Response to RWM's Site Evaluation (England) Consultation

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

Welsh Government publishes Working with Communities policy

Following consultation in 2018, the Welsh Government has published its new policy for geological disposal of higher activity radioactive waste in Wales. The policy shares many features of the equivalent policy recently published by BEIS for England. Its founded on the principle of partnership working between communities and the developer, Radioactive Waste Management Ltd, although is tailored for the different local authority structure applicable in Wales.

The new policy is available on the Welsh Government website - here.

In response to the new policy announcement, Radioactive Waste Management have issued a version of their proposals for evaluation of potential host sites in Wales, for public consultation. The public consultation is open until 14 April 2019.

Government publishes new policy and RWM launches Siting process for geological disposal

Following public consultation on the draft earlier this year, Government has today published its updated policy framework Implementing Geological Disposal - Working with Communities. This is applicable to England only: a separate, but compatible policy is promised for publication by the Welsh Government in due course.

This important policy step has enabled Radioactive Waste Management Ltd to launch its Siting process with the invitation to communities to find out more about what would be involved in hosting a geological disposal facility and whether the geology in their area might be suitable. To aid this process RWM has published its long-awaited geological screening information and issued its Site Evaluation methodology for public consultation.

RWM has also issued Community Guidance explaining how it anticipates working with communities throughout the Siting process and an accompanying Prospectus introducing the project and setting out why a community might want to get involved.

Working with Communities

The new policy framework for the long-term management of higher activity radioactive waste confirms Radioactive Waste Management Ltd as the delivery body for the planned geological disposal facility. The framework maintains the previously proposed consent-based approach and sets out the working arrangements between RWM and the community. The policy describes the proposals for community investment funding, the right of withdrawal and the test of public support. The policy also sets out the role of the Community Partnership and principal local authority/ies.

Policy here

National Geological Screening

Radioactive Waste Management’s national geological screening information is now live. The geological screening web-site presents for the first time information and maps describing the geology of England, Wales and Northern Ireland down to a depth of around 1000 metres, with the particular objective of informing that initial question might the geology in my area be suitable to host a geological disposal facility?

NGS site

Public Consultation

Consultation on Radioactive Waste Management Ltd’s proposals for evaluation of potential host sites for geological disposal opened today. The consultation runs through to the end of March.

Consultation here

Position Papers published by CoRWM

The Committee on Radioactive Waste Management (CoRWM) published on 7 November four new Position Papers reviewing and updating the committee’s position on key issues that have been raised by stakeholders in discussion and in response to consultations related to geological disposal. The position papers cover:

Support for disposal rather than indefinite storage

The committee reaffirms that based on the best evidence available, geological disposal remains the preferred choice for the long-term management of radioactive waste. CoRWM also notes that whilst there is presently no viable alternative to geological disposal, development of alternative management options should continue to be pursued through monitoring and/or participation in national or international research programmes.

Safety requirements of geological disposal

The committee concurs with the view of Barlow Geosafety that geological disposal will only be sanctioned and licensed for construction and operation at a particular site, if the independent regulators are satisfied that any safety issues have been satisfactorily resolved. The committee notes that such safety issues could be of a considerable number and must all be addressed by Radioactive Waste Management’s disposal system Safety Case. One of CoRWM’s ongoing roles will be to ensure that such concerns are ‘mapped’ into the safety assessment and safety case and successfully resolved.

Selecting a geological disposal facility (GDF) site based on the best geology

The committee has reviewed their previous advice and reaffirmed the view that any move towards ‘choosing the best geology’ at the start of a GDF siting process cannot be justified on technical grounds as each geological setting will have advantages and disadvantages. It was this conclusion that led CoRWM to recommend to Government in 2006 that the siting process should be based on a voluntarist approach, with the evaluation of geology and other siting factors commissioned once an interest had been expressed.

Transport considerations for radioactive materials

The committee reviews previous and more recent work and has concluded that any detriment suffered [by the public] as a result of transport of radioactive materials is very largely due to the conventional risks of transport (e.g. collision, derailment) with very little which can be attributed to the characteristics of the actual materials being transported.

The committee notes that concerns have been raised about security and that these must be taken on board by the relevant authorities. However, they conclude that there is currently little evidence that the transport of radioactive waste to a disposal facility would pose challenges outside the envelope of activities already undertaken for many decades.

The position statement concludes that ‘with all other things being equal’, transport is an activity which should be minimised, however they note that such minimisation must be prioritised against other siting attributes and resource uses of any radioactive waste management scheme. This must be done proportionately and with a clear evaluation of changes in other attributes. This is totally consistent with the site evaluation approach recommended on this news summary by Barlow Geosafety.

Regulators publish their review of the 2016 generic Disposal System Safety Case

The Environment Agency and Office for Nuclear Regulation have published the results of their joint review of Radioactive Waste Management’s 2016 generic Disposal System Safety Case. (DSSC)

The regulators state:

We recognise that the 2016 gDSSC represents an early (but important) stage for RWM in developing its approach for assessing the safety of any future geological disposal facility. Currently, from our assessment of the 2016 gDSSC, we have not identified any fundamental regulatory issues that would prevent RWM developing a safety case in the future to address our regulatory requirements. However, we note that there is a significant amount of work for RWM to do to develop a comprehensive, site-specific safety case, and that many aspects can only be fully evaluated when a site is selected and specific designs are produced. RWM should continue to engage in dialogue with the regulators and take steps to address our feedback as it undertakes this further development work.

