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Introduction to VLLW Disposal Services
Introduction to VLLW Disposal Services
Alex McCarthy, Waste Services Contract Manager
Objectives
1. Establishing the Service,a. Establishing the service and managing nuclear liabilityb. Our service summarised
2. Introduce the service and how it will work,a. Key documents in the Waste Services Contractb. VLLW Staged Project Delivery
3. Service development,a. Near term service developmentb. Medium / Long term service development
1a. Establishing the service and managing nuclear liability
• Supply Framework established following a competitive tender exercise• Customers access service through the Waste Services Contract (v3)
– Special Conditions manage the specific needs of this service
• Problem: How to manage the transfer of Nuclear Liability for SLCs– Reduce burden on SLCs for managing VLLW disposed at other sites– Provide clarity on who holds liability after waste disposed– Reduce risk of multiple tenuous claims
• Our solution: LLWR acts as channelling entity– Single SLC acting as the liable Party– Amended Insurance Policy in place– Service specific delivery process
1b. Our service summarised
• Delivered using the Waste Services Contract (v3)• LLWR will accept the nuclear liability via relevant carriage,
and our approach reflects this • The Waste Acceptance Procedure will apply with a
customised consignment stage• Gated project development and delivery model• Onsite witnessing required
2a. Key documents in the Waste Services Contract
• Waste Acceptance Criteria
• Relating to the Waste Acceptance Procedure– Compliance Dossier– QP037 Quality Plans for project and consignment specific– Waste Transfer Forms for each load
2a. Key documents in the Waste Services Contract
• VLLW Waste Acceptance Criteria– An overview document
describing the VLLW Service as a whole
– Common format
• Selected points from WAC– Physical and Chemical
Properties– Packaging and Transport
Requirements– Radiological Properties
2a. VLLW WAC - Summary
Waste Treatment and Segregation (V1)• Waste should not be consigned for disposal if reasonably practicable measures
could be adopted to reduce the final volume requiring disposal.• Where waste is not selected for treatment, acceptance will require Suitable
Supporting Justification to be provided.
Approved Waste Packages and Transport Containers (V3)• Waste for Very Low Level Waste disposal may be consigned to LLW
Repository Ltd or the Service Suppliers in a wide range of Waste Packages and Transport Containers.
• The acceptable range of Waste Packages includes 210 litre Drums and Soft Sided Packaging.
2a. VLLW WAC – Summary
Radioactivity Limits (V2)• Service Supplier specific criteria for Activity limits apply for Low Activity Low
Level Waste and Very Low Level Waste. Specific restrictions will be determined through the Waste Enquiry Process. However, the following criteria provide a general guide:
Table 1: Specific Activity Limits
Radionuclide Specific Activity (MBq/t)
Acceptable Likely to be Accepted
All <4 <200
Tritium <40 <200
2a. Compliance Dossier
• It is the collected evidence gathered to demonstrate compliance with all necessary rules, regulations, and permits in delivering the disposal service
• Compliance Dossier divides all evidence and activities into six distinct stages, which are,1. Project Initiation2. Service Definition3. Consignment Preparation4. Project Execution (Consignment and Disposition)5. Audit Reports6. Communications and Notifications
• Designed for our initial projects
2a. Quality Plan – QP037
• Comprises two sections,– QP037A Covers project activities at Pelham House (Stage A, B, C,
E, and F)– QP037B Covers individual load activities in the field (Stage D)
• Confirms that specified activities have been completed and evidence has been gathered
• Structure mirrors the Compliance Dossier template
• Further guidance at www.llwrsite.com under Logistics Services – VLLW / LA-LLW Transport Guidance Note - PAA/GN06
2a. Waste Transfer Form
• Expected VLLW service characteristics,– Large volume, low activity– High number of consignments per project– Commonality between individual consignments– Potential for increased administrative burden
• Needed to evolve to maintain quality whilst reducing paperwork
• Need to align with new Service Providers • Small number of Over-arching WCI Forms (Parent)• Numerous Waste Transfer Forms (Children)
2b. VLLW Staged Project Delivery
Waste Management Services
STAGE AProject Initiation
WEN BAT EPR / RSA WCH Analyses
Upon approval proceed to Stage B
Consign model
2b. VLLW Staged Project Delivery
Waste Management Services
STAGE BService Definition
WSQPre-
acceptance
RA
Programme
MSDS
Upon approval proceed to Stage C
Activity assess
Transport
2b. VLLW Staged Project Delivery
Waste Management Services
STAGE CConsignment Preparation
Verification
WAC
Compliantwith WAC
Packaging
Loading
Upon approval proceed to Stage D
assessed
Variations
Disposal
2b. VLLW Staged Project Delivery
Waste Management Services
STAGE DProject Execution
Pre-loading
Loading
Consigning document Waste
Transfer form
Dispatch procedure
Evidence gathered during delivery
AcceptanceOngoing
Monitoring
2b. VLLW Staged Project Delivery
• Stages that cover entire lifecycle• Section E: Audit Reports
– Duty of Cares, Transport Audits, Audits required by Service Provider or Customer
– Must be completed before progression to Stage D• Section F: Communications and Notifications
– Regulatory / Authority notifications– Stakeholder communications– Check of whether new comms plan is required (determined
according to project)– Must be completed after Stage A, but before Stage D
Waste Management Services
2b. VLLW Staged Project Delivery
• LLWR witnessing schedule defined per project• The minimum requirements for witnessing are,
1. the packaging of waste for the first consignment2. the loading of packages onto the conveyance for the first
consignment, and subsequently for any change to the WLP3. the despatch monitoring of packages for first consignment4. the transport consignment of waste for the first consignment and
any changes in radiological transport classification5. Receipt of waste at landfill for the first consignment6. Disposal of the first consignment
• LLWR is observing not supervising • LLWR control through paperwork approvals
Waste Management Services
3a. Near Term Service Development
• Deliver the service safely and responsibly• Live projects
– 1 project currently at execution stage (LLWR Service Commissioning Project)
– Several projects at preparatory stage (Normal business)• Open up all new disposal routes• React to Customer Waste Enquiries
3b. Medium / Long Term Service Development
• Medium term (12 – 18 months)– Analysis of Waste and Inventory Data – identify opportunities– Early and targeted engagement at the decommissioning stage
• Long Term (2 – 5 years)• Changes to the Paris and Brussels Conventions on Nuclear Third
Party Liability – 2011 Public Consultation• Decoupling of Licensing and Liability• Application to remove the need for licensing for LLW Disposal
sites• Open up the market and remove LLWR from channelling role
Recap of Objectives
1. Establishing the Service,a. Establishing the service and managing nuclear liabilityb. Our service summarised
2. Introduce the service and how it will work,a. Key documents in the Waste Services Contractb. VLLW Project Delivery
3. Service development,a. Near term service developmentb. Medium / Long term service development
Key Points
• Contact your Service Delivery representative for more information
• Access the service via the Waste Services Contract (if required)
• Service will involve LLWR site witnessing and greater planning than normal
• One key issue is stakeholder perception of risk– Our priority is safe and responsible development and delivery of
the service– Programme and price follow this
Questions?