Corporate report

Regulatory scrutiny and engagement for geological disposal: annual report 2023 to 2024

Updated 22 October 2024

Foreword

The Environment Agency is the independent environmental regulator for the nuclear industry in England. Our activities are guided by our plan ‘EA2025 creating a better place’. This plan acts as our compass, enabling us and others to chart a course towards a healthier, greener and more prosperous country.

Our EA2025 plan sets out 3 main goals:

• a nation resilient to climate change
• healthy air, land and water
• green growth and a sustainable future

Our regulation of disposals of radioactive waste, including radioactive discharges to air and water, and disposals of solid waste to land, aligns with these goals. It helps ensure that these facilities are designed and operated in ways that minimise waste and protect the environment.

The Office for Nuclear Regulation (ONR) is the UK’s independent nuclear regulator for safety, security and safeguards at licensed nuclear sites in the UK. Our mission is to protect society by securing safe nuclear operations.

ONR has the legal authority to regulate nuclear safety, nuclear security and conventional health and safety at the 36 licensed nuclear sites in Great Britain. We also regulate the safety of transporting radioactive materials and work closely with the International Atomic Energy Agency (IAEA) to ensure that the UK’s safeguarding obligations are met.

This is a joint Environment Agency and ONR publication that summarises our work relating to the geological disposal of radioactive waste during 2023 to 2024. As regulators for this waste, we are working together to make sure that any future geological disposal facility (GDF) will meet the high standards for environmental protection, safety, safeguards and security that the law requires, and the public expects.

We have established agreements with Nuclear Waste Services (NWS), the organisation responsible for developing a GDF, to provide regulatory advice and to scrutinise its work. We are engaging with NWS early, before regulation starts, so that when a site is identified, NWS already clearly understands what it needs to do as part of the regulatory process. We also liaise with NWS to make sure that it gives the right advice to waste producers about packaging radioactive waste for future disposal at a GDF. This helps NWS understand what it needs to do to meet applicable legal requirements for environmental protection, safety, radioactive materials transport, safeguards and security. It also helps us better understand NWS’ work and lets us prepare in advance for any permit or licence applications we might receive from NWS, so that we can respond promptly and knowledgeably.

We have no regulatory role in selecting potential sites for a GDF. However, we support communities that are considering hosting a GDF on matters relating to our respective areas of regulation.

We have set out our regulatory expectations for geological disposal, covering our respective remits. The Environment Agency has issued its Guidance on Requirements for Authorisation (GRA)^{[footnote 1]}. We are consulting on revisions to the GRA in autumn 2024; this document references the published, 2009, version. ONR has issued a technical assessment guide on geological disposal^{[footnote 2]}, which it updated in March 2023, and will draw on relevant aspects of the Safety Assessment Principles for Nuclear Facilities (SAPs)^{[footnote 3]}, the Security Assessment Principles for the Civil Nuclear Industry (SyAPs)^{[footnote 4]} and the Construction (Design and Management) Regulations 2015.

As independent regulators, we are committed to making our work open and transparent. This report will help us to continue to do this.

You can find further information on:

• the Environment Agency’s role in regulating a GDF
• ONR’s engagement on the GDF

Executive summary

This report summarises the work that the Environment Agency and the Office for Nuclear Regulation (ONR) carried out to scrutinise Nuclear Waste Services’ (NWS’) work related to geological disposal, and our associated interactions with the public, from April 2023 to March 2024.

A site has not yet been selected to host a geological disposal facility (GDF). However, as of March 2024, NWS is engaging with 3 GDF community partnerships. NWS has started evaluation work in these areas, with the aim of selecting up to 2 communities to carry out detailed intrusive investigations. We continue to develop our relationships with the GDF community partnerships that have formed to date, and to provide information on how we would regulate a GDF.

NWS reorganised its GDF programme during 2023 to 2024, with the objective of better aligning it to longer-term needs and the inherent risk and uncertainty in such a programme. This led to delays in some aspects managing of NWS’ work. NWS informed us that these delays will not impact the major programme milestones.

Our pre-application advice and scrutiny during 2023 to 2024 covered a wide range of topics, including:

• the integration of management arrangements as the former Low Level Waste Repository (LLWR) Ltd and Radioactive Waste Management (RWM) Ltd businesses became a single legal entity (Nuclear Waste Services Ltd) on 1 April 2024
• NWS’ developing management arrangements for holding an intrusive investigation permit
• the scope and content of the Initial Site Evaluation and underpinning information that will accompany an intrusive investigation permit application
• design and safety case development
• disposability assessment and waste package records management

Throughout 2023 to 2024, we have observed good progress on these topics. However, we observed some important gaps in our engagement, most notably relating to progress on site evaluation and on the research, design and development strategy, programme and prioritisation. We advised NWS that we did not have detailed enough programme information to plan our forward engagement in 2024 to 2025 and beyond and to prepare for an intrusive investigation permit application. We will continue to engage with NWS in 2024 to 2025, including to establish this level of detail.

Introduction

Radioactive waste has been, and continues to be, produced from the UK’s historic and current nuclear power, research and defence programmes, as well as from industries, hospitals and universities that use radioactive material.

There is currently no available route in the UK to dispose of the most hazardous radioactive waste, so it is stored on existing nuclear sites until a solution can be found.

UK government policy for the implementation of geological disposal of the UK’s most hazardous radioactive waste is described in the 2024 UK policy framework for managing radioactive substances and nuclear decommissioning^{[footnote 5]}. This sets out the framework for implementing geological disposal in England and Wales. Scottish Government policy does not support geological disposal. Rather, its policy is for the long-term management of higher activity waste (HAW) in near-surface facilities that are located as near to the site where the waste is produced as possible.

The Nuclear Decommissioning Authority (NDA) is responsible for implementing government policy on the long-term management of radioactive waste. Nuclear Waste Services (NWS), which is part of the NDA Group, is responsible for developing a geological disposal facility (GDF). NWS was created in January 2022 by the integration of Radioactive Waste Management (RWM) Ltd - a subsidiary of NDA that was responsible for developing a GDF; Low Level Waste Repository (LLWR) Ltd - also an NDA subsidiary; and the NDA’s Integrated Waste Management (IWMP) Programme. NWS became a single legal entity (SLE) on 1 April 2024.

The Environment Agency and ONR are responsible for making sure that any future GDF in England or (for ONR only) Wales meets the high standards necessary to protect people and the environment when it is being developed, while it is operating, and after it has closed.

We will be responsible for granting the necessary environmental permits and nuclear site licence, and for our respective regulatory roles of environmental protection, safety, security, radioactive materials transport and safeguards. Regulatory control of a GDF is likely to be required for at least 150 years.

Our regulatory partner, Natural Resources Wales (NRW) has similar environmental protection responsibilities for Wales, and we keep it aware of matters arising and important outcomes from our work.

