Holistic Approach to Risk Management? Public Doses from the UK Nuclear Industry

1. Holistic Approach to Risk Management? Public Doses from the UK Nuclear Industry Bob Morley British Nuclear Group (Sellafield) Ltd Co-authors Gregg Butler Professor of Science in Sustainable Development and Dalton Nuclear Institute, University of Manchester Director: Integrated Decision Management Ltd and Grace McGlynn Director: Integrated Decision Management Ltd

2. Where to start? Well – how about looking at the total public dose detriment of the UK nuclear industry?? • The UK has 24 Magnox reactors at 10 sites, all of which will be shut by 2011, 14 AGR reactors at 6 sites and one PWR • It has two reprocessing plants at Sellafield and a fully functioning weapons industry • The highest critical group dose in the country is that from Sellafield, at 0.2mSv • The TOTAL annual public dose committed by the entire nuclear industry is …… 20 man sieverts

3. UK Nuclear Industry Public Detriment • 20 man sieverts implies 1.2 fatalities at some time in the future • It is, however, instructive to look at the level of individual risk at which this detriment will be delivered • Taking Sellafield as the dominant example, we looked at the dose distribution to individuals • Note that the highest critical group dose in the country (0.2mSv) means that NO member of the public is exposed to a risk of more than 1 in 100,000 per annum

4. UK Nuclear Industry Public Detriment Collective doses are predominantly delivered at very low levels, as illustrated by the typical Sellafield discharge scenario1 seen below The bulk of the dose is delivered between 0.0015 and 0.000015 microsieverts per annum, corresponding to an annual risk between one in ten billion and one in 1000 billion. 1. BNFL National Stakeholder Dialogue, Spent Fuel Management Options Working Group Report, Appendix 10.

5. UK Nuclear Industry Public Detriment • So – we have a dose of 20 man sieverts which converts to a detriment of 1.2 theoretical deaths suffered by individuals almost entirely at risk levels in the sub-1 in 10 billion range, and in no case above one in 100,000 • How do we weight this detriment into the overall scheme of nuclear operations? • …………………….and we need to – because……

6. UK Nuclear Industry Cleanup • The cleanup of the UK civil nuclear sites has been entrusted to the Nuclear Decommissioning Authority • A £70B public liability – huge incentive to achieve a balance and optimise spend • Public spend means it really is a choice between risk reduction, discharge abatement, health provision, education and transport schemes! • Budget limitations mean that money spent on ALARA of discharges will not be spent on hazard potential reductionSo balancing dose reduction with other factors is actually important

7. Comparisons and Problems • Comparisons of different detriments are possible using ‘lives’ or ‘money’ • There is great controversy on values used, and on whether this is ethical • BUT – if gross misuse of resources is possible, and greater detriments result, is it ethical NOT to do these comparisons?

8. Comparisons and Problems Optimisation of resources? Overall Societal Detriment

9. Dose comparisons in the EU (MARINA II) Collective dose rates on EU population from marine sources (2000): • Nuclear Industry – 14 man Sv/yr • NORM (oil/gas, phosphate industries) – 130 man Sv/yr • Natural radionuclides in marine environment – 17000 man Sv/yr • Natural background radiation, total environment – 844000 man Sv/yr

10. UK Nuclear Industry Cleanup • When we examine the cost of dose reduction, we find that spends of >£10M per statistical life are commonplace • Thus ‘site cleanup’ as practiced in the UK must almost certainly involve overall societal detriment • BUT – there is a methodology in the UK which does attempt to value collective dose. • It is, however, largely ignored, and in any case we believe it considerably overestimates the worth of public dose

11. How we balance dose – Dose Valuation – NRPB 1993 • Pitched at ‘a few, or a few tens, of microsieverts’ • Overall dose valuation recommended of £20K per man sievert • No specific consideration of very low doses and risks

