Memorandum by the Nuclear Industry Association
The Nuclear Industry Association (NIA) welcomes
this opportunity to respond to the Committee's inquiry into radioactive
waste management.
NIA is the trade association and information
and representative body for the civil nuclear industry in the
UK. It represents over 180 companies operating in all aspects
of the nuclear fuel cycle, including the current and prospective
operators of the nuclear power stations, the international designers
and vendors of nuclear power stations, and those engaged in decommissioning,
waste management and nuclear liabilities management. Members also
include nuclear equipment suppliers, engineering and construction
firms, nuclear research organisations, and legal, financial and
consultancy companies.
We note that the Committee has decided to focus
on the role and performance of CORWM and so our response covers
this area. We wish, however, to be clear that the issue of key
significance to the industry is continued good progress by all
those involved with the timely delivery of the Managing Radioactive
Waste Safely (MRWS) strategy. The NIA also wishes to place on
record the importance we attach to maintaining public confidence
in the implementation of the MRWS strategy. CORWM has in the past
and should in the future continue to play an important part in
achieving this.
CORWM'S
PERFORMANCE
CoRWM has scrutinised the Government's MRWS
process thoroughly but we have noticed some inconsistencies and
are concerned about how efficient its scrutiny has been in some
areas. While CoRWM's response to government is in many cases presented
with a strong evidence base it contains some statements which
are presented with no evidence base to back them up (and often
there are inaccuracies). For example in their draft response to
the Energy NPSs, CoRWM dismisses the NDA's disposability assessments
(which have a strong and documented evidence base) in order to
say there is no evidence as to the disposability of new build
waste. It does this without providing evidence to support the
view that this conservative reference scenario is invalid. In
contrast Government would appear to have taken a more consistently
evidence based approach to decisions on MRWS.
This may of course relate to resources and the
extent to which CoRWM has been able to bring in external technical
and scientific expertise. However it seems to us that the main
problem is that CoRWM has taken a broad approach to its work,
attempting to examine a very wide range of complex issues, and
we feel it could be more effective if its work were more focused
on specific topics, relevant to the stage the Government has reached
with its MRWS programme. On occasions CoRWM also seems to stray
beyond its remit which we discuss further below.
CORWM'S
REMIT
We acknowledge that CoRWM's remit is broadly
speaking correct but there have been some examples when it appears
to stray beyond its remit. For example, the organisation's remit
confines it to the issue of wastes rather than other parts of
the fuel cycle. So it is right that it considers the issue of
new build waste but plutonium could only come within the remit
of CoRWM if it is declared a waste. It should therefore not be
investigating the government's policy formation in this area.
CoRWM's remit is to scrutinise the implementation of government
policy in the area of nuclear waste disposal and provide feedback
to government to assist in that implementation. It is not to suggest
or formulate new policy or to scrutinise other areas of policy.
Scrutiny of government policy in the nuclear sector is carried
out by select committees in both houses of Parliament and by competent
expert regulators including the Health and Safety Executive, Environment
Agency, and Scottish Environment Protection Agency.
CoRWM's remit is also not to re-scrutinise its
own policy decisions which were arrived at in a lengthy and open
debate as this is not within its remit. Much of the value in the
original CoRWM process lay in this fundamental deliberative approach,
and there is a danger in reopening issues without any such process.
For example, we think that opening the issue of borehole disposal
again is neither helpful nor productive. We suggest it would be
useful if the sponsoring departments could engage more directly
with CoRWM over its work programme in order to get the advice
they need at the time they need it, focusing explicitly on the
waste disposal process rather than broader issues.
CoRWM rightly operates in an open manner and
allows the public to participate in its meetings and have a dialogue
with it. However its operating method of producing papers—often
written only by one member—for debate in the plenary sessions
sometimes leads to preliminary views being interpreted as formal
CoRWM positions. It would be better if more complete papers which
had been subject to internal debate and review were considered
instead with the key options outlined for debate in plenary sessions.
CORWM AND
GOVERNMENT
It is difficult for us to comment on the interaction
between CoRWM and government departments. However from what we
can see Government clearly takes CoRWM's advice into account in
formulating its policies although as we stated above the interaction
might be improved if CoRWM's work programme was more closely related
to the work being carried out under the MRWS programme.
January 2010
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