NDA Low Level Waste: - Nuclear Decommissioning Authority

Guidance on authorisation and licensing issues associated to new disposal routes ...................................46Review of Exemption Orders under the Radioactive Substances Act.........................................................46Phase II of the Environmental Permitting Programme................................................................................476.3.3 New Nuclear Build ........................................................................................................................................476.3.4 Contaminated ground ...................................................................................................................................476.4 Classification of waste and the importance of a robust inventory.......................................................................486.5 Research and Development .............................................................................................................................496.6 Sharing good practice ......................................................................................................................................497 Risks, opportunities and contingency plans..........................................................................................................517.1 Risks................................................................................................................................................................517.2 Opportunity: National LLW Management Plan ..................................................................................................547.3 Contingency planning.......................................................................................................................................577.3.1 Contingency 1 – development of facilities by NDA.........................................................................................587.3.2 Contingency 2 – development of a successor facility to LLWR ......................................................................588 Next steps ...........................................................................................................................................................608.1 Summary of consultation questions ..................................................................................................................60Appendices ........................................................................................................................................................................63Appendix 1 - The National LLW Strategy Group ............................................................................................................63Appendix 2 - Regulation of LLW ....................................................................................................................................64Appendix 3 - References ...............................................................................................................................................66Appendix 4 - Glossary ...................................................................................................................................................67Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 6

1 IntroductionConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 7

1.1 Government’s Policy for the managementof solid LLW in the UKIn March 2007 the UK Government and devolvedadministrations (for Scotland, Wales and NorthernIreland, from here on referred to as ‘Government’)published their policy for the management of solidlow level waste (‘the Policy’). The Policy sets out anumber of core principles for the management oflow level waste (LLW). This proposed strategy hasbeen developed within the framework of theprinciples set out in the Policy:• use of a risk-informed approach to ensuresafety and protection of the environment• minimisation of waste arisings (both activityand mass)• forecasting of future waste arisings, basedupon fit for purpose characterisation ofwastes and materials that may becomewastes• consideration of all practicable options forthe management of LLW• a presumption towards early solutions towaste management• appropriate consideration of the proximityprinciple and waste transport issues• in the case of long term storage or disposalfacilities, consideration of the potentialeffects of future climate changeThe overall aim of the Policy was to set out theneed for greater flexibility in managing LLW,recognising that previous Government policy wasnot developed to take account of large scaledecommissioning and environmental restoration.The Policy also sets out a number of requirementsfor the NDA, including:• develop a UK nuclear industry LLWstrategy• work with Government to ensure alignmentwith the UK non-nuclear industry LLWstrategy• develop and publish a plan for the optimumuse of LLWR• make NDA LLW management andtreatment facilities available to othernuclear and non-nuclear managers ofradioactive waste• assess the need for other disposal optionsand at what point a replacement for LLWRmight be requiredConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 9

1.3 ConsultationThe development of this strategy has alreadyinvolved a number of key stakeholders, throughdirect communication and the National LLWStrategy Group (see Appendix 1). The StrategyGroup includes LLW waste producers, both fromthe nuclear industry and the non-nuclear industry,the NDA, LLW Repository Ltd, representatives fromGovernment, Regulators and planning authorities.The interests of the nuclear industry supply chainare represented on the Strategy Group by theNuclear Industry Association.The remit of National LLW Strategy Group is abody formed to consult on recommendations forbest business practices, economies of scale,standardisation, and the implementation of thewaste management hierarchy throughout the UK. Aprimary goal of the Strategy Group is to minimisewaste volumes for disposal at the LLWR and otherfacilities as applicable. The LLW Strategy Groupare not required to formally endorse this strategy.We have also worked directly with nuclear siteRegulators to ensure appropriate consideration ofHealth, Safety, Security and Environmental issues indeveloping this draft strategy.This document provides a formal opportunity for you to give the NDA your views on the proposed strategy. Thedocument includes a number of consultation questions, however, you are welcome to give us your views on anyaspects of the proposed strategy. We welcome and will consider all comments provided to us. Following theconsultation, we will provide a written summary of how we have responded to your comments.We are also interested in comments on the Strategic Environmental Assessment which has been published forconsultation in parallel with this report. The consultation period for both documents will run for 14 weeks from the5 June 2009 to the 11 September 2009.Copies of both documents are available electronically from www.nda.gov.uk/consultations or copies can berequested by writing to the address below. You can provide comments electronically through the web basedconsultation or email or alternatively by post.Please provide comments by Friday 11 September 2009.Comments should be sent to:Post: LLW Strategy Consultation Email: llwstrategy@nda.gov.ukNuclear Decommissioning AuthorityHerdus House,Westlakes Science and Technology ParkMoor Row, CumbriaCA24 3HUIndividual responses and information provided in response to this consultation, including personal information,may be subject to publication or disclosure in accordance with the access to information regimes (these areprimarily the Freedom of Information Act 2000 (FOIA), the Data Protection Act 1998 (DPA) and the EnvironmentalInformation Regulations 2004). If you want other information that you provide to be treated as confidential, pleasebe aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply andwhich deals, amongst other things, with obligations of confidence.In view of this, it would be helpful if you could explain to us why you regard the information you have provided asconfidential. If we receive a request for disclosure of the information we will take full account of your explanation,but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automaticconfidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the NDA. TheNDA will process your personal data in accordance with the DPA. In the majority of circumstances, this will meanthat your personal data will not be disclosed to third parties.Individual responses will not be acknowledged unless specifically requested.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 11

2 BackgroundConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 12

2 BackgroundThe NDA was established under the Energy Act2004 with responsibility for the decommissioning ofa number of civil public sector nuclear sites safely,securely, and cost-effectively, whilst protecting theenvironment. The NDA’s functions andresponsibilities are set out in the Energy Act 2004and in the Secretary of State’s designations relatingto each of the sites for which it is responsible.The LLWR near the village of Drigg in westCumbria is one of the sites for which NDA isresponsible for under the Act. This is the onlydedicated engineered LLW disposal facility in theUK. NDA are able to make this facility availableunder suitable commercial terms to nuclear andnon-nuclear waste producers.2.1 Definition of the nuclear industryGovernment’s LLW Policy requires a strategy forthe management of solid LLW from the nuclearindustry. For the purposes of this strategy we havebroadly defined the nuclear industry as those sitesthat hold a nuclear site licence. In general, thisincludes NDA Site Licence Companies (SLCs),British Energy and certain Ministry of Defence sites(i.e. those organisations involved in the generationof electricity by nuclear means, decommissioning ofnuclear related facilities and organisations involvedin maintaining the UK’s nuclear deterrent). Certainhealthcare institutions hold nuclear site licences;these organisations will have reference to both thisstrategy and the strategy for the management ofLLW from the non-nuclear industry.NDA sites are expected to generate approximately80% of all LLW from the nuclear industry.The largest NDA site is Sellafield, in Cumbria. Asignificant amount of LLW (approximately 60%)comes from the Sellafield site and will have animportant influence in implementing the LLWstrategy. Operations at the Sellafield site includespent fuel reprocessing, fuel manufacture,treatment and storage of radioactive waste anddecommissioning of redundant facilities.Sellafield Ltd have recently developed their ownstrategy for the management of LLW at theSellafield site. We have worked closely to ensurethat the Sellafield strategy is compatible with theemerging UK nuclear industry LLW strategy and webelieve that this has been achieved. However,Sellafield will review its own strategy, as is thecase for other sites with respect to their integratedwaste strategies, once the final UK nuclear industryLLW strategy has been published.2.2 Low level wasteSolid radioactive wastes have been produced,stored and disposed of by various industries in theUK since the 1920s. The main sources of wastegeneration since the 1950s onwards have beennuclear energy development, nuclear powergeneration and the weapons industry. In addition,hundreds of non-nuclear industry users ofradioactive materials produce radioactive wastes,for example universities, hospitals, thepharmaceutical industry, research establishmentsand the oil and gas industry.In the UK solid radioactive wastes are definedaccording to three main categories: low,intermediate and high level wastes. Low LevelWaste (LLW) represents a broad categoryspanning a range of five orders of magnitude ofradioactivity (See Environment and SustainabilityReport for more information on radioactivity andhow it is measured). Solid LLW is generated inmany locations across the UK today, from theoperation of power stations and fuel facilities to thedecommissioning and clean-up of nuclear sites.Ninety-eight percent of UK LLW arises at nuclearsites undertaking the following activities:• fuel fabrication and uranium enrichment• nuclear power generation• spent fuel reprocessing• nuclear energy research and development• Ministry of Defence activities• manufacture of radioactive medicalproductsUnlike High Level Waste (HLW) and IntermediateLevel Wastes (ILW), LLW does not normallyrequire special shielding during handling ortransport.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 13

2.3 Regulation of radioactive wasteEnvironmentIn the UK, the Radioactive Substances Act 1993(RSA93) (Ref. 8) provides the framework forcontrolling the management of radioactivematerials and wastes so as to protect the publicand the environment. RSA93 requires priorauthorisation to dispose of radioactive waste,including from nuclear installations. It also requiresregistration for the keeping and use of radioactivematerial (other than by nuclear sites licensees) andauthorisation for the accumulation of radioactivewaste (other than on nuclear licensed sites). TheAct empowers the appropriate environment agency(the Environment Agency or the ScottishEnvironment Protection Agency) to attachconditions and limitations to any authorisation thatit issues.Authorisations under RSA93 require operators todemonstrate that they are applying BestPracticable Means (BPM) to minimise the impactsof the authorised activities on people and theenvironment. This incorporates where appropriatedemonstration that the Best PracticableEnvironmental Option (BPEO) has been adopted tomanage radioactive wastes.SafetyUnder UK law (the Health and Safety at Work etc.Act 1974) employers are responsible for ensuringthe safety of their workers and the public, and thisis just as true for a nuclear site as for any other.specific requirements relating to the accumulationand storage of radioactive wastes on nuclear sites.The nuclear licensing regime is complemented bythe Ionising Radiations Regulations 1999 (IRR99)and other health and safety regulation which theHSE also enforces on nuclear sites as it does onany other sites. This general health and safetylegislation will also apply to non-nuclear sites whichtreat or dispose of LLW.SecurityThe Nuclear Directorate’s Office for Civil NuclearSecurity (OCNS) is the security regulator for theUK’s civil nuclear industry. It is responsible forapproving security arrangements within the industryand enforcing compliance. The environmentalagencies have responsibilities for the security ofradioactive substances on non-nuclear sites.SafeguardsThe UK Safeguards Office (UKSO) oversees theapplication of nuclear safeguards in the UK toensure that the UK complies with its internationalsafeguards obligations. Nuclear safeguards aremeasures to verify that States comply with theirinternational obligations not to use nuclearmaterials (plutonium, uranium and thorium) fornuclear explosives purposes.Further information on the regulation of radioactivewaste is included in Appendix 2.This responsibility is reinforced for nuclearinstallations by the Nuclear Installations Act 1965(NIA65), as amended. Under the relevant statutoryprovisions of the NIA, a site cannot have nuclearplant on it unless the user has been granted a sitelicence by the Health and Safety Executive (HSE).This licensing function is administered on HSE'sbehalf by its Nuclear Directorate. The NuclearDirectorate, sets out in conditions attached to a sitelicence the general safety requirements to deal withthe risks on a nuclear site which Licensees mustcomply with. These licence conditions includeConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 15

3 LLW arising from the nuclearindustryConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 16

3 LLW arising from the nuclearindustryThe UK LLW Strategic Review (Ref. 2) includes abaseline inventory of all LLW waste to be managedover the projected lifetime of the NDA’s sites(between 2008 and 2129). This baseline has beendeveloped using the 2007 UK National Inventoryand Lifetime Plan (LTP) 08 Waste AccountancyTemplates in consultation with waste producers.The estimated volumes include waste from NDAsites, British Energy sites and Ministry of Defencesites. It also includes information from non-nuclearindustry LLW producers, for example the healthcareindustry and research establishments. The reviewfound that there will be approximately 3 million m 3 ofLLW to be managed over this period. At present,approximately 60% of this waste has beendesignated as High Volume Very Low Level Waste(VLLW).The review demonstrated the greatest generation ofLLW (following current planned activities) occursover the period from 2008 to 2031. There is also anincrease in the generation of LLW around 2090 as aresult of final site clearance activities at a number ofNDA sites.The strategic review document sets out the originsof the waste. Notably, it indicates that a significantproportion of the LLW (44%) and the VLLW (69%) tobe generated originates from Sellafield. Other majorproducers of LLW include the Magnox operatingsites and British Energy sites. The other notableproducer of VLLW is Springfields, near Preston. It isworth noting that these figures are subject to changeas waste producers refine their plans and wasteforecasts accordingly.The Strategic Review also provides an assessmentof the types of waste to be managed. In terms ofvolume, the two LLW types that stand out are metal(37% of the inventory) and soil / rubble (33% of theinventory). For VLLW, the same two waste streamsdominate; soil and rubble account for 63% of VLLW,metal accounts for 23%. The strategic review alsodocuments when waste will arise. It determined thatmore of the metal waste is scheduled to beproduced in the near term, (between now and 2030)Soil and rubble will be generated in both the nearterm and later on as part of final site clearanceprogramme.There are a range of options for the managementof LLW. In the past, the majority of LLW has beendisposed of at LLWR with little or no pre-treatment.Other options used to a limited extent in the pastinclude disposal of certain wastes to landfill or to anincineration facility (either on-site or off-site),treatment of metallic wastes and the use ofoverseas waste treatment routes.Analysis of this inventory shows that continuation ofpast approaches to LLW management will result inaround 2.4 million m 3 of LLW requiring disposal atLLWR or a new national LLW repository. This canbe compared to the scheduled capacity at LLWR ofaround 0.7 million m 3 , which is subject to planningand regulatory approvals. The review demonstratesthat if this is the case a new repository could berequired by 2037, or possibly even earlier, if wastecurrently destined for other facilities had to bedisposed to LLWR.Further detail and analysis is included in theStrategic Review document:http://www.llwrsite.com/llw-strategy-group/consultationdocumentsThe UK LLW Strategic Review baseline does not include:• Low Level Waste associated with the operation and decommissioning of new nuclear power stations (seeSection 6.3.3 for more information on new nuclear build)• radioactively contaminated ground at nuclear sites that is not currently declared as waste (see Section 6.3.4for more information on contaminated ground)Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 17

4 Strategic EnvironmentalAssessmentConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 18

4 Strategic EnvironmentalAssessment (SEA)The NDA is committed to safe and secure deliveryof its missions and ensuring that its strategies takeappropriate account of sustainability andenvironmental considerations. For this reason wehave undertaken a SEA to inform the developmentof this strategy of such sustainability considerationsand to assess the potential social, health, economicand environmental impact of the proposed strategycompared to a number of reasonable alternativesor options. Extracts are included from the StrategicEnvironmental Assessment in this consultationdocument (see pale green boxes) that set out theissues and considerations around the approachesproposed.We have undertaken this SEA in accordance withthe requirements of the European Union’s SEADirective (2001/42/EC) and transposing UKRegulations. The scope of the assessment hasalso been expanded to provide consideration ofrelevant potential environmental, social (includinghealth and safety and hazard reduction) andeconomic effects ensuring that this assessmenthas the same scope as a sustainability appraisal.The SEA process aims to:• integrate environmental and relevant socialand economic factors into the preparationof the Nuclear LLW Strategy and decisionmaking• improve the Nuclear LLW Strategy, andenhance environmental protection• facilitate public participation in decisionmaking• facilitate openness and transparency ofdecision makingThe consultation on this draft Strategy is thereforesupported by an Environmental and SustainabilityReport. This summarises the development of theNuclear Industry LLW strategy, includingconsideration of reasonable alternatives, andpresents the findings of the detailed assessment ofthe preferred options against a range of social,economic and environmental objectives. Whereany significant adverse effects are identified,mitigating measures have been proposed, alongwith an indicative monitoring framework.The Environmental and Sustainability Report aimsto:• provide information on the UK NuclearIndustry LLW Strategy• provide a summary of relevantenvironmental information drawing on areview of relevant plans and programmes,baseline information and consultee views• outline the process of assessment, theresults of the scoping stage consultationand any difficulties encountered during thecompletion of the assessment• identify, describe and evaluate the likelysignificant effects of the UK NuclearIndustry LLW Strategy and reasonablealternatives• provide potential measures to avoid,reduce, mitigate or offset any potentiallysignificant adverse effects on theenvironment and, where appropriate, tosuggest potential measures to enhance thecontribution of the UK Nuclear IndustryLLW Strategy to the achievement ofenvironmental and sustainability objectives• provide an opportunity for the consultationauthorities and the public to offer views onthe findings of the assessment of the UKNuclear Industry LLW StrategyThe Environmental and Sustainability Report waspreceded by production of a Scoping Report whichwas issued for consultation in July 2008. This setout the proposed appraisal framework (expandedto include social and economic issues) andmethodology to be used to assess both the revisedNDA Strategy and the Nuclear LLW Strategy. Theresponses were used to revise the approach andupdate the information that has been incorporatedinto the report.The Environmental and Sustainability Report and aNon-Technical Summary (which provides a highlevel summary of the findings) are availablefrom www.nda.gov.uk/consultations/ to inform yourreading and response to this draft Strategy. Wewelcome your feedback on the Environmental andSustainability Report. Specific findings areincluded in the relevant sections of the strategy(see Section 5) to demonstrate the reasoningbehind part of the strategy.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 19

