This is a joint Environment Agency and Office for Nuclear Regulation () publication that summarises our work relating to the geological disposal of radioactive waste.
As regulators for these wastes, we are working together to make sure that any future geological disposal facility () will meet the high standards for environmental protection, safety and security that the public expects.
We have established agreements with Radioactive Waste Management Limited (), the organisation responsible for developing a , to provide regulatory advice and to scrutinise its work.
We are engaging with early, before regulation starts, so that when a site is identified already clearly understands what it needs to do as part of the regulatory process.
We also liaise regularly with to make sure that it gives the right advice to waste producers about packaging radioactive waste for future disposal at a .
We have no regulatory role in selecting potential sites for a . However, we will offer our support on matters relating to our respective areas of regulation to communities that are considering hosting a .
We continue to speak openly with to help it understand what it needs to do to meet environmental, safety and security regulations.
It also helps us better understand ‘s work, and lets us prepare in advance for any permit or licence applications we might receive, so that we can respond promptly and knowledgeably.
We have set out our regulatory expectations for geological disposal, covering our respective remits.
The Environment Agency has issued its Guidance on Requirements for Authorisation ().
has issued a Technical Assessment Guide on Geological Disposal, and will draw upon relevant aspects of ‘s Safety Assessment Principles for Nuclear Facilities.
Throughout this document ‘we’ refers to both the Environment Agency and ; where comment is made on matters specific to one regulator then ‘The Environment Agency’ or ” is used.
As independent regulators, we are committed to making our work open and transparent. This report will help us continue to do this.
Government policies in England and Wales state that higher activity radioactive waste () will be managed in the long term through geological disposal.
This is currently being progressed alongside ongoing interim storage of waste and supporting research.
is the organisation responsible for implementing government policy on geological disposal of and for providing advice on managing radioactive waste.
It is currently carrying out ‘generic’ preparatory work for a , as no sites have yet been identified.
This report summarises the work that the Environment Agency and the have carried out to scrutinise ‘s work and our interactions with the public during 2019 to 2020.
Our oversight of is helping it to better understand the regulatory requirements and the submissions it needs to make to apply for environmental permits and a nuclear site licence for geological disposal activities.
As we summarise in this report, has progressed in a number of areas, but further work is still required. The main outcomes from our work during 2019 to 2020 are detailed below.
We are pleased to note that in its Corporate Strategy 2019 sets itself a strategic objective “to complete its cultural and capability development for major programme delivery by 2022”.
We recognise that has implemented a number of significant organisational changes in a relatively short time.
However, needs a clear plan in place to show how and when it will establish itself as an organisation suitable to hold an environmental permit, and subsequently a nuclear site licence.
has provided a large amount of new material that represents some progress towards providing the necessary information. However, work is still needed to present an integrated programme.
It will need a targeted, prioritised research and development () programme to address relevant uncertainties and to make sure it applies Best Available Techniques.
We consider that ‘s systems and processes for are suitable for this early stage. However, should clarify in its research plans why each project is important in developing a safety case, and what impact completed projects have made, justifying any deferrals or delays.
In particular, we have asked to consider whether it knows enough about the impacts of waste package voidage on a and the development of a in an evaporite geology.
Good progress has been made towards establishing a Research Support Office, but needs to make sure it develops links with relevant engineering disciplines to understand more about operational safety challenges.
‘s 2010 generic Environmental Safety Case did not address this adequately.
The Environment Agency has since reached a common understanding with of its regulatory expectations; has made significant progress and has taken much of our advice into account.
has significantly improved its Total System Model () for non-radiological contaminants in a , aligned now with its for radioactive substances.
is also developing its disposability assessment advice for waste packagers on non-radiological contaminants.
This will cover approximately 100 hazardous substances and non-hazardous pollutants that may be present in the waste and, or introduced through the waste packaging and conditioning process (or both).
must consider how to address significant uncertainties. We emphasised that its guidance for waste producers should be balanced, without unnecessarily increasing the reporting and waste characterisation burden on waste producers.
recognises its guidance will need to meet the needs of different audiences, including its own disposability assessment team, waste producers, and those involved in developing strategies for radionuclide data generation and recording.
needs to clarify how it will establish baseline conditions through its site characterisation work and demonstrate suitable arrangements to manage data and information quality.
