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1.0 Dounreay
LLW Consultations
1.1 The Scottish Environment Protection Agency (SEPA)
has launched a consultation into UKAEA proposals to dispose of
solid low-level waste from Dounreay to BNFL's Sellafield and Drigg
sites. The documents can be found at www.sepa.org.uk/consultation/ukaea/index.htm
This is not to be confused with the consultation which has just
closed, by UKAEA itself, on the Best Practicable Environmental
Option (BPEO) for the longer-term management of LLW at Dounreay.
1.2 UKAEA describes the proposal as an "interim measure",
whilst a long-term strategy and associated facilities to manage
all existing and future LLW arisings is being determined by the
BPEO process referred to above.
1.3 In its response to the consultation the Scottish
Executive complains that the application gives no indication
of the quantities and timescales involved for this interim measure
or of the safety implications of continuing to store LLW at Dounreay,
and it asks for details of the number of containers involved and
the methods of transport, and an environmental assessment of the
impact of the transports. Most importantly it asks whether granting
the authorizations will prejudice the outcome of the BPEO consultation.
1.4 In March 2003, the Radioactive Waste Management
Advisory Committee (RWMAC) advised Scottish Ministers that:
"…there is a danger of national policy effectively being
pre-empted by … a decision to open up the Drigg disposal
route … If this is allowed, the possible future implications
for ILW and High Level Waste (HLW) must also be considered".
1.5 This unacceptable situation has arisen as a result
of a recommendation made by the 1998 Dounreay Safety Audit
by HSE and SEPA. Recommendation 80 said that UKAEA should develop
a modern well-engineered low-level waste disposal facility at
Dounreay. But in the meantime it said UKAEA should "dispose
of waste to Drigg wherever possible".
1.6 SEPA cites current government policy to justify this
approach as expressed in the most recent policy document - Cm2919
. However, this 1995 document states that waste should be "…safely
disposed of at appropriate times and in appropriate ways …
in a manner that commands public confidence". A policy of
transferring waste, from Dounreay to Sellafield or Drigg cannot
be described as commanding public confidence. RWMAC said in September
2001 that it "is not persuaded that existing statements of
radioactive waste management policy, notably the previous Conservative
Government's White Paper (Cm 2919), provide a sufficiently robust
template against which to assess possible solutions for Dounreay
LLW."
1.7 In its submission on the BPEO consultation Shetland
Islands Council called for urgent consideration to be given
to the idea of super-compacting all existing LLW on site at Dounreay
to free up space in existing facilities, and if necessary additional
interim storage facilities should be provided on site.
1.8 The only indication of the scale of the proposed transports
to Sellafield and Drigg was given in a Sunday Herald article on
3rd February 2002. This suggested that a train load every month
or a lorry load every fortnight is likely until new facilities
are available on the Dounreay site around 2010 - 15.
1.9 The consultation exercise runs until 23rd February
2004.
2.0 Dounreay Shaft Consultation
2.1 Meanwhile UKAEA has launched yet another consultation
- on the end state of the waste shaft. It wants views on what
should happen to the rocks immediately around the shaft once it
has been emptied. The actual emptying of the shaft will be subject
to a different consultation. The end state of the shaft is being
examined first because whichever option is chosen may affect the
options for emptying the shaft itself. UKAEA requests comments
by 7th February 2004.
2.2 The consultation is concerned with what should happen
to the contaminated rock sides of the shaft itself, called the
'near field', and the 'far field'. Contamination from the shaft
has leaked into the rocks up to 300 metres offshore from Dounreay.
The options for dealing with both the 'near field' and the 'far
field' include: natural attenuation, or doing nothing and letting
the radioactive contamination decay naturally; excavate the contaminated
rock; immobilise the contamination in the rock by using grout
or something similar; and 'back flushing' chemicals into the rocks
so contamination is flushed into the empty shaft. Excavating all
the contaminated rock in the 'far field' would involve a massive
engineering and mining operation costing upwards of £300
million and taking at least 10 years to complete.
