Challenges arising from nuclear site clean-up and developments in the regulatory landscape

1. Challenges from nuclear site
clean-up and developments in
the regulatory landscape
Dr Juliet Long FIEMA CEnv
Radioactive Legacy & Waste Issues
Environment Agency
Presentation to IES Land Condition Symposium 2020, online, 11 November 2020

2. Outline
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• Introduction
• Environment Agency & Nuclear Regulation
• Expectations for successful land quality
management
• Challenges
• ‘No danger’
• Optimisation of radioactive waste & site clean-up
• Integration of radioactive / non-radioactive issues
• Clarity in regulatory expectations
• Development in regulatory landscape
• Proportionate regulatory controls
• Joint Statement of Common Understanding

4. Radioactive Substances Regulation
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• Environment Agency: Regulates radioactive
discharges and disposal of radioactive waste:
• Nuclear Sites
• Non-nuclear (inc use and accumulation)
• Radioactive Contaminated Land
• Import / Export of Radioactive substances
• Office for Nuclear Regulation
• Nuclear Safety & Security, Safeguards, Transport
• Worker & Public Safety

5. Nuclear Sites in the UK
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6. Land Quality at Nuclear Sites
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• Range of historic (pre-nuclear) and current
activities
• Activities involving both radioactive and non-
radioactive substances (eg oils, acids,
asbestos)
• On-site and nearby receptors including
protected species and habitats and
archaeological features

7. Regulatory vires?
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8. Regulatory vires?
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9. Regulatory vires?
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10. Regulatory vires?
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11. Regulatory vires?
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12. Regulatory vires?
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13. And others?

14. East Northants Resource
Management Facility
Clifton Marsh
Low Level Waste Repository
Lillyhall
Stoneyhill
Dounreay
Sellafield
Port Clarence
Radioactive Substances Permitted landfill or repository
Key Radioactive Substances Permitted Incinerator
NORM waste only
Lower Activity Wastes
- ~ 4.5 million m3 from civil
nuclear decommissioning
- ~ 1.2 million m3 permitted
capacity (time limited
availability)
- potentially 6 million m3 more
from nuclear site clean-up

15. Decommissioning = Significant
volumes of waste

16. Environment Agencies approach
• Guidance on Requirements for Release of
Nuclear Sites from radioactive substances
regulation (the ‘GRR’)
• Optimisation is a key principle
• Ensuring exposures to ionising radiation
are kept ALARA, economic and social
factors being taken into account.
• Requirements include:
• Waste Management Plan
• Site Wide Environmental Safety Case

17. Guidance Objectives
• ‘What is the right thing to do with the waste,
including all radioactive and hazardous
wastes?’
• Aims to be:
• Proportionate - allowing site specific clean-up
to risk-based criteria
• Explicit as to the options that could be used for
the management of bulk decommissioning
waste

18. Waste Management Options

19. Optimisation of waste management
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20. Site Wide Environmental Safety Case
(SWESC)
• Demonstrates protection of people and the
environment on and from the site
• Understanding of the site
(geology, hydrology etc.)
• E.g. Conceptual Site Model
• Evolution of the waste and the
site
• Impacts to people and the
environment

21. Waste Management Plan
• Planning for current and future disposals of
radioactive waste at or from the site
• Demonstrating optimisation of waste
management decisions
• Links closely to the SWESC
• If waste is to be left on site (e.g. in-situ
disposal) it will need to be permitted by the
relevant environment agency

22. Implementation of the GRR
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• All nuclear site operators, irrespective of lifecycle,
are required to produce a WMP and SWESC
• A UK wide programme of work is underway to
implement these requirements:
• To establish agreed timescales for production
• To resolve technical queries and share learning
• Engagement with Nuclear Industry Group on
Land Quality (NIGLQ) & SAGTA

23. Change to nuclear legislation?
• UK Government is proposing changes to legislation that
will release controls on decommissioning sites earlier
than now – recognising the change in risk profile
• Doing so could enable earlier reuse of sites, lower
costs, reduce waste transport and lower impacts
• Implementation of the Environment Agencies GRR
document is a key enabler for this
• Significant work to be done to properly characterise
contamination on nuclear sites and to inform site clean-
up
• Our objective is sustainable remediation

24. Thankyou
Any Questions?
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25. Challenges from nuclear site
clean-up and developments in
the regulatory landscape
Dr Juliet Long FIEMA CEnv
Radioactive Legacy & Waste Issues
Environment Agency
Presentation to IES Land Condition Symposium 2020, online, 11 November 2020