Guidance

Radioactive substances management: generic developed principles

Updated 2 May 2024

Applies to England

In this document we describe in general terms how an operator should manage the radioactive substances it uses including any wastes that it creates, manages and disposes of – radioactive substances management developed principles (RSMDPs).

We expect operators to have sufficient relevant information about its radioactive substances and a written strategy for their management.

We expect an operator to do its best – what we describe more formally as using ‘best available techniques’ (BAT) - when using radioactive substances to minimise the amount of waste created and disposed of, taking into account costs and benefits.

We also describe in this document more specific requirements on issues such as avoiding the production of waste, the storage and disposal of waste, and record keeping.

These principles apply to all the organisations that we regulate as radioactive substances activities but the level of detail to which an organisation should be expected to comply with them depends on the scale of the organisation’s radioactive substances operations.

For example, on a nuclear licensed site a strategy for the management of radioactive substances (RSMDP1) may be large and complex and will need to be described in one or more substantial documents (for example, an integrated waste strategy (IWS) document). At a small laboratory where small quantities of radioactive substances are used a radioactive substance management strategy can be very simple and described in 1 or 2 pages.

RSMDP1 – radioactive substances strategy

A strategy should be produced for the management of all radioactive substances.

Considerations

The strategy should ensure that for human health and the environment an optimal level of protection is achieved and maintained; and that impact and risks have been optimised taking into account all relevant factors including:

• worker and public safety (including radiological risks)
• security
• technical capability
• burdens on future generations
• precautionary principle
• use of resources
• stakeholder views
• cost

The strategy should be integrated so as to take into account all matters that might have a bearing on the management of radioactive substances. Such matters include:

• how the creation of radioactive waste will be prevented, and where that is not practicable minimised, including taking opportunities for recycling and reuse, through application of the waste management hierarchy
• how the unnecessary introduction of radioactive waste into the environment will be avoided
• the requirement that radioactive wastes are safely disposed of, at appropriate times and in appropriate ways
• relevant radiological risk assessments
• the requirement that predicted impacts on future generations, including health, will not be greater than relevant levels of impact that are accepted today
• the use of the BAT to prevent, and, where that is not practicable, generally to reduce emissions and the impact on people and the environment as a whole
• all radioactive wastes arisings, including those from operations, decommissioning and site restoration
• actions having irreversible consequences including inadvertent actions
• the desire to dispose of waste in near-by facilities, where available, so as to minimise the environmental impact of transport
• how the characterisation, segregation and categorisation of wastes will be undertaken
• how progressive reductions in discharges will be achieved consistent with the UK Discharge Strategy including identifying any cases needing short term increases in discharges
• constraints imposed by existing facilities and proposed developments the predicted future pattern of radioactive waste arisings, disposals and discharges
• how, during development, a range of appropriate options will be considered, documented and the chosen options substantiated
• how and when BAT assessments will be undertaken
• the outcomes of BAT assessments
• how on site and off site interdependencies, for example, between processing facilities, have been taken into account
• that each step in the management of radioactive substances should be compatible with all other steps including pre-treatment, treatment, storage, disposal, handling, and on-site and off-site transport
• how existing inventories and future arisings of radioactive wastes will be managed to avoid or minimise further processing and secondary wastes
• how creation of waste, incompatible with current disposal techniques or developing techniques likely to be successful, will be prevented
• where wastes have already been produced which are likely to be incompatible with current disposal techniques, how these will be managed and solutions identified or developed
• how relevant stakeholders will be engaged
• how uncertainties and risks relating to the achievement of the strategy will be identified and managed
• the management system for radioactive substances
• the radioactive properties of the substances including decay and in-growth
• the non-radioactive properties of the radioactive substances including their physical, chemical and biological properties
• anticipated timescales for the management of radioactive substances
• monitoring of radioactive substances and the environment

The strategy should seek to be consistent with government Policy, UK international commitments, and regulatory and other relevant requirements. Any inconsistencies should be identified, explained and justified.

