material accountancy and control activities in a manner appropriately to ensure that they do not adversely affect each other and that, to the degree possible, they are mutually supportive “in a manner” is not clear enough. UK 46 4.02 Delete Paragraph 4.2 repeats the key points of paragraph 4.1 clar GER2 25 4.03 “When material is required to be accessed for waste management or safeguard purposes, this should take account of relevant safety requirements for radiation protection, and waste management as well as nuclear security considerations should be taken into account.” To improve the comprehensibility of this statement, the sentence should be reworded. Our proposal is provided here. edit IND 3 4.03 When material is required to be accessed for waste management or safeguard purposes, this should take account of requirements for radiation protection, and waste management as well as nuclear security considerations should be taken into account. Paraphrasing for better expression UK 47 4.03 Last line Suggest adding sentence ‘Specific recommendations on nuclear security in the management of radioactive waste are dealt Since guidance on security matters ins not covered in this section there should be a reference indicating
waste arisings are required to be managed. It requiring requires decisions on waste forms to be produced which, in this situation, must be made before all radioactive waste management activities are finally established. edit IND 6 4.11 Where If there is no disposal facility yet available or defined, then an interim position should be defined …. Where If there is no disposal facility yet available or defined, then an interim position should be defined …. UK 52 4.11 After Insert new Para: “Waste packages should have a system of identification that is unique, able to be linked to its associated records and that takes account of the need to be read in the long term future up to disposal.” Omission CAN 17 4.12 Delete 1st sentence of example. It appears to duplicate 4.5(b) and the concluding sentence carries the matter. X edit IND 7 4.12 Site and facility waste management programmes should be carried out to identify all relevant interdependences and include arrangements to ensure that they are appropriately considered from the point of generation to the point of disposal. Paraphrasing for better expression CAN 18 4.13 1st sent. Suggest moving the words in brackets “(safety, health, environmental…)” from 4.14/first line to 4.13/ first line after “The requirements on management systems”. This better identifies the different management systems. X CAN 19 4.14 1st sent. Replace the word ‘required’ with ‘recommended’. The management system requirements of Integration should not be a requirement but rather be based purely on an analysis by the facility. There are sound benefits and
4.14 last sent. GS-R-3 can still be mentioned in 4.13 but make the requirement for integration a recommendation only. Change appendix 2 to appendix 5. increases in safety level with integration; however, this may not always be the case for every facility at any stage in its lifetime. Integration may not make sense in some facilities in certain situations and may not have any added safety benefit. Please check, I think the wrong appendix is being referenced. clar GER2 28 4.14 1st sentence: “As stated in GS-R-3 [8], aAn integrated management system (including safety, health, environmental, nuclear security, quality and economic elements) is required to be established, implemented, assessed and continually improved by the operating organization. and iIt has to should be applied to all steps of the predisposal management of radioactive waste [8] [4].” In a Safety Guide, usually recommendations (or “should” statements) are provided. Modify wording to emphasize that two requirements (or “shall” statements) are cited here. The respective requirements should be addressed in two separate sentences. clar GER2 29 4.14 3rd sentence: “Management systems should make provision for siting, design, construction, commissioning, operation, maintenance and decommissioning of the predisposal radioactive waste management facility.” For completeness. The Draft Safety Guide DS441 “Construction for Nuclear Installations” provides specific recommendations on the management system for the construction of nuclear installations. Remember that the revised definition of the term ‘nuclear installation’ includes facilities for the predisposal management of radioactive waste arising from nuclear fuel cycle
facilities. clar GER2 30 4.14 last sentence: “Examples of management system lifetime provisions are provided in App. 2 5.” Wrong App. is cited in this Para. JAP E3 4.14 Line 2 (p.17) The Mmanagement systems should make provision for Editorial JAP E4 4.14 Line 2 (p.17) …provided in App. 5 2. Editorial CAN 19a 4.15 1st sent. Change “… management facilities are maintained,…” to “…management facility is maintained,…”. Since management system is singular then typically it is one waste management facility. However, if the intention was to mean that there could be multiple facilities under one management system, then this comment can be disregarded. X edit GER3 31 4.15 1st sentence: “The management system should be designed to ensure that the safety of the radioactive waste management facilities are is maintained, …” Grammar. edit IND 8 4.15 The management system should be designed to ensure that the safety of the radioactive waste management facilities are maintained, and that the quality of the records and of subsidiary information on radioactive waste inventories is preserved, with account taken of the duration of the management and storage periods and the consecutive management steps are taken into account, for example, clearance, Paraphrasing for better expression
