The Committee on Radioactive Waste Management welcomes the
Nuclear Regulatory Task Force report, Nuclear Regulatory Review
2025. It provides a very helpful and comprehensive account of
the current state of regulation of nuclear and radioactive
materials and highlights some important obstacles to new nuclear
projects and the decommissioning of existing installations. We
particularly welcome its recommendations in the areas in respect
of which CoRWM advises
and, as a result, feel no need to make any extensive comments.
However, there are some issues that we want to briefly note to
avoid any possible misunderstandings.
General issues
To begin with, the following:
Paragraph 157 et seq. The Committee would advise
caution concerning the use of international comparisons of
Commission-based models. There are undoubtedly lessons to be
learnt but some of these are negative. The UK needs to be
particularly careful that a revised regulatory approach does not
starve operations of resources, leaving them as a poor relation
to design and construction.
Recommendation 4. The Committee would also
counsel a degree of caution in the matter of a single regulatory
authority, for waste disposal specifically.
Both ONR and
the Environment Agency have complementary expertise and
from CoRWM's
experience are working closely and effectively together on
Geological Disposal Facility proposals and other radioactive
waste matters.
Generally, the Committee's perception is that
the Report could have emphasised the importance of addressing
back-end issues in new build, to avoid creating huge financial
and technical challenges for future generations. In particular,
the Committee would stress the need for extensive research to
address the risks and disposability of waste streams from novel
reactor types.
Issues specifically pertaining to the role
of CoRWM
The Committee noted the presence of some inconsistencies in the
discussions of CoRWM's work
and most notably:
Paragraph 448. ‘CoRWM is
currently undertaking further work in the consideration of
alternatives to a geological disposal facility' might seem to
imply that there is an option for meaningful disposal which does
not require a Geological Disposal Facility. Rather the committee
is considering options that will minimise the amount and type of
waste that might have to go into such a facility. There is
always going to be an inventory for which deep geological
disposal in stable formations is the only option.
Paragraph 451. ‘CoRWM told
the Taskforce that they strongly consider the need for
a DCO for the boreholes to
be disproportionate'. We would want to avoid possible confusion
here. In respect of access to land and shallow boreholes for
preliminary investigations we would agree that a case can be made
that planning permission may not be necessary. However, for
deep investigative boreholes, (which could be either onshore or
offshore) a DCO or planning
permission will, in CoRWM's view,
be necessary, as these are substantial and probably controversial
engineering works. The DCO route is likely to be
preferable to the delays inherent in the normal planning system,
which may be highly politically contentious. It can also retain
the benefits of the extensive public engagement and participation
requirements that characterise the DCO system.
