Response to Committee on Radioactive Waste Management's call for fact checking: Report on National Research and Development for Management of Nuclear materials, and Interim Storage and Geological Disposal of radioactive Wastes
Submitted 14 May 2009
General Comments on the Draft Report:
We recognise that you are asking primarily for ‘fact checking’. But it is difficult to draw a clear line between facts, the way in which information and ideas are expressed, values, and judgments. In this context, it is unfortunate that the report is not yet complete, and that in particular many of the ‘emerging key points’, lessons (e.g. those learnt from overseas experience – see below) and conclusions have not been set out. Nonetheless, some of our comments necessarily go beyond factual correction.
CoRWM has generally done a very good job of covering a wide and complex territory in an organised way. Inevitably it has not been possible for you to cover research and skills needs across the entire HLW-SF and ILW system, as well as the international experience, in uniform detail. Given this, we think it is important to identify priorities to be followed up, and if possible to commission (or to propose that others commission) those with relevant expertise to compile information and assessments in key areas. Some of the ‘emerging key points’ constitute calls for action, but in some cases their status is not clear, and as noted above many are not yet written. An example is that CoRWM might seek to review which aspects of GDF design identified in section 5.3 are likely to require underground research (beyond site characterisation), using the expertise of those with direct experience and a broader peer community who can ‘ask the right questions’. The learned societies might assist in such processes.
There is little in the report about Engineering Barrier System design and performance of the EBS ‘in situ’ in a GDF, at least until late in the process (i.e. testing of the EBS at stage 6, in an underground research facility), and in a rather restricted sense in the context of co-disposal. Research priorities in this area should focus on identifying suitable combinations of waste type, containers, buffer, backfill and host rock type. An important omission from the report is the key point that performance interdependencies between EBS and geosphere are different for HLW-SF (small volumes, high performance containers, tightly-engineered buffer and backfill material, geosphere setting primarily to provide stability for EBS) and ILW (large volumes, lower performance containers and buffer, hence geosphere setting and retention become more significant for long-term performance). The report does identify the issue of cement-bentonite interaction, but does not pose the question of what research is needed to test whether cement backfill is the best route for an ILW GDF and whether compacted bentonite is the best buffer for HLW-SF. It would be a mistake to accept that the Nirex 'reference vault backfill' and the SKB-Posiva bentonite buffer are the only or correct specs for the UK's GDF.
There is also no mention of research relating to the biosphere (beyond microbe/geosphere interaction), i.e. the receptors of any radiological dose.
While the report rightly highlights the role of social science as well as a range of natural scientific disciplines, the relevance of social science is not restricted to PSE as implied. Economics and risk management are notably absent, particularly given their importance in interdisciplinary work to identify the most suitable solutions to problems, and the possibility of disposing of new build wastes in the same facility as legacy wastes poses serious social and political questions which would need further work. But we recognise that scientific and technical R&D is the focus of the report.
Specific Comments on the Draft Report:
3. UK R&D for Management of Higher Activity Waste
3.5 – some FP7 activity is identified. But there is a vast archive of research reports that have resulted from the FP4 to FP6 projects (some involving UK partners, many not). These have varied in ‘value for money’ terms and in quality. Many, though, provide good overviews of what is 'state of the art' in relevant R&D. It is understandable that CoRWM has not had the time to review this literature in detail, along with the vast ‘grey literature’ and published background research associated with, for example, the Swedish, Finnish, French, Swiss and US projects. More effective use might be made of this in future.
3.9.1 (p35) – it is said that ‘the new US administration has stated that there will be a review of policy for the management of spent fuel’. In fact, the federal administration’s stated intention is to devise a new strategy for radioactive waste disposal, and all funding for the Yucca Mountain programme has been stopped except for that needed to answer inquiries from the NRC.
3.9.4 – it is asserted that the Posiva research programme supports around 250-300 researchers across two sites. One of the Geological Society contact group has considerable experience with the Finnish programme, and believes the numbers are considerably lower. He notes that the Finnish programme is considerably smaller than that in Sweden, and that they often collaborate. Is it possible that 250-300 is the total staff count?
3.9.6 (p 40) – does this refer to lessons learnt by the UK community? Or lessons which should be learnt? Or lessons learnt by CoRWM in developing its report? Without the content in place it is hard to tell.
4. R&D Skills to Support the MRWS Programme
4.5 (p 53) – reference is made to one of the discussion meetings organised by the Geological Society, with CoRWM and other learned societies, at which the International Association of Hydrogeologists was represented. Note that the September meeting with WG-C (CoRWM doc 2455, correctly referenced in Box 4) was not attended by the IAH. They did, however, come to the meeting with WG-A in November (CoRWM doc 2484). Although skills issues were discussed at both meetings, I think most of what you cite here came out of the WG-C September meeting (in which case the IAH should not be referenced). The CoRWM document number has not been included in the main text yet, so I can’t tell for sure. Something to double check, perhaps.