Guidance: LC 32 Accumulation of radioactive waste

Site inspection and enforcement

T/INS/032 - Issue 1

Issue Date:

23.04.03

Review Date:

23.04.06

Open Government Status:

Fully open

Approved By:

B J Furness

1. Purpose and scope

1.1 The purpose of this guidance is to facilitate a consistent approach to LC 32 compliance inspection and to provide assistance to inspectors while carrying out their duties in this area. The guidance should not be regarded as either comprehensive or mandatory.

1.2 The guidance does not indicate when or to what extent these compliance inspections should be made as these matters are covered in individual inspectors inspection programmes.

1.3 The guidance provided is split into four main elements:

1.4 This guidance should be read in conjunction with T/AST/024 - Management of Radioactive Materials and Radioactive Waste on Nuclear Licensed Sites. All Site Inspectors should be familiar with the general introductory material and those at sites with significant radioactive waste issues should be familiar with the whole document.

2. Licence Condition

2.1 Licence Condition 32 - Accumulation of radioactive waste

32(1) The licensee shall make and implement adequate arrangements for minimising so far as is reasonably practicable the rate of production and total quantity of radioactive waste accumulated on the site at any time and for recording the waste so accumulated.

32(2) The licensee shall submit to the Executive for approval such part or parts of the aforesaid arrangements as the Executive may specify .

32(3) The licensee shall ensure that once approved no alteration or amendment is made to the approved arrangements unless the Executive has approved such alteration or amendment.

32(4) Without prejudice to paragraph (1) of this condition the licensee shall ensure that radioactive waste accumulated or stored on the site complies with such limitations as to quantity, type and form as may be specified by the Executive.

32(5) The licensee shall, if so specified by the Executive, not accumulate radioactive waste except in a place and in a manner approved by the Executive

3. Purpose of Licence Condition

3.1 The purpose of this condition is to ensure that the rate of production and the accumulation of radioactive waste on the site is minimised. Waste storage comes within the definition of "operations" and consequently all conditions apply to it. Inspectors should check that waste is held under suitable storage arrangements and that adequate records are being made and kept. Waste should be disposed of via authorised routes where these exist but if disposal routes do not exist then the waste should be stored in a safe, passive form.

3.2 Nuclear Licensed sites are exempt from registration under the Radioactive Substances Act (1993) in respect of the keeping and use of radioactive materials of any description (including radioactive waste). In recognition of this exemption, this licence condition, and LCs 33 and 34 are intended to ensure that an "equivalent regime" exists on licensed sites. Inspectors should note that nuclear matter can only be identified and declared as radioactive waste by its owners who may not be the licensee for the site on which the waste is situated.

3.3 Inspectors are also reminded that on matters concerning radioactive waste the site licence is administered in conjunction with the Environment Agencies (EA & SEPA) in accordance with Memoranda of Understanding which exist to provide a framework for inter-regulatory liaison.

3.4 LC32(1) provides for the making and implementing of arrangements.

LC32(2) gives the power to the Executive to specify the arrangements or parts of arrangements for approval and subsequent alterations and amendments also have to be approved. NII does not generally approve any part of LC 32 arrangements.

LC32(3) ensures that where the Executive has approved arrangements the Licensee must apply for approval to amend or alter those arrangements.

LC32(4) provides the Executive the power to specify the quantity, type and form of radioactive waste accumulated and stored on site.

LC32(5) gives the power to the executive to specify that radioactive waste can only be accumulated in an approved manner and place.

4. Guidance on arrangements for LC 32.

4.1 The following list of elements of arrangements provide NSD's views on what the Licensee's arrangements might be expected to contain to comply with the LC. The list is neither exclusive nor exhaustive and will be subject to review and revision in light of operational experience. If licensees have generic model(s) for arrangements then it is for the site to justify any deviation from the model(s). [note: not all licensees use generic models].

4.2 Arrangements should be provided to comply with LC 32.

4.3 Arrangements shall address the licence condition requirements.

4.4 The arrangements can be defined as a single document or suite of linked documents which provide the procedures and instructions to ensure that regular and systematic examination, inspection, maintenance and testing of all plant items and systems that may affect safety takes place.

4.5 LC4 applies to storage of nuclear matter including radioactive waste and the arrangements for LC32 should therefore cross refer to LC4 arrangements with respect to storage aspects.

4.6 Accumulation of radioactive waste is defined as an "operation" in condition1(1). Therefore the arrangements should state that the LC23 requirements for safety cases and operating rules apply. The safety cases that are produced under these arrangements should outline how the total quantity of radioactive waste is minimised so far as is reasonably practicable, describe the methods of accumulation and demonstrate how the risks from the accumulated waste will be kept as low as is reasonably practicable until final disposal. These safety cases should be produced and assessed in accordance with LC14 arrangements and reviewed and reassessed in accordance with LC15 arrangements.

4.7 Since there is a requirement in LC32(1) for recording radioactive waste accumulated on the site, the arrangements should include a suitable cross reference to the arrangements for LC6 and 25.

4.8 The arrangements should include a definition of radioactive waste in accordance with the Radioactive Substances Act 1993 but make it plain whether or not spent nuclear fuel in the form of fuel elements is radioactive waste.

