1. Technical Meeting on the Safe Disposal of Intermediate Level Waste –
Environment Agency (England) Comments
Dr Andrew Fairhurst
Nuclear Regulator
IAEA Headquarters, Vienna
3 – 7 November 2014

2. High level comments (1) Much useful information
Useful addition to IAEA documents, definite merit to report
May increase attention on ILW
No significant omissions or concerns
Scope about right
Generally well written
Good that not overly prescriptive
National examples will be useful

3. High level comments (2)
Possibly needs some increased clarity of scope, objectives and purpose up front:
Where it sits relative to other documentation
Appears to present some new ‘free-standing’ guidance, examples of use of ‘should’......
Intent to fill a gap, or provide a collation of existing guidance / requirements?
Possibly scope to reduce length by cross-referencing where limited unique ILW information

4. More detailed comments
Some areas where clarity could be improved (wording)
Would benefit from more out referencing to IAEA documents
Suggested technical additions:
Heterogeneity (particles, items) especially for near-surface disposal
Voidage
Chemical content of containers and engineered barriers
Appears to endorse landfill and trench disposal for ILW