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 support communities that are considering hosting a on matters relating to our respective areas of regulation.
We continue to speak openly with . This helps 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 from , 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 on relevant aspects of the Safety Assessment Principles for Nuclear Facilities (SAPs) .
Throughout this document ‘we’ refers to both the Environment Agency and . Where comment is made on matters specific to one regulator then ‘we (Environment Agency)’ or ‘we ()’ is used.
As independent regulators, we are committed to making our work open and transparent. This report will help us to 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.
is currently carrying out ‘generic’ preparatory work for a geological disposal facility (), as no sites have yet been identified. However, discussions are ongoing between and interested communities.
This report summarises the work that the Environment Agency and carried out to scrutinise ‘s work and our interactions with the public during 2020 to 2021. Coronavirus (COVID-19) impacted our work during this reporting period. We had no in-person meetings with – all engagement was online. Disruption and staff availability due to the effects of the pandemic were a challenge for all organisations.
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 several areas, but further work is still required. In particular, is not yet ready as an organisation to hold the necessary permits for site investigation. It has made progress this year, but further work is still required.
We advised that it needs to improve the visibility of its overall work programme for implementing geological disposal. We (Environment Agency) developed a tracking system to help us assess ‘s progress in meeting our regulatory requirements for geological disposal.
continued to improve towards becoming an organisation that meets our requirements to hold an environmental permit and site licence. However, with significant organisational change and growth underway, we are concerned with:
We consider though that there is enough time to address these matters before it applies for its first environmental permit and site licence.
We (Environment Agency) are satisfied with ‘s approach and progress towards documenting the claims, arguments and evidence underpinning its environmental safety case (through its Visualisation of System Information () system). But we are yet to determine the success of its implementation.
is updating its procedures for building confidence in its data and modelling to address our (Environment Agency) advice, but the matter is yet to be fully resolved.
has made progress in updating its list of radionuclides that need to be considered when assessing the environmental, operational and transport safety of geological disposal. We (Environment Agency) are confident that is taking our advice into account appropriately.
has made considerable progress to address our (Environment Agency) advice to demonstrate compliance with the requirements to protect groundwater from non-radioactive hazardous substances and non-hazardous pollutants in the inventory for geological disposal. But more work is required to fully address our concerns.
‘s proposed borehole sealing trials could potentially add value and could help build confidence, but we (Environment Agency) were critical of the level of ambition of the scope and conduct of the planned trial at Harwell. is addressing our concern in its plans.
We (Environment Agency) continue to provide advice and clarification to on several aspects of environmental permitting, and identify areas of uncertainty to address through our ongoing work
We offered our support to Copeland Working Group and Allerdale Working Group and attended introductory meetings with both working groups – we subsequently supported several Copeland Working Group engagement activities.
We (Environment Agency) contributed to forthcoming International Atomic Energy Agency () guidance on regulatory review and assessment of geological disposal.
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 , the most radioactive categories 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 geological disposal facility () 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. Scottish Government policy advocates near-site, near-surface management of , and 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 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 a licence, we are providing regulatory advice rather than making regulatory decisions.
COVID-19 impacted our work during the reporting period. We had no in-person meetings with – all engagement was online. Disruption and staff availability due to the effects of the pandemic were a challenge for all organisations. However, we reprioritised and adapted our programme accordingly and were able to progress most of our planned work.
We have no regulatory role in selecting potential sites for a . However, we will:
Our discussions with about its plans and proposals for working groups are helping us prepare to support community discussions. As part of these preparations, we produced a short animation on YouTube to explain the regulators’ role in geological disposal.
Regulating the geological disposal of radioactive waste
The animation complements other information we have developed to assist us in discussions with interested stakeholders, for example:
Following the formation of Copeland Working Group in November 2020 and Allerdale Working Group in January 2021, we wrote to the independent chairs of each working group outlining our regulatory roles and the processes that will help protect people and the environment now and in the future. We offered our impartial participation in working group events such as exhibitions, and to give access to our materials online. However, we stressed that, to maintain our regulatory independence, we would not be a formal member of either working group, and not be involved in decision-making.
Both working groups invited us to join them for introductory meetings where we explained our roles and responsibilities. We also supported online webinars organised by Copeland Working Group and produced an article on regulation for its newsletter.
We provided feedback independently on the Committee on Radioactive Waste Management’s (‘s) draft position paper on regulation to clarify our regulatory roles and highlight opportunities to improve the position paper.
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.
Engaging with on geological disposal at an early stage helps us 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.
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.
We will maintain and enhance our capabilities to meet our responsibilities in regulating geological disposal, and work is underway to do this.
