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1 Record Keeping for Decommissioning and Waste Management Michele Laraia, former IAEA Unit Leader in Nuclear Decommissioning, consultant [email protected]
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Record Keeping for
Decommissioning and Waste
Management
Michele Laraia, former IAEA Unit Leader in Nuclear Decommissioning, consultant
2
Lecture outline
Records as part of a facility’s lifecycle
Records as a component of QA programme
Typical concerns in record keeping for D&D
IAEA guidance on D&D records (TRS # 411)
Long term issues on D&D records (TRS #467)
Record selection
The Record Management System
Specific aspects of RWM vs D&D record-keeping
Lessons Learned
Summary
NSRW/WSS
State
Design,
Construction &
Start-up Phase
Operating
PhaseShutdown
Pre-
decommissioning
Phase
Safe Enclosure
Preparation
Safe Enclosure
Period
Final
Decommissioning
Phase
Activities
Initial
Decommissioning
Plan
Ongoing
Decommissioning
Plan
Final
Decommissioning
Plan
Source Term
Removal/
Defuelling.
Waste
Conditioning
Site Preparation
Initial
Dismantling
Surveillance &
Maintenance
Final
Dismantling.
Final Survey &
License
termination
DECOMMISSIONING STAGES IN THE LIFETIME OF A
NUCLEAR FACILITY
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Decommissioning Staff
Project Manager
Quality Assurance
Budget/Finance
Administrative Support Services
Contracts/Procurement
Personnel
Technical Support Services
Training
Health Physics
Technical Records
Industrial Safety
Waste Management
Engineering Services
Public Relations
Non-Craft Support
Security/Fire Protection/Emergency Preparedness
Craft Support
Radiation protection technicians
Decontamination/dismantlement technicians
Rigging & Hoisting operators
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Elements of a Quality Assurance Programme
Typical QA Plan elements include:
Description of the QA Program
Personnel Training & Qualification
Quality Improvement
Documents & Records
Work Processes
Design
Procurement
Inspection & Acceptance Testing
Management Assessment
Independent Assessment
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Quality Assurance (QA) and Documentation
An appropriate QA Programme should be in place for use by the decommissioning team
The QA Programme should be formulated, in place and working before decommissioning operations are initiated
Description of the QA Programme should be included in the Decommissioning Plan
A strong QA Programme ensures compliance with regulatory body requirements for decommissioning and controls changes to work scope and methods
IAEA guidance documents are available to support the development of effective QA programs
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Quality Assurance (QA) and Documentation
(cont’d)
Acquisition and retention of records for / from the
decommissioning activities are a key component in
the QA programme
Records maintained should be available for future
decommissioning projects and as dictated by
national requirements
Records retention periods and storage locations
should be routinely reviewed to ensure that those
in use are appropriate
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Quality Assurance (QA) and Documentation
(cont’d)
When prolonged periods of safe enclosure are planned, it is
critical that accurate and complete information be maintained
on radioactive materials remaining at the facility for use in
the eventual final dismantling
For deferred dismantling, reports of on-going surveillance
and maintenance (S&M) results and the needs for future S&M
needs should be maintained and documented [Note: records
will be produced even in a passive safe enclosure
configuration]
Progress of decommissioning once underway should be
documented by the managing organization
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Quality Assurance (QA) and Documentation
(cont’d)
All radioactive material present at the beginning of
decommissioning must be should be properly
accounted for with the final disposal site
documented.
After each phase of the decommissioning, details
of the progress in the decommissioning process
should be reported to the regulatory authority –
this report might also detail other anomalies
observed during this same period.
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Quality Assurance (QA) and Documentation
(cont’d)
Upon completion of final dismantling, appropriate
records should be retained – both by the licensee
and the regulator
In accordance with the national framework, these
records will then be held and used to confirm
completion of the decommissioning process in
accord with the approved Decommissioning Plan.
