Wednesday, 14 November 2018

Large looms as hero for environmentalists


Letter  submitted to The Guardian:
Paul Brown’s obituary of the irreplaceable nuclear engineer and technical critic, John Large - an absolute hero of the environment movement - mentions his counter-expertise on a range of nuclear hazards (on line, 14 November; https://www.theguardian.com/environment/2018/nov/14/john-large-obituary).
His most important was on nuclear  (in-)security, on which he wrote a detailed and devastating report for Greenpeace on Sellafield, weeks after the terrorist assault on the Twin Towers and the Pentagon in the US in September 2001.*
Barely a week before John’s death, the Government’s official nuclear waste oversight quango, the committee on radioactive waste management (Corwm) published a series of new documents on matters within its remit. One, on nuclear transport, stated, inter alia:


“Many of the security specialists considered that there is a significant vulnerability to terrorist attack and misappropriation during [nuclear materials] transport. The type of material being moved influences the desirability or otherwise of transporting it. Highly radioactive material, such as spent nuclear fuel and  HLW [high level waste], is regarded by some members of the public and stakeholders as an attractive target for terrorists, although the robustness of the transport packages, the form in which the waste exists, the dispersibility of the radioactivity, the utility of the waste to terrorists, and the level of security arrangements, are all elements for assessment in respect of the potential dangers represented by transport. (CoRWM Position Paper: Transport Considerations; 25 October 2018; https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/753940/3467_O_Radioactive_Waste_Transport_Considerations.pdf)

Had John still been with us, he would have elaborated on why  nuclear transports are so dangerous, especially as ministers are determined to  significantly increase nuclear movements with new large GW ( gigawatt)  nuclear plants and small modular reactors(SMRs).
 
 
*
THE VULNERABILITY
OF
 
 
BRITISH NUCLEAR FUELS SELLAFIELD PLANTS
TO
 
 
TERRORIST ATTACK
CLIENT: GREENPEACE INTERNATIONAL
REPORT REF NO
R3074-A2
29 OCTOBER 2001
FOR RESTRICTED CIRCULATION ONLY
 
 
Although the basis of this Review is that any reasonably informed person could obtain the
information required for the assessment from publicly accessible sources, because of the sensitivity
of the issue Large & Associates have sought and agreed with Greenpeace International that the
detailed content of this Review will not be openly published, thereby denying any form of
assistance to international terrorism
 
Final Issue 29 October 2001 Issue 15
 
THE VULNERABILITY OF BNFL SELLAFIELD TO TERRORIST ATTACK
SUMMARY
 
 
In September international terrorists targeted the World Trade Center successfully demolishing the Twin Towers which,
together with the simultaneous attack on the Pentagon, cost 5,000 or more lives. Instead of using guns and conventional
explosives, the terrorists adopted and adapted high technology in the form of directing fully fuelled aircraft towards their
targets and, to do this, the individuals comprising each group of hijackers had to give their own lives. It is this demand for
mass casualties, in combination with technological prowess and willingness for the ultimate of self-sacrifices that breaks
open the hitherto taboo that terrorists will not attack highly hazardous plants.
International terrorism centres around but is not confined to attacks on the United States. Organised terrorism seems to pay
no heed to international borders, following the September atrocity active cells of Usama bin Ladin's group, al-Qaida, were
unearthed across continental Europe. Terrorism is adopting and adapting technology, the World Trade Center groups trained
for months to gain proficiency in piloting the aircraft and in 1995 the apocalyptic Aum Shinrikyo group itself developed and
manufactured the chemical agent released into the Tokyo subway, all at great cost using highly skilled technicians. It is
perhaps just a short and logical step for the terrorists to latch onto how highly hazardous plants themselves might be triggered
into releasing energy and toxins via an aerial attack. And if and when so, could it be that such plants cannot provide a robust
defence against an aerial attack and, if so, are there particularly vulnerable parts of the buildings and processes that, if
penetrated, could lead to a devastating release of energy and toxins?
The nuclear plants at Sellafield are such highly hazardous plants. The individual plants undertake a variety of processes,
some of which involve intensely radioactive materials and highly reactive chemicals. Moreover, being nuclear there is a
public perception of dread and fear (ie a fate worse than death) associated with radioactive release. However, to mount an
attack on Sellafield the terrorist cell would have to plan ahead, locate the particularly hazardous plants and stores, determine
the amount and nature of the radioactive contents and how readily this might be dispersed into the atmosphere, and to identify
the most vulnerable aspects of the buildings and containments of the targeted plants.
This Review examines how and by which means those planning such a hypothetical act of terrorism might obtain this sort
information. The Review has intentionally confined itself to information and documentation available in the public domain,
although it is assumed that those involved would either possess or successfully seek some relatively elementary knowledge of
building construction, radioactive materials and substances, reactor fuel, its radioactivity and chemistry.
The outcome of this Review is disturbing. First, it is relatively straightforward to obtain all of the information required by
 
