home > about > archive > past consultations > july 2000 workshop

Workshop on land management options, July 2000

This report by David Churcher, Senior Research Manager, CIRIA, has been produced to convey the essence of what was discussed at this workshop to those who were not present. It has not been approved by the workshop participants.

• Introduction
• Operational nuclear-licensed sites
• Nuclear-licensed sites intended for de-licensing
• MoD sites planned for change of use or ownership
• The way forward

Introduction

The purpose of the workshop was to identify the issues of concern regarding the selection, implementation and validation of land management options to deal with radioactively contaminated land on nuclear licensed sites (both those still operational and those intended to be delicensed) and non-licensed defence sites.

Delegates to the workshop represented a broad range of stakeholders in these issues - site owners, regulators, local authorities, contractors, pressure groups, central government. The findings from the workshop will feed into the preparation of best-practice guidance, which will be prepared by the SAFEGROUNDS Learning Network.

This report presents the key messages coming out of the issues generated at the workshop, and is divided into three main parts, one for each type of site that the land management guidance will be dealing with.

Operational nuclear-licensed sites

Some issues for this type of site were considered to be related to policy, rather than problems affecting those involved in actual land management.

The main groupings of policy issues were:

• Issues to do with the source of contamination (e.g. tritium may be present in low levels in groundwater, but cause a major public relations problem; or the fact that mixed contamination gives rise to different regulatory requirements, different responsibilities for investigating and remediating and different timescales)
• Issues to do with the risk/safety driver (e.g. transfer of radioactivity from one place to another as part of the waste management process; the need to deal with problems now while regulatory and best practice guidance is still being formulated; the implications of the chosen option for future delicensing)
• Issues to do with the regulatory framework (e.g. the need for a common approach across all types of contamination and across all regulators)
• Issues to do with definitions (e.g. potential differences in future definitions of 'radioactively contaminated land' for licensed and non-licensed sites; changes in the definition of what is safe over time; how to deal with contamination that pre-dates any licenses or authorisations)

The main groups of issues concerned with selecting the best land management option were:

• Process issues (e.g. problems of secrecy and the public perception of this; the need for transparency, for example in the composition of local liaison committees; criteria to determine the level of sophistication in the selection of options)
• Operational constraints (e.g. impact of land management on on-going operations, and vice versa; through-life management of the site)
• Health and safety (e.g. balancing risks to remediation operators with long term environmental effects)
• Attributes of options (e.g. cost; practicality; stakeholder involvement; value for money; sense of perspective with regard to hazards; waste acceptance criteria)
• Need for a best practicable environmental option (BPEO) approach

The main groups of issues concerned with implementing the best land management option were:

• Process issues (e.g. forms of contract; sentencing and averaging; preparation of site strategies and plans)
• Regulatory issues (e.g. consistency in approach to safety cases)
• Operational health and safety (e.g. requirements for workforce and public safety)

The main groups of issues concerned with validating the land management were:

• Keeping records (e.g. which ones; for how long; in what way; quality assurance)
• Timing of validation exercises (e.g. one-off or indefinite monitoring)
• Long term integrity of the land (e.g. disturbance by animals; dealing with future accidental discharges)

In addition to these principal sub-divisions of the issues, there were some general or miscellaneous points made under the following headings:

• Disposal (e.g. lack of disposal routes for large volumes of waste)
• Consultation (e.g. when should the licensee start talking to the public, need to use local liaison committees)
• International dimension (e.g. reference to lessons learned by US Department of Energy - existing web site)

Nuclear-licensed sites intended for de-licensing

This sub-group divided issues into 5 categories - policy, general, selection, implementation and validation. In addition to categorising the issues generated by the whole group, the sub-group made some comments on each category.

