Orientering om evaluering af Danmarks system til håndtering af radioaktivt affald, fra sundhedsministeren

Til orientering fremsendes vedlagt: “Integrated Review Service For Radioactive Waste
And Spent Fuel Management, Decommissioning And Remediation (ARTEMIS), Mission
To Denmark.”.
Evalueringsrapporten gennemgår det danske system for håndtering af radioaktivt
affald og indfrier Danmarks forpligtelse efter EU-direktiv 2011/70/Euratom, artikel 14
(3), til at foretage en selvevaluering af det nationale system for håndtering af
radioaktivt affald med efterfølgende international evaluering mindst hvert 10. år.
Rapporten er udarbejdet af Det Internationale Atomenergi Agentur (IAEA) på
baggrund af en ekspertgruppes besøg i Danmark den 1.-9. maj 2022.
Det fremgår af rapporten, at ”In summary, the ARTEMIS Review Team considers that
the Danish system for management of spent fuel and radioactive waste has a well-
developed infrastructure, provides robustness, effectiveness and safety now and in
the future. Denmark has demonstrated the commitment and ability to enhance the
safety of radioactive waste and spent fuel management”.
IAEA konkluderer således, at det danske system til håndtering af radioaktivt affald
samlet set er velfungerende og lever op til internationale standarder for sikkerhed.
Rapporten indeholder samtidig nogle konkrete anbefalinger og forslag til Danmark
om yderligere optimering af området fremover. Det gælder bl.a. i forhold til visse
praktiske foranstaltninger inden for myndighedsudøvelse og affaldshåndtering.
Sundhedsministeriet og Uddannelses- og Forskningsministeriet vil gå i dialog med
relevante myndigheder mv. om den nærmere opfølgning frem mod en IAEA-
statusevaluering om 3-5 år.
Med venlig hilsen
Jesper Petersen / Magnus Heunicke
Sundhedsudvalget
Uddannelses- og Forskningsudvalget
Holbergsgade 6
DK-1057 København K
T +45 7226 9000
F +45 7226 9001
M sum@sum.dk
W sum.dk
Dato: 03-10-2022
Enhed: FOPS
Sagsbeh.: DEPCEB
Sagsnr.: 2205835
Dok. nr.:
. / .
Offentligt
SUU Alm.del - Bilag 2
Sundhedsudvalget 2022-23


IAEA-NS-ARTEMIS
ORIGINAL: English
INTEGRATED REVIEW SERVICE
FOR RADIOACTIVE WASTE AND
SPENT FUEL MANAGEMENT,
DECOMMISSIONING AND
REMEDIATION (ARTEMIS)
MISSION
TO
DENMARK
Roskilde, Denmark
1-9 May 2022
DEPARTMENT OF NUCLEAR SAFETY AND SECURITY
DEPARTMENT OF NUCLEAR ENERGY
Offentligt
SUU Alm.del - Bilag 2
Sundhedsudvalget 2022-23
ii
REPORT OF THE
INTEGRATED REVIEW SERVICE FOR RADIOACTIVE WASTE AND
SPENT FUEL MANAGEMENT, DECOMMISSIONING AND
REMEDIATION (ARTEMIS)
MISSION
TO
DENMARK
iii
REPORT OF THE
INTEGRATED REVIEW SERVICE FOR RADIOACTIVE WASTE AND
SPENT FUEL MANAGEMENT, DECOMMISSIONING AND
REMEDIATION (ARTEMIS) MISSION
TO
DENMARK
Mission dates: 1-9 May 2022
Location: Roskilde, Denmark
Organized by: IAEA
ARTEMIS REVIEW TEAM
Mr Stefan Theis ARTEMIS Team Leader (Switzerland)
Mr Matthias Hackstein Reviewer (Germany)
Mr Lamberto Matteocci Reviewer (Italy)
Mr Darius Lukauskas Reviewer (Lithuania)
Mr Andrey Guskov IAEA Team Coordinator
Ms Merle Lust IAEA Deputy Team Coordinator
Ms Kristina Nussbaum IAEA Admin. Assistant
IAEA-2022
iv
The number of recommendations, suggestions and good practices is in no way a measure
of the status of the national infrastructure for nuclear and radiation safety. Comparisons
of such numbers between ARTEMIS reports from different countries should not be
attempted.
v
CONTENTS
EXECUTIVE SUMMARY..............................................................................................1
I. INTRODUCTION...................................................................................................3
II. OBJECTIVE AND SCOPE....................................................................................4
III. BASIS FOR THE REVIEW...................................................................................5
1. NATIONAL POLICY AND FRAMEWORK FOR RADIOACTIVE WASTE
AND SPENT FUEL MANAGEMENT .................................................................7
1.1. NATIONAL POLICY....................................................................................7
1.2. LEGAL, REGULATORY AND ORGANISATIONAL FRAMEWORK
(PARTLY REFERRING TO IRRS) ............................................................9
2. NATIONAL STRATEGY FOR RADIOACTIVE WASTE AND SPENT
FUEL MANAGEMENT.......................................................................................14
2.1. SCOPE...........................................................................................................14
2.2. MILESTONES AND TIMEFRAMES .......................................................16
2.3. PROGRESS INDICATORS........................................................................18
3. INVENTORY OF SPENT FUEL AND RADIOACTIVE WASTE .................20
4. CONCEPTS, PLANS AND TECHNICAL SOLUTIONS FOR SPENT FUEL
AND RADIOACTIVE WASTE MANAGEMENT............................................23
5. SAFETY CASE AND SAFETY ASSESSMENT OF RADIOACTIVE WASTE
AND SPENT FUEL MANAGEMENT ACTIVITIES AND FACILITIES.....27
6. COST ESTIMATES AND FINANCING OF RADIOACTIVE WASTE AND
SPENT FUEL MANAGEMENT.........................................................................30
7. CAPACITY BUILDING FOR RADIOACTIVE WASTE AND SPENT FUEL
MANAGEMENT – EXPERTISE, TRAINING AND SKILLS ........................32
APPENDIX A: TERMS OF REFERENCE.................................................................34
APPENDIX B: MISSION PROGRAMME .................................................................38
APPENDIX C: RECOMMENDATIONS AND SUGGESTIONS.............................39
APPENDIX D: LIST OF ACRONYMS USED IN THE TEXT ................................41
APPENDIX E: IAEA REFERENCE MATERIAL USED FOR THE REVIEW ....42
1
EXECUTIVE SUMMARY
On 14 December 2016, the Resident Representative of Denmark to the IAEA, requested the
International Atomic Energy Agency (IAEA) to organize and carry out an Integrated Review
Service for Radioactive Waste and Spent Fuel, Decommissioning and Remediation
(ARTEMIS) review.
The objective of the ARTEMIS Peer Review Service was to provide independent expert opinion
and advice on the radioactive waste and spent nuclear fuel management programme in
Denmark, based on the relevant IAEA Safety Standards and proven international practice and
experiences, following the guidelines of the ARTEMIS review service, requested in line with
the obligations under Article 14.3 of the Council Directive 2011/70/Euratom of 19 July 2011
establishing a Community Framework for the Responsible and Safe Management of Spent Fuel
and Radioactive Waste.
The review was organized by the Department of Nuclear Safety and Security and the
Department of Nuclear Energy, and performed by a team of four senior international experts in
the field of management of spent fuel and radioactive waste, supported by IAEA staff providing
coordination and administrative assistance.
Preparatory meeting was held in December 2021. Review of the Advanced Reference Material
(ARM) was carried out in the first quarter of 2022. The ARTEMIS review mission was
conducted from 1 to 9 May 2022.
Denmark has no nuclear power plants but manages waste from the ongoing decommissioning
of six nuclear facilities at Risø, including three research reactors, a hot cells facility, a fuel
fabrication plant, and a waste treatment plant. The decommissioning waste is treated and stored
by Danish Decommissioning (DD), a state-owned company managing also radioactive waste
from the use of radiation sources in medicine, industry and research in Denmark.
During the ARTEMIS mission the team comprised of senior international experts in the field
of radioactive waste management and decommissioning from the Germany, Italy, Lithuania
and Switzerland held discussions with the representatives of the Danish Ministry of Health,
Danish Health Authority (DHA), the Danish Ministry of Higher Education and Science, the
Danish Agency for Higher Education and Science, the Danish Emergency Management Agency
(DEMA), and DD.
The ARTEMIS Review Team very much appreciated additional documentation presented by
the Danish counterparts to address the expert’s questions during the mission, continuous and
open manner of discussions and intention to use whatever comment from the Team as input for
the process of continuous improvement of waste management in Denmark.
Based on these exchanges, covering subjects such as the Danish national policy for waste, the
waste inventory, and safety assessments, as well as a visit to the facilities at Risø site, the
ARTEMIS Review Team noted that Denmark has developed and implemented a robust and
well-functioning system for maintaining and further enhancing the safety and effectiveness of
spent fuel and radioactive waste management. However, the Team prepared recommendations
(R) and suggestions (S) into a draft report which was handed over at the official exit meeting.
Parliamentary Resolution B90/2018 (B90) is considered by the Team as a key document for
translating political and strategic decisions into an executable national waste management
program.
Uncertainties for management options for some waste types due to pending decisions and the
financing of associated treatment steps should be eliminated in due time.
2
With the aim of introducing all radioactive material without intended further use into the
radioactive waste management system, DD should be obliged to accept any notified radioactive
material including from non regulated use.
The Team has identified specific areas where licensees could receive even better support for
their undertakings, if the regulatory body would specify all their requirements for waste
treatment, storage and disposal facilities during their entire life-time in guidances.
The key implementing organization for the National Programme is DD, which has already
established a strategy (described as DD strategy hereafter). This was presented during the
mission and could serve as a master plan for the implementation of the National Programme.
To serve this purpose from the DD strategy the implementation plan for disposal can be
developed.
To ensure the timely execution of the National Programme and the provision of necessary
services and products the Team recommends corresponding control and assurance procedures.
Optimization in radiation protection, especially minimization of professional exposure can be
supported by adjusting operations foreseen during waste transfer activities and establishing
waste acceptance criteria (WAC) for disposal as soon as possible.
Sustainable support for the financing of waste management activities is and will be based on
open communication and regular update of the cost estimations on the best available
information basis.
A long term human resources and competence management plan will support the strategic
decision by DD to become and maintain the status of the national competence center for waste
management even during the foreseeable transition phases of the future.
In summary, the ARTEMIS Review Team considers that the Danish system for management
of spent fuel and radioactive waste has a well-developed infrastructure, provides robustness,
effectiveness and safety now and in the future. Denmark has demonstrated the commitment and
ability to enhance the safety of radioactive waste and spent fuel management. In this respect,
the ARTEMIS Review Team is of the opinion that the benefits of carrying out an ARTEMIS
follow-up mission could be taken into consideration as an addition to the already significant
efforts being made in this area.
