Appendix CRF - Part 3 - Northamptonshire County Council

waste properties the risk assessment underpinning the existing permits is
conservative because LLW with non hazardous or inert properties will have a
lower non-radiological risk than the existing risk assessment allows for.
3.2.7 An approach to regulation could be for the RSA authorisation to replicate the
relevant conditions of the existing permit/risk assessments in addition to further
conditions specific to the LLW. This could be achieved by reference to the
existing risk assessments which underpin the current landfill permit and this
approach is assumed in the remainder of this document.
Existing Permit under the
Landfill Regulations 2002
Application for disposal of LLW including HV-VLLW under RSA 1993,
for the East Northants Resource Management Facility:
Supporting Information
New Authorisation
under RSA 1993 for
LLW disposal which
also refers to existing
risk assessment
constraints
A Hazardous Waste stream Applies Does not apply because
the waste is not a LLW
LLW that does not also Does not apply because the
Applies
possess Hazardous Waste
properties
waste is not a controlled waste
LLW that does also possess Does not apply because the
Applies
Hazardous Waste properties waste is not a controlled waste
The parallel regimes of the Landfill Regulations and the Radioactive Substances Act
3.2.8 The majority of the wastes will be LLW with other properties that are nonhazardous
or inert. This raises the question of why a hazardous waste site such
as the East Northants Resource Management Facility should be authorised as
opposed to a non-hazardous site. The reasons for proposing this arrangement
are:
Use of a hazardous site will allow the small amounts of LLW that are also
landfillable hazardous waste to be consigned (for example, asbestos
gaskets in radioactively contaminated waste ventilation ducts) and this
helps prevent such wastes becoming orphaned.
Hazardous waste sites have to be engineered using Best Available
Techniques (BAT) that are to the highest standard for landfill and
therefore represent a good choice for LLW which have to be disposed of
using Best Practicable Means (BPM) that also meet a high standard.
Hazardous landfills have well developed operational procedures for the
acceptance and handling of difficult wastes. For example, the East
Northants Resource Management Facility has a comprehensive
laboratory with qualified chemists who will be able to manage the
acceptance and disposal of the wastes. The facility utilises waste
handling methods that are identical to those required for emplacing LLW.
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WS010001/ENRMF/CONSAPPCRF 350