GUIDELINE FOR RADIOACTIVE WASTE AND SPENT NUCLEAR FUEL
The Board of Directors of Iberdrola Generación Nuclear, S.A.U. (the “Company”), as the owner and body responsible for the operation of nuclear power plants for the generation of electric power, recognises its social responsibility to present and future generations for protecting the environment, in accordance with its environmental guideline. In addition, it recognises its Nuclear Safety Guideline as a premise and essential element for reaching its environmental protection goals. Through the promotion of innovation and eco-efficiency, and always by carrying out its activities giving absolute priority to nuclear safety, the "Company" is committed to assuming its responsibility as regards radioactive waste and spent nuclear fuel, from their generation through to their final transfer to an authorised treatment plant, in accordance with current legislation.
Innovation, eco-efficiency and security, cornerstones of management
Social environmental responsibility is of paramount importance in all matters related to the management of radioactive waste and spent nuclear fuel. This management, within the scope of the Company's responsibility, includes four well-defined facets or phases: first, minimization of generation, including waste from decommissioning; second, handling, characterisation, treatment and conditioning in safe conditions for workers and the public; third, temporary storage in the mid or long term at the facility where they have been generated and the preparation of the facility prior to its decommissioning and until final transfer of the stored waste to the waste management company; and fourth, funding of the components of the entire process — from generation to final disposal — which by law are the responsibility of the party that generates the waste.
In Spain, the management of radioactive waste, including spent fuel and the dismantling and decommissioning of nuclear facilities, constitutes an essential public service for which the Spanish State is responsible. In 1984, the Empresa Nacional de Residuos Radiactivos S.A. (ENRESA) was commissioned to manage this public service through Royal Decree 1522/1984 of July 14. The State will assume ownership of the radioactive waste once its definitive disposal is undertaken.
Detailed information on ENRESA's functions can be found in Article 19.2, on the approval of the new Royal Decree 102/2014 of 21 February on the responsible management of spent nuclear fuel and radioactive waste.
The General Radioactive Waste Plan (GRWP) constitutes the official document, which ENRESA draws up addressing the strategies, the necessary actions and the technical solutions to be developed in the short, medium and long term, aimed at ensuring the adequate management of radioactive waste, the dismantling and decommissioning of nuclear and radioactive facilities and the rest of the activities relating to the above, including the economic and financial measures required to carry them out.
Nevertheless, although the ultimate responsibility for radioactive waste and spent nuclear fuel lies with each State, the responsibility for the generation, treatment, temporary storage and funding subprocesses, according to current legislation, lies with the Company, which is aware that in those activities it must apply the highest quality standards for efficient management and ongoing improvement, adapting itself to changing requirements in harmony with the facility's operating activities, as a way to reach its corporate sustainability goals.
The above must meet the international obligations in this area through active involvement in the programmes and activities of the World Association of Nuclear Operators (WANO) and compliance with internationally accepted ethical principles and current regulations, including the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, the applicable regulations of the International Atomic Energy Agency (IAEA safety fundamentals, requirements and standards), the recommendations of the International Nuclear Safety Group (INSAG) and European Union regulations.
Aware of its responsibility to present and future citizens, employees, shareholders, suppliers and other stakeholders, the Company will endeavor to ensure excellent management in minimizing the amounts generated, the treatment and storage of radioactive waste and spent nuclear fuel, while guaranteeing the safety of the facilities, the radiological protection of workers and the public, and the physical protection of nuclear materials, in order to avoid leaving an undue burden for future generations.
These commitments are assumed and promoted through this Guideline so that all individuals, bodies and levels of the organisation integrate, watch over and promote the prioritisation of managing radioactive waste and spent nuclear fuel.
This radioactive waste and spent nuclear fuel Guideline is consistent with the Iberdrola Group's Policies and materialises in the following basic principles for action:
- Pay due attention to all matters related to the treatment, storage and minimisation of radioactive waste and spent nuclear fuel, paying them the attention they deserve, owing to their importance.
- Comply at all times with the terms and conditions of the official authorisations and all requirements imposed by regulations, in order to attain more demanding levels through self-regulation.
- Establish an organisation with adequate design, capacity, functions, responsibilities, qualifications, expectations and resources for implementing this Guideline and for fulfilling current legal funding obligations.
- Ensure that the original design of the radioactive waste and spent nuclear fuel treatment and storage facilities and their updating meets the accepted standards, agrees with current design and licensing specifications, and maintains adequate control of the facility's configuration, of the safety margins and of the principles of 'defence in depth'.
