National Policy Statement for Geological Disposal Infrastructure

Following public consultation earlier this year and scrutiny by the Business, Energy and Industrial Strategy Committee, the Government has today ‘laid before Parliament’ its National Policy Statement for Geological Disposal Infrastructure. It is expected that the NPS will be finally designated i.e. published, in the late Summer/Autumn.

This NPS will be used as the primary basis for the examination by the Planning Inspectorate, and for decisions by the Secretary of State, in considering development consent applications for geological disposal infrastructure i.e. deep investigation boreholes or a GDF (geological disposal facility).

Peer review of Ghana Atomic Energy Commission proposals for disposal of disused sources

Very pleased to be engaged by IAEA to lead an independent peer review of proposals from the Ghana Atomic Energy Commission (GAEC) to dispose of disused sealed radioactive sources in a purpose-designed borehole. The peer review team comprised myself and three other international experts. During the course of the mission we reviewed the GAEC borehole safety case, safety assessments for operations and post-closure and geological investigation work undertaken to characterise the proposed disposal site. The review concluded with a week-long meeting at the Vienna headquarters of the IAEA where we discussed and presented our findings to IAEA and GAEC representatives.

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Illustration from IAEA publication Management of Disused Sealed Radioactive Sources report NW-T-1.3

Response to RWM's Site Evaluation (Wales) Consultation

Barlow Geosafety has today submitted a response to the public consultation on Radioactive Waste Management proposals for evaluation of potential geological disposal sites in Wales. The proposals are similar to those published for siting in England but tailored for the differing policy, planning and regulatory regimes in Wales. In our view this has only been partially successful.

See the response here

Post Graduate Educational Course in Radiation Protection and the Safety of Radiation Sources

For the period 29 January to 1 February I am pleased to be working with the Greek Atomic Energy Commission (EEAE) helping to deliver their Post Graduate Education Course (PGEC) in Radiation Protection and the Safety of Radiation Sources. This is a course offered by EEAE in their capacity of IAEA Regional Training Centre in Europe. My role during the week is to deliver a series of lectures on the topic of Radioactive Waste Management.

Response to RWM's Site Evaluation (England) Consultation

Barlow Geosafety has today submitted a response to the public consultation on Radioactive Waste Management proposals for evaluation of potential geological disposal sites in England.

In the response we make three key points:

• We support the proposal to utilise RWM’s published Disposal System Specification as the source of Requirements to dictate the Siting considerations but conclude that the proposed Site Evaluation (Framework?) is not yet sufficiently transparent to understand how it will work in practice or how the Requirements will be translated into useful siting criteria. Further work is required in this respect. 

• We conclude that the Site Evaluation seems to gloss-over the role of comparative evaluations. The consultation identifies two key milestones where such evaluations may be required in support of Siting recommendations made to the Secretary of State. It fails to recognise that comparative evaluations of some form will be a necessary feature throughout this iterative process even at the earliest stages, not just at the two key milestones flagged in the text.

• The third point relates to what RWM describes as the “evaluation approach” for comparative evaluations. We support RWM’s contention that this be “qualitative, evidence-based and iterative” but recommend that the suggestion that it will not involve ranking or scoring be revisited. Any comparative evaluation must by its nature involve some form of ranking - perhaps RWM means that they wish to avoid use of a numerical scoring system - if this is so then this would be supported. Qualitative assessment systems are widely used and commonplace in for example, environmental impact assessment and road options assessment, where it is necessary to rank alternative options and such a system could be utilised for such a Siting application. Indeed the Generic Environmental Assessment published by RWM in 2016 includes a comparative evaluation scheme that could form the basis of a “qualitative, evidence-based and iterative” system to be utilised in support of Site Evaluation.

See the response here

Welsh Government publishes Working with Communities policy

Following consultation in 2018, the Welsh Government has published its new policy for geological disposal of higher activity radioactive waste in Wales. The policy shares many features of the equivalent policy recently published by BEIS for England. Its founded on the principle of partnership working between communities and the developer, Radioactive Waste Management Ltd, although is tailored for the different local authority structure applicable in Wales.

The new policy is available on the Welsh Government website - here.

In response to the new policy announcement, Radioactive Waste Management have issued a version of their proposals for evaluation of potential host sites in Wales, for public consultation. The public consultation is open until 14 April 2019.

Government publishes new policy and RWM launches Siting process for geological disposal

Following public consultation on the draft earlier this year, Government has today published its updated policy framework Implementing Geological Disposal - Working with Communities. This is applicable to England only: a separate, but compatible policy is promised for publication by the Welsh Government in due course.

This important policy step has enabled Radioactive Waste Management Ltd to launch its Siting process with the invitation to communities to find out more about what would be involved in hosting a geological disposal facility and whether the geology in their area might be suitable. To aid this process RWM has published its long-awaited geological screening information and issued its Site Evaluation methodology for public consultation.

RWM has also issued Community Guidance explaining how it anticipates working with communities throughout the Siting process and an accompanying Prospectus introducing the project and setting out why a community might want to get involved.