simply accessing publicly available documents ministries and agencies of central government publish most of these sources
of quite detailed information. Second, the requirement that aircraft crash, irrespective of the forecast accident frequency, be
accounted for in the regulatory safety case was not introduced until 1979 for nuclear reactors and 1983 for chemical
separation and nuclear fuel plants such as those at Sellafield - examples of where the nuclear industry have taken this into
account, such as for the Sizewell B PWR, are almost dismissive of the risk solely on the basis that the calculated frequency
renders such an accidental event to be entirely incredible and, hence, there may have been little incentive to include for such a
remote event in the design. Third, nuclear plants such as Sellafield are almost totally ill-prepared for a terrorist attack from
 
the air the design and construction of the buildings date from a period of over 50 years, many of the older buildings would
just not withstand an aircraft crash and subsequent aviation fuel fire, some buildings, now redundant for the original purpose,
have been crudely adapted for storage of large quantities of radioactive materials for which they are clearly unsuited, and the
design of the most modern plants on the site does not seem to provide that much defence (in terms of containment surety and
segregation of hazardous materials) against an aerial attack.
In conclusion, a terrorist cell charged with attacking Sellafield could readily obtain sufficient information from publicly
available documents to identify highly hazardous and vulnerable targets on the Sellafield site for which there exists little
defence in depth. If there is a terrorist threat that puts Sellafield and other nuclear sites in the United Kingdom at risk then
the government agencies and ministries, and the operators themselves, should immediately review the material that is
presently available in the public domain.

 Finally, it should be noted that this Review has considered terrorist attack by aircraft crash, a mode of sabotage that was inconceivable just a month or so past. We now know that deliberate aircraft crash has to be defended against but what of the next attack, what shape and form will that take and how will plants like Sellafield be defended against it?
 

The nuclear regulator in the United State, the NRC, closed down all of its publicly accessible web sites in order to review the content of the web pages
shortly following the 11 September incident.
 
 
 
 
 

Friday, 9 November 2018

Nuclear Meltdown; Moorside atomic plant abandonned as economics trumps propaganda


 

In the early hours of Thursday morning came the announcement from  half way across the world in Tokyo, that  the Japanese electrical conglomerate had pulled the plug on its UK subsidiary NuGen ( Nuclear Generation Ltd), the consortium tasked with developing the £15bn Moorside new-build project in West Cumbria. In its press statement, Toshiba’s Board said in devastating bluntness:

 After considering the additional costs entailed in continuing to operate NuGen, Toshiba recognises that the economically rational decision is to withdraw from the UK nuclear power plant construction project, and has resolved to take steps to wind-up NuGen”.

The statement added that Toshiba said it expected to “take a hit” of £100.5m (18.8bn Japanese yen) from the withdrawal from the disastrous industrial contract. (Toshiba Press Release 8th Nov 2018.
http://www.toshiba.co.jp/about/ir/en/news/20181108_4.pdf

The hyperbolic and nonsensical response from trades union GMB national officer Justin Bowden was: "The British government has blood on its hands". The usually staid Times business commentary observed “Moorside's nuclear dreams [have been] looking nightmarish ever since the Nugen project's champion, Japan's Toshiba, went into financial meltdown.”

