The Nuclear Free Local Authorities (NFLA) publishes on its website its model response to the Nuclear Decommissioning Authority’s (NDA) Strategy 4 consultation, which outlines its core plans for the period 2021 -25. Whilst it welcomes some of the proposed plans, it makes a number of important recommendations for improvement. (1)
The NDA was established in 2004 by the UK Government to lead the decommissioning of nuclear facilities that have concluded their operating life whilst taking on the safe management of the radioactive waste created over the past 70 years. It works to five year strategy plans to determine its core strategies and is currently consulting on its plans for the period 2021 – 2025.
NFLA notes that the NDA’s mission will take over 100 years to complete and it is estimated to cost in excess of £120 billion to deliver. Facilities more than 60 years old were neither designed nor operated with decommissioning in mind. The NDA’s aspiration is that at least one of its sites will be fully decommissioned and released for its next planned use by 2040. (2)
The NFLA response is detailed and forensic. Its core conclusions make five core points including:
- In the absence of any agreement between the NFLA and the NDA on nuclear waste management in general and the waste hierarchy in particular, we think it is incumbent on the NDA to provide stakeholders at each of its sites with an inventory of waste already present and which will be produced during the decommissioning process along with its likely proposed destination. This allows for easy understanding and comparison to the NFLA’s core demand that if any part of a nuclear site is proposing to allow unrestricted use, it must be able to show that doses to members of the public will be of the order of 0.01mSv or less per year. This process should allow local authorities which are expected to host waste management facilities off-site – such as landfill sites, and local authorities on transport routes – to be part of the active policy conversation.
- Any proposals for the management of Higher Activity Waste (HAW) in near-surface facilities needs to follow the Scottish Government policy of requiring that facilities are monitored and have a capability to retrieve waste packages if necessary.
- It is noted that Sellafield Ltd could be allowed to increase certain discharges for a certain length of time, in order to carry out a particular decommissioning task, provided it has submitted an acceptable Best Available Technique (BAT) case. Unfortunately, it is not clear from the document whether any superior abatement techniques have been rejected on, for example, cost benefit grounds, or what research is going on so that discharges to the sea can be further reduced. This flexible approach should require the NDA to regularly consult stakeholders and members of the public on the use of BAT.
- We hope the NDA, in conjunction with EDF Energy, will seriously consider an early AGR decommissioning project for Hunterston B.
- The NDA should recommend to the UK Government that it drops the idea of re-using plutonium as Mixed Oxide (MoX) fuel.
The NFLA’s approach in this area would be always to stop producing more nuclear waste, and manage existing waste in a way which minimises any potential risk of environmental contamination by concentrating and containing existing waste.
The NFLA has again reiterated to the NDA it uses a set of environmental principles including:
- The idea that radioactive waste can be “disposed” of be rejected in favour of radioactive waste management.
- Any process or activity that involves new or additional radioactive discharges into the environment be opposed, as this is potentially harmful to the human and natural environment.
- The policy of ‘dilute and disperse’ as a form of radioactive waste management (i.e. discharges into the sea or atmosphere) be rejected in favour of a policy of ‘concentrate and contain’ (i.e. store safely on-site).
- The principle of waste minimisation be supported.
- The unnecessary transport of radioactive and other hazardous wastes be opposed.
- Wastes should ideally be managed on-site where produced (or as near as possible to the site) in a facility that allows monitoring and retrieval of the wastes.
NFLA argue such principles are well considered and appropriate. If the NDA does not work to these principles then, at the very least, it needs to consult regularly with all relevant communities affected, including all those on transport routes.
NFLA Steering Committee Chair, Councillor David Blackburn said:
“The NFLA model response on the NDA’s latest strategy for the next five years has carefully considered the plans and supports improvements in a number of areas. NFLA make some pointed recommendations over the NDA and its environmental principles and allowing for much more extensive consultation on the management of radioactive waste and the decommissioning of nuclear reactors. The vast costs of the NDA’s work over the next 120 year, possibly as high as £200 billion in total, are reminders of the burden to the taxpayer from our 70 year old nuclear programme, which would only go up if we decide to build new nuclear reactors. NFLA want to see effective strategies in these areas and calls on the NDA to carefully consider the detailed points made in its response.”
Ends – for more information please contact Sean Morris, NFLA Secretary, on 00 44 (0)161 234 3244.
Notes to Editors:
(1) The NFLA Radioactive Waste Policy Briefing 83 on the NDA Strategy 4 consultation is attached with this media release and can be found on the NFLA website
(2) NDA Strategy 4 consultation, August 2020
The closing date for consultation response is the 8th November 2020.