Radioactive Waste Consultations

For over three decades, efforts to find solutions to the problem of long-term radioactive waste management in the UK have failed. (See the History of Nuclear Waste Disposal Proposals In Britain) The Government’s latest review of policy led to the appointment of the Committee on Radioactive Waste Management (CoRWM) in 2003. CoRWM reported in July 2006. It recommended deep geological disposal, but also stressed the vital role of interim storage, because of the uncertainties involved with deep dumps. CoRWM also recommended a new approach to implementation, based on the willingness of local communities to participate.

CoRWM's recommendations can be found at:  

www.corwm.org.uk/content-1092

The Government's response to CoRWM at:  

www.defra.gov.uk/environment/radioactivity/waste/index.htm

The Government invites comments on CoRWM's recommendations and its own response up until 31 January 2007.

These can be submitted as appropriate to:

DEFRA at: radioactivewaste@defra.gsi.gov.uk

Scottish Executive at: RadioactiveWasteTeam@scotland.gsi.gov.uk

Welsh Assemby Government at: env-p&q@wales.gsi.gov.uk

Northern Ireland at: epd@doeni.gsi.gov.uk

To help with your response, you might want to consider the following points which have been summarised from the submission made by the Nuclear Free Local Authorities.
 
(1) DEFRA has not captured the heavily qualified nature of CoRWM’s recommendation about deep disposal.  The concept is not proven for the many thousands of years that containment and isolation of wastes would be required. The Environment Agency in its November 2005 review of Nirex's phased geological disposal concept, lists 10 'key technical challenges' "...where further work is needed before an acceptable repository safety case could be generated."  CoRWM called for an intensified research programme to resolve these questions but DEFRA commit only to ‘ongoing’ research.  
 
(2) DEFRA disregards CoRWM’s recommendation about wastes from a new nuclear programme.  CoRWM’s entire public consultation and stakeholder engagement programme was around the management of the higher-level legacy wastes, not new wastes.  CoRWM was explicit that a separate process of public consultation would be necessary to establish a publicly acceptable policy for the management of new wastes.  DEFRA ignore this and openly state that consideration of wastes from any new nuclear build will be included in developing a partnership approach with a potential host community. 
 
(3) DEFRA skipped a stage of consultation when it announced that NDA is to absorb Nirex.  This runs counter to the ethos of openness and transparency.   There was no consultation about whether the NDA is the most appropriate body to take forward long-term policy implementation.  In fact, as Nirex itself highlighted, there is a potential conflict of interest because the NDA is a waste producer.

(4) Further, DEFRA dilutes CoRWM's recommendation about independent oversight of the policy implementation process.  CoRWM called for an oversight body.  DEFRA commits only to a reconstituted CoRWM as an advisory body. 
 
(5) DEFRA is reopening the door to landfill disposal of radioactive waste even before publication of its review of low level radioactive waste policy that is expected in early 2007. 

 
(6) Finally, regarding the proposed voluntarist approach, DEFRA acknowledges that the practicalities have yet to be fully worked out.  Time is needed to think through and consult on workable arrangements.  DEFRA needs to allow sufficient time for consultation on the proposed Framework on Implementation to enable full democratic local debate and for the commissioning of expert research and advice if necessary.  24 weeks is the minimum practical consultation period.  Currently the DEFRA timetable through to 2008 looks far too tight to allow 24 weeks consultation.