The review presents Radioactive Waste Management with 38 recommendations to be considered in the development of future iterations of the safety case. The review also raises 3 new Regulatory Issues (RI) and 2 new Regulatory Observations (RO) concerning topics warranting particular consideration. Progress against these recommendations, RIs and ROs will be monitored and reported by regulators in future regulator progress reports.

What is meant by a "suitable site" for geological disposal?

The 2014 White Paper ‘Implementing Geological Disposal’, sets out a process whereby Government (and ultimately, the developer, Radioactive Waste Management Ltd) will work with a willing community in a consent-based process to identify potential suitable sites for development of a geological disposal facility. We have a general idea how the “willing community” part may work from Government’s proposals on Working with Communities, but Government and Radioactive Waste Management have yet to describe what constitutes a “suitable site”.

Land-owners, local authorities or others interested in questioning whether their area or community could be suitable for geological disposal, should read my brief on the topic (here).

House of Lords Grand Committee take note of Draft National Policy Statement for Geological Disposal Infrastructure

The Rt Hon Lord Henley, Parliamentary Under-Secretary of State BEIS, moved a motion to take note of the Draft National Policy Statement for Geological Disposal Infrastructure. The Minister noted that the draft National Policy Statement had been scrutinised by the BEIS Select Committee and the Committee’s report and recommendations published on 31 July 2018, and confirmed that BEIS are considering the responses to the consultation on working with communities and aim to publish a final policy “in the autumn”.

The debate as recorded by Hansard is available here.

BEIS Select Committee publish report on the Draft National Policy Statement for Geological Disposal Infrastructure

The BEIS Select Committee today published its report on the Draft National Policy Statement for Geological Disposal Infrastructure.

The Committee conclude that the Draft National Policy Statement is fit for purpose and contains adequate guidance and details needed for the developer, the Planning Inspectorate and the Secretary of State to put forward and make recommendations on development consent orders. Subject to some caveats (below) the Committee support the case that the final NPS be brought before Parliament for approval.

The report focuses on four issues that were raised during the inquiry and addressed in the evidence session on 10 July.

• National Parks and Areas of Outstanding Natural Beauty

  The Committee decided against adding an exclusionary criterion for National Parks and AONBs as they conclude that safety should prevail over environmental concerns and believe that existing planning legislation and the NPS contain sufficient safeguards against intrusive developments and environmental damage in National Parks and AONBs. The report does agree however that major developments should not be allowed in designated areas except under exceptional circumstances.

• disposal of waste (in the GDF) from new nuclear build

  The Committee conclude that any long-term waste management strategy should include waste from new nuclear as all waste generated from nuclear should be disposed of safely. Nevertheless, the Government must clarify in the NPS the level of uncertainty regarding the inventory of radioactive wastes and materials to be stored in the GDF, especially regarding levels of radioactivity of new nuclear waste.

• the place of local community consent in the NPS

  The Committee supports the Government’s decision to keep the community consent process separate from the NPS but we recommend that the Government should clarify the hierarchy between development consent orders and community consent in the NPS in a way that is accessible to a lay audience so as to promote engagement by prospective communities.

• how the NPS is linked to the Industrial Strategy to deliver socioeconomic benefits

  The Committee finds the link between the NPS and the Industrial Strategy to be spurious and the emphasis on socioeconomic benefits to the host community insufficient. In order to be consistent with the Industrial Strategy, the Government should ensure that the NPS places stronger requirements on the developer to establish robust local skills partnerships with the host community and to rely on local employment and sourcing opportunities. The Secretary of State should also favour developments that demonstrate they can deliver strong socioeconomic to host communities.

The report concludes that overall, and with the caveats outlined above, the Committee is satisfied that the NPS provides the right level of guidance to the decision-maker on the type of geological disposal infrastructure that will be suitable for England’s legacy and future higher activity radioactive waste. Provided that the Government takes into account the recommendations, the Committee supports the case for the final NPS to be brought forward and approved by Parliament.

International Summer School on Decommissioning and Waste Management

Very pleased to be supporting the International Summer School on Decommissioning and Waste Management organised by the EC Joint Research Council and held at their Ispra site in Italy. The Summer School is aimed at masters degree level students and provides them with the opportunity to explore and discuss some of the challenges facing the decommissioning and waste management community. 

I was invited as one of the expert speakers within the session on "what to do with waste in the long term?"

BEIS Select Committee meets and takes oral evidence

The BEIS Select Committee continues its inquiry into the draft guidance on the determination of radioactive waste disposal planning applications and today takes oral evidence from three witness panels:

Panel I -  Philip Matthews, Executive Director, Nuclear Legacy Advisory Forum; Ruth Bradshaw, Policy and Research Manager, Campaign for National Parks; Dr Pauleen Lane, Group Manager National Infrastructure, Planning Inspectorate.

Panel II - Bruce McKirdy, Managing Director, Radioactive Waste Management; Stephen Tromans QC, Member, Committee on Radioactive Waste Management; Professor Andrew Blowers, Co-Chair, NGO Forum and Chair, Blackwater Against New Nuclear Group.

Panel III -  Richard Harrington MP, Parliamentary Under-Secretary of State, Minister for Business and Industry, Department for Business, Energy and Industrial Strategy; Stephen Speed, Director, Nuclear, Department for Business, Energy and Industrial Strategy; Umran Nazir, Deputy Director, Decommissioning, Radioactive Materials and Geological Disposal Programme, Department for Business, Energy and Industrial Strategy.

The record of the hearing is available here