The main groups of issues concerned with policy were:

• Definition of endpoints (e.g. how is "no danger" defined; how might this change in the future; if the public's view of "clean" is different from the regulatory view or the industry's view, how can these be reconciled so that everyone accepts the levels of clean-up to be achieved)
• Consultation regarding de-licensing (e.g. who should NII consult; should consultation with the public be made a legal requirement)
• Transfer of liabilities (similar to point made under MoD sites)
• Dealing with groundwater

General issues covering the whole of the land management process:

• Disposal costs (e.g. the volumes of LLW envisaged; the costs of disposing of radioactive material at a cost appropriate to the real level of hazard)
• Forms of contract for remediation works
• Groundwater issues and migration of contamination off site
• Acknowledgement that de-licensing can apply to parts of a site or to the whole site

The main groups of issues concerned with selecting the best land management option were:

• Timescales (e.g. wishing to de-license ahead of guidance; need to consider long term management alongside de-licensing options; what timescales do we build into risk calculations)
• Community involvement
• Waste management methods (e.g. on-site burial, on-site storage, off-site disposal)
• Impact of future use considerations on options

The main groups of issues concerned with implementing the best land management option were:

• Averaging volumes (e.g. impact on waste disposal routes and costs)
• Relationship between the depth at which contamination is buried and the level of risk
• Techniques for reducing volume of material (e.g. soil washing; phytoremediation; segregation of waste streams)

The main groups of issues concerned with validating the land management were:

• Averaging volumes for calculating residual levels of contamination
• Understanding the audience (e.g. who are we validating for, and how)
• Quality Assurance (e.g. systems for storing records; keeping documents for the long term

MoD sites planned for change of use or ownership

This sub-group considered the three stages of the land management process (selection, implementation and validation) and a general category of issues

The main groups of issues concerned with selecting the best land management option were:

• Suitability for use (e.g. remediating to fitness for purpose; allowing some radioactivity to remain)
• Risk based methods (e.g. consultation on criteria; use in decision making)
• Access to records (e.g. are these even available?; tracing contamination back to WWII; what about bases occupied by foreign governments
• Different options available (e.g. dig & dump; containment; barriers; new methods such as phytoremediation)
• Level of expertise in Local authorities to deal with (previously) radioactively contaminated land

The main groups of issues concerned with implementing the best management option were:

• Averaging volumes (e.g. need definitions)
• Availability of information (e.g. to contractors; to the public)
• Public risk during works
• Terms of engagement (e.g. contracts defining end points; assignment of risk between parties)

The main groups of issues concerned with validating the land management were:

• Verification (e.g. satisfying all parties; audit trails; degree of investigation required to prove site is clean; public access to validation information
• Continuing management (e.g. post-disposal programmes; limitations on end-use)
• Dealing with MoD sites overseas

General issues raised concerning land management:

• Planning guidance (e.g. project could comment on proposals)
• Similarities with MoD nuclear sites (non-licensed, not destined for change of use or ownership) and former MoD sites - include these in the project?
• Scope of the guidance (e.g. whether or not a risk guided contaminated land regime exists; what about sites about to be sold, or already sold?)
• Definitions (e.g. remediate vs. manage; risk; radioactive)

The way forward

Although it had previously been thought that the three types of site would each be the subject of a separate guidance document, the view of the workshop was that a single document would be more sensible. There was most support for a document that had a common front end, with separate supporting sections for each type of site.

Evaluation at the end of the workshop showed a high degree of commitment from the participants to the dialogue process. The quality of the results achieved was judged to be good, given the time constraints in tackling three large subjects in one day.

Given that the majority of the participants at the workshop were from a technical background, it was agreed that it was vital that more input to the guidance was obtained from a wider range of local authorities, non-governmental organisations and community based organisations, whose interest would be mainly socio-political. With this in mind, preparation of the guidance will involve many different parties - participants at future workshops, consultation through the SAFEGROUNDS web site, a technical Group, a mainly Group giving feedback on non-technical issues and a research contractor.

David Churcher, CIRIA
August 2000

sitemap