When developing the strategy a proportionate approach should be adopted taking into account the scale and scope of use of radioactive substances.

The strategy for the management of radioactive substances should be consistent with all other relevant strategies.

The strategy should avoid disproportionate adverse environmental effects, for example in terms of use of raw materials or energy, or in the generation of non-radioactive wastes.

The strategy should be developed as part of the planning stage for new facilities and, for existing facilities, as part of the review of existing plans.

The strategy should be reviewed periodically and following significant internal and external changes.

The strategy should be consistent with the operator’s policy, principles and objectives with regard to radioactive substances.

The strategy should set out all relevant information, including:

• uncertainties
• risks
• assumptions
• exclusions
• key decision points

The strategy should include requirements for its own review for example being reviewed every few years and more often if necessary to take into account:

• changes in legislation or policy
• new facilities and substantial changes to existing facilities
• new scientific and technical knowledge
• technical developments

RSMDP2 – justification

Radioactive wastes shall not be created unless the practice giving rise to the waste has been justified (in advance for new practices).

Considerations

The principle of justification can be stated as: “no practice involving exposures to radiation should be adopted unless it produces sufficient benefit to the exposed individuals or to society to offset the radiation detriment it causes”.

‘Justified’ in relation a class or type of practice means justified by its economic, social or other benefits in relation to the health detriment it may cause.

Under the relevant regulations, government departments are responsible for consideration of justification.

A list of existing justified practices is maintained by government.

Justification can be reviewed for existing practices if significant new information about the benefits or detriments of the practice becomes available.

RSMDP3 – use of BAT to minimise waste

BAT should be used to ensure that production of radioactive waste is prevented and where that is not practicable minimised with regard to activity and quantity.

Considerations

Processes creating radioactive materials should be chosen and optimised so as to prevent and where that is not practicable minimise the production of radioactive waste at source over the complete lifecycle of the facility.

Processes handling, treating or storing radioactive substances should be chosen and optimised so as to prevent or where that is not practicable minimise the production of secondary radioactive wastes over the complete lifecycle of the facility.

The process of optimisation to minimise the radioactive waste produced should:

• be done as part of a waste strategy
• use option studies, particularly for proposed new facilities or proposed modifications to existing facilities
• use BAT

Considerations during optimising should include choice of process; design including choice of materials, structures, systems and components; manner of operation including supervision, maintenance and training; and manner of commissioning and decommissioning.

Considerations should also include reuse and recycling of materials and wastes, in accordance with the waste hierarchy.

Radioactive materials and wastes should be properly contained using BAT so as to avoid spread of radioactivity and contamination of other materials.

Processes producing radioactive waste should be reviewed at intervals to identify opportunities to further minimise waste production.

RSMDP4 – methodology for identifying BAT

The best available techniques should be identified by a methodology that is timely, transparent, inclusive, based on good quality data, and properly documented.

Considerations

The process to identify BAT should be carried out by competent, properly informed personnel who have relevant expertise and involve strategic decision makers.

The resources used in the process to identify BAT should be proportionate to the environmental benefits or potential environmental benefits to be derived.

The process to identify BAT should be initiated:

• for new sites or facilities at an early stage when options are being conceived, evaluated and decided on
• for existing sites or facilities, when modifications to scope or function are proposed or expected and when options are being conceived, evaluated and decided on
• when there are significant reasons to believe that substantially better options might be available
• on a periodic basis

The process to identify BAT should be transparent such that:

• the process is properly documented and be capable of review
• the decision to be made is clear
• the scope of the study is clear and that all boundaries and constraints relevant to the decision to be made are set out
• all assumptions are set out plainly, together with the data and basis on which they have been made
• sufficient information is provided to confirm the validity of all data used
• the conclusion arrived at has integrity – it is rational, equitable and defensible

The process to identify the BAT should be inclusive such that the extent to which stakeholders are involved reflects:

• the technical and societal significance and human health and environmental implications of the decision
• the information that stakeholders can bring to the process
• what the impact on the process and its conclusion might be of a wider range of stakeholder perspectives, established for example through sensitivity studies
• whether stakeholder ‘ownership’ of the process is an objective
• the need for wider confidence in the process

The process to identify BAT should use good data and in particular:

• all data should be at a level of detail that ensures that it is fit for purpose
• relevant information and data should be identified and considered
• where there is significant uncertainty about the data used this shall be taken account of within the process
• where there is significant uncertainty in key data associated with particular options then it may be appropriate that such options are screened out of further consideration at an early stage, or further work to reduce the uncertainty is undertaken, or that a range of conclusions are reached dependent on the outcome of such uncertainties

The process to identify BAT shall be properly documented such that there is sufficient detail to support the conclusions reached.

RSMDP5 – actions having irreversible consequences

Actions with radioactive substances having irreversible consequences should only be undertaken after thorough, detailed, consideration of the potential consequences of those actions and of the other available options. The best available techniques should be used to prevent irreversible consequences from occurring inadvertently.

Considerations

Preference should be given to preventing and minimising releases by concentrating and containing activity rather than by relying on dilution and dispersion of the release, particularly for radionuclides that have long half-lives and accumulate in the environment.

BAT should be used to prevent releases of radioactive substances being made inadvertently including via leakage.

Where leakage has occurred, BAT should be used to prevent the migration of activity.

RSMDP6 – application of BAT

In all matters relating to radioactive substances, the ‘best available techniques’ means the most effective and advanced stage in the development of activities and their methods of operation.

Considerations

‘Available techniques’ means those techniques that have been developed on a scale that allows their implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced inside the UK, as long as they are reasonably accessible to the operator.

‘Best’ means the most effective in achieving a high general level of protection of the environment as a whole.

‘Techniques’ includes everything that has a bearing on the benefits to be derived, for example:

• the selection of a process to be used
• the design of facilities and systems
• the detailed implementation of facilities and systems
• how it is managed, operated and maintained

Consideration of what are BAT should be carried out on a case by case basis at each decision point where options exist.

What is BAT is specific to the circumstances that exist at each specific decision point. Decisions should be informed by relevant guidance and good practice, wider experience and developments, for example, at facilities elsewhere.

A technique will not be BAT if its costs are grossly disproportionate to its environmental benefits. Costs include time, trouble, money and all other resources. All benefits and potential benefits should be taken into account.

Where a statutory obligation requires stricter conditions and limits than those achievable by the use of BAT, then additional measures should be applied.

If any benefit or reduction in detriment, however small, can be achieved using few or no additional resources then it should be secured.

There is no threshold to dose, or any other detriment including environmental risk or contamination, below which no further consideration of what are BAT is required.

In determining BAT, an operator needs to achieve a balance across safety and environmental, societal and economic issues.

RSMDP7 – BAT to minimise environmental risk and impact

When making decisions about the management of radioactive substances, the best available techniques should be used to ensure that the resulting environmental risk and impact are minimised.

Considerations

Examples of decisions that concern environmental risk and impact include:

• when specifying the resources and expertise necessary to properly design, construct, commission, operate, maintain and decommission a system, facility or site
• decisions at the detailed design stage, when implementing the option has been determined to be BAT
• at the procurement stage, when materials are being specified and purchased
• when specifying maintenance schedules
• at the operational level, for example when deciding whether a specific batch of aqueous effluent should receive further treatment to reduce activity
• during facility perturbations, for example when deciding on actions to return the facility to its usual state or performance

RSMDP8 – segregation of wastes

The best available techniques should be used to prevent the mixing of radioactive substances with other materials, including other radioactive substances, where such mixing might compromise subsequent effective management or increase environmental impacts or risks.

Considerations

The requirements of subsequent radioactive substance management steps through to disposal should be considered before mixing radioactive substance streams, including with other materials. Such steps include the ability to store, characterise, retrieve, treat, condition, and dispose.

