Jan Haverkamp, WISE, Amsterdam
9 June 2020
NIRAS/ONDRAF, the Belgian nuclear waste management organisation wrote a draft plan for long term management of high-level radioactive and/or long-lived nuclear waste. In a public consultation, people and (Belgian) authorities can react on this plan and a Strategic Environmental Assessment (SEA) until 13 June 2020. NTW member WISE has written an extensive reaction (in Dutch).
WISE’s general conclusion is that this SEA shows that NIRAS has a too limited view on which environmental effects and risks can in this stage already be estimated, and should have been estimated and described. NIRAS furthermore shows some strong biases on the necessity of production of this waste and in favour of the choice of one technological pathway. All considerations around prevention of waste were explicitly excluded from the SEA paper, and the justification given for the choice of deep geological disposal in Boom or Iperian clay were not covered by the documentation. This bias also caused a certain tunnel vision in the analysis of possible alternatives. This is remarkable, because a similar limitation of view already led to rejection of an earlier programme for deep geological disposal in the Boom clay in 2015 by nuclear regulator FANC.
NIRAS wrote a methodologically defensive SEA report. Normally spoken, one would expect an inventory of important aspects and an as good as possible qualitative overview of impacts, as well as where possible a quantitative analysis. NIRAS, however, excluded everything that had any form of uncertainty. This created an oversimplified picture. Where it, for instance, devoted a lot of space to calculate the expected amount of lorries per day for transport in different phases over the coming 100 years, there was no analysis of any risks due to severe accidents during the filling of a repository, or later due to human interference.
- The programme should pay more attention to the fact that the current default solution for high level wastes is temporary storage. This means that, that also the environmental impacts of this interim storage are an integral part of every final disposal option. NIRAS only mentions temporary storage as the zero-option, but fails to take up the existing environmental impacts of temporary storage into its plans for final deposition;
- The programme, in this stage, should include a broader field of environmental impacts should; Incidents and accidents should not be excluded in this stage;
- The programme does not take alternatives sufficiently seriously;
- There lacks sufficient transboundary analysis;
- NIRAS concentrates too much on quantitative analysis of small and often marginal details and turns its back actively to all factors that could have substantial environmental effects (incl. incidents and accidents, and human interference). Instead of giving a good qualitative overview, NIRAS only offered a limited amount of detail facts of those few factors it could in this stage fully oversee, and excluded all other factors.
- The complexity of environmental impacts of different options for final deposition should be more clearly acknowledged and described in a comparison between different alternatives, and in comparison with prevention of production of different types of radioactive waste.
WISE concluded that this SEA from NIRAS does not fulfil the criteria that can be expected of a good SEA for a plan for management of long lived and high-radioactive waste. For that reason it requests it to be rejected.