Penfold J, Pearce S, Batandjieva B and Sinclair P, Development of ...

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Therefore, in recognition of the current status of the LLWR, the strategies that areidentified are broad alternatives, representative of different approaches that couldcontribute to reducing post-closure risks. The advantages and disadvantages of each ofthe strategies are outlined, in the context of the existing Reference strategy. Theoutcome of this systematic analysis provides information to support the futureselection of an Institutional Control Strategy, which is likely to draw on elements fromeach of the strategies identified here.Requirements and Functions of Institutional ControlIn order to understand what is needed from an Institutional Control Strategy, thepresent-day context of the LLWR is set out and a review of the main regulatoryrequirements that relate to institutional control for the LLWR is provided. Theserequirements arise from a number of perspectives (and a number of regulators),although the most detailed requirements are set out in the EA’s Guidance onRequirements for Authorisation for Near-Surface repositories (NS-GRA). The recentupdate of that guidance includes significant developments since the version that wasaddressed by the 2002 PCSC. This is particularly relevant as it was duringdevelopment of the 2002 submissions that the existing baseline Institutional ControlStrategy was principally defined. Some of the most significant developments inregulatory guidance include greater emphasis on justifying the Institutional ControlStrategy, demonstrating that it is soundly based, contributes to optimisation, and isunderpinned by an appropriate rationale. In addition, consistency with therequirements set out by other regulators is an important consideration, such as the wayin which Nuclear Site Licence conditions would be fulfilled.Best-practice guidance arising from experience from other facilities and industries alsoprovides important input into the strategy development process. Whilst regulatoryrequirements have developed over recent years, practical experience has onlygradually been gained. Probably the most relevant case for LLWR is Centre de laManche. This is notable for demonstrating a successful construction of a cap, withcontinued monitoring and leachate collection, in a manner similar to the existing plansfor the LLWR. The site also has some similarities with the LLWR, inasmuch as wasteshave been disposed historically to different standards than those applied today. Thereis limited experience from other sites because they are under significantly differentforms of regulation (e.g. US and Russia) or because the sites are still operational or yetto fully enter Institutional Control.ii
QRS-1443T-1, Version 1Development of Alternative StrategiesExamination of the requirements derived from appropriate contextual, regulatory andbest-practice considerations has identified five main themes that need to be addressedwithin the Institutional Control Strategy:Optimisation – ensuring that the strategy is optimised in respect of environmentalsafety performance;Implementation Capability – providing confidence that the strategy is capable ofimplementation;Information Management – demonstrating that key information is being retainedover the period of interest;External Factors – ensuring that the effects of Institutional Control beyond the siteboundary are considered; andPassive Control Requirements – putting arrangements in place to maximise thebenefit from passive controls after the period of management.Guidance such as the NS-GRA is also clear about what should be expected to be themain functions of Institutional Control. These are:Identification and Control of the Site;Site Surveillance;Monitoring; andRemedial Capabilities.Together, the above requirements and functions have been used to systematicallyidentify the range of activities that could form an Institutional Control Strategy, andtherefore used to generate several illustrative strategies that are relevant to the LLWRsite. The illustrative strategies were designed to help gain understanding of the mainissues to consider, with the intention that a suitable Institutional Control plan for theLLWR can then be devised from a combination of their features.The illustrative strategies include:The Reference strategy (as defined in 2002 PCSC) and the Modified Referencestrategy (including updates to address regulatory requirements and feedback since2002) which were primarily used to provide a point of comparison;iii
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