3
I. INTRODUCTION
At the request the Resident Representative of Denmark to the IAEA, the International Atomic
Energy Agency organized an ARTEMIS review of the Danish Policy on Spent Fuel and
Radioactive Waste Management. The objective of the ARTEMIS Peer Review Service is to
provide independent expert opinion and advice on radioactive waste and spent nuclear fuel
management, decommissioning and remediation, based upon the IAEA Safety Standards and
technical guidance, as well as international good practice. Denmark requested this review to
fulfil its obligations under Article 14.3 of the Council Directive 2011/70/Euratom of 19 July
2011 establishing a Community Framework for the Responsible and Safe Management of Spent
Fuel and Radioactive Waste (“Waste Directive”).
The review was performed by a team of four senior international experts in the field of
decommissioning and radioactive waste and spent fuel management, from multiple IAEA
Member States, with IAEA staff providing coordination and administrative support.
Subsequent to a preparatory meeting in December 2021, and the receipt and review of
Advanced Reference Material in February 2022, in May 2022 the ARTEMIS Review Team
evaluated the Danish strategy for the management of all types of radioactive waste and spent
fuel, including aspects of decommissioning.
4
II. OBJECTIVE AND SCOPE
The ARTEMIS review provided an independent international evaluation of the Radioactive
Waste and Spent Fuel Management Strategy of Denmark, requested in line with the obligations
of the Waste Directive.
The ARTEMIS review, organized by the Department of Nuclear Safety and Security and the
Department of Nuclear Energy of the IAEA, performed against the relevant IAEA Safety
Standards and proven international practice and experiences with the combined expertise of the
international peer review team selected by the IAEA.
The ARTEMIS review assessed, as requested by the Waste Directive, the overall strategy for
the management of all types of radioactive waste in Denmark.
5
III. BASIS FOR THE REVIEW
A) PREPARATORY WORK AND IAEA REVIEW TEAM
At the request of the Government of Denmark, a preparatory meeting for the ARTEMIS Review
mission, was conducted on 14 December 2021 online. The preparatory meeting was carried out
by the appointed Team Leader Mr Stefan Theis, the IAEA coordinator and deputy coordinator
Mr Andrey Guskov and Ms Merle Lust, and the team of National Counterparts led by Mr David
Ulfbeck from the DHA, Radiation Protection, with participation of representatives of the
Ministry of Health, Ministry of Higher Education of Science, DD and Danish Emergency
Management Agency.
The ARTEMIS mission preparatory team had discussions regarding:
• the Terms of Reference for the ARTEMIS review of the Danish strategy to fulfil
obligations from article 14(3) of the Waste Directive; and
• the relevant detailed aspects for organization and conduct of the review.
IAEA staff presented the ARTEMIS principles, process and methodology. This was followed
by a discussion on the work plan for the implementation of the ARTEMIS review in Denmark
in May 2022.
Mr David Ulfbeck was appointed as the National Counterparts for the ARTEMIS mission and
designated IAEA point of contact.
Denmark provided IAEA with the ARM for the review on 15 February 2022.
B) REFERENCES FOR THE REVIEW
The articles of the Waste Directive, the draft guidelines for the ARTEMIS review service and
the responses to the self-assessment questionnaire were used as the basis for the review together
with the ARM and materials presented during the mission and associated discussions. The
complete list of IAEA publications used as the basis for this review is provided in Appendix E.
C) CONDUCT OF THE REVIEW
The initial Review Team meeting took place on Sunday, 1 May 2022 in Roskilde, directed by
the ARTEMIS Team Leader Mr Stefan Theis, the ARTEMIS Team Coordinator Mr Andrey
Guskov and the Deputy Team Coordinator, Ms MerleLust.
The ARTEMIS entrance meeting was held on Monday, 2 May 2022, with the participation of
the DD, the DHA, Radiation Protection, the DEMA, the Ministry of Health and Ministry of
Higher Education and Science senior management and staff. Opening remarks were made by
Mr Andreas Jull Sørensen (Ministry of Health), Mr Kristoffer Brix Berthelsen (Ministry of
Higher Education and Science), Mr David Ulfbeck (DHA, Radiation Protection), Ms Mette
Øhlenschlæger (DHA, Radiation Protection), Mr Ole Kastbjerg Nielsen (DD) and Mr Stefan
Theis, ARTEMIS Team Leader.
During the ARTEMIS mission, a review was conducted for all review topics within the agreed
scope with the objective of providing Danish authorities with recommendations and suggestions
for improvement and, where appropriate, identifying good practice.
The ARTEMIS Review Team performed its review according to the mission programme given
in Appendix B.
6
The ARTEMIS Exit Meeting was held on Monday, 9 May 2022. Opening remarks were made
by Mr Kristoffer Brix Bertelsen, Senior Adviser, Ministry of Higher Education and Science. A
presentation of the results of the Review Mission was given by the ARTEMIS Team Leader Mr
Stefan Theis. Closing remarks were made on behalf of the IAEA by Mr Peter Johnston, Director
of the Division of Radiation, Transport and Waste Safety, Department of Nuclear Safety and
Security.
An IAEA press release was issued.
7
1. NATIONAL POLICY AND FRAMEWORK FOR RADIOACTIVE WASTE AND
SPENT FUEL MANAGEMENT
1.1. NATIONAL POLICY
Danish position
According to the ARM, the Government of Denmark established the national policy for
decommissioning and the management of different classes of radioactive waste through the
adoption of Parliamentary Resolution B48/2003 (B48) on the Decommissioning of Nuclear
Facilities at Risø Research Centre and Parliamentary Resolution B90/2018 (B90) on a Long-
Term Solution for Denmark’s radioactive waste, based upon proposals of the Ministry of
Science, Technology and Development (current name: Ministry of Higher Education and
Science). Fundamental principles for radiation protection and safety, including protection of
people and the environment, protection outside of national borders, protection of future
generations are mentioned as important conditions for the parliamentary resolution. In addition,
elements of the policy are established in Parliamentary Resolution B103/1985, Radiation
Protection Act 23/2018, Nuclear Installations Act 170/1962, Executive Orders 669/2019 and
670/2019, Circulars No. 9654/2020 and No. 9261/2022.
The national policy must be implemented observing the fundamental principles for radiation
protection and safety that are embedded in the Radiation Protection Act, which imply that
exposure to radiation must be justified, to be as low as reasonably achievable and below
specified limits, while placing primary responsibility on licensees using ionizing radiations.
According to the Radiation Protection Act, the fundamental safety principles apply to any use
of radiation or radioactive source, including the management of radioactive waste. Also, policy
must be implemented observing the specific waste management principles: ultimate
responsibility of the licensees, graded approach, due consideration of interdependencies among
waste management phases, waste minimization, financial compensation, avoiding unjustified
burden to future generations as well as ensuring transparency and public participation.
B48 formed the basis for the current policy on decommissioning and management of
radioactive waste assigning to the state owned undertaking DD the responsibility for
decommissioning of nuclear facilities at Risø Research Centre in order to release the site for
unrestricted use within the timeline of up to 20 years (2003-2023).
B90 aims to implement a national long-term solution for Denmark’s radioactive waste. B90
resolution specifies the objectives for management and disposal of radioactive waste streams
and assigns DD as a national radioactive waste management organisation. According to B90
the solution for the radioactive waste management is identified in the continued safe storage in
a dedicated storage facility until the geological disposal in a facility to be commissioned at the
latest by 2073. A short-term goal is therefore represented by the construction of a new
radioactive waste storage facility. In medium-term, geological studies are planned at a depth of
up to 500 m in order to identify suitable conditions for a deep geological disposal facility. B90
specifies that recommended locations for deep geological disposal facility can be identified
after an analysis, considering geological, physical as well as socio-economic factors and, in
particular, on the basis of a voluntary participation of local municipalities/communities. In
parallel, the exploration of possibilities for an international solution for the disposal of long-
lived radioactive waste will be pursued as established in B90, until an act on the planning of
deep geological disposal facility is passed.
8
According to B90, also a disposal solution of the NORM waste could be considered, which is
currently stored in waste producers’ facilities. The issue of management and disposal of NORM
in a common Nordic disposal facility was discussed by members of the Nordic Council. On 11
November 2021 the Nordic Council adopted Recommendation 36/2021 asking Nordic Council
of Ministers to consider the identification of suitable sites for one or more joint Nordic disposal
facilities for NORM waste, identification and remediation of legal and regulatory obstacles for
import/export of NORM between member states, initiation of establishment of the joint
financing of one or more NORM disposal facilities and establishments of procedures to ensure
the safe management and handling of NORM transportation between member states. However,
the Nordic Council of Ministers decided not to accommodate Recommendation 36/2021.
Consequently, the handling and disposal of NORM will be considered on a national level.
However, the option to reach an agreement on a common solution on disposal of NORM waste
on bilateral base remains.
The ARTEMIS Review Team is also informed that this specific issue of NORM has been
discussed in the IRRS mission to Denmark 2021 and addressed in the Recommendation R3 of
the IRRS Report.
The ARTEMIS Review Team has also been informed that the Ministry of Health has taken
initiative to setup a cross-sectoral working group intended to include authorities, municipalities
and NORM industry operators, with the purpose of defining overall policy goals for NORM
waste management in order to elaborate a proposal for a new parliamentary resolution. The
primary aim is to ensure safe pre-disposal management and disposal of NORM waste
originating from industrial off-shore oil and gas activities.
ARTEMIS observation
The ARTEMIS Review Team noted that the Danish policy established by B48, B90 and
B103/1985, Radiation Protection Act 23/2018, Nuclear Installations Act 170/1962, Executive
Orders 669/2019 and 670/2019, Circular No. 9654/2020 and No. 9261/2022 contains all
elements of the policy in a manner consistent with the recommendations of IAEA Safety
Standards.
The ARTEMIS Review Team also noted that the management of NORM waste is not dealt with
in the existing policy documents, although B90 stipulates that “final repository could also be
considered for housing NORM waste”.
This issue has been identified in the IRRS mission to Denmark 2021 and addressed in the
Recommendation R3 of the IRRS Report. Hence, the findings of ARTEMIS Review Team will
be fully addressed once the above mentioned IRRS mission recommendation will be
implemented.
9
1.2. LEGAL, REGULATORY AND ORGANISATIONAL FRAMEWORK (PARTLY
REFERRING TO IRRS)
Danish position
As Denmark is a member of the European Union and the European Atomic Energy Community
the law and regulations have been amended in order to transpose into the national regulatory
framework the Euratom Directives. EU regulations are directly applicable in Denmark.
