Proposed UK Strategy for the Management of Solid Radioactive Waste from the Non-Nuclear Industry Katherine Mondon – representing the Department of Energy and Climate Change (DECC) May 2009

Presentation will cover: Definition of the non-nuclear industry Description and quantity of the wastes Disposal options for the wastes and associated risks Why a UK strategy is needed for these sectors Who the strategy is aimed at; what does it comprise Sustainability appraisal Conclusions and next steps

The Non-Nuclear Industry 1) Organisations that handle radioactivity for specific purposes, and consequently produce radioactive waste, eg hospitals – located around the UK 2) Industries that create radioactive waste as a result of their operations ie oil and gas industries - hence mainly located in Scotland/North Sea. All are registered and/or authorised under the Radioactive Substances Act 1993 The following types of organisations handle radioactivity for specific purposes and consequently produce radioactive waste: Hospitals using radiopharmaceuticals for the diagnosis and treatment of disease; Pharmaceutical industry undertaking drug and technology development in specific areas of disease research Biotechnology industry undertaking diagnostic and life science research Universities, colleges and other research laboratories undertaking study and research using radioactive materials Veterinary medicine using radiopharmaceuticals for diagnosis and treatment of animal diseases Some industries create radioactive waste as a result of their operations ie oil and gas industries. Waste arising from extraction operations contains enhanced levels of naturally occurring radioactive material (NORM).

Non-Nuclear Industry Radioactive Waste Examples: plastics, paper, glass, metal, soil oil and gas industries – sludges and scales Majority of non-nuclear industry radioactive waste is Very Low Level Radioactive Waste (VLLW) and Low Level Radioactive Waste (LLW) Non-Nuclear Industry Radioactive Waste Similar in its physical and chemical nature to wide variety of other municipal, industrial and commercial wastes but contains radioactivity additional to that present naturally and unmodified in all the earth’s raw materials.

Quantities of Non-Nuclear Industry Radioactive Waste Routine data collection: LLW only and in terms of radioactivity Data on physical quantities from surveys: cover no more than about one third of industries holding RSA93 authorisations. Data for VLLW highly uncertain. Estimates from surveys in 2005/6: UK arisings of VLLW plus LLW - around 5,400 m3 per year, Plus incinerator residues (VLLW) at 42,000 m3/year. Routine data collection from waste producers by the Environment Agency is in terms of radioactivity in disposed wastes (eg becquerels per year via particular disposal routes). Surveys therefore have been undertaken to find out physical quantities but none have captured data from more than about 30% of industries holding RSA93 authorisations. Data for VLLW highly uncertain as it permitted to be put into ordinary rubbish bins by waste producers, hence estimates made in surveys may include entire rubbish bins from premises, and not just VLLW. Incinerator residues from RSA93 licensed facilities are classed as VLLW, and may include residues from some nuclear LLW combustion.

Total VLLW and LLW for England/Wales: 2008 survey covered 20% of 877 RSA93 authorisation holders Total VLLW and LLW for England/Wales: unlikely to exceed 50,000 m3/year Total quantity of M, C, I wastes across England: 272 million m3 /year Therefore non-nuclear wastes unlikely to exceed 0.02% of volumes of M,C,I wastes 2008 survey data (only covered about 20% of organisations that had RSA93 authorisations) VLLW: 46,550 m3 - nearly 90% from Scottish organisations Therefore total for all of the rest of UK could be up to around 26,300 m3 LLW: 4,798 m3 Therefore total for all of UK could be up to around 24,000 m3 Total VLLW and LLW for England/Wales unlikely to exceed 50,000 m3/year Total quantity of M, C, I wastes across England: 272 million m3 /year Therefore non-nuclear wastes unlikely to exceed 0.02% of volumes of M,C,I wastes Data on LLW and VLLW excluded from oil and gas industries, MoD and Northern Ireland waste producers.

Disposal options for non-nuclear industry wastes Incineration (dominates disposal of primary VLLW and LLW) Landfill (includes secondary VLLW as incinerator residues) Some LLW must go to Low Level Waste Repository near Drigg Waste producers: must have RSA93 authorisations from the Environment Agency to dispose of waste. Disposal facilities taking low volume VLLW: no requirement for RSA93 licence Facilities taking LLW and high volume VLLW: must have RSA93 licence Main disposal options are incineration and landfill ie using the same facilities as those for conventional wastes. Primary VLLW and LLW are wastes created by waste producers – most goes for incineration. Incineration of LLW along with large quantities of non-radioactive waste creates secondary VLLW as incinerator residues – mainly goes to landfill, some reused/recycled. Non nuclear industries have not yet produced any high volume VLLW. Indicative data from 2008 survey (dominated by Scottish data). The data are only from those who responded (ie from around 20% of waste producers) Incineration of LLW and VLLW: 50,200 m3 VLLW to landfill: 900 m3 LLW to landfill: 29 m3 LLWR near Drigg: 53 m3

