Radioactive Waste Issues in Planning

- A local authority perspective

Rob Murfin

Planning Officers Society

Head of Planning Services Derbyshire County Council

The starting point – NPPFBottom up issues

• Focus on sustainable development & growthWhat are the implications?

• Emphasis on local decision-making?• Reduced national guidance ?• Not control, but facilitation of development• Genuinely plan-led• Shift to opportunities, not barriers

NPPF – a year on

• Implications of shift from arguments around impacts to that of benefits

• Equalising 3 legs of sustainable development• Taken industry time to adopt to reemphasis• More generic economic benefits now need to

be expanded and put into society and sector based context.

Economic benefits – a new approach

• Argument “will undermine inward investment because of image”

• Demise of RSS tier, decisions must be directly consistent with national policy. No interpretation via RSS need/apportionment

• NPPF arguments more info about economics• Traditional counter “it will create 23 jobs”

NPPF generic Use of Evidence Political confidence v crossing line to “advocate”

•Description of Strategic Context, fit with national, strategic and sub-regional growth plans•Market Context of the proposal•Description of the Socio-economic Context•Examples of business sectors and elements of society to be “customers” and scale of demand •Attempt assessment of the quantifiable Economic Impact including direct, indirect and supplier chains•Challenge organisational objectors (including PC) to at least try to quantify alleged negative impact

Radioactive wastes

• Start from “Schools and Housing” argument• General waste disconnect• “OK, but not needed here”• VLLW – exposes the issues of NPPF approach

DCLG Guidance on implementing the Waste Framework Directive (Dec

2012)

New style guidance “expect WPAs to plan for the sustainable management of wastes including:”

Municipal/household Commercial/industrialConstruction/demolition Low Level RadioactiveAgricultural waste Hazardous waste

VLL radioactive specific “needs”

• Wealth of information out there• Hard to distil from primary sources in day job*• Key texts for non-expert to get going

*Micro-pig contextual framework scenario

NPPF = Plan positively for low level radioactive waste???

Housing acceptance*

• Need to establish start part of role• Accept that there will still be resistance

Spatial : often urban distribution…Hospitals 250+ nuclear medicine centres, 670K procedures PA. Last 10 years increase of 40%. Estimated 77% of small VLL arisings

Pharmaceutical Industry Employs c68k. 40% directly involved in research, 20% used radioactivity Contaminated land Legacy from activities pre-dating control of use/disposal. Processing of uranium ore during 1940/ 50s to extract radium for paint, dials and watches

Universities 10,000 monitored workers

Oil/Gas Industry “Overboard discharge”* and reinjection of material into the seabed subsurface of NORM

Scale: Very Low Volumes of Very Low Level Waste

• Most sites produce less than 50 m3 pa• Most areas unlikely to exceed 0.1% of non-

radioactive directive waste• Permit to use disposal routes under radioactive

waste regs is held by waste producers, not operator of receiving disposal facility

• Any landfill or incinerator may have been accepting low volume VLLW mixed in with the other wastes

Features: waste

• Majority of LLW similar physical & chemical nature to MSW or C&I waste streams

• Radioactivity additional to present in raw materials - therefore is also in all types of waste

• Because of low risks/ small quantities, disposal mostly been via facilities used for other wastes

• Reported reduction in “availability” of facilities• Concern about continued availability of facilities

or need to transport waste over long distances

Key messages • Plan provision, inc. imports to ensure plan is

consistent with national policy• Confirm opportunities for disposal will be

assessed against positive policies, not just barriers• Abolition of RSS = embrace cross boundary

working (DtC) • Definition itself gives rise to public concern=

deterrent for operators to provide a disposal service.

• May very well make a hard task even harder in some parts of country

• VLLW clarity needed even if it means plans and facilities “harder” to get through

• Linked issues ; reduce the fragility of disposal arrangements and arrangements needed to provide security of supply of hydrocarbons

• “it is appropriate that local communities should take greater responsibility for how they deal with non-nuclear industry arisings”

All this does not mean every WPA has to have a LLW facility…

.. But does not mean defaulting to disposal in Cumbria

or Oosoom District Council*

• No RSS, but “reality apportionment” evidence cannot be ignored

• Government does not believe it is appropriate to require operators of commercial waste facilities to take particular wastes.

• Support provision of sufficient opportunities within local planning strategies to meet the non-nuclear industry disposal needs

Challenge

• Non-nuclear industry distributed across UK, although tends to be urban

• Small volumes of LLW are largely insufficient to drive the provision of bespoke facilities or via allocation process.

• Awareness of issue could be the problem? • WPAs should actively state conditions when

LLW can go to given facilities• NPPF– look for solutions, not restrictions