RSRL Integrated Waste Strategy - Issue 5- Oct 2012.pdf

NOT PROTECTIVELY MARKEDRadioactive Low Level Waste (LLW) PolicyAs previously discussed, the Government issued its new policy for the long term managementof solid low level radioactive waste in March 2007. The policy updated Cm2919 in:• Allowing greater flexibility in managing in the wide range of LLW that already exists andwill arise in the future, proposing that a risk based approach is used in selecting disposaloptions;• Giving NDA the remit for creating a UK-wide strategy for managing low level waste fromthe nuclear industry, including at what point in the future a replacement (orreplacements) for the national disposal facility near Drigg in Cumbria (LLWR) might berequired and planned;• Permitting export of LLW to other OECD and EU countries for the recovery of re-usablematerials, or for treatment that will make its subsequent storage and disposal moremanageable where this has been demonstrated and authorised as the best practicableoption.The policy also gave new definitions for the lower activity end of the LLW, namely givingthe two new categories of Low Volume and High Volume Very Low Level Waste (VLLW).The activity of High Volume VLLW can be up to 4Bq/g except for tritium which is allowedup to 40Bq/g.RSRL is represented at the LLW Steering Group which continues to take forward theUK-wide strategy for managing LLW for the NDA and hence maintains awareness ofdevelopments which may impact on the management of LLW at the RSRL sites. TheNDA issued the UK Strategy for the Management of Solid LLW for the Nuclear Industryin August 2010 and this supports the use of off-site waste disposal routes for Harwelland Winfrith VLLW and HV-VLLW.Dedicated disposal facilities may be developed solely for LLW or HV-VLLW. These maybe situated on or off nuclear sites. An operator of such a site will need to hold anenvironmental permit for disposal of radioactive waste. The Environment Agency shouldalso consider the non-radiological impact of the radioactive waste being disposed of andmay place conditions in the environmental permit in relation to such non-radiologicalproperties.These Regulations have removed the previous requirement under RSA 93 thatapplications for disposal are sent to the Local Authorities where it is proposed to sendwaste for disposal. As a result it is not necessary for permits to identify specific site(s) atwhich the waste will ultimately be disposed of. Permits allow the transfer to any sitewhere the operator of that site holds an environmental permit to accumulate or disposeof the relevant type of waste, or for HV-VLLW to any site disposing of conventionalwaste. However, the Environment Agency may identify specified sites in permits asnecessary to meet the requirements of Government policy, for example to deliver therequirements of the proximity principle and the waste hierarchy. Records of wastetransfers must be kept by both the consignor and the receiving site operator.Other Regulatory ConstraintsThere are no licence instruments or improvement notices on waste management issues ateither RSRL site. RSRL has however recently received an improvement notice relating tocontrol of work, supervision and training and this is due to be closed out by December 2012.RSRL IWS (Issue 5 – October 2012)115