Appendix CRF - Part 3 - Northamptonshire County Council

the Environmental Permitting Regulations (formerly the Landfill Regulations) and
which applies to non-radioactive pollutants. Indeed, there is a view that that BAT
and BPM are synonymous. Many BAT features of new landfill sites for
hazardous waste such as the East Northants Resource Management Facility are
effectively prescribed (for example, the permeability performance of barrier
layers), whereas BPM features are not so specifically prescribed.
11.2.6 The BPEO study undertaken for the example Harwell waste stream is likely to be
typical for all decommissioning waste arising. That study indicates that shallow
disposal in an engineered facility is likely to be the BPEO for most low level
decommissioning wastes of the type proposed for ENRMF. Hence, BPM for
such an option focuses on the design of the facility, whether it meets modern
standards and whether any further straightforward improvements are feasible.
11.2.7 The current state of the wastes on the various nuclear sites, whilst adequately
controlled, is unarguably less satisfactory and less sustainable than final
disposal. If the waste is not disposed to engineered facilities it will remain in
above ground stores or in contaminated land areas and will present a higher risk
to future generations. The proposed option represents a net reduction in risk
from the current situation.
11.2.8 It is submitted that use of a modern standard hazardous waste landfill that has
been designed and implemented using BAT under recent legislative guidance
represents BPM for the disposal of LLW of the type proposed for ENRMF. The
reasoning is that the LLW has the same chemical properties whilst being no more
mobile and are generally less reactive than the hazardous wastes for which the
landfill was designed and that the landfill was designed in such a way as to
prevent harm to humans and the environment. If a new specialist landfill were
designed for the LLW of the type proposed for ENRMF it is unlikely to use
engineering features and standards beyond those currently used to define BAT
for modern hazardous waste landfills.
11.2.9 The risk assessments in this application support the case that the existing landfill
design will prevent harm arising from the LLW to an appropriate risk standard.
11.2.10Further limitations have been proposed on the disposal that are additional to the
BAT features of the existing landfill and these are described throughout this
application and in particular in section 5, including :
Wastes will only be accepted for disposal if the source site (in the case of
a nuclear industry site) demonstrates that the option is BPEO and that
BPM has been used to apply the waste hierarchy and to characterise the
waste.
The radiological capacity of the landfill has been back calculated to give a
design risk target under the most restrictive future scenarios of