Challenges in LLW Management: a Local Government Perspective Fred Barker, Executive Director, NuLeAF SAFESPUR FORUM 29 April 2009

Introduction to NuLeAF Established in 2003 – a Special Interest Group of the Local Government Association 103 member authorities in England and Wales – including those with nuclear sites Steering Group – meets quarterly to oversee work programme and approve proposed initiatives

Overall Aims 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; 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.

LLW Strategic Objectives To seek to ensure that LLW Strategy is developed and implemented in ways that can inspire local authority and public confidence In the context of implementation of the waste hierarchy and subject to suitability of the nuclear licensed site in question, to encourage development of local or regional LLW management facilities at existing nuclear sites, rather than at non-nuclear sites.

A Key Challenge NuLeAF supports: the need to preserve LLWR capacity; rigorous application of the waste management hierarchy; and opening up new disposal routes. But the challenge of WHERE to site facilities is critically important to local government. Illustrate the point by reviewing the pros and cons of On-Site Disposal (OSD) v landfill.

The Case for OSD of LLW Springfields – local stakeholder preference for on-site disposal, not disposal to landfill at Clifton Marsh (no LLW transport, use of a purpose-designed facility and confidence in nuclear site management) Hinkley – SLC considers on-site disposal to be a simple and sustainable approach, offering a significant financial saving against the ‘baseline’ (disposal to LLWR). A facility could accommodate all LLW from ‘final site clearance’ (a significant LLWR capacity saving).

Disadvantages of OSD Requires an increase in short-term funding to secure the financial savings May be perceived by some local stakeholders as incompatible with their preferred ‘end uses’ for the site May be a delay to de-licensing the OSD ‘footprint’ beyond ‘final site clearance’

The Case for Disposal to Landfill Contribution to multiple disposal routes Conforms with Government policy on a ‘risk- informed approach’ Avoids increase in short-term funding for OSD Transfer of long-term risks to the supply chain

Disadvantages of Disposal to Landfill Risks local community and local authority opposition (local transport, lack of confidence cf OSD, bucks trend away from landfill use, adverse socio-economic impacts) Wider impact on public attitudes to the nuclear industry Uncertainties of relying on supply chain (particularly if concerted local opposition) Can only take a proportion of LLW (10-30% at Magnox sites)

NuLeAF’s Preferred Approach View on balance of pros and cons will depend on your stakeholder perspective and the sites in questions NuLeAF’s view – a national organisation representing local authority interests – is that where practicable OSD is preferable We think NDA should encourage SLCs to examine the potential for facilities on or adjacent to their sites, before considering other sites (including landfill)

Local Authority Planning Local planning policy – the main material consideration in judging planning applications – could encourage concentration of facilities at or adjacent to existing sites Local applications for authorisation to dispose to landfill – the local planning authority will want to check the original planning permission and conditions Renewal or extensions to planning permissions for landfill – planning authorities may wish to re-visit conditions (to ensure that only waste types specified in the application are disposed of)

Role of ‘Public Acceptability’ NDA mission is to “deliver safe, sustainable and publicly acceptable solutions”. This implies: NDA should give a high level of consideration to public acceptability in the development and implementation of LLW strategy NDA will need to carefully assess what proportion of consultation responses can genuinely be taken as broad support for its proposed strategy, and how to revise that strategy if broad support for aspects of it does not exist

Finally, Some Questions … If the management of LLW becomes dispersed in more communities, will this lead to more widespread understanding and acceptance of things radioactive, or stir up wider opposition? How can a path be taken that gives appropriate weight to ‘public acceptability’? Should NDA spend more in the short term to fund OSD, which is likely to achieve longer term savings and wider stakeholder confidence?