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Research and Development for Management of Nuclear Materials - 2nd Draft

Response to Committee on Radioactive Waste Management draft report: Report on National Research and Development for Interim Storage and Geological Disposal of Higher Activity Radioactive Wastes, and Management of Nuclear Materials

Submitted 11 September 2009

General Comments on the Draft Report:

The Geological Society is grateful for the opportunity to comment on the draft report, and pleased to have been involved substantively earlier in the process. The Society has a long term commitment to helping responsible bodies, including government, NDA and CoRWM, to deliver the MRWS programme, drawing on our collective expertise, our ability to communicate with scientific and technical groups whose engagement with the project is essential, and our links with institutions including other learned societies.

We consider CoRWM’s draft report a very high quality, perceptive and ‘forensic’ analysis of the situation, past and present. We strongly support many of the recommendations and conclusions. In particular, we are pleased that CoRWM has highlighted the need for co-ordinated strategic oversight of R&D within and between institutions, and the significant problem represented by the very limited number of places on taught MSc courses in hydrogeology and engineering geology.

We have not been able to comment in depth on all parts of the report, but we raise a number of matters of detail here. We are happy to discuss these further with CoRWM, if that would help.

Specific Comments on the Draft Report:

Executive Summary

9. This refers to ‘nuclear industry and regulators’ as being the users of research councils’ research. This is how it should be, but is there a common understanding of this ‘provider-user’ relationship in the research councils. This is fleshed out around para 3.133, but there is a tension in understanding of these definitions. It’s not clear in 3.133 what is meant by ‘overemphasis on applied research’. Does this refer to ESPRC specifically? NERC is said to be ‘slow to respond to needs of MRWS’. It is important that the report is clear about references to particular research councils, and to the research councils in general. Interface and relation between research councils’ programmes and ‘users’ like NDA is evidently a difficult area – a problem not unique to radioactive waste management. 

The report also implies a rather linear view of ‘ideas’ generated by researchers (by implication, mostly based in universities and research institutes) which should then be taken up by the user (i.e. industry). In reality, of course, the relationship between the actors involved – and the interplay between basic, strategic and applied research, development work, and industrial technology and practice – are much more complex matters. For their work to be relevant and well-judged, those working primarily in academia must fully understand the context of radiological risks, geology and especially the hydrogeology and geochemistry of geosphere containment (similar consideration apply to engineered barriers research needs, but fall less within the Geological Society’s purview). It is our impression that this complex coupling is often ineffective at present, leading to research which lacks relevance, and risking significant failure of trust and cooperation between the research community and the user community. Much more effective communication is needed between the various communities involved – and responsibility falls primarily to the research community to ensure that its work is well-founded and relevant.

12. The independent research needs of the regulator (the EA) are raised here, but the views of the EA itself are not apparent. The regulator cannot spend money replicating or shadowing every piece of research and technology that the implementer uses, but needs to sustain an independent and scientifically credible view on the science that underpins critical aspects of safety assessment. Whether or not the regulator should be able to mimic the safety assessment with its own independent calculation tools is debateable and has long been an issue in Sweden and Finland, for example. An early understanding of regulator’s strategy and research needs in this respect is essential. What is the EA’s view about this?

16. The recommendation that a distinct stage of MRWS be identified for underground R&D is a sensible one (as also discussed in paragraphs 5.43-5.44). While it is well established that underground ‘facilities’ can play a very important role in building confidence and developing (or rebuilding) technical skills, CoRWM (and, later, others) should be careful about the benefits claimed. There is no automatic guarantee that underground R&D will reduce uncertainties in surface-based measurements and interpretations. A careful and critical assessment of what is expected and what can actually be achieved from this stage of R&D is essential to building and maintaining confidence among scientific, stakeholder and public communities. Much can be learned from the varying URL ambitions and experiences of Sweden, Switzerland, the US, France, Finland and Japan, both with regard to technical and social considerations.

Establishing R&D Requirements

2. We strongly support the conception of R&D as including technological development (including ‘development of devices, methods, etc). This will be critical to improving reliability and cost-effectiveness of site characterisation, and later stages. Experience overseas is that the ‘spin off’ return on investments in technology development is very positive.

5. We regard it as self-evident that basic and applied research are both necessary –indeed, that these cannot easily be disambiguated. The need for both, and their entanglement, is recognised in overseas contexts of which we have experience.

