As progress is made towards a geological disposal facility for higher level radioactive wastes, it is vital that the public in general, and potential host communities in particular, have a clear understanding of how such a facility would be regulated and by whom, and have confidence in the independence and robustness of that regulatory system. The independent advisory committee, CoRWM has produced a Position Paper looking specifically at regulation, addressing these issues. This has involved CoRWM in several months of discussion with the relevant regulators, the Office for Nuclear regulation, Environment Agency, Scottish Environmental Protection Agency and Natural Resources Wales.

In CoRWM’s view, the regulation of a GDF cannot be divorced from the wider context of policy for the management of higher and intermediate level wastes, including consideration of the option of near surface disposal of suitable intermediate level wastes. CoRWM has therefore reviewed developments since the last comprehensive statement of general policy, Managing Radioactive Waste Safely in 2008.

As the CoRWM paper points out, one vital part of the GDF process is public and stakeholder trust in the regulators. Another is confidence in the fairness, openness, participative nature and transparency of the regulatory process. One challenge in this regard is the comparative complexity of the UK’s regulatory process. Another challenge, particularly stark for a GDF, is the maintenance of institutional learning and capability of the regulatory system over the very long time periods involved.

CoRWM makes a number of recommendations:

1. As a matter of urgency, a clear statement of government policy on matters relevant to a GDF, near surface disposal (NSD) and other issues relevant to radioactive waste management in England and Wales needs to be produced, preferably in a single, accessible document. It should recognise, address and explain any implications of the different policy which applies in Scotland.

It should also provide clarity as to the relationship to the UK radioactive waste inventory, including materials not currently classified as waste, but which in one form or another will be disposed of in a GDF.

The policy statement should be subjected to rigorous scrutiny and public debate, given the very long term environmental, health and safety implications.

2. We recommend that the term “risk-informed” should not be used as a term of regulation. Where used in the policy context it needs to be more clearly defined and justified.

3. There should be a commitment by government to continue external (non-UK based) expert reviews of the management of radioactive waste at regular intervals, especially as proposals for a GDF or NSD are developed.

4. Legislation should be revised as a matter of urgency to provide clarity on licensing a GDF as a nuclear licensed site. This should also include consideration of NSD, as to whether that activity will be licensable if undertaken outside an already nuclear-licensed site.

5. A clear summary of relevant regulatory responsibilities as they now stand should be produced reflecting the excellent work done by ONR and the Environment Agency (EA) in terms of co-ordination. It should also make clear the position in Scotland.

6. Clarification is required regarding the implications of the potentially earlier availability of NSD facilities for the future approval and regulation of a GDF.

7. The legal and regulatory implications of including an underground rock laboratory (URL) within proposals for a GDF will need to be considered if this is a real prospect.

8. Careful consideration needs to be given now to the policy, legal and regulatory implications of near shore disposal, including public international law.

9. Careful thought needs to be given to the application of safeguards legislation to a GDF or NSD, and the implications of this.

10. If NSD is an option to be pursued seriously, then consideration needs to be given as to whether it should be brought within the 2008 Planning Act system.

If you have questions about this content please contact corwm@beis.gov.uk.

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Coldingley only accepts residents with a minimum of 2 years to their release date. They must be prepared to work full-time and willing to take part in development programmes, for example with The Forward Trust’s 12 step programme.

GFSL is demonstrating its commitment to one of its core objectives – rehabilitation and reducing offender rates. Despite facing extreme challenges during the COVID pandemic, prisoners can access a wide range of work experience across Coldingley’s industrial complex which operates within the five acre prison site.

HMPPS operates a state of the art, £5 million Coldingley printing press, capable of producing high quality signs, printed materials and metalwork at the most competitive prices on a not-for-profit basis. It employs around 20 instructor staff and 100 prisoners.

“In terms of GFSL’s contribution to the prisoners, we’re currently offering valuable working experience to around seven prisoners at Coldingley. They range from handyman to electrical positions providing new technical skills which are transferable in today’s construction and manufacturing sectors’ says GFSL’s Site Manager, Adrian Page.

‘Some prisoners are allowed to train for formal qualifications and go on to secure paid employment after their sentence has been served.’ he added.

Alongside this, is a one acre engineering plant operated by HMPPS which employed 100 working prisoners prior to the COVID pandemic. The HMPPS run workshops design and produce a variety of bespoke metalworks. Many are produced for the prison estate like lockers and signs. They even make the cell doors (but not the locks).

Last year, they employed designers and craftsmen to develop bespoke pieces from scratch to any specification, using modern software run machinery.

Finally, there are smaller workshops fully managed by GFSL such as the carpentry workshop which carries out vital maintenance and repair work throughout HMP Coldingley.

They also offer vocational training via the CRED programme which has successfully led to ex-prisoners being offered full time jobs after serving their sentence.