Segregation of radioactive substances should be addressed when designing new facilities.

Mixing of radioactive substances should be prevented where the mixing is with other substances or materials with incompatible physical or chemical properties.

Mixing of radioactive substances, including with other materials, may be undertaken where this facilitates subsequent management.

Mixing of radioactive wastes to increase their total volume should only be carried out when it is a stage in the use of the BAT to manage the wastes.

The degree to which wastes that are already mixed should be segregated should be determined as part of the assessment of what are the BAT to manage the wastes.

RSMDP9 – characterisation

Radioactive substances should be characterised using the best available techniques so as to facilitate their subsequent management, including waste disposal.

Considerations

Characterisation should provide sufficient information, including physical, chemical, radiological and biological properties and inventory, to properly inform decisions and reports.

Characterisation is required to properly inform decisions about, for example, design, operation, maintenance and decommissioning of facilities; handling, storage, processing and transport of radioactive substances, and the disposability of wastes.

Characterisation should be carried out:

• where there is a lack of sufficient information or knowledge
• where information might be out of date or properties changed
• for quality assurance or checking
• at stages in a process when information can be optimally assessed, for example with regard to minimising measurement uncertainties, or where otherwise information might be lost

RSMDP10 – storage

Radioactive substances should be stored using the best available techniques so that their environmental risk and environmental impact are minimised and that subsequent management, including disposal is facilitated.

Considerations

This principle applies to radioactive wastes and materials that may become or give rise to radioactive wastes in the future.

Radioactive substances should be stored in a passively safe state that minimises the need for further treatment. In this state the substances will be:

• immobilised in a form that is physically and chemically stable
• stored in a manner that minimises the need for, control and active safety systems, maintenance and monitoring, and prompt human intervention

The arrangements for storage of radioactive substances should take into account the following considerations:

• the planned future use or treatment of the material being stored
• the avoidance of leaks to ground or groundwater from the store through, for example, multiple barrier techniques
• where releases of contaminated water are unavoidable, these should be minimised and appropriately managed
• the need to avoid or minimise and manage gaseous releases from the store
• the need to avoid loss or escape of radioactive substances
• the prevention of access to stored substances by any unauthorised persons
• the need to minimise degradation of the store and the substances stored
• the need for facilities to be constructed, maintained and used to minimise contamination and cross-contamination
• stores should avoid being located close to any corrosive, explosive or flammable materials, except where necessary because of a facility’s function
• the provision of appropriate monitoring, including the ability to inspect both the substances being stored and the storage facility
• appropriate records of stored substances, storage conditions, storage durations, and any changes in these during the storage period
• the ability to retrieve substances

Where radioactive wastes are being packaged, the packaging should take account of all relevant requirements including compatibility with handling, retrieval, transport and disposal requirements.

Where radioactive wastes are being packaged, operators first need to demonstrate that the wastes being packaged will meet anticipated disposal requirements.

Waste packages should be clearly marked to indicate that they are radioactive, to provide other information necessary for their identification, and to ensure records related to the packages are traceable. Unique marking may be appropriate.

RSMDP11 – storage in a passively safe state

Where radioactive substances are currently not stored in a passively safe state and there are worthwhile environmental or safety benefits in doing so then the substances should be processed into a passively safe state.

Considerations

Decisions about whether it is worthwhile to process substances into a passively safe state, and if so when, should take into account the environmental risk and impact arising from:

• the state of existing storage facilities and their anticipated lifetime
• the availability of contingency storage in the event of failure
• the physical stability of the waste and its potential deterioration
• the radiological hazard of the waste
• reliance on active safety systems, maintenance, monitoring and human intervention

Decision should also take into account:

• security issues
• worker safety
• the need for progressive radiological hazard reduction
• uncertainty about the current state of substances and storage
• the availability of detailed knowledge about substances and storage arrangements from records and via other means (for example, corporate memory)
• the availability of storage facilities for ongoing arisings
• the availability of techniques to retrieve and process the waste, including secondary wastes
• the anticipated final disposability of the passively safe waste
• costs, where these are grossly disproportionate to the risks of continuing to store the substances
• the potential that disposal options might be unacceptably foreclosed – the future acceptability of waste made passively safe for the disposal options that might be available

Where a number of radioactive substances need to be processed into a passively safe state, the priority should be assessed and the substances processed accordingly. Factors taken into account should include those identified above.

