The Nuclear Free Local Authorities (NFLA) submits today its views on the Nuclear Decommissioning Authority’s (NDA) Draft Radioactive Waste Strategy. (1) While supporting parts of it, NFLA remain concerned that the strategy continues to promote the dilution and dispersal of some forms of radioactive waste rather than concentrating and containing it, as per its own set of environmental principles.
NFLA note that the Nuclear Decommissioning Authority’s (NDA) Radioactive Waste Strategy Document (2) begins by pointing out that the UK has been producing and managing radioactive waste for many decades, implying that there are no problems associated with current policies. Yet no country in the world has implemented a long-term solution for higher level radioactive waste.
NFLA is concerned, and has engaged with the NDA on a number of occasions, that the NDA continues to promote the use of volume as a comparator for different types of waste, as it does in the introduction to this consultation document. The use of volume as a measure of the impact of radioactive waste is highly misleading. Volume is not the best measure to use to assess the likely impact of wastes and spent fuel from a new reactor programme, in terms of its management and disposal.
For example, by looking at the amount of radioactivity in the waste instead, it can be seen from RWM Ltd figures that Hinkley Point C alone will produce waste which will contain 3,800,000TBq by the year 2200, or about 80% of the radioactivity of the existing UK waste burden. (3)
In 2004, NFLA agreed a set of environmental principles that it continues to recommend to the nuclear industry for the safe and sustainable management of radioactive waste. (4) Considering the NDA’s draft radioactive waste strategy, NFLA argues that the NDA’s key objectives should rather be:
- To encourage nuclear operators to end the production of new nuclear waste (including spent fuel) as soon as practicable;
- Existing radioactive wastes should be ‘concentrated and contained’ to avoid wherever possible further radioactive discharges into the environment. The use of the waste hierarchy under these circumstances is not appropriate;
- Waste Management infrastructure needs to be developed to facilitate the long-term, passively safe storage of radioactive waste near or on the surface and as near as possible to where the waste was produced, in a way which facilitates monitoring and retrieval and protects from malicious attack;
- Existing wastes, including spent fuel and plutonium, should be immobilised and placed in long-term passively safe storage as quickly as possible;
- The collective radiation dose to the UK and global population should be reduced to an absolute minimum.
NFLA also consider in detail issues in the NDA strategy around ‘storage’ and ‘disposal’. NFLA rejects the idea that radioactive waste can be “disposed” of. The dictionary definition of “dispose” is “to get rid of something”. Even those in favour of disposal do not believe that disposal gets rid of waste. They agree that radionuclides in waste will eventually return to the surface or disperse in the environment, but they seek to show that radiation doses to the public will be at an acceptably low-level. In such instances, and considering Government and NDA / RWM policy to seek to develop a ‘Geological Disposal Facility’, NFLA believes it is currently impossible to demonstrate with any scientific credibility that the resultant radiation dose to people from a nuclear waste repository would be at an acceptably low level into the far distant future.
The NDA Consultation Document also says “disposal of radioactive waste should follow a risk-based approach”. The document talks about “making best use of capacity and capabilities that either exist now or could be developed in the future”.
This strategy is virtually the opposite of concentrating and containing radionuclides, as advocated in the NFLA’s environmental principles. It means permitting this disposal of radioactive waste in various ways to save money provided it can be shown that the increased risk to the public is ‘acceptably’ low. Along with several ‘treatment’ methods mentioned, such as incineration and so-called ‘decontamination’ and ‘recycling’, many of these ‘disposal’ methods will have the effect of increasing the collective radiation dose to the UK population. NFLA remains dismayed at the NDA continuing with such an approach.
NFLA Chair, Councillor Ernie Galsworthy said:
“The NFLA has consistently argued that developing radioactive waste management policy needs to be underpinned by a clear set of environment principles. The most important of these principles is that the nuclear industry should stop producing more waste as soon as possible. These principles also mean that waste policy should be about limiting and restricting discharges and dispersal of radioactivity into the environment, and aiming for a goal of zero discharges. As NFLA Chair, I remain concerned that NDA strategy is continuing processes which increase dilution and dispersal of waste rather than concentrating and containing it. I call on the NDA to carefully consider the NFLA’s submission and amend its strategy accordingly.”
Ends – for more information please contact Sean Morris, NFLA Secretary, on 0161 234 3244.
Notes for editors:
(2) NDA Radioactive Waste Strategy for Integrated Waste Management, July 2018
(3) An overview of the differences between the 2013 Derived Inventory and the 2010 Derived Inventory, RWM Ltd, July 2015
(4) NFLA’s Environmental Principles agreed in October 2004:
- 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.