Records maintained should be commensurate with
the complexity of the installation being
decommissioned and its associated hazards
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Some typical QA records
Determining the inventory and radionuclide
content of radioactive waste packages
Calibrating radiation field measurement
instruments
Inspecting and certifying lifting equipment
Inspecting sealed waste packages for compliance
with acceptance criteria at disposal site
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Some Typical Documentation Concerns
It is never too early to start compiling key
decommissioning records or to start planning for
eventual decommissioning
Loss of institutional control of records (and
institutional knowledge) critical to the
decommissioning process
Inability to access records due to changes in
records storage technology (long term issue)
Duplicate records should be maintained in at least
two separate secure locations , possibly using
different media
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Some Typical Documentation Concerns
(cont’d)
Definition of records that will constitute the project
data package and that will be available to both
operator and regulator staffs to document the
process used for successfully completing
decommissioning. Copies of this package should
be readily available for auditing
If it is not properly and adequately documented, it
cannot be expected to be performed properly by
others or even accepted by others as having been
performed
In decommissioning, records are actually used in
planning and implementation of activities
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TECHNICAL REPORT SERIES NO. 411 ( 2002)
Record Keeping for the Decommissioning of Nuclear
Facilities: Guidelines and Experience
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Integrated Management Information System
for a Decommissioning Project
Financial
Management
Records
Database
Waste
Management
Records
Database
Human
Resources
Records
Database
Documentation
Management
Records Database
Licensing &
Statutory
Records Database
Storage &
Maintenance
Records Database
Safety
Management
Records
Database
NSRW/WSS
A SET OF DECOMMISSIONING-
ORIENTED RECORDS SHOULD BE
DEVELOPED AND MAINTAINED
DURING PLANT CONSTRUCTION AND
OPERATION EVEN BEFORE
PERMANENT SHUTDOWN
NSRW/WSS
ACCORDING TO IAEA GUIDANCE,
DECOMMISSIONING-ORIENTED
RECORDS SHOULD BE A SUB-SET OF
OPERATIONAL RECORDS (i.e.
READILY EXTRACTED FROM THOSE
RECORDS) . “FLAGGING “ RECORDS
FOR DECOM PURPOSES SEEMS A
GOOD APPROACH
NSRW/WSS
IN MOST CASES , IT WOULD BE
WORTH INVESTING IN NEW
TECHNOLOGIES (e.g. CD-ROMs) FOR
LONG TERM KEEPING OF RECORDS.
HOWEVER, RELYING ON
TRADITIONAL MEDIA (e.g.
PHOTOCOPIES) WOULD BE
NORMALLY REQUIRED AS A
BACKUP
NSRW/WSS
DETAIL PROCEDURES AND TRAINING
ARE REQUIRED FOR RECORDS
MANAGERS (E.G.THOSE INPUTING
DATA AND THOSE MAINTAINING THE
SYSTEM)
NSRW/WSS
A RECORDS MANAGEMENT UNIT IS
PROBABLY REQUIRED EVEN FOR A
SMALL DECOMMISSIONING PROJECT
NSRW/WSS
RECORDS GENERATED IN THE
COURSE OF DECOMMISSIONING
SHOULD BE INTEGRATED WITH
EXISTING RECORDS
NSRW/WSS
RECORDS AVAILABILITY (LOCATION,
ACCESS, READABILITY,
MODIFICATIONS, SECURITY,
ENVIRONMENTAL PROTECTION)
SHOULD BE ENSURED AT ALL TIMES.
PERIODICAL TRAINING AND
AUDITING FUNCTIONS SHOULD BE IN
PLACE
NSRW/WSS
TYPICAL ISSUES IN RECORD
KEEPING MAY INCLUDE: AS-BUILT
DRAWINGS; UNCONTROLLED
MODIFICATIONS; LOSS OF RECORDS;
UNRECORDED INCIDENTS e.g.
SPILLS; DETERIORATION;
SOFTWARE READIBILITY
NSRW/WSS
TOP LEVEL DECOM PROJECT
MANAGEMENT WILL DECIDE ON
IDENTIFICATION OF AND ACCESS TO
DECOMMISSIONING RECORDS .
RECORDS NOT IMPORTANT TO
DECOMMISSIONING WILL BE
DISCARDED.
NSRW/WSS
POST-DECOM RECORDS INCLUDE:
DISCHARGES TO THE ENVIRONMENT; WASTE
GENERATION AND FATE; OCCUPATIONAL
EXPOSURES; FINAL SURVEYS ETC.
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Advantages and Disadvantages of Relative Storage Media
Hard Copy
ADVANTAGES
Original masters held. Difficult to
alter or modify. Paper and copying
mechanisms available for archive
period. Legally acceptable.
DISADVANTAGES
Controlled environment required.
Large volume. Damage due to
handling. Cumbersome copying.
Easily lost or misfiled.
Microfilm/Microfiche Difficult to alter or modify. Easily
duplicated. Compact storage.
Legally acceptable.
Controlled environment required.
