The Nuclear Free Local Authorities (NFLA) has submitted today to the UK Government its views on a discussion paper considering how civil nuclear sites are delicensed as full decommissioned concludes. The Business, Energy and Industrial Strategy (BEIS) Department has published a discussion paper on what the process should be to move nuclear sites from nuclear regulatory to environmental regulatory and eventually likely local authority control. This process is likely to require changes in nuclear legislation, in particular the 1965 Nuclear Installations Act. Some sites like Winfrith, Trawsfynydd and Dounreay are just a few years away from beginning the full decommissioning process in earnest, with other nuclear sites close behind them. The three environmental regulators for England, Scotland and Wales have earlier this year consulted on how the regulatory regime will have to change and the BEIS discussion paper links to it be considering its impact on nuclear legislation and how the process may develop. The five key conclusions in the NFLA response to the discussion paper are: There is a danger that what is being proposed will simply be seen as turning nuclear sites into nuclear dumps as a way of saving money. The concept of “optimisation” which is decided by the operator and regulators making value judgements needs to be replaced with the concept of the Best Practicable Environmental Option which uses a systematic, consultative and decision making procedure. Any part of a nuclear site upon which it is proposed to allow unrestricted use must be able to show that doses to members of the public will be of the order of 0.01mSv or less per year. Using a risk factor in conjunction with probability of receiving a dose is too flexible and unacceptable. Any waste left on-site much be concentrated and contained in a monitorable, retrievable store. Former nuclear operators should remain liable for any future unexpected events and should also be liable to pay for any regulatory effort in perpetuity.
NFLA 9th Dec 2016 read more »