We advised to carry out a structured analysis of options for underground investigations.
The Environment Agency also held a technical exchange meeting with the Swedish nuclear regulator and visited a number of facilities in Sweden, including an underground research laboratory.
The mission gave us the opportunity to have our regulatory framework reviewed by our peers from across the globe. The team made some findings related to progressing with strengthening the regulatory framework for a future .
Radioactive waste has been, and continues to be, produced from the UK’s historic and current nuclear power, research and defence programmes, as well as from industries, hospitals and universities that use radioactive material.
There is currently no route to dispose of higher activity radioactive waste (), the most radioactive category of waste, so it is stored on existing nuclear sites until a solution can be found.
UK government policy for the long-term management of in England is described in the 2018 policy document.
This sets out the framework for managing through geological disposal, focusing on how a would be implemented in England.
Similarly, the Welsh Government has adopted a policy of supporting geological disposal for the long-term management of .
Scottish Government policy does not support geological disposal. It advocates near-site, near-surface management of . Also that long-term storage in a near-surface storage facility is the primary long-term management option.
The Nuclear Decommissioning Authority () is responsible for implementing government policy on the long-term management of radioactive waste. Its subsidiary, , is responsible for developing a .
The Environment Agency and the are responsible for making sure that any future in England meets the high standards necessary to protect people and the environment when it is being developed, while it is operating, and after it has closed.
We will be responsible for granting the necessary environmental permits and nuclear site licence, and for our respective regulatory roles of environmental protection, safety, security, radioactive materials transport and safeguards.
Our regulatory partner Natural Resources Wales () has similar environmental protection responsibilities for Wales, and we keep them aware of matters arising and important outcomes from our work.
Regulatory control of a is likely to be required for at least a century. We are engaging with now to make sure that any future applications to develop a take account of all permitting and licensing requirements.
We also want to make sure that gives the right advice to waste producers, so that radioactive waste packaged at their sites is suitable for future disposal.
Discussions at this early stage will also help us prepare in advance for any permit or licence application we might receive from , so that we can respond promptly and knowledgeably.
At this stage, before considering issuing permits or licence, we are providing regulatory advice rather than making regulatory decisions.
We have no regulatory role in selecting potential sites for a . However, we will offer our support to communities that are considering hosting a , and will advise on matters relating to our respective areas of regulation.
We continue to liaise with to make sure that our regulatory requirements are recognised in the plans and tools it is developing to locate potential sites for a .
Our discussions with about its plans and proposals for working groups are helping us prepare to support community discussions.
Our preparations to date include identifying staff to lead our support to working groups and sharing communications and engagement materials with them. These preparations will continue to ensure we are ready well in advance.
Ahead of discussions with specific communities, we have supported national stakeholder engagement through attendance at the Department of Business, Energy & Industrial Strategy () forum of environmental non-governmental organisations.
also invited us to its regional site stakeholder group meetings on waste management and geological disposal. We were able to provide information on our role as regulators and to respond to any relevant questions.
We expect to have a clear and comprehensive plan of work to implement geological disposal that meets regulatory requirements and to demonstrate progress against it ( §6.2.5 to 6.2.41). We recognise that such a plan may need to meet other stakeholder needs in addition to regulatory matters. However, these wider stakeholder needs are not part of our regulatory responsibilities and so do not form part of this work scope.
This will give us confidence that understands what it needs to do to achieve its goals at each phase of its work. It will also enable us to plan and focus our scrutiny work and assess ‘s progress towards meeting our requirements.
We have, for some years, advised that there is not a good overall view of its programme. We stressed should demonstrate all it needs to achieve, by when, in a way that we and others can understand.
We consider that this will be a high priority if wishes to efficiently and successfully progress geological disposal.
Our engagement with , over the period covered by this report, has proved fruitful.
has provided a large amount of new material that demonstrates some progress towards providing the necessary information. However, more work is still needed to adequately present an integrated programme.
We will continue to engage with to help it address our regulatory requirements. We will use the information gathered to monitor its progress and readiness.