We are engaging with NWS now to make sure that any future applications to develop a GDF take account of all permitting and licensing requirements. We also want to make sure that NWS gives the right advice to waste producers, so that radioactive waste packaged at their sites is suitable for future disposal, can be safely stored in current stores, and can be safely transported to a future disposal site.

Discussions at this early stage will help us prepare in advance for any permit or licence application we might receive from NWS, so that we can respond promptly and knowledgeably.

In addition, it ensures that waste producers and NWS fully understand our regulatory expectations and can provide adequate documentation to support any future applications.

At this stage, before considering issuing permits or a licence, we are providing regulatory advice rather than making regulatory decisions.

Support to the siting process

We have no regulatory role in selecting potential sites for a geological disposal facility (GDF). However, we are:

• providing support to communities that are considering hosting a GDF
• sharing information with community partnerships in Cumbria and Lincolnshire
• advising on matters relating to our respective areas of regulation

As of March 2024, there are 3 GDF community partnerships in England: Mid Copeland and South Copeland in Cumbria and Theddlethorpe in Lincolnshire. The potential GDF host rock of interest in all 3 areas is in the inshore area, that is the underground part of the facility that would be located deep below the seabed, but within the outer limit of UK territorial waters at around 22 km offshore.

During this reporting period, NWS took the decision not to take Allerdale further in the search for a suitable site to host a GDF. South Holderness Working Group operated briefly during January and February 2024.

Our GDF communications and engagement strategy sets out our objectives, stakeholders and activities. These activities include publishing information and infographics, producing materials to use at public exhibitions and online, as well as engaging with groups and community partnership members to explain our role. The information includes:

• a short animation to explain the regulators’ role in geological disposal available on YouTube
• an overview of the regulatory processes that the Environment Agency and ONR will apply to the development, operation and closure of a GDF in England
• information pages on GOV.UK and the Office for Nuclear Regulation websites
• our annual reports, including this one

Mid Copeland, South Copeland and Allerdale GDF Community Partnerships

During 2023 to 2024, we regularly offered online meetings to the community partnerships to help them understand our role. We also wrote to the chairs of each partnership to offer our support and offered to attend community engagement events.

We attended the following events:

• Mid Copeland GDF Community Partnership team at the Gosforth Agricultural show on 19 August 2023 to answer questions from the public (Environment Agency)
• South Copeland GDF Community Partnership meeting on 13 September 2023 (Environment Agency and ONR)
• Mid Copeland GDF Community Partnership meeting on 20 September 2023 (Environment Agency)
• South Copeland GDF Community Partnership Big Picture film event on 24 November 2023 (Environment Agency) and 25 November (ONR)
• Allerdale GDF Community Partnership’s screening of The Atom – A Love Affair, in Workington on 13 July 2023 (Environment Agency)

We noted NWS’ announcement on 28 September 2023 that it had decided not to take Allerdale further in the search for a suitable site to host a GDF. Allerdale GDF Community Partnership closed in March 2024.

We welcomed the opportunity to place an article about the role of the regulators on the South Copeland GDF Community Partnership website and ebulletin in September 2023.

We manage our own local communications and engagement plans for each partnership. They are informed by NWS’ market research, local conversations, questions and concerns raised at local meetings and our own engagements.

We also use our annual reports to share information about our work with stakeholders. We promote it through e-bulletins and social media. The community partnerships share news on social media channels and e-bulletins.

Theddlethorpe GDF Community Partnership

We offered online meetings to the Theddlethorpe GDF Community Partnership to explain our role and wrote to the chair to offer our support. We also offered to attend community engagement events.

We attended the Theddlethorpe GDF Community Partnership Big Picture event to observe on 11 August 2023 (Environment Agency).

We use our annual reports to share information about our work with local stakeholders and the community partnership.

South Holderness GDF Working Group

South Holderness GDF Working Group was launched on 25 January 2024. We were ready to provide support to the working group, however it was not taken forward following a decision by East Riding of Yorkshire Council on 22 February 2024.

Wider stakeholder engagement on geological disposal

In May and October 2023, the Environment Agency held its bi-annual ‘meet the regulator’ engagement forum for stakeholders in Cumbria to provide an opportunity for discussion and questions about geological disposal.

ONR’s Non-Governmental Organisation (NGO) Forum meets twice a year. The meetings provide an opportunity to discuss and engage with members of the NGO community on a range of issues, including geological disposal. During the reporting period, the forum met in April and October 2023. Minutes from the meeting are available on ONR’s website.

Both the Environment Agency and ONR have responded to several enquiries from the public and NGOs about how we would regulate geological disposal.

We met with the Committee on Radioactive Waste Management (CoRWM) in November 2023 to discuss its developing position on the need for an underground research laboratory (URL). We also discussed CoRWM’s forward workplan and its position on retrievability. Both the Environment Agency and ONR provided feedback on a draft version of CoRWM’s position paper on the implications for the management of higher activity wastes and spent fuel resulting from the development of small modular reactors and advanced modular reactors, which was published in February 2024.

The Environment Agency meets with the Marine Management Organisation (MMO) several times a year to discuss regulating an inshore GDF. We confirmed that we will be the lead regulator for regulating groundwater in rock formations below the seabed in the inshore area. We will be working with the MMO to develop joint communications materials covering roles and responsibilities in the regulation of an inshore GDF. 

The Environment Agency also meets with the Planning Inspectorate (PINS) several times a year to discuss the interface between planning and permitting of a GDF. PINS had not started formal engagement with NWS on the intrusive investigation Development Consent Orders (DCOs) at the time of our last meeting in February 2024.

Working with Nuclear Waste Services (NWS)

The Environment Agency and ONR meet regularly with NWS’ community engagement and communications team. These meetings enable NWS to share its plans for community partnerships and help us support community discussions.

We work with NWS to consider how best to share information about regulation with community partnerships and any future working groups that may emerge. We also receive updates from NWS on its corporate communications on geological disposal, national stakeholder engagement, and work with CoRWM.

We attend quarterly GDF regulatory stakeholder meetings. These meetings are coordinated by NWS to manage the interfaces between the organisations that would be involved in the future regulation of a GDF.

The Environment Agency is working with NWS to support the development of a new charging agreement to fund our pre-application advice in the period leading up to the first environmental permit application and DCO for the intrusive investigation.

Regulatory preparations

Engaging with Nuclear Waste Services (NWS) on geological disposal at an early stage helps us prepare for any environmental permit or nuclear site licence application that we might receive, so that we can respond promptly to what will be a first-of-a-kind activity.

