Scottish Government

Environmental Report: Non Technical Summary

In June 2007 the Scottish Government announced that its policy for the long-term management of higher activity radioactive wastes (the Waste) arising in Scotland is to:

Support long-term near surface, near site storage facilities so that the Waste is monitorable and retrievable and the need for transporting it over long distances is minimal.

In order to establish the implementation of this policy, a Detailed Statement of Policy has been produced. In accordance with the Environmental Assessment (Scotland) Act 2005, the Scottish Government is undertaking a Strategic Environmental Assessment ( SEA) of this Detailed Statement of Policy on higher activity radioactive waste.

What is Strategic Environmental Assessment ( SEA)?

SEA integrates environmental considerations into the development of the Policy. It predicts the potential significant environmental effects of a plan or policy and identifies how environmental damage can be avoided or reduced by suggesting how it can be changed. It also allows the public to give their view on the plan and its potential environmental impacts.

The process of SEA begins with screening. This determines whether a full assessment is or is not required, based on an assessment of whether the plan or policy is likely to have a significant environmental effect. Where this is established, the next stage is scoping, when the proposed assessment and consultation methods are considered. Scoping identifies the relevant aspects of the environment to be considered further in the SEA and the environmental problems which need to be taken into account when developing the plan or policy. At this stage, the statutory Consultation Authorities: Scottish Natural Heritage ( SNH), the Scottish Environment Protection Agency ( SEPA) and Historic Scotland ( HS) comment.

These comments are taken into account in the subsequent assessment and preparation of the Environmental Report ( ER). The ER documents the findings from the environmental assessment, and is published for consultation to allow the public the opportunity to comment on both the ER and Detailed Statement of Policy. The ER also explains how environmental considerations have been integrated into the Policy. Once this stage is complete, the Policy will be revised and adopted and a post-adoption SEA Statement is subsequently published.

Higher Activity Radioactive Waste in Scotland

Radioactive waste is categorised in accordance with the level of radioactivity which it contains. The UK has accumulated a substantial volume of radioactive material from various civil and defence programmes. Scotland has approximately 10% of low level waste ( LLW) and intermediate level waste ( ILW) in the UK, and no high level waste. Higher activity radioactive waste (the Waste) for the purposes of the Policy is defined as radioactive waste which falls within the current category of Intermediate Level Waste ( ILW) and certain Low Level Waste ( LLW), which by their nature are not currently suitable for disposal in existing LLW facilities. This has radioactivity levels exceeding the upper boundaries for low level waste ( LLW) but does not generate enough heat for heat generation to need to be taken into account in the design of storage or disposal facilities (as would be the case for HLW). The Policy does not cover spent nuclear fuel, plutonium and highly enriched uranium.

Scotland's Higher Activity Radioactive Waste Policy

As explained in more detail in Chapters 1 and 3 of the Consultation Document, since the 2007 announcement further consultation has been undertaken which has led to the conclusion that it is feasible to broaden the Policy to allow disposal as well as storage of the Waste, where this is feasible and appropriate in near surface facilities. The Scottish Government Policy is now therefore to:

Support long-term near surface, near site storage or disposal facilities so that the Waste is monitorable and retrievable and the need for transporting it over long distances is minimal.

In summary, the policy:

Allows:

• the storage or disposal of the Waste in facilities constructed:
• on the surface or;
• near to the surface to depths of several tens of meters.
• The storage or disposal of the Waste in facilities located:
• on existing nuclear sites or;
• near existing nuclear sites; and
• the treatment of the Waste including sending it elsewhere for treatment, subject to any requirements by the relevant regulators in the UK and overseas for the return of the Waste.

Requires:

• arrangements, including replacement or refurbishment of storage facilities, for safe and secure storage for at least 100 years, with the capability of extension beyond 100 years if necessary;
• disposal facilities to meet the requirements set by the appropriate regulators, including consideration of a period of 300 years for institutional control;
• storage and disposal facilities to be subject to monitoring as required by regulators;
• the Waste to be retrievable based on regulatory requirements;
• the location of facilities to be determined by application of the Proximity Principle;
• the need to transport the Waste over long distances is minimal; and
• the development of a Strategy to implement the Policy.

