The Nuclear Decommissioning Authority

Last Updated: 27 July 2010

Non-radioactive and hazardous waste is generated at NDA sites as a result of both decommissioning and operational activities. Included in this category of waste are hazardous wastes such as asbestos; process chemicals; oil and general waste arising from site activities such as demolition rubble, packaging, paper and food waste.

Currently there is consultation on a National Strategy for Hazardous Waste Management in England, issued by the Department for Environment, Food and Rural Affairs (DEFRA) in July 2009.  It is unlikely that non-radioactive hazardous wastes generated within the nuclear sector would be substantially different from those generated outside the sector.  In view of the imminent publication of the National Strategy for Hazardous Wastes and mature practices in the management of these wastes, there are likely to be few options to be considered that might lead to significant differences in the strategy for the nuclear sector.  As such, the topic strategy for non-radioactive and hazardous waste is likely to progress quickly through the Strategy Management System (SMS).

Downloadable version of this page:
 Non-radioactive and Hazardous Waste Topic Strategy Summary (150Kb)

Objective

In alignment with the national strategies for the management of conventional and hazardous wastes, and with requirements for the implementation of the Waste Hierarchy (WH) laid down in the Waste Framework Directive 2008/98/EC, the objective of this topic strategy is: to reduce waste generation and optimise management and disposal of non-radioactive and hazardous wastes at NDA sites by implementation of the Waste Hierarchy at every level across the NDA Estate.  

Scope and Boundaries

The Topic Strategy for non-radioactive and hazardous waste covers the characterisation, segregation, treatment, transport and disposal of non-radioactive waste and non-radioactive hazardous waste (solid and liquid) from NDA owned sites and facilities via conventional waste management routes.   Where mixed wastes arise, e.g. non-radioactive and radioactive waste, such materials are managed as Radioactive Waste in accordance with authorisations under the Radioactive Substances Act 1993 (RSA93), which takes precedence over other waste management regulations.  This topic strategy also includes radioactive waste that has been demonstrated as exempt from regulation under RSA93 through use of exemption orders.  Whilst such wastes remain radioactive waste from a regulatory perspective they are in practice managed along with conventional wastes.  It is this management in practice that makes such wastes suitable for inclusion in this topic strategy.  

Interfaces

The non-radioactive and hazardous waste strategy interfaces with a number of other topics including:

• Decommissioning and clean-up strategy, and Site end states strategy and Land and groundwater quality management strategy because of the quantity of non-radioactive and hazardous waste that will need to be managed
• Lower Activity Wastes strategy with improved management and treatment potentially resulting in waste being re-categorised as Non-radioactive hazardous wastes
• Asset care, which has a strong influence on the control of wastes during their management.

Credible Options

We are at an early stage in developing this topic strategy.  However, as noted earlier, options for developing it further are limited.  This is due to the mature practices and the existence (or development) of national strategies for the management of these wastes.  

There are a number of influences that will impact the development of the topic strategy:

• Input from key stakeholders with an interest in the strategy
• The approach will focus on the best outcome for people and the environment
• There are well developed processes and a mature supply chain for the management of these wastes outside of the nuclear industry
• The actual waste management decisions will be made by waste producers, underpinned by BAT / BPEO /BPM assessment, which are required to satisfy the regulators that a broad range of criteria and impacts have been considered in the decision making process. 

Current Position

For non-radioactive and hazardous wastes the current strategy (i.e. that already in action at the waste producing sites) is that NDA sites plan for the management of these wastes as part of their integrated waste planning.  In particular, sites are required to develop continuously their Integrated Waste Strategy (IWS), taking full cognisance of UK waste policy, the Waste Hierarchy, the proximity principle and compliant with all relevant UK waste regulations relating to (non-radioactive) hazardous waste.  Likewise, this topic strategy is part of a wider integrated waste management theme.

As noted above, we are at the early stages of the topic strategy development process.  However, due to maturity of the non-radioactive and hazardous waste industry we consider development of this topic strategy to be low risk.  In regulatory terms, mature regulation exists across the devolved governments: in Scotland, Waste Planning Policy is underpinned by the National Waste Management Plan for Scotland Regulations 2007 and in addition Scotland has recently consulted on a national Zero Waste Plan; and in England and Wales, National Policy is underpinned by a developing Strategy for Hazardous Waste Management in England, and the Hazardous Waste (England and Wales) Regulations 2005 (SI 894) and Amended Regulations 2009 (SI507).

We are working towards a Gate C submission early in 2010 to demonstrate that this topic strategy is already at Stage D, implementation.

Position at Strategy II (June 2010)

The Non-radioactive and hazardous waste topic will be at implementation for Strategy II.