Introduction to VLLW Disposal Services
1
Introduction to VLLW Disposal
Services
Alex McCarthy, Waste Services Contract Manager
Objectives
1. Establishing the Service,
a. Establishing the service and managing nuclear liability
b. Our service summarised
2. Introduce the service and how it will work,
a. Key documents in the Waste Services Contract
b. VLLW Staged Project Delivery
3. Service development,
a. Near term service development
b. Medium / Long term service development
1a. Establishing the service and managing
nuclear liability
• Supply Framework established following a competitive tender exercise
• Customers access service through the Waste Services Contract (v3)
– Special Conditions manage the specific needs of this service
• Problem: How to manage the transfer of Nuclear Liability for SLCs
– Reduce burden on SLCs for managing VLLW disposed at other sites
– Provide clarity on who holds liability after waste disposed
– Reduce risk of multiple tenuous claims
• Our solution: LLWR acts as channelling entity
– Single SLC acting as the liable Party
– Amended Insurance Policy in place
– Service specific delivery process
1b. Our service summarised
• Delivered using the Waste Services Contract (v3)
• LLWR will accept the nuclear liability via relevant carriage,
and our approach reflects this
• The Waste Acceptance Procedure will apply with a
customised consignment stage
• Gated project development and delivery model
• Onsite witnessing required
2a. Key documents in the Waste Services
Contract
• Waste Acceptance Criteria
• Relating to the Waste Acceptance Procedure
– Compliance Dossier
– QP037 Quality Plans for project and consignment specific
– Waste Transfer Forms for each load
2a. Key documents in the Waste Services
Contract
• VLLW Waste Acceptance
Criteria
– An overview document
describing the VLLW Service
as a whole
– Common format
• Selected points from WAC
– Physical and Chemical
Properties
– Packaging and Transport
Requirements
– Radiological Properties
2a. VLLW WAC - Summary
Waste Treatment and Segregation (V1)
•
•
Waste should not be consigned for disposal if reasonably practicable measures
could be adopted to reduce the final volume requiring disposal.
Where waste is not selected for treatment, acceptance will require Suitable
Supporting Justification to be provided.
Approved Waste Packages and Transport Containers (V3)
•
•
Waste for Very Low Level Waste disposal may be consigned to LLW
Repository Ltd or the Service Suppliers in a wide range of Waste Packages
and Transport Containers.
The acceptable range of Waste Packages includes 210 litre Drums and Soft
Sided Packaging.
2a. VLLW WAC – Summary
Radioactivity Limits (V2)
•
Service Supplier specific criteria for Activity limits apply for Low Activity Low
Level Waste and Very Low Level Waste. Specific restrictions will be
determined through the Waste Enquiry Process. However, the following
criteria provide a general guide:
Table 1: Specific Activity Limits
Radionuclide
Specific Activity (MBq/t)
Acceptable
Likely to be
Accepted
All
<4
<200
Tritium
<40
<200
2a. Compliance Dossier
• It is the collected evidence gathered to demonstrate compliance with all
necessary rules, regulations, and permits in delivering the disposal
service
• Compliance Dossier divides all evidence and activities into six distinct
stages, which are,
1. Project Initiation
2. Service Definition
3. Consignment Preparation
4. Project Execution (Consignment and Disposition)
5. Audit Reports
6. Communications and Notifications
• Designed for our initial projects
2a. Quality Plan – QP037
• Comprises two sections,
– QP037A Covers project activities at Pelham House (Stage A, B, C,
E, and F)
– QP037B Covers individual load activities in the field (Stage D)
• Confirms that specified activities have been completed and
evidence has been gathered
• Structure mirrors the Compliance Dossier template
• Further guidance at www.llwrsite.com under Logistics
Services – VLLW / LA-LLW Transport Guidance Note PAA/GN06
2a. Waste Transfer Form
• Expected VLLW service characteristics,
–
–
–
–
Large volume, low activity
High number of consignments per project
Commonality between individual consignments
Potential for increased administrative burden
• Needed to evolve to maintain quality whilst reducing
paperwork
• Need to align with new Service Providers
• Small number of Over-arching WCI Forms (Parent)
• Numerous Waste Transfer Forms (Children)
2b. VLLW Staged Project Delivery
STAGE A
Project Initiation
WEN
BAT
EPR / RSA
WCH
Analyses
Upon approval proceed to Stage B
Waste Management Services
2b. VLLW Staged Project Delivery
STAGE B
Service Definition
WSQ
RA
Preacceptance
MSDS
Programme
Activity
assess
Consign
model
Upon approval proceed to Stage C
Waste Management Services
2b. VLLW Staged Project Delivery
STAGE C
Consignment Preparation
Compliant
with WAC
Verification
WAC
Packaging
Loading
Transport
/ b / g
assessed
Variations
Upon approval proceed to Stage D
Waste Management Services
2b. VLLW Staged Project Delivery
STAGE D
Project Execution
Consigning
document
Pre-loading
Loading
Waste
Transfer
form
Dispatch
procedure
Disposal
Acceptance
Ongoing
Monitoring
Evidence gathered during delivery
Waste Management Services
2b. VLLW Staged Project Delivery
• Stages that cover entire lifecycle
• Section E: Audit Reports
– Duty of Cares, Transport Audits, Audits required by Service
Provider or Customer
– Must be completed before progression to Stage D
• Section F: Communications and Notifications
– Regulatory / Authority notifications
– Stakeholder communications
– Check of whether new comms plan is required (determined
according to project)
– Must be completed after Stage A, but before Stage D
Waste Management Services
2b. VLLW Staged Project Delivery
•
•
LLWR witnessing schedule defined per project
The minimum requirements for witnessing are,
1. the packaging of waste for the first consignment
2. the loading of packages onto the conveyance for the first
consignment, and subsequently for any change to the WLP
3. the despatch monitoring of packages for first consignment
4. the transport consignment of waste for the first consignment
and any changes in radiological transport classification
5. Receipt of waste at landfill for the first consignment
6. Disposal of the first consignment
•
•
LLWR is observing not supervising
LLWR control through paperwork approvals
Waste Management Services
3a. Near Term Service Development
• Deliver the service safely and responsibly
• Live projects
– 1 project currently at execution stage (LLWR Service
Commissioning Project)
– Several projects at preparatory stage (Normal business)
• Open up all new disposal routes
• React to Customer Waste Enquiries
3b. Medium / Long Term Service Development
• Medium term (12 – 18 months)
– Analysis of Waste and Inventory Data – identify opportunities
– Early and targeted engagement at the decommissioning stage
• Long Term (2 – 5 years)
• Changes to the Paris and Brussels Conventions on Nuclear Third
Party Liability – 2011 Public Consultation
• Decoupling of Licensing and Liability
• Application to remove the need for licensing for LLW Disposal
sites
• Open up the market and remove LLWR from channelling role
Recap of Objectives
1. Establishing the Service,
a. Establishing the service and managing nuclear liability
b. Our service summarised
2. Introduce the service and how it will work,
a. Key documents in the Waste Services Contract
b. VLLW Project Delivery
3. Service development,
a. Near term service development
b. Medium / Long term service development
Key Points
• Contact your Service Delivery representative for more
information
• Access the service via the Waste Services Contract (if
required)
• Service will involve LLWR site witnessing and greater
planning than normal
• One key issue is stakeholder perception of risk
– Our priority is safe and responsible development and delivery of
the service
– Programme and price follow this
Questions?