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

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 waste Above or below HV-VLLW limits Approach likely to be similar to that for ‘controlled burial’: detailed radiological assessment may be necessary proportionate use of specialist guidance (e.g. GRA) we may impose additional conditions in the authorisation

LLW disposal - consultation Landfill site application for disposal Local 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 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 HV-VLLW disposal to landfills Presumption to early solutions Proximity principle as a point of reference NDA National LLW Strategy development Preserve LLWR capacity by increased recycling, disposal to appropriately engineered facilities and increased application of the waste management hierarchy

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 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

LLW authorisation changes - overview Future facilities Metals Recycling Facility, Lillyhall (HV VLLW) (combustible wastes) LLWR New route (metals) Transfers for disposal or onward transfer (metals, HV VLLW, combustible wastes New route for all sites (metals) We want to minimise the number of transfers via the LLWR, we will work with operators and other regulators to achieve this Initially we propose not to allow transfers of combustible LLW or HV-VLLW via the LLWR, until a site specific case is made We will place strict volume limits on any HV-VLLW transfers via the LLWR Should other treatment facilities, offering clear environmental benefits, become available we would consider authorising transfers in a similar manner to that proposed for the Metals Recycling Facility We expect operators to continue to seek the best environmental option for wastes - these proposals in no way preclude other options All Nuclear Sites (England and Wales)

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 2002 Currently safe, but Adequate 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 solutions We 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?