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Briefings & Information Submission to DEFRA consultation: Managing radioactive waste safelyMarch 2002
Introduction1. CND welcomes the opportunity to comment on the consultation document 'Managing Radioactive Waste Safely.' (1) 2. The document is essentially a consultation on the consultation process, and its recognition that public acceptance depends on effective and widespread dialogue is an important step forward. Unfortunately, however, the document offers no clearly defined objectives for the process of engaging the public and its format means that this initial stage is unlikely to have engaged many members of the public beyond the usual stakeholders. CND believes this was a missed opportunity. If progress is to be made on this issue it is essential that public involvement is at the heart of the process. 3. The reasons why this is necessary are clear. The public is no longer willing to accept a 'decide - announce - defend' approach to complex technological issues. Pure reliance on scientific expertise is no longer seen as sufficient to meet societal needs and people are now less willing to leave important decisions solely to governments, regulators and industry. Modern approaches must reject the 'top-down' style in favour of dialogue and the building of mutual trust. 4. Early and effective engagement and involvement of stakeholders and the public in the decision making process is vital. Indeed, the decision making process itself needs to be developed collaboratively with the public and adequately reflect the issues raised by them. Openness and consensus building at every stage is the only way to achieve an outcome that attracts public support. Unless people have the sense that their views are actually influencing the decisions, they will not have any real confidence in the outcome. We detect that the consultation document does not fully embrace this kind of approach. History5. The UK nuclear industry developed after World War II with almost no thought being given to the long term. The immediate priority was seen as the production of plutonium for nuclear weapons, followed by the establishment of a civil nuclear industry, itself partly predicated on the military's desire for plutonium. Very little attention was paid to radioactive waste management. 6. A quarter of a century later, in 1976, the situation was such that the 'Flowers Report' felt moved to recommend that "There should be no commitment to a large programme of nuclear fission power until it has been demonstrated beyond reasonable doubt that a method exists to ensure the safe containment of long lived, highly radioactive waste for the indefinite future." (2) 7. Today, a further quarter of a century on, radioactive waste policy is still in disarray. The decision, in 1997, not to proceed with NIREX's proposed Rock Characterisation Facility (RCF) has left the UK without an active programme for the long term management of intermediate level waste (ILW), high level waste (HLW), spent fuel and military waste. 8. It is to be hoped that this consultation is the start of a process that will lead to the remedying of this highly unsatisfactory situation. Comments on specific issues raisedA Public Debate 9. As indicated in our introduction, CND believes that widespread public debate which reaches beyond the usual stakeholders is essential. All of the techniques mentioned in the consultation document probably need to be employed at some stage in the process. The work of existing 'Stakeholder Dialogues' etc can be built upon, but should not be used to short circuit open debate and public involvement. Use of so-called 'Front End' consultations, such as that undertaken by Lancaster University for the MoD ISOLUS project (3), should be more prevalent. 10. In addition, highly visible and ongoing newspaper/media campaigns are required to inform people of the process that is being undertaken and how they may participate in it. Ideally, one such campaign should have been undertaken in relation to the current consultation in order to instigate a wider debate and response. 11. The importance of public debate and involvement is amply illustrated by the situation in Canada where their House of Commons notes that, although the nuclear industry made the technical case for a deep repository, it did not sufficiently engage the public to achieve consensus. Informing the Debate 12. We note that Chapter 6 of the consultation document is entitled "Managing the Debate" whereas in the Conclusions this has become "Informing the Debate". We trust that the former phrase is an administrative error and that the process is indeed intended to proceed in the more open and transparent manner indicated by the latter phrase. 