2. SAFESPUR FORUM - Challenges in reducing the burden on the UK’s national Low Level Waste Repository 29 April 2009, Birchwood

3. Environmental regulations for radioactive waste management and decommissioning Colin Hardman, Environment Agency

4. 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

5. “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”

6. 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!

7. 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)

8. 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

9. LLW disposal to landfill – LV-VLLW LV-VLLW (‘dustbin disposals’) Status quo Non-nuclear origin (hospitals, universities etc.) < 50 m 3 /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

10. 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 site A simple assessment, referring to published research, may well suffice If 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 systems Records

11. 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

12. 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

13. “GRA” Guidance – LLW disposal Revised 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

14. Other sources of guidance Environment Agency Guidance Note – see http://www.environment- agency.gov.uk/static/documents/Business/LLW_guidance_note _on_brand.pdf 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.pdfhttp://www.environment- agency.gov.uk/static/documents/Business/LLW_QA_FINAL.pdf Contact your local Environment Agency Office

15. LLW disposal - consultation Landfill site application for disposal Local 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

16. 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 services Short-term handling of small volumes of packaged waste via LLWR Application to transfer metals to Studsvik Metals Recycling Facility for treatment Studsvik Metals Recycling Facility (MRF) opening this summer

17. LLW authorisation changes - proposals To authorise all nuclear sites in England and Wales: To transfer metals to the Studsvik Metals Recycling Facility for treatment To 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

18. 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)

19. 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

20. 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 pages Application forms and radiological assessment guidance drafted Recommend landfill operators to engage with us early - we are advising now on content of applications

21. Clarification questions ?