DTI, BNFL and BE expect new reactors within 10 - 20 years

At the end of 2002, before the Government’s Energy Review was published, the Health and Safety Executive, parent body of the Nuclear Installations Inspectorate, commissioned an independent review of the staffing needs of the NII. This review was delivered in July 2003, and confirms suspicions that planning for a nuclear revival is underway despite the Energy White Paper.

The independence of the review team can be gauged by the presence of Gregg Butler, a BNFL board member who expands to fill any space he is in. The review felt that the demands on the NII to regulate nuclear power stations and fuel processing plants are likely to decrease steadily and massively over the next few decades, as old plants are retired.

As this reduction in its traditional workload occurs the NII will need to take care to ensure that its effort remains proportional to the hazards it regulates as these decrease. This is code for cut the NII down to size, but hope is offered if the NII were to change in its direction, towards assessing new nuclear reactor designs.

Although the review acknowledges that there is little immediate likelihood of new-build “it may be appropriate to seek to develop a licensing regime for international designs which would keep the option open”. DTI’s ‘Secret plan to revive British nuclear power industry’ (New Scientist July 4th 2002) which was based on the 'harmonisation' of the licensing of new reactors with 'overseas' arrangements is clearly proceeding. The ‘expected case’ scenario for the coming 10 - 20 years contains a startling assumption that in addition to the NII giving a preliminary "licensing view" on a number of potential new reactor designs submitted by BE and BNFL:

“there are at least two major public enquiries involving significant input from NII, e.g. into a new Pressurised Water Reactor (PWR) station or a new reactor on the Sellafield site or new interim or long-term storage facilities".

The review confirmed that few stakeholders held out any realistic hopes for any significant new reactor build during the review period. However, NII is seen by DTI, BNFL and BE as providing an important link with the development of new reactor designs overseas. In particular, they feel that NII can play an important role in the "harmonisation" of licensing approaches for such new reactor designs.

According to the review the ‘open-ended prospect of regulator-led design change’ which characterised previous programmes has got to be dispensed with.

Changes to the Westinghouse Standardised Nuclear Unit Power Plant System (SNUPPS) reactor submitted to the NII in 1981 were required for that design to meet British safety standards. They resulted in Sizewell B having 13% more large pipework and 22% more cabling than SNUPPS, as well as 75% more structural concrete.

The ‘simplified’ AP 1000 design that BNFL are currently promoting has half the valves, two thirds of the pumps, a fifth of the pipes and a third of the cabling of a ‘current’ PWR. The review concludes that for new reactors to be built in the UK there will need to be a licensing regime which gains public assurance ‘while moving to international designs and safety standards’. Without such a regime ‘new build cannot happen’.

The NII Response

The staffing review’s point that the current reactor licensing regime was not well suited to accepting international designs was rejected by the NII. “UK licensing regime is flexible enough to deal with foreign reactor designs as shown with Sizewell B, which was based on the US SNUPPS design.

For future international designs what is needed is development of agreed international safety standards and resources to enable NII to work with other regulators in assessing specific future reactor designs against internationally agreed standards/requirements. NII needs legislative vires to recover costs for this type of work.”

In addition the NII has published its own projections of staffing needs over the next twenty years . See chart below. This specifically ignores the resources that would be needed for new build, but assumes that the current projections for the closure of Magnox stations will occur as BNFL expects.

The Nuclear Decommissioning Authority - how will it work?

The draft NDA Bill has given us a glimpse of the future of the nuclear legacy, but left some unanswered questions. The NDA is to be the ‘owner of the site’ but will manage at a strategic level. As ‘licensee of last resort’, it will establish ‘site licensee companies’ on each site in order to hold the site licence and promote competition for ‘site management contractors’.

The danger is that the NDA site licensees will lose control of safety if they have insufficient staff to act as an ‘intelligent client’ and ensures that site management contractors fulfill their contracts. A loss of control of site safety to decommissioning contractors lead to the "chronic safety problems" that emerged at the Dounreay nuclear plant in Caithness in 1998.

It is understood that discussions between the DTI and the NII are still going on to identify the ‘person in control’ of safety on each site.

WANA Comment - It should be the person holding the license. The NII, working with the NDA, is going to have to demonstrate that it is 'driving' decommissioning and waste management in a 'pro-active' way.

The current 'non-prescriptive' licensing regime for operating reactors is insufficient to regulate sites once the income stream from the site has ceased. The public cannot have confidence in a regulatory regime that is tailored to the business interests of the licensee once those interests are best met by delaying indefinitely the final dismantlement of reactors. To ensure public confidence in the management of nuclear sites that are destined to become 'de facto' radioactive waste stores for the coming 50 years at least there will have to be much greater involvement at local and regional level of 'stakeholders'.

The DTI appear to accept this, and are currently engaged in several rounds of ‘stakeholder workshops’ to pave the way for the NDA Mere repackaging of the puny ‘Local Community Liaison Committees’ will not convince anyone that the NDA means business.

CoRWM - what’s going on?

