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.
Submission
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
Annex
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.
No comments:
Post a Comment