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National Strategic BAT for Organic Low Level Radioactive Waste Final BAT Report January 2014

Doc No: 60X50008_Organic_LLW_National_BAT_Report_Final_Issue_12022014(AP).doc

Document control sheet BPP 04 F8

Version 16; October 2013

Project: LLWRP130318: National Strategic BAT for Organic Low Level Radioactive Waste

Client: LLWR Ltd. Project No: 60X50008

Document title: Final BAT Report

Ref. No: 60X50008_01

Originated by Checked by Reviewed by

ORIGINAL

NAME NAME NAME

A Paulley J Penfold, D Collier, I Coleman

R Hill

Approved by NAME As Project Manager I confirm that the

above document(s) have been subjected to Jacobs’ Check and Review procedure and that I approve them for issue

INITIALS R Hill

DATE 12-09-13 Document status:

First Draft

REVISION NAME NAME NAME

A Paulley R Hill R Hill



INITIALS R Hill

DATE 06-11-13 Document status

First full version (updated after workshop)


A Paulley A Dixon R Hill



INITIALS R Hill


Draft assessment report issued to Main Workshop


A Paulley A Dixon A Dixon



INITIALS C Johnson


Final BAT report incorporating stakeholder comments

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Executive Summary

Purpose of this document

Low Level Waste Repository Ltd (LLWR Ltd) is responsible for delivering the UK’s Low Level Waste (LLW) Strategy on behalf of the Nuclear Decommissioning Authority (the NDA). This is achieved via delivering the LLW National Waste Programme (the National Programme), through collaboration with all of the UK’s LLW producers. The National Programme therefore provides a strategic framework and associated guidance and direction to LLW management programmes for UK waste producers.

An important component of the National Programme is the identification of optimised national strategies for the management of key LLW categories. These strategies are informed by Best Available Technique (BAT) studies for specific waste types. This document reports the process and outcomes for a BAT study informing strategy for the UK’s organic low-level radioactive wastes (LLW; including very low-level wastes or VLLW).

The category of organic LLW is here assumed to consist of waste streams which mainly comprise organic solid wastes. The wastes of interest are often termed ‘process’ wastes and arise from day-to-day operations; such as paper, plastics and general process equipment. Wood and other putrescibles are also considered to fall within this category. In addition, organic LLW liquid wastes (e.g. oils, sludges etc) are also within scope.

Overview

The aim of this National BAT study is to identify a generic national ‘baseline’ BAT option to underpin strategy for the future management of the UK’s organic LLW.

It is not the purpose of this study to define the management option for these wastes at each site. Each site holds specific legal and regulatory responsibility for doing so. Instead, the National BAT study will identify preferred strategy options, justification and rationale that will provide a framework for site-specific studies.

The study will support the development of a consistent and optimised approach to the management of these wastes throughout the UK. It will also help identify opportunities for integration across the NDA’s portfolio including any gaps in service provision or other potential enabling strategies that could be of assistance in implementing and executing the BAT outcomes.

Process

The approach followed for this BAT study was designed to follow good practice as defined in relevant guidance documents. The main elements of BAT processes are identified as follows.

Scoping.

Options development and initial assessment.

Main assessment and workshop.

Integration.


The primary aim of Scoping in the BAT assessment process is for the project team and key stakeholders to develop a common level of understanding regarding the objectives and framing of the study, and the process for options generation and comparison. A scoping document was developed by the project team, and used as a basis for stakeholder engagement to test and update the process.

The Options development and initial assessment stage considered a detailed range of alternative treatment strategy options, on a ‘generic’ basis, i.e. considering the projected inventory for future arisings of organic LLW across the UK rather than on a site- or waste-stream specific basis. A detailed long-list of technology options for each stage of the waste management process was identified, and following appropriate screening, combined ‘strategy options’ were constructed.

The Main assessment and workshop phase involved the compilation of an information pack for the short-listed treatment strategy options, based on a technical appraisal and systematic evaluation against identified assessment attributes. This assessment was initially undertaken by experts within the project team, and then subject to detailed review through a stakeholder workshop. The stakeholder workshop also explored views on the relative importance of key assessment criteria relevant to differentiating strategy options (i.e. criteria ‘weighting’). The outcomes of the options assessment were then summarised and documented, and provided to the stakeholders for comment, prior to production of this final version of the report.

The development of strategy options looked to consider each of the main stages of any post-generation LLW treatment strategy, including: enabling technologies (such as sorting and segregation, characterisation, oil filtering etc); main treatment options (thermal treatments, supercompaction, chemical treatments, encapsulation, no treatment etc); and disposal options. Issues such as the location of treatment were also considered, although given the generic nature of the study, this was restricted to comparison of UK and non-UK options.

The assessment phase utilised a systematic multi-criteria decision-analysis (MCDA) approach. Consistent with the generic nature of the study, a qualitative, evidence-based options assessment approach was followed. The criteria list utilised was consistent with best-practice (grouped under Safety and Security; Environmental Impact; Technical Feasibility; Community Impacts; and Financial Cost headings). Detailed criteria were identified under each category so as to explore the range of issues of relevance in identifying differentiators between strategy options.

Integration is beyond the scope of this report. It reflects the process of turning the technical ‘generic’ BAT outcomes from this document into a UK-wide strategy. This will be undertaken by LLWR supported by a range of stakeholders including waste owners informed by this report. To maximise the value of the generic BAT study to the integration and final strategy development process, the process was designed to obtain and collate relevant documentation e.g. reflecting what barriers individual sites may face to implementing the generic BAT outcomes for their specific wastes.

Outcomes

A schematic showing the overall BAT process outcomes is provided in Figure E1. This summarises the generic BAT outcomes for treatment of organic LLW and VLLW wastes within the UK. It highlights different routes from waste generation to disposal, covering the key elements of the waste management strategy.


For each waste type, the ‘most preferred’ main treatment option that is applicable to those wastes is central to the generic BAT outcomes. In particular for wastes which are suitable for volume reduction by thermal processes, incineration, ideally through co-incineration, provides the basis of the generic BAT outcome.

The schematic also recognises that individual waste-stream or site-specific factors might mean that subsequent BAT studies identify an option other than the generic BAT option as being preferred for specific sites or wastes. A hierarchy of options is therefore presented in the schematic.

Key details of the generic BAT outcomes for each key element of the management strategies identified are summarised in Table E1. This includes highlighting the rationale for the hierarchy of main treatment options and indicating considerations when identifying site- and waste- specific BAT options from the hierarchy. The outcomes and rationale are based upon the more detailed statement of assessment outcomes presented in the main body of this document.

Next Steps

The BAT outcomes identified in this document, together with the associated rationale and identified wider considerations for integration into formal strategy, will be taken forward into a development process to be co-ordinated by LLWR Ltd. It is this process that is intended to lead to development of a formal National Strategy.


Figure E1: BAT Outcomes Summary Schematic

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Table E1: Generic BAT Outcomes for Each Waste Management Strategy Element

Element Generic BAT Outcomes

Enabling Technologies

Enabling technologies are a key feature of any organic LLW or VLLW waste management strategy. Examples include sorting, segregation, characterisation and low-force compaction, shredding and size reduction approaches. Optimisation of these elements of a management strategy is required to enable the efficient use of treatment technologies to achieve waste diversion, volume reduction or passivation. However, the choice of enabling approaches will depend on the specific nature of a waste stream and site arrangements. Therefore, no further guidance can be provided at the level of a national generic BAT.

Main Treatment Options

The outcomes of the assessment of main treatment technology options reflect a general preference for incineration at the generic level, with thermal treatment by co-incineration offering more advantages than batch incineration. This is followed by supercompaction as the next option in the hierarchy.

Other approaches including encapsulation of oils, chemical oxidation and stabilisation treatments and other thermal options may provide volume reduction or passivation options for some wastes that are otherwise difficult to treat. Such approaches may be particularly applicable to orphans that would otherwise not be disposable.

Disposal with no treatment (where acceptable given Waste Acceptance Criteria (WAC)) was identified as the option of lowest preference, unless a strong waste-stream specific BAT argument for disproportionality of costs can be made (e.g. for specific VLLW/low activity LLW (LALLW) wastes).

While a preference for incineration is the baseline assumption for incinerable wastes, a waste-stream specific study might identify a different option in the hierarchy outlined above as being BAT. This could reflect, for example; difficulties implementing necessary enabling technologies; difficulty in meeting treatment facility WAC; facility availability or capacity constraints, or another factor (see the main body of the document for more details).

Location of Treatment

Treatment within the UK is preferred in principle, consistent with considerations such as the Proximity Principle. However it is recognised that BAT cases can be made for treatment overseas in a range of circumstances e.g. limited treatment capacity in the UK. The choice of treatment facility within the UK is a site-specific consideration.

Location of Disposals

Disposal within the UK is assumed, consistent with LLW strategy and policy. The choice of disposal facility within the UK is a site-specific matter, although options are limited for LLW above LALLW and comprise only LLWR, or the Dounreay LLW facilities for DSRL and Vulcan wastes. Disposals of wastes beneath the LALLW limit will make use of VLLW/LALLW and exempt/out-of-scope facilities as far as practicable (i.e. wherever WAC allow). Aqueous and gaseous effluents will be managed consistent with the Permits of relevant treatment facilities.

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Contents

Terms and Definitions 3 1 Introduction 4 2 Objectives and Context 5

2.1 Objectives 5

2.2 Relationship with Waste Producer Strategies 6

2.3 Wastes Categories 6

2.4 Current Forecasts for Waste Arisings 7

2.5 Existing Organic LLW Management Arrangements 8 3 BAT Study Approach 12

3.1 Overview 12

3.2 Key Steps 12

3.3 Schedule 17 4 Technology Options Long-list and Screening 18

4.1 Overview 18

4.2 Screening criteria 19

4.3 Screening workshop 19

4.4 Screening outcomes and final long-list 20 5 Identification of Treatment Strategy Options 27

5.1 Context for Development of Treatment Strategy Options 27

5.2 Approach to the Development of Treatment Strategy Options 28

5.3 Applicability of Treatment Strategy Options to Key Waste Streams 31 6 Assessment of Treatment Strategy Options 35

6.1 Approach to the Assessment and the Main Project Workshop 35

6.2 ‘Location’ Element of Treatment Strategy Options 37

6.3 Criteria and ‘Key Questions’ 38

6.4 Assessment of Treatment Strategy Options 41 7 Overall BAT Process Outcomes 51

7.1 Summary of Main BAT Outcomes 51

7.2 Wider Inputs to the Integration Phase 53

7.3 Next Steps 55 8 References 56 Appendix A Pre-screening Long-list 57 Appendix B Waste Acceptance Criteria for Existing Facilities 60

B.1 Low Level Waste Repository 60

B.2 Very Low Level Waste Disposal 63

B.3 Supercompaction 65

B.4 Combustible Waste Treatment 66

B.5 Incineration Facilities 67 Appendix C Cost Norms for Existing LLWR Treatment Services 77 Appendix D Workshop Attendees and Agendas 79 Appendix E Details of the Treatment Strategy Options Assessment 82 Appendix F Weighting 92

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Terms and Definitions

Term Definition

ALARP As Low As Reasonably Practicable

BAT Best Available Techniques

Defra Department for Environment and Rural Affairs

DSRL Dounreay Site Restoration Limited

EDF Electricité de France

EARWG Environment Agencies Requirements Working Group

EA Environment Agency

H&S Health and Safety

HTI High Temperature Incinerator

HV-VLLW High Volume - Very Low Level radioactive Waste

IWS Integrated Waste Strategy

ILW Intermediate Level Waste

JWMP Joint Waste Management Plan

NWP Low Level Waste National Waste Programme

LA-LLW Lower Activity – Low Level radioactive Waste

LLW Low Level radioactive Waste

LLWR Low Level Waste Repository

MCDA Multi-Criteria Decision Analysis

NDA Nuclear Decommissioning Authority

NISDF Nuclear Industry – Safety Directors Forum

NNL National Nuclear Laboratory

NORM Naturally Occurring Radioactive Materials

NuLeaf Nuclear Legacy Advisory Forum

PCM Plutonium Contaminated Material

PVC Poly Vinyl Chloride

R&D Research and Development

RSRL Research Sites Restoration Limited

SEPA Scottish Environmental Protection Agency

UKRWI UK Radioactive Waste Inventory

VLLW Very Low Level radioactive Waste

WAC Waste Acceptance Criteria

WAMAC Waste Monitoring and Compaction Facility

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1 Introduction

Low Level Waste Repository Ltd (LLWR Ltd) is responsible for delivering the UK’s Low Level Waste (LLW) Strategy on behalf of the Nuclear Decommissioning Authority (the NDA). This is achieved via delivering the LLW National Waste Programme (the National Programme), through collaboration with all of the UK’s LLW producers.

The National Programme implements the National LLW Strategy which was approved in August 2010 by the UK Government and devolved administrations (NDA, 2010). The National Programme therefore provides a strategic framework and associated guidance and direction to LLW management programmes for UK waste producers.

An important component of the National Programme is the identification of optimised national strategies for the management of key LLW categories. This has involved the use of options assessments that are high-level and strategic in nature because they apply to a range of waste streams and different sites. Nevertheless, the assessments need to remain consistent with the application of Best Available Techniques (BAT) and associated regulatory requirements and best practice guidance.

LLWR maintains the national strategies for metal, VLLW (Very Low Level Waste) and organic (previously termed ‘combustible’) wastes on behalf of NDA. These are reviewed on a 5 year cycle. For organic wastes the 5 yearly review suggested that a full BAT study would be required, as described here. Such BAT studies have already been undertaken for metallic wastes (Stevens, 2011; Rossiter, 2006) and very low level wastes (VLLW) (Donohew et al., 2009). The present study concerns organic LLW (defined in more detail in Section 2) and is intended to provide a full stand-alone BAT assessment, thus updating the outcomes of a previous study (Abbott, 2008).

This document has been developed as a live document that was revised and amended as the project progresses. This final version represents the main BAT strategy report and presents the study outcomes and rationale.

A first draft of this document was provided as input to a ‘Scoping Workshop’ (see Section 3.2.1) involving stakeholders. That workshop and subsequent engagements provided fora whereby scoping considerations were presented and subject to additional input, query and challenge. Feedback from the engagements was used to inform the BAT process and the outcomes presented in this final version of the document. In addition, it takes into account stakeholder challenge and feedback on options and their assessment obtained at the main project workshop (see Sections 3.2.3 and 6).

The report is structured as follows.

Section 2: Overview of the objectives and scope of the study.

Section 3: The proposed assessment process.

Section 4: Presents outcomes from the options screening workshop.

Section 5: Presents strategy options for comparison formulated on the basis of the screening process.

Section 6: Records the outcomes of the assessment of strategy options against relevant criteria.

Section 7: Presents a statement of the final BAT strategy process outcomes, and associated key considerations for the next steps of the strategy formulation process.

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2 Objectives and Context

2.1 Objectives

The objective of this BAT study is to identify the preferred strategic option or options for the management of the UK’s organic LLW.

There are a number of fundamental considerations that apply to the identification, assessment and implementation of strategic options.

The wastes should be treated and disposed in a manner that protects the health and safety of the workforce and the public.

Consistent with regulatory expectations, impacts on the environment should be minimised, practicability considerations also being taken into account.

The principles represented in the Waste Management Hierarchy should be considered throughout.

As set out in the National LLW Strategy (NDA, 2010), maximisation of the capacity of the LLWR (i.e. minimisation of the volume of waste for disposal) is an important consideration.

For decommissioning wastes, NDA (2010) notes that it is often not possible to avoid LLW waste generation and where this applies, the focus is on the lower levels of the waste hierarchy, with re-use, re-cycling and volume reduction important considerations prior to final disposal.

It is the strategy of the NDA (as detailed in NDA, 2010) and also a requirement of the regulatory regime (for example, in site Environmental Permits) that a BAT approach should be used in the management and control of radioactive waste disposal. BAT provides a method for addressing the considerations presented above as well as wider factors.

As a strategic BAT study, the aim is to provide an overarching rationale for the optimised management of relevant wastes – the ‘strategy baseline’. This will identify the preferred ‘baseline option’ technique or techniques for the treatment of organic LLW, taking into account factors such as;

The overall inventory of organic LLW in the UK and its main features.

The nature and availability of treatment options, and combinations of options (e.g. enablers such as sorting, segregation and characterisation options, and the ‘main’ treatment options) that deliver benefits given the overall objectives.

Treatment option availability, waste acceptance criteria (WAC), transport etc.

It is not the purpose of this study to define the management option for these wastes at each site. Each site holds specific legal and regulatory responsibility for doing so. Instead, the National BAT study will identify preferred strategy options, justification and rationale that will provide a framework for site-specific studies. The baseline strategy BAT outcome and associated documentation will facilitate sites in subsequently selecting options that are consistent in broad terms with the BAT outcomes, whilst recognising that wider considerations (e.g. nature of wastes, availability of local treatment option providers) will mean that different sites will implement different strategies. These issues are already captured in individual site strategies, and the updated BAT will provide additional support to future site-specific

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issues. The current study therefore takes into account the spread of options that are currently being implemented by different sites, and are likely to be considered in the future.

The study will support the development of a consistent and optimised approach to the management of these wastes throughout the UK. It will also help identify opportunities for integration across the NDA’s portfolio including any gaps in service provision or other potential enabling strategies that could be of assistance in implementing and executing the BAT outcomes.

2.2 Relationship with Waste Producer Strategies

All existing waste producers have robust LLW management strategies that are captured, for example, in their Integrated Waste Strategy and Joint Waste Management Plans (or equivalents). As permit and/or licence holders, individual waste producers are responsible for demonstrating BAT and implementing the resulting strategies for their wastes.

The outcome of this strategic BAT study - the strategy baseline - will help identify the preferable overall approach to managing such wastes and identify in broad terms the key issues and considerations at a site level, without overlapping inappropriately with individual waste producer strategic decision-making. It will help provide justification for site-specific decisions consistent with the strategy, and indicate what will need to be demonstrated if sites are to adopt different approaches from the main national outcomes. It will thus provide a framework to help ensure consistency of producer-specific waste management decisions, and to support LLWR Ltd and NDA in identifying opportunities for integration and gaps in service provision.

The existing producer-specific studies therefore provide important information resources and input into the current strategic BAT study. In turn, the outcomes of this process will provide significant input into future iterations of producer-specific studies, by providing framing arguments and associated guidance and information.

2.3 Wastes Categories

The category of organic LLW is here assumed to consist of waste streams which mainly comprise organic solid wastes. The wastes of interest are often termed ‘process’ wastes and arise from day-to-day operations; such as paper, plastics and general process equipment. Wood and other putrescibles may also be considered to fall within this category.

Following the Scoping Workshop (see Section 3.2.1), it was clarified that organic VLLW and liquid wastes (e.g. oils) are also within the scope of the study. However wastes that are predominately composed of other materials (metal, soil and rubble, asbestos, etc) are not within the scope of this study. These wastes are the subject of separate studies including those noted in Section 0. The exception is where wastes streams that are currently declared as ‘mixed’ wastes might yield a substantial proportion of organic wastes if subject to a campaign of enhanced sorting and segregation. In such cases however, it is only the potential organic component that is within scope. The role of sorting and segregation in defining strategy options is discussed in Section 4.1.

This study concentrated on projections of future arisings from existing waste producers. However, the sensitivity of the options assessment to changes in assumptions, in particular considering the potential for wastes from new nuclear

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power stations, is considered at a high level. This is intended as a practical approach given the uncertainty about the nature and rate of arising of new build wastes, and as waste volumes are likely to be smaller than the main legacy site decommissioning waste streams (as discussed in, for example Section 4 of LLWR ( 2011)).

2.4 Current Forecasts for Waste Arisings

2.4.1 Low Level Waste

UK LLW producers provide estimates of future waste arisings in support of the collation of the UK National Radioactive Waste Inventory (NDA, 2010; NDA and DECC, 2011). These estimates are subject to the significant uncertainties inherent in decommissioning historic facilities, but represent the best projections on the basis of available data and provide useful context to the present study.

Future ‘raw’ untreated LLW arisings are projected to be of the order of 1.1 million cubic metres (Garrs, 2011). Of these raw arisings, projections indicate organic wastes may account for around 15% of this volume (LLWR, 2011).1 The main single waste producing organisation is likely to be Sellafield Ltd, with estimated future organic LLW arisings of around 120,000 cubic metres (Loudon, 2012). Other key producers will include Magnox Limited, Research Sites Restoration Limited (RSRL), and Dounreay Site Restoration Limited (DSRL). Other waste producers are likely to contribute smaller volumes of waste.

If directly disposed without treatment, these estimates would lead to a conditioned waste volume of the order of 250,000 cubic metres.2 This is significant in the context of disposal facility capacity; for example the projected future capacity of the LLWR to 2080 (Vault 14) is around 860,000 cubic metres (LLWR, 2011).

2.4.2 Very Low Level Waste

Forecast arisings of VLLW based on the 2010 UKRWI as reported in the 2010 LLW Strategic Review are 3.3 million cubic metres (Garrs, 2011). The Strategic Review provides a breakdown of VLLW arisings by material which is summarised in Table 1. The figures are provided in tonnes rather than volumetrically. The vast majority of the VLLW arisings are Soil / Rubble at 86% of total VLLW arisings. Organic VLLW materials, including plastic / rubber, soft organics and wood, total around 141,000 tonnes or 4% of total VLLW. As a rough approximation, 4% of total VLLW arisings would represent around 132,000 cubic metres (not allowing for differing material densities). In addition there is 41,000 tonnes of ‘unknown material’ which may include a proportion of organic material. A figure of 92,227 tonnes for ‘Other’ material is also reported in the Strategic Review (Garrs, 2011 - Figure 12, p24). The difference between figures for ‘unknown’ and ‘other’ material is noted as due to discrepancies in the UKRWI reporting procedure.

1 LLWR (2011) is based upon the 2007 National Inventory rather than the 2010 or forthcoming

2013 equivalent, but this estimate nevertheless provides an appropriate indicative estimate. 2 LLWR (2011) indicates that the grouting process typically leads to around 40% of final

disposal volumes being comprised of additional grout. A volume increase of a not dissimilar order is likely to also apply to DSRL’s disposal to the Dounreay LLW facilities.

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Table 1: Raw VLLW Material Arisings for the UK between 2010 and 2120 (extracted from Garrs, 2011 – Table 4, p12)

Material Arisings (tonnes) % of Total

Graphite 1,826 0.1%

Metals 294,025 8.5%

Plastic /Rubber 26,523 0.8%

Soft Organics 66,642 1.9%

Soil /Rubble 2,993,137 86.2%

Wood 48,016 1.4%

Unknown Material 41,086 1.2%

Total 3,471,255

2.5 Existing Organic LLW Management Arrangements

2.5.1 Overview

The main management options currently pursued by organic LLW producing organisations include:

Supercompaction followed by disposal of compacted pucks;

Incineration of combustible wastes; and

Direct disposal without treatment.

