Directive for radioactive waste and spent nuclear fuel

These commitments are assumed and promoted through this Directive so that all individuals, committees and levels of the organisation integrate, ensure and promote preferential attention to of the management of radioactive waste and spent nuclear fuel.

This radioactive waste and spent nuclear fuel Directive is consistent with the Iberdrola Group's Policies and materialises in the following basic principles for action:

• Pay due attention to all matters related to the treatment, storage and minimisation of radioactive waste and spent nuclear fuel, paying them the attention they deserve, owing to their importance.
• Comply at all times with the terms and conditions of the official authorisations and all requirements imposed by regulations, in order to attain more demanding levels through self-regulation.
• Establish an organisation with adequate design, capacity, functions, responsibilities, qualifications, expectations and resources for implementing this Directive and for fulfilling current legal funding obligations.
• Ensure that the original design of the radioactive waste and spent nuclear fuel treatment and storage facilities and their updating meets the accepted standards, agrees with current design and licensing specifications, and maintains adequate control of the facility's configuration, of the safety margins and of the principles of 'defence in depth'.
• Encourage the involvement and commitment of all individuals at all levels to radioactive waste and spent nuclear fuel treatment, storage and minimisation through their individual responsibility, exemplary conduct, teamwork, qualification and ongoing training, within a work environment that creates a favourable atmosphere for reporting deficiencies or opportunities for improvement and fosters swift resolution of incidents, fostering the highest levels of safety culture and respect for the environment.
• Implement, as parts of the integrated management system, processes, internal rules and supervision systems that contribute to attaining the desired conduct in favor of radioactive waste and spent nuclear fuel treatment, storage and minimisation, and assess the processes, rules and systems in order to achieve ongoing improvement. Stagnation and complacency are considered to lead to declining performance in the area of safety; however, self-criticism and organisational learning are vital elements for improving management.
• Measure the results in the area of safety through a system of indicators based on best international practices, providing the resources needed to achieve demanding goals related to those indicators, and oversee the application of this Directive through the body responsible for independent internal nuclear supervision.
• Follow previously approved operating procedures inspired by the principles of prevention, surveillance and mitigation, oversee strict compliance with those principles and develop a dynamic of ongoing improvement through the feedback of usage experience, in both normal operation conditions and in emergencies.
• Maintain the traceability of radioactive waste and spent nuclear fuel and of the connections and dependencies across all treatment phases.
• Guarantee the physical protection of nuclear materials which may be diverted for illicit use while they remain in the facility under the responsibility of the holder of the operating authorisation or license.
• Establish a “prudent operational decisions” system that guarantees that the important issues for radioactive waste and spent nuclear fuel treatment and minimisation are treated with rigor, prudence, diligence and by competent individuals or bodies, with the involvement of those which can add value to the decision-making process, paying special attention to emerging matters of a multidisciplinary nature.
• Make the most of own and third-party operating experience for preventing incidents through the establishment of an efficient process for exchanging experiences and for analysing causes, and participate actively in the industry's international bodies through an exercise of peer comparison and evaluation, promoting a healthy emulation of the best.
• Extend the criteria related to radioactive waste and spent nuclear fuel treatment, storage and minimisation to the suppliers of goods and services through contractual clauses, quality assurance audits, certifications, training, operating procedures, supervision and teamwork at the facilities.
• Disseminate relevant and truthful information on the activities carried out and promote communication and dialogue with the various stakeholders.
• Cooperate with the competent authorities in the exercise of their supervision, regulation and public information functions, as guarantors of international commitments in countries where the facilities are located, and contribute to the improvement and optimisation of the regulatory framework.
• Maintain a long-term vision of radioactive waste and spent nuclear fuel treatment and minimisation through research, development and innovation, with participation and promotion in international forums and in organisations devoted to safety knowledge and improvement of radioactive waste and spent nuclear fuel management.
• Apply this Directive as one of the criteria for selecting technologies in the case of new nuclear power plant projects.

The guiding principles and policy directives for the management of radioactive waste and spent fuel in Iberdrola Generación Nuclear are:

• Responsibility as a producer, from waste generation until it is transferred to ENRESA or the applicable disposal responsible entity. In the case of fuel, it becomes waste after irradiated in the reactor core; nevertheless Iberdrola Generación Nuclear takes responsibility for it once the fresh fuel is delivered on the sites.
• The radiation protection of public and workers during:
  • The internal management.
  • The transfer to other stages and, when appropriate,
  • the decommissioning phase which goes from the time the plant is definitely shutdown until the site is transferred to ENRESA or the applicable entity.
• The traceability of waste and the operations of management of radioactive waste.
• Knowledge and control of the flow of waste and spent fuel and the evolution of their chemical, physical and radiological characteristics.
• As far as reasonably possible from a technical and economic standpoint:
  • The reduction of generated radioactive waste and spent fuel to the minimum quantities and the radioactive waste management, applying the best available techniques and technologies depending on the type of reactor.
  • The separation and recovery of the waste materials.
  • The security of the interdependence of all phases of management.

Throughout the radioactive waste treatment processes and the spent fuel management, Iberdrola Generación Nuclear applies the criteria ALARA (as low as reasonably achievable) to maintain the individual doses, the number of exposed people and the likelihood of potential exposure at levels as low as reasonably achievable, taking into account economic and social factors. The management of radioactive waste also employs the cycle of continuous improvement, the key steps of which are: planning, implementation, evaluation, and management of:

• Preventive and corrective actions.
• Actions for improvement.

For new build, one of the criteria for technology selection will be the expected operational waste generation, which is predicted by design, taking into account both volumes and radioactivity involved.

These principles are applied to all Iberdrola Generación Nuclear facilities and all types of radioactive waste that can be generated, including those corresponding to plant dismantling when Iberdrola Generación Nuclear has the responsibility. The storage areas are aim to be operated following best practice to achieve the safest and most secure store for the entire length of the storage life until transfer to ENRESA or the waste management company.