# LC32 -- Accumulation of Radioactive Waste

## Condition

Licence Condition 32 requires the licensee to make adequate arrangements to minimise the **production and accumulation of radioactive waste** on the site, to ensure that waste is stored under suitable conditions, and that adequate records of waste are maintained.

## Key Requirements

- The production of radioactive waste must be minimised so far as is reasonably practicable
- Accumulation of waste on site must be minimised
- Waste that is accumulated must be stored under conditions that maintain safety and minimise further hazard
- Adequate records must be kept of the nature, quantity and location of all radioactive waste
- The arrangements must address all waste categories: Very Low Level Waste (VLLW), Low Level Waste (LLW), Intermediate Level Waste (ILW) and High Level Waste (HLW)

## Relevance to Decommissioning

Decommissioning generates large volumes of radioactive waste across all categories:

- **Volume and variety.** D&D operations produce contaminated concrete, activated steel, contaminated soil, process residues, filters, resins, and decontamination liquors. The waste management challenge is frequently the dominant factor in decommissioning cost and schedule.
- **Minimisation.** LC32 drives the application of the waste hierarchy -- avoid, minimise, reuse, recycle -- before disposal. Techniques such as size reduction, decontamination and segregation at source reduce the volume requiring disposal as radioactive waste.
- **Interim storage.** Where disposal routes are not yet available (notably for ILW pending a Geological Disposal Facility), waste must be conditioned and stored safely for extended periods. LC32 requires that these storage conditions remain adequate.
- **Record keeping.** Accurate waste records are essential for demonstrating compliance with environmental permits and for planning disposal campaigns. They also feed into the site-wide radioactive material inventory required by LC25.
- **Sentencing.** Each waste stream must be characterised and assigned to the correct disposal or storage route -- a process that requires robust arrangements under LC32.

## Docket Cross-References

- Chapter 6, Section 6.5 -- Key Nuclear Site Licence Conditions

## See Also

- [LC33](LC33.md) -- Disposal of Radioactive Waste (the disposal counterpart)
- [LC25](LC25.md) -- Operational Records (waste record keeping)
- [LC34](LC34.md) -- Leakage and Escape of Radioactive Material (containment during storage)