Land Management Guidance (v2)

2. Land Management Guidance (v2) Philippa Towler

3. Purpose • Aid for those responsible for the management of contaminated land • Primarily for site owners, operators and their contractors • Inform stakeholders (regulators, public) • Supplements government and regulatory guidance

4. Status Living document, intended to be revised at intervals: • In light of experience; • In response to policy changes; • In response to regulatory changes; and • Other changes.

5. Scope • Radioactive, non-radioactive and mixed contamination on nuclear-licensed and non-nuclear defence sites on which there is radioactive contamination • Deals mainly with general approaches • Not prescriptive • Strategic planning and specific issues • Is technical but focuses on issues outside this sphere (citizens guide)

6. SAFEGROUNDS Documents Land Management Guidance v2 detail in • Site Characterisation Guidance -2000(8) • Options Comparison Guide -2007(8) • Health & Environmental Risks -2005 • Record Keeping - 2007 • Regulatory Framework - 2007 • Citizen’s Guide - 2007(8)

7. Key Principles • Protection of People and the Environment • Stakeholder Involvement • Identifying the Preferred Land Management Option • Immediate Action • Record-Keeping

8. KP1: Protection of People and the Environment The fundamental objective of managing contaminated land on nuclear-licensed sites and defence sites should be to achieve a high level of protection of people and the environment, now and in the future.

9. KP2: Stakeholder Involvement Site owners/operators should involve stakeholders in planning and decision-making processes for the management of contaminated land.

10. KP3: Identifying preferred LM option Site owners/operators should identify their preferred management option (or options) for contaminated land by carrying out a comprehensive, systematic and consultative assessment of all possible options. The assessment should be based on a range of factors that are of concern to stakeholders, including SHE impacts and various technical, social and financial factors.

11. KP4: Immediate Action Site owners/operators should take measures immediately to monitor and control all known (or suspected) contamination and continue such measures until an acceptable management option has been identified and implemented.

12. KP5: Record-Keeping Site/owners/operators should make comprehensive records of the nature and extent of contamination, the process of deciding on the management option for the contaminated land and the findings during the implementation and validation of the option. All records should be kept and updated as necessary.

14. Stage 1: Applicability • Is it known or suspected that radioactive contamination is present above natural or artificial background? • Identify the relevant legislation, statutory and regulatory guidance

15. Stage 2: Formulation of Plans • Stakeholders • Range of stakeholders depends on the significance of the contamination and the stage in the land management process • Consult key stakeholders if in doubt as to who to involve • Discuss resource required by stakeholders – commensurate with scale of problem, but may need capacity building • On NLS integrate with other engagement programmes (e.g.IWS) • Defence site more limited – sale v retention issues

16. Stage 2: Formulation of Plans • Record-keeping • Cover all characterisation work, decision making processes, implementation of chosen option, validation and stakeholder interaction • Recommendation for a ‘Land Quality File’ – part of documents MS Long-term storage is a National problem • Nuclear site licensees keep till ‘period of responsibility’ ends • No mechanism for storage in accessible form • Nor for updating records for delicensed land and sold for non-nuclear use • MOD has long-term record storage, but not updated once land sold • Regulator register of ‘Special Site’ but not for detailed records Recommend owner keeps and passes to new owner

17. Stage 3: Characterisation & Immediate Actions Characterisation: • Phase 1 with preliminary risk assessment – consider need for immediate action • Prioritise, plan and implement targeted Phase 2 with generic or detailed risk assessment • Prioritise areas • Prioritise, plan immediate, short-term, long-term management measures (enough data?) Consult Stakeholders: 1. Contaminants of concern 3. Characterisation techniques 2. Areas of interest 4. Background measurements

18. Stage 3: Characterisation & Immediate Actions Immediate Actions Aims: • Control source • Prevent spread of contamination • Control exposure • Monitor until loner-term management started Not always necessary (risk assessment/change of use) Do not prejudice long-term management options Stakeholders

19. Stage 4: Long-Term Strategy • Site owners/operators and stakeholders assess and compare candidate strategies; • Site owner/operator identifies preferred strategy, with stakeholder input; • Preferred strategy is considered by regulators’ and others’ acceptance procedures; • Site owner/operator develops proposed strategy; • Regulators and decision-makers assess proposed strategy; and • Site owner/operator decides on strategy to be implemented 1 & 2 = Option Comparison guidance Whole site or Specific Areas

20. Stage 6: Achievement of end-state • Implementation of preferred option (monitoring, waste management, stakeholders) • Validation – consideration by stakeholders; independent verification

21. Issues to consider: • Is the LMG useful for you as a consultant/contractor? • Where has/can it benefit the industry most? • How far should the link with CLR11 go and why?