(processing, storage) of radioactive waste management, consideration should be given to the incorporation of measures that will ease operation, maintenance of equipment and eventual decommissioning of the facility.” this document are reproduced from Para 4.20 of the Safety Guide SSG-15 “Storage of Spent Nuclear Fuel”. Therefore, it is understood that the phrase ‘long term radioactive waste management’ in the context of both paragraphs relates to processing (i.e. pretreatment, treatment and conditioning) and storage. This should be clarified by the proposed insertion. In Paras 3.13 and 6.16 of this document, the phrase relates to disposal as the final management step. CAN 24 4.23 Consider adding section with similar text to DS448 section 4.19 To include future possibility of waste relocation edit IND 11 4.23 Consideration should also be given to the need to of developing monitoring programmes and inspection techniques for use during extended periods of storage. Preposition correction clar GER2 36 4.24 Include new 3rd sentence: “… Storage arrangements for records should meet the requirements prescribed by the national authorities or the regulatory body and the status of the records should be periodically assessed. In general, records should be stored at two different sites which have no physical connection to each other (principle of redundancy). If records are inadvertently destroyed, …” It is a good practice when records concerning the generation, processing and storage of radioactive waste are stored, physically separated from each other, by both the operating organization and the regulatory body (or the national authority, depending on national regulations).
edit GER3 35 4.24 1st sentence: “… the likelihood and consequences of loss, damage or deterioration due to unpredictable events such as fire, flooding or other natural or human initiated occurrences induced hazards.” Consistency with the terminology used elsewhere in this document (compare with Paras 6.76 (e), (f) and 6.85 (b)) as well as in the Safety Requirements NS-R-3 and subordinated Safety Guides. edit IND 12 4.24 Records concerning the radioactive waste and its storage that need to be retained for an extended period should be stored in a manner properly such that minimizes the likelihood and consequences of loss, damage or deterioration due to unpredictable events such as fire, flooding or other natural or human initiated occurrences can be minimized. Paraphrasing for better expression clar UK 57 4.24 “If any records are inadvertently destroyed, the records that survive are likely to become more valuable – operators should their records retention strategy in such circumstances.” The original wording may be misinterpreted, as asking for consideration to be given to deletion of the remaining records, in the event that a proportion of the pre-existing records are accidently destroyed. IRQ 8 5 Safety considerations in the design of predisposal waste management facilities for radioactive waste should be specified (such as ventilation systems, engineering shields, etc.) Ensuring safety during operation of predisposal waste management facilities. UK 58 5 This section could be made more concise and better targeted if it focused on issues specific to the management of radioactive wastes. The Guidance on the Management of Higher Activity Wastes that has been The original text contains a significant amount of guidance that is applicable to all activities with any type of nuclear matter and is adequately covered in other Safety evaluate
produced jointly by the ONR and the Environment Agencies in the UK could provide a useful template to follow. Guides. UK 59 5 This section could be strengthened by inclusion of some advice on how to apply proportionality in safety assessments for radioactive waste management facilities. Facilities involved in predisposal management of radioactive wastes handle wastes with a very broad range of hazards – ranging from spent fuel to VLLW and wastes that may ultimately be released from any regulatory controls. Some of the described approaches would be disproportionate for those facilities that deal with relatively low hazard material. UK 87 Req. 14 Add “commissioning”. Active commissioning of a facility can generate radioactive wastes, so is relevant to this requirement. edit GER3 37 5.02 1st sentence: “Prior to authorization of a radioactive waste management facility or a facility that generates radioactive waste, the operating organization should provide the regulatory body with a safety case and supporting safety assessment that demonstrates the safety of the proposed activities and demonstrates that the proposed activities will be in compliance with the safety requirements and criteria set out in national laws and regulations.” last sentence: “The operating organization may wish to set an operational target level below the specified limits and controls to assist in avoiding any breach of those that may be approved.” Consistency with the wording used elsewhere in this document (compare with Paras 5.4, 5.5 and 5.9). The safety case will normally include the findings of a safety assessment. Wording.
