Extended interim storage in Gorleben
Contribution of BASE to the BGZ dialogue event
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2025.01.28
Speaker Dr. Christoph Bunzmann, Head of Licensing Department
The licence for the interim storage facility for spent fuel elements in Gorleben expires in 2034. An extension of interim storage will be necessary, as no repository site for high-level radioactive waste will have been designated by that time.
BASE considers it both necessary and feasible to identify a safe repository site by around 2050 and is currently working with the other responsible actors to accelerate the search in a targeted and safety-driven manner.
BGZ plans to apply in 2026 to the Federal Office for the Safety of Nuclear Waste Management (BASE) for permission to continue storing the CASTOR casks in Gorleben, thus initiating the formal licensing procedure under the Atomic Energy Act. In advance of this licensing process for extended interim storage, BGZ has submitted a request to BASE to initiate an environmental impact assessment (EIA).
At a dialogue event held by BGZ on 28 January 2025 in Hitzacker, the public was informed about the framework conditions of the procedure. Representing BASE as the responsible licensing authority, Christoph Bunzmann, Head of the Licensing Department, explained the scope, level of detail and the methods to be used in the investigations conducted as part of the EIA.
– The spoken word prevails –
Ladies and Gentlemen,
The task is clear, and it requires considerable perseverance: the high-level radioactive waste currently stored in Gorleben and other locations must be transferred safely and without delay into deep geological formations. Until that happens, safe interim storage and safe transport are essential to ensure the protection of people and the environment.
This task is being carried out by the Federal Company for Radioactive Waste Disposal (BGE), the Interim Storage Company (BGZ), the Decommissioning and Waste Management Company for Nuclear Facilities (EWN), nuclear regulatory authorities at the state level, research institutes, advisory bodies, and us – the Federal Office for the Safety of Nuclear Waste Management (BASE). It involves engineers, scientists, legal experts, public participation specialists, administrators and professionals from many other disciplines – all contributing their expertise and experience, working with clearly defined responsibilities and with the involvement of you, the citizens.
The actors and their roles
A major project involving so many different actors requires a clear structure in order to succeed. Several key institutions contribute to this effort, four of which I would like to briefly mention here:
- The Federal Ministry for Environment, Nature Conservation and Nuclear Safety is developing an overarching plan for nuclear waste management through the National Waste Management Programme. The programme was recently revised in draft form; a public participation process will follow, and the federal cabinet is expected to adopt the updated plan later this year. The ministry also holds technical oversight of BASE and – separately – oversees BGZ’s public participation processes.
- BGZ has presented its research programme as well as its plans for public participation and demonstration of compliance within the licensing procedure.
- Nuclear regulatory supervision in Lower Saxony lies with the state environment ministry. It ensures that operations run safely and follows up thoroughly on open issues. In particular, it ensures that licence conditions and nuclear regulations are met. To that end, the authority conducts on-site inspections and document reviews. Every ten years, it performs a comprehensive assessment of operational safety through a periodic safety review.
- And we at BASE, as the licensing authority, have our own structures in place for our responsibilities in the area of interim storage, which I will now briefly outline.
BASE as an actor in nuclear waste management
BASE’s responsibilities cover all aspects of nuclear safety, including the operation of nuclear power plants, interim storage, transport, final disposal and site selection for a repository for high-level radioactive waste. For the upcoming licensing procedure, the following areas are particularly relevant: research, the development of safety requirements, the procedural flow of the licensing process and the environmental impact assessment. I will now go into these in more detail.
BASE has developed a research programme that deals intensively with the safe interim storage and transport of radioactive waste. The current version was presented for consultation in Berlin last August. Many thanks to all who contributed.
The Atomic Energy Act defines “safe interim storage” initially in abstract terms. It makes clear that very high standards of technical safety must be met, and that both the operator and the safety authorities must work together, using what is known as an integrated safety and security concept, to ensure that even an attack on an interim storage facility would not lead to serious consequences for the public.
That is why it is essential to develop concrete regulations for safety and security. This task falls to the responsible authorities – the Federal Environment Ministry, the Federal Interior Ministry, BASE, other federal agencies and the competent state authorities. These rules define BGZ’s responsibilities: its plans for extended interim storage will only receive approval if they meet these requirements.
