UK government’s proposals on radioactive substances : -all of its 7 “consultation questions” should be vigourously opposed.

Nuclear Waste Consultation, No2 Nuclear Power SAFE ENERGY E-JOURNAL No.97, April 2023

The UK and devolved governments have launched a consultation on proposals to update and consolidate policies on managing radioactive substances and nuclear decommissioning into a single UK-wide policy framework. (1) The new document will basically replace existing policy which dates back to a 1995 document commonly known as Command 2919. The proposals focus on 3 areas: managing solid radioactive waste; updating the policy for nuclear decommissioning; managing nuclear materials and spent nuclear fuel. Proposals include leaving lower-level waste behind on decommissioned sites; disposing intermediate level waste in near surface facilities and, most shockingly, reintroducing reprocessing.

In a draft response, I argue that the consultation has its priorities the wrong way round. In Part 1 there is far more emphasis placed on cost-effectiveness and removing burdens from industry, whereas protecting public health appears to be relegated to a second-class objective. Even here the emphasis is on meeting safety and environmental regulations rather than maximising public health protection, with no recognition of the uncertainties involved in radiation protection.

There needs to be a new emphasis on openness, transparency and public consultation as plans for decommissioning and waste management are developed, so that the public is fully aware of the intended destination of each waste stream, radioactive discharges expected from each proposed method of waste management and the dose implications of each proposed action. The public should also be given access to independent advice.

The document says: Government “must strive to keep the creation of radioactive waste to a minimum,” which given that the latest UK Energy Security Strategy proposes increasing the target for new nuclear power stations from 16GW to 24GW is nothing short of misleading.

The proposals would embed the so-called Nuclear Waste Hierarchy into Government Policy. In our view the Hierarchy promotes methods of radioactive waste management which are basically ways of diluting and dispersing radioactive waste around the environment, ultimately discharging radioactive substances into our estuaries, seas and atmosphere whilst masquerading as the environmentally friendly sounding ‘waste hierarchy’. Diverting increasing quantities of radioactive waste to landfill, metal recycling and incineration plants is a policy of dilute and disperse rather than one of concentrate and contain. This is ‘waste management on the cheap’. Waste management techniques should be based on environmental principles, particularly the principle that hazardous waste should be concentrated and contained in isolation from the environment.

The document also proposes a new policy framework for near surface disposal facilities for some types of intermediate level waste in England and Wales. It should be noted that while these near surface facilities might resemble Scottish near surface facilities, in Scotland waste could be retrieved if something went wrong, but in England and Wales retrieval is not planned for.

The new policy also proposes the promotion of on-site disposal on nuclear and former nuclear sites with the rider “where it is safe to do so”. This is to “help drive earlier and more cost-effective nuclear decommissioning and management of radioactive waste without compromising safety and security.”

Finally, the consultation says “New and advanced reprocessing technologies, with integrated waste management, may be developed in the future which support advanced nuclear reactor systems. The UK Government is continuing to support the advanced nuclear sector through investments in research facilities and programmes.”

The Consultation Document asks 7 “Do you agree” questions. The answer to all seven should be “No”. https://www.no2nuclearpower.org.uk/wp/wp-content/uploads/2023/04/SafeEnergy_No97.pdf