2.3 The options have already been considered by two stakeholder
panels - both rejecting the option of 'natural attenuation', or
doing nothing. The external stakeholders panel favoured immobilising
the contamination in the 'far field' and removing the contaminated
rock from around the empty shaft. Full details of the consultation
and the draft Best Practicable Environmental Option study are
available at www.ukaea.org.uk
2.4 Orkney MSP Jim Wallace has called the information
released for the waste shaft consultation "somewhat worthless",
and wants more information on the extent of contamination and
on its likely to spread if no recovery or treatment is undertaken.
3.0 Dounreay Particles
3.1 Three more radioactive particles were
found on the Sandside beach during November bringing the total
found since 1984 to 46, and 24 in 2003. The latest particle found
was the second most active ever. The caesium-137 particle was
280,000 Becquerels. Philip Day, the expert consultant for the
beach's owner said the find was worrying because it showed the
particles were not all being broken down by the actions of sea
and sand. He added that the particle was 1,000 million times more
active than what the UKAEA is permitted to discharge legally from
Dounreay. The beach owner, Geoffrey Minter, has called for consideration
to be given to the idea of removing sand from the beach to reduce
contamination.
4.0 Nuclear Decommissioning Authority
4.1 As expected the Queen's Speech on 26th November included
an Energy Bill, which incorporates the proposals in the Draft
Nuclear Sites and Radioactive Substances Bill to set up the Nuclear
Decommissioning Authority. The Energy Bill was introduced the
following day in the House of Lords, and published on 28th November.
The second reading was held in the House of Lords on 11th December.
The Bill can be found at www.publications.parliament.uk/pa/pabills.htm
4.2 Nothing in the Energy Bill reflects the concerns raised
by national environment groups with the Department of Trade and
Industry - despite the fact that the House of Commons Trade and
Industry Committee agreed with many of the points made in evidence
to the Committee. NGOs have been told some environmental principles
may go into a 'mission statement' - this will not have legislative
powers.
4.3 There is a huge job of work to do in dealing with
the legacy of nuclear waste created by the bad decisions of the
past. However, the NDA will have no overriding environmental objectives,
increasing the risk that inappropriate decisions on decommissioning
and waste management will be taken in the future. For example,
some sections of the nuclear industry have already said they may
increase radioactive discharges when undertaking decommissioning.
In addition, industry pressure may lead the NDA to fail to prioritise
dealing with the most hazardous wastes and also make unnecessary
transfers of wastes from one site to another.
4.4 As well as continuing to operate the loss-making Magnox
reactors, and the two Sellafield reprocessing plants, the NDA
will be the conduit the Government uses for subsidising waste
management for British Energy. The worst aspect of this is that
the relevant clauses in the Bill are written to allow the government
to bail-out future nuclear companies. And the DTI's refusal to
include a clause making segregated decommissioning funds a legal
requirement of any new reactor building programme could make new
nuclear build more attractive to investors who will know that,
should they fail to set aside sufficient funds for decommissioning,
the government will bail them out.
4.5 The Energy Bill is a huge disappointment. It will
do nothing to dispel the public's cynicism about the Government's
motives for establishing the NDA. The Bill completely fails to
dispel doubts that setting up the NDA could just be an exercise
in getting the bankrupt nuclear industry back on its feet again
in time to make another attempt at building new nuclear stations
in the UK in 3 or 4 years time. It would have been encouraging
to see a world-class, environmentally sustainable body being set
up which was prepared to go beyond simply meeting regulatory requirements.
[NB. Some aspects of the Energy Bill which promote offshore wind
deserve to be widely welcomed. The above comments refer to the
nuclear legacy section of the Bill only].
4.6 Since a number of provisions in the Energy Bill cover
functions devolved to the Scottish Parliament, the issue has already
been raised at Holyrood. The Deputy Minister for Enterprise and
Lifelong Learning, Lewis Macdonald said on 18th December that
he has written to the conveners of the Enterprise and Culture
Committee (Alasdair Morgan) and the Environment and Rural Development
Committee (Sarah Boyack) to advise them that a "Sewel memorandum"
is under preparation and will be with them soon. A "Sewel
motion" is the procedure used in the Scottish Parliament
to allow consideration of Bills laid before the Westminster Parliament.
