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1. Draft key principle: protection of human health and the environment
"The fundamental objective of managing contaminated land on nuclear-licensed sites and defence sites should be to achieve a high level protection of human health and the environment, now and in the near and far futures. It should not be assumed that protecting human health will always protect the environment, or vice versa."
2. Draft key principle: identification of preferred land management option
"A ‘best practicable environmental option’ (BPEO) approach, as recommended by the Royal Commission on Environmental Pollution, should be used to identify the preferred land management option (or options). A range of stakeholders should be involved in establishing the framework for the BPEO analysis and in carrying it out."
3. Possible issue for a key principle: timing of clean-up
4. Possible issue for a key principle: general clean-up objectives
6. Draft key principle: stakeholder involvement in land management decisions
"The owner of the site is accountable for land management decisions, but broadly based stakeholder consultation is essential. Its scope should take account of stakeholders’ perceptions of the significance of the project. Consultation should be, and be seen to be, an integral part of the decision-making process and there must be a genuine willingness to consider alternative courses of action. Access to relevant information is a prerequisite for effective participation."
7. Draft key principle: funding land clean-up
"The polluter must pay for the management of contaminated land. In general, land should be cleaned up before it is sold or sold on the basis that the new owner will clean it up promptly. The sums of money set aside for clean-up should include contingency funding, or insurance, for dealing with contamination that is not known about at the time of initial clean-up."
8. Draft key principle: keeping records of what has been done at a site
"Comprehensive records of contamination and remediation should be drawn up by the site owner. These records should be treated as legal documents and passed on to new owners when the site is sold. A second copy or summary version of the records should be lodged with a public body. Arrangements should be put in place to keep records indefinitely and to make them available for public scrutiny on request."
9. Issues not appropriate for key principles The following seven issues (A-G) were raised during the first stage consultation. They are not appropriate for inclusion in key principles for land management but may need to be taken forward in the SAFEGROUNDS project. Please indicate (by answering questions 10-16) which of them you think should be taken forward and how, which of them should not be pursued, and give your reasons:
Carrying out a UK national consultation on standards/policy
Review, revision, and clarification of the law
Setting up a segregated fund to meet the costs of cleaning up
Inclusion of information in the UK Radioactive Waste Inventory
Encouraging the government to fund further, independent research
Checking the consistency between Part IIA of the Environment Act and the Pollution
Prevention and Control Regime
Considering mitigation banking
(Answers to this question are missing).
discontinuation of the use of the 0.4 Bq/g level in the Substances of Low
Activity Exemption Order (SoLA) as a clean-up target for contaminated land
establishing new ‘de minimis’ radioactivity levels for ground
and groundwater (i.e. Bq/g levels below which the ground or water would not
be considered to be radioactively contaminated)
taking account of fundamental uncertainties about the health effects of low
level radiation and of differing scientific paradigms about radiation effects
on humans
preventing radioactively contaminated sites being abandoned without clean-up
making arrangements for records of contamination and clean-up to be kept by
public bodies