Consultation on the Detailed Statement of Policy of Scotland's Higher Activity Radioactive Waste Policy and the Strategic Environmental Assessment Environmental Report
1.01 The Scottish Government conducted a public consultation on its draft Detailed Statement of Policy ( DSP) for Scotland's Higher Activity Radioactive Waste ( Ref 1) and the Environmental Report ( ER) ( Ref 2) on the Strategic Environmental Assessment ( SEA) of the Policy. These documents were published on 15 January 2010 along with a Supplementary Information ( SI) document ( Ref 3) providing additional factual information to assist consultees.
1.02 Responses were requested by 9 April 2010, however the internal approval processes of some respondents meant that they were unable to submit their responses by that date. We were advised of this before the deadline and, in those circumstances, agreed to accept late responses. The last response was received on 26 May 2010.
Consultation on the Annex to the Strategic Environmental Assessment Environmental Report: Supplementary Assessment of Policy Alternatives
1.03 In response to comments received on the DSP and ER published on 15 January 2010 a Supplementary Environmental Assessment was undertaken. The Supplementary Environmental Assessment was published for public consultation on 9 September 2010, inviting responses by 21 October 2010 ( Ref 4).
1.04 During the initial January to April 2010 consultation period meetings were held with a wide range of stakeholders at locations around Scotland. Following the initial analysis of responses, further meetings were held between September and November 2010 with stakeholders, including organisations and individuals who responded to the consultation. These meetings provided feedback on the initial analysis of, and outlined the proposed Scottish Government response to, the comments received.
Scottish Government Policy Statement: Response to Comments from the Consultation Processes
1.05 The Scottish Government Policy Statement for higher activity radioactive waste arising in Scotland has been informed by the responses to the consultations on the DSP and ER including the Supplementary Environmental Assessment. These are reflected particularly in the Scottish Government Policy Statement in Section 2 of this document. The structure of the Policy Statement now differs from that proposed in the DSP to describe more clearly the long-term management options for the waste. Section 3, which outlines the Implementation Strategy ( IS) for the Policy, also reflects comments received and the content of the Post-Adoption Strategic Environmental Assessment Statement ( PAS).
1.06 The Policy Statement draws more heavily on the "Near-surface Disposal Facilities on Land for Solid Radioactive Wastes - Guidance on Requirements for Authorisation - February 2009" ( GRA) ( Ref 5) than in the DSP. The GRA was specifically referred to in a number of the responses to the DSP.
1.07 The Scottish Government Policy also reflects the 2006 report from the Committee on Radioactive Waste Management ( CoRWM), "Managing our Radioactive Waste Safely, CoRWM's recommendations to Government". ( Ref 6) In particular, recommendation 8 in the report which recommended that consideration should be given to other management options for reactor decommissioning wastes. Such wastes represent a significant volume of the waste produced in Scotland.
1.08 In addition to this document, the Scottish Government is also publishing separately:
- a document summarising its analysis of the responses to the DSP Consultation and the Scottish Government response to them; ( Ref 7) and
- a Post-Adoption Strategic Environmental Assessment Statement. ( Ref 8)
1.09 The Post-Adoption Strategic Environmental Assessment Statement reaffirms the Scottish Government position that it does not support deep geological disposal of radioactive waste as it does not consider it to be a "reasonable alternative" at this point in time. The Scottish Government Policy remains that the long-term management of higher activity radioactive waste, as defined in Section 2, should be in near-surface facilities.
1.10 A number of respondents sought additional information and clarification on issues raised in the DSP and ER, some of which were already addressed in part in the SI document. In response to those requests the Scottish Government has now prepared separate documents drawing on information in the DSP, ER and SI, supplemented and updated by additional information received since those documents were published in January 2010.
1.11 These additional documents ( Ref 9) cover:
- Radiation and Radioactivity
- Higher Activity Radioactive Waste in Scotland
- Legislative and Regulatory Framework for the Management of Radioactive Waste
- Treatment Options for Radioactive Waste
- International Examples of Near-Surface Facilities
- Retrievability and Reversibility
- Glossary of Terms
1.12 These documents illustrate that the Scottish Government Policy reflects existing practice in other countries, in some cases near-surface facilities have been operating for many years. They will be published separately on the Scottish Government website. The intention is that they will be individual documents which can be revised and updated more easily. This will enable them to reflect more timely any changes in facts or technological advances to inform the next stages of this process, particularly the Implementation Strategy outlined in Section 3.
Scottish Government Policy Statement and Implementation Strategy
1.13Section 2 of this document is the Scottish Government Policy Statement for higher activity radioactive waste arising in Scotland. The waste to which the Policy applies is defined in Section 2 as are those materials such as spent nuclear fuel which are specifically excluded from the Policy.
1.14 This is a high level Policy which provides the framework for the long-term management of the waste. The Policy is not prescriptive in its approach, recognising that it applies to waste:
- which may not be produced for decades; and
- for which long-term management options may not be feasible at present or have yet to be developed.
1.15 The Policy provides the framework within which regulators, facility operators, waste producers and owners and the Nuclear Decommissioning Authority ( NDA) will take decisions on the long-term management of the waste and undertake the work, and duties, for which they are responsible. The Policy enables options to be considered which may require research or development, recognising that advances may be made over time to manage wastes for which long-term options are not currently feasible.
1.16 The Policy is explicit that all options for the long-term management of the waste will be subject to robust regulatory scrutiny and cannot be undertaken without approval by the relevant regulatory bodies.
1.17 The Policy requires all long-term management options to be assessed taking account of fundamental principles, including the application of the Waste Hierarchy ( Ref 10) and the Proximity Principle ( Ref 11). The presumption is that options will be undertaken as close to the sites where the waste is produced as is practicable.
1.18Section 3 of this document reflects comments on the DSP and ER on the need to explain in more detail how the Policy will be implemented. The section outlines the process for the Implementation Strategy which will be subject to a Strategic Environmental Assessment and public consultation before it is adopted. Development of the Strategy will be led by the Scottish Government.
Scottish Government Policy
1.19 The Scottish Government Policy is that the long-term management of higher activity radioactive waste, as defined in Section 2, should be in near-surface facilities. Facilities should be located as near to the site where the waste is produced as possible. Developers will need to demonstrate how the facilities will be monitored and how waste packages, or waste, could be retrieved. All long-term waste management options will be subject to robust regulatory requirements.
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