LLW disposal to landfill – recent
Environment Agency
experiences
David Bennett & Juliet Long
Radioactive Substances Regulation
July 2011
Structure
Our ambitions
Recent developments
Permitting landfill disposal of LLW
Experiences of working together
Our Ambitions
Proper protection of people and the
environment
Progress in dealing with the nuclear legacy
Reducing risk to this generation and the burden on
future generations
Help inform and enable progress, provided people and
environment protected
People have confidence in our decision making
Outcomes?
Radiation doses that are as low as reasonably
achievable
Fit-for-purpose regulatory framework
robust, transparent, participative and integrated
decision-making based on evidence
consistent with national policy
Environmental hazard and risk stabilised and
reduced
Disposal sites –applications for permits
for disposal to landfill
Consistent with national policy
Supported by ‘environmental safety case’
Consigning sites - inter-site transfers of
LLW
Approach under Environmental Permitting
Regulations 2010 (EPR): - no need for statutory
notification of local authorities
Operators need to let the local authority know the
origin and nature of the waste before receiving the
first shipment from a consignor
The permit will
specify each permitted combination of waste and disposal route
permit transfer to either named sites or ‘the holder of a permit
under the Environmental Permitting Regulations to receive and
dispose of HV-VLLW’
Schedule 3 – Specified transfers to other
premises
Specific waste type
Metallic LLW
Person to whom waste may be transferred
The holder of a permit under the EPR to receive and dispose of LLW at ..
Purpose of transfer
For subsequent treatment and / or transfer for disposal
Radionuclide / group of radionuclides
Any
Calendar year limit
No limit
Annual volume limit
No limit
Inter-site transfers
No barriers to waste treatment / disposal BUT not unrestricted:
Operators must still consider the options for disposal before generating
waste
Disposal must still represent BAT and relevant Government policy e.g.
proximity principle
We may decide to identify specified sites as necessary e.g. to
deliver the requirements of the proximity principle or the waste
hierarchy, but would not normally expect to do so
Records of waste transfer must be kept by consignor and receiving
site operator
Public acceptability and decision making
Stated as an aim in both National LLW policy and
strategy
We don’t place requirements on this:
At receiving site – we would consider content of concern, rather
than forming judgements on degree of concern (i.e. voting)
At consigning site – EPR approach of not requiring specific routes
to be permitted renders Policy approach out of date
Some ambiguities in Policy and Strategy wording
Kings Cliffe inspector recognised it as a difficult area
Integrated Waste Management
Integrated waste strategies are important considerable progress across NDA and other sites
NDA, regulators and MoD working together to take an
overview of Integrated Waste Management strategy
development and implementation
inc. revision to IWS specification
Continued support to LLW Management Programme
through Programme Delivery Group
LLWR ESC review
2002 Cases ‘inadequate’
Disposal to Vault 8 only
Vault 9 built (storage only)
Authorisation required updated ESC by May 2011
Technical basis for future permitting decision
Need for certainty - Industry need – status quo
unacceptable
LLWR > £8m, Our review > 5 person years
Key objective:
Reach a clear and justified regulatory decision on
future operations at the LLWR, underpinned by a
robust technical review
Be proportionate and timely
Good communications with Cumbria CC on EPR
permitting – Planning interface
Outline timescales
-
ESC submitted
Technical
Review
May ‘11
-
Initial review
Aug ’11 – Apr ’12
-
Core technical review / audits
May ’12 – Apr ‘13
-
Prepare conclusions & publish
Mid to late ’12
-
Application for further disposal
-
Consult application (3 months)
-
Draft decision / permit
-
Consult draft decision (3 months)
-
Decision
Early autumn ’13
Permit Review
May ’11 – July ’11
Landfill disposal of LLW
Kings
Cliffe
Lillyhall
Clifton
Marsh
Keekle Head
WRG Lillyhall landfill HV-VLLW application
Non-hazardous, household and asbestos waste site
Application under RSA93 received May 2009
Existing planning permission until 2014
For HV-VLLW up to 26,000m3/yr, 582,000m3 total
Single consultation on application
Objections on grounds of proximity and socio-economic
impacts
Article 37 decision received March 2011
EPR permit granted April 2011
Local Authorities maintaining objections
Planning permission renewal required by 2014
Kings Cliffe Controlled
Burial application
Hazardous waste landfill
Application for 200Bq/g under RSA93 July 2009, <
250,000m3/yr
Supported by a detailed radiological assessment
Following our review of this we reduced limits requested by
Augean by factor of 18
Two consultations (application & “minded to”)
Vigorous objection on broad grounds – need, safety and
socio-economic impacts, process, perception
Article 37 decision received in January 2011
EPR Permit granted May 2011 along with planning
permission - SoS decision
Clifton Marsh Controlled
Burial application
Currently permitted to receive waste from Springfields /
Capenhurst
Non-hazardous and asbestos landfill
Application for < 1000Bq/g under RSA93 Nov 2009
< 250,000m3 by 2020
Article 37 decision received March 2011
Planning permission until 2015
Single consultation on application and draft permit started
2 June 2011
Keekle Head
proposals
Dedicated facility in disused coal quarry workings
1 million m3 / up to 500Bq/g (mostly short lived) / 50-60 yrs
A ‘dry site’, covered during operations
Planning application submitted 2010
Proposals inconsistent with Cumbria County Council’s
policies
Local opposition including pressure groups
We have been flagging concerns to CCC as part of their
planning consultation e.g. groundwater impacts and River
Keekle restoration
Experiences of Engagement with Local
Authorities
Review across nuclear regulation group
suggest a ‘variable’ experience:
Primarily via consultation during permitting
• Correspondence & direct briefings (eg Preston CC
Environment committee)
Site Stakeholder Groups & planning for emergency
exercises
Routine & ad-hoc in places eg. Cumbria, Allerdale
Nuclear issues Group
Long term & regular engagement via the Cumbria
MRWS Partnership
Is there more we can do?
Opportunities
Accompanied site visits, attendance at annual reviews?
Bespoke workshops? “tumbleweed moment”
Better understanding of contacts & role?
“I am not sufficiently aware of their role and the scope of their
activities”
“Useful to be able to pick up the phone easily”
“The benefit [with the Partnership] has been the long process and
lengthy engagement”
“Are there any LA ‘trade mags’ or newsletters”
Summary
Considerable changes have taken place, and will
continue to happen
Policy and strategy development & implementation
Ways of working within industry
Our regulatory approach under EPR
Supply chain – new participants offering disposal routes
Variable experience in our ways of working with Local
Authorities
Keen to explore ways of improving and understanding
each others’ roles, expectations, and ways of working
together