Scottish government higher activity waste (HAW) policy

The Committee on Radioactive Waste Management (CoRWM) produced its recommendations to the UK government and devolved administrations on the long-term management of HAW in November 2006 (CoRWM, 2006).

At that time, as a sponsor of CoRWM, the Scottish government was content with CoRWM’s recommendations. The main recommendation was that geological disposal was the best available approach for the long-term man­agement of HAW. One of the qualifying conditions was the need for robust interim storage until geological disposal could be implemented, which could take up to 40 years.

The Scottish government, however, changed its view in June 2007 when Richard Lochhead, Cabinet Secretary for Rural Affairs and the Environ­ment, announced that the Scottish government ’s policy for the long-term management of HAW was to support long-term, near-surface, near-site storage so that waste is monitorable and retrievable and the need for trans­porting the waste is minimal (Scottish Government, 2010a).

Consequently, the framework for implementing geological disposal, Man­aging Radioactive Waste Safely (MRWS), published as a White Paper in June 2008 (UK Government, 2008) was not sponsored by the Scottish gov­ernment. The White Paper noted that the Scottish government supported long-term interim storage and a programme of research and development.

Thereafter, the Scottish government embarked on a process (CoRWM, 2011) to develop a more detailed statement of its own HAW policy which included significant stakeholder engagement. From January to May 2010 the Scottish government consulted with the public and stakeholders on a draft Detailed Statement of Policy for Scotland’s HAW (Scottish Govern­ment, 2010a) and supporting documents which comprised a Supplementary Information report (Scottish Government, 2010b) and an Environmental report (Scottish Government, 2010c).

The Scottish government published its Policy (2011a), Summary of Com­ments (2011b) and Post Adoption Strategic Environmental Assessment Statement (2011c) on 20 January 2011. An additional seven reports pro­vided supporting information.

The policy sets out in detail the Scottish government’s position on a wide range of HAW issues. In summary the key points are: [29]

• When disposal is employed, the facilities should be near surface (no more than a few tens of metres below surface) and near to the site where the HAW is generated.

• Disposed HAW must be able to be monitored and retrievable.

• The policy will be reviewed every ten years to assess whether technolo­gies have developed sufficiently to warrant a change to the policy.

The policy for HAW in Scotland now differs from the rest of the UK. The Scottish government has rejected at present the concept of deep geological disposal for HAW that cannot be disposed of in near-surface facilities. The Scottish government is not taking part in the MRWS process to identify a site for, and develop, a geological disposal facility (GDF). The policy does not contain the concept of volunteerism by communities for HAW facilities which is fundamental in the MRWS process.

Operators with HAW at facilities in Scotland which is unsuitable for near-surface disposal and who previously had planned for disposal of that HAW in the projected UK GDF now need to plan for new stores and longer storage periods in the absence of an identifiable final end-point.

The generally accepted understanding of disposal is that there is no inten­tion to retrieve the waste. In practice, this means specific retrieval features are not included in the disposal facility design. Also monitoring is applied to the surrounding environment rather than the waste itself. In the Scottish context, while there may be no intention to retrieve, the policy requires that HAW in near-surface facilities must be able to be monitored and retriev­able. This introduces additional requirements for designers and operators of Scottish HAW disposal facilities for monitoring of the waste itself in the facility and for including features to enable retrieval of the waste.

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