EA-Norfh W^slr Boy S> 5 Environment wM A g e n c y Environment Agency Information Services Unit Please return or renew this item by the due date Due Date j:/\ U le & t Radioactive Substances Act 1993 Decision Document on the Review of Authorisations for British Nuclear Fuels pic to Dispose of Radioactive Wastes from the Springfields Nuclear Site Main Document September 2004 En v ir o n m e n t Ag e n c y Environment Agency This page has intentionally been left blank Decision Document ii BNFL Springfields Review September 2004 Environment Agency Contents Page Number Contents iii Executive Summary iv Summary of the Agency's Conclusions and Decisions vi 1. Introduction 1 2. Guide to this Document 4 Part 1 - The BNFL Springfields Review, the Springfields Nuclear Site & Processes 6 Part 2 - Concepts and Principles 10 Part 3 - Legal & Policy Framework and International Commitments 20 Part 4 - The Agency’s System of Regulatory Control 35 Part 5 - The Agency’s Review and Re-authorisation Process 41 Part 6 - The Agency’s Considerations After Consultation 46 - Section 6A Consultation Responses and Agency Comment 46 - Section 6B General Considerations 59 - Section 6C Limits and Conditions in the Authorisation and Radiological Impacts 62 Part 7 - The Agency’s Decisions 86 Appendix 1 - Glossary 93 Appendix 2 * List of Consultees 98 Appendix 3 - Organisations and Individuals Responding to the Consultation 102 Appendix 4 - Responsibilities of Government Departments and Public Bodies 104 Appendix 5 - List of Changes Made to the Draft Authorisation 109 Appendix 6 - The New Authorisation for the BNFL Springfields Nuclear Site 112 Decision Document iii BNFL Springfields Review September 2004 Environment Agency EXECUTIVE SUMMARY Decision Document on the Review of Authorisations for British Nuclear Fuels pic to Dispose of Radioactive Waste from the Springfields Nuclear Site. The Environment Agency (the Agency) has the responsibility for regulating radioactive waste disposals from nuclear sites by means of authorisations issued under the Radioactive Substances Act 1993 (RSA93). The Agency reviews on a regular basis nuclear site authorisations to ensure that: • radiation impacts to members of the public are as low as reasonably achievable (ALARA) and within national and international limits and constraints; • UK policy requirements are implemented; • environmental impacts are prevented or minimised; and • existing limitations and conditions remain appropriate. The Agency published a document setting out its proposed Scope and Methodology for a full re-examination of the Springfields authorisations in October 2001. It then published in November 2003 an Explanatory Document and associated draft Certificate of Authorisation in which the Agency proposed a number of changes to the regulation of radioactive waste disposals from Springfields. The Environment Agency has considered the issues and has consulted on the review and draft Certificate of Authorisation with the public, Government, public bodies and interested stakeholders. This Decision Document now sets out the Agency’s decisions and provides the background and basis for them. The Agency considers that the new authorisation will: • Reduce the radiological impact, especially on those people near the Springfields site. In particular, the decrease in authorised radioactive discharges to the River Ribble from Springfields will ensure reductions of 48 per cent initially, and 85 per cent from 2008, in the assessed radiological impact to the most exposed public groups from discharges at the new limits; • Ensure that potential radiation doses from discharges continue to be below national limits and constraints; • Reduce the annual liquid discharge limit for total beta by 42 per cent initially and by 91 per cent from 2008; • Reduce the annual liquid discharge limit for total alpha by 86 per cent initially and by 97 per cent from 2008; • Improve regulation by the introduction of discharge limits to individual plants; • Provide a more transparent approach to the regulation of the site; • Strengthen the Best Practicable Means (BPM) conditions by requiring waste minimisation at source, which will maintain downward pressure on waste disposals Decision Document iv BNFL Springfields Review September 2004 Environment Agency below the limits imposed by the authorisation and will minimise the environmental and radiological impact; • Encourage BNFL’s progress in treating historic legacy wastes and residue materials; • Promote BNFL’s decommissioning programmes for redundant plants; The Agency considers that the new authorisation will not: • Place a grossly disproportionate additional burden on BNFL staff resources in meeting the requirements for information in the authorisation; • Involve grossly