 And concluded: “So two key questions spring to mind. What'll replace it? And should it be nuclear? As the Energy and Climate Intelligence Unit points out, offshore wind and solar power is already cheaper - as is gas. Throw in smart grids, energy saving and battery technology and the case for overpriced nukes vanishes. Toshiba is proof of the dangers.” (The Times Business, 9 Nov 2018;
https://www.thetimes.co.uk/article/0c99973c-e39a-11e8-9838-efa7e96cbe2b

Nugen's chief executive, Tom Samson, said the company had been unable to find a buyer for the project because there was too much "policy and legislative risk" as the government reviews the financial support on offer for nuclear plants. The same paper recalled that when the UK Government gave the green light to the Hinkley Point C plant just two years ago, the business secretary, Dr Greg Clark,  hailed the decision as the start of "a new era of UK nuclear power...the first of a wave of new nuclear plants", with 5  more  proposed around the country.” It concluded: “Despite the financial hit (an estimated £100 million), the company's share price has leapt. The lesson is that market confidence in Britain's nuclear industry is far from high….Once, it  [Moorside] was supposed to be powering six million homes by 2023. Today it is unclear if it will ever power even one (The Times, 9 Nov 2018; https://www.thetimes.co.uk/article/f36ba6da-e39c-11e8-9838-efa7e96cbe2b; https://www.thetimes.co.uk/article/4a626bd4-e3a4-11e8-9ca5-2dc8c6b25903; https://www.thetimes.co.uk/article/c821a6a0-e397-11e8-9838-efa7e96cbe2b)

 “This is a huge disappointment and a crushing blow to hopes of a revival of the UK nuclear energy industry,” Tim Yeo, the chair of pro-nuclear lobby group New Nuclear Watch Institute and a former Tory MP told the Guardian. Greenpeace UK’s executive director, John Sauven, wryly said: “The end of the Moorside plan represents a failure of the government’s nuclear gamble.” But form every cloud comes a silver lining, and the collapse of the scheme should be seen as an opportunity rather than a risk, for the UK to prioritise renewables instead. Jonathan Marshall, an analyst at the ECIU think tank, said: “Shifting away from expensive, complicated technology towards cheaper and easier to build renewables gives the UK the opportunity to build an electricity system that will keep bills for homes and businesses down for years to come.” The Guardian, 8 Nov. 2018; www.theguardian.com/environment/2018/nov/08/toshiba-uk-nuclear-power-plant-project-nu-gen-cumbria; www.theguardian.com/business/2018/nov/08/toshibas-failure-shows-business-cant-deliver-a-nuclear-future; CORE 8th Nov 2018
http://corecumbria.co.uk/briefings/nugen-to-nogen-consortium-liquidated-by-toshiba-as-it-abandons-moorside-new-build/)

Four years ago, American reactor safety expert Arnie Gundersen a former US nuclear regulator turned whistle blower who accepted an invitation from local Cumbrian campaigning group, Radiation Free Lakeland, to speak about the Moorside plan way back in 2014.  Gunderson - and another equally qualified nuclear expert, independent expert, Dr Ian Fairlie, were considered too controversial by local grandees and banned from speaking at a local hall in Keswick, forcing the venue to be switched to the Skiddaw Hotel. Once again independent expertise has trumped blinkered  nuclear industry and  Government advisors: and now even nuclear indulgent Toshiba agree with these more insightful and smarter experts! (Radiation Free Lakeland 8th Nov 2018
https://mariannewildart.wordpress.com/2018/11/08/we-did-it-maybe-did-we-just-stop-moorside/
)

Over the past few years I have attended several meetings with energy ministers and officials of the business and energy department (BEIS) and its predecessors DECC, BIS, etc, during which myself and other attendees from environmental organisations have argued nuclear power is both ecologically and economically unsustainable. 

Our analysis and arguments were consistently rejected. 

Now the hard headed board of Japanese nuclear investor, Toshiba, has taken an important decision that agreed with our economic evaluation.

The last thing we now want to happen is to do as the GMB and Prospect trades unions want, to artificially subsidise  new nuclear reactors, and electricity bill payers and the taxpayer are forced to step in where experienced nuclear plant builders and operators have understandability feared to tread. 

The atomic dinosaur should be put to rest. 

Wednesday, 31 October 2018

Plutonium problems dominate inadequate UK radioactive waste strategy


NDA radioactive waste management strategy

Response to public consultation

by Dr David Lowry

member, Nuclear Waste Advisory Associates (UK)

Senior international research fellow

Institute for Resource and Security Studies

Cambridge

Massachusetts  02139 

USA

 
31 October 2018

Introduction

On the last morning of the period for this consultation, 12 hours before the end of the consultation, the respected and influential House of Commons Public Accounts Committee (PAC) published a swingeing critique of radioactive waste management at NDA-owned Sellafield, nuclear waste and fissile materials storage plant  where the vast bulk of the UK’s radioactive waste burden is located. (https://publications.parliament.uk/pa/cm201719/cmselect/cmpubacc/1375/137502.htm)|

The day before the consultation was planned to close, Sellafield Ltd, who work very closely with the NDA chose to release another very relevant report, Sellafield medium to    long term research needs , (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/752392/Sellafield_Medium_and_Long_Term_Research_Needs_2018.pdf)

The very late release of these two reports complicates the ability of  interested parties to  respond to the consultation. However, as a result of these two publications, I have redrafted my reply to take into account the specific concerns the MPs raise over plutonium management.