We (Environment Agency) continued to develop our programme of work so that we will be ready when we need to regulate geological disposal. Our programme is in its early stages of development, but during this reporting period we have:
We (Environment Agency) participated in the ‘s meeting on guidance on preparing for and conducting regulatory reviews and assessments of geological disposal programmes. The aim of this project is to prepare a guidance document that helps regulators prepare for and conduct regulatory reviews and assessments of geological disposal programmes. We have advised on an early draft of the document and have drafted an annex on ‘Environment Agency preparations for geological disposal in England’. The project is focused on post-closure assessment, therefore this is an Environment Agency (not ) piece of work.
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 ( Requirement 4 [1]). We recognise that such a plan may also 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 (Environment Agency) advised that there is not a good overall view of its programme and that it should demonstrate all it needs to achieve, by when, in a way that we and others can understand. We (Environment Agency) consider this to be a high priority if wishes to efficiently and successfully progress geological disposal.
In response, hosted an initial programme planning workshop with regulators, which gave us a useful high-level overview of ‘s programme. We agreed that further meetings would be required to enable us to understand the detail and to then assess ‘s progress towards carrying out its programme.
At the workshop, we (Environment Agency) shared our developing tracker for assessing ‘s progress towards implementing geological disposal. We continued to develop the tool and are planning to trial it next year.
Following the workshop, we (Environment Agency) advised on the timescales for determining a radioactive substances activity permit for surface-based investigations and underground investigations . This included the following points.
The time it takes us to determine any permit depends on several factors, such as:
Because this is a major and complex project, the statutory timescales for permit determination are unlikely to apply. No set determination period applies to an application for the grant or transfer of a permit from a nuclear site licensee in relation to a radioactive substances activity.
We believe 18 months for determining an application for a radioactive substances activity permit for surface-based investigation is achievable in a best-case scenario. However, this will need efficient pre-application engagement and will remain subject to a wide range of uncertainties, including the degree of public interest. Further engagement with will help us judge whether this assumption is realistic. Given the inherent uncertainty at this point, we advised to include some contingency time should our determination exceed 18 months.
We consider an assumption of 18 months for determining the radioactive substances activity permit for underground investigation is unrealistic given the likely technical complexity of the submission, and the potential public interest. Presently, we cannot confirm exactly how long it will take to determine this application, however, further engagement will help improve these estimates.
The developer/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 [1], 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 capability 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 note that the is planning to bring and the Low Level Waste Repository () together into a Waste Division from January 2022. will remain a separate legal entity on that date, but it is likely that there will be changes in the future. We are engaging with to understand the impact of these changes on the future organisational capability and management system.
As a result of an inspection in 2014 we raised concerns over ‘s corporate structure and supply chain management (GDF_RI_009 – see Annex A). We asked to:
Since then, has integrated its quality function with its health, safety, security and environment () function to bring all associated aspects of assurance under a single Director for Health, Safety, Security, Environment and Quality (). It has demonstrated a clear commitment to ensuring that the function is adequately resourced and given suitable importance.
In the context of effective supply chain management, we advised to maintain an ‘Intelligent Customer’ capability to know what is required and to fully understand the need for a contractor’s services at any level of the supply chain. We noted, in particular, that should be capable of specifying requirements, supervising the work and technically reviewing the output before, during and after implementation. We pointed to relevant guidance . We consider has made sufficient progress since the original inspection in 2014 for us to close the regulatory issue ().
During the reporting period, we also closed an on ‘s workforce capability plan (GDF_RI_012 – see Annex A). We asked to develop and maintain a formal plan setting out how it intends to meet and maintain the necessary competences to ensure operational and environmental safety of its undertakings.
has demonstrated to us that it understands what is required at this stage of the project to determine and maintain the skills needed. This was demonstrated through:
Therefore, we closed the , but ‘s organisational development will continue to be a significant ongoing area of work for and regulatory focus.
We (Environment Agency) advised on its organisational development and capability to address potentially multiple matters of environmental compliance regarding its activities as part of the site investigation phase. We (Environment Agency) will continue to discuss these matters so that we:
We (Environment Agency) are committed to implementing a robust, proportionate approach to regulating the activities required for the site investigation phase.
We assessed the maturity of ‘s , organisational design, process and its cultural improvement programme. ‘s process is particularly important given that the organisation is currently going through a significant change programme.
recognises that it needs to update its systems and processes to deliver its programme. is embarking on an ‘Enhanced Management System’ project to ensure its management system is suitable and adequate to support the changes necessary for a rapidly expanding organisation. The work is led by ‘s Director and should be completed during 2022. We note that this is not without risk as planning for such transformation can put a strain on the leadership and existing workforce trying to absorb the growth. We advised to embed its revised process early in what is an ambitious change programme.
We are concerned with the apparent immaturity of ‘s culture improvement programme. However, given that does not anticipate applying for the first environmental permit until 2025 at the earliest, we consider there should be sufficient time for to develop both its and culture to the level we would expect of a permitted organisation.
