NIA RESPONSE TO CONSULTATION ON MANAGING RADIOACTIVE SUBSTANCES AND NUCLEAR DECOMMISSIONING

The NIA is the trade association and representative body for the civil nuclear industry in the UK. We represent around 270 companies operating across all aspects of the nuclear fuel cycle, including the current and prospective operators of nuclear power stations, international designers, and vendors of nuclear reactors, and those engaged in decommissioning, waste management and nuclear liabilities management. Members also include nuclear equipment suppliers, engineering and construction firms, nuclear research organisations, and legal, financial and consultancy companies.

Many of our members will have made their own, detailed response to this consultation. The focus of this submission is therefore on industry-wide matters, illustrating our recommendations and arguments with specific case studies where appropriate.

Executive Summary

The NIA agrees with and takes as our starting point the consultation’s statement that “we are clear that we must strive to keep the creation of radioactive waste to a minimum. We must strive to find the most cost effective and sustainable solutions for its long-term safe management. We must strive to reduce the burden for future generations of managing the radioactive waste that has already accumulated or has yet to be generated, for example, through nuclear decommissioning and clean-up activities.”

Since we share these goals of minimising waste, ensuring cost effective and sustainable solutions, and minimising the burden on future generations, we support the following high-level steps:

• Aggressive application of the waste hierarchy with a clear mandate from the Government to the NDA to seek out and implement solutions that reduce waste volumes and drive down waste classifications as far as possible. This saves money and improves efficiency.
• We have cited the example of a re-characterisation solution applied by ANTECH to just 1,810 drums of Intermediate Level Waste plutonium-contaminated materials. ANTECH’s re-measurement found that more than 95% of the drums were in fact Low Level Waste or below, generating an estimated £9 million of savings. This is the kind of solution we should apply.
• Implementation of the consultation’s recommendation of near-surface disposal of appropriate ILW, rather than its consignment to the GDF, because the GDF is the most highly-engineered solution and thus less likely to be cost-effective for ILW under a risk-informed decision making framework.
• Establishment of a policy principle to minimise the volumes of waste going to GDF, as it is the most highly-engineered disposal solution and thus at the very bottom of the waste hierarchy.
• Enhanced collaboration with other countries on shared solutions to waste, because it is highly unlikely to be sustainable or cost-effective for every country that has generated nuclear waste to develop all the capabilities necessary to treat, store and dispose of waste themselves.
• Specialisation of countries in the treatment and disposal of certain kinds of waste is much more likely to be efficient and sustainable, so the transfer or exchange of waste should be allowed pragmatically.
• The “Self-sufficiency” principle alone should not be sufficient to deny authorisation for trans-frontier shipment of waste.
• Establishment of an overall policy preference for the re-use of nuclear materials where possible
• In-principle support for the reprocessing of spent fuel, and thus its preservation from geological disposal as long as practical. Ideally, reprocessing should be pursued to extract the maximum possible clean energy from nuclear materials and to minimise volumes consigned to a GDF, but we appreciate the challenges that would emerge in practice. The UK Government should encourage viable proposals for reprocessing, cognisant of the lessons of past experience.
• Special categorisation of uranium within nuclear materials policy to reflect its lower hazard, lower proliferation risk, and high potential for further productive use.
• A formal policy to re-use the public stockpile of uranium wherever possible in nuclear or non-nuclear applications. It is noted that while there is an opportunity for re-use some uranium stocks through further enrichment, there will still be residues that may ultimately require disposal and so a pragmatic management solution remains a priority.
• Renewed pursuit of the re-use of plutonium through a dedicated programme to support the deployment of plutonium-burning reactors, or the use of the plutonium in MOX fuel for any viable reactor type: funding, costs, risks and rewards should be shared between the NDA and the private sector under a clearly defined framework reflecting the particular considerations at work.
• Any programme will likely take years to reach fruition, but procrastination makes it harder to reuse the plutonium effectively. Since re-use is the policy, re-use should be pursued actively to implementation.

Please click here to view our full response.