Sorting and segregation is an important up-front component of the management strategies pursued, in particular where supercompaction or incineration are utilised.

A brief description of the existing facilities utilised for organic LLW management is provided below. Whilst these approaches are currently being actively applied by UK LLW producers, the current study considered all plausible options afresh to ensure the process was sufficiently comprehensive and robust to provide confidence in the BAT outcome. The approach to identifying options is set out in Section 3.

2.5.2 Supercompaction

A high-force supercompactor authorised for radioactive waste treatment is located at the Waste Monitoring and Compaction (WAMAC) facility at Sellafield. The supercompaction process typically leads to a final puck volume that is about 30% of the raw waste volume.

To date, the vast majority of Sellafield Ltd’s organic ‘process’ LLW has been treated at WAMAC prior to disposal at LLWR. However, the recent Joint Waste Management Plan (Loudon and Ruddy, 2013) indicates a strategy to increasingly utilise incineration for the future treatment of organic LLW, recognising benefits including minimisation of disposal volume, diversion of volumes from disposal at LLWR, and cost.

Under the provisions of LLWR’s Supercompactable Waste Treatment Service, all UK organic waste producers have access to the treatment process provided by WAMAC.

Inutec also offer a supercompaction service via the LLWR framework, through Energy Solutions. The mobile supercompaction plant is designed to process standard 200

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litre waste drums. The routine scope of supply includes drum and supercompacted puck handling equipment, puck measuring equipment, activity-in-air monitoring equipment and onward product transport.

2.5.3 Incineration

A number of LLW producers make use of LLWR’s Combustible Waste Treatment Service, or make use of their own incinerators. Experience has shown that for relevant wastes, the volumes of final residues for disposal can be about 2.5% of the original raw waste volume. Most commercially available incinerators operate on a continuous basis with co-incineration of LLW (or VLLW) wastes with other (e.g. hazardous) wastes, with which they are mixed during the treatment process. The resulting residues are typically out-of-scope/exempt wastes (for LLW or VLLW), and VLLW or Low Activity – LLW3 (LALLW) (for LLW only), achieving 100% diversion of LLW from LLWR. Other incinerators (e.g. on-site small-scale incinerators and the Studsvik plant in Sweden) operate on a batch process with return of LLW (or VLLW, for treatment of VLLW wastes) residues and filters for disposal.

The LLW incinerators accessible to UK waste producers include the following (Garrs, 2011).

(a) Incinerators on NDA sites:

It should be noted that all the following incinerators will be taken out of use by early 2014 on the basis of the requirements of the EU Waste Incineration Directive following its transposition into UK Law.

Oldbury (oil burner);

Sizewell A;

Wylfa;

and potentially at Winfrith4.

(b) Incinerators on non-NDA sites:

Hinkley Point B (now mothballed);

Heysham (now mothballed);

Hartlepool;

Hunterston B (now mothballed);

Sizewell B (now mothballed);

and potentially at Capenhurst3.

(c) UK-based incinerators currently accessible via the Combustible Waste

Treatment Service:

Tradebe (Fawley, Hampshire; via Studsvik);

3 Lower Activity – Low Level Waste (LALLW) is defined as radioactive waste with a maximum concentration of 200 MBq (megabecquerels) per tonne of total activity that can be disposed of to specified landfill sites.

4 N.B. Capenhurst and Winfrith have incinerators that are currently mothballed.

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Veolia (Ellesmere Port, Cheshire via Abbot Nuclear Consulting); and

Grundon (Colnbrook, Berkshire; via Energy Solutions).

(d) Overseas incinerators currently accessible via the Combustible Waste

Treatment Service:5

Bear Creek (Oak Ridge, Tennessee, USA; via Energy Solutions); and

Studsvik AB at Nyköping (Sweden).

2.5.4 Other Organic LLW Treatment Facilities

There are a limited number of commercial scale alternative organic LLW treatment facilities currently available to UK LLW producers. Augean Plc has a thermal desorption facility licensed for acceptance of LLW located at Port Clarence, Middlesborough. The facility is designed to enable recovery of hydrocarbons from contaminated liquid organic wastes but is not currently available via the LLWR framework.

2.5.5 Disposal

Untreated organic LLW, or more typically treated LLW e.g. as supercompacted pucks is disposed to engineered facilities at either the LLWR or (specifically in the case of Dounreay and Vulcan wastes) will be disposed to the LLW facilities at Dounreay once they are operational.

At LLWR, wastes within half-height ISO containers are grouted primarily for void-filling purposes (if they are not already grouted prior to receipt) and disposed to concrete-lined vaults. As noted previously, the grouting and containerisation process adds significantly to the effective volume of wastes disposed. Whilst LLWR (2011) notes on average the added grout constitutes about 40% of the final waste volume within the containers, this varies across individual waste types.

For example, Paulley et al. (2009) and underpinning references noted that while LLW residues from batch incineration processes (ashes, etc) are typically a factor of 10 lower in volume than the equivalent treated waste volume arising from supercompaction (return of around 2-3% compared to 30% of the original raw waste volume) the incineration residues are usually incorporated in grout to stabilise them for disposal (although this is a recommendation rather than a direct requirement of the WAC). This process can lead to an increase in effective disposal volume for LLW batch processes that means that the final disposal volume can be closer to that for supercompacted pucks than may be immediately obvious.

Untreated LALLW and VLLW arising from treatment of LLW or VLLW, is disposed to a range of permitted disposal facilities. This has historically included LLWR, but increasingly facilities such as Clifton Marsh, Kings Cliffe and Lillyhall are being utilised.

5 Note that Socodei (Centraco, France) and Belgoprocess (Mol-Dressel, Belgium) facilities are

currently unavailable due to the absence of an inter-governmental agreement allowing their use.

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2.5.6 Waste Acceptance Criteria

A review of the relevant WAC for the facilities identified in Sections 2.5.2 to 2.5.5 has been conducted and is presented in Appendix B. The review contains details of the WAC for each facility including the type and form of materials accepted, specific activity limits, and unacceptable materials. The WAC review informs the options assessment process including consideration of potential limitations regarding the use of existing facilities.

Note that the Appendix review focusses on existing WAC; for LLWR, draft WAC likely to be implemented in the near future (LLWR, 2013) will limit the amount of untreated organic wastes per consignment in order to constrain the ‘total potential voidage’, taking into account the potential for organic degradation.

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3 BAT Study Approach

3.1 Overview

The process implemented for this study is based upon the application of a BAT process consistent with best practice. It is intended to be evidence-based and robust, and recognises the importance of engagement with the range of stakeholders who have an interest in this study. A further core consideration in the process design was the National Strategic nature of the study. Typically, site-specific BAT studies often consider a specific issue (e.g. the management of a particular waste stream) and specific options for dealing with it, which enables the assessment to efficiently draw on detailed specific information sets where available. For a National Strategic study, the performance of options is more likely to be evaluated in broad terms because a broad range of situations may need to be considered. This section outlines the approach proposed to deal with the more ‘generic’ requirements of the national study.

The interpretation of BAT (or, more broadly, optimisation) in the context of radioactive waste management has tended to adopt a broad remit, reflecting the desire to minimise, so far as is practicable, the release of radioactivity to the environment while also taking into account a wider range of factors, including cost-effectiveness, technological status and feasibility, operational safety, wider environmental considerations (such as energy and other resource use) and socio-economic factors (EA, 2010; EA and SEPA, 2004). This broad balance between potentially conflicting objectives is particularly relevant in the context of activities on nuclear licensed sites, where there is a legal requirement on site licensees to demonstrate that the risks associated with operations have been reduced to levels that are as low as reasonably practicable (ALARP).

The Environment Agency (EA) has recognised that the demonstration of optimisation may vary, but that in all cases the overall assessment process can be described simply as comprising two main steps:

Asking if there is anything further that can be done to reduce doses to people; and then

Implementing that, unless the associated detriments are grossly disproportionate to the benefits gained.

There are no definitive conventions for demonstrating gross disproportion in relation to achieving BAT. Indeed, the EA considers that “sound judgment and a clear, logical argument” (EA, 2010) can be sufficient to make a successful case.

3.2 Key Steps

The following section sets out the four key steps for this BAT study. It was designed to follow good practice for BAT assessment as defined in relevant guidance documents (EA, 2010; NISDF, 2010). The main elements are identified in Figure 1.

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Figure 1: Annotated Version of the Nuclear Industry Code of Practice BAT Process Diagram (after NISDF, 2010) Showing the Four Main Process Steps for This Study

3.2.1 Scoping

The primary aim of this initial step in the BAT assessment process was for the project team and key stakeholders to develop a common understanding regarding the objectives, scope and context of the study. It also provided an opportunity to define specific assumptions and constraints. This provided a basis for the initial identification and characterisation of options considered in the assessment.

The main activities associated with Scoping were therefore:

Develop the overall options appraisal programme, incorporating the definition of objectives, constraints, and assumptions.

Identify key stakeholders and develop a plan to ensure they are effectively engaged.

Agree an approach to identifying and characterising options, including appropriate recognition of ‘enabling’ technologies (e.g. sorting and segregation) as well as primary treatment technologies, leading to an initial long-list of technologies.

Agree a provisional set of screening criteria and constraints that can be used to short-list the options.

Agree a provisional set of assessment criteria. These will be the factors against which the performance of options is assessed, in order to provide a basis for comparing them.

Undertake a literature review with a view to describing the options in sufficient detail for the assessment, and to identify any data gaps that may need to be filled in advance of the main assessment phase.

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The discussions on scope in this document reflect the outcomes of the Scoping process. An early draft of the scoping version of this report was provided as an input to a scoping workshop involving an appropriate range of stakeholders. This scoping workshop presented and reviewed the scope of the study, and elicited feedback and challenge. The agreed process was then utilised as a basis for execution of the rest of the BAT study.6

3.2.2 Options Screening and Initial Assessment

In this phase, the initial long-list of options identified during scoping was further developed and subject to initial assessment. The aim of the long-list was to describe all technologies that could plausibly provide a part, on their own or in conjunction with others, of an option that could potentially deliver benefits for the management of the UK’s organic LLW against the objectives previously described. Hence ‘enabling technologies’ needed to be identified as well as the primary management technologies, and appropriately addressed.7

The initial long-list made use of a range of information from best-practice resources from within and outside the nuclear industry, including existing Site Waste Management Plans and Integrated Waste Strategies, BAT studies, UK LLW strategy documents and generic resources such as EARWG (2013).

The long-list then needed to be screened against appropriate criteria (Section 4.2) in order to remove options assessed as not being sufficiently credible to warrant more detailed assessment. A full audit trail of the screening process and decisions made was recorded.

A draft screening process was undertaken by the BAT project team (see Section 4). The outcomes were then presented, tested and finalised at the main project workshop (see Sections 3.2.3 and 6).

3.2.3 Main Assessment and Workshop

The short-list of options identified following the screening phase was then used to develop a set of detailed strategy options for the main BAT assessment (see Section 5). These options were subsequently assessed against the assessment criteria (see Section 6) using a multi-criteria decision-analysis (MCDA) methodology.

For the present BAT assessment, a qualitative, rather than fully quantitative, evaluation scheme was developed for use within the MCDA analysis. This was based upon experience of executing high-level strategic BAT studies, whereby the complexities of the decisions involved and the uncertainties that apply do not lend themselves to quantitative scoring. Consistent with other recent strategic BAT studies therefore, the focus was on identifying the key strengths and weaknesses of different options against each criterion, and understanding the differentiators between options they imply, and the key benefits and trade-offs. This approach has the advantage of ensuring the study focusses on the key issues, and does not get bogged down in uncertainties. It is also more flexible and can more easily accommodate option ‘hybrids’ (also known as combinations) of options.

6 The Agenda for and participants at the workshop are outlined in Appendix D. Several

stakeholders (e.g. the EA) were not able to attend the workshop and were consulted separately. 7 In this context, enabling techniques are activities that are required to render the waste stream

suitable for the primary management techniques. An example of an enabling technique would be sorting of a waste stream to segregate combustible material.

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The main draft outcomes of the MCDA process were recorded as a matrix of key strengths and weaknesses against assessment criteria, with a full audit trail recording the underpinning rationale.

The assessment needed to be conducted at a high level (national and strategic). However it also provided a key opportunity to collate views on the key factors that will drive site-specific preferences. Such questions include:

If this technique is the overall BAT outcome, what would stop an individual site adopting it?

What are the enablers that would be required to open up this route for specific sites?

The assessment outcomes need to provide a clear indication of the way in which site-specific adoption of the strategy will occur. This approach also helped test how robust each option is to variations in waste producer considerations and assumptions. The assessment process was therefore designed to record this ‘meta-data’ information alongside the National Strategic assessment outcomes. Conclusions are presented so as to ensure they do not prescribe a particular course of action, but indicate the strategic considerations and opportunities that are required to be addressed when reaching a site-specific decision.

This was achieved by:

Firstly undertaking the MCDA analysis by considering main management technologies for a range of wastes broadly representative of organic LLW within the national inventory.

Considering if any of the main differentiators/assessment outcomes would change if different or enhanced enabling technologies are applied (i.e. different or enhanced characterisation, sorting and segregation).

Reviewing the sensitivity of the assessment outcome to other site-specific considerations (e.g. transport distances from waste producers to treatment facilities).

Multi-criteria options assessments can be intensive and time consuming in workshops, and can reveal hitherto unappreciated data gaps. Therefore, the BAT project team undertook the main phase of assessment via workshops involving a range of technical specialists primarily drawn from the BAT project team. The draft outcomes of this assessment were then presented and reviewed in detail at the main assessment workshop.

The main assessment workshop8 involved a range of stakeholders and provided the main forum through which their input to the BAT process was gained. Participants were taken through the draft options assessment in detail, including the rationale for the draft outcomes. The workshop was designed to present an opportunity for challenge, clarification and update. The agreed outcomes and other feedback were then subsequently used by the BAT project team to update and finalise the options assessment and its outcomes.

In addition, stakeholder views on the ‘weighting’ of criteria were sought. The options assessment identified a number of differentiators between options, mapped to

8 The Agenda for and participants at the workshop are outlined in Appendix D. As for the

scoping workshop, a number of stakeholders invited but not able to attend the workshop were consulted separately.

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different criteria. Stakeholders were invited to provide feedback on the relative importance of the differentiators identified against different criteria. Different stakeholders may have different perspectives on the factors that are important, and so a simple process was designed to capture the range of views and to ensure they were recorded and appropriately considered within the development of the final BAT outcome. A key point of interest was to understand if the overall outcomes are sensitive to different views on the importance of criteria. Given that the main options assessment was qualitative, this weighting assessment was also qualitative, with a focus on logic and the underpinning rationale.

At a high-level, a preferred BAT option for each of the main waste categories within the scope of the study was agreed during the workshop. This represented the preferred technique or techniques that represent the UK baseline assumption for each category of LLW/VLLW organic wastes, with supporting information detailing key issues for waste producers within this generic framework, and associated gaps, challenges and opportunities. The further detail and clarification required to fully develop the BAT strategy outcome was identified at the workshop.

Subsequent to the workshop, the options assessment and corresponding draft of this BAT report were updated to take account of feedback received. Hence, subsequent sections reflect the workshop outcomes. Workshop participants and observers were given the chance to comment on this final draft. The report was then updated to represent the final formal outcome of this stage of the process.

3.2.4 Integration

As noted previously, the BAT process informs, rather than ‘makes’ decisions. Thus after a BAT recommendation is made, a process of integration is required to transpose the outcomes into waste producer and NDA planning and associated implementation and funding decisions. During this process, a range of wider issues and perspectives will be of relevance (e.g. annual budgets, opportunities for service provision, competition for funding, etc). It is only at the end of this process that the BAT outcomes will become formal NDA/waste producer strategy. Integration will also need to include guidance on the way that the National Strategic BAT can be used to support and assist the identification of a preferred management approach for organic wastes at site-level. It is only at this stage that a full strategy can be developed, taking into account the technical BAT outcome, in terms of a preferred management strategy option or options, identified in this document.

The planned process for the integration phase is outside the scope of the current project, but was nevertheless discussed by LLWR at the main assessment workshop. It is understood it will be implemented utilising established procedures and engagement processes defined within the National Programme.

3.2.5 Note on Stakeholder Engagement

Effective stakeholder engagement is an important requirement of the successful outcome of any BAT study. A range of stakeholders were identified for engagement in the process including:

Waste producers;

Waste management service providers (treatment and disposal);

Regulators;

Councils/planners;

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NDA.

Regulators were asked to provide ‘active observer’ roles, providing clarification on regulatory issues, views on process, and challenge to the assessment outcomes.

Given the range of waste producers involved, and the local/national regulators and council/planners with an interest in those producing sites, the stakeholder constituency is large. The approach for engaging stakeholders effectively without overburdening either stakeholder groups or the BAT process itself was therefore as follows.

A subset of stakeholders was invited to the scoping workshop, sufficient to provide confidence that the scope and proposed study approach was likely to be acceptable to the full range. Participants from all groups were invited to the main study workshop. Those who could not join the workshops but expressed an interest were informed by other means e.g. by being provided with the draft and final reports, with comments invited by email or phone. Comments on the draft report were received from a several stakeholders and have been considered during development of this final report.

3.3 Schedule

The schedule for the study is set out in Table 2.

Table 2: Study Schedule

Principal Steps Date

Scoping

Scoping Information Pack (incl. draft Scoping Report)

Scoping Workshop

Scoping Report (final)

August & September 2013

Options Development and Initial Assessment

Screening Information Pack

Internal Screening and Assessment Workshop

September & October 2013

Main Assessment and Workshop

Assessment Information Pack

Internal Assessment Workshop

Draft BAT Study Report

Main Workshop

Draft Final BAT Study Report

Final BAT Study Report

October 2013 – February 2014 (Main Workshop beginning December)

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4 Technology Options Long-list and Screening

4.1 Overview

Options screening is designed to consider whether each of the technology options are capable of providing a meaningful contribution to the overall objective of achieving safe management of organic LLW (including VLLW). The aim of the screening process was therefore to derive and review a long-list of potential technology options and then screen out options that are assessed as having significant disadvantages, such that it is not considered plausible that they could provide a meaningful role in the subsequent derivation of strategy options. The shortlist of remaining technology options were then taken forward and used in the development of an appropriate range of strategy options (Section 5).

Derivation of the pre-screening options long-list

The pre-screening long-list of technology options is set out in Appendix A. It was devised with a focus on ensuring a comprehensive list of potential technologies was developed. These technologies were selected on the basis that it is possible their application could deliver some benefit in terms of organic LLW management in the UK, noting the drivers presented in Section 2.1.

The list was made as comprehensive as practical, erring on the site of inclusion where there is doubt about the benefits that could be delivered, noting that the coarse screening process will then reduce the size of the list.

The pre-screening long-list has been drawn from a range of references, which are also set out in Appendix A. These were selected from a wide range of both generic and waste-category specific waste treatment information resources, both from within and outside the radioactive waste industry. These were utilised in order to derive a comprehensive long-list, which was not unduly biased by the knowledge of the compiler. Enabling technologies

An important class of technologies concerns ‘enabling technologies’. In particular, some approaches (incineration / supercompaction / organic destruction, for example) are often only possible if characterisation, sorting and segregation of ‘raw’ LLW (and VLLW) is implemented. Where such enablers are identified as important but do not represent the main element of a treatment strategy option for organic wastes at a generic level, or indeed are common across several options, their importance needs to be noted and an appropriate discussion recorded. The main assessment phase can then focus on the differentiators associated with the main management option.

On this basis it was agreed at the Scoping Workshop that the mode of application of enabling technologies is typically site- and waste-stream specific and so it is not appropriate to focus on them unduly at the strategic level. However, it is appropriate that a discussion of the importance of enablers will be a component of the statement of the final BAT outcome.

Therefore, during the long-list development such enabling approaches (e.g. sorting and segregation, and characterisation technologies) were identified and discussed separately from the ‘main’ treatment/management options. Broad categories of

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enabling technologies were listed to ensure the discussion was comprehensive, but they do not need to be screened or explicitly carried forward to the main assessment phase.

Dealing with treatment locations in the long-list of options

During the Scoping Workshop, it was agreed that differences between national and international facilities in strategy option development need to be recognised, but that within the UK, regional or local facilities should not be explicitly differentiated as those choices are also likely to be governed by site-specific decisions, which are beyond the scope of a strategic assessment.

The long-list of options therefore includes a discussion on location variants for different elements, focussing on the country within which facilities are based. These were subsequently used to help construct strategy options. A discussion on the role of location in defining and comparing strategy options is provided in Section 6.2.

4.2 Screening criteria

Options screening is designed to consider whether each of the technology options are capable of providing a meaningful contribution to the overall objective of achieving safe management of organic LLW and VLLW. On the basis of discussions at the Scoping Workshop, the screening criteria that were applied during the screening assessment are:

Is the technology capable of being legally implemented?

Is the technology expected to provide a tangible environmental benefit (e.g. reducing volumes for disposal)?

Is there confidence that potential service providers will be available to provide required treatment services within a reasonable timeframe?

Are there clear arguments that show the cost would be disproportionate to any benefits gained?

4.3 Screening workshop

The screening of the long-list against the criteria was undertaken at a project team workshop involving experts from LLWR Ltd and the Jacobs/Quintessa team, held at Jacobs’ offices in Westlakes, Cumbria on Thursday 17th October 2013.

Commentary on backfilling / grouting options

‘Backfilling’ here refers to the process of void-filling using appropriate inert material, such as the grouting processes used at LLWR. It was agreed during the screening workshop that consideration of backfilling / grouting options at LLWR or any other low-level waste disposal facility is out of the scope of the current assessment. This is because:

The use of grout for backfilling at a site such as LLWR is a general requirement for disposals and not a waste stream specific issue. It is not considered a specific treatment option in this study, in that although it might provide some chemical conditioning benefit relevant to post-closure performance (e.g. limiting mobility of released radionuclides within the

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repository due to high pH conditions), the main role of backfilling is to fill any voids in the disposal container arising after any treatment and waste emplacement in the container, rather than to ensure passivation or encapsulation.

Given backfilling / grouting is a general requirement it is not appropriate to evaluate waste stream specific deviations that would be inconsistent with general WAC. Any review of the backfilling (or indeed the containerisation approach) would need to be undertaken separately with a more general remit.

Void filling is not required for all facilities e.g. certain VLLW/LALLW disposals. That is, requirements for backfilling / grouting will in any case vary across the disposal concepts covered in this BAT study.

As backfilling / grouting requirements are general and apply to all waste streams, not just organic wastes, they extend beyond the restricted scope of this study. The assumption for this BAT process will consequently be that all disposals will comply with existing backfill requirements for relevant sites.

Note that backfilling is not necessarily the same as stabilisation (including encapsulation). Some of the treatment strategies would deliver enhanced waste-forms (e.g. vitrification) with or without backfilling of containers.

