The UK Government
launched on 11 January - with a media fanfare- its long delayed 150-page national
environmental strategy (for England) titled
'A Green Future:
Our 25 Year Plan to Improve the Environment (https://www.gov.uk/government/publications/25-year-environment-plan).
Prime
Minister May asserted in her foreword: “We hold our natural environment in
trust for the next generation. By implementing the measures in this ambitious
plan, ours can become the first generation to leave that environment in a
better state than we found it and pass on to the next generation a natural
environment protected and enhanced for the future.
……. We will
use this opportunity to strengthen and enhance the protections our countryside,
rivers, coastline and wildlife habitats enjoy, and develop new methods of
agricultural and fisheries support which put the environment first.”
In his own foreword,
Environment Secretary Michael Gove added:“Environment
is – at its roots – another word for nature, for the planet that sustains us,
the life on earth that inspires wonder and reverence, the places dear to us we
wish to protect and preserve. We value those landscapes and coastlines as goods
in themselves, places of beauty which nurture and support all forms of
wildlife….We will underpin all this action with a comprehensive set of
environmental principles. To ensure strong governance, we will consult on plans
to set up a world-leading environmental watchdog, an independent, statutory
body, to hold Government to account for upholding environmental standards.”
These warm
green words are, however, not backed up with the kind of action that recognizes the real environmental priorities with
which ministers need to get a grip.
The most egregious
omission for action is anything to halt, reverse and deal with nuclear
industry radiological pollution and
nuclear waste from power generation, spent irradiate nuclear fuel reprocessing and nuclear warhead production.
Chapter 4is
titled’ Increasing resource efficiency and reducing pollution and waste’ but
makes zero mention of nuclear waste or radiological pollution, but does expend
time and effort addressing far less
ecologically damaging no radiotoxic
waste pollution. Here is an extract:
iv. Improving
management of residual waste
Since 2000 we have diverted
significant quantities of residual waste – i.e. waste that cannot be reused or
recycled – from landfill through the development of energy from waste (EfW)
facilities. These generally recover energy from the waste to produce
electricity. In 2016/17, some 38% of waste collected by Local Authorities went
to EfW compared with 16% that went to landfill. More can be done however. We
want to make sure that materials ending up in the residual waste stream are
managed so that their full value as a resource is maximised and the impact on
the environment of treating them is minimised.
We
will continue to encourage operators to maximise the amount of energy recovered
from residual waste while minimising the environmental impact of managing it,
for example by utilising the heat as well as electricity produced. The actions
set out in this Plan will help us build on this to ensure that the value of
residual waste as a resource is fully realised and that emissions of carbon dioxide
during the energy recovery process are kept as low as possible. We must bear in
mind that any infrastructure must be able to adapt to future changes in the
volume and make-up of residual waste generated and developments in technology.
That way, waste is not locked into residual waste treatment processes when it
could be reused or recycled. (page 94)
Annex 2 of the two Government
reports on Environment 25 titled Government
strategies to protect and improve the environment (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/673160/25-year-environment-plan-annex2.pdf
comprises of nearly 50 “strategies and plans for some of the
government’s work to protect and conserve the environment,” but contains not
one report that addresses environmental protection from radiation or from
nuclear industry operations!
However,
two days before the 25-year green strategy was issued, the Government quietly
released ( to absolutely zero media attention) a 221- page document that explains
how it plans to deal with nuclear waste
in the UK. Clearly ministers wanted attention on plastic waste policy, but none fro
radiaoctive waste policy.