Commentary

The paragraph below comprises the PAC report’s very critical conclusions on the current status of  plutonium management at Sellafield.

The NDA’s programme to deal with the plutonium stockpile in the near term is late and its costs are increasing. (emphasis added|)

 The Department [BEIS] is no closer to understanding what to do with plutonium in the long term. Sellafield is home to 40% of the world’s global stock of plutonium. The Department is responsible for setting the government’s policy for dealing with plutonium in the long term. In 2014, we reported that the Department did not have a strategy in place for the plutonium stored at Sellafield. The Department has still not decided between the two options available to it: readying the plutonium stockpile for long-term storage in a geological disposal facility (that has yet to be constructed); or reusing it as fuel in new nuclear power stations. In the meantime, the NDA is responsible for ensuring that the plutonium currently at Sellafield is stored safely and securely. It has a programme in place to do so, which consists of projects to repackage plutonium canisters for long-term storage until the Department decides what to do with them. However, the NDA has recently discovered that some of the plutonium canisters have been decaying faster than expected. This concerning development is made worse by the fact that the NDA’s project to repackage these canisters is at least two years late and expected to cost over £1.5 billion, £1 billion more than it first expected. The NDA told us that it has put in place a series of contingency arrangements to manage these decaying canisters.

But these are short-term fixes for a long-term problem and the Department has yet to set out clearly what its strategy is and the associated costs to the taxpayer.

Recommendation: Within six months, the Department should write to the Committee, setting out its plan for deciding on the long-term use of plutonium. The NDA should also write to the Committee explaining fully its contingency arrangements to manage plutonium at the site, and the reasons behind cost escalations and delays.

NDA’s Integrated radioactive waste management strategy executive summary,issued on 30 July 2018, states:

“In the 2016 NDA Strategy we made a commitment to develop a single radioactive waste strategy for the NDA Group. This strategy applies to all radioactive waste generated within the NDA estate, (including materials that may become waste at some point in the future).  The radioactive waste strategy provides a high level framework within which waste management decisions can be taken flexibly, to ensure safe, environmentally acceptable and cost-effective solutions that reflect the nature of the radioactive waste concerned.   A single radioactive waste strategy provides a consolidated position and greater clarity of our strategic needs in this area; promotes cross-category waste management opportunities; supports a risk-based approach to waste management and provides an integrated programme to deliver suitable and timely waste management infrastructure to support the NDA mission.”

Like motherhood and apple pie, it is impossible to oppose this proposition. However, because of the indecision over the future fate of the 140,000kilogrammes of plutonium at Sellafield, integrating its custody into the overall waste management strategy is  hamstrung.

As the PAC states, Government indecision has left the NDA unable to decide plan between: “readying the plutonium stockpile for long-term storage in a geological disposal facility (that has yet to be constructed); or reusing it as fuel in new nuclear power stations

NDA should press ministers to decide on declaring all the separated plutonium as a waste, as there is no  UK facility available to turn it into a fuel; and to construct one bespoke at Sellafield is likely to cost billions of pounds; there is no   national or international market that makes  plutonium-based mixed oxide (MOX) fuel economically competitive, and any re-use of plutonium in MOX nuclear fuel increases manifold the  opportunities for terrorists to disrupt facilities and transports, and  continued plutonium infrastructure  creates conditions for proliferation (see the new 150-page international study covering, UK. Belgium, France, Germany, Japan, Netherlands, and Switzerland ‘Plutonium for Energy: explaining the global decline of MOX’ edited by Alan J. Kuperman, Nuclear Proliferation Prevention Project, University of Texas at Austin, October 2018; http://sites.utexas.edu/prp-mox-2018/files/2018/10/Plutonium-for-Energy-2018-Oct-19-book-style.pdf)

 

The Sellafield Ltd report on  research priorities states that amongst the technology  priorities is work on : Novel materials which may have the potential for future uses or to replace existing materials.