Commentary on decay storage

At the screening workshop, there was a discussion on the concept of decay storage. This concerns the possibility that LLW wastes could be de-classified to VLLW prior to disposal, or VLLW de-classified to out-of-scope/exempt. This would require storage for a period of time sufficient for radioactive decay to lead to an associated reduction in the average activity of the wastes.

It was noted at the screening workshop that long-term storage of LLW is not UK policy. In addition, the requirements for long-term storage of LLW would not be dissimilar to those for actual disposal and so the difference in lifetime costs may not be substantial. Moreover, after the workshop, a number of simple decay calculations were undertaken based upon the projected forward inventory of raw waste UK LLW arisings. These indicated that decay storage over several decades would lead to a notable reduction in average activities of certain waste streams. However, as the LLW classification covers a significant range of activities, this reduction will not lead to substantial changes in the total volume of raw wastes classified as LLW.

Decay storage was formally screened out after the workshop on the basis of inconsistency with national strategy (if long-term decay storage over a period of several decades or more is required), limited or no cost benefit per waste package, and the low waste volumes likely to be affected.

4.4 Screening outcomes and final long-list

The outcomes of the screening process, and the final long-list, was discussed and agreed at the Main Project Workshop. They are summarised in Table 3 to Table 5 below.

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Table 3: Main Treatment/Management Technology Options

Options Brief technology summary Screen

IN or

OUT?

Rationale and Notes

Compaction options:

Super-compaction

Supercompaction to enable significant volume reduction producing compacted pucks for disposal

IN Supercompaction is proven in achieving volume reduction benefits. After supercompaction it is unlikely that further treatment would be required or possible.

Disposed in half height containers potentially with soil infilling or other materials, and grouting.

Current practice – service already available.

Compaction (mechanical methods other than super-compaction)

Compaction using approaches other than high-force compaction, most likely in-drum compaction e.g. of shredded material. Post-screening, supporting approaches, such as vacuum packing, are also included in this category

IN Some volume reduction achieved. Usually prior to further treatment to maximise use of transport containers. Could potentially be used in isolation prior to disposal. Generally utilised for specific waste forms where there are reasons to prefer it to supercompaction. In-container compaction can be used prior to transport and subsequent further treatment including supercompaction.

Current practice – service already available.

No compaction with other treatment

As an alternative need to consider no processing of waste by compaction prior to onward treatment or disposals

IN Current practice. Must be included as other treatments – and even no treatment - are plausible. No treatment at all would require specific BAT assessments etc to be acceptable at LLWR.

Thermal treatment options:

Incineration

High-temperature incineration.

Produces off-gases / particulate / contaminated filters. Can drive off volatiles, other contaminants retained as ash.

Typically executed as a continuous process with LLW included with other wastes. This typically results in production of LALLW / VLLW or even

IN but see ration-ale / notes

Achieves volume reduction; is current practice; there are available facilities that are suitably permitted.

This is screened in, both in terms of co-incineration and batch incineration. However it should be noted, specifically, that co-incineration overseas is screened OUT, on the basis of radioactivity accountability – mixing with overseas wastes / lack of return is not consistent with legislation and policy. Batch processing oversees is however IN, as accountancy can be controlled and the LLW ash returned.

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IN or

OUT?

Rationale and Notes

out-of-scope ash, allowing disposal elsewhere than LLWR.

Batch-processes (e.g. using on-site incinerators) focussing on LLW only will most likely return LLW ash that will require stabilisation within grout prior to adding to a container - though this has not always been required (Studsvik, Sweden).

It should be noted that incineration facilities for hazardous waste can deal with hazardous constituents of the LLW streams.

Where waste incineration facilities are equipped with energy generation plant, the process can potentially be considered as a ‘recovery’ operation under the requirements of the revised Waste Framework Directive (Directive 2008/98/EC).

Pyrolysis / gasification

Heating in vacuum leading to off-gases and ceramic-like solid residue/slag, or similarly gasification heating in low oxygen environment. Examples include the THOR process (e.g. “Mini-Thor” – Sweden, or the full THOR plant in the USA)

IN Screened in but recognised most likely to provide benefit only for a sub-set of organic LLW. The cost of pyrolysis may be acceptable for specialist wastes.

Gasification is similarly screened in on the basis that it is a subclass of pyrolysis. However it was noted there is a lack of confidence in its potential to be legally implemented within appropriate timescales.

Plasma Targeted high-temperature treatment leading to off-gases and glass-like solid residue/slag

OUT This is not likely to be available over the next few years – there are no existing permitted facilities. It would be extremely costly for LLW compared to other options that would achieve the same result.

However this technology will be considered in terms of integration opportunities. It is important to keep a watching brief as, for example, Sellafield may produce a plasma solution for its heterogeneous Plutonium Contaminated Material (PCM) and asbestos waste streams. In which case organic LLW treatment may be useful as part of a combined solution with LLW as a feedstock to cover gaps in PCM availability/suitability.

Vitrification High-temperature treatment leading to off-gases and glass-like solid residue/slag

IN In-container Geomelt type processes are currently implemented in the US and being implemented in the UK. It achieves some volume reduction, and the resulting waste form provides long-term

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IN or

OUT?

Rationale and Notes

performance. It is plausible that the cost would be disproportionate to the benefit if applied in bulk, but is retained as it is possible ‘mobile’ plants could give benefits for specific problematic waste streams.

No thermal treatment

Dispose but treat by compaction etc. IN Must be included as other treatments – and even no treatment - are plausible.

Other treatment options:

Bio-degradation e.g. anaerobic digestion, composting

Anaerobic or aerobic breakdown of organics leading to off-gas generation and solid residue

OUT Not plausible that any significant fraction of organic LLW will be treated via this route within the next few years, even for smaller specific waste streams. The volume reduction benefits would be eroded by grouting.

This is a candidate to maintain as a watching brief for specific wastes.

Chemical organic destruction / oxidation

E.g, by dissolution with solvents or reaction to convert to off-gases and solid residue. Includes also acid washing, chemical oxidation and destruction, Arvia adsorption / electrochemical processes, molten salt oxidation etc. Several of these processes may involve evaporation which is also included, although on its own this would strictly be a physical process.

IN There are existing processes available in both the hazardous and radioactive waste inventories that are suitable for treating certain organic LLW waste streams. Includes electrochemical process for treating oils, and NNL and others provide technologies for chemical oxidation. Note this process gives rise to liquid effluent which can be treated via current effluent treatment process and / or grouting. NB returned sludge/sediment would probably not meet WAC for subsequent incineration. Molten salt oxidation, as practiced in US for example, and evaporation (although on its own a physical process) also included here. Note that a subset of these technologies could also be used as enablers.

Thermal desorption

Thermal desorption aims to recover hazardous organics from contaminated wastes, rendering the residue non-hazardous and suitable for landfill disposal; works by driving off volatiles (e.g. oils and solvents) for destruction or recovery

IN There are available processes in the UK, and could plausibly be used for lower-volume/orphan wastes. A key aim is to recover ‘clean’ oils etc.

Although a heat-driven process, it is explicitly not an incineration-based approach, and achieves a similar result to some of the chemical organic destruction/oxidation technology variants (in that it drives off volatile organics for separate treatment/destruction)

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IN or

OUT?

Rationale and Notes

and for simplicity is subsequently addressed under that category.

Micro-wave decomposition

Use of microwaves to achieve similar result to chemical destruction

OUT Screened out for ‘early’ consideration (i.e. next 5 years or so). Technology readiness level is too low. To date research shows theoretically possible and used in bench experiments.

This is a candidate to instead keep on the watch list for specialist waste forms as part of a pre-treatment option.

Cryogenic crushing

Supercooling to facilitate crushing via a hammer mill for overall volume reduction (e.g. use of liquid nitrogen and hammers / compactors)

OUT Benefit is marginal or zero for organic LLW, especially compared to other compaction approaches, and cost would be disproportionate.

Plastic melting Primarily for size reduction reasons OUT No obvious benefit compared to a range of other simpler void/volume reduction options (compaction, supercompaction, thermal). Volatile release an issue. No strong prospect of availability of permitted treatment facilities.

Shredding / Chipping / Cutting

Size reduction by cutting into small pieces, often followed by compaction (e.g. low-force in-drum compaction)

IN This is very close to being an enabler only. Retained on the basis that it could be used for certain wastes for volume reduction. Most likely applied prior to sentencing, but could be a later precursor to compaction. Already current practice. Unlikely to feature prominently in a combined strategic option.

Steam reforming

Waste converted into gas by high-temperature steam processes that break down long-chain hydrocarbons, producing off-gases and other products, potentially together with solid residue/slag (in which case process essentially pyrolysis)

OUT Unlikely service providers will supply permitted facilities suitable for organic LLW in a reasonable timeframe. Secondary wastes would need to be dealt with. Other treatment options are already available that achieve equivalent results.

Stabilisation (including encap-sulation)

Chemical stabilisation of oils and other liquid containing wastes, encapsulation/grouting (e.g. in drums), oil solvent solidification.

IN Stabilisation of oils involves producing a solid or semi-solid product by physico-chemical treatment of oils.

This is already current practice for relevant waste streams.

No other Dispose but treat by compaction etc. IN Must be included as other treatments – and even no treatment -

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IN or

OUT?

Rationale and Notes

treatment are plausible.

Storage options:

Decay storage Decay storage assumes a significant fraction of the inventory of a waste-stream is short-lived, such that the decay storage allows diversion (e.g. LLW to VLLW)

OUT Unlikely that LLW to VLLW or VLLW to free release for non-trivial volumes could be achieved within plausible timescales. Inconsistent with national strategy, and limited cost benefit even for those wastes affected (see main text).

Long-term storage

Here long-term safe storage rather than final disposal is pursued.

OUT Not consistent with policy for LLW/VLLW, or indeed licence condition 32 as leads to accumulation of waste. Note for some wastes there are no current management solutions. However this is not an ‘intentional’ approach to orphan wastes.

Final disposal options:

Disposal to existing LLW facilities

i.e. LLWR/Dounreay IN This is current practice for relevant wastes.

Disposal to existing LALLW/ VLLW facilities

e.g. those UK facilities currently permitted to accept VLLW (Clifton Marsh/ Kings Cliffe / Lillyhall)

IN This is current practice for relevant wastes.

Disposal to new LLW facilities

Most likely surface or near-surface, elsewhere than LLWR/Dounreay

OUT Current policy is for maximum usage of existing assets (i.e. LLWR; note Dounreay LLW facilities will only accept Dounreay LLW). This is taken as the baseline assumption here. In any case if LLWR disposal volume is exhausted, that would be an industry-wide rather than waste category specific issue. In that case the preferred approach to organic wastes would arguably simply be transposed to any new arrangements. Therefore, this does not need to be considered explicitly.

Disposal to new LALLW / VLLW facilities

Most likely new permitted UK landfill facilities

IN It is plausible that new UK options for disposal of LALLW / VLLW may become available within the next few years, subject to licensing consent considerations.

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Table 4: Location Option Variants

Options Screen IN or

OUT? Rationale and Notes

Treatment in the UK9 IN Location variants that apply to any of the above treatment options. Plausible and (for relevant wastes/technologies) current practice.

Treatment overseas IN

Disposal in the UK IN Current practice.

Disposal overseas OUT Inconsistent with current legislation and policy.

Table 5: Enabling Technology Options

Options Notes

Segregation

All retained as generic enabling technologies (see main text).

Generally standard components of existing enabling approaches.

Note that ‘decontamination’ (e.g. washing to remove surface contamination / dust from PVC) was moved here at the screening stage.

Characterisation

Sorting

Decontamination

Monitoring

Filtration (oils)

9 NB treatment could be via existing permitted facilities, new permitted facilities, or ‘hazardous’

waste facilities upgraded to achieve permitting to accept radioactive waste

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5 Identification of Treatment Strategy Options

5.1 Context for Development of Treatment Strategy Options

As noted in Section 1 and elsewhere in this document, a full strategy for the management of UK’s organic LLW wastes will include a wide range of elements. These include:

1. Consideration of enabling and main treatment technologies;

2. Mapping preferred enabling/treatment technologies to different waste streams;

3. Disposal/discharge options;

4. Locations (UK, overseas);

5. Timeframes (next 5 years, longer term);

6. Identifying modifiers (e.g. management strategy “x” is preferred for waste-stream “y” unless site-specific concerns such as “z” are relevant, in which case…);

7. Opportunities (treatment technology availability in next 5 years and longer term, etc);

8. Risk management (flexibility of the strategy; response to plausible what-if scenarios e.g. unexpected treatment facility unavailability).

Such aspects have been addressed as far as possible within the ‘technical’ assessment component of the BAT study. In particular, the aspects of the above list numbered 1 to 4 have been considered through the development of ‘treatment strategy options’ reflecting the whole waste management life-cycle. Information was also gathered during the technical assessment phase to support consideration of the elements numbered 5 to 8 in the list. Subsequently, the full range will need to be considered within the ‘integration’ phase.

For the current assessment phase, the following approach has been adopted.

Development and assessment of technology-based treatment strategy options (enablers, main treatment technologies, disposal options).

Dealing with location variants using logical argument.

Identifying timeframes of interest to the main assessment and to the wider strategy.

Collating information on the remaining factors through the assessment process for input into the final BAT outcome and integration phase.

The collation of strategy relevant meta-data during the assessment (see Sections 6 and 7) is an important component of the process. It is not within the remit of this study to overlap with or pre-judge site-specific studies (as discussed elsewhere); however the process outcomes provide a framework and starting point for those studies. Potential blockers and modifiers that may need to be considered in site specific studies need to be recognised when formulating National Strategic options. Therefore it was important to ask questions such as the following during the assessment:

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How significant would transport considerations be for a typical site and typical waste stream?

To what extent is the viability of this option dependent on enhancing the application of enabling technologies such as sorting and segregation?

What would prevent site “x” from taking up technology “y”?

The remainder of this section details the approach to developing technology-based treatment strategy options, assessment of which informs the relevant key component of the overall strategy. The other elements highlighted above were addressed in subsequent phases of work. However, they are relevant to note here, as the options should be defined in a way that assists in addressing these wider elements during the assessment and the later integration stages.

5.2 Approach to the Development of Treatment Strategy Options

The technology option short-list that was retained following screening provides the basic building blocks for the treatment strategy options. This is where ‘technologies’ are combined into options appropriate to be assessed as ‘techniques’ reflecting appropriate strategic themes. The intention is that each option should reflect a plausible management strategy for the wastes, and be sufficiently detailed and useful to provide the basis of a framework for subsequent site-specific decisions, including informing LLWR/NDA strategy development and implementation.

Together, the treatment strategy options need to:

Capture all the main elements of life-cycle waste management options defined as being within scope.

Appropriately represent all the ‘building block’ technologies taken forward after screening.

Allow sufficient simplification / grouping to make the assessment tractable.

Rationale for Proposed Approach

A diagram summarising the approach to constructing treatment strategy options for organic LLW is provided in Figure 2.

The structure of the diagram is explained below.

Each ‘column’ within the diagram represents a key stage in the waste management life-cycle.

Different life-cycle strategy options are represented by different ways of progressing from left to right through the diagram, following the directions of the arrows.

Key simplifying assumptions are set out below.

‘Enablers’ are not part of the options comparison, following agreement at the Scoping Stage that their importance needs to be recognised but judgements on their utility are site-specific matters. Similarly backfilling / grouting is a disposal-facility specific requirement (where applicable), consideration of options for which is beyond the scope of this study.

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The issue of use of UK vs. overseas facilities can be decoupled from the main ‘technical’ assessment of options. This discussion (see Section 6) can be overlaid on the outcomes of the technical assessment.

All management options that produce solid wastes should be capable of delivering wastes that will meet the disposal WAC of ‘standard’ LLW, LALLW/VLLW or out-of-scope/exempt waste facilities. It would be reasonable to assume that all VLLW activity wastes will go to LALLW/VLLW facilities to reduce pressure on LLWR. Then the choice between new and existing facilities will depend upon their availability and WAC. At the BAT level it is unlikely that a differentiator will be observed as both options will meet common regulatory/permitting requirements. Therefore these aspects are not reflected in the options for comparison. However, a discussion on the importance of ensuring there is sufficient capacity overall will be an important aspect of the final strategy to be produced following the integration phase.

A number of management options involve the generation of aqueous and/or gaseous discharges. This includes approaches whereby the main waste products are disposed/discharged via these routes. Therefore these discharge routes need to be recognised in the overall treatment strategies.

Main treatment process options

Given the above arguments that aspects such as enablers and location can be decoupled from the main treatment options, then the strategy treatment options can be grouped according to those primary treatment methods. These are summarised below.

Thermal treatment via co-treatment processes: that is, incineration by addition of radiological wastes to hazardous/conventional wastes within a continuously operating incinerator, leading to out-of-scope/exempt waste or LALLW/VLLW for disposal (for LLW; out-of-scope/exempt only for VLLW) and energy generation at certain facilities).

Thermal treatment via batch processes, leading to LLW residues for disposal (for LLW treatment; similarly no change in category for VLLW).

- Primarily batch incineration.

- Batch pyrolysis and vitrification also to be assessed, noting that it is likely they will primarily apply to specific waste streams e.g. orphans.

Low-force compaction, possibly including shredding and vacuum packing but most typically in-drum compaction (with shredding/vacuum packing then essentially reduced to enablers). Note that the compacted wastes may be directly sentenced for disposal, in which case low-force compaction can be seen as the main treatment process; if however it is used to enable efficient transport etc prior to another treatment process, it becomes an ‘enabler’ and is dealt with as part of the enabling technology group discussed above.

Supercompaction prior to disposal of pucks.

Chemical organic destruction/oxidation covering a range of technologies to break down applicable wastes.

Stabilisation including chemical stabilisation and encapsulation in grout, applicable to sludges, liquids and oils.

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No treatment is the ‘null’ option, and is practiced at present, although LLWR WAC require a strong justification for disposal of LLW wastes that could be volume reduced via treatment but are not.

Approach to options for VLLW

The same set of treatment options is also relevant to the VLLW subset of wastes, noting the reduced options for disposal. The equivalent diagram to that for LLW is provided as Figure 3.

Summary of Strategy Options

On the basis of the above discussions and the alternative strategy options represented by Figure 2, the following LLW strategy options can be identified for assessment.

LLW sentencing > enabling approaches > co-treatment thermal >disposal as out-of-scope/exempt material or VLLW with backfilling/containerisation10 as required.

LLW sentencing > enabling approaches > batch thermal > disposal as LLW with backfilling/containerisation as required.

LLW sentencing > enabling approaches > compaction > disposal as LLW with backfilling/containerisation as required.

LLW sentencing > enabling approaches > supercompaction > disposal as LLW with backfilling/containerisation as required.

LLW sentencing > enabling approaches > chemical organic destruction/oxidation > disposal as LLW with backfilling/containerisation as required, or disposal via permitted aqueous/gaseous discharge.

LLW sentencing > enabling approaches > (sludges/flocs/liquids/oil) stabilisation > disposal as LLW with backfilling/containerisation as required.

LLW sentencing > enabling approaches > no treatment > disposal as LLW with backfilling/containerisation as required.

For VLLW, (Figure 3), this is modified to:

VLLW sentencing > enabling approaches > co-treatment thermal > disposal as out-of-scope/exempt material.

VLLW sentencing > enabling approaches > batch thermal > disposal as LALLW/VLLW with backfilling/containerisation as required.

VLLW sentencing > enabling approaches > compaction > disposal as LALLW/VLLW with backfilling/containerisation as required.

VLLW sentencing > enabling approaches > supercompaction > disposal as LALLW/VLLW with backfilling/containerisation as required.

VLLW sentencing > enabling approaches > chemical organic destruction/oxidation > disposal as LALLW/VLLW with

10

Note that consistent with terminology used elsewhere in this document, ‘backfilling’ refers to void filling with inert material such as grout. The practice of co-disposal of wastes of different geometries to maximise packaging efficiency and reduce voidage is not considered explicitly here, as it is considered to be part of the normal disposal step.

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backfilling/containerisation as required, or disposal via permitted aqueous/gaseous discharge.

VLLW sentencing > enabling approaches > (sludges/flocs/liquids/oil) stabilisation > disposal as LALLW/VLLW with backfilling/containerisation as required.

VLLW sentencing > enabling approaches > no treatment > disposal as LALLW/VLLW with backfilling/containerisation as required.

5.3 Applicability of Treatment Strategy Options to Key Waste Streams

As discussed elsewhere, a range of LLW and VLLW organic waste streams fall within the remit of the present BAT study. It is instructive to note (a) which of these waste streams are the most significant in terms of raw-waste volume and (b) which treatment approaches are applicable to each waste stream.

A high-level analysis of projections for future organic waste arisings and WAC limits and requirements for treatment options has therefore been undertaken. This is not intended to be exhaustive but as a resource to guide thinking. The analysis is summarised in Table 6.

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Figure 2: Treatment Strategy Options Summary Schematic for LLW

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Figure 3: Treatment Strategy Options Summary Schematic for VLLW

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Table 6: Waste Stream Treatment Option Matrix

Key:

= Treatment is suitable = Treatment may be suitable but with potential restrictions = Treatment is unsuitable

Treatment

Thermal Compaction Chemical / organic

destruction Stabilisation

Direct Disposal Material Incineration Pyrolysis

In-Situ Vitrification

Shredding Vacuum packing

Low force compaction

Super-compaction

Cellulosics 2.1% total LLW 48% of organics

a

b c

Wood Approx. 30% of

cellulosics

d e

Plastics 1% total LLW

23% of organics

e f

Rubbers 0.3% total LLW

6% organics

g

Sludges, flocs & liquids

0.2% total LLW 5% organics

Oils Unknown % of sludges, flocs &

liquids

Other Organicsh 0.8% total LLW 17% organics

Notes:

a - Requires materials that contain glass formers, such as soil, ash or sediment to establish and propagate a melt. b - Not suitable for material with high moisture content c - Putrescible materials limited to <1% (for LLWR) d – Achieves limited benefit e – Wood / hard plastics not readily compactible f - Process is typically slow for plastics g – Rubbers can cause issues with compaction / re-assertion if part of a mixed waste stream h - Other Organics are materials that have not been specified by producers, thought to include a combination of the solid organic materials above and likely to include an element of orphan waste material.

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6 Assessment of Treatment Strategy Options

6.1 Approach to the Assessment and the Main Project Workshop

This section contains an assessment of the treatment strategy options (further details can be found in Appendix E). As described in Section 3, the assessment was undertaken through a three-stage process, outlined below.

Preparation of a Draft Assessment

A draft assessment of options against criteria for each waste stream was undertaken through an expert workshop held at Pelham House, Calder Bridge on 8th November 2013, involving members of the LLWR/Jacobs/Quintessa ‘internal’ project team. Participants also included waste treatment experts from outside the core project team to introduce an element of independent challenge. This was then further developed by off-line additions, refinement and review, prior to the full review and update at the main project workshop.

