Appendix CRF - Part 3 - Northamptonshire County Council

3.1.3 The HPA have recently issued their advice on Radiological Protection Objectives
for the Land-Based Disposal of Solid Radioactive Wastes (ref 14) which provides
overlapping guidance to the guidance on requirements for authorisation. Where
there is a conflict between these guidance documents the guidance on
requirements for authorisation has been used.
3.2 The Radioactive Substances Act 1993
3.2.1 The Radioactive Substances Act (RSA) 1993 defines what a radioactive waste is,
establishes that users of radioactive material/waste must be registered (section 6
and 7) and establishes arrangements for the authorisation of disposal and
accumulation of radioactive waste (section 13). The Environment Agency
provides regulation of RSA 1993 in England and Wales.
3.2.2 This application for authorisation of disposal and for registration as a user of
radioactive materials is made under the RSA 1993.
3.2.3 Note that the East Northants Resource Management Facility is an existing
permitted hazardous waste landfill under the Landfill Regulations 2002. The LLW
authorisation, should one be granted, is additional to the existing permits and
may be considered a separate but overlapping regime. The total tonnage
capacity and the broad environmental impact of the landfill will be unaffected by
the permitting of this type of waste.
3.2.4 Where wastes are currently acceptable under the existing permits it is proposed
that these arrangements will not be altered by any new authorisation granted
under RSA 1993. The LLW authorised under RSA 1993 will have to comply with
both the existing risk assessments (which underpin the existing permit conditions,
as far as they can be applied and referred to in the new permit) and the RSA
authorisation.
3.2.5 LLW is radioactive waste and is therefore not a “controlled” waste in England and
Wales (ref 7 and 11). The regime of regulation that applies to conventional
landfill sites encompasses controlled wastes and does not cover LLW. The
Hazardous Waste Regulations exclude radioactive waste except in the special
case where the waste is exempt from the requirements of the RSA 1993 for
disposal but is still a radioactive waste. This can occur for some so-called
“exempt” wastes that are