The Environment Agency (EA) has strongly criticised the Nuclear Decommissioning Authority’s (NDA’s) draft business plan for 2008/2011.
In its consultation response to the business plan, the environment regulator for England and Wales asked what the consequences will be for other nuclear sites when decommissioning funds are focussed on high-hazard sites.
EA says the draft plan proposes “significant changes” to the NDA strategy which the NDA needs to show are necessary and can be delivered while ensuring “continued protection of people and the environment”.
“Whilst we support the need to focus on high-hazard facilities, consistent with a risk-based approach, there needs to be an assessment of the implications for the environment that this will have for other sites.
“Proposals to delay decommissioning and clean-up should be based on an assessment of the environmental implications of such a decision – and not simply on the basis of ‘affordability’,” the EA stated.
“We expect NDA to engage with its regulators and other stakeholders, in considering the pros and cons of each option – rather than concerns about simply what is ‘affordable’. Such an approach is in accord with the responsibilities of the NDA set out in the Energy Act 2004, the Memorandum of Understanding between our organisations, as well as the expectations of NDA’s stakeholders.”
In its response, the EA says the future NDA strategy review should not be used to present arguments for decisions that have already been taken.
According to the EA, the NDA draft plan doesn’t show that reallocation of money takes the environment into account, and should be based on a strategic environmental assessment.
“We appreciate that the NDA has to work within funding limitations, and that the level of funding has increased since NDA was established. However, the increase in funds has not kept pace with the increased estimate of liabilities costs and the work to be done,” it said.
The EA said the NDA funding model “hampers” its ability to deliver its mission. This is because it is reliant partly on income from commercial operations in ageing plants, and a fixed short-term funding settlement that doesn’t provide any flexibility or contingency to respond to any issues that may emerge.
NDA should work with the UK government to explore better models of funding, according to the EA.
In terms of the site license companies, the NDA summaries suggest that a significant amount of decommissioning work will take place at a number of sites.
But the EA says it is “not clear” how this work will be affected by the decision to focus on high-hazard sites like Dounreay, in northern Scotland, and Sellafield, in northern England.
“In particular NDA needs to set out which activities will no longer take place as a result of any decision to re-prioritise funding,” it states.
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