The Nuclear Free Local Authorities (NFLA) has submitted its views on a joint consultation by the Environment Agency, Scottish Environment Protection Agency and Natural Resources Wales on its proposals to release nuclear sites from radiation substances regulation as they are reaching full decommissioning.
The joint proposal by the three national environmental agencies (1) provides a set of requirements to enable site operators to make the decisions they need to bring a site to a state in which it can then be made available for other uses and eventually released from radioactive substances regulation (RSR) for unrestricted use.
NFLA welcomes this early consideration of what will be an important environmental and waste management issue as nuclear sites are fully decommissioned over the next few decades. It also welcomes the proposed establishment of a sound and effective environmental framework for achieving this by a site wide environmental safety case (SWESC).
NFLA (2) though raises three key concerns about the proposals:
- The way of assessing the radiological hazard of a site which has been released from radioactive substances regulation appears to be too flexible.
- It is not clear who is expected to regulate a site which is being made available for restricted use. Local authorities are unlikely to have the resources to regulate such a site.
- The proposals appear to allow for the unrestricted use of sites which may have nuclear waste buried and which could be capable of administering doses of up to 20mSv/yr if human intrusion occurs. It is the NFLA view that such sites should remain subject to radioactive substances regulation.
Other critical comments made by the NFLA include:
- Basing whether or not to release a site from RSR on the probability of an exposed person receiving a certain level of dose is going to rely on uncertain environmental models. The NFLA view is that this leaves too much open to interpretation. NFLA prefers the Health and Safety Executive view that 0.01mSv/yr broadly equates to a risk of 10-6 and would therefore expect the dose to the most exposed person after a site has been removed from radioactive substances regulation to be at least as low as 0.01mSv/yr.
- The NFLA believe that nuclear sites which are only suitable for a restricted use should not be removed from RSR. The environment agencies should encourage tough clean-up standards by only removing sites from RSR if they are suitable for unrestricted use.
- It is the NFLA view that a clear distinction should be made between a de-licensed site which can be removed from radioactive substances regulation, and a near surface disposal site which should remain within radioactive substances regulation as long as such regulations exist.
NFLA are also concerned whether, given the huge cuts to local authority services in recent years, which has had a major impact in particular on specialist areas like scientific services, environmental health, specialist areas of planning and waste management; if Councils will have sufficient resources to take over the safe management of such sites as they are removed from radioactive substances regulation.
NFLA Chair Councillor Ernie Galsworthy said:
NFLA welcomes this initiative from the three environment agencies to consider at an early stage the impact of nuclear decommissioning as many reactors come to the end of their generating capacity. However, the consultation has critical issues of concern around being potentially too flexible in some areas and not prescriptive enough in others. With most Councils seeing their specialist scientific, planning, waste management and environmental health sections decimated in recent years, and with more cuts expected to come, it is also necessary to pose the question on how Councils can take eventual stewardship of these sites without the sufficient resource for safely managing them. It is really important that we do not simply convert these nuclear sites into nuclear dumps. NFLA will work on behalf of its members to call for these issues to be fully resolved.”
For more information please contact Sean Morris, NFLA Secretary on 07771 930196, who can arrange a specialist interview with the NFLA Steering Committee Policy Advisor, Pete Roche.
Notes for Editors
(1) EA, SEPA and NRW joint consultation on ‘Requirements for Release of Nuclear Sites from Radioactive Substances Regulation’, February 2016
(2) NFLA Radioactive Waste Briefing 63, May 2016