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 properly

Recognised 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 sites

Lower 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/y

No controls on radwaste aspects after leaving consigning site

From research we are satisfied there is no risk to human health or the environment

LLW disposal to landfill – HV-VLLW

We 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 higher

A 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 guidance

Environment 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 relevant

Landfill 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

Summary

We 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 ?