We anticipate that regulated activities will continue for around 150 years from the start of the construction of a GDF, during its operation and through to its final closure. Regulation of the development, operation and eventual closure of a GDF will take place in stages. Approval is required from regulators for surface-based investigations, and, in due course, for underground investigations, construction, operation and closure. The developer is not able to progress from one stage to the next without first securing the relevant permissions it needs. The purpose of this staged approach to regulation is to ensure that the development is carried out safely and securely at all times, and in ways that ensure people and the environment are properly protected without inadvertently undermining the long-term performance of the facility.

The regulatory process will start when the developer decides there is a need for certain surface-based intrusive investigations such as drilling boreholes. At this stage, the developer will need to apply to the Environment Agency for an environmental permit before starting any such works. Joint regulation by the Environment Agency and ONR will begin after a preferred site for a GDF has been identified. The developer will need to apply for both a nuclear site licence and the appropriate environmental permit before starting excavations to enable underground investigations.

We recognise that regulatory responsibilities and requirements may change and evolve during the design, construction, operation, closure and post-closure periods of a GDF. There could also be unexpected changes in government policy on waste disposition routes. We give advice and scrutiny based on the latest knowledge, directions and legal requirements. We maintain and enhance our capabilities to meet our responsibilities in regulating geological disposal. This includes engaging with other regulators and international programmes relevant to radioactive waste disposal.

Permitting and guidance

The Environment Agency is developing a bespoke template for the intrusive investigation environmental permit along with supporting guidance on staged regulation. In parallel, we are also updating our Guidance on Requirements for Authorisation of a GDF for solid radioactive waste (the GRA)^{[footnote 1]}. We have developed a strategic plan for delivery of regulatory guidance and the permit template, which we have shared with NWS.

We produced a first draft of our staged regulation guidance document and specified what is covered under the scope of ‘intrusive investigation activities’. We defined how we would regulate the phased drilling of intrusive investigation boreholes, including how we apply the definition of ‘site’ and ‘premises’ to any location where intrusive investigations are taking place. NWS has reviewed the draft guidance and provided valuable feedback. We are carefully considering NWS’s feedback as we develop the next version of the staged regulation guidance.

We have updated early drafts of the intrusive investigation permit template as well as the guidance on our requirements for the Initial Site Evaluation (ISE) and Preliminary Environmental Site Evaluation (PESE) that will accompany the intrusive investigation and underground investigation permit applications, respectively. We are reviewing these documents internally and will use feedback we receive to refine them further so that they are fit for purpose.

Work to update the GRA has advanced with the conclusion of an internal review of the draft guidance document. We are using feedback from the internal review to inform amendments of the draft GRA.

After we have completed the next versions of the GRA and staged regulation guidance, we will subject them to a full public consultation in autumn 2024. This will give relevant stakeholders the opportunity to participate in developing the guidance for transparency and to build public confidence. We do not consult on our permitting tools and templates. However, we have incorporated the ISE and PESE guidance into annexes of the consultation version of our staged regulation guidance.

Capability building

While regulating geological disposal is similar to ongoing regulatory activities, it also has some significant differences. It is necessary to enhance regulatory capabilities in some areas at certain times and to maintain these capabilities over extended periods during the design, construction and operation of the facility.

The Environment Agency is continuing to review and develop its capability to ensure that we can regulate a GDF over the coming decades, starting with getting ready to permit the intrusive investigations.

We are boosting our team through recruitment and targeted learning and development. We continue to arrange internal training seminars on topics of relevance to geological disposal. In 2023 to 2024, this included:

• an introduction to geological disposal for new members of our Nuclear Regulation Group
• the challenges and uncertainties facing community partnerships in the GDF programme
• learning from the Swiss programme of site investigation in support of its GDF site selection process
• the GDF siting process in Germany

We have also visited the British Geological Survey (BGS) in Nottingham to see core samples from rock types similar to those at the potential host communities, to view the seismic survey data that has been collated and analysed on behalf of NWS in the Copeland and Theddlethorpe inshore areas, and to visit BGS’ laboratory facilities. We also attended the NWS Research Support Office (RSO) conference in January 2024. The RSO helps provide independent research by the academic sector to support the implementation of a GDF in England and Wales (part of NWS’ research, development and demonstration).

International engagement

During 2023 to 2024, both the Environment Agency and ONR engaged with other regulators and international programmes relevant to geological disposal, both in person and virtually. This engagement provided us with valuable information and learning from international organisations, GDF developers and regulators from countries that are in various stages of GDF siting and development.

The Environment Agency is a member of the Nuclear Energy Agency (NEA) Integration Group for the Safety Case (IGSC). In this capacity, we:

• attended the annual IGSC meeting which included updates from international organisations, overseas programmes and IGSC sub-groups as well as a joint session with the NEA Expert Group on Operational Safety focused on sharing ‘lessons learned from the operation of facilities’
• are members of the organising committee for the NEA IGSC Safety Case Symposium 2024

The Environment Agency also:

• is a bureau member of the NEA’s Forum on Stakeholder Confidence and contributed to its periodic virtual planning meetings and document review process
• attended virtually the International Atomic Energy Agency (IAEA) technical meeting on ‘Practical experiences and considerations in the planning, construction and initial operation of the first underground facilities at potential deep geological repository sites’ in September 2023
• attended in person the German Federal Office for the Safety of Nuclear Waste Management’s (BASE’s) second research symposium ‘safeND 2023’, an interdisciplinary research symposium on the safety of nuclear disposal practices in September 2023
• met the Canadian Nuclear Waste Management Organization’s (NWMO’s) Director of Siting Coordination to learn from its experience of the site selection process for a GDF for Canada’s spent fuel, in particular relating to stakeholder engagement
• arranged a virtual seminar with the Swiss National Cooperative for the Disposal of Radioactive Waste (Nagra) and the Swiss Federal Office for Energy (the authorising department) to learn from its experience of recent site investigation and borehole drilling activities carried out during its GDF site selection process
• held the latest in a series of bilateral virtual meetings with the Canadian Nuclear Safety Commission (CNSC) on ‘trust in the regulator’
• attended a number of international workshops virtually, including a US Nuclear Waste Technical Review Board (NWTRB) workshop on consent-based siting; a European Joint Programme on Radioactive Waste Management (EURAD) uncertainties management (UMAN) workshop, which explored stakeholder views on near-field uncertainties; EURAD training courses on sensitivity analyses in safety assessments for geologic disposal facilities and monitoring in geological disposal facilities of radioactive waste; and a webinar on delivery of the EU research programme on pre-disposal management of radioactive waste (PREDIS) strategic research agenda

Geological disposal programme

We expect Nuclear Waste Services (NWS) to have a clear and comprehensive programme of work to implement geological disposal that meets our regulatory requirements, and to demonstrate progress against it (GRA Requirement 4^{[footnote 1]}). We recognise that such a programme may also need to meet other needs in addition to regulatory matters. However, these wider needs are not part of our regulatory responsibilities and so do not form part of the scope of our work.