The developer and operator of a should foster and nurture a positive organisational culture (promoting safety, security and environmental compliance) at all times.
It should also have a management system, organisational structure and enough resources to provide essential functions [ Requirement 4; Licence Conditions 17 and 36].
To issue environmental permits for borehole investigations at a potential site, or sites, we need to be confident that can comply with those permits from the date we issue them.
must also continue to develop its organisational structure and management systems so that it is capable of holding the necessary environmental permits and a nuclear site licence to construct and operate a .
We have been monitoring ‘s progress over recent years and have reported the outcomes of our inspections in previous annual reports.
We recognise that has implemented a number of significant organisational changes in a relatively short time and that periods of organisational instability can prove challenging.
We want to be ready to apply for the environmental permits it needs to begin its site investigation work. We are pleased to note that in its Corporate Strategy 2019 set itself a strategic objective “to complete its cultural and capability development for major programme delivery by 2022”.
However, needs a clear plan in place to show how and when it will establish itself as an organisation suitable to hold an environmental permit, and subsequently a nuclear site licence
is developing an ‘integrated capability development plan’, which will address this. We will continue to advise as it develops this plan.
We have advised that matters highlighted in its Health, Safety, Security, Environment and Quality () Strategy are of interest to us.
These include the need for suitable management arrangements; knowledge management; record keeping; qualified and experienced personnel; technical oversight capability; and quality assurance.
The Environment Agency will need to be confident that is competent in these and other aspects before we can grant any environmental permits.
The Environment Agency will continue to provide advice to on its ‘organisational development’ expectations of a permit holder.
will also continue to advise to make sure that its organisational development is in line with the expectations of a prospective holder of a nuclear site licence.
We consider that ‘s Safety & Environment Management Prospectus is adequate for the current stage of the programme. Together with its Organisational Baseline, this is adequate for making sure has the necessary capability to implement its plan of work. However, we advised to use the plan to help it appoint people to important organisational baseline roles.
In doing this, needs to consider the competing demands for nuclear skills nationally over the next 2 decades, and the current age profile of experienced people, to establish what it needs to do to develop its own skills and experience.
We also advised to identify all the management system, quality and environmental standards it needs to comply with.
Our engagement with has given us a useful insight into its current approach, through its Transformation Programme, to become a safe and effective organisation through cultural change, increased organisational capability and improved ways of working.
We will continue to engage regularly with and monitor progress. We plan to carry out an inspection during 2020 to 2021 focused on ‘s management of change capability.
‘s applications to develop a must take full account of our environmental permitting requirements [ §5] and the duties placed on operators of a licensed nuclear site (nuclear safety, security, safeguards, radioactive materials transport, and conventional health and safety).
‘s understanding and interpretation of the full range of relevant regulations and guidance should be consistent with our expectations [ Part 2, Licensing Nuclear Installations], and it should be aware of new and emerging regulations.
An application for any environmental permit relating to a proposed disposal of solid radioactive waste must be supported by a suitable environmental safety case ().
Similarly, any application for a nuclear site licence to construct and operate a will need to be supported by adequate demonstrations of safety and security.
We want to establish a clear and common understanding with of the requirements of the applications for permits and licences to make sure that any future applications take full account of our regulatory requirements.
The Environment Agency will require an Initial Site Evaluation () to support an application for a radioactive substances activities environmental permit to start intrusive investigation work in the search area for a .
At this stage, our main regulatory aim will be to make sure that any proposed intrusive site investigation will not compromise the integrity of a potential site to the unacceptable detriment of the long-term environmental safety case for a possible .
We will also want to make sure ‘s proposals can adequately collect information and data to support a decision to start underground operations and that is able to appropriately manage any relevant subcontractors.
The Environment Agency will subsequently require a Preliminary Environmental Safety Evaluation () to support an application for a variation (change) to an environmental permit to allow underground operations to start ahead of a being constructed.
At this stage, the Environment Agency would expect to be able to demonstrate that underground operations would not compromise the integrity of a candidate site to the unacceptable detriment of the environmental safety case for a .
