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Policy and Regulatory Framework

  

Policy for the Long Term Management of Solid LLW in the UK

 The UK policy for the management of Solid Low Level Waste establishes the Waste Hierarchy as a central theme and states that:
‘LLW managers should plan to manage their wastes in accordance with the Waste Hierarchy principles established in the UK Waste Strategy documents’.
The policy states that for LLW implementation of the Waste Hierarchy means:
  • Not creating waste where practicable;
  • Reducing waste arisings by activity and mass to a minimum through the appropriate design and operation of processes and equipment and making effective use of techniques such as waste characterisation, sorting and segregation, volume reduction and surface contamination removal;
  • Minimising quantities of LLW requiring disposal through decay storage, re-use and / or recycling, and incineration;
  • Disposal.
 
Waste minimisation through the application of the Waste Hierarchy is embedded in UK National Policy.

UK Nuclear Industry Strategy for the Management of Solid LLW

The UK strategy for the management of Solid Low Level Waste has been issued for consultation. This document clearly articulates a vision for the management of LLW through application of the Waste Hierarchy:
 ‘The UK strategy for the management of solid low level radioactive waste from the nuclear industry will facilitate continued hazard reduction and decommissioning through application of the Waste Hierarchy’.

Nuclear Installations Act 1965 and Licence Conditions

The HSE enforces the Nuclear Installations Act 1965 (as amended). Supporting the Health and Safety at Work Act 1974 this is the principal legislation covering the safety of workers and the general public at nuclear sites in the UK.
36 standard licence conditions (LC) are attached to all nuclear site licences. These detail how licensed sites should be managed by the operator.
Whilst a number of licence conditions are relevant to the management of radioactive waste on nuclear licensed sites, it is Licence Condition 32 that is particularly relevant to the waste management hierarchy. LC 32 requires site licensees to establish and implement adequate arrangements to minimise the rate of production and total quantity of radioactive waste and to record such waste.
The Safety Assessment Principles reflect site licence condition 32 and place the implementation of the waste management hierarchy at the centre. In particular they require:
  • The development and implementation of a strategy for the management of radioactive waste on-site;
  • That the generation of radioactive waste should be prevented or, where this is not reasonably practicable, minimised in terms of quantity and activity; in essence application of the waste management hierarchy.

Radioactive Substances Act 1993 (RSA93)

The Radioactive Substances Act 1993 regulates:
  • The disposal of radioactive waste to all media (disposal to land, airborne and liquid discharges);  
  • The transfer of waste between sites, including treatment and disposal facilities.
 
Authorisations are required for the disposal and accumulation of radioactive wastes and such authorisations prohibit any disposal other than in accordance with the conditions of the authorisation.
Authorisation includes standard statements that require application of concepts embodied in the waste management hierarchy:
‘The operator shall use best practicable means to minimise the volume of radioactive waste disposed of by transfer to other premises’
It is important to note that RSA93 will be integrated into the Environmental Permitting regime in 2010.

Environmental Permitting Regulations

 Radioactive Substance Regulations (RSRs) have been incorporated into the Environmental Permitting Programme with the aim of consolidating all environmental permitting under a single regime. The following minor changes to the current regulatory regime are envisaged:

  • Exemption orders consolidated and risk based limits established;
  • Replacement of Best Practicable Environmental Option (BPEO) / Best Practicable Means (BPM) with Best Available Technique (BAT).
(Note: Scotland will retain the Radioactive Substances Act 1993) 

Nuclear Sector Plan

The second issue of the Nuclear Sector Plan was published in July 2009. This document details the environmental objectives against which the nuclear sector will be measured. It reflects the issues that are considered important to both the regulator and the nuclear industry.
The objective established for LLW emphasises the importance of the waste management hierarchy in the management of waste arisings:
Objective - LLW Management: operator will use the waste management hierarchy as much as possible and minimise use of LLWR as a national asset
In this context operators are required to report the % of LLW sent for:
  • Reuse or recycling;
  • Disposal to other routes other than LLWR (e.g. incineration, HV VLLW to landfill);
  • Disposal to LLWR. 

 

Joint Regulatory Guidance 

The HSE, EA and SEPA have developed joint regulatory guidance. This guidance is focussed on the management of higher activity waste and provides useful insight into regulatory priorities and the central role of the waste hierarchy in regulation. Guidance is available in the following areas:

  • The Regulatory process
  • An introduction to the management of higher-level radioactive waste on nuclear licensed sites
  • Managing information relating to radioactive waste in the United Kingdom
  • Waste minimisation, characterisation and segregation
  • Radioactive Waste Management Cases

 

Useful Links

Policy for the Long Term Management of Solid Low Level Radioactive Waste in the UK

Waste Strategy for England

UK Nuclear Industry LLW Strategy for the Management of Solid Low Level Waste 

Nuclear Installations Act 1965 (as amended)

Health and Safety at Work Act 1974

Nuclear Site Licence Conditions

Health and Safety Executive, Safety Assessment Principles for Nuclear Facilities 2006

Radioactive Substances Act 1993

Environmental Permitting Programme, Consultation on Government Guidance

Environmental Permitting, Environment Agency Guidance 

Environmental Permitting (England and Wales) Regulations 2010, Annex II

Nuclear Sector Plan, Environmental Sector Plan for the Nuclear Industry