The report,
titled UK's sixth national report on
compliance with the obligations of the Joint Convention on the safety of spent
fuel and radioactive waste management states it “considers each of
the Joint Convention’s obligations and explains how the United Kingdom
addresses them."https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/672640/20171020_-_UK_Sixth_National_Report_to_the_Joint_Convention.pdf )
Document
The reveals that the “
Office for Nuclear Regulation (ONR) prepared this report on behalf of the
Department for Business, Energy and Industrial Strategy (BEIS) in consultation”
with and incorporating contributions from:
•
Civil Aviation Authority
•
Department for Business, Energy and Industrial Strategy
•
Department of Health
•
Dounreay Site Restoration Limited
•
EDF Energy Limited
•
Environment Agency
•
Food Standards Agency
•
GE Healthcare
•
Public Health England
•
UK Home Office
•
Low-level Waste Repository Limited
•
Magnox Limited
•
Maritime Coastguard Agency
•
National Nuclear Laboratory
•
Natural Resources Wales
•
Northern Ireland Environment Agency
•
Nuclear Decommissioning Authority
•
Radioactive Waste Management Limited
•
Scottish Environment Protection Agency
•
Scottish Government
•
Sellafield Limited
•
Springfield Fuels Limited
•
Urenco UK Limited
• Welsh Government
Here are some of its more interesting
revelations, which should not leave environment ministers sanguine:
Whilst the UK has other
types of sites that generate relatively small volumes of Low-level Waste (LLW)
including disused radioactive sources, such as hospitals, educational
facilities and non-nuclear industries, the UK’s policy is to primarily focus
its report on the arisings of radioactive waste that occur from the UK’s
nuclear industry. As such, wastes contaminated with Naturally Occurring
Radioactive Materials (NORM) are not explicitly included in the scope of this
report.(p.30)
The ONR considers that
an additional risk of death to an individual of one in a million per year, is
‘broadly acceptable’ to society in line with the tolerability of risk framework
(p.38)
The UK Government
considers this liability regime should not apply to low-level waste disposal
sites, such as landfill facilities. This is on the basis that those sites do
not present a sufficient level of risk to warrant compliance with the
requirements of the Paris regime and has sought exclusion for such sites
through the Organisation for Economic Co-operation and Development (OECD)
Nuclear Energy Agency (NEA) Nuclear Law Committee. (p.3)
Waste disposed of at the
Low Level Waste Repository [LLWR at Drigg] is placed in metallic Intermodal
Shipping Containers (ISO). Any voidage inside the containers is minimised by
filling with grout at LLWR and the containers are then placed in engineered
concrete-lined near-surface vaults. At 1 April 2017, the containers occupied
227,650 m3 of vault space (compared to the 2013 UK Radioactive Waste Inventory
(RWI), the granting of the revised permit in November 2015 and the planning
permission in July 2016 enabled the containers in both Vaults 8 and 9 to be
classed as disposed). Consignments to the LLWR over the past ten years have
totalled about 67,170m3.(p.22)
Defueling of both
Calder Hall and Wylfa is expected to finish in 2019 and based on a lower bound
reprocessing performance of 450 tU per year, Magnox fuel reprocessing will
complete by December 2020. (p.5)
The UK Government believes that
spent fuel should not be categorised as a radioactive waste so long as the
option of reprocessing remains open and a practicable future use for the fuel
is foreseen. However, the Government is currently not expecting any proposals
to reprocess spent fuel from proposed new nuclear power plants in the UK and
therefore spent fuel from these power stations will be designated as HAW in due
course….
The UK Government conclude that
it is technically possible to dispose of new higher activity radioactive waste
in a GDF and that this would be a viable solution and the right approach for
managing waste from any new nuclear power stations, including spent nuclear
fuel. (pp.9-10)
Due to associated
radioactive discharges to the marine environment, the conclusion of Magnox
Reprocessing is a consideration within the UK Strategy for Radioactive
Discharges and the OSPAR Convention.(p.10)
Electricité de France
(EDF) Energy has contracts in place for the potential reprocessing of
approximately 5,500te of its spent AGR fuel at Sellafield (see Figure 3).
