Memorandum submitted by British Energy
INTRODUCTION
British Energy welcomes the further opportunity
for dialogue and consultation on radioactive waste management
that will be provided by the Environment, Food and Rural Affairs
Committee. Our main submission will be made through the DEFRA
consultation process, but set out below is a summary of British
Energy's views on the principal issues and responses to the specific
questions raised by the Committee.
KEY POINTS
British Energy supports the DEFRA consultation
process and considers that public involvement in policy development
and implementation are essential. However, this should not be
used as an argument for delaying decisions. Government will have
to adopt a leadership role in policy development and implementation.
Nuclear generation has a major role to play
in avoiding global warming and providing security of supply, but
its potential is presently constrained by uncertainty on waste
policy.
A clear Government policy and credible implementation
strategy are needed on an early timescale to build public confidence
that there is a solution to radioactive waste management.
There is scope for a reduction in the consultation
timescale, especially as the range of feasible options is already
well understood.
There should be a common UK solution for waste
management. British Energy should be able to contract with a Liabilities
Management Authority, or similar body to take the waste and spent
fuel from its stations. Waste management solutions should clearly
be cost-effective and fit for purpose.
Radioactive wastes can be surface stored in
passively safe facilities for many decades, allowing policy implementation
to proceed at a pace that commands public support.
Ultimately, and without prejudging the output
from the consultation process, British Energy considers that the
principles of sustainability and intergenerational equity would
best be met by the phased co-disposal of all radioactive waste
to a deep geological repository.
At this time we should not foreclose using the
potential energy value of plutonium and uranium by declaring them
to be waste. However, given that there is no technical requirement
to reprocess AGR fuel, and that storage would be considerably
cheaper, there is no logic in adding to existing stocks (which
are already sufficient for any foreseeable requirements) and there
should be a moratorium on the reprocessing of AGR fuel.
SPECIFIC QUESTIONS
1. Timetable and Progress with the consultation
process
British Energy is pleased that the process of
developing a new radioactive waste management policy is underway.
Previous Government policy was effectively undermined by the failure
of the 1997 Rock Characterisation Facility planning application,
and the uncertainty that followed has been unhelpful.
Radioactive wastes are currently stored safely
in purpose designed facilities and can continue to be stored in
such form for many decades. However, a clear policy on radioactive
waste management is essential to build public confidence in the
nuclear industry. Nuclear generation has an essential role to
play if the UK is to meet its greenhouse gas commitments under
the Kyoto agreement and in maintaining security of supply, but
its future potential is currently constrained by uncertainty on
waste policy.
To put the nuclear contribution in context,
about a quarter of the UK's electricity in 2000-01 was generated
by nuclear power. Had this energy been generated with the current
mix of fossil fuels, then the UK's emissions would have been increased
by 50 million tonnes of carbon dioxide, equivalent to the emissions
from almost half the vehicles on UK roads. Over the next 25 years
the nuclear contribution will dramatically decline as all the
BNFL and British Energy nuclear plants (bar Sizewell B) will close.
On current trends, and without new nuclear build, the UK's greenhouse
gas emissions will rise.
The overall approach of the DEFRA consultation
is to develop an inclusive process that genuinely engages the
public in identifying and reviewing the options. British Energy
believes that this offers the best way forward and the greatest
likelihood of success. Experience from the Swedish and Finnish
programmes indicate that developing and implementing a waste management
policy in this way is certainly feasible.
However, British Energy has concerns about the
length of the timescales proposed. Important decisions need to
be taken now about the replacement of nuclear with nuclear if
the UK is to avoid substantially increased carbon dioxide emissions;
this is not compatible with the DEFRA timescales of policy development
by 2006-07. British Energy believes that there is scope within
the consultation process for shortening of timescales without
compromising public involvement, especially in the area of options
development where the range of feasible options are already well
understood and researched.
Consultation and public involvement are precursors
to the development and implementation of policy. The Government
will need to take a leadership role in driving the process forward.
British Energy believes that the important pre-requisites for
developing public confidence are that a publicly acceptable policy
is in place, a credible implementation strategy is clearly mapped
out and that the Government and waste producers are committed
to its implementation. Credibility does not rest on having the
actual solution in place, but rather in the confidence that a
solution has been identified and will be achieved.
In British Energy's opinion, the solution that
best meets the criteria of sustainable development and intergenerational
equity would be disposal of wastes to a deep underground repository,
although surface storage is nonetheless a feasible option. Emplacement
in a repository could be phased over a period of many decades,
with monitoring and retrievability built in, and could allow for
the disposal of a wide range of radioactive wastes including high
level waste and spent fuel. Such co-disposal of wastes to a single
repository would reduce the need for a difficult and repetitive
site selection, regulatory and licensing process. A single site
would also reduce the impact of site development and construction
activities and the associated anxiety felt by local communities.
Reconciling the national need for a solution
to radioactive waste management with the local needs of communities
who may be called upon to host such a facility is an important
issue for the consultation, and one that does not appear to be
explicitly addressed. Factors such as community benefits, the
right of veto and planning mechanisms need to be considered at
the outset if the policy is to be credible and implementable.
2. What difficulties arise from current radioactive
waste policy, including consideration of what should be defined
as waste?
The main problem with current radioactive waste
policy has been the uncertainty caused by the 1997 RCF decision
and the abandonment of the repository programme. This left the
policy with no mechanism by which it could be implemented and
therefore minimal credibility.
Whilst this uncertainty has had little direct
impact on the current management of radioactive wastes, (which
can continue to be stored safely for a considerable time) there
have been, and continue to be, areas of difficulty.