5 The UK strategy for themanagement of solid low levelradioactive waste from the nuclearindustryConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 20

5 The UK strategy for themanagement of solid lowlevel radioactive waste fromthe nuclear industry5.1 VisionThe UK strategy for the management of solid lowlevel radioactive waste from the nuclear industry willfacilitate continued hazard reduction anddecommissioning through application of the wastemanagement hierarchy. It will also providecontinued capability and capacity for the safe,secure and environmentally responsiblemanagement and disposal of LLW in the UK, forboth the nuclear and non-nuclear industries.The strategy will provide value for moneyapproaches to the management of LLW. It will takeinto account the technical, environmental andsocial factors, coupled with the most advantageoususe of the UK Low Level Waste Repository.We have set out below key principles that weconsider appropriate for the management of LLWfrom the UK. They provide a framework in whichthe strategy should be implemented and also giveguidance on Government expectations of NDA,nuclear waste producers, regulators and planningauthorities to implement this strategy.• Health, safety, security, environmentalexcellence and public acceptability is vital tothe development of appropriate wastemanagement plans and their implementation.• Waste avoidance should be implemented byall producers of LLW.• Effective characterisation and segregation ofwaste and material that will become waste iscritical to flexible management of LLW.• Given the diverse physical, chemical andradiological nature of LLW, it is important tohave a variety of proportionately regulatedwaste management routes.• The development of new waste routes orapproaches to the management of LLWrequires early and proactive engagementwith local and national stakeholders.• Availability of flexible waste managementroutes is essential for hazard reduction anddecommissioning and the continuedoperation of the nuclear and non-nuclearindustries.• Waste management decisions should besupported by sound business cases anddemonstrate the use of robustdecision-making processes to identify themost advantageous option.• This strategy does not aim to provide a singlesolution; different fit-for-purpose solutions willbe required for different wastes.• Where appropriate and practicable, we willmake waste management facilities on NDAsites available for non-NDA producers ofLLW on suitable commercial terms.Likewise, we would expect that non-NDAfacilities are made widely available wherethis is appropriate.• Integration of strategies for all wastes (bothradioactive and conventional) is importantnationally and at a site level; waste plans willbe consistent with, and complement, nationalstrategy and Government policy.It is recognised that there are other policy andregulatory requirements and principles that apply toLLW management. Clearly, the implementation ofthis strategy will need to be undertaken incompliance with all relevant legal and regulatoryrequirements. More information on theserequirements can be found on the websites of theEnvironment Agency, Health and Safety Executiveand Scottish Environment Protection Agency andwithin the UK's reports to the Joint Convention onthe Safety of Spent Fuel and Radioactive Waste.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 21

5.2 Key themesWe propose that the UK nuclear industry LLWstrategy comprises three strategic themes:I. application of the waste managementhierarchy to extend the life of LLWR andensure waste is managed in a risk-based, fitfor-purposemannerII.best use of existing assetsIII. new fit-for-purpose waste managementroutesFigure 2 sets out the proposed UK nuclear industryLLW strategy in summary.Each theme is described below, setting out theissue or need, strategic direction and what the NDAand its partners will do to respond to that need.Discussion is then provided on how the strategy willbe implemented, including information on therelationship between this strategy, LLW RepositoryLtd, waste producers and the supply chain.It should be recognised that managing LLW shouldnot be separated from managing conventionalwaste on a nuclear licensed site. Implementationof this strategy will require an integrated wastemanagement approach where a strategy is neededto manage all waste arisings.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 22

Figure 2 – diagrammaticrepresentation of the UKnuclear industry LLWstrategy.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 23

5.3 Application of the waste managementhierarchy to extend life of LLWR andensure waste is managed in a risk based,fit for purpose mannerThis section of the UK nuclear industry LLWstrategy is focused on the waste managementhierarchy. The waste management hierarchy wasfirst introduced in 1975 in EU waste policy in theFramework Directive for non-radiological waste('controlled waste'). It is an integral part of thedevelopment of integrated waste strategies atnuclear (and non-nuclear) sites. Application of thehierarchy is central to our approach for a number ofreasons.• The waste management hierarchy isrecognised as good practice in wastemanagement.• Government’s policy for the management ofLLW tells us that waste should be dealt with atthe highest practicable level in the hierarchy.• The biggest challenge for the management ofLLW in the UK is the availability of safe, secureand environmentally appropriate disposalcapacity. There will be approximately 3 millionm 3 of LLW generated in the UK once it hasbeen packaged by waste producers fordisposal (Ref. 2). Even with planned capacityfor construction at LLWR (subject to relevantapprovals) there would still be a requirement for2.4 million m 3 elsewhere. We see theapplication of the waste management hierarchyand risk based approaches to the managementof LLW as a critical part of addressing thischallenge. Size reduction, change of physicalform, reduction of waste volumes and moreeffective ways of handling LLW can beachieved at all levels of the hierarchy.Meeting regulatory requirements for themanagement of LLW, to ensure safety, securityand protection of the environment, is the firstpriority for NDA and its operators.Implementation of the waste managementhierarchy is mandated by policy, environmentalregulation and is recognised as good practice inall aspects of radioactive and non-radioactivewaste management. We believe it is an essentialelement for effective management of LLW.5.3.1 Waste avoidance and characterisationWe believe there is a significant opportunity both onNDA and non-NDA sites to avoid the generation ofradioactive waste, which will have a beneficialimpact on a large percentage of waste identified inthe UK’s LLW inventory. Waste avoidance andimproved waste characterisation is alreadypracticed, although there are still significantopportunities to achieve more, possibly throughshared processes and procedures. There arefundamental approaches and principles that need tobe undertaken in order to make the most of thisopportunity. These include:• waste avoidance as a fundamental principleof design and operation of all new nuclearfacilities, including new nuclear powerstations as they are developed.• waste avoidance as a fundamental principlefor the operation of sites in the nuclearindustry and for planning decommissioning• wastes being appropriately characterised atsource, segregated and sentenced so as tonot foreclose a range of appropriatemanagement optionsInterpretation of the waste management hierarchyis less straightforward for the management ofradioactive waste than for conventional wastes.This is because there are a number of additionalfactors that need to be considered with regards tosafety, security and the environment. Due to theseadditional factors there are differing regulatoryregimes that apply to this kind of waste.Consequently, the waste hierarchy should beapplied first to the radioactive aspects of LLWbefore dealing with its conventional wasteproperties. The main implication being that asignificant portion of LLW arisings can bedemonstrated to be exempt from regulation underthe Radioactive Substances Act 1993 because ofthe insignificant hazard they present through qualityassured waste segregation and characterisation.This means that substantial quantities of wastemay be demonstrated to be safely excluded fromthe overall LLW inventory as it stands (from overestimation or pessimism in forecasting). Waste notrequiring handling and disposal as LLW will providebenefits related to cost and resource use.Conventional waste management issues still applyto the management of this waste and the wastemanagement hierarchy must remain key toConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 24

decisions about the management of this exemptwaste.Sorting and segregation of waste is essential toutilising different approaches to the management ofwaste. Historically the UK has separated LLW intocompactable and non-compactable wastes, drivenby the processes and disposal routes available.Further segregation into different waste types andcategories (for example, separating out VLLW) iscritical to successful application of the wastemanagement hierarchy. Particularly in identifyingmore appropriate management routes for waste notnecessarily requiring multi-barrier engineeredcontainment, such as that provided by LLWR.Segregation of wastes at source, where practicableis the preferred option for this activity. It isrecognised that this may require manualintervention and consequently, we recognise theneed to balance handling of waste with the need tokeep radioactive doses As Low As is ReasonablyAchievable (ALARA) and other risks As Low As isReasonably Practicable (ALARP).In order to move forward in this area we will:• develop programmes to improvecharacterisation of wastes on our sites andwork with non-NDA sites to share goodpractice• provide strategic direction to our sites,through the NDA Strategy and strategicspecifications (see Section 6.1), to enhanceavoidance of waste during operation anddecommissioning.• work with the Clearance and ExemptionWorking Group (CEWG) 2 to communicate,improve and implement the Nuclear IndustryCode Of Practice on Clearance andExemption as appropriate• through LLW Repository Ltd, investigate thepotential benefits of standardisingcharacterisation, sorting and segregation ofwaste and develop standardised proceduresas appropriate, for publication anddissemination• look to our sites to determine appropriateLLW management routes, avoidingclean/exempt and VLLW being disposed of atLLWR• look to LLW Repository Ltd to providesolutions that help sites to segregate wastemore effectively (e.g. segregation at source,provision of appropriate containers etc)• invest in research and development toimprove the availability of equipment andtechniques for characterisation• develop guidance on good practices in thisarea• provide incentives where appropriate for thesegregation of waste through pricingstrategies at LLWR and with NDA contractswhere applicable.Question 1 – Do you agree with the proposedapproach to avoidance and characterisation ofwaste? What are the most important areas forwork and are there other actions that could beundertaken?5.3.2 Minimise, Re-use and recycleThe next levels of the waste managementhierarchy include minimising waste and the re-useand recycling of waste. It has previously beenconsidered that opportunities to apply theseprinciples to radioactive waste were limited;however, over recent years, there has been moresuccess in realising these opportunities within andoutside of the nuclear industry.2 The Clearance and Exemption Working Group (CEWG)is a UK nuclear industry working group that aims toprovide responsible and sustainable approaches toclearance and exemption issues and contribute to thedevelopment of legislation, standards and guidance asappropriate. More information is available athttp://www.cewg.safety-directors-forum.org/DecontaminationDecontamination of facilities and materials prior todecommissioning and consignment as waste hassignificant potential to minimise the amount ofwaste that needs to be managed as LLW.Typically, techniques in use at present are targetedat removing surface contamination of concrete andConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 25

decontaminating metal. Examples include use ofhigh pressure water jets, shot blasting, acid bathsand machining and grinding equipment. These areall standard techniques used extensively inconventional waste management. There may befurther opportunities to increase the use oftechniques that could yield significant benefits inreducing waste volumes and activity. However,these benefits need to be considered in light ofpotential negative impacts such as generation ofsecondary waste and the costs of implementingthese techniques. Additional decontaminationinnovations and applications may also need to bedeveloped.• work with regulators and waste producers toseek clarification of regulatory requirementsand provide examples of UK and internationalgood practice in re-use of wasteMetals wastes can be readily recycled followingtreatment, which is covered later in more detail.Question 2 – Re-use and recycling of waste fromthe nuclear industry could yield significant benefits– do you agree with this approach and where doyou see the significant opportunities forimplementing the option?In order to achieve progress in this area:• waste producers should ensuredecontamination and minimisation techniquesare included in their options assessments anddecision making processes• we will determine principles for the role ofdecontamination in decommissioning andinvestigate opportunities to improve theefficiency of decontamination facilities in use atthe present timeRe-useThe LLW policy recognises the opportunities forappropriate re-use of soil and rubble; opportunitiesinclude void infill, construction and landscaping.There are examples of waste producersimplementing this alternative to disposal(international examples do exist) although they arelimited. In most cases authorisation for this activitywould be required and there may be challenges infinding opportunities that combine the availability ofappropriate material and projects that can receivethe material. There may also be impacts on thesite end state that would need to be considered.Decay storageA further opportunity to minimise the radioactivity ofwaste is decay storage of radioactive waste. Whilstdecay storage of waste to exempt levels or levelssuitable for alternative management options mayhave benefits, there are also significant challengesthat need to be overcome, including rigorouscharacterisation before and after decay storage,availability of storage space, regulatoryrequirements, stakeholder acceptance andstrategic fit with decommissioning strategies. It isour strategy that decay storage should only beconsidered on a case-by-case basis. Further studywill be undertaken to better understand decaystorage opportunities, which could include decaystorage of short-lived ILW to LLW, and thelimitations around them.Re-use of material is a significant opportunity toavoid inappropriate use of capacity at the LLWRand therefore more work is required to ensure thatthis opportunity is realised. In order to improve theimplementation of these options we will:• seek end users for soil, rubble and demolitionproducts generated within the NDA and non-NDA estate using national networks such asthe LLW Strategy GroupConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 26

The Strategic Environmental Assessment that supports the development of this strategy considersdecontamination, re-use and recycling. Conclusions of this assessment are presented below.• Decontamination to clean contaminated waste to allow it to be managed as exempt waste or to facilitate itsonward management has a positive role to play. However, specific circumstances will determine the degree towhich this should be implemented (if at all) to ensure that the benefits outweigh the potential detrimentalimpacts of decontamination, such as energy use, resource use, discharges, secondary waste generation andthe risk of exposure to workers involved in decontamination.• The re-use of materials that would otherwise be disposed of as radioactive waste has potential benefit bydeferring the need to dispose of existing waste and by avoiding the need for new material to be used, whichwould itself become contaminated. Re-use under appropriate control is also expected to result in limitedenvironmental impacts. However, the scope of implementation will be limited by the practicability ofidentifying circumstances in which material can be re-used under appropriate regulatory oversight and thechallenges of demonstrating the suitability of material for re-use.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/.5.3.3 Waste TreatmentThere are three waste treatment activities that will bekey to success in achieving the vision for thisstrategy: waste compaction; treatment and recyclingof metallic LLW; and, incineration 3 .It is our view that treatment routes for LLW shouldbe utilised to ensure optimum use of the existingnational disposal facility and where demonstratedas BPEO. Candidate waste should be cleaned,treated, recycled and / or exempted before disposaldecisions are made. Metal decontamination/smelting and incineration of candidate wastesshould be pursued to the maximum extent. Theseopportunities are discussed in greater detail below.Waste compactionIn recent years, compaction and high-forcecompaction of LLW have realised a significantamount of volume saving prior to disposal. Onaverage, compaction of LLW achieves a 5:1 ratio ofvolume reduction. Compaction is a relativelysimple process and technologies are mature. It istherefore considered to be an appropriatetechnology to maintain as part of our strategy.Improved waste packaging (e.g. 1 m 3 boxes ratherthan cylindrical drums) to maximise packingefficiency for compacted waste should also bepursued.In order to optimise the use of compaction we will:• determine whether there is a need foradditional compaction capacity in the UK andensure availability of compaction for LLW• encourage the use of reusable containers forthe transport of waste for compaction (forexample Type-0075 containers) to reduce theamount of new packaging being compactedand also preserve space by generating arectilinear waste form rather than the roundwaste form achieved with drummed waste• expect suppliers of services to work with wasteproducers to provide innovative services asapplicableQuestion 3 – To what extent do you believe thatcompaction still has a key role to play in theoptimisation of LLW management? What are theopportunities for improving the use of compaction?3 For the purpose of this strategy incineration is to beconsidered a treatment, rather than disposal process.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 27