SEA of Scotland's Higher Activity Radioactive Waste Policy

There are a number of key components which together form the basis for the policy, and therefore a focus for the environmental assessment:

1) the coverage of both storage and disposal of the Waste in the Policy, and allowing treatment of Waste to facilitate storage or disposal.

2) the requirement for facilities to be near surface and the requirement to consider the retrievability of the Waste;

3) the requirement for facilities to be on or near sites, together with the application of the Proximity Principle and transport optimisation in defining the location of facilities;

These three key components, and available alternatives to them, represent the key choices which have been made during the process of determining the Policy. The SEA has therefore focused on these key components, and explored reasonable alternatives to each of them, in order to provide a clear picture of the environmental effects of the preferred approach and other available options. In short, by focusing on these components, the SEA has explored the following questions:

• What facilities and activities does the Policy support?
• How will they be constructed?
• Where could they be sited?

The high level Ministerial commitment to near site, near surface facilities means that other alternatives which might otherwise have been considered, are not viewed as 'reasonable' by the Scottish Government at this stage. The most important of these is the overall alternative of allowing waste to be disposed of in deep geological facilities. Whilst this is supported by the rest of the UK, Scottish Ministers do not consider it to be an appropriate approach within the Scottish context. This alternative does not therefore form part of the assessment.

It is important to recognise that this policy topic involves consideration of impacts over much longer timescales than most other Scottish Government Activities. Many of the environmental effects discussed in this report will, by their very nature, be extremely long-term and have associated uncertainties due to that very long time frame.

The Key Findings of the SEA

The assessment highlighted the following key findings:

1. Storage, Disposal and Treatment

Within the context of a commitment to near site, near surface facilities, the Policy allows for both storage and disposal of higher activity radioactive waste.

Storage is defined as placing the Waste in a facility with the intention that it will be retrieved at a later date. Disposal implies that there is no intent to retrieve it later, although this may nevertheless be possible. There are different views on whether radioactive waste can be disposed of, as it can take a very long time for waste to decay to a state where it is no longer hazardous. However, taking into account the types of material which require to be managed in Scotland, there may be opportunities to safely dispose of some types of Waste in near surface facilities.

The SEA has also considered the environmental implications of different forms of treatment required for storage and disposal. Treatment could reduce the volume of Waste or allow certain types of material to be recovered and reused. However, some types of treatment that are required to stabilise materials prior to their storage, can increase their volume significantly.

Taking this into account, no significant effects are expected from the decision within the Policy to allow disposal as well as storage, as appropriate for the materials concerned. It is expected that key environmental hazards, including radiological exposure, would be avoided or mitigated to acceptable levels as appropriate. The treatment processes could result in the production of secondary wastes, both radioactive and non-radioactive, and are therefore closely regulated. Any impacts arising from treatment would be subjected to site level controls, monitoring and enforcement. As the Policy does not specifically propose that treatment facilities are developed, these effects should be regarded as secondary effects at this stage in the process. Allowing the Waste to be transported to facilitate treatment, and for materials to be returned following treatment, is also not considered to present a significant risk of radioactive exposure for the population or the environment, given the strict controls which are in place to regulate the transportation of radioactive waste.

The key reasonable alternative to allowing both storage and disposal of the Waste that was considered during the development of the Policy is the option of only allowing storage and indicating a presumption against disposal generally. Research has suggested that storage infers a greater and unacceptable burden on future generations (as compared to disposal), and that it carries additional security and health risks. As a result, where disposal in near surface facilities is feasible, the Scottish Government considers it to be a preferred alternative at this stage. As this cannot be achieved for all types of Waste, storage options have also been included within the Policy.

