On Monday, after more than two years of work, the Commission Storage of High-level Radioactive Waste is planning to conclude consultations and reach a decision on the outstanding substantive issues. In the intervening period, the Commission has made many important decisions even on issues that were subject to long and tenacious wrangling. During the process, the Commission has covered its task in remarkable breadth and depth. Its task is to prepare the coming site selection process in such a way that disposal of the high active waste is made possible without placing an undue burden on future generations and of doing this by the broadest possible consensus that does justice to the political compromise on which the Site Selection Act is based.
Dr. Ralf Güldner, President of the German Atomic Forum, said: “Approaching the finishing line, the Commission is running an unnecessary risk of putting its work and its recommendations to the Bundestag and Bundesrat in a bad light by violating the consensus orientation of the Site Selection Act or of overextending its mandate at the expense of the procedure’s feasibility.” Güldner went on to say: “An example for the lack of desire to reach a consensus can be seen in several long protracted conflicts within the Commission that focus entirely on the past and the dispute surrounding the Gorleben site but not on solving the question of disposal for the future. Thus the basis for a statement on Gorleben by the Commission is a document over 30 pages long which faithfully reflects the controversy within the Bundestag’s Gorleben investigation committee but not the political rationale of the Site Selection Act.”
Open questions regarding the criteria for site selection are also dictated by how withdrawal of the Gorleben site can be brought about. This is especially true for the issue of an overburden’s protective function: the introduction of such a criterion is aimed primarily at eliminating the Gorleben site from the process as quickly as possible and entails a risk that particularly suitable sites will be ruled out at an early stage. The Nuclear Waste Management Commission of the Federal Ministry for the Environment does not consider such a criterion as necessary and it is also rejected by the Institute for Geosciences and Natural Resources. On this Güldner said: “In particular, the view that an overburden should serve as a redundant equivalent barrier in addition to the isolating rock zone and guarantee long-term safety is incompatible with the safety requirement for safe enclosure of radionuclides over a million years.”
Examples of overextending the task in details can be seen in stipulations regarding requirements for future final repository casks or test procedures for the interim storage of irradiated fuel assemblies. On this Güldner said: “Requirements for final repository casks can only be developed in conjunction with a future final repository concept which is always host-rock and site-specific. Exact specifications for casks now could massively hamper the work of the project developer and the Federal Office for Nuclear Waste Management in a few decades’ time.” Specification of the future scope of tests for casks and inventory is also misplaced in the case of interim storage. Güldner went on to say: “These are classic tasks of a regulatory authority, which in the near future will be the Federal Office for Nuclear Waste Management.”
Güldner concluded: “I continue to hope that good, amicable solutions can still be found on the home stretch which will make it easier to implement the recommendations in the future.”