This article is mainly a commentary on a report by United Kingdom Nirex Limited, a review of the site selection process, conducted by Nirex in 1987-1991, for an Intermediate/Low Level Nuclear Waste Repository. However, there are implications for the whole concept of nuclear waste disposal.
The report, which Nirex call a Technical Note, was published in June 2005 under the Freedom of Information Act, which came into force on January 1st 2005. It’s available online: www.nda.gov.uk/publication/review-of-1987-1991-site-selection-for-an-ilwllw-repository. It seems to be commendably honest about the haphazard nature of the process!
My piece consists of quotes from the report, in italics, followed by my comments. The first few, without section numbers, are from the Executive Summary.
We believe that the process used was technically sound, but it was conducted in secret and did not involve stakeholders, therefore it was not a legitimate process.
Not only was the process conducted in secret, it is clear from the report that much of it was not documented. This makes it very hard to know whether it was technically sound or not – indeed, it makes it impossible to believe that it could have been consistently technically sound.
The role in the decision-making process of local communities in the areas being considered must be defined clearly at the beginning of the process, including rights such as veto and volunteerism.
The idea of a right of veto is interesting, particularly in the light of other statements made later in the report. What if every community everywhere uses a veto? What if the only places volunteering are places such as Sellafield, where the livelihood of the community might be seen to depend (at least in the short term) on the nuclear industry? Will a repository be constructed in such a place even if the local geology is totally unsuitable?
Radioactive waste has been created in significant quantities in the UK since the 1940’s. The UK has significant holdings of long-lived radioactive waste that will remain potentially hazardous for many thousands of years. Previous attempts to provide a long-term waste management facility for these wastes have ended in failure, most recently in 1997. The waste is currently being stored at 34 locations around the UK awaiting a long-term waste management facility.
We believe that radioactive waste management is an ethical issue – the waste exists and must be dealt with irrespective of any future decisions on nuclear power.
This is absolutely correct. The difficulty is that once a method of dealing with the waste is decided, the nuclear industry is going to claim that the problem is solved, and say that there is no bar to the unlimited expansion of the industry. However, the quantity of waste increases with every unit of energy generated in a nuclear power station. Every additional year that existing nuclear power stations operate increases the quantity of waste; every additional nuclear power station built increases the rate at which the quantity increases. No repository can be guaranteed leak free in perpetuity – the greater the quantity of waste stored in the repository (or repositories), the greater the hazard from such leaks.
4 IAEA GUIDANCE
The procedure that Nirex intended to follow [in 1987] was that recommended by the IAEA in the relevant Guidebook , taking particular account of the following recommendations :
* repository sites should be evaluated on the basis of geological and ecological information as well as societal considerations;
* evaluation is performed in several stages, proceeding from generic to specific assessments; and
* the site selection should be undertaken in close connection with the work for the repository concept and design, and if necessary the introduction of engineered barriers should also be taken into account.
The first point is really the point I was making above, and which Nirex signally failed to follow. The second point, and the first part of the third point, seem to me to be so obvious that they're barely worth stating. Then there's that bit about engineered barriers...
Talk about hubris! They think they can engineer something to last thousands of years? Reliably? They're dreaming. It's a tall order to predict what will happen to things we engineer over periods as short as a few decades. Some things do end up lasting millenia – the Pyramids, for example – but predicting in advance which things they will be is far beyond our capability. Even if we build new things to an old design – some new pyramids, say – we don't know how long they'd last. The pyramids have lasted as long as they have because the conditions where they are just happen to have allowed them to. If they'd been in a different location, or if the climate where they are over the last few thousand years had been different, they wouldn't have lasted. And we don't know what's going to happen to the climate, anywhere, in the next few thousand years. And there aren't any millenia old nuclear waste repositories for us to copy anyway.