One such area concerns the funding of future
radioactive waste management liabilities. British Energy makes
provisions in its accounts, and through a separate decommissioning
fund, for future radioactive waste liabilities. Such provisioning
is undertaken prudently, using conservative assumptions. However,
in the absence of firm policy the company may need to carry excessive
provisions within its accounts. Secondly, uncertainty about the
scale of waste management liabilities increases the business risk
of new build and may act as a deterrent to private sector investment.
A further issue concerns the difficulty of reaching
agreement with the environmental regulators on the management
of certain wastes, because of their concerns to avoid foreclosing
options for future disposal.
But perhaps the most significant issue is the
future status of plutonium and uranium, which arise from the reprocessing
of spent AGR fuel.
Separated plutonium and uranium are potentially
valuable energy resources and British Energy, through its reprocessing
contracts with BNFL, has spent a considerable amount of money
in their production. British Energy has never re-used any of the
material produced by reprocessing because it would be uneconomic
to do so; this is likely to remain the case in the short to medium
term. However, we do not consider that it would be appropriate,
at this time, to foreclose using the potential energy value of
plutonium and reprocessed uranium by declaring these materials
as waste and treating them to make them unavailable for use. There
are no compelling safety or security issues that require such
a decision to be made.
At the same time there is no logic in adding
to the existing stocks. Reprocessing AGR fuel is an unnecessary
and expensive exercise that British Energy cannot afford. Reprocessing
produces materials that have no current economic value. There
is no technical need for reprocessing; BNFL could provide storage
only management at a fraction of the cost, leaving open the option
in the future to reprocess if it became economically desirable
to do so. British Energy has made it clear in a previous submission
to the Trade and Industry Committee that it would prefer not to
reprocess AGR fuel, but it is constrained by contracts which BNFL
are not currently prepared to renegotiate.
Most countries do not carry out reprocessing,
recognising the economic drawbacks, and propose to directly dispose
of their spent fuel. In the US, nuclear operators deal with their
spent fuel management on a "pay as you go" basis, paying
$1 per MWh to Government. In the UK, British Energy has to pay
BNFL and other government organisations some six times this amount.
Put quite simply, if the UK arrangements for spent fuel were to
apply in North America, British Energy would be making a loss
there and if the US arrangements were to apply in the UK, we would
be in profit here.
One of the concerns about the long time scales
involved in the consultation process is that BNFL will continue
in the interim to reprocess spent AGR fuel, producing more separated
plutonium and uranium. If all British Energy's AGR fuel were to
be reprocessed under current contracts it would result in the
production of about 25 tonnes of plutonium. Currently BNFL has
only separated about 2.5 tonnes of British Energy's plutonium
and therefore the production of 22.5 tonnes of plutonium is potentially
avoidable. British Energy therefore proposes that there should
be a moratorium on the reprocessing of AGR fuel until the future
status of plutonium and uranium is determined.
3. The impact that future decommissioning
of nuclear power plants, any construction of new plants, and the
commencement of MOX production at Sellafield will have on radioactive
waste policy
British Energy's decommissioning strategy involves
the early dismantling and removal of all the power station with
the exception of the reactor building, which is transformed into
a strong and robust "safestore" engineered to be weatherproof
and intruder resistant for a very long period of time. This allows
the radioactivity within the reactor to decline over time, enabling
the eventual dismantling to be carried out more safely, with less
overall radiation dose to the workers and public and producing
less radioactive waste. Our research indicates that this deferral
should be for a period of at least 85 years.
British Energy considers that this strategy
is flexible enough to deal with a number of policy end points.
If a deep disposal approach is chosen, then the safestore can
be dismantled at any time after 85 years with the wastes transferred
to a repository. Alternatively, if interim long-term storage is
adopted, then a safestore can be maintained and refurbished to
provide storage for a significantly longer period of time, potentially
up to 150 years. Radioactive wastes, other than the reactor and
associated plant, will be stored safely, either within the safestore
or in a purpose built store on the site.
Radioactive waste from a new generation of nuclear
power stations is expected to be considerably less than from the
Magnox and AGR plants, due to advances in design and technology.
In addition, it is extremely unlikely that spent fuel arising
from new build will be reprocessed. To put this in context, RWMAC
have estimated that a continuation of a nuclear power programme,
involving a further eight PWRs over the next 30 years, would increase
total waste quantities by only 5 to 10 per cent. Nevertheless,
from a public confidence viewpoint, it is difficult to envisage
new nuclear power stations being built without a firm Government
policy and credible implementation strategy for radioactive waste
management in place.
The radioactive waste management implications
of the commencement of MOX production at Sellafield are a matter
for BNFL and the regulator. However, British Energy does not believe
that MOX production involves the creation of any substantially
different or difficult waste forms that would need to be specially
taken into account.
A key principle for future policy will be to
ensure that there is a single UK solution for radioactive waste.
British Energy is responsible for a small proportion of the UK's
radioactive waste, with the majority being in the public sector.
It is likely that the Government will be proposing a new mechanism
for the management of public sector radioactive waste, potentially
through a Liabilities Management Authority.
The roles and responsibilities of such a body
are not yet clear, but it would be sensible for such a body to
assume responsibility for the whole UK radioactive waste inventory.
British Energy would therefore wish to be able to contract with
the LMA to transfer historic wastes, and adopt a pay as you go
approach for spent fuel from future operations, and we propose
that the Government should enter into negotiations on the scope
and nature of such contracts. Clearly, cost effectiveness must
be a major driver for any Liabilities Management Authority and
British Energy would expect to see robust financial accountability
mechanisms in place to ensure that the chosen policy option is
implemented in a fit for purpose manner.
British Energy
November 2001
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