SUMMARY OF RESPONSES TO CONSULTATION ON PROPOSALS FOR INTERMEDIATE LEVEL RADIOACTIVE WASTE SUBSTITUTION
THE CONSULTATION The public consultation on Proposals for Intermediate Level Radioactive Waste Substitution was launched on 31st January 2004. Around 1600 copies of the consultation document were distributed to a wide variety of people and organisations (MPs, MEPS, local government, environment groups, industry, trade unions), and it was also made available on the DTI website. The consultation period ran from 31st January 2004 and concluded on the 30th April 2004. The consultation document contained a study conducted by NAC International on behalf of the DTI, that assessed the environmental case for implementing ILW substitution on BNFL contracts now rather than waiting until there is greater certainty on the long-term strategy for ILW. A copy of the consultation document can be found by following the links on www.dti.gov.uk This document summarises the responses received. The Government, having taken into account the points made, will announce whether or not it will allow ILW substitution in due course RESPONDENTS MP/MEP/MSP/WAM
(MSP – Member of Scottish Parliament; WAM – Welsh Assembly Member)
Number of Responses 5 19 2 7 117 44 8 2 107 14 Total 325
Nuclear Industry Trade Union Environmental Groups Members of the Public Nuclear Industry Employees Local Government Overseas Government Japanese Utilities & members of the Japanese public Other (which included Regulators, Advisory Bodies, Consultants &, Academic
Institutions )
302 respondents agreed with all or most of the findings of the NAC study and were in favour of allowing substitution, 13 were not in favour, and 10 expressed other views. A number of responses from the same organisation offering similar views were received. Respondents were asked for their views on the following areas: Whether the Integrated Toxic Potential (ITP) methodology referred to in the study is the best available means of assessing equivalence for the purpose of substitution, or whether there is some better means available;
The assessment of the environmental consequences for the UK; The benefits ascribed to the need for fewer shipments; opportunity for earlier waste return; and significant new income for the UK; Any other points not addressed in the NAC International study that they consider to be relevant to the decision on the future waste substitution policy.
A summary of the responses from the various groups are as follows: Group: MEPs All respondents were in favour of allowing substitution. All agreed with the conclusions of the NAC study that substitution would result in improved security due to fewer shipments of waste. Four agreed with the findings of the Study that there would be a negligible effect on the UK environment; there would be benefits in reduced worker and public exposure and CO2 emissions; and there would be benefits to the taxpayer from the revenue generated from substitution by funding the cleaning of the UK nuclear sites. One respondent commented that allowing substitution would stimulate debate on the current position of the accession states’ nuclear facilities and their ability to put in place the full range of handling facilities. Group: MPs Six Parliamentary Questions were asked about the Consultation. Two concerned the DTI Consultation process, one asked to whom the consultation document had been circulated; the other about the timing of receipt of the consultation document by the Vote Office and Libraries of the House of Commons and Lords. Of the remaining four, one asked about the nature of any financial arrangements between BNFL and NAC; one asked about the consultant selection process; one asked how much ILW would be stored in the UK as a result of substitution; and one asked what costs would be incurred as a result of plans for ILW substitution. Group: Nuclear Industry Responses received from this group included nine responses from UK owners (7 from the same owner, 1 ownership unspecified) and six from European owners (1 Swiss, I Italian and 4 German) and Nuclear Industry Trade and Advisory Bodies (5) All but one of the respondents were in favour of allowing substitution citing the benefits outlined in the NAC study. The remaining respondent favoured deferring the decision and suggested that Government should undertake a second consultation to assess the socio/ethical impacts of substitution; local communities had been consulted; countries affected by shipments of the waste overseas had been consulted. They also felt that substitution should be considered as part of an overall strategy for long-term waste management.