4.9 The arrangements should include the methods used for the segregation and characterisation of waste arisings. The arrangements should state that use will be made of all available disposal routes. Retained wastes should be conditioned and packaged fit for long term storage and, if appropriate, eventual disposal.

4.10 The arrangements should include a requirement for identifying sources of radioactive waste arising from all plants (existing or proposed) on the site including those resulting from decommissioning. They should state what steps are taken to examine all processes and activities to identify suitable measures for minimisation.

4.11 The arrangements should state that the site will set out to dispose of as much waste as possible. As an example they could state that consignments of Low Level Waste (LLW) to Drigg should be put together in a manner that they maximise the amount sent for disposal but stay within the acceptance criteria, ie 12GBq/tonne.

4.12 The Executive may at any time (and in consultation with the Environment Agencies) specify that waste accumulated or stored on site should comply with certain limitations on quantity, type and form. This should be recognised in the arrangements.

4.13 The arrangements should adequately address factors likely to significantly change the rate, nature and/or form of arisings (or proposed arisings) and the storage period.

4.14 The arrangements should consider that wastes for which there are no presently available disposal routes may require storage for a considerable time. Experience has shown that traditional single-walled vaults, mortuary holes and silos, particularly those with parts below ground, are unlikely to provide adequate long term containments. The arrangements should therefore ensure that stores or other accumulation facilities for radioactive waste are designed to allow retrieval of packages of such waste (e.g. for disposal, or further storage in the case of long-lived radionuclides) as necessary.

4.15 The arrangements should identify all places where radioactive waste is (or planned to be) stored on the site and the amounts, period and form of storage. The arrangements should ensure that, in view of the possibly long timescales involved for storage, disposal or decommissioning, records will be kept in accordance with LC6 arrangements and kept under review since the period may exceed 30 years. These should include unique identifiers of each package, the nature of contents, main radionuclides present and an indication of the activity/dose rate at the date of recording.

4.16 The arrangements should enable the licensee to respond to any Specification from the Executive for any part or parts of the arrangements which the Executive wishes to approve. Such arrangements should identify the person responsible for responding to the Specification and they should identify the system whereby any constraints, caveats or conditions imposed by the Executive are implemented.

4.17 The arrangements should ensure that where part or parts of the arrangements approved under this Licence Condition by the Executive can only be changed or amended with the Approval of the Executive. The person(s) responsible for ensuring compliance with this requirement should be identified in the arrangements.

4.18 The arrangements should identify the person who has responsibility for reporting non-compliance to the Executive.

5. Guidance on inspection of arrangements

5.1 Part 5 of this guidance is to assist inspectors in judging the adequacy of the licensees arrangements. The following list is neither exclusive or exhaustive and will be subject to review and revision in light of operational experience. It does however, provide a hit list of aspects of LC 32 that can be examined during routine inspections

5.2 Check that arrangements have been made to demonstrate compliance with the LC.

5.3 Examine the arrangements layout and check that it is consistent. Review the arrangements to establish validity, whether any changes have been made since the last review and whether the identified responsible persons are correct. Note whether instructions, methods and quality assurance rules claimed in procedures have been followed and whether any changes have been incorporated and validated.

5.4 Confirm that the arrangements have identified the person(s) responsible for managing the accumulation of radioactive waste.

5.5 Check that the scope of the arrangements includes a definition of radioactive waste in accordance with the current Radioactive Substances Act. Confirm that they clearly declare their aim to be the minimisation of the rate of production and total quantity of accumulated radioactive waste together with a waste management strategy and plan that covers all waste steams on the site. Note that they identify there will remain a significant risk from stored waste until disposal is implemented. Check that they cross refer to LC 4 arrangements with respect to radioactive waste storage aspects.

5.6 Confirm that the arrangements cover the aspects described in paragraphs4.6 to 4.18

5.7 With respect to ensuring suitable interaction with the Executive, check that the arrangements:-

6. Guidance on inspection of implementation of arrangements

6.1 Part 6 of this guidance is to assist inspectors in judging the adequacy of the Licensee's implementation of their arrangements i.e. is the licensee doing what their arrangements say they should be. The following list is neither exclusive or exhaustive and will be subject to review and revision in light of operational experience. It does however, provide a hit list of aspects of LC 32 that can be examined during routine inspections.

6.2 Confirm that the arrangements have identified the person(s) responsible for managing the accumulation of radioactive waste and if there are any difficulties raise the matter with the site manager. Discuss the requirements of this licence condition with the responsible person duly identified:-

6.3 Visit those areas of the plan or sites where waste is accumulated or stored. If excessive quantities are accumulated or if waste is not properly stored ask the manager of the area concerned for an explanation. Record details of quantities or take photographs as appropriate and then discuss implementation failures with senior management.

6.4 Verify, by inspection and examination of records that

6.5 Check records of all storage facilities and obtain an estimate from the licensee on the rate of accumulation of waste and also the predicted life of accumulation facilities in terms of years available for future arisings.

6.6 Check that the requirements of this condition are cross referenced to LC 4 for storage of nuclear matter including radioactive waste and to LC 6 and 25 for recording details of such radioactive waste.