APPENDIX 12
Memorandum by the Nuclear Free Local Authorities
(NFLA) Steering Committee
INTRODUCTION
1. The NFLA Steering Committee has the support
of 72 Local Authorities throughout the UK including Glasgow, Edinburgh,
Leeds, Manchester and the Greater London Authority. Some of its
member authorities host nuclear sites, some are neighbouring authorities
concerned about local economic, safety and environmental impacts
of future legacy management, others are more widely dispersed
and affected, for example, by nuclear transportation or historic
(and potentially future) nuclear facility siting issues. All are
concerned about potential major nuclear accident consequences
and co-operate in the collective community interest to: eliminate
the major production cycles that generate radioactive wastes;
phase out nuclear generating capacity; and ensure safe management
of the radioactive waste legacy.
THE REMIT
AND ACTIVITIES
OF THE
NDA
THORP, Magnox Reprocessing & the SMP
2. The NFLA Steering Committee contributed
to the Local Government Association Special Interest Group on
Radioactive Waste Management and Nuclear Decommissioning (now
known as the Nuclear Legacy Advisory Forum [NuLeAF]) response
to the NDA's Draft Annual Plan. This submission raised concerns,
in particular, about the failure by the NDA to produce a justification
for the continued operation of Magnox power stations, the Sellafield
Thermal Oxide Reprocessing Plant (THORP) and MOX/plutonium fuel
fabrication plant (SMP) for public consultation.
3. The NuLeAF submission stated that:
"There are concerns amongst some Local Authorities,
at the absence of any consultation in the context of the Annual
Plan on the merits of continuing to operate plant at Sellafield
and elsewhere. On the figures alone, it appears that the NDA considers
that it will cost more to run plant than any income that they
will generate. The failure to consult in this context contradicts
clear expectations raised."
4. In addition to its Draft Strategy, the
NDA has published an Environmental Report. This assessment includes
an evaluation of some of the operating facilities and the alternatives
to continuing with operations. But this cannot be described as
a detailed rationale for keeping the plants open. The alternative
to continuing to operate the SMP for the production of MOX is
not evaluated because "there is likely to be little or no
significant environmental effects arising from the proposed approach
as compared with the baseline". Magnox reprocessing is not
evaluated separately from Magnox generation. NFLA Steering Committee
is concerned that these commercial activities undertaken by the
NDA will result in further costs to the taxpayer.
5. The Draft Strategy states that commercial
operations "…divert resources away from our key mission
of decommissioning and clean up"". The NFLA Steering
Committee agrees and believes that commercial operations also
detract from public support for the important and urgent task
of decommissioning and cleaning up the UK's nuclear legacy. Whilst
commercial operations are projected to provide around 50% of the
NDA's total annual budget, it is not clear that continuing with
any of the commercial operations is economically sensible, and
all the operations continue to add to the stockpile of dangerous
nuclear waste for which there is currently no acceptable management
solution.
Magnox Reactors
6. The Draft Strategy states that the NDA:
"will continue to run the operating Magnox
sites until their planned closure dates unless any technical problems
force or justify closure on economic grounds."
This is despite the fact that neither the NDA
nor the Government has set out a justification for continuing
to operate the four remaining Magnox station: Dungeness A, Sizewell
A, Oldbury and Wylfa. The "Managing the Nuclear Legacy"
White Paper states that information on the rationale for continued
operation would be made available on the same basis as THORP and
SMP. (para 5.27)
7. Nuclear Economist, Gordon MacKerron has
stated that:
"there can be little public confidence in
the idea that Magnox avoidable costs are definitively below the
selling price of electricity. Testing this proposition again in
a transparent and accountable way would seem to be a necessary
condition for any future justification and approval of Magnox
operation, and this would in turn require the appointment of genuinely
independent experts to carry out the necessary work".[1]
8. There needs to be an open, transparent
and independent examination of the justification for continuing
to operate the Magnox reactors.
THORP
9. The Annual Plan says the NDA will fulfil
existing THORP contracts to reprocess spent nuclear fuel for UK
and overseas customers. The Government has argued in the past
that existing THORP reprocessing contracts must be honoured because:
"To do otherwise would break existing contractual
commitments and Government Undertakings". [2]
10. This statement clearly only applies
to overseas contracts—not those with British Energy (BE).
BE has previously called for an end to its reprocessing contracts.
A BE spokesman stated that:
"We simply do not believe in reprocessing
because of its huge costs and we want to renegotiate this contract.
