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

NOT PROTECTIVELY MARKED67. Effectively, if the guidance is followed, it is expected that the RWMC will demonstratecompliance with the law as interpreted by the regulators at the time of writing of theguidance. Traditional safety cases focus on the safety of an individual plant to conduct itsmission whilst an RWMC is intended to focus on the waste material(s) that may beprocessed through multiple plants that each has their own safety case. The guidancesuggests that the RWMC brings together various considerations including:• BAT• The impact that management of this waste stream may have on the plant, process,site safety and environment;• Proposals for storage and monitoring of waste condition;• Arrangements for preservation of data relating to this waste stream;• Integrated Waste Strategies;• Disposability of the Product.68. Whilst the RWMC may be considered part of the conventional safety case for wastemanagement facilities, many such plants became operational or waste conditioning planswere developed before it was a requirement. In such cases the RWMC needs to beproduced retrospectively; the guidance suggests that review of an RWMC should beundertaken alongside the periodic review of related plant Safety Cases. RSRL issystematically producing RWMCs for each of the relevant waste streams. The RWMCs arereviewed by the Waste Strategy team and relevant project managers. They are kept as partof the appropriate project file and can be made available to RWMD, HSE and EA asrequired.Best Available Technique (BAT) Assessments69. The Statutory Guidance requires the Environment Agency to base its regulatory decisions inrelation to discharges of radioactive waste into the environment on the principles set out inthe 2009 UK Strategy. These principles include the use of BAT as the means the operatoruses to achieve an optimised outcome. The term BAT means the latest stage ofdevelopment (state of the art) of processes, of facilities or of methods of operation whichindicate the practical suitability of a particular measure for limiting discharges, emissionsand waste. The use of BAT replaces “best practicable means” (BPM) and “best practicableenvironmental option“(BPEO), and is expected to deliver the equivalent level ofenvironmental protection as achieved previously by the use of BPM and BPEO.70. RSRL has recently undertaken high-level strategic BAT reviews for metallic LLW, WinfrithLA-LLW / VLLW and “soft-solid” LLW (formerly this was referred to as “combustible LLW”however as there are a number of treatment options available for this type of secondarywaste the term “combustible” LLW is no longer appropriate). These reviews includedreassessment of the underlying assumptions and decisions taken at the time of the originalBPEO studies. A representative from LLWR Ltd attended each of the reviews.Radioactive Low Level Waste (LLW) Policy71. In March 2007 the Government published the policy 13 for the long term management of solidlow level radioactive waste. The overall aim of the policy was to set out the need for greaterflexibility in managing LLW and set out a number of requirements for the NDA includingdevelopment of a UK nuclear industry LLW strategy and developing a plan for the optimumuse of LLWR. Following a period of consultation, NDA issued the UK Strategy for theManagement of Solid LLW for the Nuclear Industry in August 2010. The strategy13 Policy for the Long Term Management of Solid Low Level Radioactive Waste in the UKRSRL IWS (Issue 5 – October 2012)22