Published at 09:04, Wednesday, 30 January 2013

Baroness Verma received several hundreds of questions and comments for the webchat on January 17 regarding the Managing Radioactive Waste Safely (MRWS) process in west Cumbria. The minister answered as many as she could during the live webchat, but the Department for Energy and Climate Change didn't want to leave questions unanswered. They have grouped the questions she didn’t have time to get to by theme and have answered them here.

Baroness Verma

Related: Baroness Verma webchat: Geological disposal in west Cumbria

Voluntarism
Several questions were raised about voluntarism, the definition of ‘community’, and who decides. In response:

Voluntarism is an essential part of the MRWS process. We are seeking a willing community with suitable geology to proceed with a geological disposal facility. The MRWS White Paper published in 2008 (Managing Radioactive Waste Safely: A Framework for Implementing Geological Disposal http://mrws.decc.gov.uk/assets/decc/mrws/white-paper-final.pdf) defines three types of community:

• Host community is defined as the community in which any geological disposal facility will be built. This will be a small geographically defined area and include the population of that area and the owners of the land. For example, it could be a town or village.
• Decision Making Body (DMB) is the Local Government decision-making authority for the host community.
• Wider Local Interests – other communities that have an interest in whether or not a facility should be built in the host community. Such as the next village, a neighbouring district or a community on the local transport routes to the host community.

All three levels of community will need to liaise closely with one another as the process is taken forward. Both Government and the Nuclear Decommissioning Authority (NDA) will engage with all three ‘communities’.

The DMBs are democratically elected by the local population to make decisions on their behalf, and in the interests of the whole community. The DMBs are able to express an interest in the process, decide to participate in further stages and also have the right of withdrawal from the process.

Copeland Borough Council, Allerdale Borough Council, and Cumbria County Council have made an expression of interest in beginning, without commitment, discussions with Government on the possibility of hosting a geological disposal facility at some point in the future.
Following on from the expression of interest, the DMBs formed a partnership, called the “West Cumbria MRWS Partnership”, representing interests from across the county, and conducted an extensive programme of public and stakeholder engagement in 3 parts, over a period of 3 years. The Partnership made significant efforts to reach as many people in the community as possible, including holding numerous public events and writing to every household in West Cumbria to raise awareness of the process.

As part of the consultation work, an Ipsos Mori poll was conducted which indicated that there was net positive support in Cumbria for moving forwards to Stage 4 of the MRWS process, without any commitment to hosting a facility.
The Partnership produced a comprehensive report for the DMBs (see http://www.westcumbriamrws.org.uk/documents/306-The_Partnership's_Final_Report_August_2012.pdf) who are now deliberating on whether to move forwards to Stage 4 of the MRWS process. Moving to Stage 4 is not a commitment to hosting a geological disposal facility, only to participate in the next stage of the siting process – to identify and assess where potential sites might be, and which further areas should be ruled out. DMBs have a right of withdrawal from the process up until construction of a facility begins. This has recently been reaffirmed in correspondence from DECC Ministers to the DMBs.

The opportunity for other communities to express an interest remains open. Government is encouraging other potential volunteer communities to come forward.

Geology
Several questions were raised on the requirements of the geology for a geological disposal facility, the suitability of the West Cumbrian geology, and how we can have confidence in the geology. In response:

Geological requirements for a geological disposal facility

There is not a recognised procedure of looking for a location with the “most promising” geology. There are various geological environments in which a GDF can be built and safety will need to be demonstrated with reference to the specifics of any chosen site. Nor has every other country looked at geology first.

Different countries have taken different approaches over whether to look at geology, or seek volunteers, first. Some, such as Sweden and Switzerland, have considered geology first and then asked the community. However, others, for example Canada, have approached the issue in the same way as we are doing and have looked for volunteers first.

Safety is paramount in geological disposal. A suitable site for a geological disposal facility is one which can be demonstrated to be safe to the satisfaction of the independent safety, security and environmental regulators. A facility would only be built if the independent regulators were satisfied that it would be safe, not just while it was operating, but also in the long-term after it was closed. Safety doesn’t require one particular type of geology – it requires a geology where the packaged waste, engineered structure of the packages, backfill, surrounding facility structure and surrounding rock all work together to provide the required level of safety for the long-term. There are a number of ways in which this can be achieved – which is evident from the range of rock types and engineered designs being developed for geological disposal facilities worldwide.