RSMDP12 – limits and levels on discharges

Limits and levels should be established on the quantities of radioactivity that can be discharged into the environment where these are necessary to secure proper protection of human health and the environment.

Considerations

Limits and levels should be established on those radionuclides or groups of radionuclides (or both) which:

• are of significance in terms of radiological impact for humans and non-human species, including those which may be taken up in food
• are of significance in terms of the quantity of radioactivity discharged
• have long half-lives and which may persist or accumulate (or both) in the environment, and may contribute significantly to collective dose
• are significant indicators of facility performance and process control
• provide for effective regulatory control and enforcement

The time periods on which limits and levels should be based should be consistent with the intent of the limit or level. Such periods include annual, quarterly, monthly, weekly and daily. The periods may be calendar or rolling.

Limits and levels may also be set on the total discharge arising from a specific work activity, for example decommissioning ponds at a power station. The time period for such limits should take into account the project programme.

Limits and levels should be set on discharges from a site and where appropriate discharges from individual facilities and or groups of facilities on a site. Decisions should be informed by criteria set out in specific guidance in this area.

Limits should be based on the level of releases achievable through the use of BAT by operators.

Limits should be set such that there is minimum headroom between actual levels of discharge expected during normal operation and the discharge limit. ‘Operation’ relates to the current activities at a site including commissioning, operations and decommissioning. ‘Normal’ operation includes maintenance and relevant operational fluctuations, trends and events that are expected to occur over the likely lifetime of the facility.

Where the operations carried out on a site are discontinuous or of varying throughput or output, variable limits and levels may be set to track the operations while continuing to minimise headroom.

Consistent with the UK Discharge Strategy, progressive reductions in limits and discharges should be sought to achieve its targets and aims by means including:

• implementation of new technology or techniques
• process optimisation
• facility closure or replacement
• decommissioning of legacy facilities

In seeking further reduction in discharges it should be recognised that a point is reached where additional costs of those reductions far outweigh the benefits arising from the improvements in the protection of the public or the environment.

Where the prospective dose to the most exposed group of members of the public is below 10 μSv/yr from the overall discharges of an authorised site, limits should not be further reduced, provided that the operator applies and continues to apply BAT.

Limits may be increased:

• to mitigate risks associated with stored historical waste
• to deal with wastes arising from facility decommissioning
• to enable new justified operations to be established
• in the light of experience of operation of new facilities or processes
• where a facility’s predicted technical characteristics result in an increasing source term for example, activation and accumulation of carbon-14 in reactor cores
• for existing facilities or processes, where the BAT are being used and there are worthwhile environmental, safety or operational benefits

In all cases where an increased discharge limit is being considered operators should be required to make a fully substantiated application. The increased discharge limits should be no greater than is necessary and may be time limited.

Advisory levels should be set that:

• prompt review of whether the BAT are being used
• ensure early assessment of the potential impact of increased discharges

Advisory levels should require early reporting of:

• operational performance issues leading to increases in discharges
• events that have given rise to higher than normal short term discharges

The process by which limit and levels are determined should be based on a data set of appropriate quality and breadth.

RSMDP13 – monitoring and assessment

The best available techniques, consistent with relevant guidance and standards, should be used to monitor and assess radioactive substances, disposals of radioactive wastes and the environment into which they are disposed.