The draft assessment was prepared as it is time-consuming to undertake such a process in a workshop involving many participants. The intention was to present the analysis in full, including the screening and treatment strategy option formulation process discussed in previous sections, at the main project workshop. The aim was to:

Present the logic and rationale for the options formulation and assessment process.

Invite detailed discussion, comment and feedback.

Elicit views on the relative importance of differentiators against relevant criteria of interest.

Provide the basis for an updated final assessment on the basis of feedback.

Discuss the key elements of the final strategy.

Consistent with scoping discussions (see Section 3) the draft assessment involved an evidence-based assessment of options against criteria. A qualitative approach to options evaluation was undertaken.

As described in Section 5 and elsewhere, there are a number of waste streams within the broader organic waste category with differing characteristics. Both LLW and VLLW waste classes are within scope and while similar waste treatments will be available, the balance of arguments (e.g. reflecting the value of avoiding LLW disposal volumes, as contrasted with VLLW volumes) will differ. The draft assessment sought to recognise these key differences, without making the assessment too complex.

Therefore, the approach was taken to first select the highest volume single LLW waste stream (cellulosics) and undertake a full assessment for that waste stream. Then, the assessors were asked to answer the following:

For each of the assessment criteria, how does the assessment change for VLLW?

For each of the other waste streams, how does the assessment change?

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This process was systematic, in that every combination of waste stream and criteria was considered, but having a ‘baseline’ established ensured the process was efficient. Also, many of the differentiators are common across several waste streams.

The draft ‘baseline’ assessment therefore followed the following steps.

Review of the options for assessment.

Review of key assumptions (including those highlighted in Sections 3 and 5).

The ‘location’ element of treatment options (see Section 6.2).

Review of assessment criteria, and ‘key questions’ intended to help guide the assessment (see Section 6.3).

Identification of a waste stream for the ‘baseline’ assessment (cellulosics).

Assessment of the strengths and weaknesses (and therefore differentiators) of each treatment option against each criterion. Development of an assessment matrix capturing the assessment.

Modification of the assessment matrix to identify changes for VLLW, rather than LLW, cellulosic wastes.

Systematic review of the baseline assessment matrix to identify what changes for other wastes.

Identification of key themes.

Review at the Main Project Workshop

The draft assessment was not intended to derive a formal proposed preferred option or options, or indeed derivation of a proposed BAT strategy. This was a matter for consideration and agreement by stakeholders, informed by the detailed assessment following its review at the main workshop. It was considered important that the ‘internal’ assessment did not pre-judge the outcome; its role was rather to help collate and assess the evidence required to inform that judgement.

The draft assessment was therefore reviewed in detail at the main project workshop, and used to inform discussions on the BAT outcome. The workshop involved a range of stakeholders including regulatory observers, industry technology and disposal facility representatives, and waste generators. Parties who expressed an interest but who were not able to attend the workshop date were contacted separately to seek their input, and were provided with relevant project documents (including this report) for comment and feedback. Details of the Agenda and participants are set out in Appendix D.

The main project workshop process can be summarised as follows.

Review of scoping outcomes, including approach to dealing with location options.

Recap, review, modify and agree screening outcomes.

Review treatment strategy options.

Detailed review of the strategy options assessment against criteria for each waste stream, and for both LLW and VLLW.

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Discussion on the key arguments informing the identification of BAT for each waste stream. Identification of the key differentiators against each criterion and their relative importance in establishing BAT (i.e. high-level, qualitative criteria ‘swing-weighting’). Consistency review between the two sets of arguments.

Agreement of ‘preferred’ treatment strategy option for each waste stream on a generic basis.

Discussion on modifiers (i.e. blockers and enablers that might prevent or indeed help sites take up the generic ‘preferred’ strategy).

Identification of the main features of a BAT outcome recognising the modifiers.

Documentation and Final Review

The final options assessment, and the statement on the main features of the BAT outcome agreed at the workshop, were then formally finalised and captured in the remainder of this document. The following sections therefore record the detail of the finalised assessment and the BAT outcomes.

This document has been supplied to and tested with workshop participants to provide a further opportunity for feedback and to ensure the key outcomes are robust.

6.2 ‘Location’ Element of Treatment Strategy Options

As discussed in Sections 2 and 3, sub-UK location options for treatment strategy components (e.g. use of facilities close to waste producers vs. central facilities) are not within the scope of the options comparison. Such aspects merit detailed discussion in the final strategy to be derived during the integration phase, and in any business cases for future developments that will be informed by the current assessment. However, in terms of a ‘technical’ BAT comparison of options such considerations involve factors that are too site-specific to be meaningfully addressed. The issue of whether treatment should be undertaken within the UK or overseas is, however, not site-specific and needs to be addressed.

In addition to meeting general regulatory requirements for transport, any treatment strategy involving the use of overseas treatment facilities would need to satisfy the requirements of the UK Transfrontier Shipment of Radioactive Waste and Spent Fuel Regulations, 2008. Moreover, when deciding whether to authorise the export of radioactive waste for treatment overseas, the EA and SEPA are obliged to take into account Government policy (e.g. DEFRA et al, 2007) as well as the requirements of the regulations.

The current UK policy on export of low-level radioactive wastes establishes guidelines that offer somewhat more flexibility than those previously in place (Cmd 2919, 1995). Specific considerations relating to UK policy include:

A presumption towards solutions local to the point of arising, based on the proximity principle and minimisation of unnecessary waste transports.

A presumption towards self-sufficiency in waste management. That is to say, a case for transfrontier shipment requires demonstration that effective treatment of the wastes concerned cannot practicably be undertaken in the

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UK. If a suitable UK option is available, the default regulatory position will tend to be that export is unnecessary.

A presumption in favour of ‘early solutions’. If UK options are unlikely to be capable of delivering final disposition of the wastes for many years, while overseas solutions are readily available, this could represent a significant consideration in relation to determining the outcome of an options assessment.

Typically, cases that have been made for overseas treatment of organic LLW in recent years have been based on an options analysis demonstrating that alternative UK solutions are not available, or would not reasonably be implementable, on timescales consistent with those desired. Nevertheless, it is recognised that arguments for the export/transport of radioactive waste can be contentious and regulators are very aware that their decisions are potentially subject to challenge, either under appeal or by judicial review. There is a considerable political dimension to such issues, particularly given that there are concerns among host communities regarding the associated ‘export’ of employment opportunities. Moreover, NDA is under a statutory obligation (under the terms of its establishment) to consider socio-economic factors in its decision making.

It is instructive to note that the BAT study making the case for the export of the Berkeley power station heat exchangers (Magnox, 2011) was based on the goal of waste minimisation, coupled with a defined objective to achieve accelerated clearance of the site rather than deferring treatment or constructing dedicated local facilities for size reduction and possible treatment. In this case, Studsvik was considered the preferred (overseas) option because of the readiness with which, once the wastes had left the Berkeley site, trans-shipments between different transport modes (and across boundaries between political jurisdictions) would be minimised.

For the present assessment, the following BAT outcomes are proposed on the topic of location of treatment.

Wastes will typically be treated within the UK wherever there is a capability to do so on suitable timeframes.

Specific wastes may be treated overseas but a strong waste-stream specific case will need to be made based upon lack of UK capability (e.g. for timely volume reduction) or disproportionality (e.g. in cost of the UK solution).

As the justification for overseas treatment will nearly always be made on a site- or waste-stream specific basis, it is beyond the scope of the present BAT study to analyse sub-UK location options in more detail.

6.3 Criteria and ‘Key Questions’

On the basis of past experience and good practice, a criteria set was identified that falls within the following ‘standard’ broad criteria headings:

Safety and Security

Environmental Impact

Technical Feasibility

Community Impacts

Financial Cost

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The detailed criteria set was reviewed and agreed at the Scoping Workshop, including the addition or modification of several criteria from that originally proposed to the workshop.

Prior to the assessment phase, a number of ‘key questions’ were formulated. These summarise key elements of each criteria group that need to be addressed in assessing differentiators between options, and provided a starting point for discussions:

Safety and Security

- Will the option help minimise health and safety risks associated with waste management – will it offer any advantages / disadvantages in terms of ease / cost of ensuring operations are ALARP?


- Does the option help deliver key elements of the Waste Management Hierarchy? Does it lead to volume reduction and/or de-classification whilst delivering a project with the required longevity? Are there secondary effects e.g. secondary wastes and/or significant resource use?


- Is the option consistent with national and NDA strategies? Is there confidence in timely availability of treatment routes, longevity of supply, and the proven performance of those routes? Is the option robust to uncertainties in the nature and rate of arisings of wastes?

Community Impacts

- Will the option have advantages or disadvantages for relevant communities, e.g. jobs, local spends or other impacts?

Financial Cost

- Will the option involve significant up-front and/or lifetime costs?

The full detailed criteria set is as follows. Note that in the assessment, the full list was used as an ‘aide memoire’ with differentiators being captured by criteria group, in the interests of minimising complexity of the assessment matrix.

Safety and Security

(1) Acceptable rate of achieving passive control. The capacity to deliver a safe passive wasteform for existing wastes within acceptable timescales.

(2) Avoidance of implementation hazards. The extent to which there may be significant health and safety hazards associated with their implementation. Whilst the requirement to demonstrate ALARP in implementation will always be respected, a treatment alternative presenting lower operational hazards to the workforce will (all other things being equal) tend be preferred over one that involves more hazardous working conditions.

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(3) Minimising off-site impact (humans, other flora and fauna, other environmental receptors). The objective of minimising the environmental footprint, taking account of secondary wastes and effluent discharges.

(4) Conditioned waste volume. The projected extent to which they are considered capable of minimising the volume of the final conditioned wasteform for disposal.

(5) Confidence in product. The confidence that can be placed in achieving a passively safe, stable final wasteform, capable of meeting waste acceptance criteria for disposal.

(6) Resource use. The extent of life-cycle energy or material costs associated with the option.


(7) Consistency with existing NDA and other waste producer strategies. Does the option support or conflict with existing strategies? Would it open up commercial opportunities for sites that would be of value in future strategy development?

(8) Strategy flexibility. Does the option rely upon a particular facility, or the creation of a new facility? Is it only a short-term solution, or does it have strong potential for the longer-term?

(9) Operability and maintainability. The extent to which technology options are considered simple to operate and maintain, and will reliably process the waste volumes involved.

(10) Confidence in process viability. The confidence that can be placed in the technical maturity of the process and its capability to deliver a satisfactory final waste product. This takes into account the nature of the wastes involved as well as process operating experience with similar types of waste materials and radioactivity content, in the UK and overseas.

(11) Availability of treatment routes. Considers the current (or potential future) availability of plant to process wastes, and whether they are likely to offer sufficient throughput capacity.

(12) Robustness to uncertainties and variation in feed characteristics. The capability of an option to accommodate conceivable variations in feed characteristics (i.e. the extent to which they will be able to deal with a wide range of waste streams within the overall organic LLW / VLLW category) with minimal rejection or breakdown.

(13) Footprint. The area of land required by a facility and its services will be particularly relevant if it is to be placed within an existing licensed site.

(14) Planning processes. Comparison with the relevant Development Plan Documents, which comprise the Regional Spatial Strategy, the Minerals & Waste Development Framework and the district Local Development Frameworks (or other similar local arrangements). They are also assessed for conformity with national policies, such as those set out in National Policy Statements, Planning Policy Statements and Minerals Planning Guidance.

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Community Impacts

(15) Socio-economic implications. Management strategies may potentially be differentiated in terms of their implications for the support for local supply chains (on a site and supplier basis, for example), the number and skill level of local jobs associated with operating and maintaining treatment plants, etc.

Financial Cost

(16) Affordability. Short and medium term costs associated with any necessary construction, commissioning and operation.

(17) Lifetime costs. Lifetime cost relates not only to the cost of implementing the waste treatment process, but also the costs of final disposal. Hence options that minimise the volume of conditioned waste requiring disposal may also be more favourable from a lifetime cost perspective.

Note on approach to evaluating costs in the assessment

It was noted from the outset that cost considerations will be important for the assessment. However, it was recognised that as this is a generic national BAT, cost comparisons will necessarily be made at a very high-level. Experience of costs associated with running existing facilities will be relevant, but detailed breakdowns will not be helpful given uncertainties in likely future waste stream characteristics. Rather, order of magnitude costs to establish any key differentiators will be the focus of attention.

On this basis, as part of the assessment, a high level consideration of costs for existing treatment options was made on the basis of information sources including the existing cost norms for LLWR treatment services as summarised in Appendix C. These and other high-level cost factors were used to establish differentiators in the options evaluation detailed in Appendix E and summarised below in Section 6.4.

During the assessment process, participants made clear that more detailed cost evaluations will be required for each subsequent site- or waste-stream specific BAT process to be undertaken within the generic framework established by the present study. From the standpoint of consistency in strategy formulation and evaluation, and in order to help assist the identification of cross-site integration opportunities, it will be advantageous if costs are assessed on a broadly consistent basis during future studies. This is a matter for potential consideration during the integration phase (see Section 7.2).

6.4 Assessment of Treatment Strategy Options

6.4.1 Assessment against Criteria

The finalised options/criteria assessment matrices for each of the key waste streams are provided in Appendix E. The reader is referred to these matrices for full details of the assessments made, including comparative strengths and weaknesses of each option for each waste stream, and underpinning rationale. Together they cover:

Cellulosics (the ‘baseline’ assessment)

Wood (as a waste stream considered separately from ‘soft’ cellulosics, and thus not included in the above category);

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Plastics;

Rubbers;

Non-oil sludges, flocculants and liquids; and

Oils.

At the main project workshop, it was identified that there are strong similarities between: Non-wood and wood cellulosics; plastics and rubbers; and oils, sludges, flocculants and liquids. There are key differences but the assessment matrices were simplified by combining waste stream assessments into these three categories, and clearly identifying those differences in the matrices.

Note that in the projected national organic LLW waste inventory as reflected in Table 6, a non-trivial volume is allocated as ‘others’. This reflects a range of wastes for which one or more of the following may apply:

the form is not yet known (e.g. pending decommissioning);

wastes are suspected as potential orphans that may need to be treated separately from the six categories listed above;

wastes are small-volume waste streams of differing physical and chemical characteristics that will require site-specific analyses;

involve small volume mixed waste streams.

This category was not assessed independently as it is considered that either (a) upon investigation their physical forms will be resolved and will be identified as falling broadly into the above categories, (b) any orphans may in any case be covered by the above physical categories, and/or (c) will require waste-stream specific studies that are beyond the level of detail of the scope of this study, but will nevertheless be beneficially informed by it.

6.4.2 Assessment Outcomes

In what follows, the key outcomes of the assessment of treatment strategy options against criteria for each of the waste streams are summarised. The summary starts with cellulosics, as it is the highest-volume waste stream and the outcomes provide a baseline for the assessment of the others.

Table 7 provides an overview of the main outcomes of the assessment of options for treating cellulosics, drawing on the detailed assessment presented in Appendix E.

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Table 7: Main Assessment Outcomes for Cellulosics

Option Summary

No treatment prior to disposal

For LLW cellulosics, there are some advantages to undertaking no treatment prior to disposal, in that this is a broadly flexible and simple approach, with no need to build any new plant. However this has the substantial disadvantage that it does not achieve diversion or volume reduction from LLWR. This has several associated implications including;

Inconsistency with UK LLW policy and strategy (which strongly favour diversion from and/or minimisation of volumes disposed to LLWR);

Enhancing the risk that a second LLWR facility would be required, which would have substantial impacts; and

Cost - in that disposal volume at LLWR is expensive.

Thermal treatment

Thermal treatment however would significantly reduce volumes for disposal, consistent with UK LLW policy and strategy. There is a particular advantage for co-incineration with hazardous/other wastes that even the volume-reduced wastes that are returned from LLW treatment (i.e. ashes etc) would be VLLW/LALLW, or in most cases out of scope / exempt waste (with return of exempt wastes only for VLLW treatment). The change in classification of returned wastes is due to mixing with non-radioactive hazardous waste during the treatment process and the release of some activity as aqueous/gaseous discharges. The advantages over no-treatment are also significant for batch processes, although the small volumes of waste returned would remain LLW (or VLLW; that is, no change in classification). The produced ashes are at least in part passivated and thus will have enhanced longevity in the disposal system compared to non-treated organics as degradable or volatile aspects of the wastes will have been treated, and relevant hazardous waste components will also be addressed.

The main trade-offs include:

The potential for aqueous and liquid discharges that would need to be managed within permitting arrangements (which would ensure the environmental / human health impacts are very limited), including the potential operation and design challenges associated with the management of off-gases.

If a new plant is required, that could be a significant undertaking with footprint and resource issues, however for co-incineration processes in particular there is notable capacity in the market, and a number of batch incineration alternatives are also currently available.

Intrinsic health and safety risks associated with high temperature processes, but these are routinely managed at such incinerators. On the other hand, batch processes involving many re-starts would be more likely to experience problems or risks, as most occur on start-up and shut-down.

Resource use may be an issue for batch processes (that is, sufficient supply of calorific material is required) but this is much less of an issue for co-incineration processes, as this is dealt with through control of feedstock.

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Option Summary

That said, this is a flexible process that is robust to the nature and timeframes of future arisings, and is commercially proven. Especially for co-incineration, the fact that there is already a business driver for hazardous waste incineration and a range of available suppliers implies a low risk associated with technology availability. For batch incineration, it was noted that there will be a significant reduction in the UK capability in 2014 as several site incinerators will be taken out of operation; whilst some capacity will remain, this is likely to be an important consideration in site-specific studies. Batch processes provided by overseas suppliers will remain available.

There may be a requirement for a greater number of transports than for some options involving on-site treatment e.g. low-force compaction, however the final volume reduction will compensate.

Pyrolysis and in-situ vitrification processes would offer less benefit than incineration (which could be applied to a large majority of cellulosic wastes) in terms of aspects including flexibility to variations in waste types and volumes and (for vitrification) overall volume reduction and would cost substantially more.

Low-force compaction and other volume reducing techniques

Low-force compaction including in-drum compaction and other mechanical approaches that fall short of supercompaction would offer benefits over no treatment in terms of volume reduction, although the advantages would be much less marked than for thermal treatment via incineration. As a main treatment option, its modest volume reduction is achieved via portable, relatively flexible approaches (at least, for non re-assertable wastes) with minimum infrastructure, and can be applied at the point of arising, reducing the number of transports. However there is no waste passivation achieved. The cost benefit over no treatment is notable, but much more limited compared to other options.

It was agreed that in most cases, low-force compaction is likely to be an enabler to reduce the number of transport operations prior to a main treatment option. On this basis it was considered that in the statement of BAT outcomes it should be considered an enabler only. This assessment was extended to all waste streams.

High-force compaction

High-force compaction achieves substantially higher levels of volume reduction than low-force compaction. This is more comparable with thermal treatments, although the reduction is of the order of 80%, rather than the 95 – 100% diversion from LLWR achievable by thermal. On the other hand, supercompaction avoids the production of off-gases and aqueous and gaseous discharges. It is proven, available, and relatively flexible, if not to the same extent as co-incineration. A detracting point is that it does not achieve the same level of long-term waste passivation as thermal processes do. There may be a requirement for a greater number of transports than for some options e.g. low-force compaction at the point of arising, however the final volume reduction will compensate (although not as much as for thermal processes).

Chemical organic destruction / oxidation and related technologies

Chemical organic destruction/oxidation may or may not achieve volume reduction depending on the process. The main issue here is that none of the processes available are mature in terms of demonstrable application to bulk organic wastes in the UK and significant R&D would be required. That said, a range of approaches are proven on the smaller scale (including thermal desorption, which also has the potential to be used for

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Option Summary

bulk wastes where applicable), or on the bulk scale but overseas (e.g. molten salt oxidation).

It is also not clear whether all of the approaches are flexible and robust to variations, for example, in waste properties and timeframes for arising. Some will produce a stabilised output, but other techniques may not. In any case, there will be resource use associated with the required chemicals, and maintaining temperature where required by relevant processes. There will be associated health and safety risks, especially given these are likely to be batch processes, but these will be manageable through conventional everyday precautions and procedures. Any new plant build for bulk wastes will be expensive and involve footprint/resource issues. Given these issues, the main application area may be for orphans not easily treatable by the standard available approaches.

Stabilisation Not applicable to this class of wastes.

These main outcomes can be drawn together to present a condensed summary of the conclusions of the assessment for cellulosic wastes. This summary is presented in Table 8, together with a similar condensed summary for other waste forms. To avoid too much repetition, the conclusions for the other waste forms are presented in terms of the differences from the cellulosics ‘baseline’ assessment. These conclusions are again based upon the detailed assessment tables presented in Appendix E.

Table 8: Overall Summary of Outcomes of the Options Assessment for All Wastes

Waste Type Summary of Assessment

Cellulosics Overall the most notable advantages were related to volume reduction and in particular thermal processes, and to a lesser extent supercompaction. There are disadvantages to thermal processes, such as off-gas management requirements and aqueous and gaseous discharge production during the treatment process. That said, in the longer term wastes disposed without the conditioning benefit of thermal processes will in any case degrade, leading to discharges over much longer timeframes that will be mitigated by engineering and chemical conditioning within a disposal facility; however this process will occur over a prolonged period. Co incineration is also most likely to offer the lowest-cost lifecycle option once disposal costs are factored in. Supercompaction also offers volume saving and cost benefits, but not to the same extent. However, there are reduced discharge impacts. Finally chemical processes may offer particular benefits for orphans.

For VLLW/LALLW similar arguments apply, however, while minimisation of volume for disposal remains a key element of the Waste Management Hierarchy and treatment will offer benefits from the perspectives of national policy and strategy, the benefits are not as marked as for LLW. This is due to the wider portfolio of facilities available for disposal, and the absence of the equivalent significant impacts that would be associated with the need for any new LLW facility, and associated risks.

Reflecting this, the cost arguments for VLLW/LALLW significantly change from those for LLW. Treating VLLW/LALLW wastes prior to disposal is likely to present significantly higher proportional costs than for disposal alone. Therefore, whilst the principle was accepted by workshop

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participants that volume reduction/diversion is important, there is enhanced scope for making cost/benefit BAT arguments on the basis of disproportionality.

Such disproportionality arguments will need to be made on a case-by-case basis as volume reduction benefits and costs will depend very strongly on the nature and volumes of wastes. It is not therefore either possible or appropriate to provide strong guidance on this aspect of the BAT outcome at a generic level. It is relevant however to observe that some waste producing organisations represented at the main workshop stated they have decided to volume reduce VLLW/LALLW prior to disposal where the costs were less than double that for disposal alone, but the same organisations have not treated such wastes prior to disposal where the cost difference is significantly higher than this.

