OPTIMISING THE NUMBER AND LOCATION OF INTERIM INTERMEDIATE LEVEL WASTE (ILW) STORAGE FACILITIES ON MAGNOX LIMITED AND EDF ENERGY SITES IN ENGLAND AND WALES – CREDIBLE OPTIONS. NUCLEAR DECOMMISSIONING AUTHORITY, MAY, 2013
RESPONSE FROM THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
BANNG Paper No. 20
The Purpose Of This Response
The Blackwater Against New Nuclear Group (BANNG) has an interest in the siting of interim storage facilities, which the group believes should be an integral part of the long-term management of radioactive wastes. In particular, BANNG is concerned with the implications of the current proposals for Intermediate Level Waste (ILW) storage at the Bradwell site.
The former Bradwell power station closed in 2002 but ILW, in the form of the reactor cores and fuel element debris (FED), will remain in situ on the site until the end of this century, possibly longer if no repository is forthcoming. The strategy paper refers to the possibility of ILW from Sizewell A and/or Dungeness A being transferred to Bradwell. BANNG is opposed to this option and believes that each site should host its own waste as originally planned. BANNG believes that the Bradwell site is totally unsuitable as it sits on a shallow estuary with an important marine environment; it is vulnerable to flooding and storm surges by the end of the century due to sea-level rise, when ILW will more than likely still be stored there. It is an unsuitable site for storage of radioactive wastes.
When Bradwell closed, the NDA undertook to return the site to green field within 35 years. There is, of course, now no hope of that happening and the hulk of the old station, containing the graphite reactor cores, will remain on the Blackwater estuary at least until the end of the century, along with storage of ILW.
The local communities were also led to believe that the old Bradwell station would be put into care and maintenance by 2015 and that they would be hosting only the ILW produced by the old station – although there was no public consultation on this storage. Now there is a proposal to store wastes from other stations at the Bradwell site which means compromising the care and maintenance process. There has been virtually no public consultation on this proposal.
Piecemeal Development of Policy for the Interim Storage of ILW
It is obvious that there is no clear and well-considered, long-term strategy for the interim storage of ILW; rather that policy is developing in a piecemeal way. In relation to Bradwell, BANNG fears that the current proposals could be the thin edge of the wedge and may lead to pre-emption of the site as a regional store. Other sites may also find themselves in the same position.
The strategy paper states (p. 6):
‘It is assumed for this study that these stores may be available to store wastes from other sites also (provided that there is spare capacity)’.
The paper, however, seems to deal with more than spare storage capacity.
We have been told that the ILW store at Bradwell has space for 240 packages of ILW. Appendix A of the strategy paper shows that there are 173 packages from Bradwell itself to be stored there (Appendix A – Current Waste Packaging Strategies and Estimated Package Numbers for Magnox and EDF Energy Sites in Scope, p. 22). That leaves space for 67 packages. Appendix A shows that Dungeness A has 219 packages and Sizewell A 28, a total of 247 packages. If Bradwell were to host ILW from Dungeness A or that station and Sizewell A, it would seem that the current store would require enlargement or another store would require to be built.
Given that the NDA’s ideas seem to be subject to change with time, where is the guarantee that more packages from other sites (perhaps Sizewell B in the case of Bradwell) will not be sent to Bradwell? In fact, under Section 2.2.2 (p. 9) there is a comparison of the costs between having three stores with having eight. And under Section 3.2 (p. 13), there is reference to minimisation of future stores, with sub-options that include some cross-region waste transfers. The options seem to be driven by cost not safety and environmental considerations.
BANNG believes that the NDA should base its ILW storage strategy on a proper long-term siting process, the priorities of which are safety and the environment.
Need for a Siting Process for Long-Term Interim Storage
BANNG believes that the geological disposal facility (GDF) and storage should be seen as separate but related and interdependent issues (see BANNG’s response to the Call for Evidence on Managing Radioactive Waste Safely (MRWS), BANNG Paper No. 19 – attached). Storage should be considered as both a prelude to disposal but also as a separate approach, requiring a separate process based on the principles of voluntarism and partnership.
