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Regulator slams Fuel consultation

The RWMAC evidence is a very frank and critical analysis of the consultation papers prepared by the UK Atomic Energy Authority and on which the DTI based the public consultation. The advisers' opinions fully supports the position of local authorities in the Highlands and Islands and environmental groups that the consultation papers failed to provide sufficient information for a reasoned and meaningful consideration of the options offered for managing the Dounreay fuel. RWMAC is also highly critical of the lack of independent analysis of the UKAEA's reports and the possible bias in favour of the reprocessing option.

RWMAC was told by the UKAEA that the consultation paper, 'Making the Right Choice' was aimed at the "intelligent 14-year-old". The committee, however, said it was "unconvinced that it achieved this objective...it does not contain sufficient information to enable the reader to question many of the statements made and, therefore, to make an informed response." Quite why the 14-year-old age-group was chosen isn't explained, especially as few 14-year-olds were likely to participate in the consultation.

Among a long list of concerns and criticisms of how the whole consultation process was prepared and conducted, the committee says it "does not believe the information presented in the consultation document supports a full statement of the strengths and weaknesses of all the options." The Best Practical Environmental Option (BPEO) was prepared 'in-house' by UKAEA and RWMAC says the lack of independent input "could colour external perceptions of the objectivity of the analysis". The 'Multi-attribute analysis' used by UKAEA comes in for strong criticisms, describing parts of the analysis as "highly speculative". Waste minimisation and transport minimisation issues were not directly included in the analysis and there was no quantitative information given on transport, worker or public radiation dose, or waste quantities, for example, for any of the three options.

The committee was "concerned over the technical robustness" of the consultation papers and needed much for information on issues central to making a decision - such as the feasibility of developing new storage technology for the fuel, whether the D1206 reprocessing plant was ever likely to get regulatory approval to re-start, or how the reprocessing options affected the UK's commitments to reduce discharges under the OSPAR Sintra Agreement.

RWMAC had "several reservations" on the financial figures provided by UKAEA. Perhaps most importantly the government advisers stated: "The Committee does not understand why the costs of repository disposal have only been allocated to the Minimum Treatment Option [storage]. It was essentially only this that led to any substantial difference in the total cost estimates" between the reprocessing and storage options.

The committee says it is "unfortunate" the consultation was held in the absence of a national policy on long-term management of high and intermediate level wastes and "before the current debate on the future status of plutonium as a resource or a waste has been concluded."

The committee stated "it was impossible" to base a judgement solely on the papers in the public consultation. RWMAC says it still lacks sufficient information even after it was given an additional lengthy private presentation by the UKAEA in April; an additional meeting with the UKAEA on 1st August; had access to the independent review ordered by the DTI of the UKAEA's financial figures; and was given DTI ministerial permission to see the evidence submitted by three regulatory bodies - the Health and Safety Executive (HSE) and the Nuclear Installations Inspectorate (NII), the Scottish Environment Protection Agency (SEPA), and Nuclear Safety Advisory Committee (NUSAC).

None of the local authorities, organisations, Members of the Westminster or Scottish Parliaments, or members of the general public were given access to any of this additional information. It is also unlikely the governments of Norway, Denmark, the Netherlands, Ireland, Iceland, France and the Isle of Man - all of whom were consulted by the UK - have been provided with the additional information.

RWMAC's main conclusions concern the lack of information and analysis of the options offered in the consultation and the need for more detailed investigations. The advisers view the so-called Hybrid Option, of reprocessing some fuel at Dounreay and some at Sellafield, as the least attractive. They see major outstanding issues with both the other options - reprocessing all the fuel at Dounreay or putting it in long-term storage prior to eventual disposal.

However, after the second private meeting with the UKAEA and access to the other evidence, RWMAC slightly shifted its position more in favour of reprocessing at Dounreay. The committee said because reprocessing was a known process, while the storage option is new and unknown and not enough work has been done investigating it, "the balance of the Committee's view" was "tilted" towards the option of reprocessing the fuel at Dounreay.

The deadline for the public consultation was 2nd June and to date there is no indication of when a decision from the DTI may be expected. The initial UKAEA deadline for a decision by September has come and gone. RWMAC's criticism of the consultation follows similar views from the Scottish Environment Protection Agency although they were less frank. RWMAC's views may renew calls from local authorities and organisations who participated in the consultation that it should be abandoned.

The full text of the RWMAC evidence to the DTI is available at www.open.gov.uk/rwmac/