4.7 The debate in the Scottish Parliament could be crucial
to the success or otherwise of the Energy Bill. A Greenpeace briefing
on issues raised by the Energy Bill for the Scottish Parliament
will be available shortly. Further briefings are available on
the Greenpeace website: http://www.greenpeace.org.uk/contentlookup.cfm?ucidparam=20031103152743&MenuPoint=D-E
4.8 Now that the Bill has had its Second Reading in the
House of Lords, it will now go into Committee Stage. This will
be a Grand Committee and will start on Jan 14th and probably won't
be finished until mid March. A Grand Committee has unrestricted
membership with all Lords free to attend and participate. After
the House of Lords Committee, the Bill will go into the House
of Commons.
5.0 Magnox News.
5.1 Although there is only one remaining Magnox reactor
in Scotland, at Chapelcross near Dumfries, which will close on
31st March 2005, the issue of whether or not the remaining Magnox
reactors are allowed to operate until 2010 is an important one
for Scotland because of the implications this has for radioactive
discharges from the Selafield reprocessing plant.
5.2 On current plans, a further 9,400 tonnes of Magnox
spent nuclear waste fuel will be reprocessed before the end of
2012 when the Sellafield Magnox reprocessing plant is due to close.
Of this, around 2,300 tonnes has yet to be loaded in the reactors.
In order to reprocess all this by the end of 2012, the throughput
of the Magnox reprocessing plant will have to be increased to
1,000 tonnes per year from the current rate of around 700 tonnes
per year or less. This increased throughput will involve increases
in discharges from Sellafield.
5.3 At the end of 2002 the Environment Agency introduced
new limits for radioactive discharges from all of BNFL's Magnox
stations, except Chapelcross. However Government Ministers are
still considering the matter of whether continued operation of
the Magnox reactors is justified one year later. Ministers have
powers to require the Agency to change or withdraw the authorisations
at any time.
5.4 For this reason David Chaytor MP recently wrote to
Nuclear Economist, Gordon MacKerron, about the economics of continuing
to operate the UK's remaining Magnox reactors. BNFL has already
admitted that the Magnox stations are loss-making, but claims
it would lose more money if they were closed immediately. BNFL's
case seems to be that its income from continuing to operate its
Magnox stations exceeds the avoidable costs. In his response to
David Chaytor, MacKerron says " There can be little public
confidence in the idea that Magnox avoidable costs are definitively
below the selling price of electricity". An Independent economic
appraisal of the case for continuing to operate the Magnox reactors
is therefore urgent.
5.5 In a related development the Environment Agency has
launched a public consultation exercise on radioactive discharges
from the Springfields plant. The consultation is due to end on
19th March 2004. Documents can be obtained from the Environment
Agency (springfieldsreview@environment-agency.gov.uk). Production
of Magnox fuel at Springfields is currently planned to cease in
2006, by which time sufficient fuel to keep the Magnox reactors
running according to BNFL's closure timetable will have been produced.
This closure is expected to reduce discharges from Springfields
by around 100TBq per year. Clearly ending the production of Magnox
fuel at Springfields now would reduce the future impact of radioactive
discharges from Sellafield on the Scottish coastline.
6.0 British Energy
6.1 British Energy announced another huge half loss at
the end of December for the first half of this financial year.
Operating losses for the six months to September were £71m,
although this was down from the £337m loss in the same period
last year. UK nuclear output rose 10% in that time, but the troubled
nuclear power generator has suffered from a string of technical
failures.
6.2 The latest problems at two units of the Heysham 1
plant in Lancashire mean that future losses attributed to this
and the recent closure of Sizewell B in Suffolk are expected to
be £95m rather than the £50m originally expected.
The problems at Heysham began in October after seawater cooling
pipes leaked. British Energy originally said it expected to have
the plant back in action in December but the shutdown is now expected
to continue "into the first quarter of 2004".
6.3 Patricia Hewitt, trade and industry secretary, agreed
in November to increase a government loan facility from £200m
to £275m to allow the group to continue to trade while repairs
were made at Heysham. British Energy has to pay higher prices
for power it buys in from the wholesale market when its own output
is reduced. This is because the company forward sold much of its
output when electricity prices were lower than they are now.
