Environmental Permitting and Radioactive Waste Management. Dr Juliet Long NuLEAF Seminar June 2014

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1 Environmental Permitting and Radioactive Waste Management Dr Juliet Long NuLEAF Seminar June 2014

2 Importance and responsibility for Radioactive Waste management Availability of robust radioactive waste management infrastructure is key to UK: Dealing with our nuclear legacy & supporting new nuclear build Dealing with our oil & gas legacy & supporting further opportunities Supporting our mineral extraction, chemicals and steel industries Manufacture and use of radiopharmaceuticals Supporting medical health case (radiotherapy / assessment etc) Research and development (eg universities, cancer research, food treatment) Etc If you ve ever switched on a light bulb / driven a car / had an x- ray / painted a room... Then you will (probably) have benefited from the generation of these wastes!

3 Permitting and Radioactive Waste Management - summary Our role The key components of UK Radioactive waste disposal infrastructure How we permit near-surface disposal Permitting at the LLWR Permitting at Landfill Challenges

4 Permitting Radioactive Waste Environment Agencies regulate disposal of radioactive wastes Environment Agency / Natural Resources Wales / Scottish Environment Protection Agency / Northern Ireland Environment Agency Environmental Permitting Regulations 2010 Replaced Radioactive Substances Act Definition of Radioactive Waste and requirement for permits Permits Based on robust application demonstrating protection of people & the environment Establishes limits and conditions on operator eg use of BAT Consignors eg nuclear site operators, hospitals, universities Consignees eg treatment sites (metal recycling), LLWR, landfills Exemptions Very Low Level Waste exempt from need for permit, but control still required

5 Key parts of UK Radioactive Waste Disposal Infrastructure Key Radioactive Substances Permitted Incinerator Radioactive Substances Permitted landfill Stoneyhill Landfill Lillyhall Landfill LLWR Clifton Marsh Landfill Incinerator Kings Cliffe Landfill Incinerator Incinerator

6 Permitting near-surface disposal of radioactive waste Joint Guidance exists* Key feature - Environmental Safety Case Site specific characteristics & design of facility Waste characteristics Safety assessments both during period of authorisation and afterwards Behaviour of waste / facility over time Impact of external events Management arrangements *

7 Environmental Safety Case Considers performance of a proposed / existing facility now and into the future Risk guidance level: risk of death of 1 in a million per year (~ 20µSv/yr) Radiological risks and risks from non-radiological components In other words.. we consider the long-term implications, recognising that the risks from radioactivity can last a long while Eg potential disruption due to glaciation, archaelogical digs etc Safety under all such potential scenarios needs to be demonstrated.

8 LLW Disposal Capacity?

9 Interim Storage of LLW 9

10 What s the issue? Older Trench Disposals Nuclear Site Boundary Irish Sea

11 LLWR Permitting (1) Current permit only allows disposal into Vault 8 Revised ESC received in May 2011 Detailed review: May 2011 Oct Publication expected: Sept 2014 Application for permit variation to allow continued disposals (October 2013) Consultation on application Nov 13 Feb 14 (28 responses received)

12 LLWR Permitting (2) Currently preparing draft Decision document and draft permit for consultation in Autumn 2014 (2 months) Aim to issue a decision in early 2015 (est. February) Any decision subject to an Article 37 opinion being received

13 LLWR Permitting - Technical issues Range of technical issues considered, including: Coastal erosion Container condition and waste settlement Discrete items Non-radiological impacts Optimisation Vault size, sequencing and capping frequency

14 LLWR Permitting - implications If we are able to issue a permit for disposal: More restrictive Qualitative & quantitative controls on higher activity particles / discrete items / sealed sources Increased information requirements on disposals (rad & non-rad) Less restrictive: Possibly re disposals of complexing and chelating agents, and changes to fissile limits Significant changes to approach Removal of annual radiological capacity limits and inclusion of a lifetime capacity controlled by the sum of fractions approach Implication? More waste will need to be managed via alternative treatment / disposal routes

15 Landfill Disposal? 3 landfills in England Inc 1 Hazardous waste landfill Each permit supported by individual site specific assessment (Environmental Safety Case). Same principles apply as for LLWR

16 Specific challenges for permitting? Sharing lessons from reviews of Environmental Safety Case Understanding the potential volumes and characteristics of radioactive wastes that will need to be managed Avoiding management of waste according to its label but rather, more considered appreciation of its characteristics

17 Challenges more generally? Current infrastructure is fragile A robust regulatory regime exists for controlling these activities technically (permitting) and in terms of development (planning) But.. There are only a few sites available and no enthusiasm for new investment Cost and time taken to acquire permissions seen as a blocker especially the uncertainty around local political support for radioactive waste disposal Public concerns need to be addressed upfront and managed. Some companies are reluctant to do this because of perceived blight. Uncertainty in throughput / volumes limits investment Limited skills and capabilities Understanding of radiation protection issues and behaviour of radionuclides in the environment Work on national radioactive strategies is key

18 Ensuring a robust infrastructure for radioactive waste management? We are all accountable for ensuring a robust radioactive waste management infrastructure and supporting safe management within our generation. Waste Producers, Managers & Disposers Environment Agencies Waste Planners Members of the public Etc We need to work together in a complementary manner, respecting one another s roles & responsibilities and enabling responsible solutions to be delivered.

19 Environmental Permitting and Radioactive Waste Management Dr Juliet Long NuLEAF Seminar June 2014

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