Or are there? The nuclear industry are very fond of telling us about the remains of natural nuclear reactors at Oklo, in Gabon, west Africa, and how the nuclear waste produced in those reactors has been naturally contained for 1.7 billion years (Oklo: Natural Nuclear Reactors – now from the Wayback Machine – they've taken the original page down). I'll leave aside the question of whether the whole story is a fiction cooked up by a few clever clogses in the nuclear industry (it's very hard for any sceptic to check the story: the mine where the reactors were allegedly found is remote, inaccessible and heavily guarded). Even if it's true, it gives no grounds for confidence that a repository will really contain the waste. Perhaps there were hundreds of such natural reactors, and the ones at Oklo are the only ones that didn't get breached – or the only ones we happen to have found. It's only chance that they have remained underground for all that time – there aren't many places on Earth with rocks as old as that, most rocks from that period were eroded away long ago. You can't predict with any certainty which formations will survive, and which will not. Even if they're not eroded away, you can't predict which will leak, and which won't. Yucca Mountain, where the US nuclear industry wants to dump its nuclear waste, is particularly vulnerable: the whole area has a history of episodic hydrothermal activity. It's dry at the moment, and has been for a few thousand years, but for how much longer? No-one knows. The uncertainty is only increased by the impending climate changes.
When Nirex's proposal for a Rock Characterisation Facility at Sellafield was rejected in 1997, the Inquiry Inspector said "Chemical containment is new and untried, with more experimentation and modelling development indubitably required. This work would to my mind be particularly difficult and important because of the problems of meaningfully testing some of the components of the concept. Implicitly Nirex feels unable to credit the notion that this barrier would fail; but the lack of any calculation based on an adverse, as distinct from a conservative, interpretation of this chemical containment seems to me to be an unfortunate omission from the emerging safety case, particularly having regard to FOE's impressive critique of the concept." Nothing has changed in any significant way since then. (This is a classic case of optimistic estimation of risk, see Logic & Reality.)
6.2 Identification of Possible Sites
Following the identification of areas of search, the next step for Nirex was to identify possible, individual sites for evaluation. This step was strongly influenced by the nontechnical, but critical, consideration that Nirex was not granted compulsory purchase powers to enable it to acquire a site for the development of a repository . Accordingly, Nirex was restricted principally to considering sites that were owned by central Government or by its nuclear industry shareholders. Some privately-owned sites were also considered: in the main these were volunteered by the owners in response to the public consultation exercise.
The failure to attach much importance to the need to find a good site for disposal of wastes is clear from the fact that compulsory purchase powers were not granted.
The notable exceptions to this strategy were :
* the exclusion of consideration of sites in Northern Ireland, because of the political situation; and
* removal from consideration of a large proportion of the potential sites in Wales, in particular Forestry Commission landholdings, following previous experience from the LLW/short-lived ILW siting studies when personal threats were received by staff involved in the consideration of such sites.
So they are worried about terrorism – or were in 1987-1991. Presumably the whole charade could be brought to an end if there was a campaign of personal threats against staff wherever the sites under consideration were. No, I'm not suggesting that as a campaign stratagem – I'm a pacifist.
The names held on Nirex records are not always as informative as might be wished, referring only to the town or village near where the land-holding was located. Checks of the grid references show that on occasions these were provided or recorded incorrectly
A very professional operation, then! (I can't resist an aside here: "professional", meaning paid for what is being undertaken, is usually taken to imply a higher quality of work than "amateur", meaning unpaid. This doesn't necessarily correspond with reality.)
7.1 Initial Screening – 537 to 204
An initial screening exercise was conducted to establish the realistic potential of the possible sites identified. 333 sites were eliminated at this stage. This was done at a very basic level, to eliminate sites that had obvious deficiencies, and was based on advice from a planning consultant (from Pieda) and a geoscientist (from the BGS) who spent two days together to review their assessment.
Two days? That's about three minutes a site.
7.4 Geological Evaluation – 117 to 39
It is stated in Nirex Report 71  that "All sites remaining under consideration were then re-examined in further detail by BGS in terms of their geological potential for development as a deep repository". The Nirex records of the site selection exercise identify a single BGS report  as the source of this evaluation. That report contains purely geological descriptions of the remaining sites; there is no record of a process of evaluation. The report also post-dates the publication of Nirex Report 71 and the issue of the Pieda report on the sieving process (identified in Section 6.1 above) .
