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NuLeAF Steering Group
24 October 2012
Nuclear site waste management plans
and community engagement.
Richard Evans
Cumbria County Council
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Requirements of the Policy for the Long
Term Management of Solid Low Level
Radioactive Waste in the United Kingdom.
(Defra, Dti, DoE, Scottish Executive, Welsh Assembly 2007)
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1. UK LLW Policy paragraphs 7 and 8
require waste managers/nuclear sites
to have radioactive waste
management plans in place in a form
and level of detail suitable for
consideration by regulatory bodies
and part of a wider integrated waste
management strategy.
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Summary of nuclear sites’ waste plans
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VLLW and LALLW
•
•
The table shows that, in their waste plans,
Springfields, Berkeley, Bradwell, Chapelcross,
Dungeness, Hinkley Point, Hunterston, Oldbury,
Sizewell, Trawsfynedd, Wylfa, Capenhurst, Harwell
and Winfrith state they have disposal routes in use
or available for VLLW/LALLW.
The table does not identify these disposal routes but
the only three landfills that I know have
Environmental Permits for these wastes are Clifton
Marsh in Lancashire, Kingscliffe in Northamptonshire
and Lillyhall in Cumbria.
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What does the UK Low Level Radioactive
Waste Policy say about these waste plans
and community engagement?
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UK Policy’s requirements for LLW
management plans
Paragraph 11.
LLW management plans …… must be developed
with appropriate regulatory and stakeholder
involvement ……. As a general principle, such
plans should be developed and agreed with the
regulatory bodies in advance of the production of
any new LLW streams.
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UK Policy’s requirements for LLW
management plans
Paragraph 12.
In addition, the preparation of LLW management
plans shall be based on:
• ………….;
• consideration of all practicable options for the
management of LLW;
• appropriate consideration of the proximity principle
and waste transport issues;
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Practicable disposal options to be
considered are described as :1)
2)
3)
4)
5)
6)
7)
Facilities that have yet to be constructed to take ILW;
Near surface facilities similar to the LLWR near Drigg;
Existing or new facilities on or adjacent to nuclear sites;
In-situ disposal, burial at the point of arisng.
Specified existing landfill sites
Low volume VLLW to unspecified destinations
Incineration.
Decay storage is also mentioned as a possible early
solution.
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UK Policy’s requirements for LLW
management plans
Paragraph 26 requires that plans are
developed by including wide stakeholder
engagement,
including communities which may be
impacted by the plans including ones in
the vicinity of a waste treatment or
disposal facility, and the local authorities
concerned.
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UK Policy’s requirements for LLW
management plans
Paragraph 27. Guiding principles that should apply
to such consultations are:
• provision for early local community input into
the decision-making process;
• openness and transparency at all stages;
• provision of well prepared, good quality,
accurate and easily understandable briefing
material;
• use of an iterative consultation process where
appropriate.
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What does the NDA’s UK Strategy for the
Management of Solid Low Level Radioactive
Waste (LLW) from the Nuclear Industry
require re community engagement?
(NDA 2010)
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Section 2.1 requires high standards of
public acceptability, early and proactive
engagement with local and national
stakeholders, consideration of a full range
of realistic available options and decision
making informed by community interests.
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Section 3 requires careful and considered
engagement with local communities early
in the waste management planning and
decision making process and open and
transparent engagement.
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Experience of community engagement
• There was significant engagement in relation to the
Northamptonshire proposals, but this seems to have
been at a late stage and not by all the possibly
relevant nuclear sites.
• Is there any evidence of early or late community
engagement by the nuclear sites, that are sending,
or plan to send, their wastes to Cumbria and
Lancashire? (in addition to Dounreay and
Chapelcross for Cumbria and Springfields for
Lancashire).
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Possible actions?
• Nuclear sites could provide links to their LLW waste
management plans and identify their (V)(LA)LLW disposal
routes and the options that were considered.
• Nuclear sites/waste managers could explain their community
engagement procedures and actions in respect of disposals.
• NDA could describe its overview role for implementing the
requirements of UK LLW Policy and its LLW Strategy.
• EA and SEPA could explain how they take account of
operator’s consultations (Policy paragraph 26).
• There could be a renewed commitment to early and
transparent community engagement.
• Local Plan policies could repeat the community engagement
requirements of national policy.
• There may be other matters that NuLeAF could take up.
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