Within the Danish national framework, in addition to The Constitution, the Danish legal
hierarchy comprises:
• Acts (and Consolidation Acts) establishing authorities, obligations, prohibitions and
framework of action. Acts are typically proposed (bills) by ministers, considered and
eventually passed by Parliament. Consolidation Acts, adopted by the relevant minister,
are administrative summaries of original acts and their subsequent amendments;
• Executive Orders setting administrative regulations based on one or more (consolidation)
acts and issued either by a ministry or an appointed authority. An executive order may
contain rules that are binding on both citizens and authorities;
• Circulars, issued by a ministerial department for example, setting administrative
regulations, typically containing provisions aimed at hierarchically lower-ranking
institutions such as authorities and agencies. Circulars, unlike executive orders, cannot
directly bind citizens or authorized parties.
The Parliament can adopt Parliamentary Resolutions: these are policy decisions, which are
binding for the Government.
The Radiation Protection Act, applies to any activity and any exposure situation and by
inference any facility in which an activity takes place, including nuclear facilities. This act
includes the fundamental basis for a framework for safety: responsibility, justification of
practices, optimization of exposure, limitation of doses, prevention of accidents and limitation
of their consequences, training of workers, protective actions to reduce existing or unregulated
radiation risks, administrative regimes, clearance of material, inspection, and appeals against
regulatory decisions.
The act empowers the DHA to lay down detailed rules for radiation protection. It also gives
DHA the legal basis to perform inspections and to grant, amend, revoke or deny an
authorization.
The types of facilities and activities regulated and their administrative regime (notification,
license and license with conditions) are further specified especially in Executive Order no.
669/2019.
The Nuclear Installations Act complements The Radiation Protection Act by defining a nuclear
facility, nuclear fuel and radioactive by products. It confers:
• The Minister of Health (originally the Prime Minister) the authority to grant or refuse the
approval for a nuclear installation or exempt an installation from such license;
• Jointly DEMA and DHA – the “Nuclear Regulatory Authorities” (NRA) – the authority
to inspect and set license conditions or establish operational limits and conditions.
The regulatory body for radiation and nuclear safety in Denmark is composed of two
authorities, with specified roles and tasks. Although other organizations do have some
10
regulatory roles on more specific or limited matters, the main regulatory authorities for radiation
and nuclear safety are:
• The DHA, an authority under the Ministry of Health;
• The DEMA, a civilian agency under the Ministry of Defence.
The DHA acts under the Ministry of Health. In accordance with the Radiation Protection Act,
the DHA is the national competent authority for regulating the use of radioactive substances
including radioactive waste.
The DEMA is responsible for Danish emergency preparedness and acts under the Ministry of
Defence. DEMA supervises authorities and municipalities on emergency preparedness.
The Nuclear Regulatory Authorities are authorized to establish limits and conditions for
operation and decommissioning, to issue terms necessary to ensure compliance and to access
nuclear facilities at any time. The nuclear installations at Risø, including the national storage
facilities for radioactive waste, are subject to oversight and inspection by the Nuclear
Regulatory Authorities.
The Danish Environmental Protection Agency is part of the Ministry of the Environment. It
administers the legislation on environmental protection, which is to ensure clean air,
(drinking- ) water and soil and good living conditions for people, animals and nature. The
Environmental Impact Assessment Act as well as the Planning Act (under the Ministry of the
Interior and Housing) are relevant in the planning and siting of facilities such as nuclear
facilities or a disposal facility for radioactive waste.
The Agency for Higher Education and Science has the formal responsibility for institutions
under the Ministry of Higher Education and Science, including DD.
Existing nuclear installations in Denmark are at a late stage of decommissioning and are
operated by a single operator, the DD.
ARTEMIS observation
The ARTEMIS Review Team found the legal, regulatory and organisational framework for
waste management to be mostly in line with IAEA Safety Standards.
The Danish policy for safe management of radioactive waste is currently established in
Parliamentary Resolutions. The Government has made initial provisions for the safe
decommissioning of the nuclear facilities at the Risø site, the safe management and disposal of
radioactive waste, and the safe management of spent fuel by the adoption of Parliamentary
Resolution B48 and Parliamentary Resolution B90 (see also chapter 1.1).
It is noted that approval for construction of a facility according to the Nuclear Installation Act
is needed by the Minister of Health prior to construction and again another approval by the
same minister prior to operation. DHA and DEMA provide support to the minister in assessing
the applications. The ARTEMIS Review Team considers it a common regulatory approach to
grant an approval prior to construction. In contrast, the required license for operation according
to the Radiation Protection Act is needed before the beginning of the operation. The licensing
process for operation according to the Radiation Protection Act is started officially only after
or parallel to the construction of the facility.
Some general requirements are established, e.g., in Executive Order 670 of 1 July 2019.
However, regulatory requirements for the different phases of the lifetime of the waste
management facilities (New Upgraded Storage Facility (NOL), waste treatment facility and
disposal facility) are not sufficiently detailed. Further regulatory requirements and
11
accompanying guidance documents are therefore needed. This is in particular the case for the
future waste treatment facility, but also for, e.g., the ageing management for and subsequent
decommissioning of the NOL facility, taking into account that the NOL has to be in operation
for several decades. This issue has been also raised by the IRRS mission in relation to regulatory
requirements of the disposal facility and a specific recommendation has been addressed to DHA
in the IRRS Report (Recommendation R12).
DD intends to apply for approval and a license to operate the NOL with no limitation on the
operation period. The ARTEMIS Review Team, taking into account that the period of time for
which the facility will be needed is not exactly clear, considers this a prudent approach. Periodic
safety reviews have however to be planned to ensure the continued safe operation of the facility.
The ARTEMIS Review Team notes that, according to para. 2 sub-para. 1 of Circular No.
9261/2022, DD accepts the following waste categories on the basis of a case-by-case
evaluation:
1) Radioactive waste from the use of radioactive material in Denmark according to national
radiation protection regulations;
2) Radioactive material of Danish origin covered by a retransfer agreement, including sealed
radioactive sources in Danish-made equipment no longer in use; and
3) Radioactive material outside of regulatory control, including radioactive material rescued
under unforeseen circumstances.
Further, para. 2 sub-para. 2 of the same Circular states that DD can decide to accept radioactive
waste or material not covered by sub-para. 1 mentioned above.
The ARTEMIS Review Team notes that there is no obligation for DD to accept waste according
to sub-para. 2. Further, it is the understanding of the ARTEMIS Review Team that even waste
according to sub-para. 1 may be rejected, depending on the evaluation of the specific case.
Taking into consideration that DD is the only state owned operator for the storage and treatment
of radioactive waste, it is therefore possible to have radioactive waste streams without a clear
disposal or storage path within the Danish legal system. Examples are orphan sources or waste
from discontinued practice, e.g., from bankrupt institutions. For certain radioactive waste, the
storage and treatment depend on the voluntary decision of DD or the authorities, but not on a
legal requirement.
12
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: Applicants, e.g., Danish Decommissioning, are required to submit a
demonstration of safety in support of their application for future facilities, e.g., for the NOL
and later for a disposal facility. Some general requirements for radioactive waste facilities
are found in the Nuclear Installation Act, the Radiation Protection Act and in two executive
orders. However, there are no specific guidance documents or specified criteria available for
the applicant/licensee.
(1)
BASIS: GSR Part 1 (Rev. 1) Requirement 24, para. 4.34. states that “The
regulatory body shall issue guidance on the format and content of the documents
to be submitted by the applicant in support of an application for an authorization.
[…]”
(2)
BASIS: GSR Part 5 Requirement 3 states that ”The regulatory body shall
establish the requirements for the development of radioactive waste management
facilities and activities and shall set out procedures for meeting the requirements
for the various stages of the licensing process.”
(3)
BASIS: GSR Part 5 Requirement 3 para. 3.8 states that ”To facilitate
compliance with regulatory requirements, the regulatory
body has to do the following:
Provide necessary guidance on the interpretation of national standards
and regulatory requirements that takes into consideration the complexity
of the operations and the magnitude of the hazards associated with the
facility and operations; […]”
R1
Recommendation: The regulatory body should establish regulatory
requirements and guidance documents for the development and
authorization of waste management facilities in the different stages of their
life-time (siting, design, construction, operation, decommissioning or closure
and post-closure, as applicable).
13
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: Danish Decommissioning takes a central role in management of institutional
radioactive waste in Denmark as sole state owned operator for storage and treatment of
radioactive waste. Danish Decommissioning accepts most radioactive waste according to
Circular No. 9261/2022. However, Danish Decommissioning does not have the obligation to
accept all types of waste. In certain situations, radioactive waste has no legally defined path
within the Danish legal system.
(1)
BASIS: SF-1 Principle 2, para 3.9 states that “[…] Government authorities
have to provide for control over sources of radiation for which no other
organization has responsibility, such as some natural sources, ‘orphan sources’
and radioactive residues from some past facilities and activities.”
(2)
BASIS: GSR Part 1 (Rev. 1) Requirement 9, para. 2.25 states that “Radiation
risks may arise in situations other than in facilities and activities that are in
compliance with regulatory control. […] Where unacceptable radiation risks arise
as a consequence of an accident, a discontinued practice, or inadequate control
over a radioactive source or a natural source, the government shall designate the
organizations to be responsible for making the necessary arrangements for the
protection of workers, the public and the environment. […]”
(3)
BASIS: GSR Part 1 (Rev. 1) Requirement 10 states that “The government shall
make provision for [..] the safe management and disposal of radioactive waste
arising from facilities and activities, and the safe management of spent fuel.“
(4)
BASIS: GSR Part 1 (Rev. 1) Requirement 10 para. 2.30 states
that ”Radioactive waste generated in facilities and activities shall be managed in
an integrated, systematic manner up to its disposal.”
R2
Recommendation: The Government should ensure management of and
control over all radioactive waste and designate waste management
organizations that are obliged to accept all types of radioactive waste.
14
2. NATIONAL STRATEGY FOR RADIOACTIVE WASTE AND SPENT FUEL
MANAGEMENT
2.1. SCOPE
Danish position
The Danish national strategy is defined in the National Programme. It describes a stepwise
approach towards a comprehensive system for safe management of all type radioactive waste,
which is based on passive safety features in the long term. The latest version of the National
Programme incorporates modifications based on the provisions of Parliamentary Resolution
B90. Activities are organised in a such way as to ensure completion of the decommissioning
tasks related to the nuclear facilities and transfer of all waste into an upgraded storage facility
for storage of up to 50 years. The technical, organisational and political options for management
of radioactive waste, including seven dedicated groups of waste referred to as “special waste”
are integrated with the activities to identify a site and develop a disposal concept of a geological
disposal facility. An international solution for the “special waste” is considered as an alternative
option.
The National Programme defines technical areas, which are subdivided into “Waste
Management”, “Geology & Siting” and “Disposal Solution” areas and the socio-economic area
subdivided into “Organisational Framework”, “Stakeholder Engagement” and “Finance and
Costing”. The main areas are further divided into a number of deliverables with multiple
interdependencies, which take effect in the short term, mid-term or long term, or extend over
several periods.
