16/11/2015 withdrawn was and date of out is Radioactive Substances Act 1993 Future regulation of disposals of radioactive waste on/from Decision Document document the Low-Level Waste Repository at Drigg, Cumbria operated by British Nuclear Group Sellafield Ltd. This February 2006 Executive Summary The Environment Agency has responsibility for regulating radioactive waste disposals by means of authorisations issued under the Radioactive Substances Act 1993 (RSA93). We periodically review authorisations for the disposal of radioactive wastes from nuclear sites, to ensure that: • radiation impacts on members of the public are as low as reasonably achievable (ALARA) and within national and international limits and constraints; • UK policy requirements are being implemented; • environmental impacts are prevented or minimised; and • existing limitations and conditions within the authorisation remain appropriate, or are changed if appropriate. Whenever we review a nuclear site authorisation, the same basic steps are followed: 16/11/2015 • A “Process and Considerations ” document is issued which describes our approach to the review. The Process and Considerations document for the Low level Waste Repository (LLWR) Review was issued in November 2004. • We carry out the review and issue an Explanatory Document setting out any proposed changes, along with a draft authorisation certificate. The Explanatory Document for the LLWR Review was published in June 2005 withdrawn • We carry out a public consultation whereby we consult widely on the Explanatory Document and ask for comments from the public as well as interested organisations. The consultation period for the LLWR Review ran from 15 June to 7was September 2005. • Once all the consultation responses have been considered, we issue a Decision Document setting out our decisions. This document is the Decision Document for the LLWR Review. • The Decision Document is sent to the Secretandary of State for Environment, Food and Rural Affairs and the Secretary of State for Health, for them to consider whether they wish to exercise their statutory powers in relation to our decisions. This document has been sent to the Secretaries of State. date • Subject to intervention by theof Secretaries of State, we will issue a new Certificate of Authorisation to BNGSL for the LLWR at Drigg, Cumbria. We have reviewed all four ofout the current RSA93 authorisations for waste disposals at the LLWR at Drigg, Cumbria. Sinceis 1 April 2005, the LLWR has been owned by the Nuclear Decommissioning Authority (NDA), and is currently operated by British Nuclear Group Sellafield Ltd (BNGSL) to whom the authorisations are issued. Our review has considered all the conditions and disposal limits in the authorisations and identified changes where appropriate. We also considered BNGSL current practices and future plans for the disposal of radioactive wastes to assess whether they represent the best practicable environmental option (BPEO) and whether BNGSLdocument are using the best practicable means (BPM) to minimise disposals, and the radiological impacts from those disposals. In our Explanatory Document, we proposed a number of changes to the authorisation and Thisregulation of radioactive waste disposals on/from the LLWR. We sought views on our proposals during the public consultation. We considered all the responses to the consultation and have taken them into account when making decisions on our proposals. This Decision Document summarises the responses and explains our decisions. Environment Agency Decision Document February 2006 British Nuclear Group Sellafield Ltd, LLW Repository at Drigg Page 2 of 104 We have decided to replace the four current authorisations with a single authorisation which we are satisfied will provide significant regulatory and potential environmental benefits, including a more transparent approach to the regulation of the LLWR. The new authorisation will also strengthen the Best Practicable Means conditions to both minimise the waste generated on the site, and ensure that the radiological impacts – both now and in the future – will be As Low As Reasonably Achievable (ALARA). Disposal of solid radioactive waste is the primary authorised activity at the LLWR and, due to the potential impacts from coastal erosion, it is the single issue that generated the most comments from respondents to our consultation. In our Explanatory Document, we proposed retaining existing solid disposal limits until such time as BNGSL has provided additional information for us to determine the radiological capacity of the site. However, some respondents were critical of this approach and recommended that we either suspended disposals until further risk management had been undertaken or changed the status of the site from disposal to long-term storage. As a result of the comments received, we have now decided the following regulatory approach:16/11/2015 i) We will authorise continued disposal of LLW to the current Vault 8 area using existing annual solid waste disposal limits; ii) We will not authorise LLW disposals to the proposed Vault 9, until it has received appropriate planning permission from Cumbria County Council and BNGSL has provided us with adequate information to allow the radiologicalwithdrawn capacity of the site to be determined. We will undertake a full review on the radiological capacity of the site and publish our findings; was iii) When Vault 8 reaches capacity (during 2008) and prior to Vault 9 being authorised, any LLW waste consigned to the LLWR shall be for the purpose of temporary storage and, by agreement with the HSE, shall be regulandated under BNGSL’s Nuclear Site Licence arrangements; and, iv) We will not allow BNGSL to constructdate the final cap over the existing Vault 8 and trench disposals until BNGSL hasof provided us with the outcome of a wide-ranging risk management study that demonstrates that future impacts will be As Low As Reasonably Achievable (ALARA),out required in 2 years. By deferring our decisionis on the radiological capacity of the site and through our commitment to a future review of the authorisation, we will also be able to have regard to the outcome of the UK Government’s and Devolved Administrations’ review of LLW Management policy, the finalised NDA Strategy and the Committee on Radioactive Waste Management’s (CoRWM’s) recommendations to Government. We considerdocument that BNGSL’s estimates of radiation doses and risks from historical disposals to members of the public in the future significantly exceed current regulatory targets, and that these impacts could be realised in a relatively short timescale (~500 years) if coastal erosion were to Thisoccur. While it would be unreasonable to expect historical practices to fully comply with present day guidance and modern standards, there may be ways of optimising the performance of the site by either minimising the impacts from certain scenarios and/or reducing the likelihood of those risks occurring. We will require BNGSL to investigate them. Environment Agency Decision Document February 2006 British Nuclear Group Sellafield Ltd, LLW Repository at Drigg Page 3 of 104 The new integrated certificate of authorisation includes a number of requirements placed on BNGSL to make improvements and supply further information. In particular, we are requiring BNGSL to improve the evaluation of risk management options in the Post Closure Safety Case (PCSC) and to provide more information to support a view on the radiological capacity of the LLWR. This information should enable us to determine the remaining radiological capacity of the LLWR and, to assess whether the current LLW disposal limits will continue to be valid for the future regulation of operations on the site. The certificate of authorisation accompanying this document will also, when implemented, place regulatory controls on BNGSL regarding: • Discharges of gaseous radioactive waste to atmosphere; • Discharges of aqueous radioactive waste via a pipeline to the Irish Sea; • Transfers of certain low-level-wastes (LLW) for treatment at Sellafield, and subsequent return to the LLWR for disposal; and, 16/11/2015 • Transfers of Plutonium Contaminated Material (PCM) to Sellafield for treatment and storage pending a final disposal route. We consider our decisions will not: • place a grossly disproportionate additional burden on BNGSL staff resources in meeting the improvement/information requirements in the new integratedwithdrawn authorisation; or • require grossly disproportionate expenditure for additional monitoring and managerial control of disposals. was The volume of LLW that will be produced in the UK during nuclear power plant decommissioning is likely to far exceed the capacandity of the LLWR. There is an urgent need, therefore, to identify the most appropriate national strategy for the future management of the UK’s LLW, including the consideration of the possible need for one or more alternative disposal sites. We will continue to work with Government, the NDA, the waste producers, local authorities and other stakeholders to addressdate this issue, and we are actively contributing to the current Government-initiated reviewof of LLW management policy. out is document This Environment Agency Decision Document February 2006 British Nuclear Group Sellafield Ltd, LLW Repository at Drigg Page 4 of 104 Contents 1. Introduction............................................................................................................................. 7 Site History 7 Site