The Environment Agency would also expect to have a suitable work programme in place to collect information and data to support a decision to move to the next stage of development.
The Environment Agency will require further applications to support proposals for construction of disposal facility areas and to support decisions to allow disposal of radioactive wastes to begin.
will need to address all environmental regulations relevant to the intrusive investigation work such as groundwater activities, waste operations, water discharge activities and water abstraction.
The Environment Agency could grant the necessary environmental permits to proceed with each stage of site investigation provided has made an acceptable application, subject to any conditions or limits that might be imposed.
For sites not selected for further investigation, the Environment Agency would only accept a permit being surrendered (cancelled) once it is satisfied that any regulated areas have been returned to a satisfactory state.
We continue to engage with to provide advice on our environmental regulations as necessary.
The Environment Agency met with to discuss its permitting process and regulatory expectations for the and to support applications for environmental permits for radioactive substances activities.
This provided the opportunity for some initial discussion and clarifications, which concluded that further, more detailed discussions were needed.
A workshop was planned in March 2020 to discuss wider matters related to the environmental permitting of an intrusive site investigation programme, including considering other relevant environmental regulations. Unfortunately, the workshop was postponed due to the COVID-19 pandemic. This area will be progressed in the ongoing work programme.
The Water Framework Directive (2000/60/EC) and the Groundwater Directive (2006/118/EC) require EU member states to protect groundwater against pollution and deterioration by preventing hazardous substances and limiting non-hazardous pollutants from entering groundwater.
‘s 2010 generic Environmental Safety Case did not adequately address the need to protect groundwater resources and the public’s health from the non-radioactive substances in the inventory for disposal. The Environment Agency has engaged with regularly since then to share its regulatory expectations and to understand ‘s work to address this. has made significant progress, but some matters remain.
The Environment Agency advised on its developing Total System Model () for non-radiological contaminants in a . The latest version is significantly improved and has taken much of our advice into account.
We are pleased that the non-radioactive contaminant is now based on the for radioactive substances, and that intends that future versions will improve the consistency between the two.
We identified a number of areas that could be improved. These included:
We also advised of our concerns over its non-conservative treatment of organic contaminants in the source term and deep groundwater.
is developing its disposability assessment advice for waste packagers on non-radiological contaminants.
This will cover approximately 100 hazardous substances and non-hazardous pollutants that may be present in the waste and, or introduced through the waste packaging and conditioning process (or both).
We advised that our biggest concern is with waste that has already been packaged, in particular historical waste with records that may not reflect recent guidance.
Because we do not expect waste already packaged to be sampled and characterised, and we wish to avoid or minimise reworking, we advised to review analogous waste streams and seek input from those involved in the processes that created (and packaged) the waste.
Where characterisation data are limited, proposes to use inventory descriptions to identify materials and chemicals that may contain, or degrade and corrode to, non-radioactive contaminants of concern.
The Environment Agency updated on the potential impact of the Mercury Regulations on the disposability of radioactive mercury and mercury-contaminated waste.
Preliminary legal advice is that radioactive waste is not excluded from the scope of the Regulations. However, the discussion has broadened to a wider debate with on exclusions from the Waste Framework Directive.
We are aware that a number of organisations are keen for advice on this and we will advise further when we can.
We will continue to work with to provide clarity on our requirements for protecting groundwater at depths relevant to a .
maintains a list of radionuclides that waste producers must report against. The Environment Agency advised on its proposed approach for re-deriving this list of potentially recordable radionuclides.
This is an important area of work, as the final output of this project will be an updated list of radionuclides that need to be considered when assessing the environmental, operational and transport safety of waste intended for disposal to a .
We consider that ‘s approach is reasonably comprehensive given the work is at an early stage, but still needs to resolve many areas of detail and practice.
We advised to consider how to address significant uncertainties. We emphasised that its guidance for waste producers should be balanced, without unnecessarily increasing the reporting and waste characterisation burden on waste producers.
recognises its guidance will need to meet the needs of different audiences, including its own disposability assessment team, waste producers, and those involved in developing strategies for radionuclide data generation and recording.
We advised that it should, as a minimum, consult with , , Low Level Waste Repository Ltd and the National Inventory Forum.
