Memorandum by Greenpeace
Greenpeace is aware that the Lords Science and
Technology Committee (STC) has requested information from only
one environmental organisation (Greenpeace) on this matter. For
the record, we are making a submission but on the understanding
that Greenpeace does not approve of such an "exclusive"
approach to gathering views.
We understand that the STC has sought a submission
from only one NGO, as a matter of urgency, because it needs to
report before a general election is called. Exactly why this is
the case has not been explained.
We would also like to note that at present many
NGOs and others interested in issues around nuclear waste management
are engaged in responding to very lengthy and complex consultations
on the Justification (of new nuclear reactors) and on the Nuclear
National Policy Statement. That the STC is taking evidence on
a related matter at the same time as these other consultations—without
a general call for evidence— may result in the validity
of the Committee's report on this matter being questioned..
RESPONSES TO
QUESTIONS
CORWM'S
PERFORMANCE
Has CoRWM effectively scrutinised the implementation
of the Government's MRWS programme?
CoRWM's efforts to scrutinise implementation
of the Government's MRWS programme are not as effective as they
could be. The main reason for this appears to be lack of funding
for CoRWM's work. From discussions we have had with various CoRWM
members, and from what has been said at a CoRWM stakeholder meeting,
lack of funding means CoRWM is not in a position to undertake
stakeholder work, or independent research, to the extent it would
like to. The STC should keep this in mind when examining the work
of CoRWM. We understand the Committee will be responding to the
draft Nuclear National Policy Statement and is seeking to meet
NGOs on this. However, it is not planning to respond to the draft
decision on Justification (of new reactors). It is extremely remiss
of the Committee not to be responding to this—particularly
as it may have an impact on many aspects of the MRWS programme.
Whether this is because of lack of funding or lack of time (or
both) is not clear at present.
Are Government decisions on its MRWS programme
evidence-based? What mechanisms are in place to ensure this is
the case? How does CoRWM scrutinise this?
Many Government decisions on its MRWS programme
simply cannot be "evidence based" eg there is no operating
repository for spent fuel and other higher activity wastes anywhere
in the world. As a result, much of what the Government says on
these matters is based on claims rather than being "evidence
based."
From observation of what Government officials
have said at a variety of meetings over a number of years, from
reading documents by the Nuclear Decommissioning Authority etc,
it would appear that although there are mechanisms in place to
examine the evidence for decisions made by government—there
are not enough resources for the relevant organisations to undertake
engage in the examining claims (this appears to be the case for
regulators too).
Remarks made by CoRWM members at stakeholder
events make it clear that CoRWM is not in a position to be able
to undertake the level of scrutiny it believes it should be doing.
We recognise that, conversely, some work cannot be fully scrutinised
before it happens. Some work can only be monitoring of progress
and examining claims made about progress. It is essential the
STC considers the ability of CoRWM—and others—to be
able to respond to Government assertions not only in the short
term but over the longer term as well.
Does CoRWM have sufficient scientific and technical
expertise to meet its remit?
CoRWM appears to have sufficient scientific
and technical expertise to meet its remit (whether this is independent
enough is another matter). However, it could certainly do with
more Committee members with expertise on social, political and
ethical matters (as CORWM I had) to examine the social, political
and ethical impact of proposals by Government and to examine its
own assumptions. It is expected that social and ethical matters
will become an increasing part of the discussion on MRWS processes
on legacy waste. When this happens CoRWM may also have to look
outside for expertise or seek new members (such expertise must
be drawn from independent sources and not from within the industry).
On the current level and mix of CoRWM's expertise,
we ask the STC consider CoRWM's draft statement[1]
on new build where it reiterates the views of CoRWM 1:
"CoRWM's position on the consideration
of wastes in the public assessment of proposals for building new
nuclear power stations remains as set out in paragraph 21 of its
2006 Recommendations (see paragraph 2 above). It believes that
a range of issues, including social, political and ethical issues
of a deliberate decision to create new wastes, should be considered
in the new build public assessment process."