Large volume. Damage due to
handling. Cumbersome procedures
for producing hard copy. Easily
lost or misfiled
Magnetic Tape Compact easy storage. Tape easily
duplicated with no deterioration of
data. Accessible. Can be updated.
Stored images can easily be
altered. Controlled environment
required. Damage due to handling
and magnetic erasure. Hard copy
requires to be scanned to tape.
Legality unclear.
Optical Disc Cannot be erased or altered.
Compact storage. Easy remote
access to data. Few environmental
controls. Duplication with no
deterioration to data.
Hard copy requires to be scanned
to tape then disc. Legality unclear.
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Long Term Issues (see TRS # 467, 2008)
Even a period of 10 year can pose a challenge to
the safe and efficient use of records, let alone 100
years (UK’s Magnox D&D strategy) or 300-500 year
duration of waste disposal institutional control
Legibility (media preservation)
Understanding technical meaning (language &
jargon)
Maintaining the skills (in non-nuclear countries?;
international networks)
Keeping records “living” (e.g. to incorporate
regulatory changes, growing experience in
decommissioning, technological progress,
economics, funding etc)
Move from “passive preservation” to “active
management” of records
Design and Operational Data Required for
Decommissioning
Original design and modifications to the plant are
kept in recoverable records
Facility operational records are maintained:
dose rate surveys, contamination maps etc
waste management records
unplanned events and clean up records
Failure to manage records at this stage has
significant implications on costs, programme
delays and safety/environmental issues
Selection of Decommissioning Records
Decommissioning strategy can dictate the record
keeping requirements:
immediate dismantling requires that complete,
up-to-date and validated records are available
(experience of staff is crucial)
deferred dismantling requires the establishment
of a long-term record keeping process to
transfer knowledge to the dismantling team of
the state of the facility
deferred dismantling imposes long term storage
of information in a suitable format
Record keeping During a Facility’s Life-Cycle -
Initial
Design, construction and modification data:
site characterization, geological and baseline
radiological data
as-built drawings and technical descriptions
including design calculations, procurement
records identifying materials used, engineering
codes and equipment specifications
construction photographs
material samples, quality certification and
facility design inventory
safety cases, environmental impact statement,
licensing documentation and operation
requirements and preliminary decommissioning
plan
Use of EUCLID software at A1 NPP D&D,
Slovakia
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Use of laser scanner at A1 NPP D&D, Slovakia
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Record keeping During a Facility’s Life-Cycle -
Operating and Post Shutdown
Operating, shutdown and post-shutdown data:
licensing requirements, safety reports,
operating and maintenance records
technical manuals, log books
environmental releases, site survey reports,
abnormal occurrence reports
design change and updated drawings
hazard material inventory, neutron fluxes,
radiation sources, laboratory test reports
waste management records
etc...
Process of selecting decommissioning
records/1
Establish the records management system:
initiate during design and construction
(preferred)
integrated facility information system collecting
data from a variety of sources and in several
forms
index of records for retrieval and manipulation
of data
transparent system
hard copy or electronic depending on
facility/organisation in questions
Process of selecting decommissioning
records/2
Select the decommissioning
records by reviewing existing
records and their relevance:
initial decommissioning plan
statutory and regulatory
requirements
engineering and safety
support
defence against future
litigation
Selection factors:
decommissioning strategy
availability of information
availability of resources
legal requirements
characteristics of the facility
radiological characterisation
records
Process of selecting decommissioning
records/3
Auditing the record management system:
carried out periodically
ensures records management system is
effective and up to date
auditing team can comprise;
decommissioning specialists
information specialists
facility operations staff
Before shutdown the documents should be
selected that form the records management
system
Process of selecting decommissioning
records/4
Documentation prepared for decommissioning is
based around the Detailed Decommissioning
Plans;
description of methods to protect
estimate of wastes and waste management
radiological and material inventory (including
non-routine areas)
unusual occurrences
material specifications and coupons
legal and regulatory requirements
Retention of Decommissioning Records
Retention of records depends on regulations of
actual service life of the equipment
Review of records for retention should be carried
out periodically and decisions made for further
retention or discarding
New records should be added when generated
during decommissioning if considered important
for retention
When decommissioning is complete the records
need to be evaluated for caretaker requirements
and regulatory changes
Records usually owned by regulatory body or
similar after decommissioning is completed
Records Management Systems (RMS)
An RMS is essential for the collection, cataloguing,
maintenance and dissemination of records
Operating period could be decades long
