Current Arrangements and Requirements for the Conditioning, Packaging and Storage of Intermediate Level Radioactive Waste: Joint RWMAC/NuSAC Report

ANNEX 1

STUDY OF TERMS OF REFERENCE

The terms of reference agreed by the Radioactive Waste Management Advisory Committee (RWMAC) and the Nuclear Safety Advisory Committee (NuSAC) for the joint study of current conditioning, packaging and storage of intermediate level radioactive waste (ILW) were as follows.

Introduction

It is now almost four years since the demise of the Nirex intermediate level radioactive waste (ILW) repository programme. It is currently unclear as to where precisely the UK is heading in respect of its longer-term solid radioactive waste management policy. A Government policy consultation has been promised.

In the meantime decisions have to be taken concerning ILW conditioning, packaging and storage. Waste is currently under the management control of waste producers such as BNFL, BE, UKAEA and MoD. It has been waste producers responsibility, when wishing to package wastes, to gain regulatory approval from NII who in turn consult with EA. To present this has required waste producers to secure a Letter of Comfort from Nirex about the potential disposability of the ensuing waste packages.

In future the safety pressure to package waste will need to be adequately recognised and although potential disposability will still be an important factor it will need to be balanced, by the waste producers, with other more immediate considerations when making a case to NII. The need to get waste in a form suitable for passively safe storage is likely to be deemed relatively more important than the past concept of delay so as not to preclude future management options.

Against this background, it is appropriate to enquire whether there are currently clear and sensible aims and objectives for the conditioning, packaging and storage of UK radioactive waste that are accepted by all the key players, clearly set out, universally applied and which adequately safeguard the health of both the public and radiation workers? If there are not, what problems is this likely to give rise to and how might they be suitably addressed? It is these broad questions that this study will address.

Issues to be considered

The kinds of issues that would be investigated as part of the study include:

• what are the current motives and drivers for retrieving, conditioning and storing ILW: is there a clear strategy and are accountabilities clear?
• what conditions and advice have been compiled and made available to the waste owners by the HSE and the environment agencies concerning the conditioning, packaging and storage of ILW?
• how do these tie in with the Letters of Advice and Comfort systems operated by Nirex?
• are there legacy radioactive wastes that are likely to give rise to particular problems: if so, what are they?
• could the specified and actual conditions and lifetimes for the packaging and storage of UK radioactive waste lead to problems in the context of future policy options, particularly in respect of an extended storage period option: if so, what are they?
• how difficult would such problems be to overcome in practice through, say, repackaging of waste or extension of store lifetimes?
• is the meaning of passive storage of waste adequately understood and defined: to what extent would its application actually be likely to foreclose future management options?
• what percentage of UK ILW is currently in a passively stored form?
• does the current role of Nirex as a third, non-regulatory player make sense given the demise of its repository programme and uncertainty concerning its future?
• how consistent is the advice available to HSE and environment agency inspectors concerning the conditioning, packaging and storage of ILW. And how consistent is application of this advice in practice?
• how, if at all, could current arrangements be improved acknowledging the uncertainties currently involved?

Output

This project will be undertaken jointly by the RWMAC and NuSAC advisory committees. It is a topic that spans the terms of reference of both committees. The output would be advice to the RWMAC's sponsoring ministers and the Health and Safety Commission as the sponsor of NuSAC.

Possible follow-on work

The coverage of this initial study will be ILW that has previously seen to be destined for the Nirex ILW repository. In principle, however, the work could be extended at some future point to cover other areas, for example spent fuel not committed to reprocessing, high level waste (HLW) and even plutonium if a proportion of this comes to be regarded as waste.