Given that storage is an integral part of long-term waste management and the possibility that a GDF may not materialise for a considerable time, if indeed at all, BANNG believes that the siting of stores also requires attention in any revised MRWS process. There has to date been little debate or public consultation about the location of these stores. In fact, as a result of the vote by Cumbria County Council, the search for a GDF has stalled and emphasised the role of storage as a vital part of the disposal package. It is also very unlikely that there will be a GDF available by 2040 as the Government and the NDA continue to claim.
Over the long-term, the conditions at the sites hosting ILW also become a significant consideration (e.g. vulnerability to flooding with sea-level rise) and some sites may need to be abandoned.
BANNG believes the long-term storage of wastes is an issue of public interest, especially for those communities who have to host them. A siting process for storage is necessary – as Recommendation 2 of ‘Managing our Radioactive Waste Safely’ – the recommendations of the Committee on Radioactive Waste Management (CoRWM) to Government, states:
‘A robust programme of interim storage must play an integral part in the long-term management strategy. The uncertainties surrounding the implementation of geological disposal, including social and ethical concerns, lead CoRWM to recommend a continued commitment to the safe and secure management of wastes that is robust against the risk of delay or failure in the repository programme.’. (p. 13)
BANNG believes that the storage of ILW should be subject to a process of site selection based on consideration of future site conditions, public as well as stakeholder engagement with relevant communities and application of a siting process based on the principles of voluntarism and partnership.
Long-term NOT Interim Storage
Under the MRWS process, the NDA is concerned with management of waste in the long-term while it claims that ILW wastes require interim storage. As this interim storage of ILW (and of spent fuel at Sizewell B and any new build stations) will be required until at least the end of this century, and perhaps indefinitely, the term ‘interim’ is a misnomer and misleading. It is, in effect, long-term storage that will be required. As stated above, the Government and the NDA need to disabuse stakeholders and the public that a GDF will exist by 2040 as this is extremely unlikely.
The ILW at Bradwell is a legacy of the former nuclear power station. It does not belong to the local communities who are required to host it; they are doing so on behalf of the nation. BANNG believes that it is only fair that such communities should be compensated for hosting this waste in a way that enhances their well-being.
BANNG considers that the Government and the NDA should adopt a policy of being open and transparent with the public about the prospects of the availability of a GDF by 2040 and inform them that radioactive wastes will require to be hosted at each site over the long-term. Local nuclear communities should not be taken for granted and expected just to host storage of ILW in the long-term, or indefinitely – and especially not wastes from other sites. These communities should be afforded compensation to enhance their well-being and, in the event of being asked to host waste from other sites, they should be offered the same voluntary and partnership package as that being offered to potential host communities in the search for a GDF.
BANNG believes that the constraint of adhering to the requirements of ‘a window of opportunity…… to allow for the investigation of this opportunity before significant funds are spent on implementation of the site-centric baseline’ (Section 2.3.2, p. 10) is unhelpful when dealing with such an important issue as the storage of radioactive wastes. As stated above, there should be a proper long-term siting process, the priorities of which should be safety and the environment. It is most important to ensure that storage of ILW is recognised as an integral part of the long-term management of radioactive wastes. Taking only costs into consideration could open the way to incremental and ad hoc policy and for pre-emption of sites as regional stores.
Storage should be considered not in a rushed but in a clear and measured way. The Government’s rush to find a GDF as soon as possible instead of as soon as practicable, as recommended by CoRWM1, has led to a stalled process. BANNG believes that the storage of ILW requires clear and measured consideration of a long-term siting process, the priorities of which should be safety and the environment; consideration should not be rushed due to financial constraints as this could open the way to incremental and ad hoc policy and to the pre-emption of sites as regional stores.
Wide public engagement and consultation
Despite its claims to the contrary (for example, as stated in Bill Hamilton’s letter printed in The Guardian on 21 June, 2013), the NDA seems to be undertaking selective consultation on this proposed optimisation of ILW storage in dealing only with stakeholders. The strategy paper has sections (2.4 and 3.7.1) devoted to stakeholder engagement with no mention of any public consultation. Local nuclear communities and the public in general are scarcely privy to the proposals. And, from the reported reaction to the proposals at the Bradwell Local Community Liaison Committee (LCLC) meeting on 15 May, 2013, it would seem that many stakeholders, too, were unaware of the NDA’s proposals.