Metal treatment and recyclingMetallic waste represents approximately 27% ofLLW in the UK. Metal decontamination and metalmelting have been demonstrated as an effectiveway to manage these wastes and can achieverecycling rates of up to 95% of incoming material(Ref. 9). Consequently, treatment of metallic wasterepresents a significant opportunity forconservation of disposal capacity at LLWR whilstalso enhancing the value of resources alreadywithin the nuclear estate.Decontamination of metal wastes already takesplace at a number of NDA and non-NDA sites, forexample Winfrith and Sellafield. There are also anumber of contractors in the supply chain whoprovide services in this area and a number of wasteproducers have initiated trials of these routes (e.g.Sellafield, Rosyth and Magnox South). We alsorecognise the investment by the supply chain in thisarea that has led to increased availability of thistreatment opportunity. Whilst the current level ofrecycling is positive, there is significant scope forincreasing the treatment of metallic waste in thefuture.There are a number of key activities that arerequired to make this happen.• We are supporting LLW Repository Ltd indeveloping a UK-wide metallic waste treatmentservice, which will open up the metallic wastetreatment market and encourage furtherinvestment in this area allowing all wasteproducers access to treatment routes they mayotherwise not be able to access.• We will work with the supply chain and LLWRepository Ltd to determine where futuredevelopments are best focussed to meet theneeds of the nuclear industry.• Waste producers should make best use ofavailable metal decontamination facilities.• NDA SLCs must demonstrate that they aremaking best use of available metal treatmentroutes.Further investigation is required to understand theoptimal management approach for VLLW metalshould alternative VLLW disposal routes open up(see below). At present, there is a reasonablefinancial and environmental case for treatment ofLLW metal when compared to disposal. However,the cost of recycling of VLLW metals compared toalternative VLLW disposal routes is still somewhatuncertain. A strategic BPEO for VLLWmanagement has recently been completed, whichindicates that metal treatment is the preferredoption for VLLW metal. The results will bepublished on the LLWR website when available.• We will work with LLW Repository Ltd to betterunderstand the opportunities for the recycling ofVLLW.The Strategic Environmental Assessment that supports the development of this strategy considersdecontamination and metal recycling. A conclusion of this assessment is presented below.• Metal treatment and recycling has the potential to significantly reduce the volumes of LLW requiringdisposal, either through volume reduction or by allowing metal to be recycled (provided it can bedemonstrated that treated metal meets the relevant safety standards). Therefore, metal treatment is anappropriate option for the management of LLW both in the UK and through using overseas facilities.Through this assessment, at a national level, it has been demonstrated the benefits outweigh the potentialnegative impacts, however, specific circumstances will need to be considered to confirm this is the case ata site level.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/.Question 4 – Do you agree that the benefits of metal treatment outweigh the detriments? If not, why not? Ifmetal treatment costs more than disposal to implement, is this acceptable?Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 28

Thermal treatment and energy recoveryThermal treatment of waste refers to the use ofprocesses such as incineration or pyrolysis tosignificantly reduce the volume of waste andremove some of the volatile / hazardouscomponents of the waste in the fly ash such thatthe final form of the waste is a more stable product.Waste forms from these processes are usually ashthat is typically solidified in concrete. It has beendemonstrated that thermal treatment is a viable andappropriate management option for LLW (Ref. 10).In particular, it is recognised that this is an effectivetreatment option for contaminated oils. It has beenshown that for LLW considered alone, conventionalincineration is likely to be the most appropriatethermal treatment technology. However, it has alsobeen recognised that the benefits do not greatlyoutweigh those achieved by high-force compactionand it is often the case that those wastes amenableto incineration are also appropriate for high-forcecompaction.We recognise that there may be opportunities forthermal treatment of LLW with other wastestreams, for example ILW, graphite and asbestos.Energy recovery from thermal treatment of waste isalso becoming a common practice in theconventional waste management industry.However, the size of incinerator that would berequired to treat incinerable waste in the UK LLWinventory would be relatively small and wouldconsequently limit any potential for major heatrecovery. We believe that, at present, coincinerationof radioactive waste with conventional(municipal) waste for the purpose of energyrecovery and driven by the primary need tomanage LLW, does not provide a favourableoption. This is due to provisions required forcontamination control, the potential to generatesignificant amounts of LLW as ash and potentialstakeholders concerns associated with wastemovements (both conventional and radioactivewaste) and dilution. (It is recognised that there maybe opportunities for energy recovery where LLW isconsigned to facilities that are already in place forthe treatment conventional waste).There are a number of incinerators operating in theUK that treat LLW from both the nuclear industryand the non-nuclear industry. However, thecapacity of these facilities is limited. There are alsofacilities not currently in use that have potential foran increased role in the future, for example theincinerator at Capenhurst site, which is notcurrently operating. We want to see continued useof existing facilities where this represents the mostappropriate management option and they can beshown to demonstrate value for money.It is also recognised that thermal treatment of bothradioactive and non-radioactive waste is an area ofsignificant concern for stakeholders, particularly thecommunities that host thermal treatment facilities.Whist it is important that communities are engagedin developments for waste management, thermaltreatment is an area where this deserves particularattention at an early stage. Clear and effectiveinvolvement of communities at an early stage whendevelopments are planned is critical.In order to make the most effective use of thermaltreatment opportunities we will:• support LLW Repository Ltd in development ofexisting supply-chain treatment routes forincinerable waste• work with Sellafield Ltd to better understandopportunities for the Sellafield sites (Sellafield,Windscale and Capenhurst) in this area (inparticular looking at opportunities for thermaltreatment with other waste streams)• expect waste producers to use incinerationopportunities for contaminated oils whereBPEO, which will contribute to the viability ofincineration routes (contaminated oil isgenerally managed as a solid waste).• further investigate opportunities for thermaltreatment of LLW with other waste streams(ILW, graphite etc)Question 5 – Do you agree with the proposals setout for thermal treatment? If not, why not? Asincineration is often a controversial approach, whatshould be the key message if the LLW strategywere to actively promote the use of thistechnology?Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 29

The Strategic Environmental Assessment that supports the development of this strategy considers thermaltreatment and energy recovery (see Environment and Sustainability Report Non Technical Summary).Conclusions of this assessment are presented below.• Thermal treatment has the potential to significantly reduce the volumes of LLW requiring disposal throughvolume reduction. Thermal treatment is an appropriate option for the management of LLW both in the UKand using overseas facilities. Specific circumstances will need to be considered to ensure the benefits ofthis option outweigh the potential negative impacts of thermal treatment such as energy use, resource use,discharges, secondary waste generation, the risk exposure of workers and any additional transport.• The use of thermal treatment with energy recovery presents potential environmental benefits over thermaltreatment without energy recovery. However, this benefit is likely to be offset as the volumes of LLW whichare suitable for thermal treatment are expected to be insufficient to support a substantial waste to energyfacility. Therefore, unless practical technology for smaller scale energy recovery is identified, then thisoption is only likely to be implemented through the co-treatment of radioactive and non radioactive waste bythe wider waste management supply chain. This latter option presents significant challenges as describedabove.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/.AsbestosThermal treatment offers potential opportunities forthe management of asbestos, both radioactivelycontaminatedand clean. However, thermaltreatment of asbestos has not yet beendemonstrated as an economical option eventhough recognised as a beneficial opportunity forthe environment. For the immediate future, LLWand VLLW asbestos should be characterised anddespatched, via appropriate pre-conditioning (e.g.super-compaction), to an appropriate disposalroute. For VLLW and exempt asbestos this mayinclude appropriately authorised landfills. In thelonger term we expect options and business casesto be developed as the opportunities for theapplication of alternative management technologiesgrow.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 30

Supply Chain approachTo support this strategy, we want to see theestablishment of a stable and competitive marketfor waste management services that will provideconfidence for private investment. We believe thatthe existing waste management supply chain, givenit’s maturity and expert capabilities, has a key rolein the delivery of this strategy and that the majorityof waste management solutions that are required toimplement this strategy are or will be available,either in the nuclear estate or through the supplychain. Therefore the supply chain should be usedin preference to centralised investment in newinfrastructure. Whilst use of the supply chain hasbeen raised as an area for concern, it should berecognised that it has to operate within the sameregulatory framework as existing site licencecompanies when operating these services and canoften provide enhanced value.There is potential for economies of scale to beachieved through centralised procurement andbrokering for these services. It is our belief that thiswill maximise opportunities for all waste owners.Therefore:• we are supporting LLW Repository Ltd indeveloping a diversified service offering toprovide metal treatment and incinerationservices through the supply chain• we will look to our sites and other wasteproducers to use services at LLWR ordemonstrate sound reasoning for selecting analternative treatment route should analternative route be appropriate in specificcircumstances• we will support the supply chain in developingnew management and disposal routes byexplaining our role in the management of LLWand making available information on the wastesthat need to be managed and when they willariseTreatment of wastes prior to disposal may lead toincreased waste movements, where treatment isundertaken at a separate location to the finaldisposal site. We believe that the relative impactsof these additional movements are small (see SEAtext below). In some cases this may requireinternational transport. International movements ofLLW come under the Transfrontier Shipment ofWaste Regulations 2008.Flexibility is required for wastes to be sent to sitesfor treatment prior to their final disposal locationwhen co-ordinated through a centralised body onbehalf of NDA. As noted above, there is existingtreatment infrastructure supporting the nuclearindustry, although determining the viability andoptions for upgrading and / or expanding thisexisting waste infrastructure remains in progress.There may be opportunities for providing servicesto NDA and non-NDA waste owners. In order todevelop this position we expect:• those sites that have the potential for extendingthe life of existing assets to work with the NDAand LLW Repository Ltd to better understandthe opportunities and, where appropriatedevelop business cases for any investment thatmay be requiredQuestion 6 – We believe that the majority of wastemanagement solutions that are required toimplement this strategy are or will be available,either in the nuclear estate or through the supplychain and therefore should be used in preferenceto centralised investment in new infrastructure. Towhat extent do you agree with this statement?Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 31

The use of the supply chain involves using waste management infrastructure owned by commercial operatorsrather than the NDA commissioning its own new waste facilities. The difference between these options was notassessed in the Strategic Environmental Assessment as a single specific option; however, the assessmentcollectively allows the implications of this decision to be considered. The key outcomes from such a choice arethe use of a mix of local, regional, national and international waste management facilities and consequentchanges in transport. There are also implications that may result from the management of radioactive waste infacilities potentially distant from where waste arises or where it has historically been managed. On the basis ofthe SEA, conclusions of this assessment are presented below.• Transport is a distinguishing factor in choices between waste management options and the transport ofradioactive materials is an issue of potential stakeholder concern. Therefore, as with conventional wastemanagement the principle of proximity between the location of waste arising and the location of treatmentand disposal facilities is a consideration. However, while transport is an issue of stakeholder interest, theactual impacts of LLW transport are small and so this issue is not a strong differentiator between options ona national scale. (This is expanded in Section 5.4.3).• When considering disposal on or adjacent to nuclear sites there is need to consider net impact on transportholistically. It is possible that any benefit from avoiding LLW transport may be offset by additionalconstruction traffic for new facilities.• Some stakeholders have raised concern about the potential impacts on economy and society arising fromthe management of radioactive waste at sites away from existing nuclear sites, for example due to negativeimpact on property prices or inward investment. The SEA looks at information on the potential effects ofnon radioactive and radioactive waste facilities in this way. The conclusions of the assessment arepresented below.► Any impact on property prices of radioactive waste facilities is expected to be equivalent to thoseobserved near non radioactive waste facilities and are expected to be both small and very localised.A study by the Department for Environment, Food and Rural Affairs (Defra) into these effects (Ref.11) concludes there is little correlation between such impacts and the types of waste received andso we do not anticipate the co-disposal of radioactive and non radioactive wastes havingsignificantly greater impacts on property prices than facilities taking only conventional wastes.► The potential for the presence of nuclear sites to discourage non-nuclear companies frominvesting in areas near to such facilities has been suggested. However, the SEA did not identifyconclusive evidence of significant negative impacts on local economies near major nuclear sites. Asa result we have not been able to demonstrate significant negative impacts on local economies andindeed, where those options require new waste management facilities modest positive impacts areexpected as a result of job creation.• While we do not envisage widespread significant negative impacts on local communities, like other wastemanagement infrastructure, such as municipal waste landfills and incinerators, the development of newradioactive waste management facilities is potentially contentious and will require effective and proactiveengagement with local communities.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 32

5.4 Best use of existing assetsThe UK LLW Strategic Review (Ref. 2) identifiedthe LLW management assets with the UK nuclearindustry. In developing this strategy we haveconsidered the value of using existing assets, inparticular looking at the LLW Repository near Driggin Cumbria. The assessment determined that thereis inherent environmental, social and economicbenefits in making the best use of existinginfrastructure. In particular, there are benefits fromthe reduction in investment and resources requiredto construct new infrastructure at NDA sites.Optimised approaches to the management ofassets align well with application of the wastemanagement hierarchy, in particular, in re-use ofresources that have already been expended.5.4.1 The UK LLW RepositoryLLWR is a key asset to the UK. LLW has beendisposed of at LLWR since 1959. Waste streamsare accepted for disposal at the LLWR based onthe availability of sufficient volumetric andradiological capacity. LLW arrives at the LLWR incontainers of varying sizes, either followingprocessing mainly in the Waste Monitoring andCompaction (WAMAC) facility at Sellafield ordirectly from waste producers. Containerisedwastes are then grouted and placed intoengineered concrete vaults.Making the best use of that asset is critical to thecontinued availability of LLW management capacityand capability. The LLWR provides a high level ofsafety, security and environmental protection forthe disposal of LLW by offering a multi-barriercontainment system. Capacity at the site is limited;continued use of the site and further extension andexpansion is subject to planning and otherregulatory requirements, such as the developmentof an acceptable Environmental Safety Case (seeSection 6.4.1). The amount of LLW currentlyforecasted to be produced in the UK could never bedisposed of at LLWR without significant treatment.Therefore, continuing to manage LLW as we havedone in the past is not sustainable. In order tomake best use of the facility it is important that onlywastes that require engineered multi-barriercontainment are consigned to the site. Otherappropriate waste routes must be used forcandidate wastes diverted from LLWR in the future.In order to achieve this we will:• ensure LLW Repository Ltd works with wasteproducers via its consignor supportorganisation to facilitate and coordinate wasterouting appropriately in its role as NDA LLWimplementation contractor• apply contractual mechanisms to our sites tominimise waste arisings and avoid sendingwaste for direct disposal to LLWR unlessnecessary• look to LLW Repository Ltd to use theConditions for Acceptance (CFA) at LLWR toensure that only those wastes that needenhanced safety, security and environmentalprotection through engineered vault disposalare consigned to the repository• support LLW Repository Ltd in theimplementation of alternative wastemanagement routes for metallic andcombustible wastes and for the management ofVLLWQuestion 7 – Do you agree with the approachesset out above for the development of an optimisedapproach to management of LLWR?Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 33

The Strategic Environmental Assessment which supports the development of this strategy considered anumber of options around the future strategy for the use of the LLWR near Drigg including abandonment of thesite and high level consideration of the impacts of retrieving waste already disposed of at the site, an importantconsideration when reviewing issues of site closure. Conclusions of this assessment are presented below.• Optimised use of the LLWR is the preferred approach, provided a safety case for the continued use of thefacility can be made and subject to any necessary regulatory and planning approvals. This option ispreferred to the ‘non optimised’ use and replacement of the facility, due to the reduced volume of LLWrequiring disposal in this type of facility and thus the reduced land take and resource used in theconstruction and capping of successor facilities.• It is difficult to determine what the effects of early replacement of LLWR without retrieval of waste would be,without knowledge of the specific location of the replacement facility. It would however result in significantexpenditure in the near term.• The retrieval of waste currently disposed of in the trenches at the LLWR would result in a range of potentialenvironmental, safety and cost effects. The Environmental Safety Case project at LLWR is consideringthese implications in more detail. To implement this approach a detailed case would need to be made todemonstrate that these effects were outweighed by a significant reduction in risk and that regulators risktargets could not be met without undertaking this course of action.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 34