 

I believe that NDA/Sellafield Ltd  needs to prioritise the urgent development to ceramic matrices to immobilize the plutonium currently being stored in inadequate temporary canisters in the Sellafield Plutonium store, in readiness for long- term secure stewardship.

 

As a start Sellafield Ltd should publish the joint research it has done collaboratively with the  national Australian Nuclear Science and Technology Organisation (ANSTO), Nexia Solutions and the National Nuclear Laboratory (NNL) on plutonium containment.


 

 

Endnote:

 

I share NDA’s stress on the importance of information governance. So the paragraph

5.2.2 on Information governance is concerning for what it omits. It asserts: ”we will work with our SLCs, subsidiaries and regulators to ensure that effective knowledge management systems are maintained.”

 

The fact this omits  to include  nongovernmental  environmental group (ngo) stakeholders, interested academics  and trades unions, limits the  scope of the governance of information to a too narrow group, The wider stakeholder community needs to  be incorporated, and participation needs to be paid for, including  the independent expertise these stakeholders may wish to invite to participate.

 

NDA needs to be involved in the European Joint Programming first  round of co-operation on long term radioactive waste management, which will start its collaborative research  in 2019,  and which does include ngos and independent experts

 

Para:5.2.2

 

“Effective and robust information and knowledge management systems are necessary for the development of strategic opportunities for the implementation of the baseline plan. Furthermore, knowledge retention over very long timescales, such as many decades to a century or more, is an essential consideration.  The ultimate product of radioactive waste management is a waste package and its associated waste package record. The waste package record has to support future operations over the lifetime of the waste package namely interim storage, transport and disposal. The requirements around what information constitutes a waste package record for each step are broadly the same but there are some specific differences and so each lifecycle step must be considered.  Plans are already in place to ensure that a robust information governance process is in place and we will work with our SLCs, subsidiaries and regulators to ensure that effective knowledge management systems are maintained”

 

 

Annex 1

 

This is part of the new PAC repoirt with most worrying  sections highlighted.-DL

Progress and constraints to reducing risk at Sellafield

Nuclear Decommissioning Authority: risk reduction at Sellafield



1.On the basis of a report by the Comptroller and Auditor General, we took evidence from the Department for Business Energy & Industrial Strategy (the Department), the Nuclear Decommissioning Authority (NDA), Sellafield Limited and UK Government Investments (UKGI) to examine the NDA’s progress with reducing risks at Sellafield.

2.The NDA is a non-departmental public body, sponsored by the Department and overseen by UKGI. The NDA is responsible for operating and decommissioning 17 nuclear reactor and research sites in the UK. Sellafield is the largest and most hazardous of the NDA’s sites, home to ageing facilities that store radioactive nuclear materials, including 40% of the global stockpile of plutonium. The NDA oversees and funds the work of Sellafield Limited, a site licence company tasked with daily operations to decommission the site. It also carries out other commercial activities, such as reprocessing spent fuel, that generate an income for the Exchequer. In 2017–18, the NDA spent £2 billion on activities at Sellafield. It expects operations to decommission Sellafield to continue for over 100 years at an estimated cost of £91 billion.

4.The NDA’s biggest challenges, and those that post the highest risks at Sellafield, include decommissioning four legacy ponds and silos, and managing plutonium stores. The Office for Nuclear Regulation regards these risks to be intolerable, meaning the NDA should prioritise reducing the risk in these facilities, and that other considerations, such as funding, should not hinder its progress in doing so. The NDA estimates that it will take decades to decommission these facilities. For example, the Magnox swarf storage silo, considered the greatest risk at Sellafield, will pose a significant risk until 2050, when work to retrieve the waste is expected to complete. For these programmes to proceed, they often require the successful completion of one or more major projects which means that progress at Sellafield must be assessed through at both programme and project level. The NDA has a set of 14 major projects that support the completion of these long-term programmes of work, with a lifetime cost of £6 billion.

