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Radioactive Waste Issues in Planning - A local authority perspective. Rob Murfin Planning Officers Society Head of Planning Services Derbyshire County Council. The starting point – NPPF Bottom up issues. Focus on sustainable development & growth What are the implications?
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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 & growth What 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 directlyconsistent 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/industrial Construction/demolition Low Level Radioactive Agricultural 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
Housing acceptance* • Need to establish start part of role • Accept that there will still be resistance
Spatial : often urban distribution… Hospitals250+ nuclear medicine centres, 670K procedures PA. Last 10 years increase of 40%. Estimated 77% of small VLL arisings Pharmaceutical IndustryEmploys 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, dialsand watches Universities10,000 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 m3pa • 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 opportunitieswithin 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