Risks from non-nuclear industry radioactive waste disposals Health Protection Agency has contributed to the strategy document. Strategy includes a summary table of maximum radiation doses: to workers from proximity to, and handling wastes to the public from living near to disposal facilities All calculated doses are less than 20 microsieverts per year, which equates to a risk of dying of a cancer of one in a million Health Protection Agency advises UK Government on risks from radiation exposure. HPA has contributed to the strategy document. HPA has described what a radiation dose means in terms of risk. Doses to workers and members of the public are assessed by modelling the behaviour of radioactivity in landfill and in incinerated waste, and using a range of exposure scenarios.

Disposal of solid LLW and VLLW, and potential exposure scenarios Direct exposure and inhalation air Discharges to air Dust from day to day operations Contamination in air deposited on land Exposure from direct irradiation from surface of land Ingestion of crops/animals Leachate to soil Ash and air pollution control residues (VLLW) To landfill Behaviour of radioactivity in wastes sent for disposal is modelled: In case of incineration, the fate of radioactivity in gaseous and liquid discharges is modelled; In the case the case of landfill, the behaviour of radioactivity in leachate arising over long periods, and in dust from day to day operations is modelled. Radiation doses from a range of exposure scenarios are then calculated using conservative assumptions about people’s behaviour. Many radionuclides present in non-nuclear industry radioactive waste are very short lived. Reuse/recycling Combustible LLW/VLLW to incinerators Liquid discharges to watercourse Exposure due to reuse/recycling of incinerator residues Leachate to watercourse Non combustible LLW/VLLW to landfill Ingestion of drinking water

Why does the non-nuclear industry need a waste strategy? Industry has reported growing trend for fewer disposal facilities 2. Network of facilities for LLW is fragile – eg most RSA93 licensed incinerators operated by one company 3. The small volumes will not stimulate disposal market 4. Radioactive waste may deter waste facility operators 5. The diverse nature of the non-nuclear industry makes it difficult for it to act collectively – but the industry is vital to society During LLW policy consultation process, the industry reported a growing trend for fewer facilities being available, leading to greater transport (most hospital incinerators now shut down) Survey in 2006 confirmed that the network of facilities is fragile – eg most RSA93 licensed incinerators were operated by one company; at the time, only one incinerator took wastes containing alpha activity; there were virtually no landfills taking LLW as controlled burials. The small volumes of its radioactive wastes will not stimulate the supply of waste disposal facilities – the industry will always have to rely on facilities that exist primarily for other large volume wastes (oil and gas sectors are likely to be an exception). The fact that the wastes are categorised as radioactive may be a deterrent to some waste facility operators to accept these wastes. The diverse nature of the non-nuclear industry makes it difficult for it to act collectively to ensure it has disposal facilities in the future. But the industry is vital to society.

Summer 2007: Programme board set up to prepare strategy Membership: Hence, Government made a commitment via its 2007 LLW policy statement to prepare a non-nuclear industry waste strategy Summer 2007: Programme board set up to prepare strategy Membership: NDA Regional Technical Advisory Bodies (West Midlands and Yorkshire and Humberside) Environmental Regulators Waste producers Government departments and devolved administrations

Proposed strategy is aimed at: Non-nuclear industry waste producers Environmental regulators Waste planning bodies NDA and its site licensed companies Also relevant to: Members of the public Those operating conventional waste facilities. The strategy will also be of interest to members of the public involved in consultations on conventional and other waste disposal facilities. It is also relevant to those operating conventional waste facilities.

Information in strategy document covers : Descriptions of the non-nuclear industry Principles of radiation protection Regulation, definitions of waste categories and disposal options Summary of 2008 survey of waste producers The assessment of risk from disposal from the non-nuclear industry Strategy then sets out the roles of different organisations in helping to maintain disposal network The strategy has an important role in providing background information on the non-nuclear industry. The intention is to promote greater understanding of why these radioactive wastes are created, what the wastes comprise, how they are managed and what are the risks associated with their disposal. However, via the strategy, Government intends to reduce the fragility of disposal arrangements for the non nuclear industry. Government wishes to see existing disposal routes conserved and that other appropriate routes can be developed and expanded as necessary. Various organisations have roles to play in helping to maintain a UK-wide disposal network.