We summarised our findings, together with recommendations, in a letter to . We will continue to consider ‘s transformation processes through our ongoing scrutiny work.
‘s applications to develop a must take full account of our environmental permitting requirements ( Section 5 [1]) 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 [1], Licensing Nuclear Installations). It should also 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 () . Prior to this, for geological disposal, the developer will need to apply to the Environment Agency for an environmental permit to undertake surface-based investigations such as drilling boreholes.
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.
We continue to liaise with to make sure that it understands the regulatory permissions it will need, and the associated application requirements, to implement geological disposal.
We (Environment Agency) held a series of meetings with to discuss ‘s progress towards establishing the activities, resources and capability needed to get the necessary permits and then to carry out site investigation.
Through the discussions, we (Environment Agency) identified areas of uncertainty in environmental permitting for site investigation which we need to consider further. We needed to clarify, as a matter of highest priority, the interpretation of intrusive investigations based on the definition in Schedule 23 of the Environmental Permitting Regulations. We have started work to address this matter.
We (Environment Agency) also provided written clarification to that an applicant (for example, ) cannot be a Competent Authority, as defined under Regulation 7 of The Conservation of Habitats and Species Regulations 2017.
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 .
issued its most recent generic disposal system safety case () in 2016. Since then, we have engaged with to assess progress against our advice and to help us understand its plans to develop the , and any site-specific submissions, in the future. intends to maintain the in parallel with any site-specific submissions until it is confident enough that the is no longer needed.
has prepared an integrated design and safety case roadmap, which will support more detailed roadmaps, including those for the operational environmental safety assessment () and the . 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 (Environment Agency) have commenced a review of roadmaps, which we will complete in the financial year 2021 to 2022.
currently does not plan to publish another set of documents. Instead, it will keep its generic safety case understanding up to date, supported by site-specific submissions, when required.
has also provided us with an interim response to GDF_RO_006 (Annex A) on building confidence in data and modelling. We are pleased that is taking our advice into account in updating its procedures. However, we will not close this RO until has fully developed its digital strategy and modelling strategy roadmap.
We raised both regulatory observations detailed in this section in response to findings from our review of the 2016 .
maintains a list of radionuclides that waste producers must report against. 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 (Environment Agency) have previously advised on its proposed approach for re-deriving the list of potentially recordable radionuclides. We discussed how it intends to address our advice and we are confident that is taking this into account appropriately. It will be some time before has fully implemented changes as a result of its review of recordable radionuclides and before waste producers can get data for any new data fields. Therefore, we accept that the approach will not be fully implemented until the 2025 UK Radioactive Waste Inventory (). We advised to keep informed of any potential implications from this work on assessment of new treatment or disposal routes for some .
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:
‘s 2010 generic did not address the need to protect groundwater resources and the public’s health from the non-radioactive substances in the inventory for disposal. We (Environment Agency) have engaged with regularly since then to explain our regulatory expectations and to understand ‘s work to address the matter.
We (Environment Agency and ) reviewed ‘s progress and developments relevant to demonstrating compliance with the requirements for groundwater protection. This included progress on related assessments. We agreed some topics and approaches on which wants more advice from us. We are currently considering ‘s report on further modelling of non-radioactive contaminants in a and will complete our assessment of it early in the financial year 2021 to 2022. At this time, we can report that we are pleased that is taking much of our advice into account to improve the robustness of its non-radiological pollutant assessment.
We (Environment Agency) also advised on the regulation of persistent organic pollutants and on the latest Joint Agency Groundwater Directive Advisory Group’s (JAGDAG) list of hazardous substances and non-hazardous pollutants.
‘s interim response to GDF_RI_013 (Annex A) on characterisation and assessment of the non-radioactive component of waste in the inventory for disposal has allowed us to close out actions which required to:
Three further actions on aimed at improving its understanding of the non-radioactive component of the inventory for disposal and engaging with us on groundwater protection requirements still need to be resolved. We will continue to engage with on these matters and the remains open.
We requested a briefing from on borehole disposal as a potential alternative concept for the disposal of . We concluded that significant challenges remain to be addressed before borehole disposal (BHD) could be considered a sufficiently mature technology for deployment in the UK for large portions of the inventory.
has no planned research on BHD. However, asked to review a report by the company Deep Isolation on the feasibility of its BHD concept for the UK. Regulators did not participate in this review, but we (Environment Agency):
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 [1]).
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.
‘s borehole sealing research and development programme includes the use of field trials to demonstrate that it can adequately seal site investigation boreholes before it commences drilling them. identified existing redundant boreholes on the Harwell Nuclear Licensed Site that were suitable for use in a field trial.
