My IPC submission on Waste management and decommissioning at Hinkley C

It is my submission that the applicant has not “proposed an effective system for managing hazardous and non-hazardous waste arising from the construction, operation and decommissioning of the proposed development”.

This issue falls within the remit of the IPC as outlined in EN-1:

IPC decision making
5.14.7 The IPC should consider the extent to which the applicant has proposed an
effective system for managing hazardous and non-hazardous waste arising
from the construction, operation and decommissioning of the proposed
development. It should be satisfied that:
any such waste will be properly managed, both on-site and off-site;
the waste from the proposed facility can be dealt with appropriately by the
waste infrastructure which is, or is likely to be, available. Such waste
arisings should not have an adverse effect on the capacity of existing
waste management facilities to deal with other waste arisings in the area;


5.14.8 Where necessary, the IPC should use requirements or obligations to ensure
that appropriate measures for waste management are applied. The IPC may
wish to include a condition on revision of waste management plans at
reasonable intervals when giving consent.

In order to assess the measures for waste management in EDF’s plan we need to look at the time-line.

Time-scale for generation and decommissioning

The time-scales presented in the plan for the operation of the Hinkley C plant and its subsequent decommissioning are optimistic, with assertions always made on the least conservative estimates. This is significant, as the longer either generation or on-site storage lasts the more radioactive waste will be produced, and the further into the future the end of generation (EOG) and decommissioning is projected the more uncertainties there are about the waste infrastructure which is likely to be available to future generations.

Start Of Generation (SOG)

In 7.5.7 EDF propose that the first reactor begins generating in 2018 (already 1 year later than their original projection) and the second commences 18 months later. This is an optimistic assumption in the light of current experience.

The first 2 EPRs currently being built in Finland and France have both experienced significant delays in completion and have both gone 100% over budget. The Olkiluoto plant in Finland is currently running 4 years late. EDF’s Flamanville nuclear plant in Normandy has had it’s completion date delayed by 2 years at present. There are now reports that a 3rd EPR station being built in China is experiencing similar difficulties. While EDF may say of course that they have learned from these experiences, the fact remains that, according to Kevin Allars of the Nuclear Installations Inspectorate (NII), no nuclear power stations in the uk have actually been built on time. It is therefore reasonable to consider, on the basis of current experience, that the SOG at Hinkley C may not be until the early 2020s.

End Of Generation (EOG)

With an assumed operational life of 60 years, EOG for the second reactor could be as late as 2085. This lifetime may in turn be extended. In 2010, EDF Energy announced a 5 year life extension for both Heysham 1 and Hartlepool , and in Feb 2012 Energy Minister Charles Hendry said that other uk reactors may have their lives extended into the mid 20s. Since we can have no control over decisions taken 60 years from now, we should allow for the possibility that EOG at Hinkley C might not be until 2090 or even 2095.

Waste management and decommissioning time-lines

During the period of generation, Low level waste (LLW) , Intermediate Level Waste (ILW) and spent fuel would be “accumulated and safely stored on-site…until a suitable disposal route or an alternative management route becomes available” (7.2.7). Spent fuel rods would be stored in the reactor fuel storage pools for approximately 3 years. This could mean that the last spent fuel is transferred from the pools to the Interim Storage Facility (ISFS) in the late 2090s. Here it needs to be stored for 50 to 100 years before being transferred to a GDF, if that is available.
NDA Technical Note no. 11261814, 2009 gives a storage period of 100 years before it is cool enough to be removed from the site to longer term storage:

“The adoption of a higher burn-up for the EPR, as compared to Sizewell B, is expected to
result in increased concentrations of radionuclides in the spent fuel. Also, the longer
operational life of the EPR (60 years as compared to 40 years anticipated for Sizewell B)
increases the concentration of long-lived radionuclides in the decommissioning waste. The
potential significance of such differences has been considered…. it would require of order of 100 years for the activity, and hence heat output, of the EPR fuel to decay sufficiently.”

EDF on the other hand assert that this storage time can be reduced by careful design to 50 years and this is the figure from which they work in the plan. It is important to note that this is unknown, especially in view of the possibility of a prolonged operational life, which would increase the predicted concentration of long-lived radionuclides. It would be wise, observing the precautionary principle, to assume that up to 100 years storage on-site may be necessary after the EOG before transfer is possible. This means, bearing in mind that the EOG date may well be later than projected, that the ISFS may need to be maintained until 2190. Even on EDF’s optimistic assumption of 50 years, we get 2140 – over 120 years from now.

This means that the people tasked with maintaining waste storage will be the great great grandchildren of the generation born in 2020 – or their children – and they will be learning and performing the tasks of maintenance and decommissioning 50 or more years after the power station has stopped producing electricity.

Future Conditions

At 5.7.3, EDF acknowledge that: “There are substantial uncertainties with respect to the characteristics of the future baseline conditions.” There are indeed. It is instructive to think back over the last 120 years of our history to grasp the kind of uncertainties which exist with respect to this future time. Obviously there have been major technological revolutions in this period and a time of unprecedented growth and prosperity in Britain since the post war boom.

