Home > LLW Strategy > Waste Hierarchy > Management Approach

Management Approach

All facilities in this study will have to review documentation prior to accepting any waste. The following sections give an overview of the materials and contaminations that can be accepted

Principles of LLW  Management

  The Principles of Radioactive Waste Management have been established by the UK regulators:

 
These apply to LLW management and have the concept of the Waste Hierarchy at their foundation.
In addition both place emphasis on the development of strategy for management as well as highlighting the importance of preventing waste generation and where this is not possible, minimisation. 

Management Approach

A generic management approach to Waste Minimisation and application of the Waste Hierarchy is presented below. 

Obtain Commitment

Commitment from senior management is essential in order to ensure sufficient resource and time can be allocated to the project. Existing project arrangements may already provide for this; for example through project sponsors.

Initial Review

An initial review to understand potential waste streams and their significance is recommended. The depth of such studies will depend on a number of parameters including:

  • This information may already be available. Existing waste inventories, life time plan strategy documents or similar reviews may have already been completed;
  • Site and regulatory priorities;
  • The number of waste streams and potential volumes;
  • Site hazard and complexity;
  • Uncertainty;
  • Radiological and chemical toxicity of potential waste streams and sensitivity of receptors;
  • Stakeholder concerns;
  • Current or proposed site operations and developments

Determine Strategy/Approach

The programme / project leadership should determine the most appropriate strategy / approach. It is essential to understand site and study priorities. Sites may operate project management systems and it may be appropriate to utilise these. Whatever systems are already in place the strategy / approach should be documented to a level proportionate to the expected nature and extent of the programme / project. Consideration should be given to:
  • Appropriate gates and milestones;
  • Interaction with the requirements of existing programmes / projects;
  • Interaction with existing site processes; for example design or process hazard review;
  • Current site operations and proposed site developments 

Once the strategy and approach is determined, then there is an opportunity to define the scope and the objectives of the study. The objectives and scope are interdependent and should be developed together. Both should be clearly stated to ensure that system boundaries and interfaces are defined and the study team is focussed.

Management Structure and Responsibilities

Waste minimisation initiatives should have a defined management structure with responsibilities clearly understood. Structure and responsibilities should however be proportionate to the study. 

Appointment of a programme or project manager should be considered to provide leadership and appropriate authority. A key responsibility of the programme / project leadership would be to ensure that programme / project activities and milestones are understood and developed. Such arrangements may already be established within site project management systems.
Team members (both permanent and temporary) should be clearly identified and their roles and responsibilities understood. Once again team size should be proportionate to the demands of the study. Waste Minimisation studies are team efforts, but the team should be as small as possible whilst containing all the relevant skill necessary to achieve project aims. Suitably Qualified and Experienced Personnel (SQEP) should be utilised with the project leadership ensuring members are appropriate for the study. 
Team composition will depend on the nature and extent of the project and stage of the process. Temporary members should be utilised, where appropriate. For example a finance representative may be required if cost benefit analysis is required.  

Identify Opportunities, Decision Making and Action Management

Programme / project arrangements should establish criteria for identifying opportunities and making the most appropriate decisions. Existing site tools and techniques (including BPM, BAT assessments, Life Cycle Analysis etc.) may be utilised but a full understanding of waste stream and waste stream characteristics is essential. The presence of SQEP resources is clearly essential. 

A systematic approach to waste management and the application of the Waste Hierarchy is considered essential to successful programmes. Such approaches may already be incorporated into existing management arrangements, tools and techniques.For significant opportunities the project team should consider the requirement for feasibility studies. Managing the actions arising from waste minimisation studies is essential. Consideration should be given to the assignment of specific responsibility. This may be the project manager or a person assigned by the project manager.

Implement and Review

In implementing actions the following should be considered:

  • Requirements for the implementation; identified opportunities may require significant resource and indeed be a project in itself;
  • Systems required to monitor progress including the need for performance indicators;
  • Opportunities to integrate into existing site programmes;
  • The requirement for pilot studies
Project / programme review should be considered throughout the lifecycle. It is customary and good practice to complete reviews post project but the following should also be considered:
  • Prior to implementation of significant initiatives the validity of supporting data and conclusions should be tested;
  • During significant studies to assess progress perhaps in support of milestones

Reporting

Within the strategy and arrangements established for waste minimisation and the application of the Waste Hierarchy, reporting structures should be clearly defined. Certainly project sponsors, team members and those responsible for action management and follow-up should receive copies of reports.

Consideration should be given to an appropriate communication strategy, and in particular, the provision of information to stakeholders and how to publicise your successes; communicating success should be seen as an excellent opportunity to communicate success and engage others in site waste minimisation programmes. 
Record Keeping
An important strength of adopting a systematic management based approach to waste minimisation is that it will provide the basis for a properly documented study.
Record keeping is an important consideration in radioactive waste management and indeed an essential element of a number of the tools and techniques supporting such activities. Record keeping in this context is often a legal requirement. For example the SAP’s specifically require that information that might be required now and in the future for the safe management of radioactive waste should be recorded and preserved. Records are essential to comply with Duty of Care requirements and should certainly be retained, including those supporting characterisation, transport, consignment, and exemption (in the case of recycled materials).
Record keeping should be proportionate but may include:
  • the process documented in sufficient detail to support the completion of the study;
  • Minutes of meetings;
  • Reporting supporting feasibility studies etc;
  • Sufficient information to support the study conclusions remembering that proposed initiatives may have both legal (including safety case) implications as well as supporting business case submissions. Conclusions should be supported and defensible;
  • Security aspects where necessary
Record keeping is an essential component of other environmental management techniques including BPEO, BPM and BAT. 
It is also considered essential to monitor waste management performance. In this context an understanding of programme is essential and records may then provide information to support reporting.
BAT implies application of the waste management hierarchy and in particular the submission should contain sufficient information to demonstrate how the operator has, or is proposing to:
  • Prevent the unnecessary creation of waste or discharges;
  • Minimise waste generation and;
  • Minimise the impact of discharges on people and the environment.

Quality Assurance (QA)

The majority of sites operate quality management systems and the principles and arrangements established in such systems can be applied to waste minimisation and associated studies.

It would is good practice to establish QA arrangements for waste minimisation programmes and / or studies; clearly such arrangements should be proportionate and may be documented. Consideration should be given to the following:
  • Quality objectives;
  • Terms of reference;
  • The requirement for quality plans;
  • Arrangements for checking and approval documentation;
  • Data validation and verification;
  • Document control procedures; 
  • Arrangements for internal audit