Implementation of the National Programme rests on the legal and regulatory framework
established for the safe management of radioactive waste. The framework assigns responsibility
for planning, conducting and the implementation of the National Programme. The execution of
the tasks from the national strategy is distributed between a number of different authorities and
institutions. The DHA assists the Ministry of Health by contributing to the preparation,
evaluation and updating of a national policy and national programme. The Danish Agency for
Education and Science assists the Ministry of Higher Education and Science by contributing to
the preparation, evaluation and updating of the National Programme. DD is the state enterprise
under the Ministry of Higher Education and Science, which is responsible for the
decommissioning of the nuclear facilities of the former Research Centre Risø, management and
storage of radioactive waste from institutional waste producers (except NORM waste),
developing a long-term solution for radioactive waste and also contributes to the revision of the
National Programme. However, the primary responsibility for development of a long-term
solution rests under the Ministry of Higher education and Science. DD has approved a waste
management strategy setting the strategic goals for the period from the begin of operation of
NOL to the placement of the waste into the disposal facility. Based on this strategy biennial
plans are formulated.
Danish Government continues to explore potential options of entering an intergovernmental
agreement on the use of disposal facilities for the “special waste”. Regarding the “special
waste”, the technical requirements and needs for research, development and demonstration
necessary to realize options for reprocessing (abroad), export with the purpose of disposal, or
inclusion in a disposal solution, must be identified and integrated in the implementation of the
National Programme at an early point in time to ensure a timely availability of the chosen
management option.
15
With regard to the exploration of exporting the special waste with the purpose of disposal, the
Danish Ministry of Foreign Affairs has conducted consultations with a number of OECD
member countries in order to establish whether legal, technical and political conditions exist
for the conclusion of a bilateral agreement on disposal of the special waste. However, so far,
this has been found not to be the case. In any case, consultations for a bilateral agreement on
disposal of the special waste will neither delay nor postpone the development of a disposal
facility on Danish soil. DD participates in the EURAD, European Joint Programme on
Radioactive Waste Management, in the Strategic Studies Work Package on waste management
routes. One of the tasks under this work package is investigating the potential of shared
solutions, both regarding pre-disposal and disposal.
Parliamentary Resolution B90 holds provisions for the possibility of including NORM waste
in a disposal solution, but explicitly does not include provisions for the management of NORM
waste in the period until a disposal solution is established. The policy proposed by a cross-
sectoral working group, initiated by the Ministry of Health, with the participation of relevant
authorities, municipalities and with the involvement of NORM industry operators will form the
basis for establishing corresponding provisions for management of NORM waste in a national
programme context.
ARTEMIS observation
The National Programme addresses the strategies, necessary actions and technical solutions to
be developed in the short, medium and long terms, aimed to ensuring management of all the
radioactive waste of the former Research Centre Risø and management and storage of
radioactive waste from institutional waste producers. A period of long storage is envisaged for
waste before disposal. The National Programme comprises concepts and plans, R&D activities,
human and financial resources for the radioactive waste management. Also, the National
Programme addresses developing a long-term solution for radioactive waste, including the
economic and financial measures required to carry them out. This approach in terms of the
scope of the national strategy is consistent with the recommendations of IAEA Safety
Standards. Also, the ARTEMIS Review Team noted that the Danish approach to radioactive
waste management considers disposal as final destination of almost all material declared as
radioactive waste.
However, NORM waste is an exception in the above mentioned approach. A strategy for the
management of NORM waste has not been established yet, and neither a National policy. This
issue has been identified in the IRRS mission to Denmark 2021 and is addressed in the
Recommendation R3 of the IRRS report.
The National Programme is based on the current radioactive waste inventory and takes into
account an estimate of the amount of future radioactive waste. This is in line with the
recommendations of IAEA Safety Standards. However, there are remaining uncertainties
regarding the characteristics and the inventory of the waste, but the National Programme
includes tasks related to re-assessment of the radioactive waste inventory.
16
2.2. MILESTONES AND TIMEFRAMES
Danish position
The National Programme is comprised by 3 technical and 3 socio-economic areas projected
over a timescale ranging from the completion of the decommissioning of the nuclear facilities
until commissioning of a geological disposal facility by 2073 at the latest. A milestone for
launching the operation of NOL for long term storage (up to 50 years) is 2023. The timescale
is divided into short, mid and long term (starting with commissioning of a geological disposal
facility) periods, which provides the time frame for the course and completion of the main
deliverables defined in the programme.
Figure 1. National Programme for the Safe and Responsible Management of Radioactive
Waste; Main areas (thick bars), deliveries (thin bars) and terms (bottom bars)
(National Programme for the Responsible and Safe Management of Radioactive Waste,
Denmark, Danish Health Authority, 2020)
The main overview of deliverables across areas over a short, mid and long term perspective in
the programme is summarized in the list below:
Short- to mid-term
1. Establish an upgraded storage facility, reassessment of radioactive waste inventory,
predisposal management and research, development and demonstration activities – taking into
account management options for the “special waste”.
2. Review and identification of geologies suitable for disposal down to 500 m depth
3. Identify possible disposal concepts including feasibility and barrier system studies
4. Designation of most relevant sites for detailed studies based on the outcome of 1-3 and
partnership options.
17
Mid to long term
1. Proposal for one or more specific type(s) of disposal solution(s) to be established
2. Planning Act (for selected option)
3. Construction Act
4. Safety Case and Environmental Impact Assessment
5. Construction and operation
6. Closure and institutional control
The operational lifetime of existing waste storage facilities it is not defined. However, structures
of the buildings are monitored and the buildings are kept in conditions sufficient for current
operational activities.
ARTEMIS observation
The National Programme defines essential tasks to achieve the overall goals for the
management of radioactive waste over short, mid and long term periods defined in Resolutions
B48 and B90. However, it specifies only few milestones related to the overall goals without in-
between milestones and end states for a period of 50 years, e.g., to establish NOL by 2023 and
to have a Danish waste disposal solution by 2073. Also, according to chapter 5.1.1 it should be
understood that a commencement of the NOL construction should be in 2022 and
commissioning of operation by August 2026.
A schedule for design, construction and operation of the NOL including licencing and other
decisions taking steps is not yet fully defined. The design operational period of existing storage
facilities for radioactive waste at the Risø Research Centre is not indicated in the ARM.
The schedule for development of a disposal facility is not clearly defined. A timeframe of the
following steps is not defined: (1) site selection (including deliverables indicated in the National
Programme), (2) development of the disposal facility concept and WAC, (3) development of
design, (4) predisposal management of waste in accordance with WAC for disposal, (5)
construction, (6) operation and (7) closure of the disposal facility, timeline for transfer of the
waste to disposal facility as well as the relevant milestones for licensing and other decision
taking points is not defined. As noted by the ARTEMIS Review Team from the discussions
with the Danish counterparts, there are no interim targets and end states neither within the frame
of national strategy nor in the plans of DD. The plan for the development of a geological
disposal facility by DD does not have interim milestones and end states. It does not include all
steps of radioactive waste management and all important elements of the strategy. This issue
will be discussed in more detail in chapter 4 of the report. The ARTEMIS Review Team noted,
that DD considers 2073 as milestone already for completion of a transfer of all radioactive
waste from the Risø Research Centre to disposal facility, but not as start of operation of the
facility.
The National Programme indicates a need of re-assessment of the radioactive waste inventory.
This activity can have considerable impact on the implementation of the National Programme.
However, a schedule for re-assessment of radioactive waste inventory as well as research and
development activities is not specified. In several parts of the ARM it is said that the
decommissioning strategy calls for the release of all buildings, installations and land previously
used by the Risø Research Centre for nuclear operations, research or development, for other
uses without restrictions (green field). A milestone for the achievement of the so called "green
field” condition of the site is not specified.
18
2.3. PROGRESS INDICATORS
Danish position
The National Programme identifies technical and socio-economic areas as overall constituents
of the programme structure. Within each area, several deliverables (objectives to be achieved)
have been defined. Deliverables are achieved through completion of projects and sub-projects,
conducted by relevant licensees, contractors, authorities etc. Achievement of objectives are not
fixed to a specific point in time, but are linked to short-, mid- and long-term perspectives. The
deliverable will be completed through conduct of projects and subprojects defined by the party
(organisation) responsible for the deliverable.
Within each project or subproject, milestones and key performance indicators (KPIs) will be
defined as per routine project management approach by the organisation (or contractor)
undertaking the project or subproject.
KPIs applied within each area may provide quantitative information on the progress towards
completing projects or subprojects needed for reaching defined objectives (the deliverable).
However, KPIs applied at the project level do not necessarily provide meaningful information
on the progress toward completing the deliverable, as this to a higher degree may depend on
acquired milestones or other qualitative factors such as the timely conduct and coordination
within the sum of projects and subprojects needed to complete the deliverable.
The progress of activities of DD is monitored by the annual Performance Contract with the
Ministry of Higher Education and Science. With regard to the activities performed by
Geological Survey of Denmark and Greenland, progress will be monitored according to a
project plan for the exploratory geological site investigations. The project plan will be
developed on the basis of collaboration with local authorities when the sites for exploratory
investigation are identified later in 2022 on the basis of a dialogue between the Ministry of
Higher Education and Science and local authorities/communities.
ARTEMIS observation
Considering that National Programme does not establish timeframe for achievement of
deliverables or milestones, interim targets or end states for monitoring progress of the National
Programme implementation, the progress of implementation of the National Programme is not
traceable.
The main indicators for monitoring of the progress of the National Programme seems to be the
timely conduction and coordination of deliverables (objectives to be achieved). However, the
National Programme states that achievement of objectives are not fixed to a specific point in
time, but are linked to short-, mid- and long-term perspectives, which also are fixed to only two
milestones: 2023 and 2073. The deliverables will be completed through conduct of projects and
subprojects defined by the organisation responsible for the deliverable and having their own
milestones and KPIs. However, the link from projects and subprojects KPIs to the indicators of
the progress of the implementation of the National Programme is unclear.
19
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: The National Programme defines essential tasks to achieve the overall goals for
the management of radioactive waste over short, mid and long term. However, it specifies only
few milestones related to the overall goals. The specified milestones are to establish an
upgraded storage facility (NOL) by 2023 and to have a Danish waste disposal solution by
2073. The National Programme does not establish milestones for achievement of deliverables
or any other interim targets or end states, which could be used for monitoring the progress of
its implementation.
(1)
BASIS: GSR Part 1 (Rev.1) Requirement 10, para. 2.28 states that “[…] The
strategy shall include appropriate interim targets and end states. Radioactive waste
generated in facilities and activities necessitates special consideration because of
the various organizations concerned and the long timescales that may be involved.