As has been pointed out several times in this document, BANNG believes that public consultation on the storage of radioactive waste is vital. As stated by CoRWM1 in its Implementation Report, Section 3.1, item 25:
‘It is clear that CoRWM’s recommendations on implementation must be applied at least to new central or major regional stores at new locations if CoRWM’s recommendations are to inspire public confidence. The extent to which they should be applied to other new stores and existing stores is a matter for further consideration.’ (p. 10)
CoRWM1 recommended that local nuclear communities should not be taken for granted but that is what is happening.
BANNG believes that the NDA should engage with and consult the public and not only stakeholders on its proposals for the optimisation of storage of ILW. The NDA should not be claiming to do so when it clearly is not.
It would be interesting to know what risk assessment has been made of the possibility of terrorism in relation to ILW stores as this is not referred to in the strategy paper.
Under care and maintenance, it is proposed that the Bradwell site will be managed from a remote hub with occasional on-site monitoring. If packages of ILW were brought from other sites as they became available, the care and maintenance process would be compromised by the opening of the ILW store to accept them.
Communities local to Bradwell may not feel that the way in which the site will be managed when in care and maintenance, or the necessity to open the ILW store from time to time to receive wastes from other sites, constitute safe and secure storage. The threat of terrorism – or even of interference – should not be dismissed.
Recommendation 2 of the CoRWM1 Implementation Proposals (p. 13) states that ‘reviewing and ensuring security, particularly against terrorist attacks’ is an important part of storage.
BANNG agrees with CoRWM1 that it is important to review and ensure security at ILW storage sites, particularly against terrorist attacks and is concerned that management from a remote hub may be too light touch. It also believes that Bradwell should be left in a state of care and maintenance in 2015, as proposed by Magnox, and that the acceptance of wastes from other sites would compromise that state and should not take place.
It would be helpful if the pages of the strategy paper were numbered.
On p. 9, it would be useful to include a heading ‘Detriments’ before discussion of these. Otherwise, a casual reader may think there are only benefits from this proposal.
Under Section 3.4.2 ‘Safety and Environment Factors’ (p. 16), it is stated ‘Options which involve fewer storage locations require more transport of radioactive wastes, leading to increased:……’. BANNG believes that risk of accidents could give rise to public and worker radiation exposure.
The following is a summary of the points made in this paper:
· BANNG believes in the strategy of each site keeping its own waste;
· BANNG deplores the total inadequacy of public consultation by the NDA on the issue of storing ILW;
· BANNG believes that a piecemeal and ad hoc approach should not be taken to storage of ILW; rather what is required is a clear and measured approach;
· BANNG believes that the strategy for storage of ILW should give primacy to safety and the environment and should not be based on considerations of cost;
· BANNG believes that storage should be perceived as long-term, requiring a proper siting process that includes wide engagement and public consultation;
· BANNG believes that as local communities are expected to host the nation’s ILW, they should be given compensation to enhance their well-being; in the event of their being asked to host waste from other sites, they should be offered the same voluntary and partnership package as is being offered to potential host communities in the search for a GDF;
· as far as Bradwell is concerned, BANNG believes that once the site is in a state of care and maintenance in 2015, and given its vulnerable location on a shallow estuary, the long-term storage of ILW should not be considered here.
Varrie Blowers, Secretary and Media Relations Officer,
On behalf of the Blackwater Against New Nuclear Group (BANNG)
30 June, 2013
(2013) Call for Evidence – Managing Radioactive Waste Safely: Review of the siting process for a geological disposal facility, Evidence of the Blackwater Against New Nuclear Group (BANNG), BANNG Paper No. 19, June
[First Committee on Radioactive Waste Management (CORWM1)]:
(2006) Managing our Radioactive Waste Safely – CoRWM’s recommendations to Government, November
(2007) Moving Forward – CoRWM’s Proposals for Implementation, CoRWM document 1703, February