Wood Arguments are very similar for wood as for cellulosics. In addition, it is notable that intact wood content is a restrictive factor for in-drum compaction (if not shredded) and that the overall volume reduction of woods in compaction (and even supercompaction) may not be as significant as for other more easily compressible wastes. This also has implications for relative cost-savings. It is also notable that available chemical treatment approaches are not optimised for wood.

Plastics Again, the arguments for plastics are not dissimilar to those for cellulosics. It is notable, in addition, that plastics can produce organic contaminants on degradation (e.g. in-situ). Chemical treatment technologies may help mitigate against this, although (as for other waste types) such treatments may instead lead to releases via permitted aqueous or gaseous discharges in the shorter-term. Also, some hard plastics are not suitable for in-drum compaction. As for wood, it also notable that some of the available chemical treatment approaches would be very slow to degrade some plastics (with the potential exception of molten salt oxidation).

Rubbers Arguments here are broadly similar to those for cellulosics, wood and plastics; the most notable advantages were related to volume reduction and in particular thermal processes. There is a need to avoid re-assertion in low-force compaction, and to a lesser extent in supercompaction. Rubbers are again slow to degrade through most available chemical treatment options.

Sludges, Flocculants and Liquids

Compaction options are not applicable to this class of wastes. WAC limits also mean that bulk disposals of liquid-based wastes are not possible, for example at LLWR. In addition, any options that involve continued storage of sludges and other such wastes prior to eventual treatment/disposal will be problematic due to the difficulties of maintaining storage facilities for such wastes over prolonged periods. Chemical stabilisation is a plausible alternative for a limited subset of these wastes (noting oils are covered separately), but will not achieve any volume reduction, and the technology is comparatively unproven for bulk treatment in the UK. A more mature alternative for a subset of these wastes concerns stabilisation via encapsulation within a cement matrix.

Given these are all organic sludges and liquids, thermal treatment is likely to offer the most significant volume reduction and flexibility in terms of robustness to variations in waste characteristics. For bulk wastes, the arguments on co-incineration and batch incineration recorded for other waste categories above therefore broadly apply (favouring co-incineration

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of relevant wastes). It is also possible that, as for chemical stabilisation, other batch thermal processes (e.g. pyrolysis) might offer benefits for a subset of wastes otherwise difficult to treat.

Oils The balance of the assessment outcomes for oils was very similar as for sludges, flocculants and liquids. Compaction options are not applicable to oils. WAC limits also mean that bulk disposals of oil wastes are not possible, e.g. at LLWR. Stabilisation is a plausible alternative, but will not achieve any volume reduction, and the technology is comparatively unproven for bulk treatment in the UK. Thermal treatment for oils will however deliver similar advantages and drawbacks as for other wastes. Stabilisation within a cement matrix may offer solutions for a subset of wastes.

6.4.3 Preferred Treatment Options

For each of the assessed waste streams, participants were asked to identify, on a generic basis, a preferred treatment option that represents a key component of the overall BAT outcome. A strong consensus emerged, that for each waste stream, thermal treatment by incineration, ideally through co-incineration processes, should provide the basis of the BAT outcome.

It was recognised, however, that in practice this generic outcome will not represent BAT for every site-specific waste stream within scope. The reasons for this are unpacked further below, and inform the formal definition of the full BAT outcome presented in Section 7.

The basis for the selection of co-treatment incineration as the generic preferred option as the basis of BAT reflects the outcomes reported in Section 6.4.2 above. In summary:

Maximum volume reduction/diversion from disposal;

Flexibility re. variations in input waste characteristics;

Mature, proven process;

Current availability of process and capability;

Aqueous and gaseous discharges a key trade-off, but manageable within existing Permitted limits;

Strong cost benefit for LLW (noting reversed for VLLW/LALLW).

Participants identified that the ‘next best’ option on a generic basis was batch incineration, which has many of the above benefits, but will achieve less diversion (due to return of residues of a similar waste classification to the original wastes) and is subject to capacity uncertainty. Beyond this, supercompaction (for non-liquid wastes) offers clear benefits, although the volume reduction is not as significant as for incineration. For liquid wastes and sludges, encapsulation in grout may be plausible. Finally other treatment options including chemical treatments (chemical oxidation, molten salt oxidation, thermal desorption) and other batch thermal treatments (pyrolysis, possibly even in-situ vitrification) and stabilisation of oils merit consideration, where they can deliver bulk volume reduction, and in particular to help deal with problematic waste streams e.g. orphans.

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Disposal with no treatment (where acceptable given WAC) was identified as the option of lowest preference for LLW. However for VLLW/LALLW wastes, it is likely that strong waste-stream specific arguments for disproportionality of costs could potentially be made for a significant subset of wastes. Given the assessed importance of volume minimisation, such BAT arguments will need to be made on a case-by-case basis. 6.4.4 Relative Importance of Differentiators against Different Criteria in

Identifying BAT

An important component of demonstrating best-practice in BAT is to understand stakeholder priorities in terms of ‘weighting’ the importance of different assessment criteria in informing BAT outcomes. This can be done on an absolute basis in the first instance, with ranking of criteria on the basis of their fundamental importance. However it is more helpful, in a qualitative assessment such as this, to understand how important differences in performance against different criteria are in informing overall outcomes.

For example, participants in the current BAT process recognised the fundamental importance of community factors (that is, socio-economic factors such as impacts on local communities, job creation etc) in waste management decisions. However, this criterion did not provide any substantial differentiation between options. Therefore, the outcomes are not sensitive to views on the importance of this criterion.

To understand views on weighting the importance of differentiators noted against different criteria, workshop participants were asked to identify the differentiating criteria which they considered the most important in identifying the BAT outcome. Then, participants were asked to express the relative importance of other differentiating criteria.11 The primary outcomes of this analysis are summarised in Appendix F.

In summary, the differentiating criteria weighting analysis indicated that:

Technical Feasibility, in terms of differentiators associated with consistency with strategy, availability of technology, robustness and capacity, and Environmental Impact including consistency with the Waste Management Hierarchy, and volume reduction/diversion, represented the most important differentiating criteria.

Secondary but also potentially important differentiating criteria were Financial Cost and Health and Safety.

It was agreed that this weighting, now made explicit, is implicit in the assessment outcomes presented in Sections 6.4.2 and 6.4.3.

The sensitivity of the BAT outcomes to alternative views on differentiating criteria weighting was discussed, and the possibility that different stakeholder constituencies would express alternative priorities was noted. However, in particular for LLW, it was made clear that many of the main differentiators identified in the assessment concerning feasibility, environment, cost etc all favour the same option i.e. co-incineration.

11

This is analogous to undertaking a ‘swing-weighting’ exercise as often practiced for quantitative MCDA assessments.

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The key exception concerns aqueous and gaseous discharges, but the assessment suggested that given discharges will be controlled to be consistent with existing treatment facility Environmental Permits, this is not as significant a differentiator as the other main competing factors. On this basis, it was considered that different views on the relative importance of criteria are unlikely to lead to substantially different outcomes. For VLLW/LALLW, this remains true, taking into account the statement above that cost proportionality issues will typically be taken into account in making BAT cases for individual waste streams on a case-by-case basis.

6.4.5 Factors that will Influence Adoption of the Generic Preferred Option for Specific Sites and Waste Streams

The outcomes described above reflect a general preference for incineration (and in particular, co-incineration) at the generic level, with other options potentially also offering benefits, with disposal without prior treatment being the least preferred in principle.

In order to better understand the drivers or modifying factors that might lead to options other than incineration being identified as BAT for specific sites and waste streams, workshop participants (who included representatives of waste producing organisations that will be involved in specific BAT studies framed by the outcomes of the present process) identified the factors described in Table 9. The aim is to indicate the areas that might drive specific waste-stream BAT studies away from the generic outcomes, and therefore to inform the subsequent integration phase (see also Section 7.2).

Table 9: Drivers or Modifying Factors that Might Lead to BAT Studies for Individual Sites or Waste Streams Identifying Outcomes other than the Generic BAT

Drivers or

Modifying

Factors

Rationale

Practicability of employing enabling technologies

This recognises that in order to ensure the feedstock will meet treatment facility WAC, it is necessary to first employ enablers that implement (for example) necessary sorting, segregation and characterisation steps, consistent with the arguments highlighted in Section 4. Practicability in this sense reflects availability and effectiveness of enablers, and any potentially disproportionality in on site process costs.

Difficulty in meeting WAC constraints

More broadly it may be challenging to meet the WAC of treatment or disposal facilities. Factors that might cause difficulties include: activity limits; non radiological/hazardous waste components (for example, asbestos); safety/ALARP issues with treating particular wastes.

Availability of Permitted facilities

Reflecting that obtaining Permits to treat relevant wastes can be challenging, and indeed existing facilities can lose Permits (by choice or by change in regulation). Availability of Permits could therefore be a constraint.

Capacity of the market

In general the capacity of the market, on a longer-term basis or on a short-term batch basis, is a key issue. There will be peaks in demand for treatment services during decommissioning; there is more confidence in available and continuing capacity for such peaks for some treatment processes than for others. For example, batch incinerator capacity in the future will be limited compared to the bulk treatment capacity of co-incineration.

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Drivers or

Modifying

Factors

Rationale

Wastes not amenable to certain treatments

Some wastes might be problematic e.g. ‘orphans’ and be difficult to treat. In this case, the choice of potential treatment technique may be significantly constrained.

New waste treatment plants become available

This recognises that is possible that waste treatment routes could become available that would influence judgements on BAT for individual waste streams. A hypothetical (if apparently unlikely) example would be if a bulk chemical oxidation plant became available in the UK within the next 5 years that demonstrates a waste volume reduction of a similar order to incineration.

Challenges in transporting raw wastes

It is possible that some wastes could be problematic to transport in their raw form, and on-site treatment facilities could be limited.

Proximity within UK, and transfrontier shipments

Factors such as transport risks, nuisance and costs associated with accessing a distant facility may be relevant to identifying BAT for specific wastes. Demonstration of BAT will involve additional challenge if a preferred facility is located overseas.

Local socio-economic, planning or ‘political’ factors

These factors may have a specific influence of importance for an individual site or waste stream. For example, creating or using a particular facility may be difficult from the perspective of local planning controls or other stakeholder views, or accessing a particular facility could involve transport-related impacts on a local community.

Waste concentration

It is considered unlikely to be a problem, but it was noted that concentration of high-end LLW to ILW through batch incineration would need to be avoided.

Packing into waste disposal containers

It is possible that some wastes could remain untreated if a more efficient use of disposal container volumes is to use them for void-filling packing around other wastes in disposal containers, thus maximising container volume utilisation and reducing the volumes of void-filling grout required (in the case of LLW disposal at facilities such as LLWR).

Changes in national strategy, policy or regulatory requirements

Recognising the possibility that the strategy, policy and regulatory requirements identified as framing the present BAT study could change, influencing future decisions.

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7 Overall BAT Process Outcomes

7.1 Summary of Main BAT Outcomes

A schematic showing the overall BAT process outcomes is provided in Figure 4. This summarises the generic BAT outcomes for treatment of organic LLW and VLLW wastes within the UK. It highlights different routes from waste generation to disposal, covering the key elements of the waste management strategy.

For each waste type, the ‘most preferred’ main treatment option that is applicable to those wastes is central to the generic BAT outcomes. In particular for wastes which are suitable for volume reduction by thermal processes, incineration, ideally through co-incineration, provides the basis of the generic BAT outcome.

The schematic also recognises that individual waste-stream or site-specific factors might mean that subsequent BAT studies identify an option other than the generic BAT option as being preferred for specific sites or wastes. A hierarchy of options is therefore presented in the schematic.

Key details of the generic BAT outcomes for each key element of the management strategies identified are summarised in Table 10. This includes highlighting the rationale for the hierarchy of main treatment options and indicating considerations when identifying site- and waste- specific BAT options from the hierarchy. The outcomes and rationale are based upon the more detailed statement of assessment outcomes presented in Section 6.

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Figure 4: BAT Outcomes Summary Schematic

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Table 10: Generic BAT Outcomes for Each Waste Management Strategy Element

Element Generic BAT Outcomes

Enabling Technologies

Enabling technologies are a key feature of any organic LLW or VLLW waste management strategy. Examples include sorting, segregation, characterisation and low-force compaction, shredding and size reduction approaches. Optimisation of these elements of a management strategy is required to enable the efficient use of treatment technologies to achieve waste diversion, volume reduction or passivation. However, the choice of enabling approaches will depend on the specific nature of a waste stream and site arrangements. Therefore, no further guidance can be provided at the level of a national generic BAT.

Main Treatment Options

The outcomes of the assessment of main treatment technology options reflect a general preference for incineration at the generic level, with thermal treatment by co-incineration offering more advantages than batch incineration. This is followed by supercompaction as the next option in the hierarchy.

Other approaches including encapsulation of oils, chemical oxidation and stabilisation treatments and other thermal options may provide volume reduction or passivation options for some wastes that are otherwise difficult to treat. Such approaches may be particularly applicable to orphans that would otherwise not be disposable.

Disposal with no treatment (where acceptable given WAC) was identified as the option of lowest preference, unless a strong waste-stream specific BAT argument for disproportionality of costs can be made (e.g. for specific VLLW/LALLW wastes).

While a preference for incineration is the baseline assumption for incinerable wastes, a waste-stream specific study might identify a different option in the hierarchy outlined above as being BAT. This could reflect, for example; difficulties implementing necessary enabling technologies; difficulty in meeting treatment facility WAC; facility availability or capacity constraints, or another factor (see Section 6.4.5).

Location of Treatment

Treatment within the UK is preferred in principle, consistent with considerations such as the Proximity Principle. However it is recognised that BAT cases can be made for treatment overseas in a range of circumstances e.g. limited treatment capacity in the UK. The choice of treatment facility within the UK is a site-specific consideration.

Location of Disposals

Disposal within the UK is assumed, consistent with LLW strategy and policy. The choice of disposal facility within the UK is a site-specific matter, although options are limited for LLW above LALLW and comprise only LLWR, or the Dounreay LLW facilities for DSRL and Vulcan wastes. Disposals of wastes beneath the LALLW limit will make use of VLLW/LALLW and exempt/out-of-scope facilities as far as practicable (i.e. wherever WAC allow). Aqueous and gaseous effluents will be managed consistent with the Permits of relevant treatment facilities.

7.2 Wider Inputs to the Integration Phase

Alongside the main outcomes of the ‘technical’ BAT assessment process, a range of wider issues were considered and recorded during its execution which will inform

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considerations during the process of integrating the BAT outcomes into a formal National Strategy. These are summarised below.

7.2.1 Sensitivity of BAT Outcomes

The main differentiators identified in the assessment across relevant criteria groups all favour the same option for LLW, i.e. co-incineration. The exception concerns the potential for aqueous and gaseous discharges, but as they will be limited by existing facility Permits they were evaluated as presenting a less significant differentiator than other factors such as waste volume minimisation and diversion from disposal. Assessment outcomes therefore indicate that plausible differences in views on the relative importance of such factors are unlikely to lead to substantially different outcomes. That is, the outcomes are relatively insensitive to views on the importance of different criteria that will also reflect important factors in the integration phase.

This rationale will also remain valid if other wastes out of the present scope are considered in the future (e.g. new build wastes, as discussed in Section 2), as all differentiating arguments point in the same direction. It also applies to the ‘others’ category in the existing organic waste inventory projections, reflecting present uncertainty in form, as there is confidence that at the point of generation (during decommissioning) they will be identified as falling broadly within one of the existing waste categories.

For VLLW/LALLW, this remains true, taking into account that cost proportionality issues will typically be addressed when making BAT cases for individual waste streams on a case-by-case basis.

7.2.2 Timeframes for the Strategy

The primary focus of the National Strategy to be developed is on the next 5 years, after which the strategy is again scheduled for review. However the strategy also needs to address the longer-term to help make sure that opportunities are identified and risks understood and managed.

One perspective on the longer-term identified during the BAT process is that several technologies offer the potential to provide benefit in the longer-term, but are not sufficiently understood or robust at present to feature in the main BAT outcomes. These include:

The potential wider (e.g. bulk waste) use of technologies grouped in the BAT study under ‘Chemical Oxidation / Destruction’ and primarily identified for dealing with problematic wastes, including chemical/solvent oxidation, molten salt oxidation, and thermal desorption.

The possible value of pyrolysis or in-situ vitrification technologies for specific wastes.

Plasma technologies were screened out on the basis of it not being plausible that a plasma plant would be implemented for organic wastes alone. However, if a plasma plant is to be created for other radioactive wastes (e.g. PCM) with a wide feedstock envelope then an opportunity for treating LLW/VLLW wastes via the same process may be realised.

Gasification pyrolysis, biodegradation, and microwave decomposition were all identified as technologies that are not sufficiently developed or robust for direct consideration in the main BAT assessment. It may be worth keeping a

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‘watching brief’ on them, for potential consideration in future iterations of the strategy.

7.2.3 Costs

A high-level evaluation of costs was considered appropriate to establish related differentiators given the generic nature of the assessment reported in this document. This utilised resources such as the LLWR cost norms and broad estimates of relative costs for relevant treatment processes and disposal facilities. Participants noted that a more detailed framework for cost evaluations will be required for future processes including site- or waste-stream specific BAT studies. It was noted that for future consistency and to ensure that cross-site integration opportunities are identified and realised, the approach to further cost evaluation should be a consideration in the integration phase of the study.

7.2.4 Other Considerations for Implementation of the BAT Hierarchy

The main BAT outcome described above captures a hierarchy of options, and the detailed discussions in Section 6.4.5 describe factors that might push site- and waste-stream specific BAT studies down the hierarchy. Related to these factors, key issues to consider in the integration phase at the strategic level include:

Recognition of the importance of enablers in opening up treatment routes for specific sites and wastes.

Ensuring continuing capacity provision (noting that, for example, UK on-site batch incineration capacity will be reduced in 2014, although this risk may be considered mitigated by confidence in the availability of higher capacity off-site co-incineration facilities). Management of related ‘what-if’ scenario risks.

Monitoring opportunities for integration across waste-streams and sites (PCM, as noted above, being one example).

The need to continue studies and potential treatment technology development for problematic wastes including orphans.

The need for effective engagement with regulators, planners and other stakeholders at a local level in developing site-specific strategies.

Keeping a watching brief on national strategy, policy and regulatory requirements.

7.3 Next Steps

It is beyond the scope of the current document to go beyond the present generic BAT outcomes and identify key elements of the UK-wide and ensuring site-specific strategies that are to be subsequently developed and implemented, taking account of the generic analysis presented in this study.

The BAT outcomes identified in this document, together with the associated rationale and identified wider considerations for integration into formal strategy, will be taken forward into a development process to be co-ordinated by LLWR Ltd. It is this process that is intended to lead to development of a formal National Strategy.

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8 References

Abbott, H., 2008. Strategic BPEO Study into the Management of Combustible Low Level Radioactive Waste. ABNC Ltd report to LLWR Ltd, ABNC/LLWR/001/Rev 0.

Defra, DTI and the Devolved Administrations, 2007. Policy for the Long Term Management of Solid Low Level Radioactive Waste in the United Kingdom.

Donohew, A., Dooley, S., Keep, M., Kruse, P., and Pugh, D., 2009. Strategic BPEO study for Very Low Level Waste. Volume 1: Final Report. ENTEC report to LLWR Ltd.

Environment Agencies Requirements Working Group (EARWG), 2013. Waste Minimisation Database. http://www.rwbestpractice.co.uk/

Environment Agency (EA), 2010. Radioactive Substances Regulation: Principles of optimisation in the management and disposal of radioactive waste. Version 2.0.

Environment Agency (EA) and the Scottish Environmental Protection Agency (SEPA), 2004. Guidance for the Environment Agencies’ Assessment of Best Practicable Environmental Option Studies at Nuclear Sites.

Garrs, G., 2011. UK Management of Solid Low Level Radioactive Waste from the Nuclear Industry: Low Level Waste Strategic Review.

LLWR, 2013. Waste Acceptance Criteria – Low Level Waste Disposal. LLWR report WSC-WAC-LOW –Version 4.0 – June 2013 Draft 2.

Loudon, D., 2012. Sellafield Site Low Level Waste Management Strategy. Issue 2. Sellafield Ltd document reference LLWSSG(11)01.

Loudon, D., and Ruddy, B., 2013. Sellafield and LLWR Joint Waste Management Plan. Sellafield Ltd document reference LLWSSG(13)01.

Low Level Waste Repository (LLWR), 2011. The 2011 Environmental Safety Case: Inventory. LLWR document reference LLWR/ESC/R(11)10019.

Magnox Ltd, 2011. Heat Exchanger Disposal Best Available Techniques (BAT) Study. Document BNLS/REP/BD/0099/11.

Nuclear Decommissioning Agency, 2010. UK Strategy for the Management of Solid Low Level Radioactive Waste from the Nuclear Industry.

Nuclear Decommissioning Agency and DECC, 2011. The 2010 UK Radioactive Waste Inventory. Pöyry Energy Limited report URN 10D/985, NDA/ST/STY(11)0004.

Nuclear Industry Safety Directors Forum, 2010. Best Available Techniques (BAT) for the Management of the Generation and Disposal of Radioactive Wastes: A Nuclear Industry Code of Practice.

Paulley, A., Towler, G., Penfold, J., Limer, L., and Wilson, J., 2009. Assessment of Potential Implications of Waste Treatment and Packaging Innovations on Long-term Safety. Quintessa report to LLWR, QRS-1443H-R2 Version 1.0.

Rossiter, D., 2006. Strategic BPEO For Metal Waste Management – Options Evaluation. Studsvik report to LLWR Ltd, P0090/TR/002 Revision A.

Stevens, L., 2011. Review of Strategic Options for Metallic Waste. ENTEC report to LLWR Ltd, WMS-REP-NLWS/LLWR/25, Issue 1.

http://www.rwbestpractice.co.uk/

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Appendix A Pre-screening Long-list

Table A - 1: Main Treatment/Management Technology Options

Options Notes

Compaction options:

Supercompaction Use of WAMAC style supercompaction to enable significant volume reduction producing compacted pucks for disposal

Compaction Compaction using approaches other than WAMAC high-force compaction, most likely in-drum compaction e.g. of shredded material.

Thermal treatment options:

Incineration High-temperature incineration with generation of a small volume of ashes/residue for disposal (typically returned for disposal via stabilisation within grout, added at containerisation stage, for batch incineration processes, or disposed as VLLW / LALLW at a suitably licensed site for co-incineration)

Pyrolysis Heating in vacuum leading to off-gases and ceramic-like solid residue/slag

Plasma Targeted high-temperature treatment leading to off-gases and glass-like solid residue/slag

Vitrification High-temperature treatment leading to off-gases and glass-like solid residue/slag

Other treatment options:

Vacuum packing/treatment

For volume reduction and control of loose wastes

Biodegradation e.g. anaerobic digestion, composting

Anaerobic or aerobic breakdown of organics leading to off-gas generation and solid residue

Chemical organic destruction/oxidation

E.g, by dissolution with solvents or reaction to convert to off-gases and solid residue. Also includes molten salt oxidation. Evaporation may be part of relevant processes.

