Spatial Planning & the Implementation of Strategy for the management of Nuclear Industry LLW

1. Spatial Planning & the Implementation of Strategy for the management of Nuclear Industry LLW David Palk Development Manager Suffolk County Council

2. Outline of presentation • Policy & Strategy for management of LLW • Waste Planning Policy: PPS10 • Waste Development Frameworks • Some issues for waste planners in dealing with radioactive waste • Example from Suffolk Waste Core Strategy

3. UK Policy & Strategy for management of LLRW 2007/2010 • Key elements in relation to planning • “All nuclear licensed sites should have a plan for the management of their LLW holdings and predicted future arisings….....” • Minimise waste arisings & deal with waste as far up the waste hierarchy as possible • Avoid, Reduce arisings, Minimise arisings, Disposal • Proximity principle should inform options assessment but must be balanced with other considerations

4. UK Policy for management of LLRW 2007 • Decommissioning will generate more LLW than can be accommodated at the LLWR near Drigg • Will need other ways to manage LLW including treatment and alternative disposal routes • Management of waste based on an assessment of all practicable options • “The Government sees no reason to preclude controlled burial of radioactive waste from nuclear sites from the list of options to be considered in any options’ assessment”

5. Interactions with Planning Authorities • Strategy should be used as guidance by WPAs when preparing their WDFs • Waste managers and facility operators should recognise importance of early dialogue both for WDFs and planning applications • Recognise complementary nature of planning & pollution control regimes • Need for a sufficient evidence base about volumes, types and timing of such arisings on a region by region basis and reasonably foreseeable facilities that might be required

6. Planning Policy Framework

7. PPS 10 Planning for sustainable waste management • Drive waste management up the waste hierarchy • Provide a framework in which communities take more responsibility for their own waste • Help secure the recovery or disposal of waste without endangering human health and without harming the environment • Enable waste to be disposed of in one of the nearest appropriate installations • Reflect the concerns and interests of communities

8. Waste Development Frameworks • WPAs have a duty to produce a M&WDF. • Must include a Core Strategy which will set the spatial framework for dealing with waste development • May also produce a Site Allocation Development Plan Document identifying sites considered suitable for waste management uses • Form part of the Development Plan and planning applications must be determined in accordance with it unless material considerations indicate otherwise

9. Sticky Planning Issues • Uncertainty in assessing need • Uncertainty in operation of the “proximity” principle • Are LLW facilities “specialist” and if so what are the ramifications of this?

10. Sticky Planning Issues • Uncertainty in assessing need • What are we planning for? How much waste is likely to arise? And when? Can this be disaggregated to individual WPA area or only to, say, regional level? • Now that the regional tier of planning has gone what mechanisms will be in place to address this issue? • Allied to quantities is type of facility. Are we planning for Storage? Treatment? Recycling? Incineration? Landfill? All of the above? Can this be done at individual WPA level?

11. Sticky Planning Issues • Uncertainty in operation of the “proximity” principle • PPS 10 “Enable waste to be disposed of in one of the nearest appropriate installations” • Does that mean that waste must be dealt with as close to its source of origin as possible, or something different? • Is distance travelled the only criterion that needs to be considered? • Is LLRW different to other wastes in this respect? • How does this sit with the assertion that communities should take responsibility for its own waste? • Is LLW a community waste or a national waste?

12. Sticky Planning Issues • Are LLW facilities “specialist” and if so what are the ramifications of this? • There may be a case for a limited number of facilities that serve a national or regional need by virtue of • Specialist nature of the facility • Limited amount of waste and therefore need for only a few such facilities • Limitations of where such facilities may be located • Does this apply to LLW management and if so why?

13. Some policy options • County self sufficiency i.e. will make provision for wastes arising within the WPA area and perhaps accept that some limited cross boundary movement might be acceptable • For significant “import” of waste indicate that for this to happen it would need to be identified as the best option for dealing with that type and volume of waste • If seeking community benefits to reflect national or regional role of LLW facilities set these out in Policy • Could adopt a sequential approach with on site, adjacent to site, remote from site with preference to other nuclear sites • Restriction on origin of waste being managed

14. Suffolk Waste Core Strategy • WDM19 Treatment, storage and disposal of low and very low radioactive waste at Sizewell nuclear power stations • Facilities for the treatment, storage or disposal of LLW or VLLW generated at Sizewell nuclear power stations will be acceptable within the Nuclear Licensed Areas at Sizewell where; • a) This is consistent with national strategy for managing LL and VLL RW and discharges and /or the decommissioning plans for the Sizewell stations, and; • b) The outcome of economic and environmental assessments justify it being dealt with on site, and; • c) facilities are located & designed to minimise adverse impacts on the environment Only LL or VLL RW generated at Sizewell shall be treated, stored or disposed of in such facilities

15. Things to consider • Talk to your SLCs • Talk to neighbouring authorities especially if you don’t have NI sites • Look at the LLW management plans for each site • Try to ascertain, how much, of what, by when? • Think about what realistic options there are? • Use available expertise including Stakeholder Groups • Think about how the community will react and engage them! • If you decide you need policies covering LLRW make sure you cover this at Issues & Options stage • If you don’t think you need policies say so but do include some text in your Strategy to show you have thought about the issue

16. Things we could have done better • Should have engaged the Sizewell Stakeholder group earlier • Should have pushed a little harder to get better information from SLCs • Didn’t really address the Non NI issue • Have only really addressed on site management • Have ducked the landfill issue • Still don’t have a really clear picture of what the implications of decommissioning at Sizewell A is for the Waste Planning Authority