The paper serves as a timely reminder that,
when considering new build wastes—as CoRWM 1 found when
considering with legacy wastes—the current Committee's work
must encompass more than just scientific and technical matters.
A further example of how CoRWM's 2 expertise
and work may need to be expanded comes from a report in which
CoRWM 1 considered the implications of long term storage of new
build wastes (in its Implementation Report). In a little remarked
paragraph the Report stated:
"It is clear that CoRWM's recommendations
on implementation must be applied at least to new central or major
regional stores at new locations if CoRWM's recommendations are
to inspire public confidence. The extent to which they should
be applied to other new stores and existing stores is a matter
for further consideration". (Moving Forward: CoRWM's Proposals
for Implementation, February 2007, p 10, Doc 1703).
It has then been considered that the voluntarism
process (for a geological disposal facility for legacy wastes)
might also apply to long term stores at new locations. This is
an issue which CoRWM should examine further, either for legacy
wastes and as part of its examination of issues around new reactors
. This will require social, political and ethical experts.
CoRWM may also wish to engage the services of
appropriately trained economists to comment on the funding arrangements
for dealing with legacy wastes, new build wastes or the reuse
of nuclear materials.
CORWM'S
REMIT
Is CoRWM's remit appropriate? If not, why not?
To what extent should CoRWM be responsible for engaging with the
public and representing their views within Government?
CoRWM 1 undertook much work on stakeholder engagement,
and therefore could do much more to reflect public/stakeholder
views, this has not been the case for CoRWM 2. Again, a lack of
finance for the Committee's ability to liaise with stakeholders
appears to be the main reason for this change. Having said that,
CoRWM can never fully represent the public's views to Government
or within Government. Indeed, we note that in a recent
draft document (CoRWM 2748, draft 2 NPS Consultation Response)
that it defines the public as:
People who have no particular interest in,
and are not affected by, radioactive waste management. [CoRWM
distinguishes between "stakeholders" and the public.]
Exactly who is completely untouched by radioactive
waste management—given the level of taxpayer funding for
both past and current operations—is something that should
be explained.
However, it is the case that CoRWM could have
a role to play in reflecting of the views of both stakeholders
and the public—but only if engages appropriately (given
time, money and its own consideration to such engagement). This
is not the case at present.
Does CoRWM's remit cover emerging areas of activity,
such as new build waste and the UK's plutonium stock pile, or
longer term issues and horizon scanning? If not, should it?
CoRWM's remit does not specificaly cover "emerging
areas of activity"—such as new build waste and the
UK plutonium stock pile. It is however inevitable, that (as with
CoRWM 1) its work will address these matters if only because of
the potential impact these may have on legacy wastes. As noted
earlier, CoRWM has recently issues a draft statement on new build
wastes. It is planning to do work on new build waste later this
year.
It has already commented on issues around plutonium
disposition.[2]
In the case of plutonium, an existing nuclear material, CoRWM
will have to look at the issues surrounding disposal of this as
a waste. If proposals are made to reuse plutonium it will be expected
to comment on the potential impacts of waste resulting eg the
MOX spent fuel that will be prodcued will be much more hazardous
even than the problematic spent fuel that new build will create.
How these might impact on legacy waste disposal, or the disposal
of other wastes from new build, is something CoRWM may feel it
should comment on.
What is crucial is that CoRWM does not take
a position on the desirability of new nuclear and/or the reuse
of plutonium. We refer the STC to a letter sent to CoRWM 2 on
how it should address new build wastes (received but not printed).
Are there any plans to change the composition
or role of CoRWM as the Government's MRWS programme continues?
Should there be?
It is not known if there are any plans to change
the composition or role of CoRWM. On what additional expertise
it might need, see earlier comments on social, political, ethical
and financial issues.
CORWM AND
GOVERNMENT
How effective is CoRWM's interaction with different
Government departments and agencies?
