Regulation of Low Level Waste Management

This will cover….

Environment Agency role in implementing Government policy

Our approach to authorising more flexible routes introduced by the policy – existing landfills and new facilities on or adjacent to nuclear sites

Proposals to change authorisations to facilitate LLW transfers for treatment and disposal

Regulatory oversight of LLWR’s Environmental Safety Case

Our role in implementing Govt. Policy on LLW

Help ensure that it is properly implemented

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

Guidance – LLW disposal

Revised guidance, published Feb 2009

Applies to all near surface disposal:

Engineered facilities such as LLWR, near Drigg

New facilities on or adjacent to nuclear sites

Existing landfills

LLW disposal to landfills, and new facilities on or adjacent to nuclear sites

Government policy

2007 LLW Policy recognised:Disposals from to existing landfills

• High Volume - Very Low Level Waste (HV-VLLW)• Low Volume - Very Low Level Waste (LV-VLLW)• Controlled Burial of LLW

Disposal to facilities on or adjacent to nuclear sites

LLW disposal to landfill – LV-VLLW

LV-VLLW (‘dustbin disposals’)Status quo – well established

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

Not totally new – some small nuclear sites have had this type of disposal route for several years

We will treat all nuclear site VLLW disposals as ‘high volume’

Consignor and landfill operator must hold an RSA93 authorisation

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 authorised 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 disposal to sites on or adjacent to nuclear sites

Covers a wide range of possibilities:dedicated facility for LLW or disposal with non-active decommissioning wasteAbove or below HV-VLLW limits

Approach likely to be similar to that for ‘controlled burial’:

detailed radiological assessment may be necessaryproportionate use of specialist guidance (e.g. GRA)we may impose additional conditions in the authorisation

LLW disposal - consultation

Landfill site application for disposalLocal authority, HSE, 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

LLW disposals - expectations

We want to see appropriate consideration of non-radioactive properties in disposal decisions

For significant disposals, particularly from nuclear sites, we want to see an integrated waste strategy considering management options, proximity principle and climate change issues

Specific projects must represent the BPEO

LLW disposals – way forward

Interest:Three landfill operators are preparing applications for HV-VLLW or LLW controlled burial

First application expected soon

Information:Further guidance and FAQs on web pages

Application forms and radiological assessment guidance drafted

Early engagement with landfill operators being sought - we are advising now on content of applications

LLWR developments

Authorisation variations to facilitate treatment and disposal

Safety case review

LLW authorisation changes - context

Nuclear site authorisations only currently allow transfer of waste to LLWR for the purposes of final disposal

NDA National Nuclear LLW Strategy

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 metals, 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

Supports self-sufficiency for UK

Preserve LLWR capacity

Regulatory efficiency

Cost savings

LLWR Environmental Safety Case - update

Environmental Safety Case - update

Requirement of the LLWR authorisation

“Design, operation and closure of the facility must be in accordance with the Environmental Safety Case”

Last submitted 2002Currently safe, butAdequate case for continued disposal (beyond Vault 8) not made

Updated Environmental Safety Case being developed for May 2011

Environmental Safety Case - progress

Ongoing regulatory dialogue addressing key issues such as coastal erosion, site understanding and performance assessment

Considerable progress made since 2002

A number of comments and recommendations remain outstanding

Delivery of a fully robust and underpinned Environmental Safety Case, addressing all our recommendations by May 2011 will be challenging, but we consider it to be achievable

Environmental Safety Case - implications

LLWR are not authorised for disposal beyond Vault 8 (nearly full). Planning permission has been granted for storage in Vault 9 when constructed.

We will not authorise further disposals until a satisfactory Environmental Safety Case is produced and will continue to require an acceptable case to be produced for past disposals.

Following review of the 2011 updated Environmental Safety Case we will consider and consult on authorisation of further disposals around 2012/3.

Summary

The new LLW Policy offers increased flexibility to the UK nuclear industry

We need to ensure public confidence in the delivery of LLW management solutionsWe have prepared guidance on LLW disposal to landfill and facilities on or adjacent to nuclear sites

We are proposing to make some authorisation changes to facilitate application of the waste management hierarchy

The Environmental Safety Case for the LLWR due in 2011 has implications for future disposals

Clarification questions?