5.4.2 PackagingThe majority of LLW disposed of in the UK ispackaged in various types of freight containers,which are grouted prior to disposal to minimise voidspace and improve long-term waste performance.Typically, the container is also used for transportingthe waste to its final destination; the containers areusually only licensed for a single transport.Although safe and reliable for waste transport anddisposal, the use of this packaging system isresource and cost intensive and does not provideoptimum use of the disposal capacity. It isrecognised that any alternative approaches mustcontinue to meet safety and compliancerequirements in this area.Improvement in this area represents a significantopportunity. In the past, the containers frequentlyhad poor waste packing efficiency. In recent yearsthis has improved somewhat, although often due tothe filling of void space with VLLW material. Whilstthis is recognised as an improvement, it results invaluable vault space being filled by VLLW. In thefuture we want to see improved packing efficiency,for LLW material requiring engineered vaultdisposal.An alternative approach to packaging could havesignificant benefits in terms of cost, resource anddisposal capacity at LLWR or other disposal sites,without compromising safety, security andenvironmental protection. Alternative packagingoptions are likely to include reusable transportcontainers and sacrificial disposal liners.Improvements to packaging need to measurebenefits for treatment and the use of alternativedisposal routes, not just the benefits that can beachieved at LLWR.In order to achieve this we will:• support LLW Repository Ltd in developingalternative packaging solutions, includingreusable transport containers, approaches toachieve improved packing efficiency anddevelopment of lower cost disposal containers;LLW Repository Ltd already provide thenational container supply service through itscustomer contracts• look to waste producers and suppliers to workwith LLW Repository Ltd in development ofpractical waste packaging solutions• ensure that alternative packaging options donot prevent LLW Repository Ltd from makingan acceptable Environmental Safety Case forits continued useQuestion 8 – What are the key considerations thatshould influence the development of newpackaging solutions for LLW management?The Strategic Environmental Assessment that supports the development of this strategy considersalternative disposal packaging. A conclusion of this assessment is presented below.• There is an opportunity to reduce both the cost and environmental impact of LLW disposal through the useof waste packages that use less resources or enable improved packaging efficiency than current methods,provided it is demonstrated that alternative packaging does not compromise the ability of a disposal site tomeet regulatory requirements and make an acceptable Environmental Safety Case.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 35

5.4.3 TransportThe movement of radioactive waste in the UK isgoverned by the Carriage of Dangerous Goods andUse of Transportable Pressure EquipmentRegulations 2007 (Statutory Instrument 1573)[10]and regulated by the Department for Transport(DfT). These regulations have recently beenintroduced in the UK to provide a consistentapproach within the EU for the safe transport ofdangerous goods including radioactive materials.The LLWR currently receives between 500 and 700half height ISO (HHISO) containers per year inaddition to occasional large items for disposal.Most of this waste (~80%) is delivered to LLWR byrail from Sellafield. Most consignor sites transportwaste by road to Sellafield for compaction atWAMAC prior to despatch by rail to LLWR fordisposal. The remainder of waste shipments arereceived at LLWR directly by road. Consignorsorganise their own transport using servicesprovided by commercial carriers or other wasteproducers.It is recognised that transport of LLW is asignificant stakeholder concern, particularly forresidents of the communities near facilitiesinvolved. Government’s policy for the managementof LLW recognises that, although the desire toavoid excessive transportation of materials is animportant consideration, it must be balanced withall the other relevant factors on a case-by-casebasis. The social and environmental impacts ofwaste transport are a function of the number ofmovements, the distance travelled and the mode oftransport utilised. There may be a significantopportunity to move a portion of waste movementsfrom road to rail and also utilise sea transport,where appropriate. We recognise these issues andwant to work with our contractors and non-NDAwaste producers to minimise the impact oftransport as far as can be achieved.In order to make the best use of these opportunitiesand in an effort to reduce the impact of wastetransport:• we have tasked LLW Repository Ltd with theco-ordination of waste transport and logisticsbetween waste producers, treatment facilitiesand LLW disposal facilities• we will work with LLW Repository Ltd andwaste producers to develop a plan for theoptimised and integrated transport of LLW,including an assessment of the costs andbenefits from greater use of rail transportIt is recognised that transport is of concern todifferent people for different reasons. For wasteproducer decision making, appropriatemechanisms should be used to ensure dialogue,review and assessment of options forimplementation of waste management thatconsider local and regional implications.Question 9 – The impacts of the transport of LLWare limited when compared to transport of othermaterials, when considered at a national level.However, it is a very significant issue for localcommunities where the transport is taking place.How do you think this should be factored in tonational strategy?Question 10 – To what extent does a movement ofwaste from road to rail for transport represent asignificant improvement? Do you see anydisadvantages to this approach?Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 36

The Strategic Environmental Assessment that supports the development of this strategy consideredthroughout the potential issues associated with Traffic and Transport (see Environment and SustainabilityReport Non-Technical Summary). Conclusions of this assessment are presented below.• Transport is a distinguishing factor in choices between waste management options and the transport ofradioactive materials is an issue of potential stakeholder concern. Therefore, as with conventional wastemanagement, the principle of proximity between the location of waste arising and the location of treatmentand disposal facilities is an important factor. Despite being an important consideration, when consideredon a national level, this issue is not a strong differentiator between options.► The contribution of LLW to local transport at consigning nuclear sites is generally only a very smallconstituent of total transport associated with the operation of the site. We would expect theadequacy of local transport infrastructure and potential disturbance to local communities to beconsidered in the siting of any substantial waste management facility providing such a service.► Transport of LLW to more distant waste management facilities does result in increased carbonemissions compared with management closer to the site where wastes arise. However, suchemissions are relatively small on a national scale when compared with UK transport relatedemissions and such emissions are also not a significant contributor to the carbon emissions of thenuclear sector.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 37

5.5 New fit for purpose waste managementroutesImplementation of this strategy will require newand / or expanded routes for the management anddisposal of LLW.Development of new routes has the potential to becontroversial, in particular with the communitiesaround which waste management operations willtake place, as is often the case with conventionalwaste management developments. Developmentand use of these new routes should considerissues of public acceptability and the communityvision for the area in which they are taking place.Development of new sites for treatment or disposalof LLW should take place at strategicallyappropriate locations depending on the servicebeing offered. This may include existing NDAestate, existing non-nuclear waste managementfacilities and new sites (local, regional or national).The LLW policy recognises that for wastes thatcannot be prevented, further minimised,diverted for recycling or re-used, final unretrievabledisposal is the end point for all LLW(Ref. 1). After all reasonable alternatives havebeen considered the following disposal options areavailable and should be considered on a case bycase basis where regulatory requirements aredemonstrated:• in-situ disposal (e.g. contaminated ground)• specified landfill or incineration, locally,regionally or nationally (e.g. VLLW)• on-site or adjacent to site disposal (e.g.decommissioning rubble)• other near surface facilities, locally, regionallyor nationally (e.g. LLWR)The Environment Agency, SEPA and theEnvironment Agency for Northern Ireland havejointly published Guidance on the Requirements forAuthorisation for near surface disposal facilities(Ref. 12) to ensure doses to people and theenvironment are ALARA (as low as reasonablyachievable) for these management options.5.5.1 LLWR Segregated Waste ServicesIn response to a number of drivers, including therevised LLWR contract, Government policy, thedevelopment of this strategy and a recognition thatalternative waste management options were neededfor LLW in the UK, LLW Repository Ltd has setabout expanding its service offering, as notedelsewhere in this document.In the past LLWR services were comprised primarilyof compaction, container supply and waste disposal.In order to improve availability of alternative wastemanagement options LLW Repository Ltd is set tooffer metal treatment, incineration and alternativeVLLW disposal, in addition to its existing services.These services will encourage better segregation ofwaste and the application of the waste managementhierarchy. In development of this strategy we havelearnt that wastes are often not segregated becauseof the lack of alternative accessible wastemanagement routes. Many waste producers havecontracts with LLW Repository Ltd and these newservices are being introduced as an extension tothose existing contracts, making these alternativetreatment routes readily available to all current andfuture waste producers, both NDA and non-NDAsites, large or small.We are supporting LLW Repository Ltd indeveloping these services and see theimplementation and use of them by NDA and non-NDA sites as critical to the success of this strategy.This is particularly the case for the near term asthese services are likely to be available sooner thandirect contracting with the supply chain by individualLLW producers.In addition, as with container supply, the value ofhaving a broker arrangement to leverage supply toexisting and future waste managementorganisations (in the UK and overseas), throughopen and fair competition, offers the advantage ofpreferential rates as an alternative to disposal atLLWR, which is relatively expensive when lifetimecosts are considered.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 38

5.5.2 VLLW disposal and controlled burialGovernment’s policy for the management of solidLLW in the UK redefined a sub-category of LLW,called Very Low Level Waste (VLLW). It comprisestwo further sub-categories, high volume and lowvolume (see Glossary for more information). AllVLLW from the nuclear industry is considered highvolume VLLW by the Environment Agency; SEPAconsider the first 50 m 3 of waste from a NuclearLicensed Site as low volume VLLW. The policypromotes the use of a risk informed approach tothe management of waste and also indicates thatall options for the management and disposal ofLLW should be considered. Following applicationof the waste management hierarchy, this includesconsideration of disposal of VLLW to landfill, andwhere appropriate disposal of LLW to controlledburial sites, “provided the necessary safetyassessments can be carried out to the satisfactionof the environmental regulators” (Ref. 1).The use of alternative disposal routes needs tomeet the relevant safety requirements, as notedabove and be demonstrated to be the BestPracticable Environmental Option by the consignorsite, this should include consideration of localcommunity issues both at the consigning andreceiving sites. As directed in Government’s LLWpolicy, development of LLW management plansshould consider all available solutions formanagement of LLW; the proximity principle shouldbe considered as part of this. The Policyrecognises that the desire to avoid excessivetransportation of materials is an importantconsideration, however, noting that “it must bebalanced with all the other relevant factors on acase by case basis” (Ref. 1).The Environment Agency has produced initialguidance on how such activities will be regulated inEngland and Wales (Ref. 13), and the ScottishEnvironment Protection Agency (SEPA) will publishguidance in due course for such activities inScotland. LLW Repository Ltd have undertaken astrategic BPEO study for VLLW management, toevaluate the potential options from a nationalstrategic perspective. This has shown a preferencefor treatment of VLLW metal over disposal. It didnot show a preference for any particular disposaloption at a strategic national level. The outputs willbe published on the LLW Repository Ltd websitewhen they are available. Other waste managementorganisations are working to identify opportunitiesto assist the implementation of Government policyand provide viable waste management options toUK waste producers.The use of alternative disposal routes for VLLWand suitable LLW through controlled burial,provides a significant opportunity for effectivelymanaging suitable types of LLW and VLLW andextending the life of LLWR. In many cases,particularly for VLLW, the level of safety, securityand environmental protection offered throughengineered vaults goes well beyond that needed todemonstrate protection and meet regulatoryrequirements. Consequently, where the necessarysafety assessments can be carried out to thesatisfaction of the environmental regulators,diversion of VLLW away from LLWR is critical toimplementing Government policy and extending thepotential life of LLWR for waste that cannot bedisposed of elsewhere.In order to do this we will:• support the supply chain in developing newmanagement and disposal routes by explainingour role in the management of LLW andmaking available information on the wastesthat need to be managed and when they willarise• expect waste producers to make appropriateuse of alternative waste management anddisposal options for VLLW and controlled burial• support LLW Repository Ltd in thedevelopment of an alternative waste disposalservice for VLLW• evaluate options for disposal on NDA sites on acase by case basis (see Section 5.5.4)Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 39

The Strategic Environmental Assessment that supports the development of this strategy considersalternative disposal options for VLLW and certain LLW waste. Conclusions of this assessment are presentedbelow.• As LLW encompasses a large range of radioactivity and a highly engineered facility such as LLWR is notnecessarily required for lower activity waste and wastes containing short lived radioactivity, the use ofconventional landfills presents potential benefits to the management of LLW. New disposal facilities will berequired to demonstrate that disposal will meet the regulatory risk target prior to authorisation. The benefitof using landfill disposal options rather than vaulted disposal is achieved through reducing the rawmaterials used, ensuring the optimised use of the LLWR and improving the efficiency with which waste ispackaged reducing the total volume of packaged waste requiring disposal.• We do not believe that the use of landfill disposal for VLLW and suitable LLW will significantly affectremaining UK landfill capacity. Total estimated LLW arisings are 3 million m 3 over a period of 120 yearswith an average annual arising of approximately 30,000 m 3 . This is a small amount compared with 335million tonnes of non-radioactive waste arising each year (Ref. 7) and total remaining landfill capacity inEngland and Wales as of 2006 of 694 million m 3 (Ref. 14).More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations.Question 11 – Government’s policy for themanagement of LLW indicates that landfill disposalof LLW and VLLW should be considered whendetermining end points for these wastes. What doyou think should be the key considerations whencomparing landfill disposal with other options suchas LLWR, new vaulted disposal routes, etc?There are no plans at present to consider disposalin this facility of other suitable wastes from both thenuclear and non-nuclear industry.The existence of a LLW facility at the Dounreay sitewill not remove the requirement to implement thewaste management hierarchy and optimisemanagement of LLW at Dounreay.In order to make this happen we propose to:5.5.3 Dounreay LLW facilityDounreay Site Restoration Limited (DSRL), theNDA’s contractor at the Dounreay Site inCaithness, Scotland, has received planningconsent from Highland Council for a new LLWdisposal facility adjacent to the Dounreay sitefollowing a detailed BPEO process. The facility isplanned to comprise a number of vaults fordisposal of LLW and VLLW separately. The facilitywill accept waste from the Dounreay Site and theadjacent HMS Vulcan Naval Reactor TestEstablishment, owned by the Ministry of Defence,for which Dounreay already provides a LLWdisposal route. The development of the facilityreflects the decision in 2005 by the ScottishMinisters to direct SEPA not to grant anauthorisation under the Radioactive SubstancesAct 1993 to dispose of LLW from Dounreay toLLWR.• continue to develop and integrate plans for thenew Dounreay LLW facility• work with DSRL (and other stakeholdersincluding SEPA) to ensure optimisation ofwaste management at the site, includingappropriate implementation of the wastemanagement hierarchyConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 40

5.5.4 Proposals for on-site disposalA number of sites in the NDA estate areconsidering on-site disposal of LLW and VLLWfollowing discussion with stakeholders anddevelopment of contingency plans for wastemanagement to support their operations anddecommissioning plans. On-site disposal may be aviable option for the management of LLW andshould be considered amongst the alternatives. Aswith other options, robust business cases forimplementing such options will be required. Whenconsidering them there are a number of issues thatwe consider critical to this assessment, theseinclude consideration of:• the appropriateness of the site for the purpose• a comparison with other options available forthe management of the waste• environmental impact of constructing a newfacility compared with using an existing facility• consideration of the potential benefits in both alocal and national context• the ability to develop a robust EnvironmentalSafety Case for waste management anddisposal• stakeholder interests, including publicacceptability and supply chain involvement• impacts on potential future uses of the site(referencing NDA property strategy)• long term impacts on the site (de-licensing, endstate and end use)Due to the importance of local issues in developingthese proposals, they need to be addressed on acase-by-case basis. This may include considerationof all reactor decommissioning wastes.On-site disposal could also include in-situ disposal ,which is included in the 2007 LLW policy amongstthe disposal options available for consideration. Itmay provide a risk based approach to themanagement of certain contaminated land wasteswhere it can be demonstrated to meet regulatoryrequirements and can be shown to represent theBest Practical Environmental Option. Again, thiswould need to be considered on a case-by-casebasis given the influence of site specific issues insuch an approach.The Strategic Environmental Assessment which supports the development of this strategy considered on-sitedisposal. Conclusions of this assessment are presented below.• One of the benefits often identified with disposal on or adjacent to nuclear sites is reducing LLW transport.However, when considering disposal on or adjacent to nuclear sites there is a need to consider net impact ontransport. The transport implications of some LLW management options, such as disposal in engineeredvaults, involve significant amounts of construction transport and it is therefore possible that any benefit fromavoiding the need to transport waste from the site could be offset by additional transport to construct an onsite facility.• The widespread use of on-site disposal involves a larger number of relatively small facilities compared toother options and so may be less efficient in terms of raw material and resource use when compared with asmaller number of larger facilities.• The location of nuclear facilities has been determined by their suitability for nuclear operations rather than aswaste disposal sites. It is therefore not necessarily the case that existing nuclear sites are suited to radioactivewaste disposal, although they may be suited to other waste management facilities.More detailed information is available in the Environment and Sustainability Report which supports thisconsultation and is available from www.nda.gov.uk/consultations/.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 41