Group: Trade Unions Both respondents were in favour of allowing substitution. They also commented that the NDA could use the revenue to: build a purpose built repository for UK waste; accelerate clean up of other redundant nuclear facilities build a new non – CO2 generating nuclear power station Group: Environmental Groups Four of the seven respondents in this group were not in favour of allowing substitution for a wide variety of reasons. One suggested that all nuclear waste generation and imports should cease. Another endorsed Option 2 set out in the Regulatory Impact Assessment – Return all the conditioned ILW as generated as in current contracts. This would avoid any risks on the calculation of equivalence. Although substitution is aimed at reducing the number of shipments, one organisation felt that substitution would ultimately lead to an increase in nuclear transportation and the accompanying accident and security risks. Another highlighted the negative impact on local inward investment together with the implication from the transport calculations in the Study that the area adjacent to Sellafield is the area that is more than likely to be the site favoured for any proposed underground repository which would result in visual intrusion into the local landscape and the National Park. Two respondents in this group provided a nil response and one other felt that due to a number of uncertainties surrounding the environmental impact and the lack of ILW disposal facilities it was not possible to take a decision now. Group: Members of the Public: 112 respondents were in favour of substitution. Most responses were comprehensive and addressed all the areas respondents were requested to consider. Some commented on only some of those areas. Four respondents were not in favour of substitution. Amongst those responses one invited the DTI to conduct a further consultation that included financial information about the number of journeys involved in waste substitution and the immediate return to the customer of un-reprocessed spent fuel. Another asserted that international opinion is far more opposed to nuclear activities and shipments than the study allows. One felt that no change was needed to the current policy. One was neither for nor against and suggested that the UK should permanently store all waste for a price thus securing a number of jobs in the area and a safe and secure long-term disposal route for the future. The respondent emphasised that the concern should be how radioactive waste is stored, not where.
Group: Nuclear Industry Employees All respondents in this group were in favour of allowing substitution. Group: Local Government Eight responses were received from representatives from local authorities and representative bodies. They included a response which was also supported by a specialist local authority group which concluded that a number of issues were inadequately explained, including why a decision has to be made in advance of CoRWM’s (Committee on Radioactive Waste Management) findings. They felt that agreeing to substitution for BNFL’s current contracts would set a strong precedent and may influence future contract arrangements. Three local authorities not in favour of allowing substitution were concerned that the additional ILW to be stored at Sellafied would further add to the incremental storage of waste imported from outside the county and would increase the environmental and security risks without significant economic benefit. Another thought that it would have a detrimental effect on the image of Copeland and thus have negative impacts for potential investment to the area. Two local authorities questioned the assertion that no suitable alternative to the Integrated Toxic Potential Methodology (ITP) was available and one believed that there needed to be a fully informed public debate on the future of reprocessing wastes before any decisions can be made about the UK’s nuclear waste management policy. Whilst not in favour of allowing substitution, one welcomed the consultation and recognised that there were benefits to be derived from substitution. One authority was in favour in principle of allowing substitution. Three provided a nil return or no comments response to the consultation. However, one commented that it was difficult to comment on the document in its entirety and that for ease of completion, it would have been easier if the consultation document had been broken down into sections with specific questions for each section. Overseas Government One organisation was in favour of allowing substitution and felt that it was a very positive initiative that gives clear advantages in terms of security and economic savings that were well supported with a coherent analysis. The other organisation felt that the decision to allow substitution should be deferred pending the outcome of further considerations about possible alternatives to ITP; the economic implications of substitution; and security issues and international relations. Group: Japanese Respondents This group included responses from the major Japanese Utilities and members of the public. All respondents were in favour of allowing ILW substitution. Most responses were comprehensive and addressed all the
areas respondents were requested to consider. Some commented on only some of those areas. Group: Other Academic Institutions Both respondents were in favour of allowing substitution. One commented that the NAC study was thorough wide ranging and clear. One broadly agreed with the conclusions of the NAC study and also considered the benefits outweighed any risks of environmental damage associated with any accident associated with shipment of HLW - a risk they judged to be extremely small. The other respondent although in favour of allowing substitution believed that agreement to build an ILW repository should be made at the same time as ILW authorisation (the NAC Study timing scenario for a repository –was 2025); and that the cost of the impact of over regulation with respect to environmental impact targets should be reviewed. Independent Consultants Five respondents were in favour of allowing substitution. One of the respondents highlighted the need to consider substitution in relation to sustainable development objectives. Regulators/Advisory Bodies All respondents were broadly in favour of allowing substitution. One felt that the ITP approach should be used with caution. One felt that the ITP approach provided in the paper was insufficiently detailed to enable an evaluation to be made of its adequacy in this regards. NEXT STEPS The DTI is grateful to all respondents for responding to the consultation. Copies of the responses, except where confidentiality was requested, are available for viewing in the DTI library at 1 Victoria Street, London SW1H 0ET. Please call the Open Government Unit on 020 7215 6618 to arrange a viewing. The Department is carefully analysing all of the responses. When that analysis has been completed and following further consultation within Government an announcement will be made. Updates will be posted on the DTI website at www.dti.gov.uk. Nuclear and Coal Liabilities Unit June 2004