Collaboration with will be particularly important in making sure that the approach can be adapted to identify radionuclides relevant to possible alternative ways of managing some Intermediate Level Waste () streams.
We advised to engage with us as it continues to develop and implement its approach.
Development of a safety case for a is complex. It is recognised internationally that continual dialogue between the regulators and the developer, from the very early design stage, is essential. A safety case should contain the claims, arguments and evidence that support the safety of a .
is preparing an Integrated Design and Safety Case roadmap, which will support more detailed roadmaps, including those for the Operational Environmental Safety Assessment () and the Environmental Safety Case.
The Integrated Design and Safety Case roadmap provides a high-level framework for the main activities, which will form the basis for the future development of ‘s Technical Programme.
We provided preliminary feedback on these documents. We particularly noted that must ensure consistency between the and Post-Closure Safety Assessment.
has no current plans to publish another set of documents. Instead, it will use its safety case tool, (Visualisation of System Information), to keep its generic safety case understanding up to date, supported by site-specific submissions, if and when required.
has put the 2016 claims, arguments and evidence into . We will continue to engage with on its development and usability.
has advised it is developing its conceptual security arrangements for a . has previously provided advice to on producing a Generic Security Plan based on ‘s Security Assessment Principles.
welcomes ‘s work in this area and advised to develop its arrangements in accordance with ‘s guidance, relating to security arrangements at various stages in the life cycle of a new installation.
will continue to engage with as it develops its security arrangements to ensure they meet our expectations for a nuclear security duty holder.
We expect to have appropriate plans and procedures in place to carry out the site investigation and characterisation work needed to implement geological disposal, and to inform the safety cases, design and construction ( Requirement 11).
At this stage, we want to make sure that ‘s plans and actions for future site investigations are consistent with our permit requirements and would not compromise the integrity of potential sites.
After considering ‘s documents that set out information requirements for site characterisation and how to meet them, the Environment Agency provided advice and recommendations to . Our main points were:
The Environment Agency has continued to engage with on its research on borehole sealing.
This has included observing ‘s downhole placement system to load large-scale borehole experiments, and attending a project workshop at which the project team discussed our suggestion that a Claims, Argument and Evidence approach is useful for building confidence in borehole sealing.
We have also engaged with on its proposals to demonstrate its borehole sealing capability in the field.
first identified a candidate borehole located on Magnox Limited’s Harwell site.
We discussed with , and its contractor, proposals for surveying the borehole to determine whether it was suitable to use in a field demonstration.
We advised on matters related to environmental protection, including groundwater resources, and we visited the site during the surveying.
identified another location in a different geological environment and began to explore feasibility. However, progress on this was stalled due to COVID-19 and we hope to pick this up in our ongoing programme.
For work that supports the environmental safety case, the developer and operator needs to make informed judgements about the quality of the science being applied. It also needs to make sure it carries out timely scientific investigations to improve understanding.
The developer and operator needs to be aware of any scientific developments, both within and outside the UK, which may have a bearing on the environmental safety case for the facility [ Requirement 4, Applying sound science and good engineering practice].
We expect to carry out a comprehensive research and development () programme, informed by wider national and international research or implementation programmes. will need to identify and address in a timely manner those issues that require to meet our requirements.
We expect to have a targeted and prioritised programme in place that addresses uncertainties and safety concerns that are important in producing a safety case.
should be clear, through its management process, why the is needed, what knowledge gap it is filling, and how knowledge gained is being used to fill this gap and to further develop the future programme.
The Environment Agency’s engagement with over the past few years has been focused on reviewing its Science and Technology () Plan and Programme, engagement through ‘s Integrated Project Teams, reviewing ‘s status reports as part of our overall assessment of ‘s 2016 , and ad hoc engagement on a number of technical areas (such as non-aqueous phase liquids, superplasticisers, colloids, and voidage).
To date, we have purposely limited the depth of our engagement on specific technical areas, in order to assure ourselves that is operating the necessary procedures and has the right tools in place for its activities.