Question 12 – To what extent do you agree withthe key considerations set out above for on-sitedisposal proposals?5.5.5 Orphan wastesCertain LLW wastes are not currently suitable fordisposal at LLWR, for example because they donot meet the CFA, and at the present time do nothave a defined route for either treatment ordisposal. These waste are often described asorphan wastes.Because of the diverse nature of these wastes,determining the most appropriate managementoption for these wastes will in some circumstancesrequire a waste stream specific assessment. Theremay however, be opportunities for determining asingle approach for similar wastes that arise on anumber of sites. One of the initiatives implementedthrough the National LLW Management Plan(Section 7.2) will be to consolidate research anddevelopment on these waste streams across theNDA estate with the aim of determining the mosteffective management option for these wastes onbehalf of all sites. In some cases new treatmentand disposal routes may be required for specificwaste streams.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 42

6 Implementation of the strategyConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 43

6 Implementation of the strategyDuring the development of this proposed strategy anumber of synergies, opportunities and initiatives toimplement the strategy were identified.As noted previously the implementation of thisstrategy will need to be undertaken in compliancewith all relevant legal and regulatory requirements.More information on these requirements can befound on the websites of the Environment Agency,Health and Safety Executive and ScottishEnvironment Protection Agency and within the UK'sreports to the Joint Convention on the Safety ofSpent Fuel and Radioactive Waste.We have set out below some of the key aspects ofimplementing the strategy within the regulatoryregime, some of the key issues that affect theimplementation and how organisations will need towork together in order to deliver the strategy. InSection 7 we have included information on theNational LLW Management Plan, the detailed planfor implementation of the strategy.6.1 Encouraging the right behaviourThis LLW Strategy is intended to bring a change inhow LLW is managed in the UK nuclear industry,recognising that many consignor sites have alreadymade significant progress in bringing about thischange. In response to Government’s policy wewant to build on this by improving considerationand use of alternatives to the disposal of LLW,ensure the best use of the UK’s assets for themanagement and disposal of LLW and open newroutes such that waste producers have viableoptions to consider in making effective wastemanagement decisions. This aims to provideoverall flexibility and mitigate risk of constrainingprovision of continued capability and capacity forthe management of LLW, a critical enablingprocess to achieve our overall mission. In addition,this strategy aims to facilitate waste prevention andreduction via application of the waste managementhierarchy.We recognise that waste producers, both thosewithin and outwith the NDA estate, are the legallyresponsible entities for the management of thewaste they produce. This means that whilst NDAcan provide high-level strategic direction, NDAcannot directly instruct a waste producer to behavein any particular way. There are key areas wherethis strategy and the NDA can actively encouragethe right behaviour.• Waste producers will align with this strategy –This strategy responds to Governmentcommitments in policy. Following consultation,it will be endorsed by ministers and will feedinto the overall NDA strategy. We will alsowork with all stakeholders to demonstrate thevalue of the approaches outlined in thisstrategy, noting that in certain circumstancesother approaches may be appropriate on acase-by-case basis.• Communication and provision of information –we will proactively communicate withstakeholders and where appropriate shareinformation to support the waste managementdecision-making process.• Changing the business case – this strategy andthe underpinning information available, nowenable consignor sites to better understand thenational implications of their wastemanagement decisions – we would expectthese benefits and detriments to be included inconsignor site decision-making processes andinform the development of business cases forthe management of LLW presented to NDA byits delivery partners, recognising that sitebased decision making may lead to diverseoutcomes.• Feeding into environmental decision making -the findings in the development of the strategywill provide information that may influenceenvironmental decision making at the site level.• Incentivising – in some circumstances we maydeem it appropriate to use financial or othercontractual incentives to influence thebehaviour of NDA contractors; we will alsowork with LLW Repository Ltd to developpricing strategies for its services which supportimplementation of the LLW strategy. One wayto instigate change in waste managementcould be to set targets for reuse, recycling,using alternative management routes for LLW.• Strategic direction – we provide strategicdirection to NDA sites through specificationsand guidance; implementation of this strategywill be incorporated into these specifications.• Opening new routes – we are working withLLW Repository Ltd to make alternative routesfor the management of LLW available to all UKwaste producers. We are also working with ourConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 44

other site licence companies, waste producersand suppliers to provide win-win solutions andrealise opportunities for efficiencies.• Supporting the supply chain – we will supportthe supply chain in the development ofalternative waste management services, thismay include support to their stakeholderengagement activities in explaining our roleand the benefits to UK as a whole of alternativewaste management options.• Sharing good practice – we will work withwaste producers, the supply chain andRegulators to ensure that good practice in themanagement of LLW is communicated toenhance performance at NDA and other wasteproducing sites.Question 13 – Do you agree with the approachesset out for encouraging the right behaviour? Towhat extent do you think that waste recyclingtargets could have benefit to the national strategy?What potential benefits and difficulties would youenvisage from implementing such approaches?6.2 Working with others, consultation andpublic acceptabilitySuccess of this strategy will rely on implementationof the strategy by all parties involved in themanagement of LLW. To ensure commitment toeffective and efficient implementation,organisations will need to work closely to achievethe best results for all parties involved. The partiesdirectly involved in the implementation include:• Nuclear industry LLW producers• Non-nuclear industry LLW producers• LLW Repository Ltd• Regulators (EA, SEPA, NII, OCNS, DfT)• Planning Authorities• NDA• Waste management supply chain• GovernmentThe strategy has been developed to delivernational benefits across the UK. It is howeverrecognised that this strategy has an impact at everylevel, including regional, local and withincommunities.The Strategic Environmental Assessment has beenstructured to incorporate all relevant facets ofsustainability appraisal. It has provided insight andinformation on potential impacts at a national level,whilst drawing out aspects where particularregional and local concerns need to recognised.At a national strategic level, due to the nature ofLLW and VLLW within the nuclear industry, itappears that impacts of LLW management andtransport on the environment, people and societyare low. However, it is recognised that radioactivewaste, even LLW and VLLW, raises particularconcerns for the public and local communities.Perceptions associated with the radioactive natureof these operations also has the potential to createnegative economic impacts and negative feelingamongst the communities involved.In light of the above it will be essential to undertakecareful and considered engagement with localcommunities where the implementation of thisstrategy leads to proposals for new wastemanagement facilities or changes in approach toLLW management. Such engagement needs to beopen and transparent and should demonstrate whya particular management option for low level wastehas benefits over other options. In some cases,those benefits may operate at a national level inaddition to more local considerations. It is importantto recognise that LLW management decisions andfacilities have, like municipal waste management,the potential to be highly contentious.As per paragraph 31 of the UK LLW Policy (Ref. 1),the final strategy will provide guidance for national,regional, and local planning authorities asnecessary in the preparation of planning strategiesand their appraisal.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 45

6.3 Key Issues6.3.2 Development of legislationThere are a number of key issues that have thepotential to impact on the management of LLW inthe UK and consequently the success of thisstrategy. These issues are outlined below.There are a number of ongoing activities related toregulation of LLW and conventional waste that willaffect how LLW and VLLW are managed.6.3.1 LLWR Environmental Safety CaseGuidance on authorisation and licensing issuesassociated to new disposal routesLLW Repository Ltd is in the process of updatingthe Environmental Safety Case (formerly Post-Closure and Operational Environmental SafetyCase) in line with the requirements of theirRadioactive Substances Act Authorisation todispose of radioactive waste. The EnvironmentalSafety Case sets out to demonstrate that the facilitywill properly protect people and the environment.In order to do this LLW Repository Ltd needs toshow that the location, design, construction,operation and closure of the site meet a series ofprinciples and requirements (see Appendix 2). Thisinvolves an extensive programme of work andregular discussion with the Environment Agency.The Environmental Safety Case is due forsubmission to the Environment Agency by 1 May2011. The Environment Agency will then reviewthe safety case and determine whether it isappropriate to continue to dispose of waste at theLLWR. They will also define types and quantitiesof waste.The safety case plays an important role, not just ingaining authorisation to continue disposal at thesite, but also how it is operated. This may haveimplications for what waste can be consigned to thesite; this may include limits on the radiologicalnature of waste suitable for disposal, thechemo-toxic nature of wastes and also how it ispackaged. The safety case will also establish thesafe capacity of the site for waste.Over the development of the safety case we willwork closely with LLW Repository Ltd tounderstand the implications of the developingsafety case for implementation of the strategy andalso the implications of the LLW strategy for thesafety case. Specifically, over the next year, LLWRepository Ltd will be undertaking a process ofoptimisation during which they will assess theimpacts of this proposed strategy. This process, aspart of the consultation on the strategy, will be usedto inform the final version of the strategy.The Environment Agency has published guidanceon how they will regulate radioactive waste beingconsigned to landfill in line with the UK LLWPolicy. SEPA is expected to publish equivalentguidance for Scottish landfills later this year. Giventhat diversion of VLLW away from LLWR to otherfit-for-purpose routes is a key part of this proposedstrategy, availability of these routes will have asignificant influence on the success of the strategy,particularly in the near term.Review of Exemption Orders under the RadioactiveSubstances ActGovernment is currently in the process of reviewingthe suite of exemption orders made under theRadioactive Substances Act 1993 across the UK.This is driven by Government’s Better Regulationagenda and aims to simplify regulations on thoseusing exemptions whilst maintaining appropriateprotection to human health and the environment.The programme will ensure that the future suite ofExemption Orders:• are easier to follow and interpret• meet current legislative standards in terms ofmodern legal drafting requirements• are transparent and easier to useCurrent proposals suggest that the revisedexemption orders will be risk informed and may useother existing standards in their formulation, forexample BSS and ICRP (International Commissionon Radiological Protection) levels. The proposalsare radionuclide specific and will allow wastes withhigher levels of lower hazard radionuclides to beexcluded from regulation than is currently the case.More restrictive limits would be imposed for theConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 46

clearance of wastes containing more hazardousradionuclides. The review of exemption ordersshould not change the volume of waste to bemanaged, but may:• result in some wastes currently designated‘radioactive’ to be changed to ‘not-radioactive’and vice versa• change the permitting requirements for somewastesPhase II of the Environmental PermittingProgrammeIn England and Wales the Government has justcompleted a consultation on Phase II of theEnvironmental Permitting Programme (EPP)including the expansion of the EnvironmentalPermitting Regime to the regulation of radioactivesubstances. The EPP is a major Defra, DECC,Environment Agency and Welsh AssemblyGovernment initiative that has created a singlemore user-friendly and modern permitting andcompliance system for Waste ManagementLicensing and Pollution Prevention and Control,while maintaining standards of environmentalprotection. The current proposals for expanding thisregime to include radioactive substancesregulation have the potential tostreamline administrative arrangements for theregulation of radioactive wastes and make sucharrangements more consistent with conventionalwaste management regulation. The proposalsalso have the potential to streamline the transfer ofradioactive wastes between sites, facilitating multisiteapproaches to waste management.6.3.3 New Nuclear BuildIn Section 2.1 we set out our definition of the nuclearindustry for the purpose of this strategy. In January2008 the UK Government published a White Paperon Nuclear Power in which it set out its view thatnew nuclear build should have a role to play in theUK’s future energy mix. As such, there is potentialfor the nuclear industry to change significantly in theforeseeable future. There are two ways in which thisstrategy will have interactions with nuclear newbuild.• Firstly, the development of new nuclear powerstations will increase the amount of LLW that willneed to be managed. Prospective vendors ofnuclear reactors indicate that the volume ofwaste generated by both operating anddecommissioning new build reactors will not besubstantial when compared to the waste alreadyin the inventory. This will, of course, depend onhow many new stations are built and as thisbecomes better understood the LLW strategywill need to be reviewed in light of this.• Secondly, an operator of a new nuclear powerstation will be required to have a FundedDecommissioning Programme (FDP), approvedby the Secretary of State for the Department ofEnergy and Climate Change, in place beforeconstruction of the power station begins.Potential new nuclear operators will thereforeneed to engage with NDA, LLW Repository Ltdand other LLW management providers onspecific issues, in order to develop their FDPs.6.3.4 Contaminated groundA number of sites in the UK (both NDA and non-NDA) either have, or may have, land contaminatedby radioactive materials. Remediation of these sitesmay require the management of substantialquantities of material. Whilst the management ofradioactively contaminated ground does not have toresult in the generation of waste, it is likely that someground (typically soil and rubble) will be consignedas LLW. Indeed some sites already declare avolume of ground-derived material as LLW in theirwaste inventory. At the present time contaminatedground declared as waste amounts to around0.5 million m 3 , which is equivalent to approximately17% of the LLW inventory. There is a significantamount of potentially contaminated ground that hasnot yet been declared as waste because it is not yetwell characterised and / or a management optionhas not yet been selected. This quantity of materialis in excess of the total inventory of LLW (estimatessuggest there could be 13 million m 3 (Ref. 6)) andpresents a significant risk to this strategy (seeSection 7) because of the impact that this materialcould have on the inventory of waste to bemanaged.In order to address this issue, in the immediate termwe are working with the regulators to fullyunderstand the requirements on sites which haveground contaminated and/or ground potentiallyConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 47

contaminated with radioactive material (and nonradioactivecontamination). We are also workingwith the regulator community and sites to fullyunderstand the options available for land qualitymanagement.In the longer term, this will allow more focussedcharacterisation of sites and an improvedunderstanding of the situation, including a betterknowledge of what volumes of material will requiremanagement as waste and where opportunities existfor the management of contaminated ground in-situ.The desired end state and end use for a given sitewill be critical to this understanding. As thisunderstanding improves we will be able to determinethe impact on the LLW strategy and develop it asrequired.6.4 Classification of waste and theimportance of a robust inventoryThe UK Government, via NDA, periodically publishan inventory of radioactive waste in the UK incompliance with EU requirements. The most recentversion of this is the 2007 UK Radioactive WasteInventory (Ref. 6). This inventory provides areference source of information for Governmentand its agencies, and others with a role or interestin the management of radioactive waste. Itspublication is one facet of the continuingcommitment of the UK Government and theorganisations responsible for radioactive wastes toopenness and transparency in matters relating tothe management of these wastes.strategy. A number of initiatives are planned toimprove our understanding of wastes that need tobe managed, particularly in respect to the amountsof VLLW and exempt waste in waste inventoryforecasts.The National LLW Management Plan (seeSection 7.2) includes a number of projects that alsosupport the development and improvement of theinventory of LLW in the UK. This will examinewaste stream characterisation and consignmentprocesses, improve quality assurance and wasteforecasting and implement archiving of records.Classification of wastes has been raised earlier inthis document. For example, the Governmentreview of Exemption Orders under the RadioactiveSubstances Act (see Section 6.2.2), which mayhave an influence on the inventory. This could theninfluence the performance of the strategy in termsof the quantities of waste that will requiremanagement.Alternative approaches to the classification ofwastes are also considered at times by variousother organisations. Such alternative approaches,for example classifying wastes in line withapproaches adopted in other countries, may havebenefits to how we manage LLW. At presentGovernment is not considering any change inapproach to the classification of LLW, however,should this situation change it would be critical tounderstand the impact on the inventory and on thisstrategy.An inventory of wastes to be managed is alsoessential to effective waste management planning,both in the near term and in the long term. Indeveloping this strategy we have used theinformation supplied for the 2007 Inventorycombined with information on LLW submitted withthe 2008 lifetime plans for NDA sites. Theinformation was collated in the UK LLW StrategicReview and has informed the development of thisstrategy. Inventory collation and refinement is aniterative process and the maturity of estimates andforecast is strongly linked to the phase of operationor decommissioning a particular site or organisationis in.Moving forward we need continued improvement inwaste inventory data to continue to plan effectivelyand also to monitor the implementation of thisConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 48

