Comments on: UK nuclear waste policy “incoherent and opaque” http://ecostreet.com/blog/toxic-world/2007/11/27/uk-nuclear-waste-policy-%e2%80%9cincoherent-and-opaque%e2%80%9d/ Raising Green Consciousness since 2002 Thu, 07 Aug 2008 20:07:39 +0000 http://wordpress.org/?v=2.3.3 By: Max Wallis http://ecostreet.com/blog/toxic-world/2007/11/27/uk-nuclear-waste-policy-%e2%80%9cincoherent-and-opaque%e2%80%9d/#comment-48842 Max Wallis Thu, 29 Nov 2007 14:03:11 +0000 http://ecostreet.com/blog/toxic-world/2007/11/27/uk-nuclear-waste-policy-%e2%80%9cincoherent-and-opaque%e2%80%9d/#comment-48842 The Welsh Anti-Nuclear Alliance response to Defra's Dump-it-Deep proposal include a paper by Hugh Richards demolishing the basics of the Defra MRWS document: www.cynefinywerin.org.uk/index.php?docid=290 plus criticisms of the 'consultation' process that include the point that any decision in principle for a nuclear dump would be invalid because no SEA has been carried out. Strategic Environmental Assessment (SEA) is a legal requirement for framework policies and programmes intended for use in development plans and consenting. It requires consideration of alternatives on a consistent basis, measured against environmental factors. The CD’s s.5.35 proposes ‘criteria’ for site assessment which are said to derive from SEA regulations, but “may not be relevant” and “may have different weight” (5.36). They are not real ‘criteria’ (eg. “potential impact on people” and “infrastructure provision”) but headings. A proper SEA of radwaste disposal (including options for “geological” disposal) has to precede site assessment and would formulate criteria for it. There was much discussion of the need for SEA at the Cardiff Workshop, with the CCW rep saying the process is not only a legal requirement but has a good deal of experience in application (contradicting Defra claims). The Leeds workshop record does not mention it, while the Reading Workshop record contains the faulty description: Strategic Environmental Assessment (SEA) requires continual review of options (i.e. review of projections, research on alternative storage) This shows the inadequacy of Workshop dominated by official and industry representatives, when this crucial process issue is not posed in the consultation material. SEA requires consideration of alternatives not continual review of options as recorded at Reading. WAG does not indicate any other options, despite saying they are not committed to geological disposal with the Minister saying rather that she is ”committed to securing the long term safety of radioactive waste”. • Defra admitted surface storage for 100 years is the fall-back option • Division Head Robert Jackson said in his presentation the alternative to deep geological disposal is surface storage for 100 000 yrs. • CoRWM’s alternative was surface storage for 300 years; they subsequently dropped this option because of uncertainty over institutional break-down over so long a period • CoRWM’s critics proposed surface storage for ~50 yrs while options are adequately researched and (potentially) international agreements changed. SEA is needed to ensure proper formulation of alternatives. There is advantage in keeping options open and not rushing to mega-£M contacts for site investigation. SEA would address variants of “deep geological disposal”, specifically an off-shore repository accessed from an island or from the shore (as in Sweden). Defra claims this is included in CoRWM’s and their definition, but they stress on a site near a ‘community’; their failure to say explicitly off-shore shows this claim is post hoc. The off-shore alternative has specific problems (eg. access; cost) and advantages (exposure to future local population) that an SEA would bring out. The Welsh Anti-Nuclear Alliance response to Defra’s Dump-it-Deep proposal include a paper by Hugh Richards demolishing the basics of the Defra MRWS document:
http://www.cynefinywerin.org.uk/index.php?docid=290
plus criticisms of the ‘consultation’ process that include the point that any decision in principle for a nuclear dump would be invalid because no SEA has been carried out.

Strategic Environmental Assessment (SEA) is a legal requirement for framework policies and programmes intended for use in development plans and consenting. It requires consideration of alternatives on a consistent basis, measured against environmental factors.

The CD’s s.5.35 proposes ‘criteria’ for site assessment which are said to derive from SEA regulations, but “may not be relevant” and “may have different weight” (5.36). They are not real ‘criteria’ (eg. “potential impact on people” and “infrastructure provision”) but headings. A proper SEA of radwaste disposal (including options for “geological” disposal) has to precede site assessment and would formulate criteria for it.

There was much discussion of the need for SEA at the Cardiff Workshop, with the CCW rep saying the process is not only a legal requirement but has a good deal of experience in application (contradicting Defra claims). The Leeds workshop record does not mention it, while the Reading Workshop record contains the faulty description:
Strategic Environmental Assessment (SEA) requires continual review of options
(i.e. review of projections, research on alternative storage)
This shows the inadequacy of Workshop dominated by official and industry representatives, when this crucial process issue is not posed in the consultation material.

SEA requires consideration of alternatives
not continual review of options as recorded at Reading. WAG does not indicate any other options, despite saying they are not committed to geological disposal with the Minister saying rather that she is ”committed to securing the long term safety of radioactive waste”.
• Defra admitted surface storage for 100 years is the fall-back option
• Division Head Robert Jackson said in his presentation the alternative to deep geological disposal is surface storage for 100 000 yrs.
• CoRWM’s alternative was surface storage for 300 years; they subsequently dropped this option because of uncertainty over institutional break-down over so long a period
• CoRWM’s critics proposed surface storage for ~50 yrs while options are adequately researched and (potentially) international agreements changed.
SEA is needed to ensure proper formulation of alternatives. There is advantage in keeping options open and not rushing to mega-£M contacts for site investigation.

SEA would address variants of “deep geological disposal”, specifically an off-shore repository accessed from an island or from the shore (as in Sweden). Defra claims this is included in CoRWM’s and their definition, but they stress on a site near a ‘community’; their failure to say explicitly off-shore shows this claim is post hoc. The off-shore alternative has specific problems (eg. access; cost) and advantages (exposure to future local population) that an SEA would bring out.

]]> By: Mitch http://ecostreet.com/blog/toxic-world/2007/11/27/uk-nuclear-waste-policy-%e2%80%9cincoherent-and-opaque%e2%80%9d/#comment-47576 Mitch Tue, 27 Nov 2007 19:14:30 +0000 http://ecostreet.com/blog/toxic-world/2007/11/27/uk-nuclear-waste-policy-%e2%80%9cincoherent-and-opaque%e2%80%9d/#comment-47576 "The crux of the problem is that the Government has ignored important recommendations of the Committee it set up to look into the nuclear waste problem. " The Crux of the problem is that there is no safe way to dispose of Nuclear Waste. Mitch “The crux of the problem is that the Government has ignored important recommendations of the Committee it set up to look into the nuclear waste problem.
”

The Crux of the problem is that there is no safe way to dispose of Nuclear Waste.

Mitch

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