The Nuclear Free Local Authorities (NFLA) publishes today its model submission for members to respond to the Scottish Government’s consultation on its implementation policy for the management of higher activity radioactive waste. (1)
The Scottish Government has launched a consultation exercise to seek views on its proposed Implementation Strategy for Scotland’s Higher Activity Radioactive Waste (HAW) Policy. (2) The Policy only applies to Intermediate Level Waste, as there is currently no High Level Waste in Scotland. Spent Nuclear Fuel is still not classified as waste and continues to be transported to Sellafield for reprocessing or storage. NFLA remains concerned about the ongoing policy of transporting spent fuel in particular from Dounreay to Sellafield for safety and emergency planning reasons.
Scottish nuclear waste management policy differs from the rest of the UK in that it does not support deep geological ‘disposal’. In Scotland long-term management of HAW should be in near surface facilities, which are located as near to the site where it is produced as possible. No definition of “near to the site” is given, but the Strategy presumes “that waste will be dealt with as close as is practicable to the site where it was produced, thus minimising the need to transport the waste over long distances”. NFLA broadly supports this policy. NFLA opposes the current policy of the UK and Welsh Governments to develop a deep-underground radioactive waste facility, as there remain a whole host of difficult scientific and technical challenges to overcome with such a development. NFLA is also concerned that such a site would not offer the possibility of retrieving waste if required.
NFLA, however, has not been supportive of the Scottish Government’s use of the “waste hierarchy” to justify transporting waste to other facilities, and even other countries, in order to carry out so-called “processing”. This is seen as running counter to the policy of rejecting unnecessary transport and counter to the rejection of “dilution and dispersal” as processing generally results in the unnecessary discharge of radioactive substances into the environment. NFLA does, of course, support the idea that wastes should not be unnecessarily created.
NFLA remains nervous about the application of the waste hierarchy and the implementation of alternative waste management strategies. This nervousness stems from policies being implemented in England and Wales by the Nuclear Decommissioning Authority (NDA) which in the view of NFLA are not compatible with environmental principles. These policies include, for example, the dilution and dispersal of waste into the sea via Magnox Dissolution Plants at, for example, Bradwell and Dungeness; an emphasis placed on “flexibility” in NDA documents indicating an intention to permit, and even encourage, the dilution and dispersal of radioactive contamination throughout the environment, provided that projected dose and risk levels remain within certain parameters; and options proposed for low level waste (LLW) management which could result in increasing public exposures and an additional burden of radiological risk carried by society.
NFLA would also have liked to gain an insight into the views of the Committee on Radioactive Waste Management (CORWM) concerning the Scottish Waste Policy. It is known, for instance, that CORWM have concerns about the waste at Dounreay which is not suitable for near surface disposal. Without knowing the detail behind their views, it is not clear how the Government will practically deal with allaying such concerns.
NFLA has played an observer role in the Project Board that has taken this policy forward. NFLA welcomes the Scottish Government’s willingness to engage with it on such matters.
NFLA Scotland Convener Councillor Bill Butler said:
This NFLA model response gives a well reasoned and intentioned submission to the Scottish Government on how it should implement its higher activity radioactive waste policy. The basic principles of the policy are broadly correct, but NFLA are concerned with issues around transportation of waste and the use of the word ‘disposal’, which remains a highly loaded term in waste management. NFLA calls on the Scottish Government to take full account of its views and concerns, and continue to involve it in the future implementation strategy of this important policy.”
For more information please contact Sean Morris, NFLA Secretary on 0161 234 3244 or Pete Roche NFLA Scotland Policy Advisor on 0131 444 1445.
Notes for editors:
(1) NFLA Radioactive Waste Management Policy Briefing 57 on the Implementation Strategy for Scottish Higher Activity Waste is attached with this media release. It will go on the NFLA website http://www.nuclearpolicy.info in the ‘Radioactive Waste Policy Briefings’ section.
(2) Scottish Government consultation document, May 2015
http://www.gov.scot/Resource/0046/00464771.pdf. The consultation closes on the 7th August.