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
PDF, 8.07MB, 32
pages