What can one say? What use is an evaluation process of which there is no record? Was there any process of evaluation? Why no record of it, if so? Did someone destroy records for some reason?
However, a later internal document, prepared in 1995 by a consultant to Nirex , assisting the legal team prior to the RCF local planning inquiry, gives summary reasons for the rejection of sites on geological grounds at this stage. These reasons are traceable to factual information in the BGS report issued in 1989. Interviewed participants in the site selection exercise recount that the consultant who authored the 1995 report conducted systematic interviews to achieve a retrospective audit trail of the decisions made at the time (1987 in this instance).
So that's all right then. Or not. The internal document  is D W C Baker and H Beale, The Selection of Sites at Dounreay and Sellafield to be Accorded Priority for Further Evaluation as Potential Locations for the Nirex Deep Underground Intermediate- and Low-Level Solid Radioactive Waste Repository, Report DWCB IPTE 1458, 1995. I'd love to see a copy of this document. Maybe I'll request a copy under the Freedom of Information Act. I wonder how much it will cost? Summary reasons only anyway – no detail. If there ever was any detail, it's gone now, other than anything that might be retrievable with considerable effort and unknown reliability from people's heads.
The guidance was based on a systematic analysis of the advantages and disadvantages of each site, which included consideration of the presence of a local community with knowledge and understanding of nuclear technology.
This is relevant to the safety of the site in its early years, but cannot be relied upon in perpetuity! In fact, the main reason why it's relevant is probably that such a community is more likely to accept (or turn a blind eye to) the risks, since their livelihood may well depend on the nuclear industry.
The choice of NY 0305 for Sellafield ‘B’ was made on the basis that Pelham House School was known to be in the ownership of BNFL and had the potential to be developed as the offices for a ‘BUSC’ repository located nearby.
This is bizarre. We're discussing the process of dealing with the most intractable problem faced by the nuclear industry, which generates 19% of the UK's electricity – and the value of an existing building as possible offices is a significant factor?
11 EVALUATION AND LESSONS LEARNED
This section actually covers many of the above points – the New Broom that has swept through Nirex actually seems to have learnt some of the lessons of the abysmal first attempt at the process! For example:
Arrangements must be made to ensure that all decisions are recorded by the decision-makers at the time they are made, with an accompanying record of the information that supported the decision. These arrangements should ensure that the process is not only traceable and transparent to stakeholders, but is recorded in a manner that provides a record for formal scrutiny, for example at a Public Inquiry.
The fact that this needed to be a lesson learnt at the end of a long and expensive process, for a purpose as important as this one, beggars belief.
Have the lessons really been learnt? The authors of this report have certainly learnt the lessons that they've listed in the report – but will the people responsible for the next process actually take them in? That remains to be seen; I can't say I'm confident of it. History suggests that it's unlikely – some of the same pressures will lead to some of the same effects, and the "lessons learnt" will be forgotten, if they're ever read at all.
12.3 The Repository Concept
The repository concept that was under consideration in the previous siting studies was based on a repository that was envisaged to be backfilled and sealed as soon as possible after all the waste was emplaced in its vaults. In response to feedback from its stakeholders and the public, Nirex has since developed the Phased Geological Repository Concept. This allows the monitoring of the waste in underground storage, under controlled conditions, for a period of perhaps hundreds of years until society takes the decision to backfill, seal and close the repository or, alternatively, to manage the waste in some other way.
This is a recipe for a repository that is monitored under controlled conditions for a period of a generation or two, then forgotten about and abandoned; never backfilled, sealed and closed or managed in any way at all.
After twenty more years of experience in the UK and internationally, there is an improved understanding of what is required from the geological barrier in a repository multiple barrier containment system. Coupled with a better understanding of relevant geological processes this means that different geological settings could now be included or excluded [my emphasis].
So maybe it's just as well we didn't build a repository before we knew enough about it. Do we know enough now, or in another twenty years will we have learnt that today's understanding still wasn't good enough? This seems highly likely to me.
It's too late now to realize that we've been manufacturing the world's most dangerous, indestructible waste ever, in large quantities, without having the faintest idea about what we can possibly do with it. It's not too late to decide to minimize the continued production of it.