We are paying six times as much to deal with our spent fuel as
American generators do at a time when electricity costs have fallen
markedly". [3]
BE has also stated that reprocessing "…has
left us with a service we don't need, for a product we don't want,
and at a price we cannot afford". [4]
11. It has now been revealed that a leak
at the THORP plant, which was discovered in April 2005, started
in July 2004. The leak rate increased gradually until mid-January
2005 when the pipe in question suffered a complete fracture. Although
this leak did not present an immediate danger to the public, sources
at the NDA have said that the most economical option may be to
keep the THORP plant shut. [5]
12. THORP is likely to remain closed for
many more months and its projected revenue will be lost to the
NDA. The NDA's plan for 2005-6 shows that, out of a total budget
of £2.2 billion, it expected to receive £1.08bn from
commercial operations, of which £635.1 million would come
from reprocessing and transporting nuclear material around the
world. A large proportion of this will be from THORP activities.
It is estimated that the leak will cost the NDA at least £300m
in lost revenue this year alone. [6]
13. It is not yet clear how much it would
cost to repair THORP, but there have been several calls to NDA
Chief Executive, Dr Ian Roxburgh, to cut the NDA's losses and
close the THORP plant permanently. With almost all foreign reprocessing
contracts now completed, it would almost certainly be uneconomic
to re-open THORP mainly to continue reprocessing spent fuel from
BE's AGR power stations. This would unnecessarily produce large
volumes of plutonium and uranium for which BE has repeatedly said
it has no use.
14. The Draft Strategy gives life-cycle
costs for Sellafield of £31.5bn and life cycle projected
revenue for THORP at £5.1bn. These figures are almost completely
useless without further information. It is noted that the Draft
Strategy document gives 2011 as the current date for the end of
THORP reprocessing. This should not be taken as a foregone conclusion.
The NDA should be encouraged to carry out an open and transparent
public consultation on the future of THORP. All relevant financial
information should be included in such a consultation.
15. The Draft Strategy also states that:
"We need to find alternatives to reprocessing
AGR spent fuel at THORP as the operating life of THORP is likely
to be less than that of the AGRs".
As well as a debate about THORP's finances,
there should also be an open and transparent examination of the
technical opportunities for the storage of AGR spent fuel, in
particular looking at the options for introducing such storage
as quickly as possible, rather than waiting until current contracts
with BE have been completed. The Draft Strategy says the NDA will
commission work to examine the options for the interim storage
of spent AGR fuel. These studies need to be made public.
16. The NDA says it will ensure that the
return of reprocessing waste products to overseas customers is
expedited. The target date for completion of this process is 2016.
This implies a large number of HLW shipments by sea to Europe
and Japan over the next decade. A draft timetable should be made
public for discussion.
Sellafield MOX Plant
17. The Draft Strategy states that the NDA
says it will "continue to support the commissioning of the
Sellafield MOX Plant (SMP) but its success rests on it meeting
sustained production targets."
18. This statement appears to pre-empt an
open and transparent examination of the justification for keeping
SMP open, as required in the White Paper. As with THORP, the financial
information given in the Draft Strategy is insufficient for any
conclusions to be reached. It states that the life cycle projected
revenue is £0.94bn, but does not give the basis for this
calculation. Does this include, for example, just the signed contracts,
or does it also include potential contracts represented by letters
of intent?
19. The Draft Strategy gives 2016 as the
likely date when commercial MOX fuel manufacture will end. However,
it does say that if SMP is unable to meet its production targets
the NDA will discuss the plants future with the Government, especially
in relation to its potential use in the management of the UK's
plutonium stock. The basis upon which meeting its production targets
is currently considered acceptable should be made clear and discussed
with stakeholders.
20. The NFLA Steering Committee would support
the use of SMP to immobilise the UK's stockpile of plutonium as
a waste-form.
Prioritisation
21. The Draft NDA Strategy states that the
NDA will:
". . . focus on the reduction of potential
high hazards, especially at Sellafield. This is our number one
clean up priority."
Reducing the volume of liquid High Level Wastes
(HLW) is the single most important activity for reducing hazards.
The obvious first step in reducing this hazard would be to end
the production of new liquid HLW—in other words to end reprocessing
of spent nuclear waste fuel. The NFLA Steering Committee has called
for this many times over many years but the Draft Strategy does
not propose this course of action.
22. The Draft Strategy states that the main
focus:
"is to retrieve the radioactive waste that
is currently being stored in an untreated form, in ageing facilities,
and condition it to put it in a passively safe for long term storage
or disposal".
23. Apart from the misnomer of `disposal'
this focus is welcomed. According to Nirex, almost 90 per cent
of Britain's hazardous nuclear waste stockpile is so badly stored
it could explode or leak with devastating results at any time
[7]. A report by two government advisory committees (The Radioactive
Waste Management Advisory Committee and the Nuclear Safety Advisory
Committee) revealed that up to 24 nuclear storage sites around
the UK house volatile material that could explode on contact with
water, spontaneously combust in the air, or leak [8].