13. CND believes that a new Advisory Body, other than RWMAC, is required and that its remit should be much wider than the information gathering role envisaged in the consultation document. We have considerable sympathy with the view put forward by RWMAC itself which recommends "an independent, or at least balanced - interest body, that is widely accepted as being capable of upholding the broader public interest" and which would oversee the policy formulation process. (4) 14. The new Advisory Body should, under the principle of 'the polluter pays', be funded by both the Government and the nuclear industry, with a composition wide enough to overcome any suspicion of undue influence by either. The specifics of the new Advisory Body's composition should be determined via 'Front End' style consultations over the coming months with a view to having it in place by the end of 2002. 15. CND believes that it is not necessary to nominate a specific research organisation and that the new Advisory Body, itself, should have responsibility for commissioning any necessary research, which could be from a variety of sources both at home and abroad. International experience in radioactive waste management can provide an important body of learning for the UK. 16. As part of the process it is vital that there is free access to all relevant information for members of the public and that that information is presented in a manner which is accessible and readily understandable. The Programme of Action 17. The timescales presented in the consultation document are realistic and the Government should resist recent calls from the industry to reduce them. (5) Undoubtedly, recovery and packaging of legacy waste material will need to proceed independently of the consultation but this is not an argument for shortening the process of arriving at a long term management option. BNFL, in particular, through its participation in the 'Stakeholder Dialogue' should appreciate that proper and serious consideration of these difficult problems takes time. The important thing is to fully engage with stakeholders and the public. Plutonium 18. BNFL currently owns and stores around 60 tonnes of separated plutonium at Sellafield and arisings from Magnox reprocessing will increase this total to 85 tonnes over the next ten years. (6) British Energy (BE) has a further 2.5 tonnes in store at Sellafield (7) and the total UK stock of separated plutonium will reach about 100 tonnes by 2010. (8) 19. In 1999, the House of Lords Select Committee on Science and Technology noted that "in terms of waste management, plutonium is a special case because of the nuclear risk it poses" (9) and that "there is no reason to continue to store plutonium which is surplus to all foreseeable requirements." (10) The Committee, therefore, recommended that a minimum strategic stock of civil plutonium should be maintained as a resource for a future fast reactor programme, but that all other plutonium should be declared a waste. (11) 20. CND welcomed the Select Committee's contention that most plutonium is surplus to foreseeable requirements. We would go further, however, and state that ALL plutonium should be declared waste because of the proliferation risk that separated plutonium poses. Moreover, the possible use of plutonium in a future fast reactor programme is extremely remote. The UK closed its prototype fast reactor at Dounreay in 1994, after some 40 years of development and the expenditure of around £4 billion. (12) Worldwide there is now very little interest in developing such reactors, which have proved themselves to be extremely costly and liable to accidents. In addition to the UK, fast reactor programmes have been cancelled in Germany and the United States, whilst in Japan the Monju reactor has been closed since a sodium leak in 1995 and in France, after a number of years of patchy operation and accidents, the Superphenix fast reactor was closed in 1998 for "economic reasons." (13) 21. The consultation document refers to the possible use of plutonium in MOX fuel and BNFL allude to this in its recent submission to the Environment, Food and Rural affairs Select Committee. However, only one UK reactor, Sizewell 'B', can use MOX fuel and its operators, British Energy, have repeatedly stated that it is uneconomic to do so. It reiterated this again in evidence to the same Select Committee, when it indicated that the price of MOX fuel was five and one half times greater than the price of fresh uranium - that is, MOX fuel costs $60 a pound compared to $9 a pound for fresh uranium. (14) These economics would also apply to any new reactors that might be built. In CND's view, therefore, the use of plutonium in MOX fuel in a normally operating market in the UK is also exceedingly unlikely. 22. It can thus be seen that plutonium has no commercial or practical value whilst at the same time its separation risks nuclear proliferation. It makes eminent sense to declare it a waste. This decision should be taken as soon as possible since it will help to define the wastes that have to be dealt with and is not dependent on any conclusion being reached on a waste management strategy. Military Plutonium 23. There is a further category of plutonium that is stockpiled in the UK which the consultation document does not address. This is military plutonium believed to be held at Aldermaston or under safeguards at Sellafield. 