Proposed roles of the waste producers/regulators (i) Regarding RSA93 authorisations: - Further application of the waste hierarchy - For LLW disposals, explicit consideration of the principles of proximity and waste transport. Regulators also have an educational role: - Assisting waste producers understand their authorisations - Assisting waste disposal facility operators’ understanding of the nature of LLW and VLLW and their regulation Re RSA93 authorisations: the application of waste hierarchy is already embodied in LLW policy and implemented by the regulators via RSA93 authorisations, but some changes are proposed that could help waste producers apply the waste hierarchy further eg the manner of waste categorisation and use of decay storage on site EA has produced new guidance and briefing notes on LLW and VLLW disposal to landfill; background information in the strategy should also help waste facility operators understand the nature of LLW and VLLW.

Proposed role of the regulators (ii) EA databases on radioactive waste from the non-nuclear industry: Can these be amended to include physical quantities on a routine basis? Strategy urges regulators to ensure that they have the right contacts within local authorities for RSA93 consultations Environmental permitting for conventional waste facilities: description of waste on permits should not exclude low volume VLLW RSA93 applications received by the Environment Agency: EA sends copies of applications from waste producers to local authorities EA will consult on applications from waste disposal facility operators to take LLW and high volume VLLW Strategy urges EA to ensure that they have the right contacts within local authorities for these consultations. Environmental permitting for conventional waste facilities: Regulators should ensure co-disposal of conventional and low volume VLLW is not inadvertently excluded from waste disposal facilities because of the description of waste in the permits

Proposed coverage of non-nuclear industry waste within land use planning Planning Policy Statement 10: WPAs should address and plan for ALL relevant waste streams, including LLW Strategy sets out national waste management requirement for radioactive waste, which should be taken into account by WPAs Responsibilities of waste planning authorities vs environmental regulators are legally separate but inter-connected in practice Guidance is given to waste planning authorities on their responsibilities within the strategy

Proposed roles of WPAs (i) Low volume VLLW: Only waste producers have to hold RSA93 authorisations But WPAs should be aware that any disposal facility taking conventional waste may also be taking low volume VLLW Current arrangements for low volume VLLW fulfil Government policy but WPAs should be aware that any disposal facility taking conventional waste may also be taking low volume VLLW.

Proposed role of WPAs (ii) High volume VLLW and LLW: Waste producers require RSA93 authorisations and disposal facilities must have RSA93 licences. WPAs should be aware that existing and new disposal sites for conventional waste may apply to take LLW or high volume VLLW WPAs should make note in their Local Development Frameworks that disposal requirements for such wastes may arise from time to time Expectation is that the planning framework will be supportive of non-nuclear industry waste disposal needs High volume VLLW and LLW: Both waste producers and disposal facility operators require RSA93 authorisations. WPAs will therefore be aware of specific sites applying to take high volume VLLW or LLW. Detailed information on specific sites not currently available, but WPAs should make note in their Local Development Frameworks that disposal requirements for such wastes may arise from time to time. It will be up to waste planning bodies and WPAs to consider how they should cover the proposed generic requirements for high volume VLLW and LLW disposals when they prepare RSSs and LDFs. If an RSA93 application from a waste disposal facility operator to take these wastes is approved by the regulators, there is the expectation that the planning framework will be supportive.

NDA strategy may stimulate the supply of disposal facilities Connection between the non-nuclear industry waste strategy and the NDA LLW nuclear strategy NDA strategy may stimulate the supply of disposal facilities But strategy sets out NDA disposal routes and which situations are expected to benefit the non-nuclear industry: LLWR near Drigg and its successor 2) New sites that the NDA’s SLCs may develop for: controlled burial of nuclear LLW landfill for nuclear high volume VLLW new RSA93 licensed incinerators new facilities for decontamination/recycling of waste In all cases where NDA facilities might be made available to the non-nuclear industry: availability will have to be under appropriate commercial terms wastes will have to meet site specific and regulatory conditions wastes should not disproportionately constrain the capacity of the site for nuclear waste.

Sustainability appraisal – current position Discussion of the role of individual disposal sites not covered in proposed strategy – non-nuclear industry will nearly always rely on facilities primarily intended for other large volume wastes Annual risks from disposals of less than one in a million Hence Board decided that requirements of SEA Directive did not apply to the strategy But scoping report for Sustainability Appraisal undertaken – consultation in Jan/Feb 09. Table cross-references key issues identified in the scoping report on SA to aspects in the waste strategy.

CONCLUSIONS Proposed strategy provides information on wastes, and guidance on roles of various bodies to maintain disposal network Landfill and incineration are fit-for-purpose for most of the waste Non-nuclear industry is scattered around the UK and their disposals should be undertaken with due consideration of proximity and waste transport The planning frameworks should be supportive of non-nuclear industry waste disposals that are in line with regulatory requirements. Next steps – oil and gas still to be covered (consultation in autumn 09?)