6.4 Meanwhile, the Financial Times says British Energy
may consider prolonging the life of its eight nuclear power stations
if it could improve their operating efficiency. BE has established
a range of plant lifetimes, for accountancy purposes, but this
does not necessarily mean that this is when the stations are will
close. Currently the closure programme is due to start in 2008,
with all but one of the stations closed by 2023. These dates are
kept under close review and adjusted (in either direction) at
any time to take account of commercial, technical and safety issues.
6.5 Nuclear operators are required, by the NII, to review
and re-assess the safety of their plants periodically and systematically.
These reviews, known as Periodic Safety Reviews (PSRs), are submitted
to the NII for consideration and assessment. PSRs are designed
to confirm that plants are safe to continue to operate for a further
10 years, and that any reasonably practicable improvements have
been made. The next PSR due in Scotland is for Hunterston B in
2006. This could, theoretically give BE clearance to operate the
station until 2016, rather than close it in 2011 - the current
expected closure date for accounting purposes. If, as a result
of the PSR process, the NII requires BE to implement plant modifications,
BE would then have to decide whether the cost of the modifications
was justified by the expected future income. If the costs were
too high BE would close the plant. Thus the decision to cease
generation is determined by safety issues and economic factors.
There is no opportunity for public intervention in the PSR process,
and the NII is not required to consult the public on issues related
to nuclear safety.
7.0 Submarine Decommissioning
7.1 The second phase of the Ministry
of Defence's consultation about how to dispose of its redundant
nuclear submarines has now finished. During the course of the
consultation two of the sites proposed were withdrawn - one by
McAlpines to use Ardyne Point, and the other by DML to use Nigg
Bay.
7.2 However, four proposals, remain under
consideration, and the DML proposal is still looking into the
use of Dounreay:-
" Rosyth - Babcocks and Motherwell Bridge: Transport submarines,
or just the reactor compartments (RCs) to Rosyth. Cut up the RCs
in a new facility at Rosyth. Package the ILW and transport to
a store at Coulport or Sellafield.
" Sellafield/Rosyth/Devonport - BNFL: Cut up RCs at either
Rosyth or Devonport or both, but package the Reactor Pressure
Vessel (RPV) separately from other ILW. The RPV & ILW would
then be transported to Sellafield for storage in a purpose-built
store.
" Devonport/Dounreay- DML: Cut out RCs at Devonport and transport
to Dounreay. Further cutting up at Dounreay could be carried out
at a later stage.
" Unspecified sites - SERCO: SERCO present two options. One
involves cutting out the RC and storing, with cutting up later;
the other involves cutting up the RCs and storing ILW on site
or transporting the packaged ILW to Sellafield.
7.3 The Scottish Parliament debated a motion
on 5th November, tabled by the SNP, to reject "any proposal
by Her Majesty's Government to dispose of nuclear waste from nuclear
submarines in Scotland" and to oppose "in particular,
any plans to cut up and store in Scotland any of the redundant
nuclear submarines currently held at Rosyth or those that will
become redundant in future". Scott Barrie, Labour MSP for
Dunfermline West explained that he didn't sign the motion simply
because the proposals are not from the UK Government, but from
industry. The Rosyth proposals gained some support from the Tories
on employment grounds. Maureen Macmillan, Labour MSP for the Highlands
and Islands expressed concern that submarine disposal would be
used as the thin end of the wedge to get a nuclear waste repository
in the Highlands. Mark Ruskell for the Greens stuck to his line
that only those reactor compartments from the submarines already
at Rosyth should be stored at Rosyth, and that there should be
no cutting up of reactor compartments and no new nuclear submarines
built. The SSP criticised the SNP for suggesting the waste should
go to Devonport.
7.4 A report on the ISOLUS consultation will be available
on the website in February 2004. The MoD will now produce a shortlist
of proposals which will go forward for detailed development. These
detailed proposals will be subject to further phase of consultation
in 2005.
8.0 Miscellaneous
8.1 The membership of the new Committee on Radioactive
Waste Management (CoRWM) has been announced, but the chair, Katharine
Bryan has already resigned to take up the post
of Chief Executive of the Water Service in Northern Ireland).
Mrs Bryan was appointed to CoRWM in July. Gordon MacKerron (see
Magnox News) is the new chair. Delays in setting up the committee
do not appear to have affected the date it is expected to report
to the Government - around 2006. As a consequence concerns have
been expressed that the Committee's remit will be limited to simply
looking at High and Intermediate-level waste. And may not be able
to look at, for example, whether plutonium should be declared
a waste or how to managed spent nuclear waste fuel.