Thermal desorption Thermal desorption aims to recover hazardous organics from contaminated wastes, rendering the residue non-hazardous and suitable for landfill disposal. It works by driving off volatiles (e.g. oils and solvents) for separate treatment.

Micro-wave decomposition

Use of microwaves to achieve similar result to chemical destruction

Cryogenic crushing Supercooling to facilitate crushing via a hammer mill for overall volume reduction

Plastic melting Primarily for size reduction reasons

Shredding Size reduction by cutting into small pieces, often followed by compaction (e.g. low-force in-drum compaction)

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Options Notes

Stabilisation (e.g. of oils) Achieved by physico-chemical stabilisation to produce solid or semi-solid product, or matrix stabilisation within grout (as a distinct process from backfilling/void filling for disposal e.g. at LLWR)

Steam reforming Waste converted into gas by high-temperature steam processes that breaking down long-chain hydrocarbons, producing off-gases and other products, potentially together with solid residue/slag (in which case process essentially pyrolysis)

Physical/chemical decontamination

To separate e.g. contaminated dust from clothing, including washing/jet-washing


This is direct disposal (within containers, grouted) of otherwise untreated wastes. Once was the UK baseline.

Storage options:

Decay storage Decay storage assumes a significant fraction of the inventory of a waste-stream is short-lived, such the decay storage allows diversion (e.g. LLW to VLLW)

Long-term storage Here long-term safe storage rather than final disposal is pursued.

Backfilling/encapsulation options:

Backfilling/encapsulation other than grouting (e.g. polymer)

Use of other backfills for void reduction, and possibly additional safety benefits

No backfilling/encapsulation

Here no backfills/encapsulants will be used

Final disposal options:

Disposal to existing LLW facilities

i.e. LLWR/Dounreay

Disposal to existing LALLW / VLLW facilities

i.e. those UK facilities currently permitted to accept LALLW / VLLW

Disposal to new LLW facilities

Most likely surface or near-surface, elsewhere than LLWR

Disposal to new LALLW /VLLW facilities

Most likely surface or near-surface, elsewhere than currently permitted UK facilities

Table A - 2: Enabling Technology Options

Options Notes

Segregation

Generally standard components of existing enabling approaches

Characterisation

Sorting

Monitoring

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Table A - 3: Location Option Variants

Options Notes

Treatment in the UK12 Location variant that applies to any of the above options

Treatment overseas Location variant that applies to any of the above options

Disposal in the UK Location variant that applies to any of the above options.

Disposal overseas Assume disposal overseas not credible due to legal requirements.

References utilised in the identification of the Long-List:

Abbott, H., 2008. Strategic BPEO Study into the Management of Combustible Low Level Radioactive Waste. ABNC Ltd report to LLWR Ltd, ABNC/LLWR/001/Rev 0.

Collier, D., 2008. Treatment of Low-Level Radioactive Process Waste at Sellafield: External Stakeholder Workshop. Quintessa report to Jacobs/Sellafield, QRS-1369B-TN10 v1.0. Donohew, A., Dooley, S., Keep, M., Kruse, P., and Pugh, D., 2009. Strategic BPEO Study for Very Low Level Waste. Volume 1: Final Report. ENTEC report to LLWR Ltd.

Egan, M., Paulley, A., and Towler, G., 2008. Treatment of Plutonium Contaminated Material at Sellafield: Best Practicable Environmental Option Study. Quintessa report to Sellafield, QRS-1372A-1 v2.0.

Environment Agencies Requirements Working Group (EARWG), 2013. Waste Minimisation Database. http://www.rwbestpractice.co.uk/

Paulley, A., 2013. National Strategic BAT for Soft-solid Low Level Radioactive Waste: Scoping Report. Version 1.1. Jacobs report for LLWR Ltd, 60X50008_01.

Paulley, A., and Collier, D., 2008. Treatment of Low-Level Waste Oils at Sellafield: External Stakeholder Workshop. Quintessa report to Jacobs/Sellafield, QRS-1369B-TN4 v2.0.

12

NB treatment could be via existing permitted facilities, new permitted facilities, or ‘hazardous’ waste facilities upgraded to achieve permitting to accept radioactive waste.

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Appendix B Waste Acceptance Criteria for Existing Facilities

A brief survey of Waste Acceptance Criteria (WAC) relating to the LLWR, Tradebe, Grundon, Veolia, Inutec, Socodei, Bear Creek, Belgoprocess and Studsvik facilities has been undertaken. The detail available varied across the suppliers/sites investigated, details of the relevant WAC documents identified are presented below. The WAC review has been conducted based on information available at the time writing in order to inform the strategic review process. The WAC documents for existing treatment facilities will be subject to update and revision and service suppliers should be contacted for the current WAC applicable to available treatment facilities.

LLWR Ltd accepts low-level radioactive waste for final disposal at the LLWR site in West Cumbria and in addition provides two waste treatment services (Combustion and Supercompaction) potentially applicable to organic wastes. The current WAC’s published by LLWR Ltd are listed below. These are available from the LLWR website (http://llwrsite.com/customer-portal/waste-acceptance-criteria, accessed September 2013).

Waste Acceptance Criteria Overview

Waste Acceptance Criteria Combustible Waste Treatment

Waste Acceptance Criteria Supercompactable Waste Treatment

Waste Acceptance Criteria Low level Waste Disposal

Waste Acceptance Criteria Very Low Level Waste Disposal

B.1 Low Level Waste Repository

For a Waste Consignment to be accepted by LLWR Ltd, it must satisfy the criteria detailed in the “Waste Acceptance Criteria Overview” document13 and the WAC for LLW14 or VLLW15, as appropriate, along with the type specific WAC. These criteria also apply to the disposal of Secondary Wastes at the LLWR, that is the residual material following treatment such as combustion. In addition, waste is accepted for treatment and disposal by LLWR Ltd based on the availability of sufficient volumetric and radiological capacity at the LLWR site. WAC for the LLWR are outlined below. In addition, there are packaging and transport requirements (also detailed in the above documents). Only solid radioactively contaminated or activated waste will be accepted for treatment and disposal at the LLWR. The waste material must have been treated or packaged so as to render it, so far as is reasonably practicable, insoluble in water and not readily flammable. Waste must not contain the following materials:

Reactive metals or other reactive materials (unless conditioned using a method approved in advance)

Explosives

13

WSC-WAC-OVR-Version3-0-Ap.pdf 14

WSC-WAC-LOW-Version3-.pdf (document currently undergoing revision - WSC-WAC-LOW-Version4-0-June2013-DRAFT2v2-LLWR-RC-ver) 15

WSC-WAC-VER-Version3.pdf

http://llwrsite.com/customer-portal/waste-acceptance-criteria/

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Strong oxidising agents

Corrosive materials such that the performance and integrity of disposal container could be significantly reduced.

Pressurised gas receptacles and aerosols

Materials which generate or are capable of generating toxic gases, vapours or fumes

Chemical complexing or chelating agents

Biological, pathogenic or infectious materials

Ion Exchange Material

Hazardous waste, hazardous substances and non-hazardous pollutants – note - the updated WAC for LLW document has been revised to place controls or limitations on acceptance of hazardous materials according to three specified categories. None of the identified materials would be expected to be a constituent part of organic LLW although may require consideration if the organic LLW is part of a mixed waste stream.

Closed radioactive sources, including sealed sources, laminated sources and/or homogeneous sources

In addition to the restrictions identified above, the following criteria are of particular relevance to disposal of organic and liquid LLW. Liquids – wastes shall not contain any free liquid or liquids with flashpoint less than 21°C

absorbed on solid materials. Aqueous or non-aqueous liquid waste may be accepted for disposal with supporting justification, if fixed in a solid matrix (no release of liquid under applied loads of 400 kN/m2), and any non-aqueous content conditioned so no visible oil or grease will be released by leaching. Soluble Solids present as bulk chemical compounds greater than 1kg mass in a consignment may be accepted with supporting justification and if fixed in a solid matrix which will not readily release, demonstrated using an agreed leach test.

The quantity of Putrescible Materials within a consignment must be limited using reasonably practicable means and if present must not exceed 1% of the internal volume of the disposal container. Amounts exceeding this may be accepted if supporting justification is provided including a BAT assessment of potential treatment options and an assessment to consider potential human health implications.

The draft update to WAC for LLW disposal includes proposed revisions to restrictions regarding WAC limits for inaccessible voidage (currently WAC inaccessible voidage limits are 10% of the volume of an ISO container). The draft WAC update states BAT shall be used in order that wastes are treated so as to minimise the Total Potential Voidage in a consignment and this shall not exceed 20% of the internal volume of the disposal container unless approved in advance. Total Potential Voidage is defined as the voidage remaining after grouting or subsequently formed by degradation and is the sum of inaccessible voidage, compression voidage and biodegradation voidage. It is noted that materials with significant compression voidage include unconditioned powders such as incinerator ash and soft waste if present in very minor quantities because they cannot be reasonably practicably treated by supercompaction. Biodegradation voidage is taken to equal the total volume of paper, cardboard, cotton, putrescible materials and other readily degradable materials including vegetative plant materials. It excludes wood and man-made polymers such as plastics and resins.

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Secondary Wastes It is noted in the WAC Criteria Overview document that the specific activity of secondary wastes from a treatment process may be concentrated in comparison with the original waste consignment. The treatment process is managed to ensure that secondary waste destined for disposal at LLWR is within the specific activity limits for LLW and meets the WAC. This includes consideration of physical, chemical, and radiological properties. Radiological criteria The activity limits for acceptance of LLW for disposal have been updated in the proposed revision to the WAC document. The total specific activity limits for a waste consignment remain as:

4 GBq/t for all alpha-emitting radionuclides

12 GBq/t for all other radionuclides

However, rather than prescribing activity limits for specific radionuclides as per the previous version of the WAC document, the revision now gives consideration to activity heterogeneity and provides limits for discrete items within a waste consignment. The WAC document references the use of BAT in the characterisation, sorting and segregation of waste to facilitate management by optimal routes including limiting the activity of discrete items. The WAC provides an allowance for variation in specific activity or discrete items within a consignment that exceed the specified total specific activity limits, provided that the total specific activities averaged over the waste consignment does not exceed these limits. The activity limits for discrete items within a consignment are provided according to the specified radionuclide groupings as below: Table B - 1: Discrete Item Limits

Radionuclide Weight 1 kg or less Weight between 1 and 100 kg

Weight 100 kg or greater

Group A 0.001 GBq 1 GBq per t 0.1 GBq

Group B1 0.01 GBq 10 GBq per t 1 GBq

Group B2 0.1 GBq 100 GBq per t 10 GBq

Group C 1 GBq 1000 GBq per t 100 GBq

Table B - 2: Radionuclide Groups for Limiting Discrete Items

Group Characteristics Examples

Group A Radionuclides with half-life of more than about 100 years that emit, or decay to short-lived progeny that emit, significant photon emissions

Nb-94, Ag-108m, Ra-226, Pa-231, Th-232, Np-237, Cm-247/248

Group B1 Alpha radionuclides with half-life of more than about 100 years that do not emit, or decay to short-lived progeny that emit, significant photon emissions

U-234/235/238, Pu-238/239/240, Am-241

Group B2 Non-alpha radionuclides with half-life of more than about 100 years that do not emit, or decay to short-lived progeny that emit, significant photon emissions.

Non-alpha radionuclides with half-life less than about 100 years that emit, or decay to short-lived progeny that emit, significant photon emissions or bremsstrahlung

C-14, Cl-36, Ca-41, Sr-90, Tc-99, I-129, Cs-137, Pu-241

Group C Radionuclides with half-life less than about 100 years that do not emit, or decay to short-lived progeny that emit, significant photon emissions or bremsstralung.

Any radionuclides with half-life less than about 10 years.

H-3, Co-60, Ni-63, Cs-134, Ra-228, Th-228

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Weight limits are specified for waste consignments containing uranium or plutonium radionuclides: (a) 150 g (U-233 + U-235 + Pu-239); or (b) 300 g U-235 if the average uranium enrichment does not exceed 5% U-235 with

respect to total uranium; or (c) 1000 g U-235 if the average uranium enrichment does not exceed 1.6% U-235 with

respect to total uranium; or (d) unrestricted if the average uranium enrichment does not exceed 0.93% U-235 with

respect to total uranium, equivalent to that of natural uranium.

Categories (b), (c) and (d) above may also contain up to 15g of (U-233 + Pu-239). The specific restrictions on U-233 are only applicable where the waste is derived from a plant or process that handled separated U-233.

B.2 Very Low Level Waste Disposal

Waste categorised as Very Low Level Waste or Low Activity Low Level Waste that is not suitable or selected for treatment can be disposed to suitable authorised landfill sites. Solid radioactive Very Low Level Waste is categorised as waste contaminated up to 4MBq/t total activity or 40MBq/t for tritium (H-3) total activity. The activity limit for Low Activity Low Level Waste is 200 MBq/t. It is noted in the WAC overview that disposal is a final option in the waste management hierarchy and should therefore only be used when other options have been ruled out. Opportunities to reduce the final waste volume should be exploited wherever possible. Low Activity Low Level Waste and Very Low Level Waste Disposal Services are provided by the following sub-contractors to LLW Repository Ltd:

Augean, using the following disposal facility: − East Northants Resource Management Facility

SITA, using the following disposal facility: − Clifton Marsh Landfill Site

Waste Recycling Group, using the following disposal facility: − Lillyhall Landfill Site

B.2.1 LALLW / VLLW Disposal Sites

East Northants Resource Management Facility (ENRMF) (Augean)

WAC for acceptance of solid low level radioactive waste at ENRMF is set out in the Augean document: ‘Conditions for acceptance of low level waste’, Part A: Specification for Acceptance.

The following materials are not accepted:

Any waste in liquid form;

Waste which, in the conditions of landfill, is explosive, corrosive, oxidising, flammable or highly flammable;

Infectious hospital and other clinical wastes

Pressurised gas vessels

Chemical substances arising from research and development or teaching activities

Ion exchange materials

Complexing agents

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Waste which would otherwise present a danger to facility operators during handling

Packages where the outer surface of the package is chemically contaminated

Leaching criteria are specified for hazardous wastes including dissolved organic carbon (1,000 mg/kg) and total dissolved solids (100,000 mg/kg). Hazardous wastes must meet organic acceptance criteria of 10% loss on ignition or 6% total organic carbon.

Radiological criteria include a maximum concentration of total radioactivity of 200 Mbq/tonne. The package shall be the radioactive materials transport container used for transporting the waste and for handling and final disposal. Radionuclide composition of the package will be subject to characterisation using good practice methods. No loose waste will be received or handled. External non-fixed contamination levels on waste packages shall be ALARP and not more than 4 Bq/cm2 beta/gamme, 0.4 Bq/cm2 alpha averaged over an area of 300 cm2. External dose rates shall not exceed 0.01 mSv/hr at 1m from the waste package on all sides.

Clifton Marsh Landfill Site (SITA)

WAC for acceptance of solid LLW and VLLW at Clifton Marsh are set out in SITA document ‘Clifton Marsh Landfill Site Disposal of Permitted Radioactive Waste Material’, Materials Acceptance Criteria (MAC). The following wastes are not acceptable at Clifton Marsh Landfill site:

Liquid waste;

Waste which, in the conditions of landfill, is explosive, corrosive, oxidising, highly flammable or flammable;

Infectious hospital and other clinical wastes;

Chemical substances from research and development of learning activities;

Whole used tyres, excluding tyres used as engineering material and shredded used tyres after July 2006.

The activity concentration of any package shall not exceed an average of 200 Bq/g fro a 10 te load for all radionuclides with half-lives greater than 3 months. Small quantities with a maximum of 1000 Bq/g can also be present within the waste consignment. The activity of short half-life decay products less than 3 months shall not be accounted for if they are present in amounts not exceeding those which could be present through natural decay of accounted nuclides. A standard waster leach test must be carried out on a representative sample of the waste and the results must comply with the limits on hazardous materials specified in the MAC document. Ignoring the radioactive component of the material; then the material must meet the European waste codes in the site permit and other applicable conditions Radioactive materials will only be accepted at the site if delivered in suitably secure containers sufficient to contain all materials during shipment by road and to the site disposal area. For ISO Containers no single internal voids of greater than 0.25 m3 should remain after loading and dispatch to the site. For sealed drums or small volume containers no single internal voids of greater than 0.1 m3 should remain after loading, and dispatch to site.

Lillyhall Landfill Site (WRG) WAC for Lillyhall landfill site are specified in WRG document ‘Arrangements for the disposal of radioactive wastes to the Lillyhall Landfill Site: Guidance for Consignors’.

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Disposed wastes must be High Volume Very Low Level Radioactive Waste (HV-VLLW), defined as up to 4 MBq te-1 total activity or up to 40 MBq te-1 for H-3 (tritium). Additionally, for each consignment, the consignor must ensure that the specific activity levels IC-14 and IRa-226 of C-14 and Ra-226 respectively (MBq te-1) are such: (IC-14/ 0.9 + IRa-226) ≤ 1. Waste streams must comprise materials that are permitted, as set out in Schedule 3 of the Lillyhall Landfill Site’s Environmental Permit. HV-VLLW for disposal at the site shall not include:

Free liquids;

Complexing or chelating agents;

Ion exchange materials;

Wastes that are capable of generating toxic gases; and

Waste capable of causing an explosive hazard.

Waste streams must not be mixed with other waste streams or with non-waste materials solely for the purpose of meeting waste acceptance criteria. It is expected that waste will generally arrive at the site in skips or tipper trucks. The wastes must be covered during transport to prevent water ingress. Plastic linings, super sacks, tote bags or drums may be used to avoid any contamination of the transport container. The waste will be loose-tipped into the disposal cells. The consignor will need to liaise over any special handling arrangements required.

B.3 Supercompaction

WAMAC (Sellafield, Cumbria)

The Supercompactable Waste treatment service is provided by Sellafield Ltd, as a subcontractor to LLWR Ltd, at the Waste Monitoring and Compaction Facility (WAMAC) at Sellafield in West Cumbria. The document “Waste Acceptance Criteria Supercompactable Waste Treatment”16 provides the WAC for supercompactable waste being consigned for treatment by high force compaction, prior to disposal at the LLWR. This includes details of the physical, chemical, radiological, packaging and transportation requirements that waste must comply with to be accepted. It provides the full requirements for packaging, receipt, high-force compaction, grouting and disposal. The criteria apply to each consignment of waste to the LLWR. The overarching LLWR WAC, as outlined above, are applicable to wastes consigned for supercompaction. Packaging and transport requirements must also be complied with. Waste consigned for treatment as Supercompactable Waste must be wastes that if subjected to supercompaction, and allowing for reassertion, could reasonably be expected to be reduced in volume by 30% or more.

Inutec (Winfrith, Dorset)

Facilities available via Energy Solutions.

Inutec is regulated under the Environmental Permitting Regulations 2010 for solid, liquid and gaseous discharges enabling processing, conditioning and disposal of wastes and

16

WSC-WAC-SUP-Versi.pdf

66

any resulting secondary wastes under its own authorised routes as well as those of its customers. These authorised routes cover the full spectrum of radioactive waste, encompassing ‘free release’ / exempt material through very low level waste (VLLW) and Low Level Waste (LLW) to higher activity wastes.

Inutec operates a mobile supercompaction operation, based at the Winfrith site, processing waste for external clients. Waste can either be transported to Winfrith for treatment, or the plant can be set up and operated on the client's site. This has been undertaken for clients in the UK and overseas for French, Belgian, Czech and Swiss wastes. The mobile supercompaction plant is designed to process standard 200 litre waste drums. It has a maximum operating capacity of 2000 tonnes and a cycle time of approximately 4 minutes.

B.4 Combustible Waste Treatment

LLWR provides combustible waste treatment through a number of third party service suppliers. The document “Waste Acceptance Criteria Combustible Waste Treatment”17 presents an overview of the key WAC for each service supplier. General guidance on types of acceptable waste and activity limits (Acceptable / Likely to be Accepted / Maybe Accepted) are given in this document and summarised in Table B-3 to B-5. However, in addition the service suppliers have their own WAC which must also be complied with (these are outlined below). Service Suppliers to LLWR:

Abbot Nuclear Consulting (ABNC), using the following treatment facilities: − Tradebe (UK)

Energy Solutions, using the following treatment facilities: − Bear Creek (USA) − Belgoprocess (Belgium) − Grundon (UK)

Nuvia, using the following treatment centres: − Socodei (France)

Studsvik, using the following treatment facilities: − Nyköping (Sweden) − Tradebe (UK)

Customers can deliver combustible waste consignments either directly to the selected service supplier’s facility or to the LLWR for onward transport. The Combustible Waste Treatment Service WAC document provides the following indicative list of acceptable waste packages, and waste types. These will, however, be dependent on the destination facility as defined by the relevant facility WAC. It is noted that the customer is responsible for ensuring that as far as reasonably practicable, waste is packaged to maximise the use of the transport container in accordance with the waste loading plan.

17

WSC-WAC-COM-Version3-0.pdf

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Table B - 3: Indicative list of acceptable waste packages Acceptable Likely to be Accepted Maybe Accepted

Fibreboard Kegs 210 litre Drums TC02

Berglof Boxes 750 litre wheelie-bins

(containing bagged waste)

IP2 Containers

Dolav Boxes IP2 Full height ISO Carboys - IP1 / IP2 Rated (25 litre

– 30 litre)

Table B - 4: Acceptable and Restricted Solid Combustible Wastes

Acceptable Solid Combustible Wastes

Provisionally Acceptable Solid Combustible Wastes

Restricted Solid Combustible Wastes

Wood Plastics (halogenated including PVC)

Pyrophorics or explosive substances including free sodium

Paper Rubber Toxic materials – including mercury, PCBs, cyanides

Cardboard Ion exchange resins Biological, Infectious or Pathogenic materials

Cloth - including cotton and PPE

Filters Asbestos

Plastics (non halogenated)

Grease Pressurised gas receptacles or aerosols

Charcoal Graphite Sealed sources (ceramic beads, pellets or smoke detectors)

Cables and thin gauge metals

Metal - including steel, lead, chromium, cadmium, mercury, beryllium, uranium metal, thorium metal, radioactive lightening conductors

Putrescent material including carrion

Concrete

Fibreglass, Mineral wool Blasting materials – including sand, grit, glass, beads, pearls

Halogenated waste Materials with sharp edges such as knives, glass, needles

Mud (non-pumpable) Luminous items

Anti-static devices containing radiation sources

Table B - 5: Acceptable and Restricted Liquid Combustible Wastes

Acceptable Liquid Combustible Wastes

Provisionally Acceptable Liquid Combustible Wastes

Oils Liquids containing suspended solids

Synthetic fluids Sludge (packaged)

Organic scintillant (in vials) Borated concentrates

Chemical wastes including solvents Paint

Decontamination solutions Fire resistant oils based on phosphate esters or equivalent

B.5 Incineration Facilities

A brief survey of Waste Acceptance Criteria across a number of commercial incinerator facilities has been undertaken to ascertain what the main features are that apply across these facilities and if there are specific facilities that are ‘odd ones out’ or are particularly restrictive in their acceptance criteria.

