Saturday, 12 February 2011

MOD nuclear decommissioning strategy, a state secret

Following an internal review relating to a FOI request to the MOD to provide information about its nuclear decommissioning strategy; MOD continues to keep details of its nuclear decommissioning strategy secret and has reneged on its own policy to involve stakeholders including NGOs in the development of its decommissioning strategy preferring the old discredited “announce and defend” approach to decision making.

The MOD policy makes clear that the strategy is to be developed in consultation with stakeholders which means that the draft strategy should be a public document.

The following references in the MOD policy support this view

Para 8 K “consulting appropriate public and stakeholder groups on the options considered and the contents of the strategy”

Para 10 “Whilst in no way underestimating the task ahead the MOD remains confident that in conjunction with stakeholders (OGDs and NGOs) it is able to deliver the policy outcomes set out above”

Extract from the MOD’s internal review.

“MOD Decommissioning and Disposal Strategy (Section 35 and Section 22)

12. DE&S informed you that the information is being withheld in its entirety under section 35(1)(a) and explained that although there is a public interest in the development of the MOD's Decommissioning and Disposal Strategy, there is a greater public interest in MOD having the space to develop that strategy in an effective manner, including proposing and discussing new ideas, without the fear that there would be early disclosure of information before it has had an opportunity to mature. At the time of your request the consultation process was ongoing and I can confirm that this has not yet been finalised. lt is vital for MOD to be able to discuss all options in a free and frank manner and that disclosure would be detrimental to this process as participants would be less than free and frank if they were concerned that their contributions would later be subject to disclosure. Again, I can also inform you that this exemption is engaged where the information can be accurately characterised as relating to formulation or development of government policy.”

It notable that the information requested does not relate to policy but the strategy that delivers the policy outcomes referred to in “Ministry of Defence Policy for Decommissioning and Disposal of Radioactive Waste and Residual Nuclear Material arising from the Nuclear Programme.

The MOD approach is in stark contrast to the open and transparent processes which the Nuclear Decommissioning Authority (NDA) employs; involving stakeholders including NGOs in the development of their strategy. The NDA seems to have no problems discussing new ideas, or fears about the early disclosure of information before it has had an opportunity to mature.

The report on non NDA Liability Management Strategy published in March 2010 indicates MOD’s failure to address liabilities for Exotic Fuel and Higher Active Waste

To quote from the report

“MoD currently owns the largest stock of exotic fuel which is stored at Sellafield. MoD does not have a long term liability management plan for these fuels so their impact on NDA‘s exotic strategy is as yet undetermined. There is the potential that this could form part of the exotic fuels inventory and hence may influence the NDA strategy” and

“Higher Active Waste. Wastes from BE reprocessing and potentially from MoD fuel processing will require (i) long term management, (ii) appropriate conditioning for ultimate disposal, and (iii) disposal in the GDF”.

This demonstrates that MODs inability to develop a strategy for managing its nuclear liabilities is impacting negatively on the NDA and nationally on the “managing radioactively waste safely” process.

This all tends to suggest that MODs reluctance to provide information on its strategy for managing nuclear decommissioning liabilities is to avoid embarrassment about an inability to make decisions on how to manage these liabilities, failure to afford them proper priority and most of all, a lack of funds.

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