Developing and maintaining a radioactive waste management plan
How to develop and maintain a plan for managing radioactive wastes created and disposed of by radioactive substances activity permit holders.
Applies to England
What this guidance applies to
This guidance is for holders of radioactive substances activity permits that cover activities involving waste from unsealed sources.
This guidance does not apply to those operating on a nuclear licensed site.
Why you need a waste management plan (WMP)
You must produce and maintain a radioactive WMP to demonstrate that:
- you have a complete understanding of your radioactive wastes
- your radioactive wastes are being disposed of using an optimised route
You must maintain a WMP until work involving radioactive substances has ceased on your premises and you have surrendered your permit.
Adopt a graded approach
You should develop your WMP using a graded approach. This means your WMP needs to be proportionate to:
- the scale and complexity of your activities
- the hazard your waste represents to the public and the environment
Your plan may be very simple if:
- your operation is of a small scale, for example a laboratory or veterinary practice
- you only use a small number of radionuclides with very short half-lives that are accumulated and decayed before disposal
Your plan may be more complex if:
- your operation is larger, for example multiple facilities, for example a large nuclear medicine department or large research facility
- you need to accumulate waste for prolonged periods
- you have wastes with no current disposal route, for example requiring disposal at a geological disposal facility (GDF)
Your WMP may have uncertainties, particularly if your activities have a long lifecycle. You should ensure that these uncertainties are resolved over time as more information becomes available to you. You should resolve all uncertainties before disposal takes place, as far as reasonably practicable.
Approach developing your WMP
You must have sufficient resources to implement your WMP throughout the lifecycle of your operations.
Your WMP should:
- cover all radioactive wastes created throughout your operational lifecycle, including those from planned decommissioning activities
- cover clean-up of radioactively contaminated ground and groundwater, where relevant
- take account of both the radiological and non-radiological hazards of the radioactive waste
You must use best available techniques (BAT) to minimise the volume and activity of radioactive wastes you create, accumulate and dispose of, as required by your permit. To understand the Environment Agency’s expectations around demonstrating BAT for radioactive waste disposals, see RSR: Principles of optimisation.
Your WMP should identify the disposal route (or routes) for all of your radioactive wastes over the lifetime of your activities. Disposal routes may include:
- disposal by transfer off-site
- disposal of liquid and gaseous waste by discharge to the local environment
- decay storage so that the waste complies with the limits in a relevant exemption or is out of scope
As required by your permit, you must:
- demonstrate that your chosen disposal routes are optimal
- ensure that radiation doses to the public and the environment from your disposals are as low as reasonably achievable (ALARA)
You should take an integrated approach to the management of all wastes, both radioactive and non-radioactive, over the lifetime of the site. Your WMP should give priority to ensuring an optimised outcome for the radioactive wastes.
Develop your WMP
You should demonstrate integrated planning for your radioactive waste, where appropriate. This should consider all current and expected future arisings of radioactive wastes and their radiological and non-radiological properties.
You should apply the waste management hierarchy, as appropriate. You should maintain a clear strategic overview of how you intend to manage the production and disposal of radioactive waste over the lifetime of your permit.
Your WMP should demonstrate that all radioactive waste on site is properly controlled using BAT so that:
- it is well characterised and disposable using your chosen disposal route
- the waste acceptance criteria (WAC), including packaging requirements, of the disposal site are met
- wastes are accumulated in a passively safe state
- secondary wastes are not unnecessarily created
- the spread of radioactive contamination, or associated chemical contamination, is avoided
Your WMP should include information such as:
- how you have applied the waste hierarchy
- how you sort, segregate, condition and treat wastes to prevent leakage and the generation of secondary wastes
- where and how you will accumulate radioactive wastes on your site before disposal
- a catalogue of your radioactive waste including their non-radiological characteristics, for example, reactivity, toxicity and other hazardous properties
- disposal options assessments to demonstrate that you have selected optimised disposal routes for your waste
- an explanation for the accumulation of radioactive waste – accumulation needs to be for a purpose
- assurance that wastes will meet relevant WAC for your selected disposal routes, where wastes are being transferred for disposal, reflected in your waste consignment management system
- disposability assessments for any higher activity wastes (HAW, defined as wastes with more than 4 gigabecquerels (GBq) per tonne alpha or more than 12 GBq per tonne beta or gamma, or both) that you generate or plans to obtain suitable disposability assessments
- a timeline of when wastes will be, or are likely to be, created, how long they will be accumulated for and when they will be disposed of
- how your wastes arise and how you have used BAT to minimise the quantities and activity of the wastes that you generate
- if you receive wastes for treatment or disposal, how you will manage the acceptance of wastes consigned to you and how you will manage those wastes on your site
Characterisation data
You must characterise, segregate and dispose of all radioactive waste using BAT to ensure that your management of the waste is optimised.
Good characterisation data should:
- form the foundation of your WMP
- be sufficient to inform decision making about managing the production and disposal of any radioactive waste during operations and decommissioning
Characterisation may be by direct or indirect measurement methods. In some cases, it will be acceptable to characterise waste using calculation methods alone. The method (or methods) you use must demonstrably represent BAT and include uncertainty and confidence levels.
You should periodically review the characterisation techniques you use, and the quality of data produced by your characterisation activities. See good practice guides for characterisation from the National Physical Laboratory and the Nuclear Decommissioning Authority.
You should characterise all radioactive waste in a way that recognises that some parts may be out of scope, while other parts may be above these values. If the outcome of characterisation is that the waste is out of scope, you must follow all legal requirements for the management of non-radioactive waste.
Records management
You must:
- make a record of all your radioactive waste accumulations and disposals throughout the lifecycle of your operations, as required by your permit
- retain your records until you surrender your permit
Your records may be hard copy or electronic.
You should design your records management system to ensure that records are retrievable and legible over many years.
If you need to retain records for a long period of time, traditional record keeping methods are unlikely to be sufficient. For example, if you are accumulating waste for long periods of time or when waste will need to be disposed of in a GDF.
Your WMP should identify your strategy, methods, and procedures for long term management of radioactive waste records.
For further guidance on methods for long term records management systems, see:
- the International Atomic Energy Agency (IAEA)
- a code of practice from the UK government
- standards available, such as BSI 30300
You can also refer to the National Archives for a range of guidance, tools and templates to help you with records management.
How to format your WMP
Your WMP does not have to be a single document. It can comprise a collection of resources that are already in place, such as:
- inventories of wastes
- record management procedures
- schedules of future waste arisings
- optimisation studies demonstrating how the radioactive waste management proposals have been determined to be optimal
If your WMP is a collection of documents, you should compile a summary or header document to identify all the information sources used to support the plan.
Your WMP should be a ‘live’ product that is maintained and reviewed on a regular basis. You should maintain the WMP in the light of factors such as developments at the site, new information, changes in legislation and government policy. You should comprehensively review the WMP at least every 5 years.
Site-specific developments necessitating a review may include, for example:
- achievement of significant milestones in the development, operation or decommissioning of your site
- new information about your waste inventory, for example because of better characterisation of known sources or identification of new sources
- availability of new waste treatment techniques or disposal routes
- new information about radiation doses to people or the environment
- changes in your operations – such as when you want to construct a new facility or undertake new work such as a new suite of experiments or tests, or the use of a new radionuclide
Environment Agency inspection
The Environment Agency will assess whether your WMP is adequate and proportionate for your activities.
They may either:
- inspect your WMP when they visit your premises
- ask for your WMP to be sent to them for inspection