Radioactive Waste – LSA and NORM

Consent Needed: Radioactive Waste Certificate of Authorisation to Accumulate and Dispose of Low Level Liquid Radioactive Waste under Sections 13 and 14 of the Radioactive Substances Act (RSA) 1993 is required for the discharge of liquid radioactive waste. Authorisation must be posted on the installation. Some radioactive wastes from offshore may be exempt from registration due to their low levels of activity (see Exemptions under the Performance Standards tab).Oil ContaminationWhere LSA waste may be oil contaminated, an OPPC Permit will also be required (see Produced Sand and Scale) prior to discharge.
How to Apply: If required, complete the RSA 3 Form (obtained from SEPA/EA) when applying for registration certificates for holding or disposal of radioactive waste (see Example RSA 3 Form (PDF document)).
Who to Apply to: Application (if needed) for consent to discharge LSA liquid waste should be made to Scottish Environmental Protection Agency (SEPA) in Scotland; and the Environment Agency (EA) in England and Wales.
When to Apply: Apply for Certificate of Registration 4-5 months prior to the expected disposal.

Some accumulations and disposals are exempted from licensing requirements due to low levels of activity.

Exemption Orders are currently under review (see the Pending Legislation tab).

Limits Placed on Oily LSA Sand, Scale or Sludge: The performance standards relating to the release of oily LSA sand, scale and sludge are specific to each case. Permits issued under the OPPC Regulations will detail limits on oil discharges, including annual reductions in discharge required (see Produced Sand and Scale for more information).
Reinjection: Reinjection downhole with produced water streams or if associated with drill cuttings reinjection is allowed.However, transfer offshore “back to source” from any onshore accumulation is not currently permitted under the London Dumping Convention.
Radioactive Material: Prior to offshore disposal, a sample of the material must be taken and analysed for radioactivity levels and types.An estimate of the total activity to be disposed of must be made and recorded. Also see Produced Sand and Scale for cases of oil contamination.
Additional OSPAR Sampling Requirements – Water Jet and Chemical Descaling Operations: Samples of scale/slurry to be taken at the discharge point whilst the operation is under way. Every de-scaling operation must be sampled.Solids to be analysed by high resolution gamma spectrometry for Ra-226, Ra-228, Pb210 and Th-228. Activity concentration in Bq/l multiplied by total volume of water discharged. A sampling/analysis protocol is being developed and will be issued to operators.
Radioactive Material: Reports of the types and quality of wastes disposed of both offshore and onshore are required.Reports to be submitted to SEPA or EA as appropriate on an annual basis by 1 April of the following year.Additional OSPAR analysis – to be reported via the BEIS EEMS system (see EEMS website).Also see Produced Sand and Scale for cases of oil contamination.
When to Report: SEPA/EA Reports on radioactive waste disposal should be made annually by 1 April of the following year. OSPAR analysis – via the BEIS EEMS system on a quarterly basis.
What to do if in Breach of Consent/Authorisation: If in breach of Certificate of Registration, report immediately to SEPA or EA.
Renewal – Radioactive Waste: SEPA/EA will review an operator’s registration at intervals of approximately 4 years.
Renewal/Variation – Oil Contamination: If oil contaminated LSA scale or sludge is included in the Fields Life Permit under the OPPC Regulations, this will be reviewed at a frequency stipulated in the permit schedule. The minimum frequency of review will be every three years (see Produced Sand and Scale). If planning to change the amount/frequency of discharge, an application for a Variation will be needed. This must be prepared by amending the original application and clearly highlighted. Variations will be dealt with by BEIS as quickly as possible, but 28 days should be allowed for the assessment of any significant changes. If a Term Permit has been issued under the OPPC Regulations (i.e. for an activity specific time limited discharge operation), this will only be valid for that operation and will expire after this time. A new application will be required for new planned discharge operations.
BEIS (then DECC) Exemption Orders review programme:

The proposed new regime provides a way to meet modern requirements for the regulation of ubiquitous and low risk radioactive materials and waste.It is proposed that the final Phase will bring the new exemptions regime into force in April 2011.
New Guidance on Near-Surface Disposal Facilities: The principles and requirements for near-surface disposal facilities dealing with radioactive waste have been set down in a new guidance document that was released on the 18 February 2009. Further information can be obtained on the SEPA website. The updated guidance was developed in consultation with industry and prepared jointly with the Environmental Agency (PDF document) in England and Wales.
Committee on Radioactive Waste Management (CRWM) Triennial Review 2015

The government has published the findings of the review which concluded that CoRWM should continue in its role as an advisory Non-Departmental Public Body (NDPB) providing independent advice, based on the available evidence (link here).

Strategy for the management of Naturally Occurring Radioactive Material (NORM) waste in the United Kingdom:

This consultation finished on 8 May 2014 and DECC (now BEIS) has recently released the results from the consultation seeking views from interested parties in regards to the management of NORM.

A link to the results is accessible here.

Guidance for landfill operators on low-level and very low-level radioactive waste:

New guidance for landfill operators on low-level and very low-level radioactive waste has been published by the Environment Agency for landfill operators who may want to accept low-level and very low-level radioactive waste for disposal. Those landfill sites in England and Wales wishing to accept this type of waste will have to apply to the Environment Agency for an authorisation, and in doing so to justify the suitability of their sites. The Environment Agency will then properly assess their applications, and if satisfied authorise disposals and regulate these sites. Authorisations granted for the controlled disposal of low-level radioactive waste at landfill will to have additional requirements and controls, compared to those for the disposal of very low-level radioactive waste. The Environment Agency will require sites authorised for disposal to be strictly monitored, and will ensure the results from this are published.
UK Policy: A policy statement, Policy Statement for the Long Term Management of Solid Low Level Radioactive Waste in the United Kingdom (PDF document), was published in March 2007 as a result of public consultation. The policy amends or replaces relevant parts of the ‘Review of Radioactive Waste Policy: Final Conclusions’ White Paper published in July 1995. The policy statement covers all aspects of generation, management and regulation of solid low level radioactive waste.
Re-injection of LSA scales and sludges: The re-injection of low specific activity (LSA) or Naturally Occurring Radioactive Material (NORM) scales and sludges is currently under consideration by BEIS.
Lessons learned from offshore inspections: SEPA discussed regulation of radioactive substances with the oil and gas industry in October 2000. Main points of discussion: The majority of SEPA’s offshore inspections performed on offshore oil and gas installations require enforcement actions. SEPA believed this could be addressed by taking the following points into consideration:

  • Consider how radioactive waste can be controlled, i.e. how NORM/LSA can be disposed of (only avenues at present are to sea, or via 1 or 2 available onshore facilities).
  • Disposal to sea – weight/mass to sea (Bq/g) measurements should be properly assessed.
  • Solid waste to sea – a particle size limit exists on licences, usually <1 mm, so ensure contractors have the necessary equipment to fulfil this requirement.
  • Put formalised procedures in place to demonstrate licence compliance/authorisation.
  • Keep records – e.g. discharging 30 tonnes and taking 1 sample is not representative. In addition, operators usually hand over responsibility for sampling to contractors. Police contractors better.
  • Waste to sea below regulatory control levels – demonstrate basis for using exemption order (e.g. why dump it), use sampling.
  • Shore-based contamination of trucks leaving bases – about 2 incidents per month. Use of detection devices could mitigate this at a fraction of cleanup costs (e.g. £25k to set up/run detection system, versus possible £250k to clean up). Please give consideration – not a legal requirement.
  • Applications – consent to accumulate/dispose of radioactive waste requires an authorisation from SEPA but there is a period of 28 days from licence issue to its coming into effect. SEPA must give this consent within 4 months of the application date, unless both parties agree otherwise.
  • Enforcement of the SEPA authorisation has three stages – a notice that the licence holder has, or is likely to, break authorisation conditions; a notice that the licence holder is causing “immediate harm to health/environment”; followed by prosecution. This process might not follow in sequence, if a serious breach were discovered.