Through our ongoing dialogue with , we are determining how we might now better understand the details and effects of ‘s programme, for example:
In the following sub sections (§7.2 & 7.3) the Environment Agency includes a number of initiatives it began this year.
concludes that, at present, is adequately engaged in relating to operational safety at a . Until disposal concepts are refined after sites are selected for characterisation, this remains at a relatively generic level.
Similarly, at present, there are no areas where considers it should carry out independent research to verify ‘s own research. Continued engagement with and the international community will ensure that can respond appropriately to any new needs in the future.
We provided high-level feedback to to inform its development of the next issue of its Science and Technology () Plan, anticipated in 2020 to 21.
We asked to include information on projects completed since the last Plan was published to track progress, and context to clarify why projects are important to developing the safety case.
outlined its prioritisation approach, which it uses to select and prioritise research projects, based on both the importance of the work and urgency with regards to the current point in the overall programme against 6 main drivers.
We advised to consider how it captures information on projects it chooses not to progress and to justify its decisions.
We also advised to include relevant timescales for projects it chooses to defer to make sure it reconsiders these at the appropriate time (either in years or at specific programme milestone).
As part of its decision to defer projects, we advised to consider future financial provision to ensure it has funding available to implement these projects when deemed sufficiently high priority.
The regulators should have (and be able to demonstrate) an understanding of the is carrying out in important areas, confidence that important areas are being investigated appropriately, and that the programme is prioritised.
The Environment Agency carried out a trial prioritisation exercise, focusing on a number of important areas of the 2016 Plan. This allowed us to test whether we could identify areas that were urgent and important in terms of demonstrating environmental safety of geological disposal, or increasing our current knowledge.
The exercise did not aim to identify the should carry out, but it did identify 2 broad areas where was scarce; namely ‘voidage’ and ‘evaporites’.
The Environment Agency will apply this prioritisation exercise again using a more up-to-date plan, to focus its engagement and scrutiny going forward.
Together with the prioritisation exercise and as part of a package of methods to assess ‘s Plan, the Environment Agency also developed a ‘Technical Risk Audit Template’ to assess how manages risk in carrying out projects that lead to a change in scientific or technical readiness levels.
The Environment Agency will trial this template in 2020 to 2021, and plans to use it as an assessment tool afterwards.
We recognise made progress in 2019 towards establishing a Research Support Office () to “harness UK university capabilities through a collaborative, long-term relationship”.
We consider that ‘s shift towards longer term collaborations should allow it to develop and share understanding across disciplines and institutions.
We agree with that university-based research can make a significant contribution to ‘s knowledge base and provide research focused on ‘s needs.
However, we noted that the university departments and disciplines associated with the focus on ‘s traditional research areas related to post-closure safety. It will need to develop links with relevant engineering disciplines, for example, to build its knowledge base with respect to operational safety challenges and future research needs.
The site sending radioactive waste to a (consignor) is responsible for appropriately characterising, treating and packaging it.
But the operator of a is responsible for making sure that the waste accepted for disposal is consistent with the environmental safety case and the operational requirements, including transport and handling [ Requirement 13].
has developed a process of disposability assessment to minimise the risk that conditioning and packaging radioactive wastes results in packages incompatible with geological disposal. Through this process, provides advice to waste producers on packaging their .
We expect to assess packaging proposals for against clear and consistent published specifications. This to assure us that is packaged suitably for handling and disposing of in a future , and to share good practice in waste packaging to avoid duplication of effort.
We are engaging with now to establish confidence that:
In particular, we have advised to make progress on establishing clear guidance for waste producers on endorsing packaging of High Heat Generating Waste such as spent fuel and vitrified products from Sellafield (High Level Waste).
Historically, has been much more focused on assessing and endorsing Low Heat Generating Waste (Intermediate Level Waste).
We worked with to agree an approach for it to address the remaining issues we have raised relating to its treatment of post-closure criticality and setting waste package fissile limits.
Our Regulatory Observation on fissile limits [/RO/008, see Annex A] required to engage with the nuclear industry to identify all waste streams that may be challenging from a post-closure criticality safety assessment standpoint and to develop a programme of work to improve packaging advice.
