3 Scottish Government Policy Implementation Strategy and Strategic Environmental Assessment
3.02 Strategy Process
3.03 Strategy Content
3.01.01 The Scottish Government Policy for the long-term management of higher -activity radioactive waste is stated in Section 2 of this document. Responses to the consultation on the draft Detailed Statement of Policy ( DSP) ( Ref 1) and the Environmental Report ( ER) ( Ref 2) on its Strategic Environmental Assessment ( SEA) heavily endorsed the Scottish Government proposal that a Strategy would be required to implement the Policy should be subject to a SEA.
3.01.02 This Section outlines the Scottish Government proposals for the Implementation Strategy ( IS) and its SEA. These reflect particularly, the Next Steps proposed in the Post-Adoption Strategic Environmental Assessment Statement ( PAS) ( Ref 4). These initial proposals are not exhaustive. They reflect the position at the present time and, as was the case in developing the Policy Statement in Section 2, it is likely that they will be adapted and revised to take account of changing circumstances as the IS is developed.
3.01.03 The Scottish Government will lead the process to develop the IS and its SEA. In doing so the Scottish Government will continue to engage with stakeholders whose input to the development of the Policy Statement has been invaluable.
3.01.04 The Scottish Government has adopted a stepwise approach to the development of the Policy Statement and this will continue in the IS stage. Figure 3 illustrates the overall process to develop and implement the Policy for the long-term management of the waste.
3.01.05 The first stage, development of the Policy Statement, was undertaken between 2007 and 2010. It is not the intention at this point in time to define a specific date to complete the second stage, the development of a Strategy. The process to develop the IS will require detailed planning and it will be at that point that milestones will be set.
Figure 3: Decision Making and Environmental Assessment of Policy Development and Implementation
3.02 Strategy Process
3.02.01 The Scottish Government will continue its stepwise approach in future stages of the process as described in Figure 3. The process will be informed by the Policy Statement and the PAS as well as by comments received in response to the consultation on the DSP and ER. It is clear that more detailed information will be needed to inform the IS and its SEA as indicated in the following paragraphs.
Managing the Process and Engaging with Stakeholders
3.02.02 The IS process will be led by the Scottish Government and will involve engagement with stakeholders in the same manner as the development of the draft DSP and its ER. Ongoing engagement with stakeholders will be needed as the IS and its SEA are developed and there will be a formal public consultation on the draft IS and its SEA. In line with a stepwise approach, it is not intended that every aspect of the IS and its SEA will be prescribed now. This Section outlines the initial approach which will need to be reviewed and adjusted as appropriate to reflect circumstances and the different stages of the work.
3.02.03 The Scottish Government will adopt a project management approach with a Project Board and associated supporting working groups. The Project Board will be chaired by the Scottish Government and will initially comprise representatives of the Scottish Government, Regulators (environment, health, safety, security and transport), local authorities in Scotland and the Nuclear Decommissioning Authority ( NDA). The Project Board will have terms of reference which will be published on the Scottish Government website as will agendas, papers and minutes of meetings. Membership and terms of reference may be reviewed and adjusted, if necessary.
3.02.04 The Project Board will be able to set up associated supporting working groups to inform and assist in the development of the IS and its SEA. The membership of these groups will be dependant on the topics they will be considering and will be similar, but not restricted to, that of the Project Board: representatives of the Scottish Government, Regulators, local authorities in Scotland and the NDA. In light of previous experience, we would expect such supporting groups to include representatives of site operating companies, local stakeholders, including members of Site Stakeholder Groups ( SSGs), the Committee on Radioactive Waste Management ( CoRWM) and non-governmental organisations.
3.02.05 Supporting groups will have their own terms of reference which will be published on the Scottish Government website as will agendas, papers and minutes of meetings. They may reflect the initial issues to be addressed as described below and, as with the Project Board, membership and terms of reference may be reviewed and adjusted, if necessary.
3.02.06 The Policy clearly states the principles which underpin it. These principles will need to be addressed in the IS and its SEA and will need in turn to be underpinned by information and evidence to support the IS. Section 5 of the PAS addresses environmental assessment issues to be considered in the next stage. These are issues which have been identified now. They are not restrictive as it is likely that others will be identified as the IS and its SEA are developed. It is also worth reiterating here that in all circumstances the IS and SEA will reflect regulatory principles applicable at the time decisions are taken.
3.03 Strategy Content
3.03.01 Section 3.02 above describes the process to manage the development of the IS and its SEA. This section addresses the content of the IS and its SEA. Adopting a stepwise approach means that the content is not restricted to the issues identified in this document or the PAS. They are the initial considerations which will be reviewed and revised as necessary as information and evidence are obtained and analysed. This will involve testing the environmental consequences of the IS and identifying mitigation measures that can be put in place to ensure that implementation of the Policy avoids generating unexpected or significant negative environmental effects as far as possible.
3.03.02 The information gathered during the SEA of the Policy will form a starting point for the IS and its SEA. The key issues which should be addressed in the initial work on the next stage are:
- Knowledge and Information Management
- Legislation, Regulation and Guidance
- Waste Identification, Treatment and Packaging
- Location, Design and Construction of Treatment or Storage or Disposal Facilities
- Social and Economic Costs and Benefits
- Best Practice and Experience in the UK and Internationally
Knowledge and Information Management: Baseline Assessments, Monitoring and Long-Term Maintenance
3.03.03 The Policy Statement and PAS are clear and consistent that more information is needed for the IS and its SEA. These will form a basis for determining the baseline information for the IS and its SEA.