This programme should give us confidence that NWS understands what it needs to do to achieve its goals at each phase of its work. It should also enable us to plan and focus our scrutiny work, assess NWS’ progress towards meeting our requirements, and ensure we can put in place regulatory resources when required.

In late March 2023, NWS informed us of changes to its target operating model (TOM) (the way it plans to operate) that resulted in changes to its GDF programme management and governance. At the same time, NWS began a further reorganisation of the GDF programme, with the objective of better aligning it to longer-term needs and better managing the inherent risk and uncertainty.

We engage with NWS at quarterly GDF programme meetings. The reorganisation of the GDF programme led to delays in some aspects of NWS’ work, including delays issuing many of the documents that we had expected to receive for scrutiny or information in 2023 to 2024. It also led to delays in completing business cases for the intrusive investigation and design and safety case development work for tranche 3 of the GDF programme. This is the period after the government has decided which sites to take forward for intrusive investigations, up until the time NWS is ready to start underground investigations at a selected site. NWS has informed us that these delays will not impact the major programme milestones as the activities are not on the critical path for the government’s decision on which site or sites to take forward for intrusive investigation, or the intrusive investigation environmental permit applications. However, we are monitoring the effects of these changes on the GDF programme, on important programme milestones, and on the efficiency of regulatory engagement.

We were updated on the NWS Technical Directorate reorganisation and the GDF programme re-baselining at a meeting in November 2023. However, as of March 2024, we were waiting for updated regulatory engagement plans and GDF programme information at the level of detail needed to plan our forward engagement in 2024 to 2025 and beyond, and to prepare for the intrusive investigation permit application.

First waste emplacement dates

NWS now considers the earliest that waste could be emplaced (deposited) in a GDF will be in the 2050s. This will be for the disposal of low heat generating waste, with the earliest possible date of 2050 only feasible if a simple host rock geology is available. This is later than 2040 or the 2040s which were used in NDA plans and as a planning assumption by the nuclear site licence companies. We advised NWS in September 2022^{[footnote 6]} to make sure that the NDA and waste producers were aware of current assumptions on the first waste emplacement dates, and to make sure that their decommissioning plans and export schedules are consistent with the GDF programme.

We met with NWS in April 2023 and January 2024 to understand how it is working with waste producers to develop a revised stores export schedule from the first waste emplacement dates onwards, and how decisions and governance of export plans would be carried out between NWS, the multiple waste producing organisations and the NDA. We confirmed that we were comfortable with the approach being taken and expect to see the conclusions of this work later in 2024.

Organisational capability and development

The developer/operator of a GDF should foster and nurture a positive organisational culture (promoting safety, security and environmental compliance) at all times. It should also have a suitable management system, organisational structure, and enough resources to provide essential functions (GRA Requirement 4^{[footnote 1]}, LC 17 and 36).

The Environment Agency needs to be confident that Nuclear Waste Services (NWS) can comply with environmental permit requirements before we issue environmental permits for borehole investigations at potential sites.

NWS must also continue to develop its organisational capability and management systems, so that it is capable of holding and implementing the necessary requirements of environmental permits and a nuclear site licence to construct and operate a GDF.

ONR recognises that NWS is not currently close to licensing a GDF, and its organisation is being developed for the next tranche of work. Our current focus is on providing advice on the management arrangements and processes needed to support a capable organisation in line with the requirements of our licence conditions. 

During 2023 to 2024, the Environment Agency and ONR continued with a programme of engagement with NWS on the development of its organisational arrangements to implement the GDF programme. The nature and frequency of these engagements was affected by the NWS Transformation Programme and the move to a single legal entity (SLE) comprising the former RWM Ltd and LLWR Ltd businesses, which came into being on 1 April 2024. Organisational development ‘keep in touch’ meetings were scheduled and attended, supported by topic-specific technical engagements on elements of NWS’ organisational arrangements. Following these engagements, where necessary, we provided NWS with written advice. 

NWS transformation to single legal entity status

NWS adopted target operating models (TOMs) in moving its organisational arrangements to SLE status. These models included shared functions and services across the new NWS SLE.

The Environment Agency and ONR received and assessed NWS’ management of change (MoC) documents for the move to SLE. We informed NWS that the MoC for integrating environment, health and safety, and independent assurance functions appeared reasonable and supported the changes. NWS identified a number of minor risks with mitigations; details of the implementation of the mitigations (by who, by when) will be defined once the MoC has been approved internally.

We also met with NWS to provide feedback on the MoC documents for establishing an integrated Technical Directorate. We signalled our intention to inspect arrangements later in 2024; our principal focus for this inspection will be on baseline roles, and securing adequate capacity and capability for implementing the GDF programme.

Throughout 2024 and 2025, we will continue to scrutinise the integration of arrangements across NWS and seek assurance that resources are adequately maintained and allocated across the NWS portfolio following the transition to SLE status.

Management arrangements

The GDF programme has employed consultants to review, and where necessary propose improvements to, its management arrangements as part of its preparations to apply for and potentially receive a permit to allow intrusive site investigation work to begin. Throughout 2023 to 2024 the Environment Agency engaged with NWS and its consultants on this work, reviewing the gap analysis that the consultants had prepared.

We noted to NWS the importance of establishing mature and effective arrangements for providing adequate organisational capacity and capability, in good time to support the development of an ISE permit application. 

Given the appointment of a Major Permissions Delivery Partner (MPDP) organisation to take much of this work forward, we let NWS know that we expect the GDF programme’s supplier audit and quality assurance arrangements to be sufficiently developed to assure the MPDP’s outputs.

We scrutinised a number of documents submitted to us relating to the GDF design process and issued a joint regulator letter to NWS with our advice. The letter included 3 recommendations to NWS that it should:

• set out the proposed structure and content of its management system document hierarchy supporting the development of the GDF and of relevance to environmental (and conventional, nuclear and security) safety and compliance
• provide regulators with a document production and submission schedule regarding the above
• make sure that its references to optimisation are clarified in its procedures and supporting design documents

Capability and competency

As part of our scrutiny of the management arrangements review and TOM implementation as described earlier, the Environment Agency provided written advice to NWS on the status of its strategic workforce plan, expressing concerns over the timescales for it to be completed. We recommended that NWS should provide:

• further clarification on its proposed arrangements to ensure that adequate capacity and capability is provided to support the development of an intrusive investigation permit application, and to prepare the organisation for complying with the conditions of that permit once it is issued
• an organogram or similar, setting out staff roles and structure, before and after becoming a single legal entity

We will follow up on these recommendations as part of our engagement activities with NWS in 2024 to 2025.

Preparing for intrusive investigations

As specified in our staged regulation process for geological disposal, NWS will need to apply to the Environment Agency for an environmental permit to carry out the drilling of deep site investigation boreholes. The applications must take full account of our environmental permitting requirements (GRA section 5^{[footnote 1]}). Based on current planning assumptions, we anticipate receiving applications for up to 2 sites in 2027 to 2028, and we are currently developing our guidance on staged regulation and the permitting templates (Regulatory preparations).