24. In March 2000, it was confirmed that the UK was retaining 3.2 tonnes of weapons grade plutonium in order to service its Trident nuclear warheads. (15) The Strategic Defence Review had earlier indicated that Trident, now the UK's only nuclear weapon system, would need a stockpile of less than 200 operationally available warheads. (16) 25. Modern nuclear warheads are widely reported as containing 3 - 4kgs of plutonium. A stockpile of 200 warheads, therefore, would require some 600 - 800kgs of weapons grade plutonium. Allowing for spares so that 200 warheads are always 'operationally available' a stockpile of 1 tonne of military plutonium would suffice for the UK's perceived needs. Moreover, a recent paper in the journal Nature suggests that not all UK nuclear warheads do indeed use plutonium. (17) 26. CND can see no good reason why the UK is maintaining a military plutonium stockpile of 3.2 tonnes - enough for more than three times as many warheads as it says it has. We believe there is considerable scope for further military plutonium to be declared excess to requirements and placed under international safeguards. Military plutonium under safeguards should be declared a waste along with civil plutonium. Reprocessed Uranium 27. Whilst some reprocessed uranium from the Magnox programme has been used in AGRs in the past this practice ceased in 1987. (18) British Energy is quoted in the consultation document, meanwhile, as saying, of reprocessed AGR uranium, that the case still needs to be made that it is "economic, operationally practicable and safe" (19) BNFL, moreover, had plans to recycle uranium recovered in THORP via a new facility at Springfields but these were terminated in the late 1990s because of lack of customer interest. (20) 28. As with plutonium it would, thus, appear that reprocessed uranium has little commercial or practical value and it should therefore be declared a waste. Depleted Uranium 29. Whilst most depleted uranium from uranium enrichment can be declared waste it is possible that some of this material may have the potential for radiation shielding in any waste management strategy eventually agreed. This is something that should be considered by the new Advisory Body. Additional CommentsReprocessing and Spent Fuel 30. The consultation document makes little mention of reprocessing even though the waste implications of its continuation, or indeed its cessation, will have a profound impact on waste streams. 31. Whilst there may be a case for continued reprocessing of Magnox fuel in order to achieve passive safety, CND finds itself, surprisingly, in total agreement with British Energy and the latter's forthright condemnation of the continued reprocessing of AGR fuel in THORP. Locked into past contracts with BNFL, British Energy has correctly stated that "Reprocessing AGR fuel is an unnecessary and expensive exercise..... 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" (21) A cessation to such reprocessing would avoid the separation of a further 22.5 tonnes of plutonium (22) and enable earlier definition of waste streams. 33. CND has argued that separated plutonium and reprocessed uranium should be regarded as waste. Logically, therefore, spent fuel itself should also be regarded as waste - as it is in most countries of the world. Discharges and Remediation of Contaminated Land 34. CND believes that there needs to be greater coordination between the approaches adopted by the Government towards radioactive waste management and towards radioactive discharges and the remediation of radioactively contaminated land. The consultation document 'comparmentalises' radioactive wastes somewhat. Treatment of radioactive wastes to put them into a suitably passive form and nuclear decommissioning will, however, both lead to additional radioactive discharges. Decommissioning will also include the remediation of large amounts of contaminated ground at nuclear sites and how this is done will impact on the amounts of solid radioactive waste that must then be dealt with. New Build 35. It is CND's view that public acceptance of radioactive waste management policy would be enhanced by a decision to phase out nuclear power and reprocessing and thereby limit the amounts of wastes that have to be dealt with. As a corollary, any suggestion of 'new build' would undoubtedly be seen as extremely cynical in terms of public acceptance of any management strategy. Other Military Wastes 36. CND welcomes the statement in the consultation document that MoD radioactive wastes should be brought under the civilian regulatory regime. (23) In particular, spent fuel from nuclear submarine reactors, currently in store at Sellafield, should be classified as waste and be taken account of in the development of a waste management strategy. Notes |
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