We (Environment Agency) reviewed ‘s proposals to seal the redundant boreholes and considered that, given the low potential for wastes to be generated or the environment impacted, the work did not require a specific environmental permit to be issued. However, we (Environment Agency) provided advice to on the scope of ‘s borehole sealing field trials, summarised as follows:
We (Environment Agency) and met to discuss and clarify the advice and recommendations. told us it had already acted on our letter, for example, by commissioning additional experimental work. It also said that it was considering extending the scope of the next field trials and that it will use the discussions to inform its response.
Planning permission for the sealing work at Harwell was granted in November and shortly afterwards work began on constructing the drilling pad. The drilling rig was deployed in January 2021. We (Environment Agency) visited the site to view the work whilst it was underway. During the work, some matters arose which needed to respond to, and which impacted on its work. These included the inadvertent release of a quantity of chemical used to produce a drilling fluid, which was contained in a lined bund within the drill pad and was removed without causing any impacts to the local environment. There were also challenges emplacing seal materials due to instability of the borehole wall following the removal of casing, which required additional seal material to be emplaced.
plans to complete the sealing activities early in the financial year 2021 to 2022 and to document the results after this, as part of its ongoing research, development and demonstration.
For work that supports the safety case, the developer or operator needs to make informed judgements about the quality of the science being applied. It also needs to make sure it carries out timely research and development to improve understanding.
The developer or 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 [1]).
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.
Through our engagement with we have maintained an overview of ‘s science and technology () plan as it has developed and heard in more detail about some of the work being carried out. has demonstrated that it has addressed much of our previous advice relating to its developing plan. provided a useful overview of its international collaboration with operators of underground research laboratories (URLs) in Europe. This gave us confidence that is appropriately leveraging and contributing to large multidisciplinary projects that will benefit its programme.
We (Environment Agency) provided further advice on the current plan . We concluded that it provides a good overview of the plans to carry out over the next decade and that it is a useful tool to help explain its planned to others. The plan should help focus its as it progresses from generic to site-specific research. We consider the plan is particularly useful in demonstrating those areas in which considers no further research is required during the generic phase. The document demonstrates good application of technical and scientific readiness levels ( and ). We noted that we would expect a progressive shift from to as research moves towards a more site-specific focus. supported these conclusions from the Environment Agency assessment. We also noted that the current plan is now aligned with ‘s programme tranches and was prepared using the tool.
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 [1]).
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 suitably packaged for handling and disposing of in a . We also expect to share good practice in waste packaging to avoid duplication of effort.
We are engaging with now to establish confidence that:
published its Low Heat Generating Waste (LHGW) Level 2 Waste Package Specifications (WPS) in November 2020. We discussed with its approach for developing the equivalent Level 2 WPSs for High Heat Generating Wastes (). We recognise that developing the specifications for can only progress so far because of uncertainties associated with site geology and disposal concepts, which can only be resolved once site selection decisions are made. ‘s main aim over the next few years is to produce a ‘requirements document for precursor products’ (rather than Level 2 WPSs). This will define the requirements to allow to be packaged and stored in a way that does not rule out future options for managing the waste.
We expect to be consulted as progresses this work.
Through our engagement with we agreed that decision-making about waste management should be based on a full lifecycle analysis of risk, but there are questions about how this lifecycle assessment of risk should be demonstrated. established a new group called the Disposability Risk Management () Group to ensure an appropriate balance between competing requirements which can influence the choice and design of a waste package across its lifecycle (from package loading at sites, through to onsite storage, transport to and operational and post-closure performance). We consider that this is a move in the right direction.
We consider the Group is a positive development, but uncertainty over governance and implementation needs to be resolved. We want to be more actively involved and informed of the work of this group and will achieve this through our engagement with the ‘s Integrated Waste Management Programme.
has made some changes to the package assurance processes, such as periodic review and records assessment, and is considering changes to its disposability assessment process. We discussed these with and how the work of the Group may affect the operation of ‘s disposability assessment process. We advised to produce a concise summary of changes to the disposability assessment process for wider dissemination (regulators and the industry).
We consider has satisfactorily engaged with industry to identify challenging waste streams with fissile content. has also identified how its methodology could be applied to ensure there’s consistency with the revised transport regulations and guidance, including where revisions may be necessary. has developed suitable programmes of work to address these matters. We have therefore closed the associated regulatory observation (GDF_RO_008 Annex A). However, we will monitor the adequacy of ‘s approach to setting package fissile limits during implementation through our ongoing engagement with waste producers and , and determine whether further actions are necessary.
Our continued interaction with is helping it to better understand the regulatory requirements and submissions it needs to make to get environmental permits and a nuclear site licence.
has made progress in several areas, such as its:
However, further work is still needed.
Our biggest challenge in the medium term will be to determine ‘s readiness as a competent organisation to hold the necessary permits for its initial investigations, in the face of significant change and with the establishment of ‘s Waste Division.
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.