Needs to be established in written instructions,
procedures or plans
Need to support the later decommissioning work
Several media forms
RMS - Requirements and responsibilities
Responsible organisation functions include:
deciding which records to be incorporated
controls access to records
provides input and output for the RMS
Group managing RMS responsibilities:
establishing requirements for managing records
managing the information processes
maintaining the RMS
RMS - further aspects
Existing staff used as much as possible to identify
and verify records to be input
Each record to be legible, official, accurate,
complete and auditable
Indexing of records is essential for retrievability of
information
Retention periods must be reviewed and updated
(including classification)
Level of access control must be established
including modifications, revision and archiving
National archive requirements
RMS - Storage media
Paper copy (hard copy) is the most common and
has a lifetime of a few decades depending on
controlled environment
Microfilm or microfiche systems last for 100 to 200
years and provide small storage capacity
compared to paper
Magnetic tape or disc has a lifetime of 5 to 10 years
and have large storage capacity but require high
maintenance
Optical disc, compact disc or digital video disk
allows comprehensive storage and indexing but
requires controlled environment and transfer of
older records to electronic forms
Other options for indexing and emerging
technologies
Management of New Records
Many interactions between organisations involved
in decommissioning that must be managed and the
information cross flow
Use of management tools for records
management:
USDoE, System of Tracking Remediation,
Exposure, Activities and Materials (STREAM)
European Commission , EC DB TOOL and
COST
Germany, Greifswald, Project Information
System
Decommissioning Reports, particularly the Final
Decommissioning Report
Lessons learned/1
Lack of records;
Lack of contamination records at GPU’s Saxton
Nuclear Experimental Corp meant the removal
of wastes from an underground steam
discharge tunnel adding to the $17million extra
costs for the project
structural drawings of a workshop at
Trawsfynydd NPP were unavailable and hence
costly core samples had to be taken to
determine loading requirements
Old military buildings at Harwell unearthed a
contaminated pipe which required removal at
extra cost
Lessons learned/2
Unchecked/inaccurate records;
inaccurate drawings meant that the grinding of
pressure tube welds at the Niederaichbach NPP
were not cut as planned and a second cut had to
be performed
live wires were identified when cutting through
control panels at the JANUS reactor. The
emergency power circuits were incorrectly
routed through the panels
the identification of an asbestos layer on the
Vandellos 1 site was found to have been
installed during a repair operation during the
operating period of the plant and was not
recorded on site documentation
Lessons learned/3
Wrong interpretation of records;
graphite selling of the thermal column at the
IRT-M research reactor resulted in a large
monolithic graphite mass requiring dismantling
and a new plan devised
poorly defined drawings at the Korea research
reactors meant that additional measurements
had to undertaken to determine the structural
suitability of the reactor hall for the temporary
storage of radioactive waste
Specific aspects of RWM record-keeping
Long to very long time frame
Loss of site institutional control
Responsibilities: from operator to national /
govt authorities
From national to international archiving
Very long term (geological disposal): lack
of records > reliance on passive protection
and site marks
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Record-keeping for Radioactive Waste
Management and Disposal :Reference IAEA
docs
Maintenance of records for radioactive waste
disposal, IAEA-TECDOC-1097, 1999
Waste inventory record keeping systems (WIRKS)
for the management and disposal of radioactive
waste, IAEA-TECDOC-1222, 2001
Records for radioactive waste management up to
repository closure, IAEA-TECDOC-1398, 2004
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The most recent , comprehensive book on
Nuclear Decommissioning
Nuclear decommissioning: Planning,
execution and international experience
Woodhead Publishing Series in Energy No. 36,
ISBN 0 85709 115 8
ISBN-13: 978 0 85709 115 4
February 2012
856 pages hardback €250.00
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Summary
There will be significant financial consequences
and safety concerns if there is inadequate
documentation to support decom and WM
The main sources of decommissioning records are
the records of design, construction, modification,
operation and shutdown of a facility
Planning for decommissioning should be
considered during design and operation, as by
doing so the information will be readily available
and transferable when needed
A Record Management System (RMS) is desirable
to facilitate safe and efficient decommissioning
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Summary ( cont’d)
Throughout the life of a facility the records archive should be frequently and independently audited, with decommissioning as a primary focus
Not all records in use during operation will be relevant to decommissioning. Selection should be based on pre-determined criteria.
It is important that the information transferred to future users be usable. Keeping control of records ( and institutional knowledge) is necessary for the whole decommissioning process
Redundancy, diversity and media selection are essential to ensure availability of an RMS at all times.