NWS will also require a Development Consent Order (DCO) to begin the intrusive investigations. The Environment Agency is a statutory consultee in this process.

Advice on major permissions

The Environment Agency are providing advice to NWS on our requirements for the intrusive investigation permit application and the supporting Initial Site Evaluation (ISE).

NWS issued us with its draft ISE template in April 2023. We attended a workshop with NWS to provide early feedback on the document and followed this up with written feedback. We concluded that the ISE template provides a good basis for further engagement between NWS and the Environment Agency to build a common understanding of regulatory expectations. However, we made 8 recommendations to NWS on information it should include within its ISE, as well as a number of minor comments and advice.

We advised NWS that we wish to continue to engage on its plans to address our feedback and our finalisation of our ISE guidance and permit template. We are pleased that NWS is taking this advice into account in its forward workplan and is developing a draft permit application and ISE for completion in early 2025 to 2026. This will give NWS an opportunity to test its procedures for the development of these regulatory submissions and will give us an opportunity to test our review processes.

The Environment Agency attended regular keep-in-contact and topic-specific meetings with NWS throughout the year. At these meetings, we informed NWS of progress we had made in developing relevant guidance and permitting templates.

We engaged extensively with NWS to understand its site characterisation plans, including the proposed number and locations of intrusive investigation boreholes for each site. We advised NWS that legislation allows flexibility in the way we might permit and regulate the number as well as the locations of intrusive investigation boreholes. We set out our regulatory approach in our draft staged regulation guidance and shared this with NWS for review and feedback. NWS welcomed the flexibility and proportionality embedded in the draft guidance.

We clarified our position on the definition of ‘site’, ‘understanding of baseline conditions’ and ‘requirements for surrender’ of an intrusive investigation permit. We also set out how we would regulate changes to the NWS site characterisation plans. For example, we may use pre-operational or information permit conditions or variations to the Compilation of Environment Agency Requirements document. These engagements helped NWS to understand our future regulatory requirements and gave us a better understanding of its major permissions programme.

ONR is not the safety regulator for the drilling of the deep site investigation boreholes, and it has advised that NWS should engage with the Health and Safety Executive (HSE). If early engagement with HSE is not possible, ONR considers it likely that NWS will have to formally notify HSE of the intended construction work under the Construction (Design and Management) Regulations 2015. HSE will then consider the appropriate regulatory approach. ONR will review NWS’ approach to this construction work at an appropriate time to inform our assessment of any future nuclear site licence application.

Site evaluation

NWS started its site evaluation and comparative assessment work programme in 2022 to 2023. It shared with us the processes that it will follow to identify and evaluate potential GDF sites. The site evaluation process considers safety, environment, transport, security and safeguards, engineering feasibility and value for money in each potential area.

Regulators are independent of the evaluation process, but we will provide advice on matters relevant to our respective regulatory remits.

NWS is developing site descriptive models (SDMs) for Copeland and Theddlethorpe. These will provide the data required to underpin the evaluation topics, for example, geological, hydrogeological and geotechnical data, and identify information gaps and uncertainties that it will need to address in its developing safety cases. The SDMs will be based on desk-based information, the results of a marine seismic survey of the geology in the inshore region off the Copeland coast during summer 2022, and the results from legacy seismic surveys in the Copeland and Theddlethorpe regions that NWS has purchased and reprocessed.

The Environment Agency received initial (v0) versions of the SDMs for Copeland and Theddlethorpe, which we reviewed for internal capability building. We met with NWS in October 2023 to understand its programme for developing subsequent versions and how the SDMs will inform development of the site characterisation plans (SCPs) and the intrusive investigation permit application.

NWS presented early outputs from its Copeland seismic survey (geometric interpretation) in 2023 to 2024. It is carrying out further work to describe properties of the Triassic Mercia Mudstone Group (MMG), which is the potential host rock in Copeland, and to assess how they could vary vertically and laterally. Supporting work includes analysing oil and gas well cuttings to obtain geochemical, petrophysical, mineralogical and possibly rock property data (porosity and permeability).

We visited the British Geological Survey (BGS) in Keyworth in March 2024 to get an update on its technical support to NWS’ site characterisation activities. We visited the BGS core store to view samples of relevant host rocks, including the MMG (Copeland) and the Jurassic clays of the Ancholme Group (Theddlethorpe).

We expect to receive updated versions of the SDMs (v0.1s) in autumn 2024. NWS will use these versions to support community decision-making. We will scrutinise these documents in the context of the future intrusive investigation permit applications. We also wish to review NWS’ SDM manual and the processes and procedures for managing data flow between the SDM and models underpinning the site evaluation ahead of the permit applications. 

Site investigation programme development

The Environment Agency expect NWS to have appropriate plans and procedures in place to carry out the site investigation and characterisation work needed to implement geological disposal, and to inform the safety cases and GDF design and construction (GRA Requirement 11^{[footnote 1]}). At this stage, we want to make sure that NWS’ plans and actions for future site investigations are consistent with our permit requirements and would not compromise the integrity of potential GDF sites.

NWS is developing its plans for site investigation activities. We have engaged with NWS during 2023 to 2024 to understand its plans for intrusive investigation. We are using these plans to inform our intrusive investigation permit template and guidance development work. We reviewed NWS’ developing site characterisation strategy and basis of borehole design to inform our ongoing engagement. We also met with NWS in October 2023 to learn about its:

• approach to developing the strategy for the long-term monitoring of boreholes
• approach to demonstrate that it will maintain site integrity throughout borehole investigations, underground investigation and construction
• development of the SCPs
• data flow process between the SDM and underpinning models/work areas (in particular, the environmental safety case (ESC) and design development) and the site characterisation work

These areas of work will provide important lines of evidence supporting the intrusive investigation permit applications.

NWS provided us with a summary of its developing claims, arguments and evidence structure for borehole sealing. We provided feedback on this report, noting that the structure of the 5 claims presented in the report, which are supplemented by the supporting sub-claims, appears viable. We identified a number of topics for further engagement during the period leading up to intrusive investigation permit applications. These included:

• how the borehole sealing claims, arguments and evidence will fit into NWS’ claims, arguments and evidence for the overall environmental safety case, and how interdependencies will be managed
• NWS’ plans for moving from generic to site-specific plans for borehole sealing
• the impact of saline groundwater on sealing technologies
• the main uncertainties at this stage of the project
• the borehole sealing forward programme

GDF development

NWS’ applications to develop a GDF must take full account of our environmental permitting requirements (GRA section 5^{[footnote 1]}) and the duties placed on operators of a licensed nuclear site (nuclear safety, security, safeguards, radioactive materials transport, and conventional health and safety).

