UK NORM Waste Strategy

RESPONDENT INFORMATION FORM

Please Note this form must be returned with your response to ensure that we handle your response appropriately

1. Name/Organisation

Organisation Name

NuLeAF (Nuclear Legacy Advisory Forum)

Title Mr X Ms Mrs Miss Dr Please tick as appropriate

Surname

Matthews

Forename

Philip

2. Postal Address

Executive Director
NuLeAF
c/o Suffolk County Council
8 Russell Road, Ipswich
Postcode IP1 2BX / Phone 01473 264833 / Email

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CONSULTATION QUESTIONS

Question 1: Do you have any comments on chapter 1, which includes discussion of the background, scope and objectives for the proposed NORM waste strategy?

NuLeAF (the Nuclear Legacy Advisory Forum) is a Special Interest Group of the Local Government Association (LGA). NuLeAF is supported by 110 local authorities and 3 national park authorities across England and Wales. Our remit encompasses all aspects of the management of the UK’s nuclear waste legacy. Our primary objectives are:
·  to provide a mechanism to identify, where possible, a common, local government viewpoint on nuclear legacy management issues;
·  to represent that viewpoint, or the range of views of its member authorities, in discussion with national bodies, including Government, the NDA and the regulators;
·  to seek to influence policy and strategy for nuclear legacy management in the interests of affected communities; and
·  to develop the capacity of its member authorities to engage with nuclear legacy management at a local level.
NuLeAF is funded by the Nuclear Decommissioning Authority (NDA) and our member authorities.
In terms of Chapter 1 we welcome the commitment to apply the waste hierarchy (1.3) and the commitment to a robust and efficient operation of the UK market for such waste. We believe however that the market should also be guided in order to minimise transport impacts and the disruption to communities and the environment.
Chapter 1 notes the separate strategies for LLW for the nuclear and non-nuclear industries (1.6) and the role of the NORM strategy as part 2 of the non-nuclear strategy. Our members have raised concerns about the lack of a ‘joined up’ approach to the management of LLW from the nuclear and non-nuclear sectors. We believe steps should be taken to ensure that all LLW is managed in an integrated way, either through a move to an integrated LLW strategy or better connections being made between the management of different LLW waste streams. This will deliver more positive outcomes than a disjointed approach.
In the same way, we believe it would be of benefit to have more integration between the management of higher and lower activity wastes.
Chapter 1 also identifies the objective of the NORM Strategy as being to ensure that ‘secure, sustainable and resilient….management options are available’ (1.15). Sustainable is defined as being about the safe management of wastes, the waste hierarchy and driving economic growth. We believe that the contribution to national policy that communities which host these waste play should also be recognised through appropriate community benefits.

Question 2: Do you have any comments on chapter 2, which includes discussion of the current regulatory framework in the UK for NORM wastes, including the land use planning system?

We note the acknowledgement (2.34) that the planning system has, in the past, failed to place sufficient emphasis on the management of radioactive wastes, leading to an absence of specific guidance in many local waste plans.
NuLeAF has been active, through our Radioactive Waste Planning Group and our recent research for LLWR Ltd on the Duty to Co-operate, in encouraging local authorities to adopt suitable policies on radioactive waste.
As the paper notes (2.40), we do now see more integration of radioactive waste issues into waste plans. NuLeAF still believes that government could do more to join up the guidance on waste management so that radioactive waste becomes an active consideration in developing all new local waste plans.

Question 3: Do you agree Chapter 3 adequately describes UK NORM waste arisings and routes for treatment and disposal? What additional information can you provide?

We accept that there are significant challenges in quantifying the likely NORM waste arisings both in total and on an annual basis. We welcome the attempt to do so but hope that more accurate date can be produced in future years.
Paragraph 3.51 notes the negative attitude of the public to NORM waste disposal and the limited facilities available – with only one site in the UK that can take hazardous NORM waste. The paper notes that this ‘clearly places a constraint on the extent to which the proximity principle can play a role.’
While we accept the challenge of identifying sites and encouraging new players to enter the market, we do believe that the maximum effort should be made to reduce waste arisings (through application of the waste hierarchy) and to look at other disposal options where possible. We believe that the nationally important role that the communities which host these landfill sites should be recognised through the provision of appropriate community benefits.

Question 4: Do you agree with the Key Themes for the NORM waste strategy set out in Chapter 4? What different or additional themes should the strategy address?

Section 4.4 sets out the Principles for the NORM Strategy:
The fourth bullet point states that it is ‘for the market to provide treatment and disposal capacity.’ We believe the market has a clear role to play but that there also needs to be an element of strategic planning to minimise the negative impacts caused by the transportation, management and disposal of NORM.
Bullet point 8 supports the integration of strategies for all waste, radioactive and non-radioactive. NuLeAF has long supported this and has consistently highlighted the issues caused by the lack of a joined up approach. We would welcome more clarity as to how Government intends to achieve this.

Question 5: Do you have any comments on how NORM waste producers are performing with respect to the roles and responsibilities set out in Chapter 4?

4.17 states that ‘NORM waste producers deciding on disposal routes need to consider the proximity principle and transport issues. However, these issues should not be the dominant ones…’ While we accept that other considerations are important, the negative impacts of long distance transportation of waste can be significant, both for communities and for carbon emissions. We believe therefore that a stronger emphasis must be places on transport and proximity. It is difficult to see how the current statement in 4.17 will have any material impact on decisions as to where waste is produced and how it is transported.

Question 6: Do you agree that the various values underpinning NORM waste regulation should be reviewed? If yes please provide any information you feel would be appropriate to take into account including how best the outcome of the review can be implemented.

No comment.

Question 7: Do you have any comments about the implementation of Article 37 requirements in the UK with respect to the management of NORM waste?

No comment.

Question 8: Do you have any comments about the regulation of the import and export of NORM waste in the UK?

No comment

Question 9: Do you have any comments on the approach in the UK to the averaging and characterisation of radioactive waste, or on the adequacy of guidance on this issue?

We support the position set out.

Question 10: Do you agree with this position on dilution that takes place during the conditioning of waste?

We agree with the position set out in the consultation.

Question 11: Do you agree with the criteria proposed by government to assess whether or not views conditioning of NORM waste to facilitate recovery of is acceptable?

No comment

Question 12: Do you think it is necessary to put in place regulatory mechanisms to facilitate the recovery and use of NORM wastes, and if so please give details?

No comment

Question 13: Do you agree that there should be no requirement to inform waste management companies about exempt radioactive waste? If not please provide any information that would justify a change to the current position.

We agree with the position set out in the paper.

Question 14: Do you support measures to improve the collection and sharing of data on NORM wastes? What processes could be used to collect data with an acceptable burden to business? What role can industry and industry groups play in collecting data?

No comment

Question 15: Do you have any information about the areas of potential growth in NORM arisings identified in Chapter 6, or on other possible growing sources of NORM waste?

We have no information to add.

Question 16: How can the functioning of the market for NORM treatment and disposal services be improved? Is there a potential role for an enhanced brokerage facility for NORM wastes?

No comment

Question 17: What is the best way to involve industry in the implementation of this strategy?

We believe that Government and regulators should facilitate ongoing discussions with the industry to ensure co-ordination and enhanced data availability and accuracy.

Question 18: Do you have any comments on the risks to implementation that are described in Chapter 6? Would you identify any additional risks?

No comment

Question 19: Do you have any other comments about the consultation paper or the proposed NORM strategy?

No further comments beyond those set out above.