11. We strongly support the observation that the UK cannot rely solely on research carried out abroad (though there is much to learn from experiences in overseas programmes), particularly given the distinctive, heterogeneous and uncertain UK waste inventory. This argument complements the justification for a strong UK research programme on grounds of skills and community development.

UK R&D for Management of Higher Activity Wastes

3. There is brief mention here (and elsewhere) of the role that consultants and contractors can have in R&D. This has been insufficiently recognised elsewhere (and is not discussed in detail here). These players can make a significant contribution. However, it is important also to recognise that most consultants do not have access to laboratories and other experimental sites. Most of their work relies on the use of models. It is important that these are calibrated and tested with real field and laboratory data – for example to maximise the reliability of long-term risk assessments (so far as testing allows), and to build confidence in them. There is an undersupply of good experimental science to deliver this calibration, which is essential to underpinning the important contribution contractors and consultants can make. We believe this matter should be addressed in CoRWM’s report.

67. In the context of EU research, it is worth noting that the Framework Programmes do not have a good record with regard to publication and peer review. However, there is considerable high quality material, including useful overviews and some good basic research. To identify what has been done and how useful it is, a detailed review would be required – such a review should be commissioned if implementing bodies are serious about drawing on EU research.

98. An important and positive feature of the Yucca Mountain project has been an intensive programme of publication of DOE research in peer-reviewed journals. The concerted attention paid to this has been very effective in building confidence in the science among the broader scientific community (notwithstanding the other reasons behind the foundering of the Yucca Mountain project as a whole). This approach to publication of research underpinning radioactive waste programmes has also been highly successful in Sweden, Switzerland and France. CoRWM should highlight the confidence and credibility this approach is likely to engender, and the momentum it lends to the science programme, and should strongly recommend that NDA adopts such a strategy. The same argument can be applied to the generation of high quality science meetings (as by Andra in France), which provide an opportunity to showcase the high quality science sponsored by the implementing body.

Some Specific R&D Issues

51. We agree that much of the required R&D will be site-specific. While it may become important for CoRWM, NDA and others to tease out the logic of what is considered site characterisation rather than R&D, for the purposes of budgeting and institutional responsibility, in practical terms the matter is incapable of resolution, is not relevant to the work which needs to be done, and should not be a primary concern. Similarly, the distinction between ‘technology development’ and ‘scientific research’ is not important – what matters is that the scope of the work being done overall is appropriate, that work is being done by appropriate institutions and individuals, and that the programme is well co-ordinated. The Swedish R&D programme is one in which good progress is being made, without undue procrastination over these distinctions.

53. There is an important point here, but it is not made explicit. It is not clear why the paper by DePaolo and Orr (2008) is picked out from the many reviews of research needs on radionuclide migration, or why this particular section is quoted. But the key phrase in the quotation refers to the need for a ‘new generation of experiments and computational models’. This implies that current experiments and models are somehow lacking. That may well be so, but the claim should be substantiated. It is not enough simply to say, in effect, that ‘something must be done’. Without going into exhaustive detail, it should be possible to say what the shortcomings are of the current approach, and what should be done to address this situation. 

Proposed Conclusions and Recommendations

As noted above, the Geological Society supports the recommendations CoRWM makes in this report – and it supports some strongly. We are surprised, however, that there is no recommendation relating to publication structures and peer review. The historical and current approach in the UK by Nirex and now NDA in this respect has been weak. Effective publication and peer review regimes have the potential to contribute significantly to the quality of research undertaken by (or on behalf of) NDA, to test and disseminate this research, and to build credibility and confidence among the scientific community whose engagement in MRWS over a period of decades is an essential factor for success – attributes which are far from universally strong at present.

5. As noted above, we strongly support the recommendation that strategic co-ordination of research within and between organisations, and the rationale for this developed in section 3, setting out in particular the shortcomings of the present arrangement, is convincing.

We would point out that this recommendation was made by the original CoRWM in its July 2006 report (CoRWM doc 700 paragraph 17.28). At that time, CoRWM saw this function as being the responsibility of the ‘overseeing body’ they recommended government establish (along with overall responsibility for the siting process). Government did not implement this recommendation, and allocated some of these responsibilities to others. However, strategic responsibility for R&D appears to have been overlooked. It is telling that the reconstituted CoRWM should also identify the need for such strategic co-ordination of R&D, on the basis of much more detailed investigation of this particular area. The urgency with which government should now address this issue has only increased in the past three years.