Thermal analysis review
Written statement by Edward Davey.
In November 2013, the Nuclear Decommissioning Authority’s Radioactive Waste Management Directorate (RWMD) informed my Department of a modelling error in their assessments of the on-site cooling time required for spent fuel from new nuclear reactors before it could be placed in an off-site Geological Disposal Facility (GDF).
RWMD subsequently corrected the error and published revisions of two disposability assessments and a feasibility study that included data from the model. These can be found on the NDA website and I have placed copies of these reports in the libraries.
There is no impact on safety at any existing site, as the corrections only increase the estimated length of time for which spent fuel from any new reactors would need to be kept in interim storage.
All other aspects of the corrected reports remain unchanged and RWMD has confirmed that the error does not affect future planning for a GDF.
My department has thoroughly assessed RWMD’s corrected figures in relation to a number of previous decisions and policy areas, some of which were debated by Parliament. We have concluded that the corrected figures have no substantive impact on policy or previous decisions, including the Hinkley Point C deal.
I set out below our consideration and findings.
Regulatory Justification of the EPR and AP1000 reactor designs
My predecessor published decisions in October 2010 that the EPR and AP1000 nuclear reactor designs were Justified in accordance with the Justification of Practices Involving Ionising Radiation Regulations 2004 (‘the Justification Regulations’). These decisions took the form of Statutory Instruments which were approved by both Houses of Parliament in November 2010.
Justification decisions involve assessing the benefits of proposed new radioactive practices against their potential detriment to health. The published decisions took account of RWMD’s modelling of interim storage times.
The Justification Regulations make provision for the circumstances in which a review may be undertaken. My assessment is that the revised modelling does not create any new health detriments that were not considered during the Justification process and does not raise any new issues about the ability to manage interim storage that may impact on the benefits of the EPR or AP1000 reactors.
I have therefore concluded that the revised modelling does not meet the “new and important” criteria needed to consider reviewing the Justification Decisions and that I do not need to review my predecessor’s decisions.
Nuclear National Policy Statement and Hinkley Point Development Consent
The Nuclear National Policy Statement sets the framework for Development Consent decisions under the Planning Act 2008. It was approved by Parliament and designated in July 2011. It included a statement on waste disposal, based on RWMD’s assessments, which made clear that interim storage would be needed on a range of timescales, during which facilities would continue to be effectively regulated.
The material in the NPS was referred to by the Planning Inspectorate in its advice to me on the application for development consent for the new nuclear power station at Hinkley Point and referred to by me in my decision.
There are no reasons to believe that the regulatory regime could not effectively regulate the increase in interim storage times under RWMD’s revised assessments and I have therefore concluded that there are no grounds for a review of the Nuclear NPS or any of the decisions taken with reference to it.
Funded Decommissioning Programmes (FDP) and Waste Transfer Contracts
No decisions have yet been taken on whether or not to approve the Funded Decomissioning Programme for Hinkley Point C. Further to the publication of the corrected reports, the developer has been asked to update their respective FDP submission for the site and this information will be taken into account in any decision.
Euratom Article 37
General data was provided to the Commission in relation to the planned spent fuel storage facilities at Hinkley Point C. This data focused on the overall plans for storage, rather than the storage period, and already takes into account a margin of error that includes the corrected figures.
We have drawn the attention of the European Commission to the re-published reports, as they provide an opinion on Article 37 applications, but do not believe that any further action is necessary.
Generic Design Assessment (GDA) and Site licensing & permitting
The original disposability reports written by RWMD were used as evidence in the GDA process and cited in the Regulators’ technical findings. Further to the corrected disposability reports being published, the Regulators are working with EDF (the recipient of the GDA design acceptances for the EPR design) to assess if there are any impacts to their GDA decision and findings.
Should any changes be required these will be addressed as part of the wider, on-going site licensing and permitting process. Similarly any impact to the findings for the AP1000 design would be addressed in any subsequent assessment or site licensing and permitting process.