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NDA response to final CoRWM report
31 July 2006
The delivery of CoRWM’s final report to Government is another important step towards having clarity on the future long term solutions for radioactive waste management.
We now look forward to Government’s announcements on how it proposes to move forward on this agenda in order that momentum can be continued.
On specific areas of the report, the NDA makes the following comments:
- We welcome the recommendation of the geological disposal solution
- We reaffirm our commitment to reducing waste hazards in the earliest possible timeframe and for providing robust interim storage solutions pending disposal
- We welcome the focus on community engagement and partnership and for the concept of community packages aligned to ‘volunteerism’
The NDA welcomes CoRWM’s preference for geological disposal of waste, which aligns with our previously stated position.
We recognise the challenges of deciding at this stage the precise form of geological disposal, although our working assumption is that repository vaults would be left open through an operational phase lasting for several decades and that waste packages would remain available for examination and potentially for retrieval during this period. However, the actual approach to be used will depend on future technical and safety case developments, taking account of site-specific issues. It must also be allowed to develop in the context of stakeholder engagement processes.
We recognise that implementation of a geological disposal solution may take a number of decades. In the meantime a ‘repository availability’ date for ILW of 2040 is used in the NDA baseline plans.
Safe and secure waste management and storage
The NDA would emphasise that safety and security is at the forefront of every aspect of our activities including waste management. In this regard our objective remains to reduce hazard and ensure that all wastes are converted into passively safe forms in the earliest possible time frame and for this to be placed into robust interim storage prior to final disposal. This intent is clearly set out in our approved Strategy document and is already accounted for in our current estimates for decommissioning and clean-up. A review of interim storage options for ILW is underway in order to identify the optimum solution for safe and secure storage up to and beyond the opening of a repository.
Design and operation of waste storage facilities on NDA sites is carried out by the Site Licensees in the context of detailed regulatory approval processes covering safety, security and environmental issues. Suitability of waste packaging and storage arrangements is a key issue for NDA. We fund our Site Licensee Companies to work closely with Regulators to ensure that all regulatory requirements are met and all our site operating contractors are meeting regulatory requirements in this regard. With regards to security, OCNS has advised us that current arrangements meet stringent requirements.
NDA plans for waste storage align with CoRWM observations on the time that may be needed to implement the disposal solution. Existing NDA baseline plans and funding for ILW management at NDA sites are predicated on a 2040 date for the repository to open its doors. ILW stores at NDA sites are built typically with 50 to 100 year design lives, with well-engineered waste packages held in conditions appropriate to protect their integrity. This timespan allows for the fact that repository filling will take place over some decades, and that wastes will continue to arise after 2040. It also means that quite large variations in the date that the repository actually comes on line can be accommodated subject to addressing consequential cost and site clearance delay implications.
Whilst the NDA recognises that the default route for Reactor Decommissioning Wastes (RDW) should be geological disposal, we believe that there may be scope for alternative ways of handling some RDW streams that could lead to recycling or re-use. As an example, reactor steel with short half life activity could be held under secure institutional arrangements (such as a shallow LLW vault) until alternative treatments become available. Similarly there may be alternative treatments for reactor graphite rather than consigning the large quantities involved to geological disposal.