Current Arrangements and Requirements for the Conditioning, Packaging and Storage of Intermediate Level Radioactive Waste: Joint RWMAC/NuSAC Report

2. FORM OF THE STUDY AND REPORT

Form of the study

2.1 The task of initial data assembly and analysis was allocated to a joint working group - the Joint ILW Management Study Working Group - whose membership is set out in Annex 2.

2.2 The Joint Working Group invited written responses to appropriate sets of questions from all the organisations listed in Annex 3. It also held meetings with the main civil ILW producers ^*, the regulators and Nirex. Written responses were also invited from the main environmental Non-Governmental Organisations (NGOs), the Trades Union Congress (TUC) and four local planning authorities for major nuclear sites (Sellafield, Dounreay, the Atomic Weapons Establishment (AWE) Aldermaston and the Trawsfynydd nuclear power station site). Responses from these other bodies, where received, are listed in Annex 3.

2.3 The Joint Working Group had responsibility for analysing the responses and preparing initial drafts of the study report. These drafts, and the conclusions contained within them, were subsequently discussed and finalised through consideration by the full membership of both committees. The advice contained within this report was thereafter delivered to Ministers and to the Health and Safety Commission on 19 April 2002. The Ministers concerned were Michael Meacher, Minister for Environment in the Department of Environment, Food and Rural Affairs, Ross Finnie, Minister for Rural Development in the Scottish Executive, Sue Essex, Secretary for the Environment, National Assembly for Wales, and Brian Wilson, Minister of State for Energy in the Department of Trade and Industry.

Form of the report

2.4 The remainder of this report has the following structure. Chapter 3 outlines the nature of ILW, including its ownership, recording, current holdings and future arisings. Chapter 4 introduces and discusses relevant aspects of Government policy. Chapter 5 outlines the roles of the regulators and reviews the nature of their guidance for the management of ILW. It also comments on tensions between the regulatory bodies. Chapter 6 explains and discusses the purpose and nature of the Nirex Letter of Comfort (LoC) system. It also reviews the operation of that system and suggests improvements. Chapter 7 provides an overview of progress with the conditioning and packaging of ILW and describes the nature and importance of "challenging" ILWs. It also outlines views on the potential impact of the regulation of radioactive discharges on the treatment of ILW. The chapter concludes with a discussion of BNFL's "Interim Safe Storage" (ISS) Strategy for the Sellafield site. Chapter 8 considers the meaning of passively safe storage and the timescale within which it should be achieved. A related question of the length of time for which it is prudent to plan for interim storage is also addressed. Chapter 9 introduces issues raised by the intention to set up a Liabilities Management Authority (LMA) ¹, including the notion of a "common purpose" approach and the role of Hazard Reduction or Safety Indexes. Finally, chapter 10 sets out conclusions and recommendations of the study.

* Whilst responses were also received from those with responsibility for Ministry of Defence (MoD) ILW, the timing of these responses was late in the project timetable and this precluded the possibility of a formal meeting with those who supplied the information.