clar GER2 40 5.06 “The safety case should include identification of uncertainties in the performance of the waste management facility and related activities, analysis of the significance of the uncertainties, and identification of approaches for the management of significant uncertainties. Such uncertainties should be a focus of an examination of the interdependences between the boundaries of interlinking safety cases. Guidance on the management of uncertainties is provided in GSG-3 [29].” 1st sentence: Clarification and completion. Compare with e.g. Para 4.6 (third bullet and last but one bullet) of GSG-3. 2nd sentence: Make clear that the safety cases for the waste management facility and the nuclear fuel cycle facility are usually interlinked. last sentence: Include reference to GSG-3 in order to guide the reader of this document. USA 13 5.06, Last sent., P. 21 Modify last sentence to read: Such uncertainties should focus on examination of inputs and interdependence of safety case options Correctness: Uncertainties are mostly related to inputs into the safety case and multiple scenario, or safety argument, options. FIN 2 5.07 P. 21 As stated in GSG-3, compliance with the requirements for the documentation of a safety case presents a number of challenges; for example, due to the target audience being composed of a wide range of interested parties with different needs, expectations and concerns, as well as due to situations in which there are complex legal and regulatory requirements involving multiple regulatory agencies with different regulatory processes and where multiple levels of documentation are required. It should be noted that the regulatory authorities involved in the authorization of nuclear fuel cycle facilities are often larger in number due to the greater scope of safety The text can be simplified. Add also security concerns.
challenge for some types of legacy waste for which the accuracy and completeness of historical records may be limited. Therefore, safety assessments for the predisposal management of legacy waste should be performed in a comprehensive and detailed manner.” documentation and knowledge, legacy waste needs to be assessed with particular care. The radioactive waste foreseen for retrieval from the Asse II repository mine in Germany is a prominent example. During the period of waste emplacement in the Asse II mine, no national or international classification system for radioactive waste existed. The waste was categorized mainly against the background of its handling (e.g. dose rate at the cask surface; the activity inventory served only a a rough guide). UK 63 5.10 Re-word third sentence to: ”In such circumstances, reasonably practicable measures should be taken to maintain adequate safety of the facility”. To improve on the grammar and clarity of the original text. CAN 27 5.12 (f) to (i) Descriptions of these bullets need to be included (after 5.25) Consistency - completion of all bullets (only descriptions of bullet (a) to (e) are provided from pages 22 to 24) ENISS 2 5.12 Add: (j) Identification of structures, systems and components important to safety and their safety requirements Missing . SSC should be introduced here FRA 4 5.12 Add: (j) Identification of structures, systems and components important to safety and their safety requirements Missing . SSC should be introduced here UKR 5 5.12 (f) Evaluation of results and comparison It seems that evaluation of results
environment.” or human induced origin. FRA 5 5.19 (c) and (d) (c) GSG-3 identifies the general criteria and methodology that should be used to screen …..on safety and environmental limits set down for that facility. The process of identification and screening of hazards should consider the complexity of the facility or activity, as well as the evolution of hazards and risks over the lifetime of the facility or activity, and should be consistent with the regulatory framework. (d) Identification of scenarios: …. that evolve significant chemical and physical processing, material transfer and human intervention. The process of identification and screening of hazards should consider the complexity of the facility or activity, as well as the evolution of hazards and risks over the lifetime of the facility or activity, and should be consistent with the regulatory framework. For clarification JAP E6 5.19(c) Line 1 (p.23) GSG-3[26] indicates… Editorial clar GER2 46 5.20 “App. 3 2 provides examples of hazards associated with typical activities for predisposal management of radioactive waste in fuel cycle facilities. App. 4 3 Wrong appendices are cited in this Para.