Suitability of West Cumbrian Geology

The geology of the whole of West Cumbria cannot be ruled out at this stage. The British Geological Survey’s initial screening against the high level criteria set out in the White Paper excluded about a quarter of Copeland and Allerdale as having clearly unsuitable geology. These criteria were very high level and designed to be easily applicable in any part of the country that might volunteer. The remaining three quarters, that’s about 1900 square kilometres, includes potential host rocks similar in type to those being investigated in other countries for hosting a geological disposal facility and is suitable for further investigation.

We don’t know enough at the moment to say whether West Cumbria has a volume of rock suitable for a disposal facility for the UK’s higher activity radioactive waste. We would need to do more investigations. That’s what would happen in the next stages of the MRWS process, if the DMBs decide to proceed. We know that some geoscientists have claimed that enough is known already to rule out the whole of West Cumbria. However, their views aren’t widely shared amongst the geoscience community and the best way to test them is to move forward and do more work on the geology.

Building confidence in the understanding of geology

Throughout the MRWS process, it will be important to have confidence in the views of the scientists involved. The scientific community has well-developed processes to provide that confidence. These include the processes of peer review One or more scientists provide an independent check on the work of others. We have already used peer review to give us confidence in the geological work carried out so far to support the MRWS process. The work carried out by the BGS was reviewed by several other groups, and the findings of those reviews have been made public. That way we can have confidence in their findings. We will continue to use peer review as the process proceeds.

Suitable geology in the UK

Some maps indicating regions of the UK which might be suitable for hosting a geological disposal facility, using a particular set of criteria proposed at the time, were produced in the 1980s to support historical siting studies. The analysis undertaken at that time showed that over 30% of the UK’s geology was potentially suitable for geological disposal. These maps are published. They are not the basis of the current Government policy which is built on voluntarism and partnership.

International experience has shown that there are two fundamental requirements for geological disposal - a suitable geology AND a willing community. The geology in many parts of the UK is potentially suitable for hosting a geological disposal facility. If these communities were to express interest in hosting a facility, they would also be considered.

Fracking
There was a question raised regarding the potential impact of ‘fracking’ on the suitability of geology.

The Department of Energy and Climate Change (DECC) has offered areas of Cumbria for petroleum licensing in the past (not specifically for shale gas or coal bed methane), but there is only one license still current anywhere near the region. That is to the north of Carlisle and is not in an area being considered as part of the siting process for a geological disposal facility. More recently, DECC has consulted on a Strategic Environmental Assessment (SEA) related to a proposed 14th onshore licensing round, which included further areas in West Cumbria, related to the coal bearing rocks already excluded from the MRWS process by the BGS. However, the SEA has not been concluded and there has been no new offer of onshore licenses. DECC would not offer for licence any area which, at the relevant time, was also under consideration as a potential site for a geological disposal facility for radioactive waste. Furthermore, such licences do not automatically cover fracking, which would require further permissions to be granted.

Safety
A range of questions were asked about how the safety of geological disposal will be demonstrated, how geological disposal will be regulated, site suitability, and long-term safety, post-closure. In response:

Demonstration of safety and regulation

The UK Government is committed to strong and effective regulation of geological disposal. If the independent regulators are not satisfied that a geological disposal facility can meet stringent safety, security and environmental protection requirements then they would not allow such a facility to be constructed or operated. These requirements are set out in legislation and in published regulators’ guidance, for example the Environment Agencies’ Guidance on Requirements for Authorisation of geological disposal facilities http://www.environment-agency.gov.uk/business/sectors/99322.aspx . These requirements reflect internationally agreed principles and best practice.
Geological disposal uses multiple barriers to inhibit the release of radionuclides. The barriers have to complement each other to provide the required level of performance. The suitability of a particular geological environment for hosting a geological disposal facility is established by the development of a safety case which needs to satisfy the independent regulators, how the engineered barriers of the disposal facility and the natural geological barriers work together to isolate and contain radioactivity.