NWS’ understanding and interpretation of the full range of relevant legislation and guidance should be consistent with our expectations (GRA Part 2^{[footnote 1]}, Licensing Nuclear Installations). It should also be aware of new and emerging regulations.

Any application for an environmental permit relating to a proposed disposal of solid radioactive waste must be supported by a suitable environmental safety case (ESC)^{[footnote 1]}. Similarly, any application for a nuclear site licence to construct and operate a GDF will need to be supported by adequate demonstrations of safety and security^{[footnote 7]}.

We want to establish a clear and common understanding with NWS of the requirements of permit and licence applications to make sure that any future applications take full account of our regulatory requirements.

Our engagement during 2023 to 2024 focused on understanding the strategic framework NWS is developing to guide its GDF design and safety case development. We also progressed several outstanding Regulatory Issues and Observations and carried out some topic-specific engagement.

Strategy for GDF design and safety case development

We provided written advice to NWS on its GDF design principles, which provide the framework for the development of a GDF Design Authority (Management arrangements). Following this, in October 2023, NWS gave us a high-level overview of its GDF: 

• system model, sponsor’s and system requirements
• model-based systems engineering strategy and roadmap
• design strategy handbook
• plans for ongoing maintenance of the generic disposal system safety case (gDSSC) and transition to waste acceptance criteria (WAC)

We received the GDF design strategy handbook, which describes the high-level technical strategies through which NWS will implement the design and safety case for the GDF, for scrutiny in March 2024. This document will help guide engagement on GDF design and safety case development. The Environment Agency provided written feedback to NWS on the document in early 2024 to 2025.

Safety case development

We have several open Regulatory Issues (RIs) and Regulatory Observations (ROs) in this area. NWS reported progress against 2 of these during 2023 to 2024.

NWS issued a response to GDF_RO_006 on data and models in August 2023^{[footnote 8]}. The Environment Agency and ONR carried out an inspection in October 2023, which covered NWS’ response to the RO, its procedures for managing technical data, its modelling strategy and the results of an internal audit of GDF programme computer modelling procedures. We were unable to formally audit any documents or procedures because NWS could not access its document management system at that time due to ongoing IT system migration. However, at a separate workshop later that month, NWS was able to show us its procedures and audit trail for change control, giving us confidence in the system. These interactions gave us sufficient confidence in NWS’ forward programme to allow us to close the RO. However, we will continue to engage with NWS on this topic, and data management and running models will be subject to a future inspection at an appropriate time before the intrusive investigation permit application. We closed the RO in early 2024 to 2025.

NWS provided the Environment Agency with a response to GDF_RI_014 on operational environmental safety assessment in May 2023^{[footnote 9]}. We reviewed the response and asked for copies of supporting references before formally responding. We had not received copies of all the requested documents by the end of this reporting period. However, we did receive and provide comment on one of the supporting references; the document specification for the generic preliminary safety report (gPSR). The gPSR is the next stage in NWS’ development of its operational safety case (OSC), building on the 2016 generic OSC. The Environment Agency would not normally offer regulatory advice on the specification of a document supporting the OSC as this is a matter for ONR. However, NWS includes operational environmental safety in the scope of the gPSR. We made 7 recommendations to NWS on aspects that it should manage if operational environmental aspects of the ESC are included in the gPSR, including the need to assess operational environmental safety in a way that is consistent with post-closure environmental safety.

We met with NWS on several occasions during 2023 to 2024 to discuss technical topics relevant to GDF safety case development.

In May 2023, NWS presented its approach to identifying external hazards that could present a risk to the viability of a GDF in a particular location, including its developing flood hazard management strategy. Based on the information available, NWS believes that flood risks are manageable in all its siting areas, but it will work with regulators to develop its approach to climate change adaptation. The Environment Agency advised NWS to consider the operational, closure and post-closure periods when planning for sea level rise and flooding.

In June 2023, NWS presented its position on the role of underground investigations and the form these might take. It has developed an ‘experimental hierarchy’ – starting with desk and surface-based work, progressing to laboratory research, then making use of generic underground research laboratories (URLs) and finally site-specific underground investigations. The Environment Agency advised of the importance of URLs in building stakeholder confidence (for example, with respect to GDF design, construction and developing experimental and technology demonstration programmes) as well as obtaining site-specific data and technology demonstration. We noted that no international URLs provide a good analogue for the Mercia Mudstone Group (MMG), and we advised NWS to work with other organisations to obtain data and samples of MMG, recognising its heterogeneity. We wish to continue to engage with NWS on this topic as its plans develop.

NWS presented its approach to assessing features, events and processes (FEPs) and developing scenarios and variants for the safety assessment in October 2023. We are waiting for supporting documents on this work before providing regulatory feedback.

Waste management

Waste producers are responsible for appropriately characterising, treating and packaging higher activity waste (HAW) to meet the expected waste acceptance criteria of a GDF. The operator of a GDF (along with the consignee) will be responsible for making sure that the consigned waste is consistent with the eventual GDF waste acceptance criteria, including transport and handling (GRA Requirement 13^{[footnote 1]} and LC 4).

NWS operates its disposability assessment process to reduce risk in the waste treatment and packaging process, and to assess whether packaging proposals are compatible with the current geological disposal concept and designs. Through this process, NWS provides disposability advice to waste producers and potential waste producers on the packaging of their HAW.

We expect NWS to assess packaging proposals for HAW against clear and consistent published specifications and guidance. This is to assure us that NWS disposability advice is underpinned and clearly traceable to its developing GDF requirements and safety case. In turn, we expect waste producing sites to use this advice to make appropriate decisions, consistent with best available techniques (BAT) and as low as reasonably practicable (ALARP) principles for the whole waste lifecycle, to ensure that HAW is suitably packaged for handling, transport to, and disposal in a GDF. We expect NWS to work effectively with waste producers, particularly where there is a need to understand and help resolve tension between nearer-term waste management priorities on existing nuclear sites (such as site hazard reduction) and longer-term disposability priorities. We also expect NWS to share good practice in waste packaging to avoid duplication of effort. We engage with NWS to build confidence that:

• HAW will be packaged in a way that is suitable for transporting to, handling and disposing of, at a GDF in line with the safety case and with no, or minimal, reworking
• HAW will be conditioned to a safe, passive, transportable and disposable form as soon as is reasonably practicable
• NWS’ procedures, guidance, specifications and limits encompass the full range of wastes destined for geological disposal and are likely to ensure compliance with permit requirements so that they are acceptable for disposal

Disposability assessment

NWS continued to evolve its disposability assessment process. We welcome NWS’ emphasis on earlier technical discussion to support waste producers in the early stages of considering waste management treatment and storage options, particularly for more technically challenging waste streams. We also welcome the effective collaboration between NWS and waste producers.

