10th November 2005

The Gloucestershire Green party's response to the Nuclear Decommissioning Authority's Proposed Strategy 


1. Magnox decommissioning should happen sooner rather than later with on-site storage

The NDA proposed strategy for decommissioning the Magnox reactors states: "We believe that the argument for decommissioning the Magnox reactors within 25 years warrants serious evaluation and we propose to work with the industry and regulators to do this."

The Gloucestershire Green party welcomes this approach because 98% of the gamma radiation and 99% of the inventory of radioactivity has gone within the first 30 years. This strongly suggests a need for early action rather than any delay.

In addition to this:

The Environmental Impact Assessment has a 30 year horizon
Intergenerational equity issues suggest a 25 year horizon
Safety cases for shut reactors have a 25 year horizon

We understand that reactor internals and pressure circuits will continue to decay physically as well as radiologically, and there will come a time at which the physical dangers of structural collapse outweigh the radiological benefits of delay. Taking into account these points delaying clean up beyond 30 years is in our view unacceptable.

Any suggestion that this approach should be dependent on a national radioactive waste dump is the wrong way to proceed.

The NDA recognise that dismantling reactors on a 25 year timescale will require the radioactive waste from the reactors to be stored 'properly' on-site because any off-site facility for Intermediate-level Wastes (ILW) that may be suggested by CoRWM would take longer to establish. Nevertheless, many have pointed out, that the strategy links the viability of the early dismantling strategy to the results of the CoRWM review, endorsing the deep geological disposal option, and implying that any delay in work to implement such long term management arrangements would jeopardise the accelerated decommissioning and clearance of Magnox reactor sites.

The Institute for Geophysical Sciences as long ago as the 1970s indicated that movements of water underground and quality of knowledge about geology and hydrology is imperfect and likely to remain so.  Any suggestions that long-term underground storage can be guaranteed to be safe seem unrealistic. In short, long-term underground storage presumes a stability of structures and a perfect hydrological knowledge which is inherently unattainable.

With reference to this, the Kent Green party have noted that the NDA should look into groundwater contamination below Sellafield and Drigg as part of its role.

A concern that is common to both present and future generations is the 'configuration' of radioactive waste on decommissioning sites in a passively safe form. The radioactivity within Magnox reactors like at Oldbury is not in a passively safe form.  If safety really is to drive the work of the NDA then the absence of a national repository is irrelevant.

Passive safety on nuclear sites with the isolation of radioactivity in purpose built facilities, is as important as final clearance.  The progressive and systematic reduction in hazard on nuclear sites cannot wait for notional 'off-site' facilities that may never happen.

To ensure that decommissioning is done to the highest environmental standards, is driven by safety, and is applied consistently within sites and between sites, purpose-built radioactive waste stores on nuclear sites must be large enough to take all reactor decommissioning wastes in a conditioned and passively safe form.

It is also worth noting:

-  that the decommissioning timelines and site clearance dates of the various sites seem to vary arbitarily. The strategy offers no explanation for these inconsistencies - nor does it offer any contingency plans.

- we would be totally opposed if the plan involved incineration of radioactive waste, even low-level waste.


2. Need for investigation into continued Magnox operation

There should be an open, transparent and independent examination for continuing to operate the Magnox reactors. If DEFRA are not planning such an investigation then the NDA should order it.

We have been particularly disturbed by the evidence relating to Oldbury gained under the Freedom Of Information Act. BBC West and ITV West programmes both confirmed the deteriorating reactor cores at Oldbury. They have now lost more than a third of their weight, are the most damaged in the UK and have gone beyond available data from existing reactors as to what this might mean in practice.

Equally worrying are the letters between BNFL and the Nuclear Installations Inspectorate which started with the NII arguing that reactor 1 was probably unsafe to operate. Although the NII was eventually won over, independent experts say many serious questions remain unanswered. For example the NII commissioned paper by Manchester University reported that at 35% depletion, the graphite could only bear 15% of its original capacity ie it could collapse.  We have not seen a satisfactory response to this.


3. Reprocessing waste products needs review

The THORP plant has had very considerable problems, not least the damning internal report into a major radioactive leak. This was undetected for 8 months, over 100 warnings about the leak were ignored and management were found to be 'complacent' despite previous incidents. We need an open and transparent review of THORP that includes financial information. We would welcome it's early closure.

In addition to this we need to reconsider the strategy for returning reprocessing products to overseas customers. This implies a large number of High Level Waste (HLW) shipments to Europe and Japan over the next years.


4. Consultation and contamination on 'site end points'

Seriously large amounts of Low Level Waste (LLW) are expected to arise during decommissioning.

Much of the LLW will go to Drigg repository in Cumbria having been compressed. But at £1,500 a m3 barrel (2002 prices) charged by Drigg, there is a lot of pressure to get rid of it in other ways eg incineration and liquid disposal in the Bristol Channel. Also Drigg is getting full and their are predictions it might be under water in 50? years due to rising sea-levels.

