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Overview of the process to allow LLW disposals in the UK.

Michael Gracey

Waste Acceptance Specialist LLWR

Introduction

• Introducing LLWR

• Background Information

• Initial requirements

• Waste Acceptance requirements

• BAT Characterisation and Assurance Documents

• Challenging Enquiries

• Summary

• Questions

Introducing LLWR

• Located in Cumbria

• Not centrally located but close to where ~70% of waste will be generated

• Waste Stored / Disposed in a near-surface engineered vault

• Waste management company offering alternatives to disposal

LLWRLLWR

Background information

LLW Definition in UK is:

• 4GBq/t Alpha Emitting Radionuclides

• 12GBq/t All Other Radionuclides

• Not half life dependant

All operating limits are in line with recently submitted Environmental Safety Case

Background Information

Waste:

• form must be solid and not liquid / gas.

• Must have a BAT document that concludes disposal is the preferred option with justifiable substantiation

• Must be compliant with either the waste acceptance criteria or have a suitably approved variation

Initial requirements prior to disposal

• LLWR assess suitability of agreement in principle form by both communication with producer and assessment of supplied information

• LLWR receive and review Draft Permit / Authorisation

• Once agreement in principle is approved and the live Permit/ Authorisation is received the acceptance process begins in earnest

Waste Acceptance requirements

What is needed to allow disposal of wastes:

• Approved Permit /Authorisation

• BAT assessment justifying that disposal is the preferred option

• Wastestream characterisation document

• Quality assurance documentation

• Signed contract

Bat Statement

• Best available technique form an integral part of the Radioactive Substance Regulatory Environmental Principles (REPS) which underpin UK discharge strategy.

• Also a requirement of the Environmental Permitting Regulation (EPR10) for the UK, Wales and the Radioactive Substance Act 1993 in Scotland

What is BAT?

Why Low Level Waste

should be managed… What should be done…

How it can be done…

How are LLWR aiding UK consignors with BAT?

Avoid

Reduce

Recycle

Reuse

Treat

Dispose

New Services

Traditional Services

Characterisation Form requirements

What does the Characterisation Form require?

• Origins of Waste, including Process Knowledge

• Details of the Sampling Plan and the actual Sampling

Campaign

• Sample Analysis undertaken, Analysis Results and

Fingerprint.

• Volume and Weight of Waste

• Materials to be Excluded and / or to be Made Safe

Characterisation Form requirements Continued

• Hazardous Properties

• Conditioning Processes to be used

• Packaging Methods to be used

• Equipment and Methods for Activity Assessment

This form is used to assess and determine suitability of waste against

LLWR’s permit, Safety Case and WAC.

Waste assurance form contains this list is not conclusive

• Consignors structure including roles and responsibilities

• Management system and record amendments

• Training and qualifications

• Internal Audits and non conformances

• Calibration

• Used to aid customer audits

Assurance Activities

• Number of assurance activities undertaken are calculated

on ratio of previous years consignments of treated and disposed containers

• Customers selected on a risk based approach and intelligent review (Volume , Activity, ESC Impact & Non -Conformances)

• Assurance activities are made up of customer audits, Assurance verification monitoring (e.g. HRGS) undertaken at treatment facilities, customer sites

Challenging enquiries

• Supernate and sludge transfer pump made of stainless steel with specific activity of 9.01GBq/t alpha and 205GBq/t beta gamma activity

• Ram Shaft Seal dose reading of 25mSv/hr βγ/γ at 1.5 metre away. Grout added to stabilise then request to dispose submitted

• Heating elements with activity ranges of 80GBq/t to 250GBq/t βγ/γ . Overall consignment would be 1.3GBq/t βγ/γ .

Summary

• The UK have a specific activity limit for LLW

• Waste must be compliant with LLWR’s Permit and recently submitted ESC.

• Conditions in the Waste Acceptance Criteria can be varied

• BAT statement pivotal to all waste management decisions.

Summary Continued.

• LLWR have aided UK consignors by offering alternatives to disposal.

• All LLWR forms have specific requirements to demonstrate consignors are in control of waste being generated and are managing appropriately.

• Continually getting challenging enquires that test the Environmental Safety Case and Permit.

Questions?