Organization and responsibility

Figure 2.1 shows the responsibilities of various players involved in a waste characterization programme [3, 4].

The regulator oversees every step in the waste characterization programme. The producer of raw waste has to conduct characterization of the waste he produces. The treatment

operator must conduct quality control during the process. Finally, the disposal operator must see that the final waste package conforms to criteria for disposal.

Taking into account the particular activities involved in each step and in the whole life cycle can help fulfil all requirements in a more effective way. Each body has to obtain regulatory agreement/approval as well as agreement from the next body (operator or authority) to transfer the waste to its next life cycle phase. It is crucial that information about the waste (including its characterization results) from the generator to disposal operator is traceable and shared between bodies.

2.6.1. Responsibilities of the regulator/licensing authority

The regulator (licensing authority) has related responsibilities which begin prior to operation of a waste characterization facility and continue through final closure. These include:

⎯ Review of the Safety Analysis Report (SAR) and granting of the license.

⎯ Issuing license requirements, including waste acceptance criteria (or at least activity limits)

⎯ Quality audit

⎯ Independent verification of characterization accuracy and reliability

⎯ Radiological safety inspections

⎯ Technical inspections

⎯ License amendments and extensions, including review of SAR revisions

⎯ Characterization facility (e.g. laboratory) decommissioning and license termination 2.6.2. Responsibilities of the generator of the waste

The waste generator has ultimate responsibility for characterizing the wastes so that the Waste Acceptance Criteria can be met throughout the life cycle. In principle, the generator should be prepared to cover all costs of waste management including waste characterization.

The generator can design the whole life cycle, identify each waste transfer between various bodies, and collect the criteria and requirements that must be fulfilled when waste goes through each phase. In most cases, effective characterization can be done on the raw waste. To be able to use early life cycle waste characterization results in subsequent phases, the generator should set up an extensive quality control system with special attention given to preserving obtained data and its proper management in subsequent waste management steps.

Ideally, all players in this process will manage data in an equally effective and secure manner.

However, if the subsequent operator cannot handle his publication management system in a way that covers all needs during the waste management life cycle, it is ultimately the waste generator’s duty to collect and properly handle data until it is accepted by the disposal operating company.

The generator of the waste is responsible for the quality control of the waste. The quality control system shall include training, method development, qualification and documentation.

Preserving the characterization data for traceability and retrievability is another important responsibility for the generator.

2.6.3. Responsibilities of the treatment/conditioning/storage operator

Before treating and conditioning the waste, the conditioning operator has to qualify treatment and conditioning methods as well as methods for characterizing the process an end product. This activity has to be licensed by the regulator.

When the waste arrives at the conditioner, he has to inspect it and perform quality control checks to be sure the waste fulfils the waste acceptance criteria.

Quality control also has to be done during the treatment/conditioning process. If the waste packages will be stored after conditioning, they must be inspected to ensure that nothing has happened to the waste packages while under his control.

Continued preservation of the characterization data for traceability is another important consideration.

If secondary waste arises during the treatment/conditioning process, the operator is responsible for characterizing that waste too.

2.6.4. Responsibilities of the operator of the disposal facility (operating company, agency)

The operating company/agency is responsible for licensing the repository and operating it in accordance with license requirements. This includes performance assessment, quality system set up, safety analysis, and developing the waste acceptance criteria. This includes defining the waste acceptance criteria consistent with the operating license and regulatory requirements, and it includes verifying compliance with the waste acceptance criteria.

When the waste arrives at the repository, the operator must inspect the waste and check the enclosed publications to be sure that the waste fulfils the waste acceptance criteria.

It may well be that not every item of the waste acceptance criteria can be readily tested upon receipt (or tests may be very expensive). In those cases, the operator’s responsibility is to inspect, check and document those items that cannot be inspected during waste acceptance procedures at the repository site.

It is very important to keep all documentation of the disposed waste packages; the operating company/agency is responsible for carrying out this activity. Some requirements may be changed during the waste life cycle, and only proper documentation covered by a quality system enables later checking.

The repository operator/agency is also responsible for the post closure monitoring if necessary.

2.6.5. Independent verification

Independent verification is a crucial element of the overall waste characterization system, especially when responsibility for waste characterization is distributed between several bodies or organizations. Intensity (frequency) of independent verification depends on the phase of the life cycle and the particular regulatory and organizational regime. Generally, the early steps in the process need more frequent and intensive verification than the last step (disposal). Evidence of proper waste handling and characterization is necessary for all operators.

All phases during the waste life cycle are licensed and supervised by the regulator or authority, and independent verification helps to show regulator independence. The degree of independence that the testing body (laboratory) has will vary. There are practical problems due to the limited number of bodies skilled enough to carry out independent verification and

Generator (RW generation)

Operator (treatment)

Operator (storage, disposal) Characterization

of the primary waste

Quality control during conditioning

Control of conformity with waste acceptance

criteria

Regulator

Independent Verification

Waste Management Organization

FIG. 2.1. Diagram showing responsibilities of various players in a waste characterization programme.

prove independence from the operator. This can possibly be solved by implementing international cooperation.