12. Average UK natural Radiation dose Methodology – Dose Valuation >98% of all collective dose 1 microsievert 100 microsieverts NRPB - Rob, JD and Webb GAM,(1993) Values of unit Collective dose for use in the 1990s, Doc NRPB 4 75-80

13. Methodology – Dose Valuation The conventional view holds that once a dose is ‘trivial’ its value remains constant. We do not believe that this is is sensible. A function has been derived which continuously reduces the ‘value of spend to save a statistical life’ This ‘function’ method will apply a greater value to higher doses, and less value to lower doses caused to wider populations

14. Methodology – Dose Valuation >98% of all collective dose

15. Methodology – Dose Valuation • This method reduces the valuation of collective dose at the current doses, but actually increases the valuation at higher doses in the region of the highest critical groups • It may also make possible comparisons between worker and public doses: this balance is included in legislation and regulation but is never attempted in practice

16. Radiation Regulation in the UK • UK adopts Linear No Threshold and the ICRP recommendations of 0.06 overall risk of fatality per sievert of dose • This gives a risk of one in a million from 0.017mSv • Tolerability of Risk (HSE) considers the maximum tolerable risk to the public as 10-4 per annum with 10-3 for the workforce – these translate into dose limits of 1 and 20 mSv respectively • UK average natural background radiation is around 2.2mSv per annum

17. Radiation Regulation in the UK • Strong drive to reduce critical group dose – with requirement to reduce doses to As Low As Reasonably Practicable levels using Best Practical Means • De minimis levels (of 0.02mSv/a) are still present in policy but have never had any effect on the regulatory approach • In non-nuclear fields, UK policy values a statistical life at around £1M

18. Doses due to use of Natural Gas • Householders – average 4 uSv/yr • Commercial – average 19 uSv/yr • Critical Group – ‘few tens of’ uSv/yr • Critical group similar to annual radioactive discharges from Sellafield • Collective doses over 10 times greater than Sellafield • BUT is exempt from registration/authorisation!

19. Doses related to NHS activities • Public doses – persons unknowingly sitting next to patient on a bus – up to 300 uSv (more than maximum fully disclosed dose from all Sellafield operations) • Sewage treatment workers receive up to 238 uSv/yr • Public doses up to 180 uSv/yr from NHS sewage outfall • Construction of I-131 holding tanks in new London hospital – cost £0.5M, public dose reduction 150 uSv/yr, workers 600 uSv/yr. BPM questioned.

20. Already one London hospital has contracted for sampling and measurement of Iodine-131 in eel samples as part of an environmental impact assessment required by the regulator Closed for Business - - Gone Fishing

21. Medical vs Industry radioactivity – Public and Media attitudes • 110 GBq Plutonium from recycled scrap smelted into 50 te metal slag in steel works • Initial public concern re. low levels of environmental contamination due to ‘nuclear fuel rod’ smelting • Radioactive fingerprint of contaminated slag showed Plutonium to be medical grade • Public concern ceased to exist

22. Balancing ALARA spend in the UK • Even using the £25K per man sievert evaluation, the total annual dose detriment of the UK nuclear industry is £500K • In theory, this should have to pay for all the work on producing BPM and BPEO studies as well as the abatement measures introduced into the plants themselves

23. Balancing ALARA spend in the UK • In the UK we have entire conferences on current experience and best practice in BPEO/BPM/ALARA • These conferences alone, and the salaries of the people that attend them, cost far more than £500K – and that is before a single engineer has started building a single plant! • Grossly disproportionate spend is a way of life

24. The Sellafield Background • Atomic weapons programme • Development of Nuclear Power for peaceful means • Magnox reactor programme - reprocessing • AGR/LWR programme - Thorp • MOX fuel fabrication • Legacy clean-up - Perception of harm from routine operations remains, due to original weapons link, secrecy, media speculation

