Friday, 12 January 2018

Nuclear polluting elephant in the great green room

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 (


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 (

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." )


(The fifth report was published in January 2015.)


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)
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)
Several Final stage Letters of Compliance (fLoC) have been issued by RWM since the last UK report, which have been key to enable the continuation of high priority decommissioning activities. In particular, fLoCs have been issued to:
• Magnox Ltd. for:
• the packaging of Ion Exchange materials in 500 litre robust shielded drums originating from Bradwell and Dungeness A;
• the packaging of Miscellaneous Intermediate Level Wastes in 500 litre robust shielded drums arising from fuel pond clean-up operations at Bradwell; and
• the encapsulation of wastes arising from decommissioning activities at Hunterston A and Trawsfynydd in 3 m³ boxes and drums.
Sellafield for:
• the packaging of Pile Fuel Storage Pond sludges at the existing Wastes Encapsulation Plant in support of high hazard risk reduction from the legacy fuel pond; and
• packaging of 100% Rotary Skip Wash Debris through the Magnox Encapsulation plant in support of improved operation of the Sellafield Fuel Handling Plant;
• In addition, a fLoC has also been provided for the packaging of Dragon fuel at the Sellafield Magnox Encapsulation Plant. The transfer of the Dragon fuel from Harwell Nuclear site to Sellafield will be a key enabler to the de-licencing of the Harwell site. (pp.26-27)


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)

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)




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

Made by: Greg Clark (Secretary of State for Business, Energy and Industrial Strategy )


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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