Considerations

The operator should use BAT to carry out monitoring and assessment of radioactive substances and disposals of radioactive waste. The objectives are that:

• responsibility for carrying out monitoring and assessments is taken by those holding the radioactive substances or making disposals of radioactive waste
• the monitoring and assessment is carried out by those who should have the best knowledge of their processes
• ownership of the consequent environmental impact is taken by those making disposals
• monitoring and assessment is carried out in compliance with relevant requirements and standards including those legally imposed

We will ensure that the quality of operator self-monitoring of radioactive substances and radioactive waste disposals is acceptable, requiring the use of standards, auditing and check monitoring. Our objectives are to:

• achieve consistency, robustness, enforceability and safe practices
• ensure adequate standards are being applied through auditing
• provide an independent check of major releases of liquid radioactive effluent to inland and coastal waters and sewers, and gaseous emissions to air and to verify compliance with disposal permits
• provide an independent check on the adequacy of operator declarations for radioactivity inventories in disposals of solid waste and on underlying declaration assumptions (for example, waste stream ‘fingerprints’)
• verify compliance with regulations and conditions of disposal of solid waste
• provide an independent check on the adequacy of operator monitoring of the environment to verify their arrangements

The objectives of the operator’s and our environmental monitoring programmes are to:

• enable doses to critical groups to be independently estimated for comparison against legal limits and for operators to assess dose as a performance measure (monitoring for critical group)
• enable doses to vulnerable reference non-human species to be independently estimated and for operators to assess impact on wildlife as a performance measure (wildlife monitoring)
• provide reassurance that the radiological impact of authorised discharges of radioactive waste and other transfers of radioactivity into the environment is acceptable (reassurance monitoring)
• establish background levels of natural radioactivity in the environment (background monitoring)
• establish baseline conditions of artificial radioactivity in the environment before new discharges (baseline monitoring)
• identify and characterise land and groundwater contamination (land contamination monitoring)
• understand and monitor behaviour of radionuclides in the environment – distribution (spatial), dispersion/concentration, changes in environmental behaviour and model validation (environmental behaviour monitoring)
• provide a long term measure of the state of the environment (environmental indicator monitoring)
• investigate incidents or developing scenarios, detect abnormal releases, detect fugitive and unauthorised releases (for example, non-point source, unexpected, non-predicted) (investigative monitoring)

Monitoring and assessment of the receiving environment should be carried out by the operator to determine the distribution of radioactivity in the environment and its radiological and environmental impact.

We will retrospectively assess the impact of releases of radioactive substances to the environment to provide an independent check on the adequacy of operator monitoring of the environment and their assessment of impact.

We will retrospectively assess the impact of releases of radioactive substances to the environment by:

• proportionate check monitoring of environment in the vicinity of sites releasing radioactive substances
• monitoring of the wider environment

RSMDP14 – record keeping

Sufficient records relating to radioactive substances and associated facilities should be made and managed so as: to facilitate the subsequent management of those substances and facilities; to demonstrate whether compliance with requirements and standards has been achieved; and to provide information and continuing assurance about the environmental impact and risks of the operations undertaken, including waste disposal.

Considerations

Records relating to radioactive substances and associated facilities include those made throughout a site or facility’s life-cycle such as:

• management arrangements
• underlying and ongoing research and development
• studies, evaluations, strategies and plans
• environmental monitoring and assessments

Also, those made at the stages of a facility’s life-cycle such as:

• site evaluation and selection
• facility design, construction, commissioning and modifications
• operations and maintenance
• evaluation of trends and events
• facility decontamination and decommissioning
• site remediation, clearance and release from regulatory control

Records should also include those made at relevant stages of the lifecycle, such as waste discharges, disposals and transfers.

The requirements of all radioactive substance management steps through to disposal should be considered when defining the records to be made and retained. Records are required to properly inform decisions about, for example, sites, design, operation, maintenance and decommissioning of facilities; handling, storage, processing and transport of radioactive substances, remediation of contaminated land and the disposability of wastes.