8.2 The people appointed are :
Mary Allan - Lecturer, The North Highland College, Dornoch Campus,
Professor David Ball - Professor of Risk Management and co-Director
of Centre for Decision Analysis & Risk Management, Middlesex
University,
Fred Barker - consultant, specialising in nuclear policy analysis
and stakeholder engagement.
Dr Keith Baverstock - chemist, Docent in Department of Environmental
Sciences, Kuopio University, Finland, former Head of Radiation
Protection Division, World Health Organisation
Professor Andrew Blowers OBE - Professor of Social Sciences at
the Open University, former county councillor, Board Member of
Nirex UK
Professor Brian D Clark - Professor of Environmental Management
& Planning and Board Member, Scottish Environment Protection
Agency,
Dr Wynne Davies - former Vice President, Group Health, Safety
and Environment, Amersham plc and former Lecturer in Physics and
Radiation Biology, University of London,
Dr Mark Dutton - physicist and radiological protection and radioactive
waste management expert, independent consultant, formerly with
NNC
Gordon MacKerron - economist and energy policy consultant, Associate
Director, NERA,
Professor Lynda Warren - zoologist and Emeritus Professor of Environmental
Law at the University of Wales, Board Member of the Environment
Agency,
Jenny Watson - Deputy Chair, Equal Opportunities Commission and
former Chair, Nirex Independent Transparency Review Panel.
Pete Wilkinson - Director of Wilkinson Environmental Consultancy,
former Chair of Greenpeace UK, Director of Greenpeace International
and co-founder of Friends of the Earth.
8.3 The next Low Level Radiation and Health conference
will be held at Heriot Watt University, Edinburgh on July 3rd
and 4th, 2004. Speakers will include Dr Keith Baverstock (see
8.2) and Dr Eric Wright from Dundee University.
8.4 UK Energy Minister, Stephen Timms, postponed a trip
to Japan scheduled for November during which he was expected to
attempt to persuade the Japanese Government to end its ban on
buying MOX fuel from BNFL. The trip is now expected to take place
early in 2004.
8.5 The DTI has launched a consultation on modernising
policy for decommissioning UK nuclear facilities. Responses are
required by 27th February. The new proposals suggest that restoring
sites for unrestricted use may not always represent the Best Practicable
Environmental Option. Previous policy assumed that a nuclear waste
repository would be available. The proposed policy allows for
the possibility that some wastes may need to be stored for a period
of time on the nuclear sites. The new policy also allows for greater
consultation with local communities and other stakeholders.
8.6 The results of a Strategic Review of BNFL were announced
on 11th December. Originally the rump of BNFL was to be partially
privatised, but this is no longer considered an option. However,
proposals for involving the private sector in individual parts
of the BNFL business will be examined. Earlier suggestions that
BNFL would be asked to sell its US Westinghouse subsidiary were
dropped, but steps will be taken to enable the business to operate
with greater financial independence from its parent, so that possibilities
for private sector participation are opened up. Westinghouse is
an international supplier of nuclear plant products and technologies,
including nuclear fuel and also owns the AP1000 reactor design,
which is being considered as the design for new nuclear reactors
should they be built in the UK. The Government's failure to force
BNFL to dispose of its Westinghouse subsidiary, magnifies suspicions
that plans for the new Nuclear Decommissioning Authority are simply
an exercise in getting the bankrupt nuclear industry back on its
feet again in time to make another attempt at building new nuclear
stations in the UK after the next General Election. Westinghouse
and BNFL's role in promoting new reactor designs around the world,
detracts from the public support which a new BNFL focussed purely
on clean-up and decommissioning, might otherwise enjoy.
8.7 The US Energy Bill, which would give tax breaks to
new nuclear reactors worth up to $7.5bn , failed to get through
the Senate in 2003. It may be introduced again during 2004, but
will most likely have to wait until after the Presedential elections.
However, the nuclear industry is hopeful that reactor building
in the US will resume soon. So, we could soon see a company, owned
by the UK Government building new reactors in the United States
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