Building pride in Cumbria Do not use fonts other than Arial for your presentations NuLeAF Steering Group 24 October 2012 Nuclear site waste management.

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NuLeAF Steering Group

24 October 2012

Nuclear site waste management plans

and community engagement.

Richard EvansCumbria 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) Facilities that have yet to be constructed to take ILW; 2) Near surface facilities similar to the LLWR near Drigg;3) Existing or new facilities on or adjacent to nuclear sites;4) In-situ disposal, burial at the point of arisng. 5) Specified existing landfill sites 6) Low volume VLLW to unspecified destinations7) 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.