The government shall enforce continuity of responsibility between successive
authorized parties”.
(2)
BASIS: GSR Part 1 (Rev.1) Requirement 10, para. 2.30 states that “Radioactive
waste generated in facilities and activities shall be managed in an integrated,
systematic manner up to its disposal. […]”.
R3
Recommendation: The Government should update the National Programme
in order to include appropriate interim targets and end states for the
monitoring of programme implementation for all types of radioactive waste.
20
3. INVENTORY OF SPENT FUEL AND RADIOACTIVE WASTE
Danish position
The classification of radioactive waste in Denmark follows the IAEA classification of 2009.
Classification as very low level radioactive waste (VLLW) can only be done with the explicit
approval of the regulatory authority. The national inventory of radioactive waste comprises of
low and intermediate level waste. All radioactive waste subject to the government waste
management policy is stored by DD at the Risø site.
For national purposes Denmark has been grouping the radioactive waste into 20+ groups in
2011 during a pre-feasibility study. The study was based on a summary and predictions on
future waste compiled in 2008 in the so called ‘basis for decision’ for a Danish disposal facility
for low and intermediate level waste, i.e. in the early days of the decommissioning at Risø. This
system is continuously used also for planning purposes.
A significant part of the inventory of ILW comprises a small amount of waste, termed “special
waste”, which has a total inventory of less than 600 TBq according to the National Programme.
The special waste consists of seven waste groups, amongst them about 233 kgHM of
experimentally irradiated fragments, some remaining unirradiated fuel and the liquid reactor
core of the former research reactor DR 1. From the 600 TBq special waste, 35 TBq are long-
lived alpha-emitting nuclides.
The mass and material composition of the special waste is relatively well known and shown in
Table 2. The fission products, 137
Cs and 90
Sr, and the actinides, 239
Pu and 240
Pu, almost
exclusively account for the current activity of the DR 1 liquid core solution.
Spent Fuel Storage facility Material Mass/Volume Activity
Core solution
from DR 1
DR 3 building
complex
Solution of
20% enriched
uranyl sulphate
in light water
4.9 kg U
15.8 l
28.4 GBq
fission
products
0.4 GBq
actinides
Experimentally
produced and
irradiated
fragments of
spent fuel of
power reactor
type
The Centralvej
Storage
Uranium oxide
pellets mostly
in zircalloy
tube
233 kg U
533 TBq
fission
products
35 TBq
Actinides
Table 1. Specification of the special waste, including the material composition and
quantities with regard to mass/volume and activity as of January 2020
(National Programme for the Responsible and Safe Management of Radioactive Waste,
Denmark, Danish Health Authority, 2020)
Most of the other radioactive waste in Denmark originates from the decommissioning of the
research reactors and associated nuclear facilities at the Risø site. A small part of the waste, less
than 10 t per year, originates from applications in industry, medicine and research, which is
delivered to DD. The total amount of waste conditioned for disposal and destined for disposal
21
after completion of the decommissioning projects was estimated at 5 000 – 10 000 m³ in 2008
and 2011 and depends on the decision regarding a long-term solution for the management of
existing and continuously produced NORM waste, which is currently being stored at industrial
sites under regulatory control but not as part of the national waste management policy.
According to more recent estimates in the National Programme (2020), the waste to be disposed
of will have a volume of around 15 000 m³ excluding NORM waste.
Following the adoption of B90, DD will establish NOL which will replace the existing five
storage facilities for radioactive waste at the Risø site. According to B90, all radioactive waste
stored at Risø will be transferred to the upgraded storage facility and will remain stored there
until a disposal solution for the waste is operational. The transfer operations are to be performed
as fast as possible and only later detailed requalification and eventual reconditioning for
disposal are foreseen. An additional, future source of radioactive waste is the increasing number
of cyclotrons to be decommissioned. According to previous preliminary studies, referred to in
the National Programme, significant amounts of low-activity concrete and steel could result
from these activities However, after re-evaluation such additional volume would not
compromise the contingency of 20 % of the planned capacity of 15 000 m3
for NOL.
The data of radioactive waste is, for most waste, available in DD’s Waste Management
Database ADS. Historical waste is not yet included in the ADS. Furthermore, for two of the
storage facilities (Drum storage and Centralvej Storage) the inventory is reported collectively
as there is only limited information on many of the individual packages.
Accordingly, some of the radioactive waste needs (re-)assessment. This is planned during the
operational phase of the NOL. The re-assessment will address the perspective for each of the
waste groups identified.
ARTEMIS observation
Although there is a data base providing some basic information on every waste item, the
information on individual characteristics of waste items needs improvement. DD plans to
execute a re-assessment programme only after transfer of all the packages into the new storage
facility. During the transfer process, the basic measurements for radiation safety are planned to
be performed. DD plans to repackage waste if necessary.
The ARTEMIS Review Team acknowledges the need for a timely transfer of radioactive waste
from the facilities that have a risk of flooding and/or other safety issues.
At the same time, the ARTEMIS Review Team points out that the transfer process is a good
opportunity to improve incomplete information on the radiological content of the individual
packages. From an organizational and radiation protection point of view, this would mean a
practical application of the principle of optimization by reducing the number of handling
procedures and correlated personnel exposure. Such a measurement program should be used
not only to fill gaps in documentation, to verify existing information for the purpose of quality
assurance and to enhance confidence on storage assessment.
The foreseen re-assessment of waste packages will be performed in a new treatment facility,
which still has to be designed. The ARTEMIS Review Team notes that such re-assessment and
this new facility are important steps in preparing for disposal. The ARTEMIS Review Team
understands that DD plans to re-assess and characterise the waste, focussing on properties
relevant for storage. The planned re-assessment and characterization would also be beneficial
for qualifying the packages in view of future disposal.
22
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: For some waste packages, especially historical waste, there is only little
information available. The inventory of radioactive waste in the drum storage facility and the
Centralvej Storage facility are reported only collectively. Danish Decommissioning intends
to transfer all existing waste to the NOL without prior re-assessment of the waste, in order to
bring the packages into a safer storage facility.
(1)
BASIS: GSR Part 5 Requirement 9 states that “at various steps in the
predisposal management of radioactive waste, the radioactive waste shall be
characterized and classified in accordance with requirements established or
approved by the regulatory body.”
(2)
BASIS: GSR Part 5 Requirement 9, para. 4.10 states that “radioactive waste
has to be characterized in terms of its physical, mechanical, chemical,
radiological and biological properties.”
(3)
GRS Part 3 para 3.24 states that “for occupational exposure and public
exposure, registrants and licensees shall ensure that all relevant factors are taken
into account in a coherent way in the optimization of protection ….”
R4
Recommendation: In order to improve inventory data Danish
Decommissioning should perform nuclide specific measurements on the
individual waste packages in the course of transfer activities to a new storage
facility, as appropriate.
23
4. CONCEPTS, PLANS AND TECHNICAL SOLUTIONS FOR SPENT FUEL AND
RADIOACTIVE WASTE MANAGEMENT
Danish position
Since 2003 DD has been conducting decommissioning activities for the major nuclear
installations in Denmark, all of them located at the site of the Risø research centre. According
to the updated timeline these activities will be terminated before the end of this decade.
Facilities and services are in place at DD for predisposal of radioactive waste from the
decommissioning as well as from the collection of institutional waste. They are regarded as
sufficient on the short term (“establishing phase”). As arisings of specific waste streams in
Denmark are limited, DD contracts some treatment services abroad, e.g., incineration of
burnable waste.
There are 1060 drums with bituminized waste stored on the Risø site. Bituminization was
stopped in 2015 after a fire incident during waste processing. No further waste of this type is
expected in the future.
DD chose a contractor to advise on how to deal with problematic waste, including the
bituminized waste. A preliminary study will start in May 2022 and is planned to be finished in
October 2022.
Currently DD is preparing the license application for the construction and subsequent operation
of NOL on the premises of the research center. Once the WAC for NOL are established and the
facility is in operation, waste now stored in the 5 existing facilities will sequentially be
transferred to the NOL-facility starting with the packages currently stored in locations with
higher flooding risk.
For already stored waste packages a need to reassess quality and documentation has been
identified, which may include the need for repackaging or reconditioning. Based on the WAC
for the NOL-facility any new waste arisings will be conditioned accordingly and directly stored
at NOL.
For the transfer, WAC for NOL take into account the requirement to facilitate transfer of all
radioactive waste already in storage but ensuring continuous safe conditions for storage at NOL.
Liquid waste will not be accepted in the NOL. Reversibility will have also to be ensured. For
the subsequent long term storage phase the WAC for NOL will require characterization of
stored packages in view of the subsequent disposal.
The safety assessment for the NOL is under preparation as well as the WAC, which shall be
finalized as soon as the safety assessment is substantiated. Requalification of existing waste
packages and conditioning of new waste according to the WAC for NOL will require the
construction of a new waste treatment facility which is deemed necessary anyway on the long
term for preparing waste packages for disposal.
Planning for the disposal of an estimated total volume of 14 000-17 500 m3
is an ongoing
process. As stated in parliamentary resolution B90 and the National Programme the disposal
facility has to start operation not later than 2073 followed by an operational phase of 50 years.
The next steps are:
• involvement of local communities in the selection of two sites for further geological
investigations shall be initiated by the Ministry of Higher Education and Science in 2022
and
• Geological invenstigations at 2 selected sites will commence in 2023 and will be
subcontracted to the Geological Survey of Denmark and Greenland.
24
ARTEMIS observation
Although there are some operational services available for the treatment of limited amounts of
solid and liquid institutional as well as decommissioning wastes, DD is planning for a new
treatment facility. This waste treatment facility is not yet described in the National Programme.
It is unclear, to which extent the management of “special waste” shall be covered by the scope
of this new facility, as the self-assessment states that also “international solutions” for these
waste groups are being considered. There exists no clear decision basis for the selection of the
most appropriate conditioning technique for some of the waste groups.
The existing decentralized storage facilities are considered inappropriate for the foreseen long-
term storage, either for technical reasons and/or as they are located at the sea shore only a few
meters above todays sea level. This is why Denmark plans to transfer such waste to the NOL
immediately after it will be licensed for operation; at present NOL is in an advanced planning
stage.
The ARTEMIS Review Team notes that even preliminary WAC for disposal do not exist, which
would be needed to plan for characterization in compliance with optimization in radiation
protection and to perform a qualified conditioning/reconditioning of historic and newly
generated waste in due time during long term storage before disposal. In their observation the
IRRS team noted that future nuclear facilities are not covered by existing regulatory framework.
The ARTEMIS Review Team expects that the necessary legal framework will be addressed in
the implementation of IRRS Recommendation R2 in order to ensure that generic WAC can be
established by the implementer.
The disposal solution for all of the waste streams still has to be defined on the technical level.