The membership of the new Committee on Radioactive Waste Management is to be announced ‘any day now’ (Nov 13th) In July last year Margaret Beckett, Secretary of State for Environment, Food and Rural Affairs, announced: “An independent body will be appointed to oversee a review of the options for managing the U.K’s growing stockpile of radioactive waste. “The first step of the review will be to set the framework for debate by establishing broad agreement on the wastes to be considered, the range of management options for each of them, and the criteria against which these options should be assessed.

In the terms of reference for the new Committee, a ‘priority task’ is identified ‘to recommend what should be done with the wastes for which no long-term management strategy currently exists - that is, high and intermediate level waste now in storage or likely to arise over the next century or two, and some low level waste unsuitable for disposal at Drigg.’

Now, CoRWM’s remit is being described by DEFRA as merely:

‘To recommend to Government what option(s) should be adopted for long term management of the UK’s higher activity wastes.’

So the first step of CoRWM’s work has apparently been completed, before it has even been announced who is on the committee.

However, CoRWM will tackle vitrified heat-emitting high level waste. In 1980 a programme of test drilling to find a suitable site for the emplacement of high-level heat-emitting radioactive waste was abandoned. This was principally because of the unsuitability of geological strata to withstand the build up of heat from the waste, even though it was to have been stored for twenty to thirty years above ground before burial. It was decided to store the heat emitting HLW for fifty years.

Where does this leave Trawsfynydd?

CoRWM is not to consider decommissioning wastes as a priority. This leads to suspicion that the 'long-term management strategy' is that radioactive waste within Magnox reactors is to be left 'in situ', indefinitely Current Government policy (Cm 2919, 1995) is for reactor dismantling 'as soon as reasonably practicable' taking account of all relevant factors, a policy which WANA heartily endorse. The HM chief inspector of nuclear installations made it clear at the Trawsfynydd public inquiry that there was 'no reason on earth' why Trawsfynydd should not be completely dismantled [within 30 years of shut down], except one - the absence of a national repository.

One interpretation of CoRWM's remit is that there may never be a national repository for Trawsfynydd decommissioning wastes.

On current evidence the NII may regard that situation as sufficient reason for accepting an open ended delay in dismantling the reactors.

This is the worst of all possible worlds: potentially unstable intermediate level waste in Magnox reactors may simply be left to deteriorate, because of some circumstance 'off site'.

New decommissioning policy proposals ‘around turn of the year’

Responding to these concerns the Radioactive Substances Division of DEFRA have told WANA that the White Paper Cm 2919 is set for Government review and that there will be a consultation concerning new decommissioning policy proposals around the turn of the year. This will ‘allow any comments resulting from the Trawsfynydd case to be input’.

1 The role of CoRWM is to recommend policy for the long-term management of the UK’s higher activity wastes. This will include the ILW which will have to be stored on the Trawsfynydd site for an interim period.

2 Ultimately, the CoRWM process will lead to decision on the construction of long-term management facilities for ILW and other higher activity wastes. This will allow the ILW to be moved offsite to a final resting place.
DEFRA recognise that there could be important issues associated with the long-term management of low and very low activity wastes likely to arise from decommissioning activities.

1 Should these wastes all be dug up and transported to Drigg? or

2 should they remain on the site of creation in some suitably managed way?

The post closure safety case assessment of Drigg, currently being overseen by the Environment Agency, could have a bearing on the decisions taken.

Government and the LMU are currently discussing the lower activity waste issues, which will be subject to future exposure to wider debate.

WANA Comments - DEFRA implied in “Managing Radioactive Waste Safely” (Sept 2001 para 3.16) that nuclear power station decommissioning is to be delayed by 100 years stating of ILW: ‘the rate arising increases after 2100, as nuclear power station decommissioning is completed.’

The DTI white paper ‘Managing the nuclear legacy’(July 2002, para 7.41) made it clear that the issue of ‘what is meant by decommissioning being carried out as soon as reasonably practicable’ is one of the issues that the Government specifically wishes to see addressed.

WANA argues that:
1 All radioactive waste remaining on the sites of redundant nuclear reactors should be treated with appropriate care, not just the operational waste of concern to CoRWM
2 Reactor dismantling, within 30 yrs, should be 'decoupled' from the national repository.
3 A purpose built on-site facility for all the decommissioning waste should be built to store it in a passively safe condition, until there is somewhere for the waste to go.

In the absence of consideration by CoRWM we have no option but to continue to campaign for a purpose built store at Trawsfynydd large enough for all the decommissioning waste to be stored in a passively safe condition.

Advance Notice: The next Low Level Radiation and Health Conference Is to held at Heriot Watt University, Edinburgh, on July 3rd and 4th 2004
Dr Keith Baverstock has agreed to give the opening
Alice Stewart lecture
Details from: Mark Howarth [jillandmark@lineone.net]

EVENTS Dec 6th 11am WANA Meeting - Cardiff County Hall Atlantic Wharf, Cardiff

Published by WANA PO Box 1, Llandrindod Wells, LD1 5AA,   Tel: 01982 570362

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