24. The Draft Strategy particularly highlights
ageing facilities at Sellafield and Dounreay, with an "ultimate
potential for an uncontrolled release of radioactivity".
It highlights in particular the need for BNG to produce plans
to enable the retrieval of degraded Magnox spent fuel in pond
B30 at Sellafield. It says that the NDA will discuss with the
Government the implications for its funding when fully detailed
plans are available from BNG.
Site end states
25. The Draft Strategy states that the NDA
plans to consult and seek consensus with stakeholders, including
local communities, on site end states. Large volumes of lower
level wastes are expected to arise during decommissioning. The
former head of the Government's Liabilities Management Unit, Alan
Edwards, estimated that these volumes could be sufficient to fill
15 facilities the size of Drigg [9]. Thus, discussion about site
end states will raise a large number of issues. There is likely
to be pressure, for example, to increase the amount of wastes
going to landfill sites, as well as pressure to lower standards
for site remediation in an attempt to reduce volumes of waste
generated and their associated management costs.
26. The recent Government policy review
of decommissioning decided that it is no longer necessarily expected
that sites should be restored to green field status [10]. The
NDA plans to conduct a separate consultation exercise later this
year to reach a consensus among local communities on site end
points. The Draft Strategy says that the full extent of contaminated
land at its 20 sites is not well understood, and will be an important
factor in determining the final end state.
27. Given the impact that site end points
will have on national radioactive waste management policy, the
NDA should consult as widely as possible, and not just with communities
local to their facilities.
Magnox Decommissioning & Radioactive Waste
Management
28. The NDA Strategy seeks to "accelerate
significantly the decommissioning of Magnox stations". The
current approach would take up to 125 years before reactor buildings
are demolished and sites are finally cleared, whereas the NDA
is now saying that it will attempt to achieve full decommissioning
and site clearance in less than 25 years. This, however, will
be "subject to long term waste management arrangements being
available".
29. The acceleration of Magnox decommissioning
is to be welcomed. It is a policy that the NFLA Steering Committee
has called for over many years. However, the Draft Strategy appears
to make the implementation of the 25-year strategy dependent on
the introduction of a centralised storage or `disposal' policy
for Intermediate Level Waste (ILW). The Draft Strategy states:
"the availability of such a repository by
2025 would substantially reduce costs and would ensure the responsible
management of ILW by the existing generation."
30. The NDA's position is in danger of pre-empting
the current policy consultations by the Committee on Radioactive
Waste Management (CoRWM). The NDA has other objectives besides
reduction of costs and it is not clear that a deep repository
does represent responsible management by the existing generation.
This would depend, at the very least, on specific proposals for
a deep repository at a specific site and forecasts about the rate
at which radioactivity would migrate from a repository.
31. The Draft Strategy makes it clear that
the NDA "would not want any of our interim storage facilities
to be considered as providing a long term management solution
(ie several hundred years) since they were not designed to fulfil
such a function".
32. It is the view of the NFLA Steering
Committee that the on-site storage of ILW, following the early
demolition of reactor buildings, in purpose-built, passively safe,
retrievable, and monitorable stores should be the favoured option.
The 25-year strategy should not be dependent on the availability
of a deep repository or a centralised interim ILW store.
33. The Draft Strategy says that the NDA
will evaluate the options for national and regional stores to
take advantage of economies of scale. This implies that, even
if CoRWM decides against a deep repository for ILW, there will
be more transports of ILW from the current locations to regional
or national stores. This underlines the need to take account of
the views of all stakeholders, including those on potential transport
routes, as well as those local to the NDA's facilities.
34. The Draft Strategy is concerned that
the cost of Low Level Waste (LLW) disposal at Drigg is very high
by international standards, and that Drigg will not be able to
take all future arisings from decommissioning and clean-up operations.
The NDA says it will ". . . seek new, more cost effective
solutions for the disposal of the rising quantities of LLW".
The NFLA Steering Committee is concerned that any new LLW management
proposals maintain current health protection and environmental
standards.
35. The Draft Strategy says that it may
be more acceptable to provide a replacement to the Drigg facility
at or close to Sellafield. The NFLA Steering Committee supports
the development, by the Government, of a new LLW management policy
based on a clear set of environmental principles, including the
polluter pays principle and the proximity principle.
Plutonium & Proliferation
36. The Draft Strategy states that the NDA
will discuss with and advise the Government what proportion of
UK plutonium should be held as strategic stock for future energy
use, and the proportion that should be declared a waste. It is
part of the remit of CoRWM to make recommendations to the Government
about this. Arrangements also have to be made, according to the
Strategy, for the repatriation of foreign owned plutonium as MOX
fuel. The Draft Strategy also suggests that the NDA will discuss
the possibility of selling UK plutonium to an overseas MOX manufacturer.