6.5 Research and Developmentprogramme, which covers larger projectsdemonstrating the value of specific technologies.The NDA carries out research and development(R&D) through provision of funding for the R&Dneeds of its sites and also directly whereconsidered appropriate, as directed in the EnergyAct 2004. At NDA sites, site-based R&D iscaptured in Technical Baseline and UnderpinningResearch and Development documents (TBURDs).These are collectively used to information thedirectly funded R&D work. Direct funding includeswork related to the decommissioning of nuclearinstallations, the cleaning-up of nuclear sites andother NDA functions. This is achieved through aportfolio of work managed through the NDA andalso through funding of various academic,university based research programmes. Withparticular reference to the university programme,there is therefore a close link with skillsdevelopment in the nuclear industry.In general, the management of LLW is not aparticularly high-tech process and thereforeresearch and development in the area is unlikely torequire a major programme of innovations.However, there are key areas where further R&Dhas the potential to yield significant gains in themanagement of LLW and the implementation ofthis strategy. These areas include:• advancing techniques for effective sentencingof waste, especially bulk waste• further developing of existing techniques for themanagement of waste• bringing techniques from outside the nuclearindustry (conventional waste management) intothe management of LLW• better understanding opportunities for cotreatmentwith other wastes (for example ILWand non-radiological hazardous waste)• exploring opportunities for alternativeapproaches to disposal for certain materials(short lived ILW, long lived LLW etc) and otherspecifically challenging waste types, such asorganics and Ra-contaminated luminescentmaterials from the non-nuclear industryIn order to ensure that there is progress in theseareas the NDA will continue to fund work throughthe Direct Research Portfolio, our programme ofConcepts Projects (which cover small packages ofwork) and through the Technology Demonstration6.6 Sharing good practiceThe Energy Act 2004 instructs the NDA in carryingout its duties to ensure the adoption of what itconsiders to be good practice at its sites. In thedevelopment of this strategy, including discussionswith waste producers and the supply chain and atsite visits it is clearly evident that there is muchgood practice already in place in the managementof LLW in the nuclear industry. Dissemination ofthis good practice and wider take up will enhancedelivery of the strategy and generate newopportunities and benefits, such as greater valuefor money, in addition to meeting the requirementsof the Energy Act. In many parts of the industrygood practice is already shared, particularlythrough multi-site site licence companies andthrough topic specific working groups. However,there remain opportunities for improving thesharing of good practice.Whilst practices throughout the management ofLLW offer potential for sharing of good practice,four areas have been recognised for specificattention through the National LLW ManagementPlan:• minimisation• characterisation• segregation• recyclingFor each of these areas a specific project has beendetermined, more details about which can be foundin the National LLW Management Plan. In addition,the LLW Strategy Group, which has membershipfrom across the industry, will continue to meet andprovide the key vehicle for sharing good practiceand collation of information and opportunities inLLW management. To date, the LLW StrategyGroup has focused on development of thisstrategy; in the future, sharing of good practice,tracking progress and planning will become themainstay of the meetings.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 49

7 Risks, contingency plans andopportunityConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 50

7 Risks, opportunities and contingency plansDuring the development of this proposed strategy we have identified anumber of key risks that may affect the implementation of the strategy.These have been identified through technical assessment of the proposedstrategy, through the SEA and through dialogue with stakeholders.Conversely, implementation of the strategy represents a significantopportunity, which can be recognised at a number of levels.We have presented key risks below, including a high level indication of whatwe will do to mitigate the potential affects of risks (Section 7.1). In addition tomitigation of risks it is important to plan for implementation of the strategy torealise the significant opportunity presented. Section 7.2 providesinformation on the National LLW Management Plan, which sets an initial 54key initiatives designed to make this happen. Further initiatives may berequired as the strategy implementation evolves.Whilst we believe that this strategy will be effective and can be implementedwe also recognise that there is a need for a certain level of preparedness, inthe unlikely event that the strategy fails, i.e. contingency planning. This isalso covered later in this section (Section 7.3).Question 14 – To what extent do you agree with the risks and mitigation setout here?7.1 RisksRisk Comment / Impact MitigationLLW Repository Ltdunable to makeEnvironmental SafetyCase to continue use ofLLWR for disposal.LLW Repository Ltd is to submit a revised Environmental SafetyCase to the Environment Agency in 2011. Given the central role ofLLWR in the proposed strategy, this eventuality would require areview of the strategy and the approach to the management of LLWin the UK (see contingency planning below).LLW Repository Ltd has a significant programme of work ongoing todeliver the revised Environmental Safety Case. During theconsultation period for this strategy, LLW Repository Ltd will beconsidering the implications of the strategy and innovations at LLWRfor making the required safety case. This will enable them torespond to the consultation with a detailed assessment of the impactof the strategy on the site. The proposed LLW strategy will bereviewed in light of this response and amended should a significantimpact on the Environmental Safety Case project result from theproposed strategy.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 51

Risk Comment / Impact MitigationUncertainties in the LLWinventory mean thatmore, less or differentwastes need to bemanaged than theproposed strategy hasbeen designed toaddress.Very large quantity ofcontaminated groundneeds to be managed aswaste.The future inventory of LLW, including quantity, type and timing ofarising has uncertainty associated with it. This is because much ofthe waste has to be estimated, particularly for the latter years of thedecommissioning programme. This uncertainty is a well recognisedfeature of the exercise of producing a forecast of waste arisings andcarries with it a certain amount of risk. In addition to the uncertainty,the inventory of waste could change for a number of reasons suchas legislative change defining what is considered LLW, change indecommissioning programmes, waste from new nuclear build andnew wastes being identified. The impact of change in the inventorycould, for example, be an inability to meet demand for wastemanagement services should volumes of waste increasesignificantly at a given time. It is worth noting that, in general,changes in the inventory are associated with conservative/precautionary approaches to estimating, meaning that volumes andlevels of radioactivity tend to go down. This cannot however berelied upon.This risk has the potential to impact in the same way as theinventory risk. We have separated this issue as it covers materialthat at the present time has not been identified as waste.Contaminated ground at some sites has been characterised andmanagement solutions identified, even if only at a high level. Insome cases this has also led to identifying what material will bemanaged as waste. However, significant areas of ground potentiallycontaminated with radioactivity have not yet been characterised indetail and management approaches determined. This means thatthere could be a need for contaminated ground to be managed aswaste. The amount of material to be managed could be greater thanthe total inventory of LLW as we understand it at present.All major producers of LLW (NDA and non-NDA) contributed to theUK radioactive waste inventory, which is completed every threeyears. In addition, NDA sites are required to submit forecasts ofwaste annually as part of their Lifetime Plan/ Integrated WasteStrategy. This regular update to the inventory of LLW provides anopportunity to review the impact on the LLW strategy and preparefor any major change. In general we would expect a few yearsbetween the change in the inventory forecast and the actual changein waste arising.In addition to annual review of inventory, together with LLWRepository Ltd and waste producers we are reviewing particularwaste streams that have an impact on the LLW strategy and theLLWR Environmental Safety Case to improve confidence in ourunderstanding. This approach has already brought usefulinformation to light that has brought particular benefit to theEnvironmental Safety Case. We are also investigatingstandardisation of characterisation procedures which may benefitthe collation of the waste inventory.Thirdly, inventory management is also required by regulators andother specific inventory improvement projects are underway.In order to address this issue, we are working with the regulators tofully understand the requirements on sites that have contaminatedand potentially contaminated ground. We are also working with theregulator community and sites to fully understand the optionsavailable for land quality management.In the longer term, this will allow more focussed characterisation ofsites and an improved understanding of the situation, including abetter knowledge of what volumes of material will requiremanagement as waste. Linkages with the desired end states anduses for a given site will be critical to this understanding. As thisunderstanding improves we will be able to determine the impact onthe LLW strategy and develop it as required.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 52

Risk Comment / Impact MitigationDifficulties in segregatingwaste at consignor sitesimpede implementationof the strategy.Alternative disposalroutes for VLLW (andcertain LLW) are notavailable.Central to delivery of this strategy is the requirement for wasteproducers to segregate waste into waste types, such that the mostappropriate management option can be employed in dealing withthat waste type. There is potential that waste producers may not beable to implement effective segregation due to a number of issues,including availability of space, unsuitable levels of waste generatedand other technical issues. Failure to segregate waste would lead tomore waste than is strictly necessary being disposed of at LLWR,reducing the potential for extending its life.In accordance with UK policy, which was subject to several roundsof public consultation, significant gains can be made in themanagement of LLW in the UK by a proportionate approach to thedisposal of low level waste, in particular VLLW. However, there areissues associated with implementation of this element of thestrategy, not least of which is public acceptability of disposal ofVLLW at conventional landfill sites. Disposal of VLLW to landfill is inaccordance with Government policy and has been demonstrated tobe safe; however, it remains an issue of concern for certainstakeholders.In order to address this risk we will work with LLW Repository Ltd toinvestigate the benefits of standardising sorting and segregation ofwaste and develop standard procedures if appropriate. We will alsowork with LLW Repository Ltd and waste producers to share goodpractice in the segregation of waste. There is also an opportunity toprovide incentives for the segregation of waste through pricingstrategies at LLWR. Finally, we will look to LLW Repository Ltd toprovide solutions that help sites segregate more (i.e. appropriatecontainers etc)Before a landfill site can receive VLLW or LLW it will have to obtainan authorisation from the Environment Agency or SEPA (dependingon where it is located). In order to obtain this authorisation theoperator of the landfill will have to demonstrate to the relevantagency that its operations will meet regulatory risk targets and may,for higher activity LLW, be required to develop a more detailedEnvironmental Safety Case to demonstrate this fact. Moreinformation can be found at: http://www.environmentagency.gov.uk/business/sectors/100241.aspxProspective operators of such facilities will need to engage ineffective and open dialogue with local communities to explain theoperations and the issues associated with it.NDA has a role in demonstrating the benefits to the UK of adoptingthis approach to the management of VLLW.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 53

7.2 Opportunity: National LLW ManagementPlanIn response to Government’s policy, we recognisedthat strategy in some areas would require greaterfocus on tactical solutions to fully address our policycommitments. As such, LLW Repository Ltd,supporting NDA has been tasked with developing aNational LLW Management Plan (Ref. 3), which isintended to sit alongside the UK nuclear industryLLW strategy and provide the detailed initiatives thatwill help to realise the significant opportunitypresented by the proposed strategy. This plan waspublished in draft form in February 2009 and isavailable for review on the LLWR website:http://www.llwrsite.com/llw-strategy-group/consultationdocumentsThe plan details a number of initiatives developed aspart of LLW Repository Ltd’s programme to supportthe NDA strategy. The plan includes details of theneed, scope, priority, deliverables and a schedulefor each initiative. The plan also proposes ownersfor these initiatives and assesses the currentavailability of funding to support the initiatives.summary of the current plan contents is provided inTable 1 below.Table 1 – Summary of the content of the National LLW Management PlanNo. Initiative Potential MechanismWaste Avoidance / Minimisation (WAM)1 Standardise waste avoidance and minimisation Waste Management Hierarchy guidance documentprogrammes2 Improve consistency of application of Nuclear Industry Formal NICoP programme on LLW ManagementCode of Practice (NICoP)3 Incentivise waste minimisation Performance-based incentives for waste managementhierarchy implementation4 Identify and share waste avoidance and minimisation Website on waste minimisation practicesbest practicesWaste Characterisation (WC)5 Standardise characterisation programmes Guidance document on waste characterisation6 Consolidate R&D on characterisation Website on waste characterisation R&D7 Identify and share characterisation best practices Website on good practices in LLW management8 Centralised provision of characterisation equipment Waste characterisation servicesand/or SQEP resource9 Re-estimate wastestream characterisation Evaluation and re-characterisation of waste streamsWaste Segregation / Categorisation (SC)10 Develop guidance on segregation best practices Guidance document on waste segregation practices11 Incentivise segregation of wastes Performance-based incentives on waste segregationimplementation12 Standardise design of waste segregation facilities Published design concept for segregated wastesWaste Treatment (WT)13 Incentivise treatment of wastes Performance-based incentives; contract and CFA modificationsfor LLW treatmentConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 54

No. Initiative Potential Mechanism14 Develop metal treatment routes Metal treatment services15 Develop incineration routes Combustible waste treatment services16 Supply chain provide new treatment facilities, capacity Waste treatment servicesand capabilities.17 Improve efficiency and utilisation of existingIndependent incineration studyincinerators at nuclear sites18 Improve efficiency of existing NDA metalIndependent metal decontamination studydecontamination facilities19 Consolidate R&D on orphan and hazardousConsolidated R&D recommendations for hazardous and orphanwastestreamswastesRecycle / Re-use and Exempt Waste (RR)20 Identify and share re-use and recycling best practices Website for sharing re-use and recycling good practices21 Develop mechanism for co-ordination of supply and Enhanced material trading platform for wastedemand for materials22 Re-use/recycle waste in new construction projects in Performance-based incentives on waste re-usenuclear industry23 Re-use/recycle in new construction projects outside Communication of re-use and recycle projectsnuclear industryWaste Disposal (WD)24 Develop alternative routes for exempt waste disposal Communication of initiative results25 Develop alternative routes for VLLW disposal Segregated waste treatment service at LLWR26 On-site/Near-Site disposal of VLLW on existing NDAsites27 On-site/Near-Site disposal of LLW on existing NDAsites28 Disposal of some LLW to Deep Geological Repository(e.g. long-lived isotopes)Alternative VLLW disposal routesStrategic BPEO for on-site/near-site facilitiesStudy on Environmental Safety Case (ESC) implications fordisposal of long-lived radionuclides29 Disposal of short-lived ILW in near-surface facilities Study on disposal options for ILW containing short- livedradionuclides30 Alternative Vault Designs Vault 9 Post-project design review and recommendations31 Optimise closure of LLWR ESC submittal to EA32 Disposal of NORM to alternative facilities Non-Nuclear Industry LLW Strategy33 Decay storage of short-lived LLW Study on disposal options for LLW containing short- livedradionuclides34 In-situ management of contaminated ground NDA Strategy for Land Quality ManagementWaste Packaging (WP)35 Develop methods and tools for improving waste Guidance document on LLW packagingpackaging efficiency.36 Use of reusable containers for transport of LLW Technical report on re-usable LLW containers37 Introduce inner disposal liners for non-compactablewasteDesign specification for LLW disposal linerConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 55

No. Initiative Potential Mechanism38 Introduce puck overpacks for compacted waste Design Specification for 1-m 3 box liner39 Introduce small modular containers for segregatedwastesDesign specification for modular inner-packaging containerliners40 Introduce reinforced bags for VLLW Design specifications for VLLW PackagesWaste Transportation (TRAN)41 Use of transport hubs Transport feasibility study42 Increased use of rail transport Transport feasibility study43 Integration of LLW and spent fuel rail shipments Transport feasibility study44 Transport of large components whole Transport feasibility studyWaste Tracking / Inventory Management (TIM)45 Simplify waste consignment processes Web-based LLW management and shipping tracking systems46 Improved waste quality assurance processes Quality Assurance guidance document for LLW47 LLW records consolidation and archiving National LLW Records Archive48 Improve waste forecasting Web-based inventory management systemOther (OTHER)49 Development of UK LLW Strategy National LLW Strategy and National LLW Management Plan50 Preparation of national strategic option assessments Strategic Option and Opportunity Studies51 Enhance communications within LLW managementcommunity52 Establish Principles for Decontamination andDecommissioning53 Develop strategy to optimise use of current/futureNDA assets54 Introduce risk-based classification of radioactivesubstances and wasteImplementation of the National LLW Strategy GroupFormal NICoP programme on LLW managementStrategic Environmental Assessment for National LLW StrategyEnvironmental Safety Case for LLWRConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 56