Only an endpoint of the establishing phase for a national disposal facility has been defined: start
of operation shall be not later than 2073. As -at least for a part of the waste- international
disposal options are still under consideration, significant uncertainties exist for a number of
boundary conditions. It is not unlikely that such pending decisions and other uncertainties of
the planning basis may have retarding effects on the development of the disposal facility.
During the presentations the ARTEMIS Review Team noted that some essential aspects of the
National Programme are missing in DD’s strategy for the disposal facility as developed up to
now and that a full understanding has still to be reached on the complex interdependencies
between the various tasks and deliverables needed for the successful conduct of a deep
geological disposal project. The ARTEMIS Review Team expects that the necessary legal
framework will be addressed in the implementation of IRRS Recommendation R2 in order to
ensure DD is fully responsible for establishing the long-term solution for managing radioactive
waste.
25
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: Concepts, plans and technical solutions are developed for the waste
management steps of the near future. Some strategic and technical decisions are pending,
especially those concerning disposal. The deadline, however, is fixed as the disposal facility
shall start operation not later than 2073. Decision making in time to reach that goal needs
an information basis for which some dedicated research and development is needed.
The current planning for the geological disposal as presented by DD needs completion -as
some important work packages are missing- and refinement -as the timeline is not entirely
consistent with the National Programme and existing interdependencies are not indicated.
It should cover the whole project period including compilation of design criteria,
conducting the site selection process, compiling the knowledge basis including any
necessary research and defining milestones for taking decisions between still available
options, design, licensing, construction, operation, closure and post closure phase.
There is no oversight process in place, how the timely implementation of the National
programme is controlled.
(1)
BASIS: SF-1 Principle 2 states that “An effective legal and governmental
framework for safety, including an independent regulatory body, must be
established and sustained.”
(2)
BASIS: SF-1 Principle 2 para 3.9 states that “government authorities have to
ensure that arrangements are made for preparing programmes of actions […]
and for disposing of radioactive waste.”
R5
Recommendation: To ensure timely operation of the disposal facility the
implementer should prepare a comprehensive implementation plan
consistent with the National Programme.
R6
Recommendation: The Government should establish a compliance
assurance procedure for the implementation of the National Programme.
26
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: Neither specific nor generic waste acceptance criteria for disposal are
available to support the selection of applicable waste treatment procedures. This favours
decisions to postpone treatment of waste, thereby increasing the risk of future legacies. The
resulting additional handling steps for final conditioning in the future will lead to avoidable
personnel exposure.
(1)
BASIS: SF-1 Principle 7, para 3.29 states that “Radioactive waste must be
managed in such a way as to avoid imposing an undue burden on future
generations;[...]”
(2)
BASIS: GSR Part 3 para 3.24 states that “for occupational exposure and
public exposure, registrants and licensees shall ensure that all relevant factors
are taken into account in a coherent way in the optimization of protection [….]”
(3)
BASIS: GSR Part 5 Requirement 10 states that “[…] The processing of
radioactive waste shall be based on appropriate consideration of the
characteristics of the waste and of the demands imposed by the different steps in
its management (pretreatment, treatment, conditioning, transport, storage and
disposal). […]”
(4)
BASIS: GSR Part 5 para 4.13 states that “The main purpose of processing
radioactive waste is to enhance safety by producing a waste form, packaged or
unpackaged, that fulfils the acceptance criteria for safe processing, transport,
storage and disposal of the waste. Waste has to be rendered into a safe and
passive form for storage or disposal as soon as possible […]”
(5)
BASIS: SSG-14 para 3.10 states that “The operator has to develop technical
specifications […]. This includes waste acceptance criteria and other controls
and limits to be applied during construction, operation and closure.”
R7
Recommendation: The implementer of the disposal facility should develop
generic waste acceptance criteria for disposal and -as soon as a facility
specific safety case is available- final waste acceptance criteria on the basis
of regulatory body requirements.
27
5. SAFETY CASE AND SAFETY ASSESSMENT OF RADIOACTIVE WASTE AND
SPENT FUEL MANAGEMENT ACTIVITIES AND FACILITIES
Danish position
The Danish legislative system sets the obligation for an undertaking applying for an
authorization to submit a safety assessment. This is regulated by the Act on Ionising Radiation
and Radiation Protection, Chapter 2, § 5, and by the Executive Order No. 669 (01/07/2019) on
Ionising Radiation and Radiation Protection of the Ministry of Health, the DHA. In addition,
Chapter 2, § 5 of the Radiation Protection Act entrusts the DHA to lay down detailed rules
regarding the compilation of safety assessments, while § 20 of Executive Order No. 669 sets
the requirements for licensees to compile a safety assessment commensurate with the nature,
scale and complexity of the use of radiation sources or exposure as well as for its continuous
update.
Furthermore, for the construction and the operation of a nuclear facility, an approval by the
Minister of Health has to be obtained according to the Nuclear Installation Act. Approvals are
granted on the basis of Preliminary and Final Safety Analysis reports to be submitted according
to Executive Order no. 278 of 27 June 1963 on Protective Measures against Accidents at
Nuclear Facilities, §§ 3 and 4.
The same Act also entitles DHA and DEMA to set Operational Limits and Conditions
associated to the Approvals. Operational Limits and Conditions for DD are regularly updated.
Activities on decommissioning of nuclear installations and corresponding radioactive waste
management are subject to the provisions of the Nuclear Installations Act. In particular, the safe
conduct of decommissioning activities and operation of the different storage facilities in the
Risø site is regulated by limits and conditions (BfDA), issued by DHA and DEMA, and
communicated to DD with a letter of the Ministry of Health in 2003, when the company took
the responsibility for decommissioning operations and waste management activities on the basis
of the B48 Parliamentary Resolution.
The safety assessment for the installations under decommissioning and for conducting waste
management activities, in particular storage, is developed in the Safety Documentation prepared
by DD in compliance with BfDA. This documentation covers different topics, including a
detailed description of facilities on the site and an assessment of emergency scenarios, such as
fire, flooding etc. For a specific facility under decommissioning project and subproject
descriptions have to be prepared, which are then reviewed and approved by the DHA and in
case of nuclear facility by the DEMA and, for specific operations, complemented with detailed
work plans that are transmitted to the DHA and for nuclear facility by the DEMA for
information. The working plans are used for by DHA and the DEMA for inspections and as a
base of information to monitor the status of the decommissioning process and timeline.
According to Parliamentary Decision B48 the Danish decommissioning strategy envisages the
unconditional release of the Risø site (green field). BfDA therefore also require that a final
decommissioning report and a final clearance report have to be prepared and defines their
content.
In relation to existing waste storage facilities in the Risø site the DD documentation comprises
a safety analysis of incidents scenarios and also less probable events (accident scenarios). BfDA
establish safety requirements for the safe storage of waste in the dedicated facilities. As reported
in the ARM the existing storage facilities are neither built nor suitable for long-term storage of
radioactive waste. In particular, design margins against flooding events are also quite small as
demonstrated in 2013 when as result of a severe storm water level raised quite above the normal
28
level. Specific emergency preparedness provisions are put in place. Existing storage facilities
in the Risø site also do not have enough capacity to store all the radioactive waste generated by
the decommissioning operation.
As said in other chapters of this report the construction of a new storage facility is planned.
This facility is planned to accommodate all the waste in storage for 50 years, in the wait that a
geological disposal will be made available. The ARTEMIS Review Team has been informed
that a safety case of this new storage facility is under preparation by DD as part of a Preliminary
Safety Report to be presented to the regulatory body – jointly DHA and DEMA – in order to
get the approval for construction. The safety case will provide demonstration that the new
facility will be adequately protected against rising water level, severe meteorological
conditions, such as the development of a hurricane, the preservation of climate control to
minimize corrosion of waste drums, as well as specific security related events, etc. A Guide
setting up General requirement for contents of safety assessment, issued by the DHA, is in place
and it is applicable also to the construction of a new radioactive waste storage facility. The
necessary specific requirements for the new storage facility have been however defined by
DHA and DEMA and provided to DD in dedicated workshops in order to facilitate the
application for approval of construction under the provisions of the Nuclear Installations Act.
In relation to the disposal facility to be realized at the latest by 2073 according to the national
policy the preparation of the safety case has to be started, being the siting process still to be
initiated and waiting for a decision on selected site.
The construction of a disposal facility is subject to a licensing procedure according to Executive
Order 670/2019 §5 and a specific safety assessment has to be submitted according to Executive
Order 669/2019 §20.
ARTEMIS observation
For decommissioning activities already in progress no general guidance had been issued by the
Regulator addressing decommissioning of nuclear facilities. In this regard the IRRS report
states that since DD is the only operator of a nuclear facility in Denmark, based on the principle
of graded approach DHA and DEMA have instead established BfDA which are specific
requirements addressing the waste management and decommissioning activities performed by
DD. BfDA include in fact details that could appear in regulations based on IAEA Safety
Standards for decommissioning. An example is the standard content of the documentation to
be prepared by the licensee for the safety assessment of decommissioning projects as reported
in section 2 of the BfDA. Furthermore, in this section it is also stated that the safety assessment
should be prepared in accordance with the pertaining IAEA Safety Standards. The IRRS team
report states that being DD the only licensee involved in the decommissioning of nuclear
installations compiling of and use of specific requirements instead of developing specific
regulatory documents for decommissioning is in line with applying graded approach in
regulation. In this regard, taking also into account the small dimension of the Danish nuclear
programme, the ARTEMIS Review Team shares the observation in the IRRS team report.
The ARTEMIS Review Team has however noted that for the waste management installations
to be developed in the future (i.e. a new storage facility, a waste treatment facility and geological
disposal facility) guidance on the format and content of the documents to be submitted by DD
in support of the application for authorization addressing safety case aspects in the different
phases of the lifetime of each installation have not been developed by the regulatory body. The
ARTEMIS Review Team has noted that this issue has also been addressed in the IRRS Report
and shares the Recommendation R8 that the IRRS team has formulated.
29
The ARTEMIS Review Team also observed that regulatory requirements covering specific
safety criteria, including those related to the performance of the safety assessment, and
associated guidance documents for the development and authorization of new waste
management facilities have also not been developed yet by the regulatory body. This issue is
covered by Recommendation 1 in this report.
30
6. COST ESTIMATES AND FINANCING OF RADIOACTIVE WASTE AND
SPENT FUEL MANAGEMENT
Danish position
Apart from the institutional radioactive waste all other radioactive waste in Denmark originates
from activities of state institutions at the research center Risø. Hence the financing of all waste
management steps is under the responsibility of the state. The costs and their timely occurrence
are correlated to three major groups of activities:
a. The decommissioning of shut down installations (to be finalized in 2023), short term;
b. Upgrading of existing storage facilities and licensing, installation and start up of the NOL,
including preparation and transfer of existing waste to this facility, mid-term; and
c. Planning, site selection, licensing, installation and operation of the final repository, long
term.