At an early planning stage in the geological disposal programme, the Nuclear Decommissioning Authority has prepared a generic safety case http://www.nda.gov.uk/aboutus/geological-disposal/rwmd-work/dssc/index.cfm , i.e. one that is not specific to a particular site or geology. The regulators’ review of the generic safety case http://www.environment-agency.gov.uk/business/sectors/111766.aspx , found no specific issues that would prevent a safety case, capable of meeting transport, operational and environmental regulatory requirements, being made for a geological disposal facility in the future. This was subject to a suitable site being chosen and RWMD addressing the regulators’ comments in the development of this and future site-specific safety cases.

Further confidence in geological disposal as a safe concept is provided by the fact that geological disposal is the internationally preferred option for managing higher activity waste in the long term.

Site suitability

Stage 4 of the MRWS process would begin to identify and assess particular sites, using existing information, to inform further decisions on which ones, if any, should be considered for detailed physical site investigations. The Government has consulted on a process to carry this out in stage 4 and published a framework for this in 2012 (Managing Radioactive Waste Safely: A Framework for the Desk-Based Identification and Assessment of Potential Candidate Sites for Geological Disposal https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/42792/4618-mrws-framework-siting.pdf). This framework included a range of national criteria to be considered in the identification and assessment of potential sites in Stage 4. The criteria cover aspects such as potential impact on people and the natural environment and cost, timing and ease of implementation. These will be supplemented by criteria considered important by local communities. Therefore, these criteria tend not to be pass/fail criteria for a site, but aid comparative assessment.
Further, detailed physical site investigations would be required to gather much more information at prospective sites in future stages of the MRWS process before suitability could be demonstrated.

Ultimately regulators will need to be satisfied that the stringent safety, security and environmental protection requirements that they enforce are met. These requirements relate to the overall disposal system. Crucially therefore, the developer does not set generic site suitability criteria, but instead has to demonstrate that the regulatory requirements are met for a proposed facility design operating at a given site. In relation to the safety of a geological disposal facility in the long-term after closure, this involves setting out how the so called ‘multiple barriers’ of the disposal system perform and work together. These barriers comprise the actual radioactive wastes to be disposed of and how they are treated and packaged, the engineered disposal facility and the geological setting in which the facility is sited. So while high level requirements for a suitable site can be given, for example, size of available rock volumes, geologically stability, absence of significant natural resources, detailed absolute pass/fail criteria cannot. Safety will be determined by an assessment of how the entire system performs as a whole.

Intrusion

The environmental regulators assert that the likelihood of humans intruding into a geological disposal facility after it has closed can be regarded as highly unlikely because of the facility’s deep location, which is expected to be well beyond the reach of many types of intrusive activity. In addition, siting a facility away from significant natural resources will also reduce the likelihood of future intrusion. Nevertheless, the developer will have to present arguments to the regulators to support this assertion. This includes consideration and implementation of any practical measures to further reduce the likelihood of human intrusion such as marking of the site and archiving of records.

Right of withdrawal
There were a number of questions in relation to the Right of Withdrawal (RoW) in the MRWS process, including requests for clarity on the terms of the RoW, and how long communities will hold a RoW from the process. In response:

The Right of Withdrawal is an integral part of the voluntarism approach outlined in the MRWS White Paper. As is set out in the White Paper, up until Stage 6 of the MRWS process, when underground operations and the construction of a GDF are due to begin, a community’s participation in the process would stop if it wished to withdraw at any stage. This enables a community to reach an advanced stage in the MRWS process without commitment to hosting a facility.

While it is the Decision Making Bodies (DMBs) who hold the RoW, their decisions will be based on recommendations from a Community Siting Partnership, comprised of key stakeholders from the local communities engaged in the MRWS process.

Government is committed to supporting communities in the MRWS process and clarifying any specific queries a community may have. In December 2012, recognising the importance of the issue to the DMBs in West Cumbria, Baroness Verma made a commitment to investigate putting the Right of withdrawal on a firmer legal footing. Government has committed to looking at potential options for doing this, including primary legislation for the MRWS process, and will explore these options jointly with DMBs during Stage 4 .

It should be emphasised that any changes to the policy confirmed in the White Paper would need to be consulted on publicly, and communities and DMBs can therefore be confident in the process outlined in the White Paper. The DMBs in west Cumbria hold a Right of Withdrawal, and will continue to hold this right until the potential commencement of underground operations and construction of a geological disposal facility in MRWS Stage 6.

