Sellafield Radioactive Substances Activities (RSA) Permit - Draft Decision

Closed 1 Dec 2019

Opened 7 Oct 2019

Contact

Nuclear Regulation Team - North

020 3025 5873

nrg.north@environment-agency.gov.uk

Feedback updated 30 Sep 2020

We asked

In October 2018, Sellafield Ltd applied for a number of changes to its Radioactive Substances Activities environmental permit, mainly to reflect the operator's forecast reductions in radioactive discharges and changing focus from reprocessing to decommissioning. We consulted on Sellafield Ltd’s application from 26 October to 21 December 2018. We took those responses into account in our determination of the application. We then consulted on a draft decision and draft permit from 7 October to 1 December 2019.

You said

The consultation responses from professional partners were positive regarding changes to Sellafield Ltd’s radioactive substances permit. Some stakeholders raised issues of concern; these are fully addressed in our final decision document, which can be found under "Files" below.

We did

We have varied Sellafield Ltd’s radioactive substances permit, to implement all of the changes as detailed in our final decision document. The key changes to the permit are:

  • Significantly reducing site discharge limits and introducing a 2-tier (upper and lower) site discharge limit structure
  • Removing some site discharge limits where discharges have fallen below significant levels and they do not meet our criteria for setting limits
  • Replacing plant discharge limits with plant notification levels so that Sellafield Ltd can make most effective use of the available discharge routes and treatment plants
  • Removing discharge limits related to the rate of fuel reprocessing (throughput) to reflect the end of reprocessing operations.

UPDATE: This permit variation (V009) was due to come into effect on 1 April 2020. As a result of the coronavirus pandemic, Sellafield Ltd was not able to make the changes required to implement the variation (V009) on that date.

As a result, Sellafield Ltd applied for and was issued with another variation (V010) on 27 March 2020 to change the date on which the permit comes into effect to 1 October 2020. The only change was a delay in the effective date.

We withdrew the previous variation (V009) and Sellafield Ltd continued to operate under its existing permit variation (V008) during the interim period.

On 24 September 2020 we issued a further variation (V011) to introduce a limit on the concentration of tritium activity for waste disposals to the Calder Landfill Extension Segregated Area (CLESA) landfill on the Sellafield site. All consignments of waste to CLESA are already subject to a permit limit for activity concentration. This variation allows an activity concentration specifically for tritium that is higher than for other radionuclides. We are satisfied that the contribution of tritium to the total dose is within acceptable levels.

We are permitting this to allow greater flexibility in disposing of waste containing tritium to CLESA which means decommissioning can progress more quickly. High tritium activity items will also be subject to Best Available Technique (BAT) assessments.

This change formed part of the original application in October 2018 and we consulted on it, and determined it, as part of our decision on permit variation V009. The reason we did not implement this change in V009 was that it required further consideration by the Department of Business, Energy and Industrial Strategy (BEIS) in relation to Article 37 of the Euratom treaty. Article 37 requires the UK to provide information on plans for disposal of radioactive waste to the European Commission (EC).

We confirmed with BEIS that Article 37 requires the UK to notify the EC of this change in permitted disposal of radioactive waste, but does not require an opinion from the EC prior to permitting the disposal. We have received confirmation from BEIS that the EC has been formally notified. This means that we are now able to implement this permit variation.

This variation (V011) immediately supersedes V010 as it has the same implementation date of 1 October 2020. There are no other changes between V010 and V011.

For further information on how we regulate the Sellafield site please see: www.gov.uk

Published responses

View submitted responses where consent has been given to publish the response.

Overview

The Environment Agency has carried out a major review of Sellafield Ltd's Radioactive Substances Activities (RSA) permit. The permit controls receipt and disposal of radioactive waste and imposes conditions and limits on discharges. This is the most significant review of this permit since the early 2000s.

As part of this review Sellafield Ltd submitted an application for a RSA permit variation in October 2018 and we ran a consultation on this application from 26 October 2018 to 21 December 2018.

We are now seeking comments on our draft decision for this permit application. Public consultation helps us to take account of any information that people think is relevant to our decision making.

The Sellafield site has historically reprocessed radioactive fuel in its THORP and Magnox reprocessing plants. However, fuel reprocessing came to an end at THORP in November 2018 and Magnox reprocessing is planned to end in 2020. This will mean that the site will see a significant reduction in radioactive discharges to the environment. Given these forecast reductions, the company will need to have a new RSA environmental permit that better reflects the new, lower discharge levels.

Following the end of fuel reprocessing, Sellafield Ltd's mission will focus on decommissioning and the safe and secure environmental remediation of the Sellafield Site. The permit review is a good opportunity to build more flexibility into the permits to allow for post operational clean out and clean-up of the high hazard legacy facilities to reduce the risk to people and the environment.

This draft decision is on the following main changes:

  • significantly reducing site discharge limits and introducing a 2-tier (upper and lower) site discharge limit structure
  • removing some site discharge limits where discharges have fallen below significant levels and they do not meet the Environment Agency criteria for setting limits
  • replacing plant discharge limits with plant notification levels so that Sellafield Ltd can make most effective use of the available discharge routes and treatment plants
  • removing discharge limits related to the rate of fuel reprocessing (throughput) to reflect the end of reprocessing operations
  • introducing a specific tritium limit for solid waste disposals at the on-site landfill known as the Calder Landfill Extension Segregated Area (CLESA).
  • updating the permit to the latest template so that it reflects recent guidance changes.

Why your views matter

The consultation will give people the opportunity to understand the proposed changes to the permit.  It is also an opportunity for people to provide us with any information that they think is relevant to our decision making.

Providing comments

We can take account of...

  • relevant environmental regulatory requirements and technical standards
  • information on local population and sensitive sites
  • comments on whether the right process is being used for the activity, for example whether the technology is the right one
  • the shape and use of the land around the site in terms of its potential impact, whether that impact is acceptable and what pollution control or abatement may be required
  • any incorrect information in the application. 

We cannot take account of...

  • issues beyond those in the relevant environmental regulations
  • anything outside the remit of the Environmental Permitting Regulations. For example Government policy and Nuclear Decommissioning Authority strategies impacting on Sellafield operations
  • whether a site should have a formal designation under Habitats Directive or other conservation legislation
  • whether the activity should be allowed or not as a matter of principle. For example we will not consider whether spent nuclear fuel should be reprocessed or stored pending disposal in a Geological Disposal Facility
  • the impact of noise and odour from traffic travelling to and from the site
  • the legally defined process we follow to determine a permit
  • the granting of a permit/variation if the operator is able to demonstrate that they can carry out the activity without significant risk to the environment or human health.

 

What happens next

Once we have assessed all the information and responses received during the consultation we will issue the permit variation to Sellafield Ltd, with the aim of doing so in Spring 2020.

Audiences

  • Members of the public

Interests

  • Business and industry
  • Waste
  • Permits
  • Nuclear
  • Environmental permitting
  • Radioactive substances regulations