Last night I submitted my latest (of dozens) of responses to a Government or nuclear industry sector public consultation on nuclear policy, this time on the flawed machinations of trying to find site or sites where nuclear waste can be disposed of.
I strongly complained that previous submissions had been entirely ignored, which had reduced the incentive to commit to researching and preparing detailed submission this time.
The same complaint was included in the Cumbria Trust submission, which asserted:"BEIS and its predecessors have a track record of issuing consultation documents and choosing to ignore responses that go against their preconceived plans."
My own submission was very short, but appended the very long evidence I submitted year ago, which was ignored, with the demand it be heeded this time.
Response to RWML consultation on: Site Evaluation - How we will evaluate sites in England
By Dr David Lowry
I attended the Site Evaluation Consultation forum hosted by RWML in London on 13 February 2019.
I found it an extremely depressing experience as a succession of BEIS and RWML officials presented a series of misinformation, and given the seniority the presenters have, they must also have dissembled, as the presenters must have known what they were saying on certain issues was inaccurate and/or untrue
I tried to intervene several times to challenge or correct this ‘fake’ information, to be fobbed off, and told I would be contacted after the forum to deal with the points I raised. This did not happen for five weeks, then all I got was a pdf copy of the very documentation I already possessed, and had already decried as replete with inaccuracies.
I regard this form of response to criticism from the body designated as the ‘implementer’ by the UK Government as quite contemptuous, disgraceful and indefensible.
It make sme concerned that the RWML officials are tin-eared and do not want to hear any comments that do not accord with their own distorted vison.
Indeed, the way officials present at the forum mentioned above, justified RWML not taking account of the detailed evidence I submitted to a similar consultation a year ago on Working with Communities.
In my view, the situation I addressed in that submission remains the same today, and so I decline to commit further work to craft a new submission, but am re-submitting the evidence in the hope finally those reading the submissions will take note of critical submissions, and, importantly act on them not just cheerleading submissions in favour of developing a GDF.
Please publish my submission in full.
Dr David Lowry
31 March 2019
My submission addresses these issues below, rather than following th efour consultation questions:
Transport – the potential implications for national and local transport networks of constructing, operating and closing a GDF at any given geographical location, including any enhancements to local networks that may be required at that location and the ability to mitigate those potential impacts.
Security 18 - The ability to design, construct, operate and close a GDF in accordance with all Requirements relating to security.
Table 6: Evaluation Considerations for the Siting Factor - Transport
The potential implications for national and local transport networks of constructing, operating and closing a GDF at any given geographical location, including any enhancements to local networks that may be required and the ability to mitigate those potential impacts.
Transport Safety 23 - The ability to design, construct, operate and close a GDF in accordance with all Requirements relating to transport safety. This will include consideration of Requirements relating to the safety of transport of both radioactive materials (regulated by the Office for Nuclear Regulation) and non-radioactive materials.
Transport Security 24 - The ability to design and operate a GDF Transport System in accordance with all Requirements relating to security.
Transport impact 25 - The potential impact of proposed transport infrastructure and associated traffic movements will be considered in line with Requirements relating to transport impact, including the ability to avoid, mitigate or compensate for those impacts.
Consultation Question 1:
Are there any other sources of high level Requirements, other than the Siting Process Requirements and the Legal Requirements identified, that you think should be reflected in the Site Evaluation and why?
Consultation Question 2:
Do you agree with the Siting Factors we have identified? Are there any other Siting Factors that should be included and why?
Consultation Question 3:
Do you agree with the Evaluation Considerations we have identified? Are there any other Evaluation Considerations that should be included and why?
Consultation Question 4:
Is there anything else that you think we should consider in our site evaluations and why?
Nowhere to Glow?
Dr David Lowry
senior research fellow, Institute for Resource and Security Studies, Cambridge, Ma. US
member, Nuclear Waste Advisory Associates, UK
19 April 2018
Analysis of the BEIS joint consultations on Working with “Communities” and the National Policy Statement on plans for a national Geological Disposal Facility (GDF)
The Working With Communities consultation document asserts at para 2.4:
“The work to take into account the views of stakeholders and the public has supported an open policy making approach throughout the development of the Working with Communities policy proposals. We are continuing this approach by seeking views through this consultation from the general public and stakeholders on the policy proposals. Once the consultation has closed, and the responses have been considered, a Government response and final policy position will be published.”
