APPENDIX
Letter to Secretary of State from Former
Members of CoRWM
20 November, 2009
Rt Hon Ed Miliband
Secretary of State for Energy and Climate Change
3, Whitehall Place,
London SW1A 2HD
Dear Secretary of State,
New Nuclear Build and the Management of Radioactive
Wastes
We write to you as members of the first Committee
on Radioactive Waste Management (CoRWM 1) which presented recommendations
on the long term management of solid higher activity wastes to
government in 2006. These recommendations were substantially endorsed
by government and expressed as policy in its White Paper on Managing
Radioactive Waste Safely in June 2008 (CM 7386). We wish
to express our concern that our recommendations have been seriously
misrepresented in your draft National Policy Statement on Nuclear
Energy published on 9 November.
In concluding the section on radioactive waste
management the NPS states: "the Government is satisfied that
effective arrangements will exist to manage and dispose of the
waste that will be produced from new nuclear power stations. As
a result the IPC need not consider this question" (paragraph
3.8.20).
We contend that it is unknowable whether or
not effective arrangements will exist and that the question of
management of these wastes on specific sites should be a matter
that the IPC must consider.
The policy stated in the White Paper on Nuclear
Energy is "that before development consents for new nuclear
power stations are granted, the government will need to be satisfied
that effective arrangements exist or will exist to manage and
dispose of the waste they will produce" (CM 7296, 2008, p.99).
In our view this is a matter of judgement not
of ineluctable fact. The CoRWM1 proposals for long-term management
of radioactive wastes identified a process towards a long-term
solution, recognising that deep disposal should be implemented
on the basis of "an intensified programme of research and
development into the long-term safety of geological disposal aimed
at reducing uncertainties at generic and site-specific levels,
as well as into improved means for storing wastes in the longer-term"
(CoRWM, 2006, rec. 4). Moreover, implementation would also depend
on finding a suitable site based on the principle of volunteerism,
that is an expressed willingness of a community to participate
in a site selection process. Neither the scientific nor the social
requirements have yet been met and consequently, in our judgement,
it is not possible to conclude that effective arrangements "exist
or will exist".
In any case, the policy set out by CoRWM1 and
subsequently pursued by government applies to legacy wastes
alone. CoRWM was quite clear that its proposals should not apply
to new build:
"The main concern in the present context
is that the proposals might be seized upon as providing a green
light for new build. That is far from the case. New build wastes
would extend the timescales for implementation, possibly for very
long, but essentially unknowable, future periods. Further, the
political and ethical issues raised by the creation of more wastes
are quite different from those relating to committed—and,
therefore, unavoidable—wastes. Should a new build programme
be introduced, in CoRWM's view it would require a quite separate
process to test and validate proposals for the management of the
wastes arising." (Page 13, Managing our radioactive
wastes safely, CoRWM's recommendations to Government, CoRWM document
700, July 2006).
However, it is clear that government has conflated
the issue of new build with legacy wastes and thereby intends
the CoRWM proposals to apply to both. No separate process, as
suggested by CoRWM1, for new build wastes is contemplated. There
will be no opportunity for communities selected for new nuclear
power stations to consider whether they wish to volunteer to host
a long term radioactive waste facility; it will simply be imposed
upon them. As the government recognises these wastes may well
be stored on site "for around 160 years from the start
of the power station's operations, to enable an adequate cooling
period for fuel discharged following the end of the power station's
operation." (Draft National Policy Statement for Nuclear
Power Generation EN-6, 3.8.17). In the absence of a process or
acceptable policy for new build wastes, they may remain on site
indefinitely It is quite possible that, as a result of sea level
changes, storm surge and coastal processes, conditions at some
of the most vulnerable coastal sites will deteriorate thereby
making it increasingly difficult to manage the wastes safely.
The problems presented by managing wastes in
the very long-term will be both generic and site-specific. Consequently
we find it hard to understand why the IPC, when considering applications
for the development of individual sites, need not consider the
question of waste management. Given the levels of public anxiety
raised by the issue of nuclear waste and the burdens of risk and
management that are imposed on future generations we believe consideration
of safe management of wastes at each site should be a primary
concern of the IPC. We invite you to confirm that this would be
your expectation.
In conclusion we reiterate that we do not consider
it credible to argue that effective arrangements exist or will
exist either at a generic or a site-specific level for the long—term
management of highly active radioactive wastes arising from new
nuclear build. We believe the scrutiny of the arrangements proposed
for each site must remain within the remit of the IPC.
We are copying this letter to the Chair of the
Infrastructure Planning Commission and the Chair of the Committee
on Radioactive Waste Management. In the interest of open debate
we shall also make these views known to the media.
Yours sincerely,
Professor Andrew Blowers OBE (member of CoRWM1)
Professor Gordon MacKerron (Chairman, CoRWM1)
Mary Allan (member of CoRWM1)
Pete Wilkinson (member of CoRWM1)
cc. Sir Michael Pitt, Chair, Infrastructure
Planning Commission
Professor Robert Pickard, Chair, Committee on
Radioactive Waste Management
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