The responsibility for cost calculation, planning and execution for activities a) and b) and –
partly – c) has been appointed. It is understood that the involved organisations bear their own
expenses in execution of their responsibility from the annual budgets unless there is a specific
government project financing available. For the project implementation of NOL and the
disposal facility, financing will be provided from the reserve fund, a budget position established
as a consequence of decisions B48 and B90, which is especially dedicated to the projects of the
National Programme. In this framework the implementation project for the disposal facility
might be regarded as a “high risk” project.
ARTEMIS observation
The mechanisms to plan and ensure financial provisions for managing radioactive waste in
Denmark are comparable to those in other countries where such responsibility lies exclusively
with the state. Operational and institutional costs are planned in the annual budgets of the
corresponding government organisations and a specific budget position, the reserve fund for
costly and/or long term projects, has been established. The successful execution of the
decommissioning projects so far gives evidence for the adequacy of installed financing
procedures.
The ARTEMIS Review Team noticed that the recent update of the cost estimations in the
National Programme (2020) is still based on a feasibility study prepared in 2011 with only
minor adaptions, e.g., application of some scaling factors. They are not based on best available
information. The ARTEMIS Review Team considers the calculational basis for estimating the
financial risks insufficient.
The ARTEMIS Review Team recognizes a significant cost risk in the fact that there seems to
be no provision for the costs which will arise from the management of NORM waste stored at
the industrial producer sites and which is still produced continuously. The ARTEMIS Review
Team highlights that in the process of updating the National Policy and National Programme
according to IRRS Recommendation 3 and Recommendation 3 of this report also the
appropriate financial provisions shall be considered.
31
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: Cost estimations for the development of the disposal are to a large extend based
on a feasibility study of 2011. The corresponding implementation plan has not yet been
developed by Danish Decommissioning. This fact is already covered by Recommendation 5.
(1)
BASIS: GSR Part 1 (Rev.1) Requirement 10 states that “Provision for the
decommissioning of facilities and the management of radioactive waste and of spent
fuel, para 2.33. states that “appropriate financial provision shall be made for:
(a) …
(b) Management of radioactive waste, including its storage and disposal;
(c) …”
S1
Suggestion: As soon as a comprehensive implementation plan for the disposal
project is available, the Government should consider updating the
corresponding cost estimation and implement a procedure for periodic review
and update. Risks and uncertainties should be accounted for according to the
stage of the project.
32
7. CAPACITY BUILDING FOR RADIOACTIVE WASTE AND SPENT FUEL
MANAGEMENT – EXPERTISE, TRAINING AND SKILLS
Danish position
The implementation of the Danish National Programme for the radioactive waste management
has its main actors in the DD, as national implementer, and the regulatory body, whose
functions are exploited by the DHA and DEMA.
In order to accomplish its tasks, Section 10 (Organization) of the DD Safety Documentation
stipulates qualification requirements and competences for all relevant staff units. As specific
educational and training programmes are not offered by Danish Universities, DD has developed
its own educational programme for new staff.
For the short term, in order to maintain the necessary competences and skills, starting from
2022 and every two years a waste management plan will be prepared indicating the current
needs for expertise, skills and resources. These plans are expected to provide what is needed in
order to properly implement the task related to the construction and operation of the new storage
facility. The ARTEMIS Review Team has also been informed that in 2022 DD intends to apply
a stronger intelligent Customer approach with the aim of having sufficient in-house knowledge
to understand and define project needs and requirements in order to select the appropriate
contractor for a given task.
For the long term DD will have to manage an important transformation phase with the view of
becoming a National Centre of Competence for RW management including disposal. DD is
aware that new competences will be needed to develop and implement a disposal solution and
that recruitment of new staff might be difficult in the future. In this regard possibilities for
collaboration between Nordic and other countries are also investigated.
In relation to the regulatory body the ARTEMIS Review Team has been informed that Circular
No. 9654/2020 §4 for DHA and Circular No. 9450/2020 §4 for DEMA stipulates that the two
authorities assist the Ministry of Health by maintaining and further developing expertise and
qualifications related to safe radioactive waste management through training or other staff
competence development arrangements, as needed for the National Programme for maintaining
safety and radiation protection. The issue of competences, resources and skills of the regulatory
body has been addressed during the IRRS mission. A general recommendation addressed to
DHA on the development of a human resources plan in relation to the entire spectrum of its
regulatory responsibilities has been formulated in the IRRS Report (Recommendation R4). In
relation to DEMA and the regulatory task expected to be performed in connection with the new
waste management facilities, a specific suggestion on the future competence needs has also
been formulated in the IRRS Report (Suggestion S5). In particular, DEMA should consider
finalising the identification of competences required for the review and assessment of the safety
of such facilities, and ensuring all competences are available in due time. Furthermore, a
suggestion has also been addressed to the Government to enhance the existing funding
mechanism for DHA (Suggestion S1). DHA has informed the ARTEMIS Review Team that a
new position related to radioactive waste management will be advertised.
ARTEMIS observation
First elements of a strategic plan for the development of necessary competences have been
defined by DD in connection with the Waste Management Plan 2022. The long duration in time
for the development of a disposal facility however indicate the need to prepare a strategic plan
33
for competences management (identification of needed skills according to the implementation
plan of the facility, recruitment, training, management of generations transition) and to
regularly review and updated it on the basis of relevant progresses in the definition of the
implementation plan. In this regard the long storage period of the waste has also to be taken
into account.
As far as the regulatory body is concerned the ARTEMIS Review Team acknowledges and
shares the recommendation and suggestions on competences and skills development formulated
in the IRRS report.
RECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES
Observation: Danish Decommissioning is aware that several competences will be needed to
develop and implement a geological disposal facility. First elements on competences needed
have been defined in the DD’s strategy. The long duration in time required for the development
of the disposal facility however suggests the need to establish a strategic plan for competences
development and to regularly update it on the basis of relevant progress in the definition of the
DD implementation plan of geological disposal facility.
(1)
BASIS: SF-1 Principle 1 states that “The prime responsibility for safety must rest
with the person or organization responsible for facilities and activities that give rise
to radiation risks.”
(2)
BASIS: SF-1 Principle 1, para 3.6 states that “The licensee is responsible for:
—Establishing and maintaining the necessary competences;
—Providing adequate training and information; […]”
S2
Suggestion: Danish Decommissioning should consider establishing the
strategic plan for competence management according to the needs identified in
the implementation plan for development of the geological disposal facility,
review and regularly update it.
34
APPENDIX A: TERMS OF REFERENCE
ARTEMIS Review
of the National Radioactive Waste Management Programme
of Denmark
Terms of Reference
1. Introduction
On 14 December 2016, the Resident Representative of Denmark to the IAEA, requested the
International Atomic Energy Agency (IAEA) to organize and carry out an Integrated Review
Service for Radioactive Waste and Spent Fuel, Decommissioning and Remediation
(ARTEMIS) review. Denmark requested the ARTEMIS review to satisfy its obligations under
Article 14(3) of the European Council Directive 2011/70/EURATOM of 19 July 2011
establishing a Community framework for the responsible and safe management of spent fuel
and radioactive waste (hereinafter the EU Waste Directive).
2. Objective
The ARTEMIS review, performed by an international peer review team selected by the IAEA,
will provide an independent international evaluation of Denmark’s radioactive waste and spent
fuel management programme, based on the relevant IAEA Safety Standards and proven
international practices.
3. Scope
The given ARTEMIS review will evaluate the Danish national programme and the national
framework for executing country’s obligations for safe and sustainable radioactive waste and
spent fuel management.
It was agreed to exclude:
1. All radioactive waste management subject to the provisions of the autonomous authority
of the respective self-governments of the Faroe Islands and Greenland.
2. The remediation of sites affected by residues from past activities, as such sites have not
been identified in Denmark.
Results from the IAEA Integrated Regulatory Review Service (IRRS) mission to Denmark
conducted from 29 August to 8 September 2021 will be taken into account, where relevant
and appropriate to avoid unnecessary duplication.
35
4. Basis for the review
The ARTEMIS review will be based on the relevant IAEA Safety Standards and proven
international practice and experiences, following the guidelines of the ARTEMIS review
service.
5. Reference material
The review will cover all documentation submitted by National Counterpart for the
considered scope of the review, including the results of a national self-assessment, which
should be based on the ARTEMIS self assessment questionnaire provided by the IAEA.
The provisional list of reference material is provided in the Annex 1 (such a list is subject to
updates and should be finalized by submission of the advance reference material).
All documents for the purpose of the ARTEMIS review shall be submitted in English.
Reference material for the purpose of the ARTEMIS review shall be submitted to the
ARTEMIS mission webpage on the Global Nuclear Safety and Security Network (GNSSN) of
the IAEA.
6. Modus operandi
The working language of the mission will be English.
The National Counterpart is the Danish Ministry of Health. The National Counterpart Liaison
Officer for the review is Mr David Ulfbeck from the Danish Health Authority, Radiation
Protection.
The ARTEMIS review mission will be conducted from 1 to 9 May 2022 at the premises of
Danish Dekommissioning, Frederiksborgvej 399, in Roskilde, Denmark. The provisional
schedule for the review mission is provided in Annex 2.
The timeline for the key steps of the review process is provided below:
• Self-assessment questionnaire: available to Denmark as of 5 May 2021
• Preparatory Meeting: 14 December 2021 (WebEx meeting)
• Notification by IAEA to the Counterparts on the review team composition: by 15
February 2022.
• Submission of reference material: reference material (in English) and the results of the
self-assessment questionnaire will be provided to the IAEA as soon as they are available
and not later than by 15 February 2022 (including the completed self-assessment)
• Submission of questions from the review team to the Counterpart based on preliminary
review of the reference material: by 8 April 2022
36
• Peer review mission: 1 to 9 May 2022 (9 days):
o Sunday: arrival of experts and their meeting.
o Monday to Wednesday: interviews/exchange/discussion with Counterparts on
the basis of preliminary analysis and drafting of recommendations and
suggestions.
o Thursday: finalization of recommendations and suggestions - presentation and
discussions of recommendations/suggestions/good practices with the
Counterparts.
o Friday: drafting of the report, informing the Counterparts when the draft report
is going to be submitted (Review Team).
o Saturday: delivery of draft report to the Counterparts for fact checking -
o Sunday: internal reflection of comments by Review Team - discussions with
the Counterparts and finalization of draft report by Review Team.
o Monday: delivery of final draft report – exit meeting – closure.
7. International peer review team
The IAEA will convene a team of international experts to perform the ARTEMIS review
according to the ARTEMIS Guidelines and these Terms of Reference. The team will consist
of:
• Four qualified and recognized international experts from government authorities,
regulatory bodies, waste management organizations, or technical support organizations
with experience in the safe management of radioactive waste.