disproportionate expenditure for additional sampling or monitoring and managerial control of discharges. The Agency has decided not to authorise the option discussed in the Explanatory Document, allowing a greater uranium disposal activity concentration to be used for decommissioning wastes to be sent for disposal to Clifton Marsh. Before implementing its final decisions, the Agency will send this Decision Document to the Secretary of State for Environment, Food and Rural Affairs and the Secretary of State for Health. This will enable them to determine whether they wish to exercise their statutory powers to issue directions to the Agency to modify the decisions. Subject to the implications of any interventions by the Secretaries of State, the Agency will issue a new Certificate of Authorisation to BNFL for the Springfields site. The Agency believes that the new certificate of authorisation, provided in Appendix 6 in this Decision Document, will provide significant regulatory and potential environmental benefits, and will take the regulation of the Springfields nuclear site by the Environment Agency under the RSA93 forward to 2008 and beyond. Decision Document v BNFL Springfields Review September 2004 Environment Agency SUMMARY OF THE AGENCY’S CONCLUSIONS AND DECISIONS INTRODUCTION The Environment Agency (the Agency) has made its decisions for the review of the BNFL authorisations to dispose of radioactive wastes from the Springfields nuclear site. The Agency’s decisions are set out in full in the Decision Document. This summary of the Decision Document is being sent to all stakeholders included in the public consultation. The Decision Document, which is being made publicly available, provides the background to and basis for, the Agency’s decisions for the Springfields nuclear site. It includes the Agency’s responses to issues raised during consultation. Details of how the full Decision Document can be obtained from the Agency are included at the end of this summary. The Agency has regulatory responsibility under the Radioactive Substances Act 1993 (RSA 93) for all disposals and discharges of radioactive waste from nuclear sites in England and Wales. As part of its role of protecting and improving the environment, the Agency is committed to progressive reductions in radioactive discharges and discharge limits where practicable. The Agency began this review in October 2001 setting out its scope and methodology. This required the provision of certain information from BNFL. Following a full re­ examination of this information and the existing authorisations, the Agency published its proposals for a new authorisation and regulation of the site in the form of an Explanatory Document and draft authorisation in November 2003. The Agency sought views on these proposals during a formal consultation, which included statutory consultees and the wider public. Due account has been taken of the responses to this consultation before any final decisions on re-authorisation were made. The Agency is now publishing this Decision Document setting out its decisions for re-authorisation of the Springfields nuclear site. BNFL Springfields Review Submission and Issues Raised by the Agency The Agency specified in the Scope and Methodology document the information that BNFL Springfields was to provide for the review of the authorisations. Hie information included: • past, current and predicted future waste disposals; • Best Practicable Environmental Option (BPEO)/ Best Practicable Means (BPM) assessments for the principal radionuclides in major waste disposals streams; • details of BNFL Springfields environmental management systems; • data on the radiological and environmental impact of discharges; and • details of research and development that BNFL Springfields is carrying out to reduce discharges of radioactive wastes. Decision Document vi BNFL Springfields Review September 2004 Environment Agency The Agency requested that the information from BNFL Springfields covered the period 1990-2008 and beyond so that the review could take a longer-term perspective and take account of the company's planned operations. The information included projected lifetimes of plants, details of future operations and predicted production throughputs. The Agency considers that this information was essential for the review and would help to ensure that any changes that the Agency decided to make to the authorisations would remain appropriate for a number of years. After examining and considering the information provided, the Agency requested in September 2002, that BNFL Springfields supply further information, partly to expand on information already supplied and partly to cover new and emerging issues. BNFL Springfields supplied this second set of information in late