provides examples of hazards associated with dedicated waste management facilities. App. 5 4 identifies hazards associated with, or that could affect waste management at typical fuel cycle facilities. …” IRQ 9 6 A description on the Waste Characterization Methods and Procedures will be required. Inclusion of recommended waste acceptance criteria will be helpful. To be used as a guideline to the member states. JAP E7 6 INTRODUCTION GENERAL GENERAL may be more appropriate. Check the titles of subsection in other Safety Guides. (e.g. RS-G-1.7 uses “General.”) AFG 3 6.01 Accept all the steps, but few are missing Immobilization Decommissioning of Nuclear facility. These two are essential and fundamental steps during waste pre-disposal. X CAN 28 6.01 Start with ‘ As per the IAEA safety glossary definitions ,….’, also include waste handling in the list Set up comes from the glossary; handling should be included GER1 47 6.01 “The steps involved in the predisposal management of radioactive waste are: assessment of potential waste arisings and evaluation of options for their long term management (disposal) waste generation and control processing …” For completeness. In a first step, it is necessary to assess potential types and volumes of radioactive waste to be generated, and to options for the safe disposal of this waste. In a second step, measures to control the generation of radioactive waste, in terms of type, activity and volume, are to be considered before the construction of a nuclear installation, beginning
of radioactive contamination; (f) Provisions for the decontamination of zones and equipment to prevent the spread of radioactive contamination. UK 67 6.06 B.) “The selection of design options that facilitate waste minimization throughout the facility’s entire lifecycle, including its final decommissioning.” Plant design can have an important impact on waste minimization during the operational phase of a facility’s life, as well as during decommissioning (eg by minimising the amount of contamination spread). UK 68 6.06 E.) “Adequate zoning to prevent contamination spread” Zoning in itself does not “prevent contamination” as stated in the original text. Instead it can help prevent the spread of contamination. USA 17 6.06, P.28 At end of Para add: Alternate to GSG-1 waste classification scheme, country specific waste classification scheme may be developed and adopted by certain States Flexibility for countries using other waste scheme classification than GSG-1. RUS 4 6.06.-6.8. WASTE GENERATION AND CONTROL This section is expedient to be supplemented by the following provision and corresponding recommendations: “Minimization of radioactive waste generation should be provided through facility lifetime by means of process and materials selection, construction methods, commissioning, operational and decommissioning arrangements.” Minimization of radioactive waste generation should be provided not only during design stage by design and engineering measures, but also through facility lifetime (siting, construction, operation and decommissioning). CAN 31 6.08 Suggest reword to ‘Pretreatment operations including segregation should be carried out to optimize the disposal route. Decay doesn’t always allow regulatory control to be removed
edit GER3 53 6.16 1st sentence: “… are provided in GSG-1 [9]; Annex III of which also provides information on origin and types of radioactive waste, including waste arising from nuclear power production and other activities in the nuclear fuel cycle.” This document deals with the predisposal management of all types of radioactive waste generated by nuclear fuel cycle facilities (excluding nuclear power plants and research reactors). FRA 8 6.18 To the extent possible, liquid waste should be processed and conditioned (eg. Through immobilization, etc.) to promote safe handling and disposal. Processing and conditioning of waste is not in the scope of “characterization and classification of waste” but in the following part “Processing of radioactive waste” (liquid waste conditioning already in 6. 47) edit GER3 54 6.18 last sentence: “To the extent possible, liquid waste should be processed and conditioned (e.g., through immobilization, etc.) to promote safe handling, storage and disposal.” Completeness with regard to the further steps involved in the management of radioactive waste. UK 72 6.19 Replace by equivalent Para (6.27) of DS448, which has two separate sentences and is clear. As written it is confusing as the second clause relates to segregation but reads as a qualification of classification. edit GER3 48 6.2 2nd sentence: “Therefore the radioactive waste has to be categorized and characterized throughout the steps of its predisposal management of radioactive waste.” Wording. USA 18 6.20, Line 29 At the end of Para 6.20,add: Blending of waste at point of origin may be permitted to facilitate its disposal. Completeness CAN 36 6.21 P. 29 Remove heading ‘Introduction’ Not required.