2. Near Surface Facilities and the Concept of Retrievability

The Policy states that facilities for both storage and disposal should be near surface. This means that facilities could be located on the surface, or at depths down to several tens of metres below the surface. Disposal facilities may use geological or engineered barriers, and could either be newly constructed or accommodated within existing structures where an acceptable safety case can be made. This could result in a range of different types of facility being built, including:

• A fabricated facility / building above ground;
• Reuse of an existing underground opening;
• Creation of a new underground opening;
• Use of a partially or wholly above ground existing facility ( e.g. capped quarry);
• Facilities under the seabed which are accessible from the land.

By definition near surface storage is reversible as the Waste will need to be removed from a store at some time in the future. The Policy also discusses the requirement for retrievability from disposal facilities to be considered in the design and management plans for disposal facilities. This means that if at any time retrieval of the Waste is needed ( e.g. for technical or environmental reasons), stakeholders have been made aware of the relative difficulties of retrieval in the event of a commitment having been made to disposal.

Regardless of the depth and more detailed specification of the facility, strict regulation, monitoring and long-term security measures will be required to mitigate any potential effects on health and the general well being of the population and the environment. Stored waste potentially also implies a burden for future generations. As a rule, waste which is more readily retrievable requires much greater security, monitoring and management, and waste which is more difficult to retrieve has the potential to require less active management over the long-term.

However, the risk of exposure to very long-term radiological hazards could be reduced by facilities being located near the surface, as the Waste could be more easily managed and retrieved. Whilst this would infer responsibility to future generations, it would also limit the risk of long-term or very long-term leakage of radioactive or other contaminants which could increase as barriers to disposed Waste which is not actively managed or readily accessible become eroded. In addition, storing Waste in the relatively accessible and flexible near surface facilities, could provide benefits for the population by leaving open options for retrieval, reuse or further treatment for future generations.

Scottish Ministers have expressed a commitment to near surface facilities, partly in order to facilitate easier retrievability over the long-term. As noted previously, the main alternative of deep geological disposal, which would imply greater levels of difficulty in terms of retrievability, is not considered to be reasonable by Scottish Ministers at this stage.

3. Near Site Facilities, the Proximity Principle and Transport Optimisation

Near site has not been fully defined within the Policy, as this will require more detailed consideration as it is implemented. In the interests of flexibility and sustainability, it is proposed that the Proximity Principle is applied to future locational decisions, with the need to optimise the transportation of Waste being built into a detailed strategic siting strategy and assessment. Transport optimisation refers to both the need to minimise travel distance and to make best use of available sustainable transport options. There is no requirement within the Policy to store or dispose of the Waste on an existing nuclear site. The Policy allows Waste to be stored or disposed of at the sites where it is currently located, or to be moved to the nearest suitable facility, depending on decisions which will made later in the policy implementation process.

In general terms, reduced transport distances could reduce the risk of accidental leakage of the Waste during transportation, and associated risk of exposure to radiation. However, varying travel distances arising from different locations are not expected to result in significant changes to the risk of accidental exposure to radioactivity, when the safety record of the transportation of radioactive waste is taken into account. A detailed regulatory and advisory framework exists which aims to avoid any risk of exposure to radioactivity arising during transportation.

The SEA also considered further environmental effects which could arise from a presumption in favour of facilities which are constructed close to the location of the Waste. These can only be determined fully as specific locations are identified within a future strategic implementation and siting strategy. However, overall the assessment showed that the Policy provides sufficient flexibility to ensure that environmental constraints and threats relating to the sites where the Waste is located, including the coastal effects of climate change, could be avoided within the later policy implementation process.