The National LLW Management Plan will be furtherdeveloped through 2009, where it will be informedby stakeholder input through the National LLWStrategy Group and through this consultation onthe UK nuclear industry LLW strategy. Themanagement plan is planned to be published in fullfor the first time in 2010 and revised annuallythereafter.LLW Repository Ltd has also, under contract,produced Initial and Preliminary OperationalStrategies, that set out how they will provide therequired LLW storage and disposal capacity atLLWR to meet the needs of UK LLW producerspresent and future, subject to an acceptedEnvironmental Safety Case. The objectives of theLLWR Operational Strategy are to transform theLLWR from a storage and waste handling site to afully integrated waste management operation,providing a full service across the broad spectrum ofwaste management activities in support of NDA,LLWR and consignor initiatives. The LLWROperational Strategy was developed around thedriving principles that recognise the need for:• disciplined and integrated implementation of thewaste hierarchy at the site of waste arising• minimising the burden on the environment fromdisposal of radioactive wastes by minimisingvolumes of waste destined for the LLWRthrough consignor support• emplacing into LLWR vaults only those wastesthat require multi-barrier containment for humanhealth and environmental protection ensuringthe best use of engineered disposal at LLWRImplementing the LLWR Operational Strategy isintended to provide the required storage anddisposal capacity for waste arisings until 2070. ADeveloped Operational Strategy will be issued byLLW Repository Ltd by March 2010, embeddinglearning from the strategy.7.3 Contingency planningWhilst we believe that this proposed strategy canbe implemented and has a good chance of successit is important to have some understanding of whatmay be required in the unlikely event that theproposed strategy should not fully meet itsobjectives. The following sets out the contingencyoptions available in this case. Firstly, shouldsupply chain approach be unsuccessful, then wemay need to consider development of facilities bythe NDA to support the implementation of thestrategy (either directly or through NDA SLCs).Secondly, should the strategy fail completely wemay need to develop a successor facility to LLWR.If the strategy is unsuccessful the implicationscould be significant. The proposed strategy, ifimplemented fully, has the potential to extend thelife of LLWR to 2070. Without adoption of thisstrategy and a consequent change in currentpractices for LLW management in the UK, LLWRcould be full as soon as 2037 or earlier. As set outbelow, we believe that the (lifetime) costsassociated with a new facility would be in theregion of £2 billion and such a facility would requirea minimum lead in time of 11 years (Ref. 15).Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 57

7.3.1 Contingency 1 – development of facilitiesby NDAThis draft LLW strategy looks towards the supplychain for provision of alternative treatment anddisposal options to assist in implementation of thewaste management hierarchy. The supply chainmay include waste producers themselves. ForNDA sites, developments in this area will be drivenby the aspirations of the site and robust businesscases will be required to demonstrate the value ofinvestment by NDA in such projects. An exampleis the inclusion in the LLWR lifetime plan of VLLWdisposal at the site and consideration of this optionfor certain wastes at other sites.In the near term, this strategy does not proposecentrally driven investment to deliver alternativewaste management solutions. However, shouldsolutions not be forthcoming we will need toconsider whether central investment will berequired to deliver the strategy. A detailedassessment of the new strategy options, costs andbenefits would be required before taking such anapproach. A review of the UK nuclear industryLLW strategy would seem appropriate at such atime.Development of specific new facilities would requirea robust business case that provides a reasonedargument for the investment. It would also need anassessment of the other options and theenvironmental and social impact, perhaps throughBPEO study or similar alternative. The businesscase would need to follow Government guidance(at present Treasury’s five case model).7.3.2 Contingency 2 – development of asuccessor facility to LLWRDevelopment of a new LLWR to take up thisnational role would be a significant project. Thelifetime costs of setting up and operating such arefacility are estimated to be very roughly in theregion of £2 billion (Ref. 15) (depending on the sizeof the facility, the time and amount of waste beingdisposed of at the facility etc).In addition to securing funding for the developmentof a new disposal facility, understanding the lead-intime for development the development is critical toensuring continued capability to manage LLW inthe UK. Based on international experience thelength of time from a decision to pursue a newfacility to that facility being available is in the orderof 11 years (Ref. 15).A number of factors affect both the cost anddevelopment time of a new national LLW disposalfacility. A key issue would be finding a suitablelocation for the facility and gaining publicacceptance for the siting of the facility. It could beexpected that a process similar to the volunteerismprocess for the Geological Disposal Facility wouldbe called for by some stakeholders.In order to know when to implement thiscontingency measure we would need to know atwhat point we had at the very least, only 11 yearscapacity for LLW management remaining. Inreality, it would be prudent to begin such a processallowing more than 11 years to deliver the project.As noted above, it is believed that the LLW strategycould extend the life of the present LLWR to 2070(or possibly even longer). Without change in ourapproach to LLW management, LLWR could be fullas soon as 2037 (and this would requireconstruction and relevant approvals for all plannedvaults). This suggests that if improvements are notrealised in the near future a decision ondevelopment of a new facility would be needed atthe very latest in 2016. Implementation of theproposed UK nuclear industry LLW strategy coulddelay this need for decades.One of the main strands of the proposed UKnuclear industry LLW strategy is the optimised useof the LLWR facility. Optimised use of the facility isintended to extend the life of the facility and deferthe need to develop a successor facility. Shouldalternative waste routes not become available,through the supply chain or through directprovision, a less optimised approach to the use ofLLWR is the likely result. This will ultimatelyrequire the development of a successor facility toLLWR when the current site is full.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 58

8 Next stepsConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 59

8 Next stepsThe next steps for development andimplementation of the UK Nuclear Industry LLWStrategy are set out below.• Formal public consultation of this Draft LLWStrategy and Strategic EnvironmentalAssessment (SEA) from May to August 2009• Following consultation, the LLW Strategy willbe updated and recommended to Governmentfor approval in early 2010• Ongoing dialogue on the LLW strategy andplans for implementation through activeparticipation and engagement at the NationalLLW Strategy Group and other stakeholderforums• Development and performance ofimplementation plans and strategic businesscases on early strategic initiatives as set forthin the LLW Management PlanThe collective implementation of the LLW Strategyand management plan initiatives could produce astep-change improvement in LLW managementpractices across the UK. Improved safety andenvironmental benefits as well as significantsavings to the current LLW baseline could result.Extension of the operational lifetime for the LLWRepository could also sustain long-termdecommissioning and cleanup for the NDA estate.A summary of the consultation questions for the UKnuclear industry LLW strategy is provided below.8.1 Summary of consultation questionsQuestion 1 – Do you agree with the proposed approach to avoidance and characterisation of waste? What arethe most important areas for work and are there other actions that could be undertaken?Question 2 – Re-use and recycling of waste from the nuclear industry could yield significant benefits – do youagree with this approach and where do you see the significant opportunities for implementing the option?Question 3 – To what extent do you believe that compaction still has a key role to play in the optimisation ofLLW management? What are the opportunities for improving the use of compaction?Question 4 – Do you agree that the benefits of metal treatment outweigh the detriments? If not, why not? Ifmetal treatment costs more than disposal to implement, is this acceptable?Question 5 – Do you agree with the proposals set out for thermal treatment? If not, why not? As incineration isoften a controversial approach, what should be the key message if the LLW strategy were to actively promotethe use of this technology?Question 6 – We believe that the majority of waste management solutions that are required to implement thisstrategy are or will be available, either in the nuclear estate or through the supply chain and therefore should beused in preference to centralised investment in new infrastructure. To what extent do you agree with thisstatement?Question 7 – Do you agree with the approaches set out above for the development of an optimised approachto management of LLWR?Question 8 – What are the key considerations that should influence the development of new packagingsolutions for LLW management?Question 9 – The impacts of the transport of LLW are limited when compared to transport of other materials,when considered at a national level. However, it is a very significant issue for local communities where thetransport is taking place. How do you think this should be factored in to national strategy?Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 60

Question 10 – To what extent does a movement of waste from road to rail for transport represent a significantimprovement? Do you see any disadvantages to this approach?Question 11 – Government’s policy for the management of LLW indicates that landfill disposal of LLW andVLLW should be considered when determining end points for these wastes. What do you think should be thekey considerations when comparing landfill disposal with other options such as LLWR, new vaulted disposalroutes, etc?Question 12 – To what extent do you agree with the key considerations set out above for on-site disposalproposals?Question 13 – Do you agree with the approaches set out for encouraging the right behaviour? To what extentdo you think that waste recycling targets could have benefit to the national strategy? What potential benefitsand difficulties would you envisage from implementing such approaches?Question 14 – To what extent do you agree with the risks and mitigation set out here?Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 61

APPENDICESConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 62

AppendicesAppendix 1 - The National LLW Strategy GroupThe National Low Level Waste Strategy Group(LSG) has been established to develop a workingpartnership between the Nuclear DecommissioningAuthority, LLW Repository Ltd, Regulators,Stakeholders and LLW Waste producers to promoteinnovation, value for money, and implementation ofthe waste hierarchy by planning for effective wastedisposal solutions. This initiative will supportongoing nuclear operations, the nuclear sitedecommissioning and remediation programme andLLW management needs of ‘non-NDA’ commercialorganisations. The National Low Level WasteStrategy Group shall serve as a primary point ofcontact for integration and engagement on LLWinnovations, issues, and strategy development.Membership of the Low Level Waste Strategy Groupincludes senior representatives from the NuclearDecommissioning Authority, Regulators,Stakeholder groups, and LLW Consignor sites thatare actively generating low level waste. The nuclearindustry supply chain is represented on the LLWStrategy Group by the Nuclear Industry Association.Each member is responsible for representing theviews and interests of their parent organisation andfor promulgating the business of the Strategy Groupback into their parent organisation.In addition to the formal membership of the StrategyGroup, other participants and organisationalrepresentatives will be invited to attend StrategyGroup meetings at the Chair's discretion.Corresponding participants will also be notified offuture meetings and topics of discussion and / orreview.The following organisations are represented eitheras members or corresponding members of the LLWStrategy Group:OrganisationNuclear Decommissioning AuthoritySellafield Site Ltd (including Capenhurst)Environment AgencyDounreay Site Restoration LtdScottish Environment Protection AgencyMagnox North SitesHealth and Safety Executive(Nuclear Installations Inspectorate)Magnox South SitesHealth and Safety Executive(Office for Civil Nuclear Security)Research Sites Restoration LtdDepartment of Energy and Climate ChangeSpringfields Fuels LtdDepartment for Environment, Food and Rural Affairs Low Level Waste Repository LtdScottish GovernmentMinistry of DefenceWelsh AssemblyAWE (Atomic Weapons Establishment)Northern Ireland AssemblyBritish EnergyNuLeAF (Nuclear Legacy Advisory Forum)GE HealthcareCumbria County CouncilNuclear Industry AssociationScottish Councils Committee on RadioactiveSubstancesDepartment for TransportConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 63

Appendix 2 - Regulation of LLWIn the UK, the Radioactive Substances Act 1993(RSA93) provides the framework for controlling themanagement of radioactive material and wastes soas to protect the public and the environment, andfor regulatory functions in relation to RSA93, theBSS Directive 96/29/Euratom has beenimplemented in the UK by country-specificregulations.Defra and the Environment Agency are at the timeof writing consulting on the extension of theEnvironmental Permitting Regime to encompassradioactive substances regulation. If this proposalis pursued following consultation this would replacethe Radioactive Substances Act in England andWales although it would not change the expectedregulatory standards and outcomes for radioactivesubstances. In Scotland, RSA 93 would remain.facilities, will meet a series of principles andrequirements. The regulators have just publishednew guidance (called Near-surface DisposalFacilities on Land for Solid Radioactive Wastes -Guidance on Requirements for Authorisation, GRA(Ref. 12)) which sets out these principles andrequirements, and which indicates how they arelikely to be interpreted. The guidance also providesinformation about the associated framework oflegislation, government policy and internationalobligations.The Environment Agency has also publishedfurther guidance on how they will regulate thedisposal of low level radioactive waste to landfillsites. Further details can be accessed here:http://www.environmentagency.gov.uk/business/sectors/100241.aspxRole of the NII in LLW managementExemptions from regulationAll materials are radioactive to some extent, andthere is some waste which is not required to besubject to specific regulatory control, because thelevels of radioactivity contained within it are eithernot possible to control, or are so low that regulationis not warranted. Such radioactive wastes can bedisposed of in the same manner as othermunicipal, commercial and industrial wastes i.e. tolandfill or incineration, without authorisations underthe Radioactive Substances Act 1993.UK Government is undertaking a review ofSchedule 1 of RSA93, and the entire suite ofexemption orders. The purpose of the review is tosimplify and rationalise the exemptions and todemonstrate clearer compliance with the BSSDirective 96/29/Euratom.Regulatory guidance on requirements forauthorisationThe developers and operators of facilities for solidradioactive waste disposal (i.e. low level wasterepositories or landfill sites that could take LLW andVLLW) have to demonstrate to the regulators thatthe facilities will adequately protect people and theenvironment. To do this, they will need to showtheir approach to developing and operating thefacilities, and also demonstrate that the location,design, construction, operation and closure of theUnder UK law (the Health and Safety at Work etc.Act 1974) employers are responsible for ensuringthe safety of their workers and the public, and this isjust as true for a nuclear site as for any other.This responsibility is reinforced for nuclearinstallations by the Nuclear Installations Act 1965(NIA65), as amended. Under the relevant statutoryprovisions of the NIA a site cannot carry out certainactivities prescribed in the Act unless the user hasbeen granted a site licence by the Health and SafetyExecutive (HSE).This licensing function is administered on HSE'sbehalf by its Nuclear Directorate. NuclearDirectorate, sets out in conditions attached to a sitelicence the general safety requirements to deal withthe risks on a nuclear site which Licensees mustcomply with. These licence conditions includespecific requirements relating to the accumulationand storage of radioactive wastes on nuclear sites.The nuclear licensing regime is complemented bythe Ionising Radiations Regulations 1999 (IRR99)and other health and safety regulation which theHSE also enforces on nuclear sites as it does onany other sites. This general health and safetylegislation will also apply to non-nuclear sites whichtreat or dispose of LLW.Specifically any LLW treatment or disposal activitiesnot carried out on nuclear sites will continue to beregulated under the IRR99 by the HSE. Theseregulations place requirements on any employersConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 64

whose practices involve work with ionising radiationsto monitor exposure to ionising radiations and applynecessary controls in order to keep such exposureas low as is reasonably practicable. Theseregulations also include legal limits on workerexposure to radiation.Under the terms of relevant Memoranda ofUnderstanding (MoU), HSE consults with theEnvironment Agency or SEPA regardingenvironmental issues relating to its regulation ofnuclear sites.’Basic Safety Standards Directive - BSSLegislation on radiation protection in the EuropeanUnion is governed by the Euratom Treaty and theDirectives. The Basic Safety Standards Directive(96/29/Euratom) of 13 May 1996 is the frameworkdirective for radiation protection in the EuropeanUnion.It deals with radiation protection of exposed workersand the public. Member States are required toimplement the BSS Directive. The main aim oftheses Standards is to ensure that exposures arekept as low as reasonably achievable/practicableand that individual dose limits are not exceeded.The Radioactive Substances (Basic SafetyStandards) (England and Wales) Direction 2000implements the EU Directive 96/29/Euratom, whereapplicable, which lays down Basic Safety Standards(BSS). A similar Direction from Scottish Ministerswas issued to SEPA. Essentially the RS Direction2000 requires:based on the three principles of justification ofpractices, optimisation of protection and doselimitation as set out in ICRP60. These principles arereflected in UK legislation and policy for theregulation of LLW management activities.ARTICLE 37As a Member State of the European Union, UKactivities involving radioactive substances aregoverned by legislation set down under the EuratomTreaty. Article 37 of the Euratom Treaty states:Each Member State shall provide the Commissionwith such general data relating to any plan for thedisposal of radioactive waste in whatever form aswill make it possible to determine whether theimplementation of such plans is liable to result in theradioactive contamination of the water, soil orairspace of another Member State.The ‘disposal of radioactive waste’ within themeaning of Article 37 of the Treaty should cover anyplanned disposal or accidental release of radioactivesubstance, in gaseous, liquid or solid form in or tothe environment, associated with the processing orstorage of radioactive waste arising from operationsand dismantling of nuclear reactors andreprocessing plants.• individual and collective doses to be ALARA• annual dose constraints to be 0.3 mSv for anynew source, 0.5 mSv for any single site and 1.0mSv dose limit• undertakings to appoint Qualified ExpertsInternational Commission on RadiologicalProtection - ICRPThe International Commission on RadiologicalProtection (ICRP) is an independent internationalbody of experts set up to provide guidance on arange of topics relating to the protection of man fromthe harmful effects of ionising radiation.For practices involving the use of radioactivesubstances the system of radiological protection isConsultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 65

