Appendix CRF - Part 3 - Northamptonshire County Council

adioactive substances regulation should be brought under the Environmental
Permitting regime. In the latter case the Best Available Techniques or BAT
concept would be applied to the LLW management process.
3.5.3 BSSD sets out requirements on the EA in relation to permitting which have been
addressed by this application including: dose limits, dose constraints,
authorisation conditions designed to be protective of human health, authorisation
limits which have in-built safety factors, flexible authorisation limits and proposals
for environmental monitoring.
3.5.4 BSSD sets out the requirements that management of radioactive waste disposal
should be undertaken following consultation by an operator with a Qualified
Expert. For this application qualified experts are provided under contract to the
site operator by the Health Protection Agency and the site operator has used
suitably qualified and experienced advisors to prepare the application obtained
from Galson Sciences and UKAEA.
3.6 Environmental Permitting Regulations 2007
3.6.1 The existing East Northants Resource Management Facility is permitted under
the Environmental Permitting(England and Wales) Regulations 2007. These
regulations set out a pollution control regime for landfills.
3.6.2 To operate the landfill, a permit was issued under the Pollution Prevention and
Control (PPC) Regulations 2000. These regulations have just been rationalised
into the Environmental Permitting Regulations 2007. A new Environmental
Permit was issued for the site in March 2009. PPC and EPR seeks to improve
environmental protection by introducing measures to reduce or prevent
emissions to air, land and water.
3.6.3 The existing landfill has been built and is operated within these regulations and
hence the pollution prevention measures which exist are of direct use in
minimising pollution from the LLW.
3.6.4 The EPR regime does not currently incorporate radioactive materials because
they are not controlled wastes. However an activity may be controlled by both
EPR and the Radioactive Substances Act 1993 and that regulators will ensure
that the two regimes do not impose conflicting obligations on the same matter.
3.6.5 The existing landfill is permitted under these regulations and that permit applies
conditions. In order for LLW to be permitted for disposal in the landfill they
require to be permitted under the Radioactive Substances Act and it is proposed
that the risk assessment constraints that apply to the existing landfill should be
replicated within the RSA authorisation where applicable and in a non conflicting
manner.
Application for disposal of LLW including HV-VLLW under RSA 1993,
for the East Northants Resource Management Facility:
Supporting Information
July 2009
35
WS010001/ENRMF/CONSAPPCRF 354