There have also been: 2 World Wars with European theatres; Ariel Bombardments of Britain, including Southwest England; 2 pandemics; The Russian and Chinese revolutions, and the emergence of new super-powers; 2 uses of nuclear weapons and at least one nuclear stand-off; New political movements and parties with new ideologies rising to power (eg Labour ); At least 3 major economic crashes and a depression; Bombing campaigns from 3 different sources (IRA, Angry Brigade, Jihadists); Plane crashes; The Ozone hole crisis; Extreme weather events.

There is absolutely no reason to assume that many of these events will not be replicated over the next 120 years. We must also add in the possible new future contingencies which could have a negative effect on populations and their infrastructure. These possible contingencies are generally agreed to include the following:
Extreme weather; runaway climate change; sea-level rise; seismic activity leading to tidal waves; war arising from resource depletion; peak oil; disruption of food supply through war or climate change; massive geo-political changes including a shift of wealth and power from the West to China and Asia; an asteroid hit or major volcanic eruption; a magnetic storm leading to the collapse of all electronic systems.

Statistically, the likelihood of any one of these events may be small, but the probability that one or more of them will occur is far higher.

5.7.3 goes on to say “the technology which may be available to assist with the decommissioning works may change relative to current knowledge and capability”. In the light of possible and quite plausible future contingencies outlined above, this may be true in a negative as well as a positive direction. The assumption that the current regulatory framework, processes and technical knowledge associated with nuclear generation will be in place in the 22nd century must also be questioned. It may well not. Current government departments have only existed for a decade. A century ago, the forerunner of DECC was called the Lords of Trade and Plantations.

Equally, it is quite possible that EDF may cease to trade at any time in the next 150 years, or have been taken over by another commercial entity, or have withdrawn from Britain because of changes in anglo-french relations.

Geological Disposal Facility (GDF)

The other major assumption I would like to address is the availability of a GDF. Although this assumption is central to the NPS and therefore may not be questioned, it is relevant to this application to consider whether or not it will be available as this will necessarily effect the waste-management plans.

According to DECC: “Government cannot be certain how long it will take to get to an operational geological disposal facility”. The planning document repeats these uncertainties and also the assurances that nonetheless the GDF will eventually be operational, because it is current government policy. It also works again with the most optimistic figures it can, quoting Charles Hendry in 2011 saying “I would like us to set a goal of putting the first waste into a geological disposal facility by the end of 2029. I have tasked the Nuclear Decommissioning Authority to look at opportunities for accelerating progress to meet this aim.”(5.6.14) Mr Hendry is not the first minister to have stated an intention. EDF however conclude that it is therefore “highly improbable” that the GDF will not be available.
However, according to the NFLA (Nuclear Free Local Authorities ) secretariat
“…a GDF with spent fuel from a 16GW new reactor programme, as well as legacy waste, will probably exceed the risk targets set by the EA. Thus, it is quite possible that two separate GDF’s might well be required. There is no detail around this possibility and what it means for UK radioactive waste management policy. In the NFLA’s view, the Appraisal of Sustainability on Hazardous and Radioactive Waste needs to be rewritten to take into account the likelihood of a 16GW nuclear programme, and the probability that two nuclear deep-waste repositories will be required”.
( )
There is currently no GDF and no agreed location for one. 2 may be required. It is impossible to give meaningful assurances that this facility will be available at the EOG, or at the end of decommissioning.

Given the very real possibility that at any point in the next 130 years communities may find themselves with either diminished technical capabilities, diminished resources, diminished populations, or a diminished knowledge base, the current plans for waste must include a failsafe system of storage which will function passively and without the need for expert maintenance for at least 100years. Where additional space may be required in future, or additional facilities, these should be provided for and constructed now, in case the task is beyond the capabilities of the future generation. Systems must be designed to a level where further work or maintenance requiring specialist knowledge will not be required.

For instance 7.5.9 says that “the ILWISF may need refurbishment to extend its life until the GDF is available.” This longevity should be built into the present ILWISF plan, rather than left to future people, who may or may not have the means.

It is unacceptable that neither the ILWISF or the ISFS have been designed yet, and that the ISFS is “at the conceptual stage” (7.6.16). Permission to begin building Hinkley C cannot be given until there is a definitive plan for how to end it. The end must be built into the beginning, not left to unborn people who will not even have benefited from the facility.

Planners need to show that adequate planning is in place in consideration of unplanned contingencies and variable timescales. The extreme and long-lived toxicity of radioactive waste mean that eventualities of even low probability should be considered and provided for, as not to do so could potentially expose people to extreme hazard.

The great great grandchildren of children born at the start of generation (SOG) will be the people who need to supply the workforce and the skill-set for maintaining the interim storage, although they will not have benefited from the power production decades previously. They will have to do this under the guidance and monitoring of regulatory bodies which are extremely unlikely to exist in the form they do now, if at all.

In turn, their children will be responsible for the 18 year task of removing the waste and “spent fuel” – eg high-level EPR waste, and transporting it to the GDF, which may or may not exist. If it does not exist they will need to begin the 30 year task of digging it. There it must remain while the isotopes decay for the next 200.000 years to 15 million years, at the end of which period it will no doubt be declared stable subject to agreement with the appropriate regulatory authority.


One Response to “My IPC submission on Waste management and decommissioning at Hinkley C”

  1. This blog is great i love reading your posts. Keep up the great work! You know, a lot of people are hunting around for this info, you could help them greatly.

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