1. Introduction to VLLW Disposal Services1 1

2. Introduction to VLLW Disposal Services
Alex McCarthy, Waste Services Contract Manager 2 2

3. Objectives Establishing the Service,
Establishing the service and managing nuclear liability
Our service summarised
Introduce the service and how it will work,
Key documents in the Waste Services Contract
VLLW Staged Project Delivery
Service development,
Near term service development
Medium / Long term service development

4. 1a. Establishing the service and managing nuclear liability
Supply Framework established following a competitive tender exercise
Customers access service through the Waste Services Contract (v3)
Special Conditions manage the specific needs of this service
Problem: How to manage the transfer of Nuclear Liability for SLCs
Reduce burden on SLCs for managing VLLW disposed at other sites
Provide clarity on who holds liability after waste disposed
Reduce risk of multiple tenuous claims
Our solution: LLWR acts as channelling entity
Single SLC acting as the liable Party
Amended Insurance Policy in place
Service specific delivery process

5. 1b. Our service summarised
Delivered using the Waste Services Contract (v3)
LLWR will accept the nuclear liability via relevant carriage, and our approach reflects this
The Waste Acceptance Procedure will apply with a customised consignment stage
Gated project development and delivery model
Onsite witnessing required

6. 2a. Key documents in the Waste Services Contract
Waste Acceptance Criteria
Relating to the Waste Acceptance Procedure
Compliance Dossier
QP037 Quality Plans for project and consignment specific
Waste Transfer Forms for each load

7. 2a. Key documents in the Waste Services Contract
VLLW Waste Acceptance Criteria
An overview document describing the VLLW Service as a whole
Common format
Selected points from WAC
Physical and Chemical Properties
Packaging and Transport Requirements
Radiological Properties

8. 2a. VLLW WAC - Summary Waste Treatment and Segregation (V1)
Waste should not be consigned for disposal if reasonably practicable measures could be adopted to reduce the final volume requiring disposal.
Where waste is not selected for treatment, acceptance will require Suitable Supporting Justification to be provided.
Approved Waste Packages and Transport Containers (V3)
Waste for Very Low Level Waste disposal may be consigned to LLW Repository Ltd or the Service Suppliers in a wide range of Waste Packages and Transport Containers.
The acceptable range of Waste Packages includes 210 litre Drums and Soft Sided Packaging. 

9. Specific Activity (MBq/t)
2a. VLLW WAC – Summary
Radioactivity Limits (V2)
Service Supplier specific criteria for Activity limits apply for Low Activity Low Level Waste and Very Low Level Waste. Specific restrictions will be determined through the Waste Enquiry Process. However, the following criteria provide a general guide:
Table 1: Specific Activity Limits
Radionuclide
Specific Activity (MBq/t)
Acceptable
Likely to be Accepted
All
<4
<200
Tritium
<40

10. 2a. Compliance Dossier
It is the collected evidence gathered to demonstrate compliance with all necessary rules, regulations, and permits in delivering the disposal service
Compliance Dossier divides all evidence and activities into six distinct stages, which are,
Project Initiation
Service Definition
Consignment Preparation
Project Execution (Consignment and Disposition)
Audit Reports
Communications and Notifications
Designed for our initial projects

11. 2a. Quality Plan – QP037 Comprises two sections,
QP037A Covers project activities at Pelham House (Stage A, B, C, E, and F)
QP037B Covers individual load activities in the field (Stage D)
Confirms that specified activities have been completed and evidence has been gathered
Structure mirrors the Compliance Dossier template
Further guidance at under Logistics Services – VLLW / LA-LLW Transport Guidance Note - PAA/GN06

12. 2a. Waste Transfer Form Expected VLLW service characteristics,
Large volume, low activity
High number of consignments per project
Commonality between individual consignments
Potential for increased administrative burden
Needed to evolve to maintain quality whilst reducing paperwork
Need to align with new Service Providers
Small number of Over-arching WCI Forms (Parent)
Numerous Waste Transfer Forms (Children)

13. 2b. VLLW Staged Project Delivery
STAGE A
Project Initiation
WEN
BAT
EPR / RSA
WCH
Analyses
Upon approval proceed to Stage B
Waste Management Services

14. 2b. VLLW Staged Project Delivery
STAGE B
Service Definition
WSQ RA
MSDS
Consign model
Pre-acceptance
Programme
Activity assess
Upon approval proceed to Stage C
Waste Management Services

15. 2b. VLLW Staged Project Delivery
STAGE C
Consignment Preparation
Verification
Compliant
with WAC
Loading
Transport
WAC
Packaging
/ b / g
assessed
Variations
Upon approval proceed to Stage D
Waste Management Services

16. 2b. VLLW Staged Project Delivery
Project Execution
Pre-loading
Consigning document
Dispatch procedure
Disposal
Loading
Waste
Transfer form
Acceptance
Ongoing
Monitoring
Evidence gathered during delivery
Waste Management Services

17. 2b. VLLW Staged Project Delivery
Stages that cover entire lifecycle
Section E: Audit Reports
Duty of Cares, Transport Audits, Audits required by Service Provider or Customer
Must be completed before progression to Stage D
Section F: Communications and Notifications
Regulatory / Authority notifications
Stakeholder communications
Check of whether new comms plan is required (determined according to project)
Must be completed after Stage A, but before Stage D
Waste Management Services

18. 2b. VLLW Staged Project Delivery
LLWR witnessing schedule defined per project
The minimum requirements for witnessing are,
the packaging of waste for the first consignment
the loading of packages onto the conveyance for the first consignment, and subsequently for any change to the WLP
the despatch monitoring of packages for first consignment
the transport consignment of waste for the first consignment and any changes in radiological transport classification
Receipt of waste at landfill for the first consignment
Disposal of the first consignment
LLWR is observing not supervising
LLWR control through paperwork approvals
Waste Management Services

19. 3a. Near Term Service Development
Deliver the service safely and responsibly
Live projects
1 project currently at execution stage (LLWR Service Commissioning Project)
Several projects at preparatory stage (Normal business)
Open up all new disposal routes
React to Customer Waste Enquiries

20. 3b. Medium / Long Term Service Development
Medium term (12 – 18 months)
Analysis of Waste and Inventory Data – identify opportunities
Early and targeted engagement at the decommissioning stage
Long Term (2 – 5 years)
Changes to the Paris and Brussels Conventions on Nuclear Third Party Liability – 2011 Public Consultation
Decoupling of Licensing and Liability
Application to remove the need for licensing for LLW Disposal sites
Open up the market and remove LLWR from channelling role

21. Recap of Objectives Establishing the Service,
Establishing the service and managing nuclear liability
Our service summarised
Introduce the service and how it will work,
Key documents in the Waste Services Contract
VLLW Project Delivery
Service development,
Near term service development
Medium / Long term service development

22. Key Points
Contact your Service Delivery representative for more information
Access the service via the Waste Services Contract (if required)
Service will involve LLWR site witnessing and greater planning than normal
One key issue is stakeholder perception of risk
Our priority is safe and responsible development and delivery of the service
Programme and price follow this

23. Questions?