The UK Government has launched a consultation on its proposed strategy for the long term efficient management of Naturally Occurring Radioactive Material (NORM) waste. The government has promised to remove policy barriers to the development of waste management market and revise the current regulatory regime to facilitate more sustainable management of NORM waste.
The new NORM waste strategy will be most relevant to companies involved in mining and extractive industries, such as oil and gas, uranium and iron and steel production. This is because NORM can naturally occur in the Earth's crust as result of such intrusive activities. In addition, businesses involved in remediating land contaminated with radioactive substances will be covered by potential changes to NORM regulations.
NORM waste can occur naturally when radioactive elements become concentrated through industrial activities, such as mining and mineral processing. The processes that cause natural radioactivity to be concentrated can have the same impact on other pollutants, such as heavy metals and organic compounds. NORM can also be generated by remediation activities on sites with high levels of radionuclides (for instance, on former military bases or decommissioned nuclear sites).
Currently, NORM waste is regulated by the Environmental Permitting (England and Wales) Regulations 2010 and the Radioactive Substances Act 1993 (in Scotland and Northern Ireland) (RSA93). Operators must ensure the sites receiving NORM have appropriate permits and that the authorised discharge limits are met. Operators are required to apply the Waste Hierarchy and carry out a best practical environmental option assessment when implementing means to remove NORM wastes.
The proposed strategy seeks to reform the regulatory framework to allow for growth in NORM-creating sectors, while promoting a robust system of waste management. Key regulatory mechanisms proposed in the consultation document are as follows:
- Introduction of regulatory mechanisms to encourage NORM waste recovery (rather than disposal), such as setting recovery criteria analogous to "end of waste" protocols.
- A proposal for companies handling exempt waste to provide information to subsequent recipient's that the waste is radioactive. This would be a shift from the current requirement under the exemption regime that labels which indicate waste is radioactive must be removed before disposal.
- A review of radiation dose limits that apply to NORM waste in line with the new EU Basic Safety Standards Directive.
- Proposal to improve regulations on transfrontier shipment of NORM waste for treatment abroad.
- A strong push for waste authorities to work with environmental regulators and waste operators to plan for NORM waste management to create opportunities for new facilities.
The strategy covers all forms of NORM waste, solid, liquid and gas, regardless of activity level. There is an impetus to increase management capacity for treating NORM waste as the quantities and activities of it are expected to increase in the next five years.
For the Oil and Gas sector, there may be a potential end to the disposal to sea of solid NORM waste that arises from the maintenance and cleaning of offshore equipment in future. This would lead to significant additional volumes of solid NORM waste being brought ashore; meaning operators may need to consider alternative disposal routes and an increase in costs for waste handling, especially when contemplating decommissioning activities.
The consultation is being led by the Scottish Environmental Protection Agency (SEPA) in collaboration with devolved environment agencies. Interested companies should consider participating in the consultation before the closing date for submissions on 8 May 2014.