While public engagement is a good practice, listening to the views expressed, and altering draft policy as a result is better practice. Experience suggests this rarely happens in radioactive waste consultations, and when it does, the changes are minimal.
It is hoped this consultation will mark a significant change from this hitherto counter-productive policy of early alienation of interested parties.
Q1.Do you agree with this approach of identifying communities? Do you have any other suggestions that we should consider?
In the consultation document, the energy minister responsible for nuclear waste policy, Richard Harrington writes: “We believe the best way to select a site for a geological disposal facility is in partnership with communities.”
He adds “Building and operating a geological disposal facility is a multi-billion pound, intergenerational, national infrastructure project, which is likely to bring substantial benefits to its host community, with skilled jobs for hundreds of people over many decade.”
This short quote embodies the problem with how BEIS has characterised what comprises community for the purposes of the consultation document “Working with Communities (WWC).” For BEIS in this document a “community” is really a “directly affected host community” around the location of the above-ground receipt and transfer terminal for waste packages transported to the GDF. It is a great pity BEIS has decided to use such a narrow definition, because it excludes by fiat several much wider issues of public, political and safety concerns that will inevitably arise with development of a GDF.
In the WWC consultation summary, it describes the nature of community concerns as follows:
“There are many different ways in which people identify with areas, or define themselves against localities within those areas. Lessons learned from previous processes have underlined the importance of finding an approach that is clear, flexible, reflects the long-term nature of the siting process, and represents local government at all levels and other community groups appropriately.”
BEIS thus sees the relevant community as a “locality” relatively closed to and surrounding the GDF above ground workings.
But several years ago, BEIS actually established and sponsored a ‘Community Representation Working Group (CRWG) to explore the meaning of community, and the consequences of defing “community” in a particular way. The WWC consultation summary states:
“Efforts have been made to include input from a range of stakeholders and the public. A call for evidence, a literature review and public dialogue events in Manchester and Swindon have been undertaken to help develop the proposals”
The relevant footnote points out that the call for evidence can be found at: https://www.gov.uk/government/consultations/implementing-geological-disposal-working-with-communitie
The literature review and public dialogue events can be found at: https://www.gov.uk/government/publications/public-dialogue-on-geological-disposal-and-working-with-communities
BEIS needs to revisit this evidence when determining the final scope for the definition of community in this decision making process. Below I have extracted some of the discussion from reports published by the CRWG, which demonstrates the differing implications for policy of adopting narrow or broader conceptualization of “community.”
One major issue underpins the reason why the wider definition is essential is any GDF will require the transport to the GDF receipt facility of the radioactive waste packages, even if the GDF were to be build close to Sellafield, where the preponderance of waste ( both by volume and radioactivity) is currently stored. This is actually recognised - in a minor way- in the WWC consultation, when it concedes that there are wider ‘affected’ communities from such a 100 plus year development, at Paragraph 4.7, which makes clear that transport links/routes, from the geological disposal facility site to the nearest port, railhead or primary road network (i.e. as far as where minor roads meet the nearest ‘A’ roads used for transport on a regional or county level’ will be considered relevant.
At footnote number 26 to the document adds: “In selecting a site, the ‘delivery body’ would give consideration to existing transport infrastructure, suitable transport modes and routes, and appropriate mitigation measures to minimise any adverse impacts on a community.”
But the potentially hundreds of miles of ‘affected communities’ along road and rail routes from radioactive waste stores, to any centralized repository, are essentially ignored. Why does BEIS believe people living in these communities with multiple hundreds of loads of radioactive materials coming past where they live for many decades do not deserve significant attention, not least because radioactive waste in transit is more immediately dangerous to people close to transport routes than it is in an engineered GDF deep underground?
The Draft National Policy Statement recognizes at para 4.11.3 that there are security implications of developing a GDF, stating inter alia:
“Where national security implications have been identified, the applicant should consult with relevant security experts from the Centre for the Protection of National Infrastructure, the Office for Nuclear Regulation Civil Nuclear Security Programme and the Department for Business, Energy and Industrial Strategy (BEIS) to ensure that physical, procedural and personnel security measures have been adequately considered in the design process and that adequate consideration has been given to the management of security risks. If the Centre for the Protection of National Infrastructure, the Office for Nuclear Regulation Civil Nuclear Security Programme and the Department for Business, Energy and Industrial Strategy (BEIS) are satisfied that security issues have been adequately addressed in the project when the application is submitted to the Examining Authority, they will provide confirmation of this. The Examining Authority should not need to give any further consideration to the details of the security measures in its examination.(emphasis added) The Office for Nuclear Regulation Civil Nuclear Security Programme is responsible for approving security arrangements within the civil nuclear industry and enforcing compliance to prevent the theft or sabotage of nuclear or other radioactive materials, the sabotage of nuclear facilities, and to protect sensitive nuclear information; it does this in accordance with the Nuclear Industries Security Regulations 2003 and the Ionising Radiations Regulations 1999. The Secretary of State is entitled to rely on appropriate regulation of impacts in considering development consent applications.”