25. Alpha Discharges to Sea from Sellafield 1970-2004

26. Beta Discharges to Sea from Sellafield 1970-2004

27. The Unveiling of Information • Discharge reporting - 1970’s • Independent regulation and audit • ICRP 60 - Justification, Optimisation and Limitation • Routine Discharges and Doses from nuclear power industry very small - no evidence of harm 1950’s - 1970’s • Perception of harm - fuelled by media speculation - remained • Massive investments at Sellafield. Discharges and Doses reduced still further, 1980’s - 1990’s. • Perception of harm still remains • Further reductions - of little or no benefit to society? 2000’s

28. Socio - Political Influences • Concern from some neighboring EU States • “Health detriment” “Loss of confidence in fishing industry” • OSPAR, UNCLOS • UK National Discharges Strategy • Target 0.02mSv by 2020 • Application of BPM and ALARA • Note: Regulatory limits bear no relation to safe/unsafe boundary

29. Sellafield Implications • Still no Statutory Guidance on UK Discharge Strategy – so no ruling on de minimis • No OSPAR pronouncement on ‘close to zero’ • Decisions on Tc-99 and Sellafield Discharges show huge divergence from previous thoughts on proportionality • Still against the background that the use of natural gas gives a public radiation dose with the critical group comparable to the nuclear industry with a collective dose a factor of 10 more…………and is declared ‘no danger’

30. Sellafield - the Legacy Challenge • Reducing legacy risk is a key safety and environmental priority • Complex plant interactions • Need a clear and practical value for money framework for discharges • Huge potential ‘opportunity cost’ for national resources

31. Aerial Discharge from Retrieval and Processing Liquid Discharge from Retrieval and Processing Routine Liquid Discharge Restriction of Retrieval Process = Delay, Increased Cost + Increased Risk from Extended Storage in Ageing Facilities The Impact of Inappropriate Limits on Legacy Management

32. B38, Original Building, External View, 2000

33. B41 Compartment Internal View

34. What is the solution? • Develop “Value for Money” framework • Present facts in a balanced way • Cost - Doses - Risks In perspective • Understand stakeholder concerns - communicate • Government, Regulations and Operators work together to achieve common aim (Sellafield - reduce potential hazard by clean up of legacy wastes as efficiently and as soon as possible) • This will involve increases in discharges, but the risks to the public will remain imperceptibly small • Proportionate application of BPM - “sensible” spend to reduce risks

35. Current application of ‘Risk Based Regulation’ • Of course we’ve got methodologies – they’re called BPEO and BPM • The will adequately deal with the dilemmas posed • But they are not objective ! • And the result will be…….. • Current ballpark is several LETP's between 2007 and 2020. • Cost - up to £500M (capital only) • Extra waste generated (primary and secondary) - unquantified in most cases but very large.

36. But – improvements on the way?? • NDA will have to prioritise spend between many projects on 20 sites, balancing environmental, safety, cost factors and hazard reduction • It has been instrumental in developing and promoting a Hazard Potential measure, and is actively addressing prioritisation methodologies. • It really is motivated to be able to balance spending – and could usefully set itself the objective of balancing cases like this….

37. Increased ‘time at hazard potential’ Reduced Hazard Potential Increased Cost A C Reduced peak discharge B D Reduced overall discharge Install Abatement Plant Time Cost £M Discharges Hazard Indicator

38. Light at the end of the tunnel? • The insights from the Hazard Potential and Prioritisation work provide a good grounding in the concepts which will be required • An initiative would require a sophisticated process with extensive stakeholder involvement – but again experience is now available • Motivation, capability and the commitment of the organisations in key roles will be the key. • For the first time in the UK a structure is in place which can bring these elements together

39. Conclusions • The existing regulatory regime has given no real safeguard against disproportionate use of resources on the reduction of discharges • The development of a transparent methodology would give real advantages, and could be done • Risk-based dose valuation seems to offer a way forward, and would allow currently ignored factors such as workforce dose to enter the evaluation process • The ‘test case’ on conditioning delay is fundamental