3.03.04 There is also a clear need for information and knowledge to be maintained in the long-term to manage the waste. There will be a need for information on specific issues and a more general need to consider how information and knowledge should be maintained so that it is accessible now and to future generations. Intergenerational equity will be a key consideration for the IS along with the following issues:
- what research and development may be needed to deliver the IS;
- how new innovations and technology will be considered to inform future decisions;
- how skills and experience can be maintained over long timescales; and
- how best practice and experience elsewhere in the World is considered.
3.03.05 This approach will ensure that environmental impact is minimised and linked with the cost implications of the Policy as well as informing monitoring requirements. A baseline is required for monitoring to allow for future assessments to clearly identify the impact of any future facility (or facilities) and its (or their) performance in relation to authorised radioactive discharge limits. Monitoring of non-radiological matters may also be required. The IS and its SEA will develop further information which can be used to inform the development of a baseline. Further site specific baseline evidence will be required to be gathered at the later project stage through Environmental Impact Assessment ( EIA).
3.03.06 Monitoring should set thresholds for specific contaminants, which trigger action if they are exceeded. As required by the "Near-surface Disposal Facilities on Land for Solid Radioactive Wastes - Guidance on Requirements for Authorisation - February 2009" ( GRA) ( Ref 5), published jointly by the environmental regulators in the UK, in the interests of avoiding placing an unreasonable emphasis on current or long-term future action, the safety of any future facility should not be reliant on post-authorisation period monitoring. The IS and project level assessments will confirm the detailed monitoring requirements. In line with respondent's comments, future monitoring should be delivered in an open and participative manner, involving stakeholders and communities.
Legislation, Regulation and Guidance
3.03.07 National, UK and international legislation, regulations and guidance are required to be followed at all times in the IS and in any subsequent project for the development of, or siting of, facilities. This will include the application of the concepts of Best Practicable Environmental Option ( BPEO), Best Practicable Means ( BPM) and Best Available Technology ( BAT) to underpin the development of the IS and to steer consideration of options within its SEA. Other concepts including As Low as Reasonably Practicable ( ALARP) and As Low as Reasonably Achievable ( ALARA) will also form an integral part of decision making. The GRA is a particularly relevant document at this time.
Waste Identification, Treatment and Packaging
3.03.08 Further work is needed to define the waste to be managed in the long-term in terms of radionuclides and type (for example, graphite, metal etc) as well as by volume. This will lead to an exploration of the scope for treatment to reduce the volume of the waste, to help reduce the scale and therefore potentially the effects of facilities. Ongoing and future research on treatment options will need to be reviewed as a part of the development of the IS, as will the options for packaging, including packaging for transport.
Location, Design and Construction of Treatment or Storage or Disposal Facilities
3.03.09 The IS should systematically and transparently explore spatial options and consider the types of facilities required in relation to the waste. Where feasible and to maximise the positive environmental effects of the IS, opportunities for the reuse of brownfield, derelict or contaminated land should be prioritised.
3.03.10 Where all other considerations are equal, the Proximity Principle should be applied to define the location of facilities in order to minimise potential risk and reduce any potential environmental impacts. This should not outweigh other considerations including safety, technical feasibility of specific locations and ability of communities and environments to accommodate developments without experiencing significant negative effects.
3.03.11 Consideration of transport optimisation will take into account any movement of the waste required for treatment, possibility of waste movements between sites, and movement required for emplacement of the waste within any future facility.
3.03.12 The design of treatment or storage or disposal facilities will need to identify clearly how monitoring will be undertaken. Similarly they will need to clearly demonstrate how waste packages and waste can be retrieved from storage or disposal facilities.
3.03.13 Good practice will be used during any construction, to avoid or minimise impacts on population and human health, soil, water, air and biodiversity. The IS will begin to explore the scope for this in order to establish the extent to which mitigation will be available for effects arising at a project level. This process will be taken forward in more detail at the Stage 3 project level and finalised through an Environmental Impact Assessment ( EIA).
Social and Economic Costs and Benefits
3.03.14 A fuller social and economic assessment of the options will be required, in addition to a SEA of the IS. The Scottish Government, through its Project Board, will give further consideration to how this is best achieved, either through a distinct workstream, or amalgamated into a comprehensive sustainability appraisal as part of the SEA.
3.03.15 Close liaison with communities who could be affected by any facilities or the transportation of waste will be required at all subsequent stages in the planning and development process and into the long-term as management responsibility passes to future generations. Intergenerational equity will be a key issue in this area.
Best Practice and Experience in the UK and Internationally
3.03.16 The Policy Statement and PAS have taken account of experience elsewhere, notably the Scottish Government's direct involvement in the Organisation for Economic Cooperation and Development work on retrievability and stakeholder engagement for the long-term management of radioactive waste. This will continue into the next stages of the IS where further work will be undertaken to establish and make use of international experiences in planning and developing near-surface facilities. These international examples are also at different stages of development and there will be an ongoing need to maintain up to date information on them and to learn from the experience of those involved in the programmes.
3.04.01 There will be an Implementation Strategy ( IS) which will be subject to a Strategic Environmental Assessment ( SEA). The IS and SEA will be led by the Scottish Government and will based on a stepwise approach engaging with stakeholders in the development of the Strategy and the SEA. The process will be undertaken on a project management basis.
3.04.02 The content of the Strategy and SEA will be informed by the Policy Statement and the Post-Adoption Strategic Environmental Assessment Statement as outlined in Section 3 of this document.
3.04.03 The draft IS and its SEA will be subject to public consultation.
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