Rather than being reprocessed, spent AGR fuel in excess of this contracted
quantity will be stored underwater in the Thermal Oxide Reprocessing Plant
(THORP) Receipt and Storage Ponds in the near-term. The THORP Receipt and
Storage Ponds are expected to store between 5,500te and 6,000te of spent AGR
fuel. The historic Fuel Contracts cover the period to 2086; activities beyond
this contracted period will be the responsibility of EDF Energy. (p12)
The NDA has decided
to reprocess specific exotic fuels, including Steam-Generating Heavy Water
Reactor (SGHWR) and Dounreay Fast Reactor (DFR) fuel, alongside bulk fuels
which have common characteristics. (p.12)
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Some exotic fuels are
not suitable for reprocessing in the current facilities. These fuels will
continue to be safely and securely stored pending development of final
disposition options. For example, the NDA has decided to store mixed oxide
fuels from the Prototype Fast Reactor (PFR, Dounreay) alongside AGR fuel. In
the event that not all of DFR fuel can be reprocessed alongside Magnox fuel,
the NDA will develop an alternative option for the DFR material so that it
can be managed at Sellafield (p.13)
A further 33 tonnes {following
11 tonnes already removed] of breeder material remains inside the Dounreay
Fast Reactor (DFR) and is also scheduled
to be transported to Sellafield. Purpose-built retrieval equipment has been
installed above the reactor; shipments of all of the remaining material to
Sellafield has commenced.(p.15)
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to avoid the UK becoming a net
importer of nuclear waste, where appropriate the NDA can employ “virtual
reprocessing” whereby title is taken to materials, where necessary, and a
radiological equivalent amount of waste (from existing stocks at Sellafield) is
allocated to a customer as if reprocessing had taken place, and the waste is
returned to the customer, except for
those instances where repatriation of a very small amount of waste is
uneconomic. (emphasis added)The NDA is currently in the process of
implementing this policy as a means of completing the overseas contracts.(p.28)
The Environment Agency
has published Enforcement and Sanctions
Statement, Guidance and Offence Response Options (ORO) that explain how the
Environment Agency makes enforcement decisions, the types of tools available
and associated processes. These range, for example, from providing advice and
guidance through to prosecution.(p.46)
With the support of
NDA, the UK Government is continuing to develop its policy on the management of
separated plutonium. At this time, the NDA holds its uranics at a nil value
pending development of long-term options and cost estimates. In the future,
assessments may ascribe a value or a liability to each type of uranic material.(p.54)
There is no legal requirement to consult members of
the public with respect to licensing decisions. (emphasis added) However,
the ONR aims to be open and transparent in publishing the basis for its
regulatory decisions to help all of its stakeholders, including the public, to
understand its work.(p.55)
The Secretary of State
can issue a direction as to ONR’s exercise of its functions. A direction may
modify a function of The ONR but (except in matters of national security)
cannot be given in relation to the exercise of a regulatory function in a
particular case. (p.58)
Realisation that a
reprocessing programme is within a few years of closure brings with it both
challenges and opportunities. The challenges include maintaining focus within
the operations / maintenance team in order to deliver safe operations and
successful closure. Preparing for the first stage of decommissioning will
involve a substantially smaller team undertaking generally familiar waste
management activities. A significant number of roles will become surplus
providing an opportunity to match the aspirations of individuals to the needs
of the organisation viewed over a period of several years. An important
consideration is the socio-economic impact within the host community as the
site nears the end of decommissioning. (p.63)
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Audited accounts of the
NDA are made available to the public via the NDA’s website and include more
information. The NDA’s funding is discussed in Section L.1 – Legislative and
Regulatory System; the total planned expenditure for the financial year 2017 to
2018 is £3.24 billion.(p.65)
Under the site licence
conditions, the licensee is required to make and implement adequate
arrangements for dealing with any accident or emergency arising on the site and
its effects. All nuclear licensees are required to prepare, in consultation
with local authorities, the police, and other organisations, emergency plans
for any nuclear and non-nuclear emergency which may occur on their site.
Licensees must submit to the ONR for approval their high-level emergency
arrangements for each site, usually known as the Emergency Plan….
Licensees are also
required to rehearse their arrangements to ensure their effectiveness. This is
achieved by the licensee holding training exercises and the ONR agreeing to a
programme of demonstration emergency exercises that the ONR inspectors observe;
they then judge the adequacy of their effectiveness and the ONR may request the
licensee to repeat elements of an emergency exercise that have not been deemed
adequate. In 2015, the ONR introduced additional assurance to the licence
conditions’ arrangements through the application of on-site emergency planning
and response capability maps. These capability maps assess both the security
and safety aspects of each site’s emergency response. (p.81)
Annex
This statement on nuclear
energy policy was made by BEIS secretary Greg Clark on the same day as the 25-year
green report was released. It also went entirely unreported by the media.
