regulation of low level waste management this will cover…. environment agency role in implementing...
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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?