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B.5.1 UK-based incinerators

Tradebe (Fawley, Hampshire)

Facilities available via contracts with Abbot Nuclear Consulting, and Studsvik. Accessible via the LLWR Combustible Waste Treatment Service. WAC requirements for receipt and disposal of radioactive waste at Tradebe’s Fawley facility are detailed in the document “Conditions for Acceptance of Radioactive Waste (Issue 4)”18 and include:

Limits on container type and size.

Restrictions on material types and specific radioactive items.

Activity limits per consignment – derived from the site’s RSA93 authorisation.

Package activity limits to restrict operator radiation dose rates In addition, the site permits19 give total annual/monthly limits for the site as a whole, which waste processing activity must fit within. The following types of radioactive wastes are routinely accepted for disposal at Tradebe’s Fawley incinerator:

Packaged solid radioactive wastes

Packaged liquid radioactive wastes (e.g. organic scintillant in vials within outer packaging)

Tradebe’s permit allows the processing of radioactive wastes through the following routes:

Drum hoist of radioactive wastes direct into the incinerator

Direct injection for liquid radioactive wastes prior to hoisting the empty container

Shredder for oily sludge and larger items such as HEPA filters For materials that are to be processed via the hoist, the individual package size must not exceed that of a 210 litre (45 gallon) container and for solid radioactive wastes the maximum permitted weight of any one individual package must not exceed 150kg. For materials that are suitable for processing via the shredder, the overall package limit is 1.2m x 1.2m x 1.2m and the weight limit is 1200kg WAC details:

Aqueous radioactive solutions may be accepted with the prior written consent of Tradebe.

Wastes of a putrescent nature may be accepted with prior written consent.

Radioactive wastes must be suitable for handling and treatment in the incinerator at Fawley. Consignors should be aware that heavy metallic and some other items may require to be excluded since they may physically damage the incinerator.

External dose rates limits apply for each waste package. The external dose rate limit for an excepted package is 5 microSieverts per hour.

If the radioactive waste would otherwise be a Hazardous Waste because of its other properties, it must be declared and treated as such (Hazardous Waste (England & Wales) Regulations 2005).

In order to comply with the site’s ash discharge authorisation to be disposed of as either solid very low level waste (with a limit of 40 KBq in any single item in this waste) or as exempt NORM, it is not possible for Tradebe to accept sealed radioactive sources in the form of ceramic beads/pellets or metal capsules that are

18

Tradebe - Code of Practice, Conditions for Acceptance of Radioactive Waste at Fawley Incinerator (Issue 6) August 2013.pdf 19

EPR RSR publicly available permit V 2.1, EPR/PP3593SE/V002.pdf

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likely to remain intact in the incineration process. Some types of low activity sources may be acceptable when present with other radioactive wastes. However, these must always be declared and will only be accepted with Tradebe’s prior written consent.

The following types of wastes must generally be excluded (waiver from this specification will only be granted with the prior written consent of Tradebe):

Pieces of uranium metal including shielding from sealed source containers, etc.

Items manufactured using thorium or thorium compounds including gas mantles.

Smoke detectors containing radioactive sources.

Radioactive luminous articles such as old clocks and watches and radioactive luminous "EXIT" signs and similar.

Radioactive lightning conductors.

Anti-static devices that use a radiation source (e.g. polonium-210)

Any sealed radioactive sources, for example, sources comprising cobalt-60, caesium-137, americium-241 and nickel-63 whether present as capsules or foils.

Lead metal including the shielding in sealed source containers and in some types of plastic containers used to hold vials of radioactive solutions (e.g. iodine-125 and phosphorus-32).

Large metallic objects such as piping, ducting and flanges. Fawley is authorised to handle wastes containing low levels of alpha emitting radionuclides. Particular attention will be paid to the physical form of this type of activity in bulk liquids so as to ensure that there is no unacceptable contamination of Tradebe’s facilities by, for example, insoluble particles suspended in the liquid wastes. Activity limits per Consignment and per Container are listed below. Table B – 6: Activity limits per Consignment and per Container

Categories and individual radionuclides

Authorised monthly limit (MBq)

Consignment limit (MBq)

Package limit (MBq)

1 Tritium 2,000,000 2,000,000 100,000 (1,000 for shredder)

2 Carbon-14 2,000,000 2,000,000 200,000 (1,000 for shredder)

3 Iodine-125 1000 1000

1000

48

48

Iodine-131 100 10

Phosphorus-32 and Sulphur-35

500 48

4 Beta and weak gamma emitters 33P, 36Cl, 45Ca, 51Cr, 55Fe, 63Ni, 90Sr, 109Cd,129I,147Pm

5000 500 40

5 Medium gamma emitters 57Co, 65Zn, 75Se, 85Sr, 86Rb, 95Zr, 103Ru, 106Ru, 133Ba, 137Cs, 203Hg

100 10

6 Strong gamma emitters 22Na, 46Sc, 54Mn, 59Fe, 56Co, 58Co, 60Co, 110mAg, 124Sb, 134Cs, 152Eu, 154Eu

100 4

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Categories and individual radionuclides

Authorised monthly limit (MBq)


Package limit (MBq)

7 Other man-made isotopes not listed (excluding alpha emitters)

100 4

8 Alpha emitters 40 40 0.5 (liquids) 1 (solids) (0.1 shredder)

Grundon (Colnbrook, Berkshire)

Facilities are available via Energy Solutions and accessible via the LLWR Combustible Waste Treatment Service. Soft solid waste is accepted in wheelie bins. Bins must comply with regulations for transport as excepted or type A packages. Energy Solutions offer to repack waste from drums into wheelie bins. However, this process has been noted as being expensive and labour intensive20. Waste is also accepted in 200 litre fibreboard bins, as bulk items, and liquids in appropriately sized containers. Activity limits per bin are specified in Grundon site safety document “Local Rules for Working with Waste Containing Ionising Radiation”21 and “Incinerating Radioactive Waste”22. Limits for acceptance of liquid and solid radioactive waste per container (“Burn Bin”) are listed below. Table B – 7: Limits for acceptance of liquid and solid radioactive waste per Container (Grundon).

Radionuclide Bin Limit (MBq) 3H 4000 (l) / 4000 (s) 14C 300 (l) / 3000 (s) 125I 20 131I 20 32P 20 33P 20 35S 25

Other beta / gamma emitters

20

In addition, the radiation level from any point on the external surface of any excepted package must not exceed 5 μSv/h23.

Table B – 8: Incinerator Permitted Burn Limits (Grundon)24

Radionuclide Daily Limit Monthly Limit

Tritium 300 GBq 3 Tbq

Carbon 14 240 Gbq 2.4 Tbq

Phosphorus 32

80 Mbq 1 GBq Phosphorus 33

Iodine radionuclides

20

Personal Communication provided by A Fisher, RSRL during BAT workshop (03/12/2013) 21

SO/CL/COL/117 Local Rules for Working with Waste Containing Ionising Radiation 22

SO/CL/COL/105 - Incinerating Radioactive Waste 23

SO-CL-COL-105a Radiation Limits - 06Sep12 24

EPR_TB3439_DM Radioactive Permit_CWI

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Total beta / gamma 50 MBq 0.5 GBq

Total alpha 5 Mbq 25 MBq

Veolia (Ellesmere Port)

Veolia Environmental Services hold a permit to treat LLW alongside non-radioactively contaminated waste at its Ellesmere Port High Temperature Incinerator (HTI). Around 1000 tonnes of LLW are expected each year, representing about 1% of the incinerator's capacity. Conditions for acceptance of Radioactive Waste are outlined in document “Radioactive Waste Acceptance Guidelines”25. Standard Waste Acceptance Criteria for Ellesmere Port, which cover all non-radiological contamination restrictions, also apply. Solid LLW is accepted in the following forms:

Drums with base diameter >40cm, no larger than a standard 205l drum and not exceeding 250Kg (further weight restrictions may apply depending on chemical, physical or radiological limitations). All drums must be plastic or fibre (steel drums not currently accepted for direct burn).

Small packaged solids on pallets in plastic or fibre kegs.

Waste delivered as excepted packages can be processed via a shredder. The overall package size must not exceed 1.2m x 1.2m x 1.2m and a weight limit of 1200kg. For drums processed via the shredder the maximum weight limit must not exceed 300kg.

Radioactive Waste cannot currently be accepted in:

Wheelie-bins - other than those with a drop down front to allow safe access to the inner containers. The surface dose rate limit of 5 microSieverts/hr applies to the inner containers.

Returnable containers that require their contents emptying at Ellesmere Port, where the outer container has been used to control surface dose rate.

There is a general Surface Dose Rate limit of 5 microSieverts per hour at the surface of any package (increases to this limit may be acceptable subject to prior written agreement).

The following types of radioactive wastes must generally be excluded (deviation from this specification will only be granted with prior written consent):

Uranium and thorium metal and compounds.

Sealed sources in the form of ceramic beads/pellets or metal capsules that are likely to remain intact in the incineration process.

Smoke detectors containing radioactive sources.

Any sealed radioactive sources, for example: sources comprising cobalt-60, nickel-63 caesium-137, americium-241 and whether present as capsules or foils; radioactive luminous articles such as old clocks and watches and radioactive luminous "EXIT" signs and similar.

Radioactive lightning conductors.

Anti-static devices that use a radiation source (e.g. polonium-210).

Large metallic objects such as valves, piping, ducting and flanges.

Lead including chevron bricks and shielding >1kg lead in type A packages.

Any drum/package containing more than 25 litres of liquid with low levels of alpha emitting radionuclides must be a free flowing liquid with no suspended solids present. This is to

25

8501-YAO-05 Appendix F Radioactive WAC

72

ensure that there is no unacceptable contamination of processing systems by high levels of suspended solids which may become deposited in pumps/pipework.

Permitted daily, monthly and annual limits and individual package and consignment limits are listed below.

Table B – 9: Permitted daily, monthly and annual limits and individual package and consignment limits.

Radionuclides Daily disposal limits (MBq)

Monthly disposal limits (MBq)

Individual package limits (MBq)


H-3 500,000 5,000,000 10,000 800,000

C-14 150,000 1,500,000 5,000 360,000

I-125, I-131,O-32, S-35, Co-60, Sr-90, Cs-137

400 4 4 320

NORM radionuclides from the U-238, U-235sec, Th-232sec, Ra-226, Ra-228, Pb-210, Po-210 series*

720 (of each nuclide in chain)

7,200 (of each nuclide in chain)

4 320

Am-241 20 200 0.5 40

Mixed 1,000 10,000 4 320

Mixed 20 200 0.5 40

* includes 238

Usec, 238

U+, 234

U, 230

Th, 226

Ra+, 210

Pb+, 210

Po, 235

Usec, 235

U+, 231

Pa, 227

Ac+, 232

Thsec, 232

Th, 228

Ra+, 228

Th+

For wastes containing mixed radionuclides the total activity from all listed radionuclides in each separate category must be summed.

B.5.2 Overseas incinerators

Socodei (Centraco, France)

Facilities accessible via Nuvia. Accessible via the LLWR Combustible Waste Treatment Service. This facility was removed in scoping due to the facility not being likely to be capable of dealing with UK waste.

Combustible liquid and solid LLW meeting the following criteria26 is accepted for incineration.

Maximum activity:

Total beta/gamma emitters less than or equal to 20 Mq/g

Total alpha emitters less than or equal to 370 Bq/g

Limitation of halogens, sulphur, heavy metals waste content. Encapsulation in:

90 to 200 litre metal or incinerable drums.

All other types of packaging subject to approval. Transport: Compliance with ADR and ISO standards.

26

http://www.socodei.fr/en/waste-processing/centraco/incineration/incineration2/ - accessed 07/10/2013

http://www.socodei.fr/en/waste-processing/centraco/incineration/incineration2/

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Bear Creek (Oak Ridge, Tennessee, USA)

Facilities available via Energy Solutions (licensed as Duratek Services, Inc.). Accessible via the LLWR Combustible Waste Treatment Service.

Information on relevant WAC are available in a guidance note produced by Energy solutions (“International Radioactive Material Acceptance Guidelines”27). This document provides Radioactive Material Acceptance Guidelines (RMAG) for the Commercial Waste Processing (CWP) facility at Bear Creek.

Radioactive material consisting of paper, plastic, cloth, rubber, and wood are accepted. Polyvinyl chloride materials >10% by mass and metal are not accepted for incineration. However incidental small amounts of metal such as nails in boards may be acceptable subject to approval. Radiological acceptance criteria for Dry Active Wastes:

≤ 1000 µSv/hr at contact with waste Radionuclide concentration limits per package (without prior evaluation and approval):

Total of all radionuclides with > 5-yr half-lives (except H-3 and C-14): ≤ 11kBq/cc

Total of H-3 and C-14: ≤ 1 kBq/cc

Other mixed fission and activation products with Z <84: ≤ 200 kBq/cc

Th-232: ≤ 40kBq/m3 or 1e-5 gm Th/cc of waste

Depleted Uranium or Natural Uranium as metal or oxide: ≤ 120 kBq/m3 or 6e-6 gm U/cc of waste

TRU’s and Ra-226 for processing: ≤ 90 Bq/g and less than 1% of activity Levels of radiation and radionuclide concentrations exceeding those detailed above may be accepted on a case-by-case basis, subject to approved prior to shipment. Dry Active Waste for sorting and incineration is accepted in poly-bags in bulk containers, material must not be pre-compacted. Procedures for acceptance of Dry Active Wastes for direct incineration are agreed on an individual basis. Typical requirements are:

Packages limited to one cubic meter with no single dimension greater than one meter.

Gross weight not to exceed 100kg.

No metal on or inside the package.

No free standing liquids in the same package with Dry Active Waste for direct incineration.

Material to be double bagged and heat-sealed or taped. Belgoprocess (Mol-Dressel, Belgium)

Facilities are available via Energy Solutions and accessible via the LLWR Combustible Waste Treatment Service. This facility was removed in scoping due to the facility not being likely to be capable of dealing with UK waste. Information on relevant WAC are available in the document “Acceptance criteria for unconditioned radioactive foreign waste: Combustible waste (waste category A11)”28.

27

International Radioactive Material Acceptance Guidelines (WAG-502-04182013) 28

Acceptance criteria for unconditioned radioactive foreign waste: Combustible waste (waste category A11). UBT/2009-04177, 01-12-2009.

74

The following unconditioned combustible radioactive waste are accepted:

Natural organic substances.

Putrifiable waste.

Materials containing cellulose, such as cotton, timber, cardboard, paper, etc.

Synthetic materials that don’t contain halogens, such as polyethylene (PE), polypropylene (PP), polyethylene vinyl acetate, polycarbonate (PC), polymethylmethacrylate (plexiglas), etc.

Combustible resins of ion exchangers.

Combustible filters.

Carrion.

Scintillation liquids in closed counter tubes.

The following conditions apply to waste consignments:

Carrion must be packed separately.

Combustible filters must be packed separate from other combustible waste, but can be mixed between them.

Scintillation liquids in closed counter tubes must be packed separately.

Resins of ion exchangers must be packed separately.

Materials containing chlorine (Cl), bromine (Br), iodine (I) (e.g. halogen polymers) must be limited to a concentration of maximum 3% per collection unit.

Non-combustible materials are allowed only if the non-combustible components (such as zippers, metal on a paintbrush, filtering material separators, nails, etc.) are hard to separate from the combustible materials. The number of non-combustible components must be kept to the lowest possible level. The unconditioned radioactive waste may not contain:

Sealed sources.

Injection needles.

Free liquids (i.e. not chemically connected and non-absorbed).

Pyrophoric and explosive substances.

Heavy metals (Hg, Cd, Cr, Tl, Pb, etc.).

Materials containing fluorine (F).

Materials that may be suitable for the production of Mixed Oxide fuel (this provision only applies to the presence of plutonium and not to the presence of uranium as a chemical element for MOX production).

There are also restrictions and requirements regarding biologically contaminated waste. All primary packages (in which waste is contained and will be transferred to the incinerator, usually plastic bags containment for solid wastes) are limited to a maximum size of 40x40x40cm for introduction to the incinerator. The following limits apply to primary packages and collection units (in which primary packages may be collected and transported):

The total beta/gamma activity concentration in the collection unit must be less than 40GBq/m³ (irrespective of the energy and the emitted beta particles).

The total alpha-activity concentration in the collection unit must be less than 40MBq/m³ (irrespective of the energy and the emitted alpha particles).

The sum of the activity concentrations of Ra-226 and Th-232 in the collection unit must be less than 1000 Bq/kg unconditioned radioactive waste.

Any quantity of fissile materials in the primary package of unconditioned radioactive waste and/or the collection unit must be limited to such an extent that it

75

can be considered as not containing any fissile materials in the sense of IAEA international transportation regulations29.

The maximum dose rate on (pseudo)contact of each primary package of unconditioned radioactive waste and every collection unit must be smaller than 2mSv/h.

For any primary package of unconditioned radioactive waste and for any collection unit, the surface contamination must be less than 0.04 Bq/cm² for alpha emitters and 0.4 Bq/cm² for beta or gamma emitters.

Studsvik AB (Nyköping, Sweden)

This facility is accessible via the LLWR Combustible Waste Treatment Service. Studsvik offers incineration of low-level radioactive waste, mostly consisting of plastic, textiles, cellulose and oil. The incinerator is subject to Paris-Brussels convention and hence is insured for any nuclear incident at the site leading to off-site release of nuclear matter. Studsvik is required (by legislation) to return all residue ashes and fly ash following treatment and any non-treatable waste/material (referred to as “secondary waste”) to international customers. Studsvik’s “Waste Acceptance Criteria Document for Incineration Services”30 specifies acceptance criteria for treatment of radioactive combustible waste, for acceptance of combustible waste at Studsvik’s incineration facility and the general treatment of combustible waste by Studsvik. The following limits apply to acceptance of dry active waste for incineration (material exceeding these limits may be accepted subject to discussion with Studsvik):

Surface dose rates: minimum 95 % of bags <100 μSv/h, maximum 5 % of bags >100 <1000 μSv/h per delivery.

Total activity: < 4000 Bq/g, whereof α maximum 80 Bq/g (for U-235 restrictions see below).

U-235: maximum 900 g per 5 tonnes.

Enrichment of U-235: maximum 5 %. The following acceptance criteria apply to specific material types:

Flame retardant plastics with halogen additives (Br, Cl) or Antimony components: < 11 % of total weight of waste/order. Packaged separately in clearly labelled and accessible packages.

Non-combustible material: < 10 % of total weight of waste/order.

PVC: should be avoided but is accepted if < 5 % of the total weight of waste/order, no more than 1.25 kg PVC/25 kg package.

Rubber: should be avoided but is accepted if < 5 % of the total weight of waste/order.

Total halides: 3 % of the total weight of waste/order whereof maximum 2.5 % Br of the total weight of waste/order.

U-contaminated dry active waste: delivered separated from other dry active waste types.

Charcoal: after special agreement only.

29

IAEA Safety Standard Series TS-R-S "Regulations for the Safe Transport of Radioactive Material", 2005 edition. 30

Waste Acceptance Criteria - Incineration Services. STUDSVIK/N-08/220, 20 March 2009.

76

Ion exchange resins: anion 1 % of the total weight of waste/order. The normally dewatered anion resin (free water drained) is accepted. Packed separately in clearly labelled packages placed close to the ISO-container doors. Maximum 1 kg/bag. Cation resins not accepted. Wet resins can be accepted in special agreement.

Materials that cannot be incinerated by Studsvik include, but are not limited to, the following:

Steel frames

Blasting material (sand, grits, glass/beads, pearls).

Cables, steel wires, wire enforced hoses.

Free liquids (except certain specified oils).

Toxic and/or hazardous substances, such as mercury (Hg), PCB, etc.

Materials with sharp edges, such as knives, glass, needles, syringes.

Asbestos.

Mineral wool, gypsum, concrete.

Silicon rubbers.

Silicon oil.

Biological material such as carcasses.

Pathogenic or infectious material.

Materials that may cause explosion or self-ignition. The following requirements apply to dry active waste packages:

Non Pre-compacted waste: Density approximately 200 kg/m3.

Pre-compacted waste: Density < 400 kg/m3, no compaction directly in drums. (Requires sorting by Studsvik.)

Super-compacted waste: Density > 400 kg/m3, accepted on a case-by-case basis. No compaction directly in drums.

Packaging: transparent plastic bags, thickness ≥ 0.1 mm.

Size single waste package: maximum 0.6 x 0.5 x 0.4 m.

Weight single waste packages: maximum 25 kg/bag.