Constraints to faster progress

9.The NDA and Sellafield Limited told us that their strategy for decommissioning Sellafield is based on prioritising the reduction of the highest risks first. The NDA and the Department confirmed that Sellafield Limited’s ability to carry out its work is not constrained by the available of funding. The NDA and Sellafield Limited consider that there are, however, three factors that constrain their ability to make faster progress at Sellafield. These are: the physical congestion of the Sellafield site; challenges to workforce productivity; and the complexity of the decommissioning task, which often requires bespoke innovative technologies, such as the six new reinforced doors the NDA recently installed at the side of the pile fuel cladding silo that has enabled Sellafield Limited to start the retrieval of waste materials earlier.

10.The NDA and Sellafield Limited told us that turning Sellafield Limited into a direct subsidiary has allowed for more innovative thinking around these constraints. Sellafield Limited also said that its new masterplan takes into account the congestion of the site. However, we were concerned that the NDA and Sellafield Limited have not carried out any analysis to understand how and to what extent these perceived constraints affect the pace of, and options for, decommissioning. Without this thorough understanding, the NDA and Sellafield Limited cannot be sure that their strategy for decommissioning the site is the right one, nor can we be sure that they are doing everything they can that they are doing everything they can to reduce risk at Sellafield as quickly as possible.

Lessons learned

11.The NDA has cancelled three major projects since 2012 because it says it has found more cost-effective ways to complete the work. The NDA spent £586 million in taxpayer money on these projects before it decided to cancel them. For two of the cancelled projects, the Silo direct encapsulation (SDP) plant and the Box transfer facility, the NDA expected combined cost overruns of £2.1 billion and delays of over 9 years before it decided to write them off. The NDA told us that to comply with the Office for Nuclear Regulation, it must always have a strategy in place to manage high-risk facilities. It therefore progressed work on the SDP project because it was the most technically advanced option at the time. Meanwhile, it worked with universities to pursue other strategies that would simplify the work and make it more cost-effective.

12.The NDA also cancelled a third project that involved building new storage tanks to store highly active liquor. It told us that following its decision to end reprocessing activity at Sellafield in 2020, the Office for Nuclear Regulation agreed to allow Sellafield Limited to use two tanks, previously kept empty to provide reserve capacity, in place of building new tanks. Sellafield Limited told us that while the regulator has been holding it to account, it has also been supportive in trying to find new ways of completing the work on the site more quickly and cost-effectively.

13.The NDA and Sellafield Limited have not quantified what, if any, benefits have been derived from these incurred costs and the work undergone up to the point the projects were cancelled. The NDA asserted that it would find alternative uses for some cancelled projects, like the box transfer facility. It also told us it is getting better at learning the lessons from strategy changes and from past mistakes. But it acknowledged that it is not yet able to evaluate to what extent changes in strategy have generated savings to the taxpayer.

Progress with managing plutonium

14.The Department is responsible for setting government policy for dealing with the UK’s stock of plutonium in the long term. The Department told us that there are two options available: readying plutonium for long-term storage in the geological disposal facility (GDF) that the Department expects will be available by 2048; or reuse the plutonium as fuel in new nuclear power stations. Either option would require several decades to be implemented. When we last examined the Department’s progress in dealing with the UK’s stock of plutonium in 2014, we found that, while the Department’s preferred option was to reuse plutonium as fuel, there was not yet a market, or any power stations, that required fuel from reused plutonium. Four years later, the Department is not any closer to deciding a course of action. It told us that is not comfortable with any of the potential options for managing plutonium other than disposing it in the GDF. In the meantime, the NDA must ensure that the stockpile currently at Sellafield continues to be stored safely and securely for decades to come.

15.The NDA asserted that it faces three main challenges in managing the plutonium stockpile at Sellafield. First, the majority of the plutonium canisters need to be repackaged to ensure they can be safely stored over the long term. The NDA’s project to build a repackaging plant at Sellafield to enable this is still in the early design phase. The project is already experiencing significant delays and is expected to cost £1 billion more than originally planned. Secondly, the NDA has recently discovered that a number of plutonium canisters are decaying faster than it had expected. These canisters will need to be repackaged before the repackaging plant is available, so the NDA will have to implement contingency plans in the meantime. Lastly, the two stores that the NDA are constructing to hold these canisters are expected to cost £200 million more than expected. The NDA has not yet set out its strategy for these contingency arrangements or their associated costs.



16 Qq 21, 60, 62

21 Qq 74–78, 82

28 Qq 17, 46, 47, 53


Annex2

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/752392/thumbnail_Sellafield_Medium_and_Long_Term_Research_Needs_2018.pdf.png


PDF, 8.07MB, 32 pages