Alternatives to geological disposal
Questions were raised on above ground storage, re-using waste, and alternative disposal options.

The Government initiated the Managing Radioactive Waste Safely (MRWS) progress with the aim of finding a practical solution for the long-term management of higher activity radioactive waste. As part of this process, the independent Committee on Radioactive waste Management (CoRWM) undertook a wide ranging review of potential options, including disposal, storage and treatment options, for the long-term management of higher activity waste. CoRWM engaged widely with the public and expert stakeholders between 2003 and 2006 and considered every available option for long-term management of waste. Government accepted the Committee’s recommendation that geological disposal, preceded by safe and secure interim storage, is the best method of managing higher activity waste in the long term. Geological disposal is also the internationally preferred option for managing higher activity waste in the long term.

Geological disposal is favoured over continued storage for a number of reasons and in particular because it reduces burdens on future generations. Nevertheless it is recognised that safe, environmentally sound and secure interim storage of those wastes is essential until they can be permanently disposed of. Therefore, the UK continues to make major investments into the conditioning and packaging of higher activity wastes and the deployment of modern standard storage facilities for those waste packages. This work continues in parallel with efforts to implement a disposal facility for the long-term.

Government recognises the need to take account of developments in storage, treatment, reuse and disposal options. Therefore it has tasked NDA with continuing to review developments so that they can be taken account of, for example to reduce the amounts of waste requiring geological disposal.

Radioactive waste is, by definition, material that has no further use. Not everything can be recycled and the current radioactive waste inventory includes waste products from the reprocessing of other nuclear materials and waste from decommissioning old nuclear facilities. These wastes will increase as decommissioning proceeds. There will, therefore, always be a need for a waste disposal solution, no matter what other options might become available for recycling some nuclear materials.

Community benefits
There were a number of questions pertaining to what the proposed ‘community benefits package’ would entail, and what jobs the geological disposal facility could bring to the area.

A geological disposal facility is a state of the art, multi-billion pound project that would directly provide skilled employment for an average of 550 people for over a century, provide indirect employment through the supply chain and the local services supporting the facility, and stimulate enhanced investment in the region’s infrastructure.

Government has also committed to providing a community benefit package, commensurate with developing the social and economic wellbeing of a community that has decided to fulfil such an essential service to the nation. Without wishing to pre-judge what the overarching objectives of a community benefits package might be – as these must be tailored to local needs - they could include educational investment, improved housing and recreational facilities, better local healthcare, and local environmental improvement.

Compensation
There were few questions asking whether individuals and / or businesses impacted by a ‘decision to participate’ in Stage 4 would be compensated by Government.

A decision to participate would not commit West Cumbria to hosting a geological disposal facility – it marks only the beginning of work to identify and assess potentially suitable sites.

Tourism and other businesses have co-existed with the nuclear industry in Cumbria with no known adverse effects for over 50 years. However, Government has agreed to support a Cumbria brand protection programme – both to provide robust evidence of the scale of any impact on the brand and future mitigation, and support the Cumbria Lake District brand, in the event of a decision to participate further in the siting process.

Inventory
Questions were asked as to whether plutonium and waste from new nuclear power stations would be disposed of in a geological disposal facility.
Currently waste owners place a zero asset value on plutonium, meaning that it is neither classed as waste nor a commercial asset. If it were decided at some point that plutonium had no further use, it could be managed through geological disposal. In the meantime, the Nuclear Decommissioning Authority will factor possible inclusion of plutonium into the design and development of a geological disposal facility. Even if plutonium is somehow re-used, that process would then generate waste that would have to be managed.

With regards to waste from new nuclear power stations, disposability assessments undertaken by the Nuclear Decommissioning Authority support Government’s view that it would be technically possible to dispose of both new and legacy waste in the same geological disposal facility. The designs for new nuclear plants that are currently available have simpler structures than most existing facilities, use fewer materials and produce less waste than earlier generations of nuclear reactors.

Planning permission
There were a couple of questions about planning permission for a geological disposal facility.

Planning permission will be required for the development of a geological disposal facility but at this point in the process no potential site has been identified. Government has not yet taken a final decision on how planning permission would be sought, but is currently inclined to look towards applying the system first established by the Planning Act 2008, to decide applications for major infrastructure projects of national importance.