From what we can gather, even in issues such
as the timing of consultations, there is no effective liaison
between CoRWM and Government departments and agencies, despite
some effort on CoRWM's behalf of make such interaction more effective.
Equally important, judging from many conversations and much correspondence
on various nuclear events and consultations, we would say that
liaison between, and even within Government departments and agencies,
is still pretty poor.
Are lines of responsibility and accountability
within Government, and between CoRWM and Government, clear?
This presumably concerns responsibility and
accountability within Government on matters relating to nuclear
waste management? This is a question for CoRWM to answer. However,
from an NGO perspective lines of responsibility and accountability
seem, at the best blurred and at the worst in conflict. The transferral
of the MRWS programme from Defra to the Office of Nuclear Development
has created further mistrust within the NGO community and public
over the way in which Government is now attempting to "manage"
this issue rather than have a full and open dialogue. It is wrong
that the department charged with promoting new build is now in
control of managing legacy wastes. There is no doubt that claims
made about how legacy waste can and will be dealt with are being
extended to cover new build wastes—giving the impression
that this particular hurdle to new build has been overcome. There
are many, many unresolved issues around legacy waste are not being
fully discussed. If CoRWM gets sucked into this deceit it will
not help its credibility, which is already being undermined (see
answer to following question).
Does the Government respond to and use CoRWM's
advice effectively? Has the Government taken on board CoRWM's
recommendations in its recent reports on geological disposal and
interim storage?
No, from when CoRWM 1 reported—and the
Government made its initial response to that report—it is
quite clear that the Government does not intend to fully respond
to, or act on, CoRWM's advice. It has consistently cherry-picked
those parts of CoRWM's work it believes are helpful to its case,
on legacy wastes and particularly on new build wastes. The Government
selectively uses CoRWM's work to give the impression legacy can
or will be dealt with in order to justify the creation of more
wastes through new reactors and possibly the reuse of nuclear
materials from reprocessing.
On this issue in particular we urge the STC
to consider the letter published by four former members of CORWM
1, including the chairman, Prof Gordon McKerron.[3]
For the second part of this question, the STC
need look no further for the type of discussion CoRWM has had
on the Government's response to its work than the draft report
on "Views on Government's response to CoRWM's 2009 report
on geological disposal."[4]
We understand that parts of that draft were
accepted (eg on monitoring the work CoRWM should undertake), but
the substantive comments were not accepted in full. However, the
document serves as a good indication of the kind of issues that
have been discussed by CoRWM in terms of Government response to
its work.
Others have also been critical of CoRWM's own
approach to dialogue.[5]
Greenpeace is in no position to substantiate the criticisms made
in the document referenced, but offers it as an example of some
of the criticisms made of CoRWM's own processes.
January 2010
http://www.corwm.org.uk/Pages/Plenary%20Meetings/2749%20Draft%202%20CoRWM%20Stmt%20new%20build%20wastes.pdf
http://www.corwm.org.uk/Pages/Other%20Meetings/2523%20-%20meeting%20with%20NDA%20on%20SF%20Pu%20U%20%
2011%20Dec%2008%20final.pdf
http://www.corwm.org.uk/Pages/Plenary%20Meetings/2738%20Draft%203%20Views%20on%20Government%27s%20response%
20CoRWM%27s%202009%20report%on%20GD.pdf
1 Doc no 2749 DRAFT CoRWM STATEMENT OF ITS POSITION
ON NEW BUILD WASTES, 18 January 2010 Back
2
Doc No 2523 CoRWM Meeting with NDA on management of spent fuels,
plutonium and uranium, 11 December 2008. Back
3
http://www.nuclearwasteadvisory.co.uk/uploads/6140CoRWM1_Letter_201109.pdf Back
4
CoRWM Doc. 2738 Draft 3 (3 December 2009) Back
5
http://www.nuclearwasteadvisory.co.uk/uploads/6072HoL%20Sci%20-%20CoRWM%20-%20Resp%20-%2024%20Jan%202010.doc Back
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