The quantity, quality and level of detail of the records made and retained should be such that they are fit for purpose.

Where there is significant uncertainty about data this should be taken in account in deciding which records to make and retain.

Records should include details of data uncertainties, in quantitative or qualitative form.

The manner of retention of the records should ensure that they remain available for all reasonable purposes for which they might be needed.

RSMDP15 – requirements and conditions for disposal of wastes

Requirements and conditions that properly protect people and the environment should be set out and imposed for disposal of radioactive waste. Disposal of radioactive waste should comply with imposed requirements and conditions.

Considerations

The requirements and conditions may be specified in, for example:

• permits
• exemption orders
• waste receiver conditions for acceptance

The intent of the requirements and conditions are to:

• protect people and the environment, now and in the future
• comply with legislation
• implement government policy
• meet international obligations for example, OSPAR
• implement Environment Agency’s policies
• implement relevant principles
• meet the requirements of waste receivers

Requirements and conditions may include:

• limits on the activity of the waste that can be disposed of
• limits on the volume or mass of waste that can be disposed of
• action levels on the activity of wastes disposed of
• restrictions on the types of waste that can be disposed of
• restrictions on the route by which the waste may be disposed of
• restrictions on the other materials that can be in the radioactive waste
• restrictions on the source of the waste
• restrictions on when waste can be disposed of
• requirements on preventing or minimising (or both) the quantity and activity of waste created and discharged
• requirements on management systems
• requirements for maintenance of related facilities
• requirements for information reporting
• requirements for keeping and managing records
• requirements for improvements
• requirements for measurements and assessments
• requirements for discharge and environmental monitoring
• requirements on the condition of facilities
• requirements set by waste receivers
• requirements to retrieve non-compliant wastes transferred to waste receivers

Specific requirements for gaseous disposals may include the use of BAT to:

• minimise the activity of waste discharged for example by HEPA filtration, electrostatic filters, charcoal filters, scrubbers
• provide good dispersion for example, location of discharge point, stack design and height, plume buoyancy, exit velocity
• monitor and assess discharges

Specific requirements for aqueous liquid disposals may include the use of BAT to:

• minimise the activity of waste discharged for example by filtration, settling, ion exchange treatment, evaporation and condensation
• provide good dispersion for example, location of discharge point, of approved routes, timing of tidal discharges
• to minimise oils, solvents, miscible solvents, solids and entrained gases, and controls on pH and temperature

Specific requirements for combustible waste disposals by incineration may include the use of BAT to:

• remove particulates and water from organic liquids
• minimise the activity of discharges from an incinerator by use of filtration, electrostatic filters, scrubbers
• provide good dispersion for example, location of discharge point, stack design and height, plume buoyancy, exit velocity
• monitor and assess waste input or discharges (or both)

Specific requirements for waste disposals by transfer may include:

• constraints arising from requirements for transport
• constraints arising from subsequent waste management processes including disposal
• obligations to transport and receive back waste found not to meet specification
• obligations to transfer information relating to wastes, in appropriate formats

Specific requirements for solid waste disposal may include:

• package identification requirements
• quality assurance
• records and information management

Specific requirements for solid waste disposal may also include conditioning to agreed specifications including demonstration of compliance of the waste and its packaging with, for example:

• criticality limits on fissile material
• characterisation of the package including radioactivity content
• fire resistance
• voidage limits
• restrictions on free liquids
• exclusion of compressed gases, explosives and pyrophoric materials
• mechanical integrity and resistance criteria

Specific requirements for the evaluation of the long term performance of the waste form may include:

• leachability
• potential for gas generation
• potential for cracking
• chemical degradation
• compatibility of the waste with its container and any immobilisation matrix
• use of coupons and non-radioactive analogues to monitor performance
• impact of toxic materials

Joint guidance on Higher Activity Wastes is available from the Office of Nuclear Regulation, the Environment Agency, the Scottish Environment Protection Agency and Natural Resources Wales to nuclear licensees.