BASE plays a key role in the ongoing development and refinement of these safety and security standards, based on our technical expertise and experience from licensing procedures.
The nuclear licensing procedure and the environmental impact assessment
This brings us to the core of today’s event: the announced licensing procedure under nuclear law and the environmental impact assessment as an integral part of it.
The starting point is BGZ’s application to initiate a licensing procedure under the Atomic Energy Act – the timeline for this was presented today by BGZ. By doing so, BGZ signals that it believes it can describe its project in sufficient detail and demonstrate that it meets the applicable safety requirements. BASE will conduct this licensing procedure transparently and with an open outcome, in accordance with the applicable laws and regulations.
The licensing procedure serves three important functions, all of which contribute to the final decision on the application:
public and authority participation, the environmental impact assessment and the safety review and evaluation.
1. Safety review and evaluation
The safety assessment is based on a detailed review of the supporting evidence submitted by BGZ. How BGZ presents this evidence in line with current regulations is up to the company itself.
In most cases, this process gives rise to points requiring clarification and additional documentation requested by the reviewers. Interim assessments are then drawn up and discussed in various meeting formats. It is expected to take several years before a final safety assessment can be issued as part of this procedure.
2. Participation of public authorities and the general public
Participation by public authorities and the general public complements the expertise of the licensing authority and ensures that all relevant aspects are considered in the safety review.
The public participation process begins when the relevant documents are made available. These documents provide a clear explanation of BGZ’s proposed project and its potential impacts. This includes both potential environmental effects and possible outcomes of incidents or malfunctions. Based on this, you – the interested public – are invited to submit objections or comments. These may take the form of questions about the process or concerns regarding compliance with safety standards. We will provide clear and timely information on how you can take part in this consultation.
All submitted objections will then be addressed during a formal hearing session. We have agreed with BGZ that this hearing will take place no more than one year after the application is submitted. This represents a significant acceleration compared to previous procedures. However, this will not reduce the time available for you to submit comments. Instead, the necessary documentation will be provided much earlier in the process.
The hearing will be conducted in accordance with procedural law and will therefore be a highly formal event. Its purpose is to ensure that we, as the licensing authority, have fully understood the core of each objection and are able to take them properly into account in our review and evaluation. If a licence is granted, we will explain in the decision how the objections were considered and addressed.
3. The environmental impact assessment (EIA)
The environmental impact assessment is carried out based on European Union law and its implementation into German legislation. As BGZ has already explained, the aim is to systematically identify and assess all potential effects on the living environment of humans, animals and plants. BASE is taking the lead in this process and working closely with all relevant authorities. The goal is to establish a shared factual basis and reach coordinated decisions. In the end, however, each authority must independently determine which environmental impacts are relevant to its specific area of responsibility.
Because a thorough assessment of the current state of the environment takes time, BGZ wishes to initiate the procedure already at this early stage. This is possible because the basis for action here is not the application under nuclear law, but rather the Environmental Impact Assessment Act. BGZ has submitted a corresponding application. We are currently clarifying some formal questions regarding such an early-start EIA – this is the first time we are conducting the EIA and the nuclear licensing procedure separately, and we want to carry out both thoroughly and correctly.
As the first step following initiation of the EIA procedure, we will define the scope of investigation for the project so that BGZ receives an early indication of whether its planned investigations and studies are on the right track.
Conclusion
With this application, we are entering a necessary next step in the process of nuclear waste management. The overarching goal of the Atomic Energy Act will be met when interim storage, as a bridge to final disposal, is demonstrably safe and can be brought to an end through the timely construction of a deep geological repository. The administrative procedures serve both the cause and the people. They ensure safety and make it transparent to all citizens that both operators and authorities are fulfilling their responsibilities with diligence.
Allow me to close with a brief outlook beyond the licensing procedure itself: We know there is a strong desire for information and dialogue on these issues, extending beyond the licensing process. We will therefore present a concept for this and offer differentiated formats based on it.
Thank you for your attention.
Stand: 2025.02.06