Letter from Alistair J MacDonald to CoWRM
Secretariat
PUBLIC AND
STAKEHOLDER ENGAGEMENT
1—RESPONSE
Please find some comments in response to your
invitation to comment on the issue of long-term radioactive waste
management.
What are the most important issues to you? What
should be considered when making decisions about a long term radioactive
waste management strategy?
The most important issues that need to be dealt
with relate to ensuring that the public understand the issue.
There is a lot of information and mis-information about the nuclear
industry and nuclear waste in particular and the issues need to
be very clearly explained. I also believe that the issue needs
to be set in context.
I do not believe that there is a one solution
for all wastes and this makes it very difficult. It appears from
your consultation document that this is the start of a BPEO study
on the issue. As the recent RWMAC Annual Report makes clear a
BPEO is but one tool to help make decisions. The issue of nuclear
waste is complex, with many different types of waste that have
been created as a legacy from experiments, to the much smaller
amounts of wastes that are generated from modern power stations.
I believe that the BPEO approach is too simplistic for the totality
of the problem.
As far as I am concerned the prime issue is
about getting our country to a position, in as quick a time as
practicable, where there is an accepted solution or end-game for
all our wastes and for those that will be generated into the future.
Most people realise that the current energy policy in the UK is
a shambles and that nuclear energy will be required to provide
a solution. However, public acceptability of this solution can
only be achieved if there is an end game for the current liabilities
and future nuclear power will not create a further legacy that
cannot be dealt with. The Generation IV nuclear programme is commendable
but this can only be achieved if the wastes can clearly be dealt
with.
At all times the industry must be open and honest.
How do you think the volume and types of waste
in the CoRWM Inventory affect our recommendation of the most suitable
option for long term management? Are some options ruled in, or
out, because of the nature of the wastes we are dealing with?
Are there other uncertainties and assumptions that you think we
should look at? Have you any other comments on our work so far?
I think that not only do the waste types need
to be dealt with separately but also the locations of the wastes
need to be considered. The current state of the wastes also need
to be considered because the options selected for detailed study
will need to take account of the efforts required to get the wastes
into a suitable end state. Do not go into this thinking there
is only one solution.
You state that you have been asked to look only
at six categories. You must consider all nuclear wastes. You must
also have clarity on the Plutonium, Uranium and Spent Fuel. I
believe that a national strategy should consider these materials
where they are not needed for national security or strategic reasons.
As an example the inventory of Highly Enriched Uranium will be
dealt with differently from say Depleted or Natural Uranium—this
needs to be accounted for. At a minimum stocks of DU should be
considered as wastes, and we should make sure that the industry
has got developed plans for dealing with these wastes. Stocks
of HEU are potentially valuable and traded as such. Perhaps a
formula needs to be developed to get to a point where a decision
can be made on a case by case basis about HEU. For example a stock
of HEU that can be made into research reactor fuel at a standard
fabrication plant is different to a stock of HEU that needs some
impurities removed and the enrichment level changed before it
can be used. The door should be open for the latter to be treated
as waste should that specific assessment declare that to be the
best option.
Nationally we do need clarity on how spent fuel
is managed. As it stands spent fuel is a waste unless reprocessing
takes place. Therefore it should be included on a waste inventory.
Only of the decision is made to reprocess on a case by case basis
should the fuel be removed from the inventory but of course it
will be replaced by an increased amount of other wastes resulting
from the reprocessing.
Your document points out a number of uncertainties.
This in effect means that there are a number of potential scenarios
that should need to plan for. You should be responsible for clear
planning of these different scenarios. If there was clarity in
the end-game for some of the materials you mention, and the different
scenarios could be reliably assessed, then this would give the
operators and the Government a more robust financial and planning
framework on which to base their decision making for the various
waste and fuel streams. This would ideally lead to less uncertainty.
Issues like substitution must have early resolution.
The industry is in a no-win situation. Where reprocessing of foreign
fuel has taken place there are agreements that wastes will be
returned to the country of origin. This is correct and no doubt
done due to environmental pressure. However recent experience
has shown that where return of waste is being enacted then environmentalists
oppose that. I know that I would prefer to see a vitrified glass
block being stored or transported near my home than a fuel element.
Perhaps time has moved on since these inter-governmental agreements
were signed and this issue should be looked at again.
Have we identified all the relevant options? Are
the options adequately described? Have we considered all the relevant
aspects of the options in our Options Report?
I am sure that you have identified all the options.
However, as I have stated above there are a number of different
waste types and the optimum option will vary.
On what grounds do you think options should be
removed from the long list? Are other issues important when assessing
options?
Options should be removed from the long list
if they are clearly impracticable. I think that your list in para
49 is broadly acceptable. I think that one other factor which
should be taken into account is the ability to get agreement of
a potential option on a short term timescale. We need to be clear
on how all our wastes are going to be managed and we need to have
that within a five year timeframe—not a 25 year one.
Again, I reinforce the fact that different waste
stream may end up with different solutions.
What do you think of our future plans? Are we
going about meeting our objective to be able to recommend to Government
the option or options that are best for the long term management
of solid radioactive waste—in the right way? How would you
like to be involved in future phases of our work?
You must meet these timescales. It is important.
Our country has spent a lot of time and effort
on this issue culminating in the collapse of Nirex following the
RCP planning application. This is taxpayers money. I believe that
you should somehow make good use of all this work as best you
can.
I also believe that there are groups of people
within the industry that have carried out a lot of work in this
area perhaps for specific wastes streams appropriate to their
organisation or their site. Again you should somehow capitalise
on this work, and this knowledge. Perhaps you should consider
getting key people with that knowledge and having them seconded
to you to help you until July 2006.
Public Consultation is commendable but very
difficult and you will never achieve consensus.
Unless the final option you come up with is
along the lines of;
— condition all the wastes at the host
site to a stable form;
— store in such a way that these are
monitorable and retrievable;
— store on site in near surface facilities.
You will never get total agreement from the
general public, unless you can clearly explain why other solutions
are better. You will have to do this through information campaigns,
stakeholder groups, targetted focus groups, press advertising
and briefings and perhaps some sort of repeat of the CEED Consensus
Conference.
I hope that you find these comments useful in
your deliberations.
I am happy that you keep my details on your
database so that you can send me further information. I will be
happy to contribute to future exercises.
3 December 2004
| 