- Encourage the involvement and commitment of all individuals at all levels to radioactive waste and spent nuclear fuel treatment, storage and minimisation through their individual responsibility, exemplary conduct, teamwork, qualification and ongoing training, within a work environment that creates a favourable atmosphere for reporting deficiencies or opportunities for improvement and fosters swift resolution of incidents, fostering the highest levels of safety culture and respect for the environment.
- Implement, as parts of the integrated management system, processes, internal rules and supervision systems that contribute to attaining the desired conduct in favor of radioactive waste and spent nuclear fuel treatment, storage and minimisation, and assess the processes, rules and systems in order to achieve ongoing improvement. Stagnation and complacency are considered to lead to declining performance in the area of safety; however, self-criticism and organisational learning are vital elements for improving management.
- Measure the results in the area of safety through a system of indicators based on best international practices, providing the resources needed to achieve demanding goals related to those indicators, and oversee the application of this Guideline through the body responsible for independent internal nuclear supervision.
- Follow previously approved operating procedures inspired by the principles of prevention, surveillance and mitigation, oversee strict compliance with those principles and develop a dynamic of ongoing improvement through the feedback of usage experience, in both normal operation conditions and in emergencies.
- Maintain the traceability of radioactive waste and spent nuclear fuel and of the connections and dependencies across all treatment phases.
- Guarantee the physical protection of nuclear materials which may be diverted for illicit use while they remain in the facility under the responsibility of the holder of the operating authorisation or license.
- Establish a “prudent operational decisions” system that guarantees that the important issues for radioactive waste and spent nuclear fuel treatment and minimisation are treated with rigor, prudence, diligence and by competent individuals or bodies, with the involvement of those which can add value to the decision-making process, paying special attention to emerging matters of a multidisciplinary nature.
- Make the most of own and third-party operating experience for preventing incidents through the establishment of an efficient process for exchanging experiences and for analysing causes, and participate actively in the industry's international bodies through an exercise of peer comparison and evaluation, promoting a healthy emulation of the best.
- Extend the criteria related to radioactive waste and spent nuclear fuel treatment, storage and minimisation to the suppliers of goods and services through contractual clauses, quality assurance audits, certifications, training, operating procedures, supervision and teamwork at the facilities.
- Disseminate relevant and truthful information on the activities carried out and promote communication and dialogue with the various stakeholders.
- Cooperate with the competent authorities in the exercise of their supervision, regulation and public information functions, as guarantors of international commitments in countries where the facilities are located, and contribute to the improvement and optimisation of the regulatory framework.
- Maintain a long-term vision of radioactive waste and spent nuclear fuel treatment and minimisation through research, development and innovation, with participation and promotion in international forums and in organisations devoted to safety knowledge and improvement of radioactive waste and spent nuclear fuel management.
- Apply this Guideline as one of the criteria for selecting technologies in the case of new nuclear power plant projects.
The guiding principles and policy guidelines for the management of radioactive waste and spent fuel in Iberdrola Generación Nuclear are:
- Responsibility as a producer, from waste generation until it is transferred to ENRESA or the applicable disposal responsible entity. In the case of fuel, it becomes waste after irradiated in the reactor core; nevertheless Iberdrola Generación Nuclear takes responsibility for it once the fresh fuel is delivered on the sites.
- The radiation protection of public and workers during:
- The internal management.
- The transfer to other stages and, when appropriate,
- the decommissioning phase which goes from the time the plant is definitely shutdown until the site is transferred to ENRESA or the applicable entity.
- The traceability of waste and the operations of management of radioactive waste.
- Knowledge and control of the flow of waste and spent fuel and the evolution of their chemical, physical and radiological characteristics.
- As far as reasonably possible from a technical and economic standpoint:
- The reduction of generated radioactive waste and spent fuel to the minimum quantities and the radioactive waste management, applying the best available techniques and technologies depending on the type of reactor.
- The separation and recovery of the waste materials.
- The security of the interdependence of all phases of management.
Throughout the radioactive waste treatment processes and the spent fuel management, Iberdrola Generación Nuclear applies the criteria ALARA (as low as reasonably achievable) to maintain the individual doses, the number of exposed people and the likelihood of potential exposure at levels as low as reasonably achievable, taking into account economic and social factors. The management of radioactive waste also employs the cycle of continuous improvement, the key steps of which are: planning, implementation, evaluation, and management of:
- Preventive and corrective actions.
- Actions for improvement.
For new build, one of the criteria for technology selection will be the expected operational waste generation, which is predicted by design, taking into account both volumes and radioactivity involved.
These principles are applied to all Iberdrola Generación Nuclear facilities and all types of radioactive waste that can be generated, including those corresponding to plant dismantling when Iberdrola Generación Nuclear has the responsibility. The storage areas are aim to be operated following best practice to achieve the safest and most secure store for the entire length of the storage life until transfer to ENRESA or the waste management company.