Working with Communities

The new policy framework for the long-term management of higher activity radioactive waste confirms Radioactive Waste Management Ltd as the delivery body for the planned geological disposal facility. The framework maintains the previously proposed consent-based approach and sets out the working arrangements between RWM and the community. The policy describes the proposals for community investment funding, the right of withdrawal and the test of public support. The policy also sets out the role of the Community Partnership and principal local authority/ies.

Policy here

National Geological Screening

Radioactive Waste Management’s national geological screening information is now live. The geological screening web-site presents for the first time information and maps describing the geology of England, Wales and Northern Ireland down to a depth of around 1000 metres, with the particular objective of informing that initial question might the geology in my area be suitable to host a geological disposal facility?

NGS site

Public Consultation

Consultation on Radioactive Waste Management Ltd’s proposals for evaluation of potential host sites for geological disposal opened today. The consultation runs through to the end of March.

Consultation here

Position Papers published by CoRWM

The Committee on Radioactive Waste Management (CoRWM) published on 7 November four new Position Papers reviewing and updating the committee’s position on key issues that have been raised by stakeholders in discussion and in response to consultations related to geological disposal. The position papers cover:

Support for disposal rather than indefinite storage

The committee reaffirms that based on the best evidence available, geological disposal remains the preferred choice for the long-term management of radioactive waste. CoRWM also notes that whilst there is presently no viable alternative to geological disposal, development of alternative management options should continue to be pursued through monitoring and/or participation in national or international research programmes.

Safety requirements of geological disposal

The committee concurs with the view of Barlow Geosafety that geological disposal will only be sanctioned and licensed for construction and operation at a particular site, if the independent regulators are satisfied that any safety issues have been satisfactorily resolved. The committee notes that such safety issues could be of a considerable number and must all be addressed by Radioactive Waste Management’s disposal system Safety Case. One of CoRWM’s ongoing roles will be to ensure that such concerns are ‘mapped’ into the safety assessment and safety case and successfully resolved.

Selecting a geological disposal facility (GDF) site based on the best geology

The committee has reviewed their previous advice and reaffirmed the view that any move towards ‘choosing the best geology’ at the start of a GDF siting process cannot be justified on technical grounds as each geological setting will have advantages and disadvantages. It was this conclusion that led CoRWM to recommend to Government in 2006 that the siting process should be based on a voluntarist approach, with the evaluation of geology and other siting factors commissioned once an interest had been expressed.

Transport considerations for radioactive materials

The committee reviews previous and more recent work and has concluded that any detriment suffered [by the public] as a result of transport of radioactive materials is very largely due to the conventional risks of transport (e.g. collision, derailment) with very little which can be attributed to the characteristics of the actual materials being transported.

The committee notes that concerns have been raised about security and that these must be taken on board by the relevant authorities. However, they conclude that there is currently little evidence that the transport of radioactive waste to a disposal facility would pose challenges outside the envelope of activities already undertaken for many decades.

The position statement concludes that ‘with all other things being equal’, transport is an activity which should be minimised, however they note that such minimisation must be prioritised against other siting attributes and resource uses of any radioactive waste management scheme. This must be done proportionately and with a clear evaluation of changes in other attributes. This is totally consistent with the site evaluation approach recommended on this news summary by Barlow Geosafety.

Regulators publish their review of the 2016 generic Disposal System Safety Case

The Environment Agency and Office for Nuclear Regulation have published the results of their joint review of Radioactive Waste Management’s 2016 generic Disposal System Safety Case. (DSSC)

The regulators state:

We recognise that the 2016 gDSSC represents an early (but important) stage for RWM in developing its approach for assessing the safety of any future geological disposal facility. Currently, from our assessment of the 2016 gDSSC, we have not identified any fundamental regulatory issues that would prevent RWM developing a safety case in the future to address our regulatory requirements. However, we note that there is a significant amount of work for RWM to do to develop a comprehensive, site-specific safety case, and that many aspects can only be fully evaluated when a site is selected and specific designs are produced. RWM should continue to engage in dialogue with the regulators and take steps to address our feedback as it undertakes this further development work.

The review presents Radioactive Waste Management with 38 recommendations to be considered in the development of future iterations of the safety case. The review also raises 3 new Regulatory Issues (RI) and 2 new Regulatory Observations (RO) concerning topics warranting particular consideration. Progress against these recommendations, RIs and ROs will be monitored and reported by regulators in future regulator progress reports.

What is meant by a "suitable site" for geological disposal?

The 2014 White Paper ‘Implementing Geological Disposal’, sets out a process whereby Government (and ultimately, the developer, Radioactive Waste Management Ltd) will work with a willing community in a consent-based process to identify potential suitable sites for development of a geological disposal facility. We have a general idea how the “willing community” part may work from Government’s proposals on Working with Communities, but Government and Radioactive Waste Management have yet to describe what constitutes a “suitable site”.

Land-owners, local authorities or others interested in questioning whether their area or community could be suitable for geological disposal, should read my brief on the topic (here).