SAFESPUR FORUM - Challenges in reducing the burden on the UK’s national Low Level Waste Repository
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Transcript of SAFESPUR FORUM - Challenges in reducing the burden on the UK’s national Low Level Waste Repository
SAFESPUR FORUM - Challenges in reducing the burden on theUK’s national Low Level Waste
Repository
29 April 2009, Birchwood
Environmental regulations forradioactive waste management anddecommissioning
Colin Hardman,Environment Agency
The Basics
Clean Technology and Best Practicable Means to minimise wastes
RSA-93 Authorisation Limits to protect against discharges
Requirements of other regulations (Environmental Permitting / PPC) and regulators (HSE / NII)
Integrated waste strategy, Waste hierarchy
Storage, management, decommissioning – minimise secondary wastes; LLW Management Plan
“We’ve met all EA’s and HSE’s on-site requirements – now we need to make some disposals of ….
- general rubbish from “active” area- contaminated equipment- metal, plastic, wood, clothing, rags- organic liquids / oils- radioactive residues”
Our response …
Have you got a route ?Is the waste receiver authorised to dispose ?Do you think you can make a case for your preferred routes being best overall for the environment ?
Then by all means submit an application!
Availability of Routes
Landfill sites NOT holding RSA Authorisation: can accept LV-VLLW – but not from nuclear sites
Landfill sites wishing to co-dispose of radioactive and non-radioactive wastes – some applications expected soon
LLWR near Drigg – limited space
Other facilities (including treatment and incineration)
2007 Government LLW policy
Our role to help ensure it’s implemented properlyRecognised disposals to existing landfills -
• Low Volume - Very Low Level Waste (LV-VLLW)• High Volume - Very Low Level Waste (HV-VLLW)• “Controlled Burial” of LLW
Ensure that plans are informed by assessment of potential radiation exposures and risks
Upper limits to exposures and risks are the same for all types of radioactive waste disposal sitesLower levels of controls needed for less active wastes
LLW disposal to landfill – LV-VLLW
LV-VLLW (‘dustbin disposals’)Status quo Non-nuclear origin (hospitals, universities etc.)< 50 m3/yNo controls on radwaste aspects after leaving consigning siteFrom research we are satisfied there is no risk to human health or the environment
LLW disposal to landfill – HV-VLLWWe will treat all nuclear site VLLW disposals as ‘high volume’
Landfill operator must hold RSA93 authorisation as well as consignor
Radiological impact assessment required for any proposed landfill siteA simple assessment, referring to published research, may well sufficeIf not we would expect proportionate application of our ‘GRA’ guidance
If authorising, we would set an upper mass / volume limit, but generally would not include conditions on how the waste is managed on site. We will focus on:
Adequacy of management systemsRecords
LLW disposal to landfill – ‘Controlled Burial’
As HV-VLLW except:Activity of any given volume of waste will be higherA more detailed radiological assessment will be necessary, making proportionate use of specialist guidance (e.g. GRA)We may impose additional conditions to ensure impacts are controlled
LLW disposals - expectations
Non-radioactive properties must be taken into account, both in the consignor’s waste management plan AND in the disposal site’s environmental assessment
For significant disposals, particularly from nuclear sites, we want to see evidence of an integrated waste strategy, optioneering to identify the BPEO, consideration of the proximity principle, and potential impact of climate change
“GRA” Guidance – LLW disposalRevised Feb 2009, applies to:New, near-surface facilities, operating solely for disposal of solid radioactive waste, including dedicated facilities for large volumes of VLLW;Engineered facilities such as LLWR, Drigg;New facilities on or adjacent to nuclear sites.
Applicants for co-disposal of LLW or HV-VLLW at existing landfills will also find useful
Other sources of guidanceEnvironment Agency Guidance Note – see http://www.environment-agency.gov.uk/static/documents/Business/LLW_guidance_note_on_brand.pdf
Environment Agency Questions-and-Answers brief - see
http://www.environment-agency.gov.uk/static/documents/Business/LLW_QA_FINAL.pdf
Contact your local Environment Agency Office
LLW disposal - consultation
Landfill site application for disposalLocal authority and HSE, also FSA if relevantLandfill operator must lead on stakeholder liaison - we are happy to support, explaining our role
Nuclear site applications for transfers to landfill or on-site disposals - as per our existing arrangements
This will change when EPR introduced in 2010
What else are we doing ?LLW authorisation changes
We think our current authorisations could be made more flexible, offering benefits without increasing environmental risks
Nuclear site authorisations only currently allow transfer of waste to LLWR for the purposes of final disposal
NDA National Nuclear LLW Strategy being developed
LLWR innovation proposals:Encourage segregation at source and offer waste treatment servicesShort-term handling of small volumes of packaged waste via LLWRApplication to transfer metals to Studsvik Metals Recycling Facility for treatment
Studsvik Metals Recycling Facility (MRF) opening this summer
LLW authorisation changes - proposals
To authorise all nuclear sites in England and Wales:
To transfer metals to the Studsvik Metals Recycling Facility for treatmentTo transfer combustible LLW and HV-VLLW to LLWR for the purposes of transfer elsewhere for treatment or alternate disposal in more appropriately engineered facilities (e.g. landfill)
We are currently consulting on these proposals
All Nuclear Sites (England and Wales)
Metals Recycling Facility, Lillyhall
LLWR New route(metals)
LLW authorisation changes - overview
New route for all sites (metals)
Transfers for disposal or onward transfer (metals, HV VLLW, combustible
wastes
Future facilities
(HV VLLW)(combustible wastes)
LLW authorisation changes - benefits
Support application of the waste management hierarchy
Encourages moves to waste segregation
Encourage transfers to treatment facilities for recycling
Preserve LLWR capacity
Cost savings
SummaryWe know of three landfill operators preparing applications for disposal of HV-VLLW or LLW, and expect the first application soon
We are proposing to make some authorisation changes to facilitate application of the waste management hierarchy
Information is available:Further guidance and FAQs, also GRA, on web pagesApplication forms and radiological assessment guidance draftedRecommend landfill operators to engage with us early - we are advising now on content of applications
Clarification questions ?