The aim of this work is to achieve the lowest practicable risk when balanced across the waste life cycle, ensuring ‘s waste packaging advice does not drive less favourable approaches, yet maintaining safety and environmental performance. has completed this for the majority of waste streams.
‘s transport safety specialists have also engaged with the International Atomic Energy Agency () on technical standards and guidance by liaising with UK industry transport groups (Transport Container Standardisation Committee and Radioactive Material Transport Users’ Committee).
has been actively involved in the Member States’ consultation on revision to the ‘s Advisory Material for the Regulations for the Safe Transport of Radioactive Material (SSG-26), led by for the UK. The revised SSG-26 has been endorsed by the ‘s Commission on Safety Standards, and it is anticipated to be published shortly.
The Environment Agency has advised on its work on waste package voidage. is reviewing its approach to screening levels that could help inform decisions at sites regarding how much voidage is acceptable for each waste package.
We anticipate that regulated activities will continue for around 150 years from the start of construction of a , during its operation, through to its final closure. This means that regulators will need to maintain capability over extended periods.
While regulating geological disposal is similar to ongoing regulatory activities, it also has some differences and so it may be necessary to enhance regulatory capabilities in some areas at certain times.
The regulators will maintain and enhance their capabilities in order to meet their responsibilities in regulating geological disposal, and work is underway to do this.
This section provides an overview of work carried out in the reporting period.
Liaising with on geological disposal at an early stage will allow us to prepare for any environmental permit or nuclear site licence application that we might receive, so that we can respond promptly to what will be a first of a kind activity.
The Environment Agency has begun to develop a programme of work to be ready to regulate geological disposal. This work programme is in its early stages of development, but we have carried out work in the following areas:
An team from the , comprising over 20 regulatory experts from across the world, led a mission to review the UK’s nuclear and radiological safety framework. missions help Member States strengthen and enhance the effectiveness of their regulatory infrastructure for nuclear, radiation, radioactive waste and transport safety. missions take place at the invitation of the host country and usually happen every 10 years, with a follow up mission within 4 years.
The review took place in October 2019 at the request of the UK government. It was hosted by and involved considerable input from multiple government departments, the devolved administrations and regulators, including the Environment Agency.
This mission report includes 24 recommendations to further strengthen the UK’s nuclear and radiological safety framework for the relevant UK authorities and regulatory bodies to consider. The majority of the findings relate to enhancing regulatory bodies’ internal processes.
We welcome the ‘s final report. This first full scope mission to the UK gave us the opportunity to have our regulatory framework reviewed by our peers from across the globe.
We welcome the findings specific to the Environment Agency and these will help us continually improve and ensure people and the environment remain protected from radioactive substances activities in England.
continues to work with to facilitate the necessary legislative amendments so that can grant a nuclear site licence for a in future. As part of this work, plans to carry out a public consultation on a revised interpretation of the term ‘bulk quantities’ in the context of disposal.
In preparation for the mission, the Environment Agency identified that its guidance needed reviewing. We will use this review as an opportunity to address this specific mission finding.
In June 2019, members of Environment Agency staff met with the Swedish nuclear regulator, SSM, as part of an ongoing programme of technical exchange visits to share experiences and learning on the regulation of geological disposal.
Environment Agency staff visited a number of facilities at Oskarshamn operated by SKB, including a copper canister laboratory, a centralised spent fuel storage facility and an underground research laboratory. SKB is the organisation in Sweden responsible for the management of spent nuclear fuel and radioactive waste.
The regulators take part in a number of international collaborative programmes to share experience with other countries. For example, during this period a number of Environment Agency staff were involved in the following Nuclear Energy Agency () work:
Our continued interaction with is helping it to better understand the regulatory requirements and submissions it needs to make to obtain environmental permits and a nuclear site licence.
As summarised in this report, has progressed in a number of areas, such as its work on site characterisation, modelling non-radiological contaminants and identifying relevant radionuclides, but further work is still needed.
‘s high-level and strategic ‘organisational development’ work needs a clear plan in place to show how and when it will establish itself as an organisation suitable for holding a permit, and subsequently a nuclear site licence.
Our work in other areas is helping to implement policy as well as our own continuing preparations for regulating geological disposal of radioactive waste in the future.