37. The NFLA Steering Committee is deeply
concerned about the proliferation implications of transporting
weapons-useable plutonium around the world, in any form. The NFLA
Steering believes that all plutonium as Sellafield should be converted
to a waste form whether it is UK or foreign owned, by negotiated
agreement with its owners. The NDA estimate plutonium disposal
will cost around £10 billion but there is no explanation
of how this figure is arrived at.
Competition
38. The Government's Nuclear Safety Advisory
Committee (NuSAC) has expressed "serious concerns" about
the plans for contractorisation of decommissioning work, fearing
that financial pressures will encourage the companies to cut corners
and increase risks [11]. These concerns have recently been repeated
by a former Sellafield site director [12]. The NDA should formally
publish the NuSAC advice along with its response explaining why
it does not agree.
Finance
39. The total estimated life cycle cost
of operations, decommissioning and clean up has increased from
£48bn (estimated in 2002) to £56bn in 2005 based on
the life-cycle baselines. The NDA is now expected to announce
that this figure has risen again, possibly to £70bn. The
Draft Strategy warns that costs could increase, particularly if
reprocessed uranium and plutonium are declared a waste. On the
other hand, the NDA hopes that innovation will start to drive
down costs.
40. The Draft Strategy says that "achieving
a rapid decision on rationalising interim ILW storage and LLW
disposal" are key elements in driving down costs. The NFLA
Steering Committee believes that waste management decisions should
be driven primarily by environmental considerations and not by
the need to drive down costs.
41. The Draft Strategy also says that over
the next five years the level of Government funding will need
to increase as commercial income decreases. There may also be
unforeseen closures:
"The uncertainty over the future of THORP
and SMP, and any earlier than foreseen Magnox closure, could lead
to a significant shortfall in commercial revenues".
This suggests the NDA's funding mechanism is
influencing its decisions about whether or not nuclear waste generating
facilities should continue operating or not. It is the NFLA Steering
Committee view that whether or not to continue operating waste
producing facilities should be driven by environmental rather
than financial considerations.
The compatibility of current plans for the NDA
and UKAEA with any increased reliance on nuclear power generation
42. Past policy towards nuclear generation
and waste management practices have together created a substantial
environmental and financial burden on society. For reasons set
out above, the NFLA Steering Committee does not believe the NDA
should itself should engage in its current commercial practices
as these detract from its nuclear legacy clean up task. Any increased
reliance on nuclear power generation will ultimately be underwritten
by the taxpayer and, if past experience is a guide to future practise,
potentially create new significant environmental and financial
liabilities that could be placed upon the NDA, or a successor
body. Therefore the NFLA Steering Committee does not consider
the NDA's main organisational task is compatible with any increased
reliance on nuclear power generation.
NOTES
[1] Letter from Gordon MacKerron to David Chaytor
MP 18 October 2003.
[2] "Managing the Nuclear Legacy""
DTI, July 2002 para 5.18
[3] Nuclear Giant in Spent Fuel Switch. James
Freeman and Catherine MacLeod. Herald 15 November 2001.
[4] Nucleonics Week (2001) BE Blames Reprocessing
Charges for Higher UK Operating Costs. Vol. 42 No. 46. page 6.
15 November.
[5] Close Nuclear Leak Plant for good says Sellafield,
by Oliver Morgan, Observer 15 May 2005 http://politics.guardian.co.uk/green/story/0,9061,1483998,00.html
[6] Sellafield Radioactive Leak to cost £300m,
by Paul Brown, Guardian 13 June 2005 http://www.guardian.co.uk/nuclear/article/0,2763,1505005,00.html
[7] Nuclear stores on verge of exploding, by
Mark Townsend, Observer 30 June 2002.
http://www.observer.co.uk/politics/story/0,6903,746724,00.html
[8] RWMAC and NuSAC (June 2002) "Current
arrangements and requirements for the conditioning, packaging
and storage of intermediate level radioactive waste".
http://www.defra.gov.uk/rwmac/reports/interwaste/index.htm
[9] Alan Edwards speaking at the 6th Irish and
UK Local Authorities Standing Conference on Nuclear Hazards, 25
March 2004, Glasgow.
[10] The Decommissioning of the UK Nuclear Industry's
Facilities, DTI, September 2004. http://www.dti.gov.uk/consultations/files/publication-1365.pdf
[11] "Privatising Nuclear Clean-up risks
public safety", by Rob Edwards, New Scientist 19 February
2005: http://www.newscientist.com/article.ns?id=mg18524874.500
[12] "Privatising Nuclear Clean Up `will
cause accidents'", by Rob Edwards, Sunday Herald, 22 January
2006: http://www.sundayherald.com/print53688
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