Other approaches
Questions were asked about what other countries are doing with managing radioactive waste.

Geological disposal is the internationally preferred approach for the long-term management of higher activity radioactive waste. The Governments of 23 countries with radioactive waste have taken a final decision on long-term radioactive waste management policy and have opted for geological disposal including Belgium, Finland, Hungary, Russia, the US and Sweden. The US has just this month published its strategy for the long-term management of spent nuclear fuel and high level waste which involves interim storage followed by geological disposal and a consent-based approach to siting.

A further 12 countries have expressed a preference for geological disposal. Six countries have yet to decide and the situation in a further two is unknown. An approach based on voluntarism and partnership has been used in a number of countries as part of processes for the siting of disposal facilities for radioactive waste. Different countries have taken different approaches over whether to look at geology, or seek volunteers, first. Some, such as Switzerland, have considered geology first and then asked the community whether they would like to participate in the site selection process. However, others, for example Canada, France and Japan have approached the issue in the same way as we are doing and have looked for volunteers first.

Under our approach we are seeking a community who are willing to work with Government to evaluate whether their area would be suitable for a geological disposal facility. Safety is paramount. Unless a site or a region can be shown, following detailed investigations, to have suitable geology for such a facility, it will not be built there.

Tourism and the national park
There were a number of questions asked about the potential impact on tourism in the area and the Lake District National Park. In response:
We remain committed to preserving the special status of the Lake District National Park. No sites have been identified at this stage. The MRWS White Paper makes it clear that local communities should not be adversely affected by being involved in the MRWS process.

If we move forward, the case for having a geological disposal facility at a particular site in Cumbria will have to be made. Part of this case will be the consideration of all impacts, both positive and negative, which would include potential impacts on tourism, jobs and the environment.

Other communities
There were several questions about potential sites for a geological disposal facility outside of west Cumbria. There were concerns that Government had pre-determined Cumbria as the only possible location for a geological disposal facility, that Government was not doing enough to encourage other communities to come forward, that the principle of voluntarism was “dubious”, and that geology might be more suitable elsewhere in the country.

The experience from the UK and overseas suggests that the best chances of success in implementing geological disposal come through working in partnership with a willing community as well as with suitable geology. The Government is therefore committed to a voluntarism and partnership approach.

We have not pre-determined that a geological disposal facility should be in Cumbria, and no potential sites have been identified. Indeed, the invitation remains open to communities elsewhere in the country to express an interest in joining the MRWS process. There has already been public engagement activity in Shepway District Council during 2012 on the potential for involvement and we look forward to wider engagement on MRWS in future.

We are always considering ways to raise wider awareness of MRWS and attract interest in the process from other communities. We remain of the view that the prospect of eventually hosting a geological disposal facility should provide a very powerful incentive: it will be a multi-billion pound development (estimated to cost over £12 billion, undiscounted over the operating lifetime of the facility). The community that hosts a geological disposal facility will benefit economically, including from the direct creation of jobs for many decades, with potentially over a thousand during peaks in construction, plus indirect employment in the supply chain and service industries, and also infrastructure improvements.

The Government has also given a commitment that there will be a substantial community benefits package, tailored to local needs and priorities, which will assist with developing the social and economic wellbeing of the host community.

New build
Questions were asked regarding whether it is responsible for the Government to pursue a policy of new nuclear build without a geological disposal facility. In response:

The Government believes that the geological disposal of higher activity radioactive waste is technically achievable, and that a suitable site can be identified. This is important not only in relation to any new nuclear power stations: the UK already has a significant quantity of higher-activity radioactive waste.

It is Government policy that before consents for new nuclear power stations are granted, we will need to be satisfied that effective arrangements exist, or will exist, to manage and dispose of the waste they produce.

Government has been clear about the need for safe long-term management of higher-activity waste produced by new nuclear power stations and that this is technically achievably through geological disposal. Until such time as a GDF is implemented, it remains Government’s policy that higher-activity radioactive waste should continue to be held in safe and secure interim storage which will be available until a geological disposal facility can accept the waste.