NWS informed the Environment Agency and ONR in March 2024 of its prioritised plan to update all its guidance for waste packaging and to make this more easily accessible via an industry shared webpage for waste producers from late 2024 to 2025.

NWS also works with the Nuclear Decommissioning Authority (NDA) and the waste producers as part of the NDA-led Disposability Risk Management Group. This group was set up to ensure an appropriate balance between competing requirements through the full lifecycle of the waste (from waste retrieval and packaging at sites, through to onsite storage, transport to GDF and operational and post-closure repository performance). We are monitoring the organisational changes that have affected the running of this group during 2023 to 2024. The group is considering some test cases and, although progress has been slow, we expect the initial conclusions on these to be shared with regulators for consideration in 2024 to 2025. NWS also briefed us in May 2023 on its developing thinking on how to demonstrate BAT and ALARP for GDF development, and we will continue to review further developments as part of our ongoing scrutiny programme.

Integration of disposability assessment with GDF systems engineering

We have 2 open Regulatory Issues (RIs) in this area. GDF_RI_005 is on the assessment of innovative packaging proposals and their impact on NWS’ disposal system technical specification and safety case^{[footnote 10]}. GDF_RI_010 is on the sensitivity of waste packaging assessments to changes in the GDF design or safety case^{[footnote 11]}. Together, these issues were raised to give us confidence that developments in waste packaging advice to nuclear sites and the GDF concept design and safety assessments are kept in step with one another.

We carried out an inspection in October 2023 at NWS’ offices in Harwell to assess progress with both RIs. NWS has made progress in significant areas relating to the original 2 issues, and we expect to close these and open a new RI cross-referring to updated actions from our inspection in early 2024 to 2025. This represents a good step forward and maintains clarity on the main aspects that are relevant at this stage of the GDF programme.

Waste package records and assurance

For waste packages and records that have already been produced, NWS continues to develop its approach to assurance through its periodic review and cross-cutting review processes. These processes are designed to maintain confidence in the disposability of the wastes through their interim storage period, and to ensure that adequate waste records are preserved to enable future disposal.

In September 2023, the Environment Agency and ONR received an update on the NDA’s waste package records programme and governance from NWS and NDA. We held a workshop with NWS and NDA in January 2024 to review the latest position on assurance of waste records and the management of waste records. This also informed our site inspection of waste records at Sellafield, and NWS joined us in this inspection. We will continue to scrutinise waste records and records assurance processes to ensure effective preparation and management of waste records that are necessary for future waste transport and disposal to a GDF.

Disposability of high heat generating waste

High heat generating waste is a category used by NWS for the most hazardous wastes in the inventory for disposal to a GDF. This includes spent fuel from existing and future power stations and high-level waste from spent fuel reprocessing. High fissile wastes (plutonium and high enrichment uranium) are also included in this group as they have similar disposal requirements even though they don’t generate significant amounts of heat.

Now that fuel reprocessing has stopped at Sellafield, there is increasing focus on expert technical advice from NWS about the disposability implications of alternative interim storage and potential treatment options for spent fuel. To develop our regulatory understanding of the disposability considerations for potential treatment and packaging options for spent fuel, we reviewed NWS’ early stage spent fuel disposability assessment reports (issued in 2021 and 2022). The Environment Agency and ONR have maintained our engagement with NWS on its spent fuel assessment work and expect a further disposability assessment report in autumn 2024. We plan to review this to support our advice both to NWS and to Sellafield/NDA on the long-term strategy for spent fuel management.

In 2022 to 2023, NWS produced an interim position paper on plutonium disposal options as an input to NDA on its plutonium disposition paper to government. We have continued our engagement with NWS on its development of plutonium packaging options and associated criticality safety modelling.

The Environment Agency and ONR participated in 2 technical workshops led by NWS in April and July 2023 to better understand its baseline assessment of both the likelihood and consequences of a potential criticality event in a GDF after the facility has closed. A further workshop was held in September 2023 with NWS and its contractors to provide regulators with an overview of ongoing developments in NWS’ criticality safety assessment methodology. NWS is developing some case studies to support further review of this work during 2024.

The Environment Agency and ONR assessed the interim pre-conceptual designs for potential disposal packages for the UK’s bulk plutonium inventory and provided advice to NWS on its forward programme towards developing a more mature disposal package specification.

Disposability of low heat generating waste

Low heat generating waste refers to the rest of the inventory for geological disposal (that is, the majority by volume that is not high heat generating). NWS has continued to provide disposability advice to waste producers on relevant packaging proposals for these waste streams. In 2023 to 2024, our engagement with this work was primarily through our site regulation rather than scrutiny of NWS, and, therefore, is not reported here.

One aspect of regulatory interest is the approach to specifying and managing acceptable levels of voidage within waste packages. This is a characteristic of waste packages that is potentially important to the long-term environmental safety of a GDF, but its significance is very uncertain and depends on the characteristics of the particular GDF site and the associated engineering design. The Environment Agency met with NWS in December 2023 to discuss its developing guidance for waste producers on the presence of voidage within waste packages destined for the GDF. We reviewed a draft of this guidance and will provide our initial feedback and advice to NWS on its further development of this guidance in early 2024 to 2025.

NWS’ research, development and demonstration

The developer and operator of a GDF needs to carry out timely research, development and demonstration (RD&D) to inform its activities and ensure it fulfils its obligations, such as demonstrating optimisation to keep doses from radiation as low as reasonably achievable/practicable (ALARA/ALARP).

We expect NWS to have a targeted and prioritised RD&D programme in place, informed by wider national and international research or implementation programmes. NWS will need to identify and address in a timely way those issues that require RD&D to meet our requirements. NWS should be clear, through its management process, why the RD&D it carries out is needed and what knowledge gaps it will fill.

We raised concerns in 2021 to 2022 that significant cuts to the RD&D budget due to GDF programme budgetary constraints would increase programme risk as a result of a reduction in information needed to substantiate future safety case claims and arguments^{[footnote 12]} . NWS subsequently informed us that it is reorganising its RD&D activities to more closely match the needs of the GDF programme.

The Environment Agency asked NWS for further engagement on its RD&D strategy, programme and prioritisation during 2023 to 2024, but this engagement did not take place. We will continue to press for engagement on this topic in 2024 to 2025 and will encourage NWS to publish its RD&D programme regularly, like many other international waste management organisations (for example, SKB in Sweden).

The NWS Research Support Office (RSO) is a dedicated office that supports the provision of independent evidence-based research to underpin implementation of a GDF. In January 2024, the Environment Agency attended the RSO annual conference in Sheffield to hear about progress in significant research areas and future plans.

