Barlow Geosafety has today submitted a response to the public consultation on Radioactive Waste Management proposals for evaluation of potential geological disposal sites in England.
In the response we make three key points:
We support the proposal to utilise RWM’s published Disposal System Specification as the source of Requirements to dictate the Siting considerations but conclude that the proposed Site Evaluation (Framework?) is not yet sufficiently transparent to understand how it will work in practice or how the Requirements will be translated into useful siting criteria. Further work is required in this respect.
We conclude that the Site Evaluation seems to gloss-over the role of comparative evaluations. The consultation identifies two key milestones where such evaluations may be required in support of Siting recommendations made to the Secretary of State. It fails to recognise that comparative evaluations of some form will be a necessary feature throughout this iterative process even at the earliest stages, not just at the two key milestones flagged in the text.
The third point relates to what RWM describes as the “evaluation approach” for comparative evaluations. We support RWM’s contention that this be “qualitative, evidence-based and iterative” but recommend that the suggestion that it will not involve ranking or scoring be revisited. Any comparative evaluation must by its nature involve some form of ranking - perhaps RWM means that they wish to avoid use of a numerical scoring system - if this is so then this would be supported. Qualitative assessment systems are widely used and commonplace in for example, environmental impact assessment and road options assessment, where it is necessary to rank alternative options and such a system could be utilised for such a Siting application. Indeed the Generic Environmental Assessment published by RWM in 2016 includes a comparative evaluation scheme that could form the basis of a “qualitative, evidence-based and iterative” system to be utilised in support of Site Evaluation.
See the response here