Siting
Questions were asked on whether a geological disposal facility could be built anywhere in Cumbria. In response:

It is not the whole of Cumbria that is being considered in the siting process for geological disposal facility. A key principle of the MRWS process is voluntarism. This means that a geological disposal facility can only be built in an area that has voluntarily expressed an interest in taking part in the process that will ultimately provide a site for such a facility.

The identification and assessment process during Stage 4 of the MRWS process will only consider areas covered by a local authority Decision to Participate in the site selection process.

The application of technical selection criteria and the regulatory permissioning process through future stages of the multi-stage MRWS process would allow Government and NDA to identify whether any sites are potentially suitable – the NDA cannot build a geological disposal in any location that at which long term safety cannot be demonstrated to the satisfaction of the independent regulators.

Cost
Some questions were asked about how much a geological disposal facility will cost, and who will pay for it. In response:

The estimated cost of geological disposal in the UK, including research, design, construction, operation and closure of a disposal facility is equivalent to an undiscounted lifetime cost of about £12 billion (2008 prices) spread over 100 years or more of operation. This will vary depending on location, design, and inventory of waste for disposal.

Existing legacy waste for disposal has largely arisen through the UK’s public sector nuclear programmes and Government has long recognised that delivering and paying for a long-term waste management solution for legacy waste is a responsibility that falls to the public sector, in line with the polluter pays principle. We have committed to a staged implementation process that allows affordability and value for money to be assessed at various points.

The Nuclear Liabilities Fund (NLF) was formed in 1996 to cover the future waste management and decommissioning costs of the British Energy nuclear estate. The British Energy estate is now owned by EDF Energy.

With regards to new build, it is for energy companies to construct, operate and decommission new nuclear power stations. In December 2011 Government published Funded Decommissioning Programme Guidance and the final Waste Transfer Pricing methodology. This will ensure that operators of new nuclear power stations make secure financial provision for their liabilities from the outset in line with the Government’s policy, as set out in a written statement of October 2010, that there should be no subsidy for new nuclear.

Council decisions in Cumbria
There were a number of questions raised about the decision the local authorities in west Cumbria are due to take on 30 January over whether to proceed to Stage 4 of the Managing Radioactive Waste Safely (MRWS) process. In particular, there were requests for clarity on local communities’ input into the decision, and the Government’s plan if the local authorities decide against participation in MRWS Stage 4. In response:

It is important to note firstly that the decision being taken on 30 January is not a decision to host a geological disposal facility (GDF). It is only a decision on participation in the next stage of the MRWS site identification process for a potential GDF, with an ongoing right of withdrawal.

While it is the local authorities who will take the decision on participation, their position has been informed by the extensive work of the West Cumbrian MRWS Partnership. The Partnership’s work was entirely funded by Government but it set its own work programme and chose how to spend the funding allocated. This group has carried out three years of public and stakeholder engagement activities to investigate issues identified as being of most importance locally. It has sought independent advice on technical and other issues of detail that arose through its work and has procured an IPSOS MORI public opinion survey in 2012, the results of which showed net public support for a Decision to Participate in the siting process for a GDF. The Partnership produced a comprehensive report to the local authorities in August 2012, which is publicly available at http://www.westcumbriamrws.org.uk/images/final-report.pdf.

If the local authorities decide to participate in Stage 4 of the MRWS process, a Community Siting Partnership (CSP) will be set up, to advise Decision Making Bodies on subsequent steps in the GDF process. While Government has not been prescriptive about the membership of a CSP, it is likely that it will involve key stakeholders and representatives of the potential host community or communities and there will therefore be an opportunity for the local communities to express their views about any further progress in the GDF process.
The Government hopes that the local authorities in west Cumbria will decide to continue with the MRWS process, but respects that it is the right of the Decision Making Bodies to withdraw from the process if they wish to do so. Government believes that implementation of a GDF is technically achievable, and that it is possible to find a site with suitable geology to host a facility. As is outlined in the MRWS White Paper, while Government policy is for geological disposal of higher activity radioactive waste, until a GDF is implemented, waste will be maintained in safe and secure interim storage.

The invitation for other communities to find out more about the MRWS process without commitment is still open. Government is keen to ensure that any interested local community receives as much information as they need to make informed decisions about progressing in stages through the MRWS process.

Published by http://www.newsandstar.co.uk