Fears have been expressed by some that the Very Low Level Waste (VLLW) particularly is likely to put pressure on landfill sites and pressure to lower standards for site remediation. There could also be pressure to allow increases in discharges of liquid radioactive waste into the marine environment.

There is a separate consultation process planned to reach a consensus among local communities on 'site end points'. Given the massive impact these will have we would urge that the NDA consults as widely as possible and not just with those communities local to their facilities.

We trust that, irrespective of the intended use of a site, decontamination should be carried out to a level where unrestricted use is possible - excluding areas used for monitorable and retrievable waste stores. In the case of Oldbury we have concerns about the silt lagoons. We would strongly object to any new LLW management proposals which involve a lowering of environmental standards or an increase in risk to health.

In particular we would recommend the NDA adhere to 'Safegrounds' principles - a working committee composed of industry and NGO reps. They offer safer solutions to decommissioning and nuclear clean-up.


5. End liquid HLW production

We do not agree with NII and BNFL that liquid waste reduction is an adequate way forward. Liquid HLW is a significant hazard potential. Production of this should stop by ending reprocessing at THORP and closing Magnox reactors as quickly as possible.


6. Plutonium sales

Plutonium is particularly dangerous waste. We are alarmed by the suggestion that it maybe sold abroad. The proliferation of transporting weapons-useable plutonium must be avoided.


7. Short and long term security issues

There are many concerns relating to security surrounding decommissioning and clean up. We are not sure from this strategy whether these have been given full consideration and have been fully costed.

Greenpeace have shown on a number of occasions how easy it is to breach security arrangements. And only last month a cargo of radioactive nuclear waste sat in a railway siding for hours in Bridgwater, surrounded by houses and less than 100 metres from a school. These 'nuclear trains' that travel the length of the country carrying dangerous nuclear waste are also reported to be rattling along at 55mph on decaying tracks.

We are also very concerned about reports this week that a 15 year old roll on, roll off ferry is being used to ship radioactive cargo from Sellafield, in Cumbria, to Sweden and other continental ports.

All this comes on top of news this week that reveals that there is an Al-Qaeda website containing detailed instructions in Arabic on how to make nuclear, “dirty” and biological bombs. It has attracted more than 57,000 hits and hundreds of readers’ inquiries.

This confirms the need for storage of nuclear material on secure sites.

In terms of climate change, we accept that Government failure to cut greenhouse gas emissions in recent years, a failure common to many industrialized states, forms part of a scenario making long-term global warming more likely. Modest temperatures increases since 1900 have changed climate patterns, raised temperatures especially in the highest latitudes, reduced ice cap coverage at the Poles and in areas which once had ‘permanent’ snow cover and there is even evidence that the freshened waters of the North Atlantic may bring the Gulf Stream to a halt, thanks to melting of the North Polar ice cap and Greenland.

This means nuclear installations and waste storage in low-lying and/or coastal areas needs assessment against the so-called ‘runaway greenhouse effect’ scenarios which have been investigated, for example by the UK Met Office. There is the risk that many existing nuclear stations and storage facilities may incur additional costs related to protection from rising seas.

Predictions of a 3 degree centigrade temperature increase during this century were dependent upon constraining greenhouse gas emissions. But rising temperatures are releasing carbon dioxide from soil and even from permafrost (so-called) in places such as northern Canada and Greenland. In consequence, the 3 degree figure may well be optimistic, making figures of 5-8 degrees centigrade more likely on the basis of current failures to cut emissions. The NDA should consider how it climate-proofs the full range of its activities.


8. Costs and commercial business

There are not clear figures about costs.  As the above point makes clear there are many possible costs that need to be considered. We have already seen decommissioning and clean-up costs increase from £48 billion in 2002 to £56 billion. The draft strategy says this could increase further, but that innovation could drive costs down. We are concerned that such huge sums of money could lead to environmental and health considerations being sidelined. The Gloucestershire Green party seeks assurances that decisions about whether or not to operate waste producing facilities should not be driven by financial considerations.

Furthermore we agree that the commercial operations, that provide 50% of NDA's budget, "divert resources away" from the "mission of decommissioning and clean up". It is not clear that such operations are economically sensible, particularly when they add to the growing stockpile of nuclear waste for which there is currently no acceptable management solution.

We agree with doubts expressed by Elliott Morley, Minister for Climate Change and Environment, (The Independent, 7/11/05) about the overall costs of nuclear power. The NDA should be concerned with achieving least cost containment of the nuclear problem, not incurring long-term costs as a result of a failure to act expeditiously.


Philip Booth, Press Officer, Gloucestershire Green Party.

We would like to acknowledge with thanks input from many Gloucestershire Green party  members, the "Nuclear Free Local Authorities' Radioactive waste policy briefing on the Government Review" (September 2005) and information from the Welsh Anti Nuclear Alliance.