Appendix 3 - ReferencesNo.1.ReferencePolicy for the Long Term Management of Solid Low Level Radioactive Waste in the United Kingdom, ByDefra, DTI and the Devolved Administrations, March 20072. LLW Strategic Review, LLW Repository Ltd, 20083. National LLW Management Plan, LLW Repository Ltd, 20094.UK Strategy for the Management of Solid Low Level Radioactive Waste from the Nuclear Industry:Strategic Environmental Assessment - Environment and Sustainability Report, NDA and Entec, April20095. LLWR consolidated technical briefs, LLWR, 20096. UK Radioactive Waste Inventory as at 1 April 2007, NDA and Defra, March 20087. Defra, e-Digest Statistics about: Waste and Recycling8. United Kingdom, Parliament 1993. Radioactive Substances Act , 1993. HMSO, London9. Strategic BPEO for metal waste management, Studsvik, April 200610.11.12.Preliminary Strategic Assessment Report to Consider Thermal Processing for the Management ofSuitable Low-Level Radioactive Waste in the UK, 722500202/R403/Issue 1, Nuclear Technologies,November 2008Valuation of the external costs and benefits to health and environment of waste management options,Final report for Defra by Enviros Consulting Limited in association with EFTEC, December 2004Near-surface Disposal Facilities on Land for Solid Radioactive Wastes Guidance on Requirements forAuthorisation, Environment Agency, SEPA, Northern Ireland Environment Agency, February 200913. Guidance note: Disposing of radioactive waste to landfill, Environment Agency, 200914.15.Environment Agency landfill capacity statistics: http://www.environmentagency.gov.uk/static/documents/Research/ew_landfill_cap_06_1958423.xlsA Cost Estimate for the Successor Facility to the Low Level waste Repository (LLWR), Nuvia, March2009Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 66

Appendix 4 - GlossaryActivityThe number of atoms of a radioactive substance which decay bynuclear disintegration each second. The unit of activity is theBecquerel, which is equivalent to one disintegration per second.As Low As Reasonably Achievable (ALARA)The ALARA principle is contained in the Euratom Basic SafetyStandards Directive 96/29, which is transposed into UK law.Essentially, it means that all reasonable steps should be takento protect people. In making this judgement, factors such as thecosts involved in taking protection measures are weighedagainst benefits obtained, including the reduction in risks topeople and the environment.Becquerel (Bq)The standard international unit of radioactivity equal to oneradioactive transformation per second. Becquerels areabbreviated to Bq. LLW is classified according to its radioactivitycontent per unit mass of waste (Bq per gram, or per tonne).Multiples of becquerels commonly used to define radioactivewaste are: kilobecquerels (kBq) equal to one thousand Bq;megabecquerels (MBq) equal to one million Bq; gigabecquerels(GBq) equal to one thousand million Bq.Best Practicable Environmental Option (BPEO)In the context of authorisations under RSA93, for nuclear sites,the options’ assessment method currently used is BestPracticable Environmental Option (BPEO). BPEO was describedby the Royal Commission on Environmental Pollution, TwelfthReport (Cm 210) 1988 as “…. the outcome of a systematic andconsultative decision-making procedure which emphasises theprotection and conservation of the environment across land, airand water. The BPEO procedure establishes, for a given set ofobjectives, the option that provides the most benefit or leastdamage to the environment as a whole, at acceptable cost, inthe long-term as well as in the short term”. A BPEO study isusually carried out by or on behalf of the waste producer andassessed by the relevant environment agency as a basis for itsregulatory decision-making.Best Practicable Means (BPM)BPM is a term used by the environment agencies (EA andSEPA) in authorisations issued under the RSA93. Essentially, itrequires operators to take all reasonably practicable measuresin the design and operational management of their facilities tominimise discharges and disposal of radioactive waste, so as toachieve a high standard of protection for the public and theenvironment. BPM is applied to such aspects as minimisingwaste creation, abating discharges, and monitoring plantdischarges and the environment. It takes account of such factorsas the availability and cost of relevant measures, operator safetyand the benefits of reduced discharges and disposals. If theoperator is using BPM, radiation risks to the public and theenvironment will be ALARA.Clean-upThe decontamination and decommissioning of a nuclearlicensed site.Command 2919 (Cm2919)The Review of Radioactive Waste Management Policy: FinalConclusions White Paper published in July 1995. This was thelast comprehensive UK Government radioactive waste policystatement. Areas of this statement have been superseded bythe decisions and actions of subsequent UK Governmentadministrations.Controlled burialAlso known as “special precautions burial”. A process ofdisposal for solid LLW that has an activity level above that whichwould allow it to be disposed of as VLLW. Controlled burialtakes place at landfill sites used for the deposit of substantialquantities of ordinary refuse but which are approved for thedisposal of radioactive substances. Controlled burial has variouslimitations placed on its use in terms of maximum activity perwaste container, type of container, surface dose rate ofcontainer, and depth of burial beneath earth or ordinary waste.Decay storageThe process of allowing material containing short-livedradionuclides to decay so that the final waste is easier todispose of as radioactive waste, or until the point where thewaste becomes exempt from specific regulatory requirements.Used extensively in hospitals and research establishments, andto some extent by the nuclear industry.DecommissioningThe process whereby a nuclear facility, at the end of itseconomic life, is taken permanently out of service and its sitemade available for other purposes.DecontaminationRemoval or reduction of radioactive contamination.DelicensingThe process of removal from regulatory control by the Healthand Safety Executive, of a nuclear site, which has been licensedunder the Nuclear Installations Act 1965.DisposalIn the context of solid waste, disposal is the emplacement ofwaste in a suitable facility without intent to retrieve it at a laterdate; retrieval may be possible but, if intended, the appropriateterm is storage. Disposal may also refer to the release ofairborne or liquid wastes to the environment (i.e. emissions anddischarges).DoseA general term used as a measure of the dose absorbed by manfrom radiation, measured in sieverts, and its sub-multiples(millisieverts – mSv - equal to one thousandth of a sievert, ormicrosieverts, equal to one millionth of a sievert). Radiationdose is received from many sources – of the average annualdose of 2.6 mSv, 85 per cent comes from natural backgroundradiation, 14 per cent from medical sources and the remainingone per cent from miscellaneous man-made sources.Energy Act 2004An Act of Parliament, which (inter alia) established the NDA andset out its duties and responsibilities for the decommissioningand clean-up of the UK’s public civil nuclear sites.Environment Agency (or EA)The environmental regulator for England and Wales. TheEnvironment Agency’s role is the enforcement of specified lawsand regulations aimed at protecting the environment, in thecontext of sustainable development, predominantly byauthorising and controlling radioactive discharges and wastedisposal to air, water (surface water, groundwater) and land. Inaddition to authorisations issued under the RSA93, the EA alsoregulates nuclear sites under the Pollution Prevention andControl Regulations and issues consents for non-radioactivedischarges.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 67

European Union (EU)The European Union of countries of which the United Kingdomis a member. The EU issues its own legislation which the UK, asa member state, is obliged to follow.Exemption Order (EO)RSA93 makes provision for certain low activity wastes, whenused for certain purposes and when managed in particularways, to be excluded from particular regulatory provisions madeunder the Act.Fit for purposeIn the context of this document, a term applied to wastemanagement activities which are engineered to a degree that iscommensurate with the types of wastes they will receive. Forexample, for disposal, LLW towards the higher end of itsdefinition would go to a facility that has a greater degree ofengineering than those towards the bottom end of the definition.In all cases, the intention is that facilities will provide adequateprotection of people and the environment, and would meet allregulatory requirements.Health and Safety Executive (HSE)A statutory body whose role is the enforcement of work relatedhealth and safety law under the general direction of the Healthand Safety Commission established by the Health and Safety atWork Act 1974. HSE is the licensing authority for nuclearinstallations. The Nuclear Safety Directorate of HSE exercisesthis delegated authority through the Nuclear InstallationsInspectorate (NII) who are responsible for regulating the nuclear,radiological and industrial safety of nuclear installations UKwide.Integrated Waste Strategies (IWS)An integrated waste strategy is not a legal requirement but isrequired of contractors working under the auspices of the NDA.It covers solid radioactive waste in all waste categories (i.e.LLW, ILW, HLW). For example, during an options’ assessment,one option could be to store ILW until it decays to LLW.Intermediate level waste (ILW)Radioactive wastes exceeding the upper activity boundaries forLLW but which do not need heat to be taken into account in thedesign of storage or disposal facilities.International Commission on Radiological Protection (ICRP)An advisory body founded in 1928 providing recommendationsand guidance on radiation protection. ICRP recommendationsnormally form the basis for EU and UK radiation protectionstandards.Ionising Radiations Regulations 1999 (IRR99)The main legal requirements, enforced by the HSE, concerningthe control of exposure to radiation arising from the use ofradioactive materials and radiation generators in work activitiesin the nuclear industry; medical and dental practice;manufacturing; construction; engineering; paper; offshoredrilling; education (colleges, schools) and non-destructivetesting.LandfillThe disposal of waste by shallow burial. Modern landfills arelined to reduce seepage of material from the site into theenvironment, and once full, are capped to reduce rainfallentering the site. The EU Directive on the landfill of waste(Council Directive 99/31/EC) set targets for the reduction ofbiodegradable municipal waste sent to landfill.Licensed nuclear sitesA site given a licence by the NII under the Nuclear InstallationsAct.Low Level Waste (LLW)Includes metals, soil, building rubble and organic materials,which arise principally as lightly contaminated miscellaneousscrap. Metals are mostly in the form of redundant equipment.Organic materials are mainly in the form of paper towels,clothing and laboratory equipment that have been used in areaswhere radioactive materials are used – such as hospitals,research establishments and industry. LLW contains radioactivematerials other than those acceptable for disposal withmunicipal and general commercial or industrial waste. It is nowdefined as “radioactive waste having a radioactive content notexceeding four gigabecquerels per tonne (GBq/te) of alpha or 12GBq/te of beta/gamma radioactivity”.Low Level Waste Repository (LLWR) near DriggThe LLWR is in Cumbria and has operated as a national LLWdisposal facility since 1959. Wastes are compacted and placedin containers before being transferred to the facility. Following amajor upgrade of disposal operations in 1995, all LLW is nowdisposed of in engineered concrete vaults. The LLWR nearDrigg is owned by the NDA and currently operated by aconsortium of companies called UKNWM.Local communityIn the context of this document, those communities which maybe impacted by waste management plans, including any hostcommunity in the vicinity of a waste treatment or disposalfacility, and the local authorities concerned.LuminisingThe process of using a radionuclide with a material that emitslight when irradiated, for example, radium was used in oldwatches and instrument dials so their numbers could be seen asa green glow in the dark.Ministry of Defence (MoD)MoD sites producing radioactive waste are mainly thoseproducing and handling nuclear fuel for submarines and thoseproducing and handling radioactive materials for nuclearweapons.Nuclear Decommissioning Authority (NDA)The NDA was set up on 1 April 2005, under the Energy Act2004. It is a non-departmental public body with designatedresponsibility for managing the liabilities at specific sites. Thesesites are operated under contract by site licensee companies.The NDA has a statutory requirement under the Energy Act2004, to publish and consult on its Strategy and Annual Plans,which have to be agreed by the Secretary of State and theScottish Ministers.Nuclear Installations Act 1965 (NIA65)UK legislation which provides for the operation and regulation ofnuclear installations within the UK.Nuclear Installations Inspectorate (NII)See Health & Safety ExecutiveOffice for Civil Nuclear Security (OCNS)The independent security regulator for the UK civil nuclearindustry.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 68

OptimisationOptimisation is the process of ensuring that all radiationexposures of the public are as low as reasonably achievable(see ALARA). Optimisation is achieved by employing bestpracticable means (BPM). Optimisation, justification andlimitation are the three key principles of radiation protectionrecommended by the International Commission on RadiologicalProtection in 1990 and which form the basis of EuropeanCommunity and UK legislation.Planning authoritiesA general term for those regional planning bodies and localauthorities throughout the UK who are responsible for thepreparation of planning strategies and for determiningapplications for construction and operation of waste treatmentand disposal facilities that may be sited in their area ofresponsibility.Proximity principleThe Proximity Principle is a key element of EU environmentaland municipal waste management policy. It was introduced inArticle 5 of the Waste Framework Directive (75/442/EEC asamended by Directive 91/156/EEC), and is incorporated into UKwaste strategy documents.Radioactive wasteAny material contaminated by or incorporating radioactivityabove certain thresholds defined in legislation, and for which nofurther use is envisaged, is known as radioactive waste. (SeeRSA93 and NIA65.)RegulatorsIn the context of this document, principally those bodiesresponsible for the regulation of the nuclear industry and nonnuclearindustry LLW producers and treatment and disposalsuppliers (See Environment Agency, SEPA, HSE, Departmentfor Transport and the Office for Civil Nuclear Security.)RiskThe chance that someone or something that is valued will beadversely affected by a hazard, where a hazard is the potentialfor harm that might arise, for example, from ionising radiation.Radioactive Substances Act 1993 (RSA93)UK legislation which provides for regulation of the disposal ofradioactive wastes, including liquid and gaseous discharges tothe environment. It also provides for regulation of theaccumulation of radioactive wastes on non-nuclear sites: thisfunction for licensed nuclear sites being provided by the NIA65.Scottish Environment Protection Agency (SEPA)The environmental regulator for Scotland. SEPA’s role is theenforcement of specified laws and regulations aimed atprotecting the environment, in the context of sustainabledevelopment, predominantly by authorising and controllingradioactive discharges and waste disposal to air, water (surfacewater, groundwater) and land. In addition to authorisationsissued under the RSA93, SEPA also regulates nuclear sitesunder the Pollution Prevention and Control Regulations andissues consents for non-radioactive discharges.SentencingThe step of the waste management process at which thedecision is made that an article or substance is clean, excluded,exempt or radioactive.StakeholdersPeople or organisations, having a particular knowledge of,interest in, or be affected by, radioactive waste, examples beingthe waste producers and owners, waste regulators, non-Governmental organisations concerned with radioactive wasteand local communities and authorities.StorageThe emplacement of waste in a suitable facility with the intent toretrieve it at a later date.Strategic Environmental Assessment (SEA)SEA refers to the type of environmental assessment legallyrequired by EC Directive 2001/42/EC in the preparation ofcertain plans and programmes. The authority responsible for theplan or programme must prepare an environmental report on itslikely significant effects, consult the public on the report and theplan or programme proposals, take the findings into account,and provide information on the plan or programme as finallyadopted.Sustainability appraisal (SA)A form of assessment used in England, particularly in regionaland local planning, covering the social, environmental andeconomic effects of proposed plans and appraising them inrelation to the aims of sustainable development. SA’s fullyincorporating the requirements of the SEA Directive(2001/42/EC) are mandatory for a range of regional and localplanning documents under the Planning and CompulsoryPurchase Act 2004.Very low level waste (VLLW)Covers waste with very low concentrations of radioactivity. Itarises from a variety of sources, including hospitals and thewider non-nuclear industry. Because VLLW contains little totalradioactivity, it has been safely treated by various means, suchas disposal with municipal and general commercial andindustrial waste directly at landfill sites or indirectly afterincineration. Its formal definition is:(a) in the case of low volumes (‘dustbin loads’) of VLLW“Radioactive waste which can be safely disposed of to anunspecified destination with municipal, commercial or industrialwaste (“dustbin” disposal), each 0.1m3 of waste containing lessthan 400 kilobecquerels (kBq) of total activity or single itemscontaining less than 40 kBq of total activity. For wastescontaining carbon-14 or hydrogen-3 (tritium):• in each 0.1m3, the activity limit is 4,000 kBq for carbon-14and hydrogen-3 (tritium) taken together• for any single item, the activity limit is 400 kBq for carbon-14 and hydrogen-3 (tritium) taken togetherControls on disposal of this material, after removal from thepremises where the wastes arose, are not necessary.”Or (b) in the case of high volumes of VLLW “Radioactive wastewith maximum concentrations of four megabecquerels per tonne(MBq/te) of total activity which can be disposed of to specifiedlandfill sites. For waste containing hydrogen-3 (tritium), theconcentration limit for tritium is 40MBq/te. Controls on disposalof this material, after removal from the premises where thewastes arose, will be necessary in a manner specified by theenvironmental regulators”.Waste producerThe organisation that produced radioactive waste in the firstinstance. The waste producer may or may not equate to thecurrent waste manager, as responsibility for the waste may havebeen passed to another organisation in the interim.Consultation Document UK Nuclear Industry LLW Strategy June 2009 Page: 69