clar GER2 67 6.65 Note: Items (f) and (g) should be moved to the preceding Para dealing with the management of liquid radioactive waste and effluents. Consistency with Para 6.40. As mentioned in this Para, spent ion exchange resins are usually flushed out as slurry and subsequently managed as liquid waste. This categorization is supported by IAEA-TECDOC-1504 “Innovative waste treatment and conditioning technologies at nuclear power plants” (2006) and “New developments and improvements in processing of ‘problematic’ radioactive waste” (2007). According to them, spent ion exchange resins are managed as liquid (wet) waste. CAN 44 6.65 (a) What does ‘amount’ refer to? Not clear if this is volume/weight and volume is size? CAN 45 6.65 (b) & (c) Suggest combining these as one. ‘Consideration of the waste classification’ More consistent CAN 46 6.65 (g) This bullet also applies to liquid radioactive waste Filtration is in the active liquid waste system UKR 9 6.65 p. 38 Add after (d) a new bullet “Areas for storage of raw radioactive waste and final product following predisposal management” For completeness clar GER2 68 6.67 “The predisposal management of radioactive waste may also entail the management of non-radioactive hazardous material. Measures should be taken so as to ensure that its management is in compliance with the applicable regulations relating to Clarification and completion with regard to a suitable handling of non-radioactive hazardous material in the predisposal management of radioactive waste.
USA 32 App. 2 P. 49 Insert in 1st and 2nd row of the table: Environmental Impacts Completeness JAP 10 App. 4 Facilities, (p.54) bottom line 1 ●Chemical process that generate effluent and gaseous emissions (including formation of explosive mixtures in the off-gas system) We propose to add example with specific consideration related to the off-gas system at reprocessing facilities. It would be assumed to form ammonium nitrate due to hydrazine and nitric acid mixture in the off-gas system. JAP 9 App. 4, facilities (p.54) ●Chemical reagents and reaction products (including hydrogen, and nitrogen oxides and organic materials) Organic materials (dodecane, DBP, MBP etc.) are also potentially reactive materials. JAP 11 App. 5 Clarify demarcation between this App. and DS477 ”The Management System for the Predisposal and Disposal of Radioactive Waste”. These descriptions should be addressed in DS477 ”The Management System for the Predisposal and Disposal of Radioactive Waste”. ENISS 9 App. 6 P. 59 Replace “ROBUSTNESS “ by “LONG TERM PERFORMANCES and DURABILITY” Correct terminology FRA 16 App. 6 p. 59 Replace “ROBUSTNESS “ by “LONG TERM PERFORMANCES and DURABILITY” Correct terminology edit GER3 76 App. 6 “RADIOLOGICAL PROPERTIES The radiological characteristics of the waste could include: (a) number and types of radionuclides nuclide-specific activities and (b) total radioactivity content (alpha, beta/gamma); Items (a), (c), (d) and (e) can be merged into a single item.
(c) half-life; (d) activity; (e) activity concentrations; (fc) dose rate; (gd) Hheat output.” edit USA 22 P. 33 Two subtitles “Liquid waste and discharges” appear on P. 33. Please remove 2nd subtitles. Remove duplication and redundancy edit JAP E12 Ref. [06] INTERNATIONAL ATOMIC ENERGY AGENCY, Safety of Nuclear Fuel Cycle Facilities, IAEA Safety Standards Series No. NS-R-5, IAEA, Vienna (2008). Currently under revision (DS439 and DS478) For consistency with description of other references. edit GER3 77 Ref. [31] This reference should be deleted. WS-G-2.3 exists twofold in the list of references (also Ref. [18]). edit GER3 78 Ref. [37] “INTERNATIONAL ATOMIC ENERGY AGENCY, Safety Aspects in Siting Site Survey and Site Selection for Nuclear Installations, DRAFT SAFETY GUIDE DS433 (in preparation).” Correct title of the publication approved at the 34th CSS meeting in November 2013. edit GER3 79 Ref. [38] “INTERNATIONAL ATOMIC ENERGY AGENCY, Construction of for Nuclear Installations, DRAFT SAFETY GUIDE DS441 (in preparation).” Correct title of DS441.