WS Department for Business, Energy and Industrial
Strategy
Made on: 11 January 2018
Energy Policy
The UK has benefited from its membership of the European
Atomic Energy Community since joining the EU and Euratom in 1973. The
Government’s ambition is to maintain as many of these benefits as possible
through a close and effective association with Euratom in the future, after the
UK withdraws from Euratom, at the same time as withdrawing from the EU, on 29
March 2019. Our plans are designed to be robust so as to be prepared for a
number of different scenarios including the unlikely outcome that there is no
future agreement at all. Our number one priority is continuity for the nuclear
sector.
Since the 1950s, when the UK launched the world’s first
nuclear power station, this country has been a leading civil nuclear country on
the international stage, with deep nuclear research and nuclear decommissioning
expertise, and with nuclear power playing a vital part in our electricity
generation mix. It is vitally important that our departure from the EU does not
jeopardise this success, and it is in the interests of both the EU and the UK
that our relationship should continue to be as close as possible. We recognise
and understand the concerns that the nuclear industry has raised. We agree it
is essential that projects and investment are not adversely affected by the
UK’s withdrawal from the EU, and can continue to operate with certainty.
To achieve this outcome, the Government’s strategy is
twofold: through negotiations with the European Commission we will seek a close
association with Euratom and to include Euratom in any implementation period
negotiated as part of our wider exit discussions; and at the same time, to put
in place all the necessary measures to ensure that the UK could operate as an
independent and responsible nuclear state from day one.
Our strategy is therefore based on the following
principles:
· to aim
for continuity with current relevant Euratom arrangements;
· to
ensure that the UK maintains its leading role in European nuclear research;
· to
ensure the nuclear industry in the UK has the necessary skilled workforce
covering decommissioning, ongoing operation of existing facilities and new build
projects; and
· to
ensure that on 29 March 2019 the UK has the necessary measures in place to
ensure that the nuclear industry can continue to operate.
The Government has made good progress on separation
issues in the last few months as part of Phase One of negotiations with the EU.
Negotiations have covered a set of legal and technical issues related to
nuclear material and waste, and safeguards obligations and equipment. The next
phase of discussions will focus on the UK’s future relationship with Euratom.
We believe that it is of mutual benefit for both the UK and the EU to have a
close association with Euratom and to ensure a future safeguards regime that
will be equivalent in effectiveness and coverage as that currently provided by
Euratom, including consideration of any potential role for Euratom in helping
to establish the UK’s own domestic safeguards regime.
The UK’s specific objectives in respect of the future
relationship are to seek:
· a close
association with the Euratom Research and Training Programme, including
the Joint European Torus (JET) and the International Thermonuclear Experimental
Reactor (ITER) projects;
· continuity
of open trade arrangements for nuclear goods and products to ensure the
nuclear industry is able to continue to trade across EU borders without
disruption; and
· maintaining
close and effective cooperation with Euratom on nuclear safety.
We understand the importance to businesses and
communities, including those in the nuclear sector, of being able to access the
workforce they need. Proposals for our future immigration system will be set
out shortly and we will ensure that those businesses and communities, and
Parliament have the opportunity to contribute their views before making any
decisions about the future system.
Whatever the outcome of the negotiations with the EU, it
is vital that Government pursues all options for providing certainty for the
civil nuclear industry that it will be able to continue its operations,
including that the UK has a safeguards regime that meets international
standards by the end of March 2019 and that necessary international agreements
are in place. Such elements are not dependent on the EU negotiations and the UK
Government is well advanced in delivering this plan.
The UK is: establishing a legislative and regulatory
framework for a domestic safeguards regime – the Nuclear Safeguards Bill will,
subject to the will of Parliament, provide legal powers for the Secretary of
State to establish a domestic regime which the Office for Nuclear Regulation will
regulate; negotiating bilateral safeguards agreements with the International
Atomic Energy Agency; and putting in place bilateral Nuclear Cooperation
Agreements with key third countries.
As set out by the Prime Minister, the UK Government is
proposing a time-limited implementation period where we continue to have access
to one another’s markets on current terms and take part in existing security
measures. This implementation period would cover Euratom too. The exact nature
of the period will be subject to forthcoming negotiations including on the
issues outlined in this statement.
As discussions with the EU move
onto the important issue of the future relationship, I shall report back every
three months about overall progress on Euratom, covering the EU negotiations
and other important matters covered in this statement, by way of further
Written Statements to keep Parliament updated.
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