• Two IAEA staff to coordinate the mission. The Coordinator of the ARTEMIS review is
Mr Andrey Guskov of the Department of Nuclear Safety and Security of IAEA. The
Deputy Coordinator is Ms Merle Lust of the Department of Nuclear Energy of IAEA;
• One IAEA staff for administrative support.
A senior staff member from the Department of Nuclear Safety and Security of IAEA will
oversee the closure of the review.
The peer review team will be led by Mr Stefan Theis, ENSI, Switzerland, Team Leader from
the review team. The IAEA will inform the National Counterpart regarding the composition of
the proposed review team prior to submission of reference material. The review mission may
include the presence of up to two observers, including the possibility of an observer from the
EC. The National Counterpart will be notified of any proposed observers; the presence of any
observers must be agreed in advance of the mission.
37
8. Reporting
The findings of the peer review will be documented in a final report that will summarise the
proceedings of the review and contain any recommendations, suggestions and good practices.
The report will reflect the collective views of the review team members and not necessarily
those of their respective organization or Member State or the IAEA.
Prior to its finalization, the ARTEMIS Review Report will be delivered to the National
Counterpart for fact-checking, represented by the Danish Health Authority, Radiation
Protection.
9. Funding of the ARTEMIS review
The cost estimate for the ARTEMIS review includes travel costs, per diem of the peer review
team (external experts and the IAEA staff) in line with the IAEA Financial Regulations and
Rules.
The peer review will be funded by the Government of Denmark. The cost of the ARTEMIS
review is estimated to the amount of 32 000 EUR, to be paid to the IAEA as voluntary
contribution before the start of the mission. Denmark is aware that the review cost includes 7%
programme support costs.
If the actual cost of the ARTEMIS review exceeds the estimated voluntary contribution,
Denmark agrees to cover such additional cost to the IAEA. Similarly, if the actual cost is less
than the estimated voluntary contribution, any excess will be refunded to Denmark through the
MO Danish Health Authority
These Terms of Reference were agreed on 14 December 2021 between the IAEA and the
Danish Health Authority on behalf of the Ministry of Health, during the preparatory
meeting held on-line.
38
APPENDIX B: MISSION PROGRAMME
Time Sun, 1 May Mon, 2 May Tue, 3 May Wed, 4 May Thurs, 5 May Fri, 6 May Sat, 7 May Sun, 8 May Mon, 9 May
8h30 –
10h00
Arrival of
Team
Members
9h00 Opening
General
presentation
Inventory
Concepts, Plans
and technical
solutions
Cost estimates
and financing
Capacity
building
Finalization of
Recommenda
tions and
Suggestions
Drafting of the
report
Draft report to be
sent to the
Counterparts for
fact checking
Internal reflection
of comments
Discussions with
the Counterparts
on the draft report
Delivery of final
draft report
EXIT MEETING
10h00 -
12h00
National Policy
and Framework
12h00 -
13h00
Lunch Lunch Lunch Lunch Lunch Lunch Lunch
Departure of
Team Members
13h00 –
16h00
National
Strategy
Safety case and
safety
assessment
Site visit
Presentation
and
discussions of
Recommenda
tions and
Suggestions
with the
Counterparts
Drafting of the
report
Informing the
Counterpart
when the draft
report is to be
submitted for
fact checking
Counterparts
review the draft
report
Finalising draft
report
16h30 -
17h30
Artemis team
meeting
Team meeting Team meeting Team meeting
Social event*
(*- subject to
Counterparts)
Drafting of the
report
Drafting of the
report
Drafting of the
report
39
APPENDIX C: RECOMMENDATIONS AND SUGGESTIONS
Area
R:Recommendations
S: Suggestions
G: Good Practices
Recommendations, Suggestions or Good Practices
1.
NATIONAL POLICY
AND FRAMEWORK
FOR RADIOACTIVE
WASTE AND SPENT
FUEL MANAGEMENT
R1 The regulatory body should establish regulatory requirements and guidance
documents for the development and authorization of waste management facilities
in the different stages of their life-time (siting, design, construction, operation,
decommissioning or closure and post-closure, as applicable).
R2 The Government should ensure management of and control over all radioactive
waste and designate waste management organizations that are obliged to accept all
types of radioactive waste.
2.
NATIONAL
STRATEGY FOR
RADIOACTIVE
WASTE AND SPENT
FUEL MANAGEMENT
R3 The Government should update the National Programme in order to include
appropriate interim targets and end states for the monitoring of programme
implementation for all types of radioactive waste.
3.
INVENTORY OF
SPENT FUEL AND
RADIOACTIVE
WASTE
R4 In order to improve inventory data Danish Decommissioning should perform
nuclide specific measurements on the individual waste packages in the course of
transfer activities to a new storage facility, as appropriate.
40
Area
R:Recommendations
S: Suggestions
G: Good Practices
Recommendations, Suggestions or Good Practices
4.
CONCEPTS, PLANS
AND TECHNICAL
SOLUTIONS FOR
SPENT FUEL AND
RADIOACTIVE
WASTE
MANAGEMENT
R5 To ensure timely operation of the disposal facility the implementer should prepare
a comprehensive implementation plan consistent with the National Programme.
R6 The Government should establish a compliance assurance procedure for the
implementation of the National Programme.
R7 The implementer of the disposal facility should develop generic waste acceptance
criteria for disposal and -as soon as a facility specific safety case is available- final
waste acceptance criteria on the basis of regulatory body requirements.
6.
COST ESTIMATES
AND FINANCING OF
RADIOACTIVE
WASTE AND SPENT
FUEL MANAGEMENT
S1 As soon as a comprehensive implementation plan for the disposal project is
available, the Government should consider updating the corresponding cost
estimation and implement a procedure for periodic review and update. Risks and
uncertainties should be accounted for according to the stage of the project.
7.
CAPACITY BUILDING
FOR RADIOACTIVE
WASTE AND SPENT
FUEL MANAGEMENT
– EXPERTISE,
TRAINING AND
SKILLS
S2 Danish Decommissioning should consider establishing the strategic plan for
competence management according to the needs identified in the implementation
plan for development of the geological disposal facility, review and regularly
update it.
41
APPENDIX D: LIST OF ACRONYMS USED IN THE TEXT
ARM – Advance Reference Material
ARTEMIS – an Integrated Review Service for Radioactive Waste and Spent Fuel,
Decommissioning and Remediation
B48 – Parliamentary Resolution B48/2003 on the Decommissioning of Nuclear Facilities at
Risø Research Centre
B90 – Parliamentary Resolution B90/2018 on a Long-Term Solution for Denmark’s radioactive
waste
DD – Danish Decommissioning
DEMA – Danish Emergency Management Agency
DHA – Danish Health Authority
IAEA – International Atomic Energy Agency
IRRS – Integrated Regulatory Review Service
KPIs – key performance indicators
NOL – New Upgraded Storage Facility
VLLW – very low level radioactive waste
WAC – waste acceptance criteria
42
APPENDIX E: IAEA REFERENCE MATERIAL USED FOR THE REVIEW
[1] INTERNATIONAL ATOMIC ENERGY AGENCY, Fundamental Safety Principles, Safety
Fundamentals No. SF-1, Vienna (2006).
[2] INTERNATIONAL ATOMIC ENERGY AGENCY, Governmental, Legal and Regulatory
Framework for Safety, General Safety Requirements No. GSR Part 1 (Rev. 1), Vienna (2016).
[3] INTERNATIONAL ATOMIC ENERGY AGENCY, Leadership and Management for Safety,
General Safety Requirements No. GSR Part 2, IAEA, Vienna (2016).
[4] INTERNATIONAL ATOMIC ENERGY AGENCY, Radiation Protection and Safety of Radiation
Sources: International Basic Safety Standards, IAEA Safety Standards Series No. GSR Part 3, IAEA,
Vienna (2014).
[5] INTERNATIONAL ATOMIC ENERGY AGENCY, Safety Assessment for Facilities and
Activities, IAEA Safety Standards Series No. GSR Part 4, IAEA, Vienna (2009).
[6] INTERNATIONAL ATOMIC ENERGY AGENCY, Predisposal Management of Radioactive
Waste, IAEA Safety Standards Series No. GSR Part 5, IAEA, Vienna (2009).
[7] INTERNATIONAL ATOMIC ENERGY AGENCY, Decommissioning of Facilities, IAEA Safety
Standards Series No. GSR Part 6, IAEA, Vienna (2014).
[8] INTERNATIONAL ATOMIC ENERGY AGENCY, Disposal of Radioactive Waste, IAEA Safety
Standards Series No. SSR 5, IAEA, Vienna (2011).
[9] INTERNATIONAL ATOMIC ENERGY AGENCY, Safety of Nuclear Fuel Cycle Facilities, IAEA
Safety Standards Series No. NS-R-5 Rev. 1, IAEA, Vienna (2014).
[10] INTERNATIONAL ATOMIC ENERGY AGENCY, Nuclear Energy Basic Principles, Nuclear
Energy Series, NE-BP, Vienna (2008).
[11] INTERNATIONAL ATOMIC ENERGY AGENCY, Radioactive Waste Management and
Decommissioning Objectives, Nuclear Energy Series, NW-O, Vienna (2011).
[12] INTERNATIONAL ATOMIC ENERGY AGENCY, Nuclear Fuel Cycle Objectives, Nuclear
Energy Series, NF-O, Vienna (2013).
[13] INTERNATIONAL ATOMIC ENERGY AGENCY, Policies and Strategies for Radioactive Waste
Management, IAEA Nuclear Energy Series No. NW-G-1.1, IAEA, Vienna (2009).
[14] INTERNATIONAL ATOMIC ENERGY AGENCY, Policies and Strategies for the
Decommissioning of Nuclear and Radiological Facilities, IAEA Nuclear Energy Series No. NW-G-2.1,
IAEA, Vienna (2012).
[15] INTERNATIONAL ATOMIC ENERGY AGENCY, Policy and Strategies for Environmental
Remediation, IAEA Nuclear Energy Series No. NW-G-3.1, IAEA, Vienna (2015).
[16] INTERNATIONAL ATOMIC ENERGY AGENCY, Joint Convention on the Safety of Spent Fuel
Management and on the Safety of Radioactive Waste Management, IAEA International Law Series No.
1, IAEA, Vienna (2006).
[17] INTERNATIONAL ATOMIC ENERGY AGENCY, Safety Glossary – Terminology used in
Nuclear Safety and Radiological Protection, IAEA, Vienna (2018).
[18] Official Journal of the European Union No. L 199/48 from 2nd Aug 2011, COUNCIL DIRECTIVE
2011/70/EURATOM of 19 July 2011 establishing a Community framework for the responsible and safe
management of spent fuel and radioactive waste, Brussels (2011).