During the development of the Policy, consideration was given to whether it would be beneficial to guide the future site selection process in a more prescriptive way. However, taking into account the likely technical complexities arising during the site selection process, and the need for different types of facility to accommodate the range of wastes which are known to exist, it was concluded that this would be inappropriate at this stage, and unlikely to provide significant environmental or other benefits from a national perspective. In terms of environmental impacts, the SEA noted that going too far towards defining the location of the facilities could increase the risks from the Policy, particularly when the vulnerability of the nuclear sites to long-term climate change impacts including sea level rise and coastal erosion are taken into account. As a result, the Policy has remained sufficiently flexible to allow the site selection process at the next stage to define the optimal solution on the basis of more detailed planning and assessment.

Key Effects, Monitoring and Mitigation

To provide a clearer understanding of the implications of the Scottish Government's Policy as a whole, the key effects of the policy as a whole are summarised in Table 1.

Table 1: Summary of the Environmental Effects of Scotland's Higher Activity Radioactive Waste Policy

Cumulative effects may arise from communities living in the vicinity of any future facilities. These cannot be fully defined at this stage as the location of the facilities remains open to debate at the next stage. There is potential for multiple effects arising from the construction of facilities, but these would be temporary and are therefore not expected to be significant when scope for mitigation is taken into account. More permanent effects during the operational phase would relate to the long term responsibility for managing facilities which is placed on future generations.

In terms of monitoring the policy requirement for facilities to have a lifespan of at least 100 years supports the timescales for this type of development which are defined within relevant regulations and guidance. More specific monitoring of the environmental effects of the facilities can be incorporated within these measures. This will be considered further as the Policy is implemented.

In terms of mitigation, radioactive waste management and associated activities are already covered by numerous international and national level commitments to environmental protection, these are discussed in further detail in Chapter 5 of the Consultation Document and Section 3 of the Supplementary Information. These aim to ensure that any discharges or emissions of radioactivity are strictly regulated and maintained within prescribed levels. Any future Waste facilities which are planned and developed on the basis of the Policy will be required to comply with this framework of regulation, which should ensure that the public and the environment are not exposed to hazards from radioactive materials during their storage, transport or disposal. The assessment findings are based on an assumption that these defined limits and controls will not be exceeded.

In addition, at the next stage in the process, where the Policy forms the foundations of a strategic implementation strategy, further consideration should be given to the need to avoid or reduce a number of potential environmental effects. Specifically:

• the possible issues arising from the coastal location of the sites where Waste is currently located should be considered further, depending on the location of the storage and disposal facilities.
• opportunities for reducing the volume of Waste should be maximised within treatment processes, to help reduce the effects of facilities on communities and the environment.
• at the project level, good practice should be used during construction to avoid or minimise impacts on population and human health, soil, water, air and biodiversity.
• where all other considerations are equal, the Proximity Principle should be applied to define the location of facilities in order to maximise social and environmental benefits. However, it should not outweigh other considerations including safety, technical feasibility of accommodating facilities at a specific location, and ability of communities to absorb developments without experiencing significant negative effects.
• close liaison with communities who could be affected by the facilities will be required at all subsequent stages in the planning and development process, and over the long-term as management responsibility passes to future generations.

Guidance for Consultees

The Scottish Government is inviting written (by post or email) responses to this consultation by Friday 9 April 2010.

Please send your response, including the Respondent Information Form to:

Radioactivewasteteam@scotland.gsi.gov.uk
Or
Scotland's Higher Activity Radioactive Waste Consultation

If you require further clarification please contact us on the email address above or on 0131 244 0199.

Please indicate in your response which questions or part of the Consultation Document, Environmental Report or Supplementary Information you are responding to as this will aid our analysis of the responses received.

The Environmental Report can be found at www.scotland.gov.uk/HAW-ER

The Consultation Document can be found at www.scotland.gov.uk/HAW-ConDoc

The Supplementary Information can be found at www.scotland.gov.uk/HAW-Sup

Next steps

The Scottish Government will subsequently finalise the Policy, taking into account views on the consultation paper and this Environmental Report. Following adoption of the Policy, an SEA Statement will be published, which sets out how the key findings from the assessment and SEA consultation have informed decisions on the finalised version of the Policy.