The LLWR’s 2011 Environmental Safety Case (ESC) was submitted to the Environment Agency on the 1st May 2011. It plays a very important role in determining the future of the Low Level Waste Repository (LLWR) as the UK’s primary facility for the disposal of low level waste.
What is an Environmental Safety Case?
The Environment Agency, in their ‘Guidance on Requirements for Authorisation’, define an environmental safety case as:
‘a set of claims concerning the environmental safety of disposals of solid radioactive waste, substantiated by a structured collection of arguments and evidence.’
The objective of our ESC is to demonstrate to the Environment Agency and other stakeholders that it is safe to continue to dispose of LLW at the LLWR.
Our ESC considers environmental safety both now and up to thousands of years in the future. It covers arguments and evidence relating to our:
- management system and safety culture;
- interactions with regulators;
- dialogue with other stakeholders;
- characterisation and understanding of the facility system and local environment, including the wastes, engineered system, geology and hydrogeology, and coastal erosion;
- optimisation studies;
- development plans;
- assessments of radiological impacts to people and non-human biota, and non-radiological impacts;
- waste acceptance processes
Why is the 2011 ESC so important?
The environmental safety case submitted in 2002 did not fully meet the Environment Agency’s requirements. When they issued the LLWR with an Authorisation (now called a Permit) in 2006, it only allowed disposal of LLW in Vault 8. The subsequently constructed Vault 9, although designed and built to meet Environment Agency disposal criteria, was authorised for storage and not disposal. A revised or new permit is required for us to be allowed to dispose of waste in Vault 9 and future vaults.
Environment Agency’s role
The Environment Agency is currently reviewing the ESC to see if they agree with our conclusions. Details of the review, along with briefing notes on recent progress are provided on the Environment Agency website:
In due course, we will be submitting an application to the Environment Agency for a revised permit allowing us to dispose of LLW in Vault 9 and future vaults and to start to install the necessary engineering to close the Repository, including the final cap over the facility. The Environment Agency anticipate consulting on this issue in 2013, before reaching a final decision on the suitability of the LLWR for continued disposals of LLW.
We also need planning permission from the Waste Planning Authority Cumbria County Council, to dispose of LLW in Vault 9, build future vaults for disposal, and build the closure engineering (including a final cap over the waste).
A planning application was submitted to Cumbria County Council on the 30th June 2011 seeking permission for the following:
- Retention of higher stacking in Vault 8.
- Disposal of LLW in Vault 9.
- The phased construction of Vault 9a and 10 to 14.
- The phased disposal of waste in vaults up to approximately 2080.
- The phased construction and final restoration cap over, and cut-off wall around, the vaults and trenches.
Further details can be found on the Cumbria County Council Planning Application Forms.
Seeking views of others
There are a number of groups and individuals who take an interest in what we do and how we do it. Engaging with stakeholders has been an important part of developing the ESC. We remain committed to working with them to ensure our management plans take account of their views.