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Appendix C Cost Norms for Existing LLWR Treatment Services

All information presented in this appendix has been sourced from: EGG01 - Supplemental Guidance on LTP Cost Assumptions for LLW Activities, NDA, Published May 2013

Table C – 1: Summary of recommended treatment and disposal costs

Activity Estimating

Norm

Unit Comments

Metal Recycling £3,500 te Average value per tonne of raw metal

Likely range may be £2,000-£4,500/te depending on metal type,

treatment requirements and contamination levels

When converting from volume a typical density of 1m3 = 1te could be

assumed for decommissioning Wastes

Compaction at

Sellafield WAMAC

facility for loose

wastes

£3,128 m3 Average value per m

3 of raw compactable waste

Rate includes final disposal charges and rental of TC05 containers

End of service at 2020 is based on current assumed life of WAMAC

This norm is not applicable for Dounreay

Compaction at

Sellafield WAMAC

facility for

drummed wastes

£590 drum Based on nominal 210 litre drum

Rate includes final disposal charges

Assume drum compaction capability is available from supply chain post-

2020 at same cost or lower


Incineration £1,350 m3 Average value per m3 of raw combustible waste


assumed for decommissioning Wastes

Disposal of EW to

Landfill

£150 m3 Average value per m

3 of p

standard rate

Disposal of

LLW/VLLW to

Landfill


3 of packaged waste

Likely range £250-£850/m3 depending on activity levels


assumed for decommissioning wastes

Includes landfill tax at standard rate

Onsite disposal of

LLW or VLLW

Case

Specific

m3 Costs will be specific to each facility

Examples include Dounreay onsite disposal and CLESA at Sellafield

Costs should be considered on a lifecycle basis (i.e. construction,

operation, and closure) for comparative purposes

Disposal of LLW

to LLWR vault

£2,911 m3 Value per m3 of packaged waste

Assume same gate price for future LLW Repositories

Typical packing factors are 8m3 – 10m

3 raw waste per HHISO container

with external volume of 19.5m3


Activity Surcharge

for LLWR disposal

only (LLW)

£1,000 m3 Average value per m

3 of raw waste

Average across multiple nuclides

Likely range £100 - £17,500/m3 depending on activity levels and

radionuclide composition

See LLWR Service Pricing List for radionuclide specific charges[7]

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Activity Estimating

Norm

Unit Comments

Activity Surcharge

for LLWR disposal

only (VLLW)


3 of raw waste

Average across multiple nuclides

Likely range £10 - £1,100/m3 depending on activity levels and

radionuclide composition

See LLWR Service Pricing List for radionuclide specific charges

Table C – 2: Summary of recommended transport and packaging costs

Activity Estimating Norm

Unit Comments

HHISO Container £8,000 Container External volume = 19.5m

3

Internal volume = 15.5m3

Average waste payload = 10m3

THISO Container £10,000 Container External volume = 13m

3

Internal volume = 11.3m3

Average waste payload = 7m3

TC05 Reusable container Rental cost included in treatment costs

TC02 Reusable container Rental model under development

LLW Disposal Liner Package under development

210l Drum £45 Drum External volume = 0.25m3 Average

waste payload = 0.2m3

VLLW Disposal Package £250 Bag Average waste payload = 1m3

Transport (UK) £600 Trip

Average value (Likely range £200-£2,700 dependent on distance travelled and requirement for specialist equipment)

Transport (Overseas) £6,800 Trip Average value for Europe

Table C – 3: Summary of all-in costs (for worked examples based on processing 150 te or 150 m3 of

waste) Waste Treatment / Disposal Service Quantity All-in estimate

Metallic Waste Treatment Service (UK) 1te £4,377

Metallic Waste Treatment Service (overseas) 1te £5,038

Combustible Waste Treatment Service 1m3 £1,619

Supercompactable Drummed Waste Treatment Service 1m3 £4,219

Supercompactable Loose Waste Treatment Service 1m3 £4,128

VLLW Disposal at Commercial Landfill 1m3 £790

VLLW Disposal at LLWR 1m3 £6,624

LLW Disposal at LLWR 1m3 £7,552

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Appendix D Workshop Attendees and Agendas

National Strategic BAT for Soft-solid Low-level Radioactive Waste – Scoping Workshop

Date and Location 19th September 2013, 10.30 – 16.00 The Studio, The Hive, 51 Lever Street, Manchester, M1 1FN Attendees List (Organisation) Helen Cassidy (LLWR) David Collier (WhiteoX) Kevin Dodd (LLWR) Richard Hill (Jacobs) Alan Paulley (Quintessa) Richard Kelsey (Magnox) Rachel Knott (LLWR) Hannah Kozich (LLWR) Sue McAvoy (LLWR) Paul McDonald (Sellafield Ltd) Damian Seath (LLWR) Lorna Stevens (EDF) Objectives

The scoping workshop is being held to establish representative initial stakeholder views and to formalise the scope ahead of the main BAT assessment phase, including the workshop to be held in December. Agenda 10.00 – 10.30 Arrival and Coffee

10.30 – 10.45 Introductions, background and meeting purpose

Welcome and introduction by LLWR Project Team (HC)

Aims and objectives of the meeting (HC)

Update stakeholders

Recommend outline stakeholder plan

Obtain guidance on key questions of scope

Obtain endorsement on proposed way forward

Reference throughout to draft Scoping Report

Agenda and facilitation approach (DC)

10.45 – 11.30 Project Introduction (RH)

Project context

The purpose of a strategic BAT

Related BAT studies

The project, roles & responsibilities, outputs

Mention opportunities for stakeholder input (detail later)

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11.30 – 12.15 Context (AP)

Overview of draft Scoping Report

Relationship with waste producer strategies

Wastes categories

Current baseline forecasts

Existing soft-solid LLW management arrangements Information sources for current technology

National Strategic BAT for Organic Low-level Radioactive Waste – Assessment Workshop

Date and Location Tuesday, 3rd December 2013, 10.00 – 16.30 Manchester Conference Centre, Sackville Street, Manchester, M1 3BB Attendees List (Organisation) Hugh Abbott (ABNC) Matt Buckley (RWMD) Helen Cassidy (LLWR) David Collier (WhiteoX) Anthony Dixon (Jacobs) Jill Douglas (LLWR) Dave Ferguson (Energy Solutions) Alan Fisher (RSRL) Graham Harrison (FCC Environmental) Phil Heaton (Environment Agency) Richard Hill (Jacobs) Richard Kelsey (Magnox Ltd) Hannah Kozich (LLWR) Chris Macey (Tradebe) Sue McAvoy (LLWR) Paul McDonald (Sellafield Ltd) Alan Paulley (Quintessa) Lorna Stevens (EDF) Gene Wilson (Augean Plc) Objectives The aim of the Assessment Workshop is to review the work to date on technology option screening and assessment and to develop conclusions concerning the BAT for the main organic LLW waste streams. The outcome of this strategic BAT study - the strategy baseline - will help identify the preferable overall approach to managing such wastes and identify in broad terms the key issues and considerations at a site level, without overlapping inappropriately with individual waste producer strategic decision-making. It will help provide justification for site-specific decisions consistent with the strategy, and indicate what will need to be demonstrated if sites are to adopt different approaches from the main national outcomes. It will thus provide a framework to help ensure consistency of producer-specific waste management decisions, and to support LLWR Ltd and NDA in identifying opportunities for integration and gaps in service provision.

81

Project Team Presenters LLWR Project Manager Helen Cassidy (HC) Jacobs Project Manager Richard Hill (RH) BAT methodology Alan Paulley (AP) Engagement & facilitation David Collier (DC)

Agenda 09.30 – 10.00 Arrival and Coffee 10.00 – 10.30 Introductions, Background and Meeting Purpose (HC/DC)

Safety and administration

Introductions

Aims and objectives of the meeting

Agenda and assessment approach/facilitation

Organic LLW Strategy

Project context

What is the strategy for, what should it cover?

Outcome of scoping

Summary of process followed

10.30 – 11.00 Options and Screening (AP) (Section 4 of the briefing document)

Recap of technology long-list and screening

Confirmation of shortlist for assessment

Derivation of treatment strategy options

Coffee as convenient

11.00 – 12.15 Review of draft options assessment tables (AP/DC) (Section 5 of the briefing document)

Review of waste stream/option table

Introduction to assessment tables

Review assessment tables in groups. For example: Cellulosics/ Wood; Plastics / Rubbers; Oils / Liquids.

Lunch 12.15 to 12.45 (as appropriate)

12.45 – 13.30 Feedback (DC)

Complete review; feedback & discussion

13.30 – 15.45 Local factors affecting BAT selection (AP/DC)

Local factors affecting selection (in groups)

Feedback on local factors & discussion

Extension to other waste streams

Coffee as convenient

Identifying BAT (Section 6 of the briefing document) (DC)

Identifying the Cellulosics BAT

Extension to other waste streams

Open floor for comments/views from the workshop participants

15.45 – 16.30 Review and remaining work (HC/RH)

Review of results

Remaining assessment work

Reporting & publication

Next phase (HC)

16.30 latest Thanks and close (HC)

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Appendix E Details of the Treatment Strategy Options Assessment

The following Tables provide details of the assessment of options against criteria for each of the following waste streams.

Cellulosics (the ‘baseline’ assessment), and wood (as a waste stream considered separately from ‘soft’ cellulosics, and thus not included in the above category);

Plastics and Rubbers;

Oils, and non-oil sludges, flocculants and liquids.

The ‘cellulosics’ assessment is shown in grey text for the subsequent waste streams with differences highlighted. Note for printing: The following pages are A3 landscape.

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Table E1: Cellulosics including Wood; nb differences for wood from those for bulk cellulosics highlighted in capitals; changes specific to VLLW in italics

Option for LLW CELLULOSICS

and WOOD

Safety and Security Environmental Impact Technical Feasibility Community Impacts Financial Cost Options


Simplest/fewest operations - minimises industrial dose /conventional safety risk during construction, operation

No benefits in terms of passivating waste form

(less significant for LALLW)

Potential off-site transport risk implications – transport of maximum volumes

Minimises operator doses due to single handling

Avoids environmental discharges from processing operations

No diversion of material from disposal site (may not apply waste hierarchy; e.g. does not protect LLWR as an asset by diverting disposals)

No volume reduction (may not apply waste hierarchy; e.g. does not protect LLWR as an asset by reducing disposal volumes)

(Cellulosics) – does not deal with potential voidage as material degrades (important in WAC due to stack / cap stability etc)

Maximum usage of volumetric capacity at LLWR

Simple to operate and maintain

Flexible

Mature / available process

No additional footprint – no new plant

Robust to varying characteristics in wastes – providing WAC met

Inconsistent with National LLW Strategy and Policy which strongly favours protection of LLWR disposal volume

… but broadly consistent with national strategy for VLLW/LALLW

Flexibility constrained by only having one LLW disposal site effectively available (more for LALLW/VLLW, with variation in WAC)

Community (or socio-economics) factors recognised as a fundamental factor of high importance

However in broad terms the technical assessment of options identified here did not identify strong differentiators between options (all have similar community impacts – scale of jobs created etc) except if volumes are not reduced and a second LLWR is required – significant impact on hosting community –

… May be viewed as positive (jobs/investment) or

… negative (transport impacts, perception)

Additional processing costs are very low – minimal additional cost to LLWR operations

Expensive to transport and dispose at LLWR; and

Risk of step-change effect - dramatically greater costs required for 2nd facility

(LALLW/VLLW disposal costs to specified landfill are significantly lower; risk of requiring new facility much lower, but there are constraints for LALLW/VLLW volumetric capacity - 2 specified landfill sites for LALLW and only one site for hazardous VLLW / LALLW)


Thermal co-treatment

Passive /chemically stabilised waste form

Reduction in radiological safety risk of final waste form (enhanced retention in ashes)

Reduction in chemical toxicity safety risk of final waste form (dependant on facility)

Reduction of inventory/activity of final disposed waste form

Inherent risk of high temperature incineration - although controlled appropriately by normal site operations

Potential off-site transport risk implications (additional transports compared to disposal alone, due to transport to treatment site then on to disposal)

Diversion of material from disposal site (LLWR) as LLW will become LALLW VLLW or exempt

Volume reduction of treated wastes

Chemically stabilised final waste form (e.g. ashes)

Energy use for combustion is a potential issue, except not (as) significant for cellulosics due to calorific value of fuel

Additional transportation for secondary waste (due to transport to thermal plant as well as to disposal site)

Generate discharges (airborne and liquid) – although will be within Permitted limits

Visual impact / footprint of new plant …

… although no new plants likely in next 5 years

Consistent with existing National LLW Strategy and Policy which favours volume reduction

VLLW/LALLW less of an advantage from National Strategy perspective, as preference not as strong, disposal not inconsistent


Confidence in future availability – incinerators available and in use, not dependent on nuclear industry throughput

Robust to varying characteristics in wastes (flexible)

Robust to timing of arisings (flexible)

Reduced overall net treatment / disposal costs; only LLW –

LALLW/VLLW likely significant increase in costs)

No capital costs to nuclear industry (if rely on existing/new commercial providers)


Batch thermal Reduction in radiological safety risk of final waste form (enhanced retention in ashes)




… note additional risk associated with

Volume reduction of treated wastes (not vitrification)

LLW ashes from batch thermal typically stabilised in cement – mitigates against some volume reduction

Chemically stabilised final waste form

Energy use for thermal treatment





Reasonable confidence in future availability (if not as strong as continuous)

Robust to varying characteristics - flexible


LALLW/VLLW likely significant increase in costs

Higher disposal costs for residue disposal compared to co-incineration

Higher fuel and consumable costs to operator than for co-incineration, as costs not shared with non-radiological disposal

Batch thermal

84


and WOOD


repeated start-up / shut-down for batch operations

Potential off-site transport risk implications (additional transports compared to disposal alone - transport to treatment site then on to disposal)

Clean-down can be challenging

Concentration of activity can create challenges …

… although unlikely to lead to change in waste category


Visual impact / footprint of new plant

More vulnerable to permit changes (smaller on-site incinerators)

Potential footprint (dependant on technology)

Requires accumulation of feed / buffer storage

Depending upon UK availability, may rely upon overseas capacity

Low-force compaction

Note: Seen principally as an enabler following the assessment process

Potential reduced off-site transport risk if operated at point of arising



No potential off-site transport risk implications (additional transports compared to disposal alone, due to transport to treatment site then on to disposal)

… unless on-site compaction

Potential industrial H&S risks although standard safety operating arrangements will mitigate


Limited infrastructure requirements (e.g. in-drum compaction) and therefore limited construction impacts / footprint

Density means volume reduction for WOOD may not be as significant as for other wastes

Broadly consistent with existing National LLW Strategy and Policy which favours volume reduction, but not preferred as other processes offer greater reduction

Flexible/robust to variations in cellulosic characteristics – although not to the same extent as other options


Confidence in future availability

WOOD would require an extra process step – shredding as an enabler – for low-force compaction to be effectively utilised e.g. for in-drum compaction. However this is not a major issue


Lower cost than direct disposal –

… but benefit is limited compared to other treatment technologies


Reduced transportation costs compared to no compaction

Benefit may be more limited for WOOD than for other wastes



Potential reduced off-site transport risk if operated on site of arising – and greater benefit than low-force compaction




… unless on-site high-force compaction

Volume reduction of treated wastes (greater than low-force)

But no actual diversion of material (doesn’t fully apply waste hierarchy)

Still some potential for voidage remaining


For LLW broadly consistent with existing National LLW Strategy and Policy which favours volume reduction, but still not preferred as other processes offer greater reduction


Flexible/robust to variations in cellulosic characteristics


Reasonable confidence in future availability







85


and WOOD


Footprint of new plant …

except where utilising existing plants




Additional risk associated with repeated start-up / shut-down for batch operations

Potential H&S risks of operating industrial chemical process

… although mitigated by standard operating procedures

Some processes may produce a more difficult waste form

… although others will produce a stabilised output



Volume reduction of treated wastes (dependant on process)

Chemical decontamination of wastes or bulk volume reducing processes will lead to diversion from sites

Energy use for operation

Resource use in chemical consumptions

Environmental discharges associated with chemical processes


Robustness / flexibility – but dependant on exact form of process

Technology demonstrated …

… but availability in short-term in UK is

not proven for bulk cellulosics …

… biggest area of applicability maybe for smaller volume orphans

Footprint of new plant

Existing processes not optimised for WOOD

It is possible there would be reduced overall net treatment / disposal costs for volume reduction where applicable to technology; only LLW – LALLW/VLLW likely increase in costs) –

LALLW/VLLW likely significant increase in costs ….

… but overall there is significant

uncertainty over costs as the technique is not proven in the UK for bulk wastes

Biggest area of applicability maybe for smaller volume orphans which would count against arguments on scale/cost efficiency

Would require research, design, development, construction costs for new facility (for bulk wastes)

Additional effluent treatment costs (dependant on technology)


Stabilisation Not applicable to this waste type Stabilisation

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Table E2: Plastics and Rubber; nb changes specific to VLLW in italics

Option for LLW PLASTICS and

RUBBER






Potential off-site transport risk implications – maximum volumes for transport

Potential off-site transport risk implications – transport of maximum volumes







Potential generation of contaminants due to PLASTIC degradation in the medium to longer term


Flexible






































LALLW/VLLW likely significant increase in costs)

No capital costs to nuclear industry (if rely on existing/new commercial providers)





Inherent risk of high temperature


LLW ashes from batch thermal typically stabilised in cement – mitigates against some volume reduction


Energy use for thermal treatment




Reasonable confidence in future




Higher fuel and consumable costs to operator than for co-incineration, as costs not shared with non-radiological

Batch thermal

87


RUBBER


incineration - although controlled appropriately by normal site operations

… note additional risk associated with repeated start-up / shut-down for batch operations








availability (if not as strong as continuous)






disposal


Note: Seen principally as an enabler following the assessment process

Potential reduced off-site transport risk if operated at point of arising



No potential off-site transport risk implications (additional transports compared to disposal alone, due to transport to treatment site then on to disposal)

… unless on-site compaction

Potential industrial H&S risks although standard safety operating arrangements will mitigate


Limited infrastructure requirements (e.g. in-drum compaction) and therefore limited construction impacts / footprint



Broadly consistent with existing National LLW Strategy and Policy which favours volume reduction, but not preferred as other processes offer greater reduction

Flexible/robust to variations in cellulosic characteristics – although not to the same extent as other options


Confidence in future availability



Limited benefit for RUBBERS

Need to avoid re-assertion (after compaction)

HARD PLASTICS and RUBBERS would require an extra process step – e.g. shredding as an enabler – for low-force compaction to be effectively utilised e.g. for in-drum compaction

Lower cost than direct disposal –

… but benefit is limited compared to other treatment technologies


Reduced transportation costs compared to no compaction


Potentially limited overall cost savings for PLASTICS and RUBBERS



Potential reduced off-site transport risk if operated on site of arising – and greater benefit than low-force compaction




… unless on-site high-force compaction

Volume reduction of treated wastes (greater than low-force)

But no actual diversion of material (doesn’t fully apply waste hierarchy)

Still some potential for voidage remaining



For LLW broadly consistent with existing National LLW Strategy and Policy which favours volume reduction, but still not preferred as other processes offer greater reduction


Flexible/robust to variations in cellulosic characteristics






88


RUBBER


Reasonable confidence in future availability



Footprint of new plant …

except where utilising existing plants

Need to avoid re-assertion …

… but less problematic than for low-force compaction – e.g. 30% reassertable waste limit in WAMAC WAC

















Several of the existing processes (e.g. solvent based chemical treatment) not optimised for PLASTICS or RUBBERS – degradation rates slow

Biggest area of applicability maybe for smaller volume orphans


Several of the existing processes (e.g. solvent based chemical treatment) not optimised for PLASTICS or RUBBERS – degradation rates slow





Biggest area of applicability maybe for smaller volume orphans which would count against arguments on scale/cost efficiency


Additional effluent treatment costs (dependant on technology)


Stabilisation Not applicable to this waste type Stabilisation

89

Table E3: Oils, Sludges, Flocs and Liquids; nb changes specific to VLLW in italics

Option for LLW OILS and

SLUDGES, FLOCS and LIQUIDS






Potential off-site transport risk implications – maximum volumes for transport Potential off-site transport risk implications – transport of maximum volumes


Need to manage sludge etc storage facilities prior to disposal, as tend to degrade






Not passively safe


Flexible







Free liquids in wastes not consistent with WAC for most disposal facilities esp. LLWR

Burden of maintaining and managing sludge etc storage facilities until disposal









Cost of any maintenance and management of sludge etc storage facilities until disposal









Package liquid restrictions and combustibility requires careful management




Some waste to energy contribution












Reduced overall net treatment / disposal costs

Cost differences enhanced for OILS and SLUDGES/FLOCS/LIQUIDS as other options difficult and more expensive than for other wastes

… especially for orphans



Reduction in chemical toxicity safety risk of final waste form (dependant on


LLW ashes from batch thermal typically stabilised in cement – mitigates against some volume


VLLW/LALLW less of an advantage from National Strategy perspective, as

Reduced overall net treatment / disposal costs (batch dependent)

Cost differences enhanced for SLUDGES/FLOCS/LIQUIDS as other options difficult and more expensive

Batch thermal

90




facility)



… note additional risk associated with repeated start-up / shut-down for batch operations





Package liquid restrictions and combustibility requires careful management

reduction


Energy use for thermal treatment; no waste to energy contribution




preference not as strong, disposal not inconsistent


Reasonable confidence in future availability (if not as strong as continuous)






More restrictions in applicability than for continuous process (less opportunity to manage feedstock)

than for other wastes

… especially for orphans


Higher fuel and consumable costs to operator than for co-incineration, as costs not shared with non-radiological disposal


Not applicable to this waste type Low-force compaction


Not applicable to this waste type High-force compaction











Can be power intensive


Less volume reduction for some OILS and SLUDGES/FLOCS/LIQUIDS than for other wastes






Can produce stabilised waste form

Resource (energy) use for some variants

Robustness / flexibility – but dependant on exact form of process

Technology demonstrated …

… but availability in short-term in UK is

not proven for bulk cellulosics …

… biggest area of applicability maybe for smaller volume orphans


Existing processes not optimised for WOOD

Only applicable to a subset of OILS and SLUDGES/FLOCS/LIQUIDS …

… but potentially may offer approaches for certain orphan waste streams within this category that would otherwise be difficult to treat

Potentially beneficial for flexibility of transportation etc of OILS and SLUDGES/FLOCS/LIQUIDS where volume reducing or creating a stabilised form important

Mainly mobile plants, requires feasibility demonstration





… and less volume reduction for some SLUDGES/FLOCS/LIQUIDS than for other wastes

Biggest area of applicability maybe for smaller volume orphans which would count against arguments on scale/cost efficiency – although …

… several orphan streams fall into the SLUDGES/FLOCS/LIQUIDS category


Additional effluent treatment costs


91




Can produce stabilised waste form

Can be used in mobile plants

Reduced start-up/shut-down issues

(dependant on technology)

Stabilisation Potential to produce a disposable waste form from certain liquids, especially for those wastes where stabilisation by encapsulation within grout is plausible

… but chemical stabilisation in

particular very challenging for many SLUDGES/FLOCS/LIQUIDS ...

... although less so for some OILS, for which a range of techniques have been designed, but still not simple

... considerable uncertainty as to whether chemical stabilisation waste form would meet LLWR etc WAC

Would lead to a net increase in volume

Uncertainty over stability of final product for chemical stabilisation– not proven for final treatment of many of the wastes in this list, including OILS

Stabilisation within grout matrix technically feasible for a subset OILS and SLUDGES/FLOCS/LIQUIDS

Chemical stabilisation may offer approaches for certain orphan waste streams within this category that would otherwise be difficult to treat

Chemical stabilisation would require potentially significant research and development costs, in particular for bulk wastes

Volume increase (even for stabilisation within grout)

Stabilisation

92

Appendix F Weighting

As described in the main text of the report, a comparatively simple criteria weighting process was undertaken. This comprised:

Asking workshop participants to identify the criteria which were associated with differentiating factors that were key to the BAT arguments.

Identifying which individual criterion was, in the view of the participants, the most important of those that present differentiation.

Assessing the relative importance of other criteria scaled against the most important criterion identified.

Testing the outcomes of weighting are consistent with the main BAT outcomes, and understanding the sensitivity of the BAT outcomes to variations in weighting.

The outcomes of the relative importance scaling exercise are shown below. Note that the focus is on the relative importance of criteria in differentiating performance, not their absolute value or importance. Key overall outcomes reflecting the other points described above are captured in the main report text.

Figure F-1: Weighting Outcomes Schematic