In autumn 2023, the Natural Environment Research Council (NERC) and NWS started a 4-year joint-funded research programme on geological disposal of radioactive waste (GeoDRAW). The strategic drivers for this programme are to:

• understand fundamental knowledge gaps around the geology, hydrogeology and controls on subsurface properties of lower strength sedimentary rock (LSSR) to understand and predict how radioactive waste could be disposed of in a way that is not harmful to the environment or human health
• provide supporting evidence relevant to sub-surface energy, for example, carbon capture and storage and other energy vectors which may also rely on engineering within LSSR
• support development of the specific skills and technical capability to support the developing geological disposal programme in the UK

The Environment Agency is represented on the Programme Executive Board and will make sure that our regulatory drivers are recognised by the programme team.

Summary

The Environment Agency and ONR engaged with NWS during 2023 to 2024 to provide pre-application advice and scrutiny of its developing GDF programme, as well as to prepare for future regulation and to support the siting process.

NWS reorganised the GDF programme during 2023 to 2024, with the objective of better aligning it to longer-term needs and managing the inherent risk and uncertainty associated with such a programme. This led to delays in some aspects of NWS’ work, including delays issuing many of the documents that we had expected to receive for scrutiny or information. NWS informed us that these delays would not impact the major programme milestones. However, at the end of 2023 to 2024, we advised NWS that we did not have detailed enough GDF programme information to plan our forward engagement for 2024 to 2025 and beyond and to prepare for the intrusive investigation permit application. We also noted some important gaps in our engagement, for example, relating to progress on site evaluation and its RD&D programme. We will continue to engage with NWS in 2024 to 2025, including to establish this level of detail.

Our pre-application advice and scrutiny during 2023 to 2024 included:

• scrutiny of the integration of management arrangements as the former LLWR Ltd and RWM Ltd businesses became a single legal entity on 1 April 2024
• engaging on the arrangements being developed for NWS to hold an intrusive investigation permit
• advising NWS on the scope and content of its Initial Site Evaluation (ISE) that will accompany an intrusive investigation permit application
• engaging on NWS’ developing site descriptive models and site characterisation plans that will underpin a future permit application
• gaining confidence in NWS’ procedures for managing technical data, modelling strategy/procedures and change control
• advising NWS on our requirements for assessing environmental impacts during the operational period of a GDF
• observing progress on NWS’ assessment of innovative packaging proposals on its safety case, and on the sensitivity of waste packaging assessments to changes in the GDF design or safety case
• limited engagement on NWS’ RD&D strategy, programme and prioritisation, with the expectation of increased engagement in 2024 to 2025

Regulators have no role in the siting process for a GDF. However, we have continued to attend events in the community partnership areas to explain our role in geological disposal and our regulatory processes. We also hold our own stakeholder engagement events throughout the year at which geological disposal is discussed.

The Environment Agency is continuing its preparations for regulating the early stages of GDF development. We are producing a new guidance document on staged regulation of a GDF, which will go to public consultation in autumn 2024, and we are developing a bespoke permit template. We continue to review and develop our capability to ensure that we can regulate a GDF over the coming decades, starting with getting ready to permit intrusive investigations.

Annex A: List of Regulatory Issues and Observations

Regulatory Issue	Title	Status
GDF_RI_001	Leadership and governance	Closed
GDF_RI_002	Organisational capability	Closed
GDF_RI_003	Control and assurance	Closed
GDF_RI_004	Organisational learning	Closed
GDF_RI_005	Assessment of innovative packaging proposals	Open
GDF_RI_006	Resolution of periodic review findings	Closed
GDF_RI_007	Assurance of packaging assessments and advice	Closed
GDF_RI_008	Board governance of important areas of risk/performance	Closed
GDF_RI_009	Corporate Health, Safety, Security, Environment and Quality (HSSEQ) structure	Closed
GDF_RI_010	Disposability assessments and endorsements sensitive to changes	Open
GDF_RI_011	Waste package records	Closed
GDF_RI_012	Workforce capability plan	Closed
GDF_RI_013	Characterisation and assessment of the non-radioactive component of waste in the inventory for disposal	Open
GDF_RI_014	Operational environmental safety assessment	Open
GDF_RI_015	Approach to fire safety assessment	Open

Regulatory Observation	Title	Status
GDF_RO_001	Protection against non-radiological hazards	Closed
GDF_RO_002	Optimisation	Closed
GDF_RO_003	Lessons from the Fukushima disaster	Closed
GDF_RO_004	Defining waste package fissile limits for disposal	Closed
GDF_RO_005	Lessons from the Waste Isolation Pilot Plant (WIPP)  incident	Closed
GDF_RO_006	Building confidence in data and modelling	Open
GDF_RO_007	Auditable evidence in support of an environmental safety case (ESC)	Closed
GDF_RO_008	Defining waste package fissile levels	Closed

References

1.  Environment Agency and Northern Ireland Environment Agency, February 2009. Geological disposal facilities on land for solid radioactive wastes: Guidance on Requirements for Authorisation. [Accessed 11 September 2024]. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰

2. ONR, March 2023. Technical Assessment Guide. Geological disposal https://www.onr.org.uk/operational/tech_asst_guides/ns-tast-gd-101.docx. Revision 1.3. [Accessed 11 September 2024]. ↩

3. ONR, January 2020. Safety Assessment Principles for Nuclear Facilities ONR CM9 Ref 2019/367414. 2014 Edition, Revision 1. [Accessed 11 September 2024]. ↩

4. ONR, March 2022. Security Assessment Principles for the Civil Nuclear Industry. 2022 issue, version 1. [Accessed 11 September 2024]. ↩

5. Department for Energy Security and Net Zero, Scottish Government, Welsh Government and Northern Ireland Department of Agriculture, Environment and Rural Affairs (May 2024) Managing Radioactive Substances and Nuclear Decommissioning: UK policy framework. [Accessed 11 September 2024]. ↩

6. Environment Agency and ONR. Regulatory scrutiny and engagement for geological disposal. Annual report 2022 to 2023. Regulatory scrutiny and engagement for geological disposal: annual report 2022 to 2023. [Accessed 11 September 2024]. ↩

7. ONR, 2021. Licensing nuclear installations. ↩

8. Environment Agency and ONR, 2017. Building confidence in data and modelling. Regulatory Observation GDF_RO_006. ↩

9. Environment Agency, 2018. Operational Environmental Safety Assessment. Regulatory Issue GDF_RI_014. ↩

10. Environment Agency and ONR, 2022. Assessment of innovative packaging proposals and their impact on the Disposal System Technical Specification and Safety Case. Regulatory Issue GDF_RI_005. ↩

11. Environment Agency and ONR, 2020. Disposability assessments and endorsements sensitive to change. Regulatory Issue GDF_RI_010. ↩

12. Environment Agency and ONR. Regulatory scrutiny and engagement for geological disposal. Annual report 2021 to 2022. Regulatory scrutiny and engagement for geological disposal: annual report 2021 to 2022 [Accessed 11 September 2024]. ↩