The Centre for the Protection of National Infrastructure was contacted in February, asking for further details of the work it has done on protecting the GDF and associated transport networks, but failed to even acknowledge the request, let alone answer it.
It is surely unacceptable that a potentially key Government body that will be involved in the future security of the GDF project can ignore enquiries for relevant information helpful to clarifying the important consultation questions.
One day before the consultation closed, BEIS delivered by e-mail an additional set of four answers to questions raised at consultation forums several weeks earlier. One Question asked was:
If the eventual site for a GDF is not near Sellafield, what are the plans for transporting all of this waste out of Sellafield? Have (RWM) considered the costs and safety and security considerations for transporting most of the GDF inventory out of Sellafield to the GDF?
The answer given was:
“Higher activity radioactive waste is currently stored at over 30 sites in England and Wales. It will be transported to a GDF site over a long period of operation and therefore the rate of movement of radioactive waste will be low. The preferred modes of transport for radioactive waste would be rail or sea, though consideration of the mode of transport will be undertaken on a site specific basis. As the developer, RWM will have to consider the transport impacts (and consult on this and other impacts) as part the planning process. Radioactive waste has regularly been transported around the country for many decades.
Waste arriving at a GDF site will be in highly engineered transport containers. Radioactive materials have been safely transported not only in the UK but worldwide for over 60 years. There is a lot of experience in this area. There are very strict safety requirements laid out in national and international law. A number of large-scale safety demonstrations have been conducted to demonstrate that transport packages can withstand severe accident conditions.”
This is both an inaccurate and misleading answer by omission and commission.
BEIS needs to do better and more credible background research, rather than mak unsupported safety assertions. It’s claim “radioactive materials have been safely transported not only in the UK but worldwide is highly misleading. BEIS should review the internationally available reports on nuclear materials transport accidents, such as
‘Transportation accidents/incidents involving radioactive materials (1971--1991)’
The Radioactive Materials Incident Report (RMIR) database contains information on transportation-related accidents and incidents involving radioactive materials that have occurred in the United States. (USDoE, Office of Science and Technology, OSTI, International symposium on the packaging and transportation of radioactive materials: PATRAM '92, Yokohama (Japan), 13-18 Sep 1992; https://www.osti.gov/biblio/7193124 & https://inis.iaea.org/search/search.aspx?orig_q=RN:24038415
The international standards and arrangements are included in this 468 page IAEA document: ‘Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material- Specific Safety Guide (No. SSG-26).’ (https://www-pub.iaea.org/books/IAEABooks/8851/Regulations-for-the-Safe-Transport-of-Radioactive-Material-2012-Edition-Specific-Safety-Requirements)
The regulator of nuclear materials transports, the Office for Nuclear Regulation, published report in which indicated over 1000 accidents/ events involving radioactive material in transit within, to or from the UK since 1958. The abstract states:
“This report includes descriptions of thirty eight accidents and incidents involving the transport of radioactive materials from, to, or within the United Kingdom, which occurred in 2011. The number of events reported in 2011 was higher than in 2010 (30 events), and near the top of the range of the number of events that have occurred in the last five year period: 30 events in 2010, 33 events in 2009, 39 events in 2008, 26 events in 2007 and 29 events in 2006. Of the 38 events included in this review 11 involved irradiated nuclear fuel flasks (there were also 8 such events in 2010). Only one of the events reported, involving the transport of a radiopharmaceutical source, resulted in any potentially significant radiation dose.
The details of these events have been entered into the RAdioactive Material Transport Event Database (RAMTED), which now contains information on 1018 events that are known to have occurred since 1958.”
(Radiological Consequences Resulting from Accidents and Incidents Involving the Transport of Radioactive Materials in the UK – 2011 Review; http://www.onr.org.uk/transport/hpa-crce-037.pdf)
It is also obvious the BEIS response makes no attempt to address the security question. By avoiding inconvenient questions does not make them go away.