2. Regulation of Low Level Waste Management

3. 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

4. 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

5. 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

6. LLW disposal to landfills, and new facilities on or adjacent to nuclear sites

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. LLWR developments
Authorisation variations to facilitate treatment and disposal
Safety case review

16. 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

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 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

18. 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)

19. 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

20. LLWR Environmental Safety Case - update

21. 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

22. 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

23. 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.

24. 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

25. Clarification questions?