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Scottish Environment Protection Agency PO Box 5708 Dingwall IV15 9YS dcon@sepa.org.uk By Email and Post 23 February 1998 Dear Mr Fearn
Radioactive Substances Act 1993 Decision by SEPA on the Application from the UKAEA to Dispose of Radioactive Wastes for Dounreay, Caithness, Scotland. Second Consultation, November 1997
***** Greenpeace objects to the UKAEA’s application for authorisations to dispose of radioactive wastes from Dounreay. Despite repeated rounds of public consultation, the application remains deficient in several key areas. It cannot be det ermined from the information presented in the second SEPA consultation that the UKAEA’s planned discharges are justified. There has been inadequate consideration of alternative strategies for dealing with Dounreay’s radioactive legacy and those of other n uclear operators, SEPA should therefore reject the application. *****
Greenpeace February 1998 The reasons for Greenpeace’s objection are set out below. Further to our submission to the consultation on the UKAEA’s application for revised radioactive discharge authorisation held by the now defunct HM Industrial Pollution Inspectorate, Greenpeace is now submitting its views on the Decisio n by SEPA on the Application from the UKAEA to Dispose of Radioactive Wastes from Dounreay, Caithness, Scotland. This document should be considered in conjunction with Greenpeace’s previous submission made on 22 February 1996, and its presentation to the SEPA Main Board in Inverness on 26 February 1997. In addition to having to demonstrate that their proposed radioactive discharges are justified, the UKAEA is obliged to also show that their plans are sustainable. None of the documents presented by the UKAEA adequately address either is sue. According to the Government Panel on Sustainable Development: "Nuclear energy arouses particular concerns in the public mind, partly because of its intrinsic nature and partly because of past attempts to minimise the effects of acc idents. The panel believes that there should be much greater openness and public understanding of the issues if such concerns are to be met." Pursuant with this principle and SEPA’s own acceptance that "there should be clear economic justification for reprocessing overseas material", Greenpeace along with two other Non-Governmental Organisations requested of SEPA, t he UKAEA and the Department of Trade and Industry (DTI), economic information on proposed MTR reprocessing contracts in order to appraise the economic justification for continued reprocessing of spent highly enriched uranium fuel from overseas research re actors (enclosed). However, no additional information has been supplied by either the UKAEA or SEPA, while at the time of writing no detailed response has been received from the DTI. Justification SEPA appears to be simply accepting all of the financial information presented by the UKAEA as correct and free from error. The history of the Dounreay site and continued mismanagement by the UKAEA warrants that no such trust be given. Indeed, in considering an application by British Nuclear Fuels to begin operating the Sellafield MOX (SMP) plant at the end of last year, SEPA’s sister body south of the border, the Environment Agency, commissioned an independent analysis of the SMP’s eco nomics and then issued the resulting report for public consultation. Greenpeace, therefore, finds it impossible to comment fully on the justification for overseas reprocessing. However, despite the lack of detailed financial information presented in the consultation and sought by SEPA, Greenpeace bel ieves that such contracts are not in the public interest for a number of reasons, including: O HEU is a weapons grade nuclear material and therefore a proliferation risk. Indeed, both the International Atomic Energy and the US Department of Energy are strenuously opposed to continued international commerce in HEU; O Radioactive discharges are still suspected of contributing to the excess of childhood cancers in the vicinity of Dounreay; O The UKAEA has yet to uncover the source of significant ongoing radioactive contamination both on and off the Dounreay foreshore and the presence of three highly radioactive particles on the Sandside public beach. While an investiga tion of the source of the particles conducted jointly by two government advisory bodies, RWMAC and COMARE, failed to rule out the fuel handling area of the MTR reprocessing plant (D1204) as a possible source; O The transportation of radioactive materials to and from Dounreay subject the people and the environment of the north of Scotland, and beyond, to a high level of unnecessary risk, particularly given the inadequacy of the IAEA regula tions for the transport flasks employed by the UKAEA and its clients; O At a time when international efforts to establish permanent repositories for nuclear waste disposal have all but collapsed, reprocessing at Dounreay massively increases the volume of radioactive material ultimately requiring dispos al; O While international consensus dictates that discharges of radiation to the environment should be driven down, SEPA’s proposed authorisations would allow Dounreay to buck this trend and actually increase some of its discharges. Ther e is simply no explanation of how he UKAEA will meet to objectives of the OSPAR Convention "to reduce and eliminate discharges." That the UKAEA continues to hide behind the disingenuous notion of commercial confidentiality can give no confidence to the public that the correct decision is being reached. It reinforces the fact that despite considerable lip-service being paid by the UKAEA and SEPA to "openness and honesty" that no such policy exists in reality. Once more it can be seen that information of vital importance to public participation in decision making process – and therefore central to the gov ernment’s policy on sustainable development -- is being withheld. Further, the position casts considerable doubt on SEPA’s ability to reach a decision on whether or not so-called commercial MTR reprocessing is economically justified. In a letter to the consultants commissioned by Greenpeace et al to e xamine the economics of overseas MTR reprocessing Mr Hugh Fearn of SEPA said: "… I would inform you that SEPA does not have the information you have requested." Waste return Greenpeace shares SEPA’s concern that waste dumping rather than reprocessing is the main reason overseas research reactor operators seeking contracts with UKAEA. Indeed, this concern is also shared by the government’s Radioactive Waste Management Advisory, RWMAC. In its recent report, "The Import and Export of Radioactive Waste", RWMAC reports: "In the RWMAC’s view it is conce ivable that a situation might arise where a foreign concern was willing to enter into a reprocessing contract, whether for irradiated or unirradiated fuel, with a United Kingdom company in order to rid itself of what is construed as a waste management pro blem, possibly one of inadequate or hazardous storage. This view can be linked to suggestions that developments in the world nuclear industry are mitigating against the re-use of materials separated during reprocessing." RWMAC concludes: "… the regulators should look carefully at whether recovery is the genuine prime purpose of the importation or whether the United Kingdom might, in certain circumstances, really be acquiring the waste management pr oblems of another country." These concerns have are also been expressed by Michael Meacher, Environment Minister, who when in opposition wrote to the then Environment Secretary, John Gummer, calling for an inquiry into all aspects of operations at Dounreay. In the letter, 15 October 1996, he wrote: "Dounreay has entered into a series of reprocessing contracts which will result in reprocessed radioactive waste remaining in store at Dounreay for up to 29 years before being returned to t he foreign originator and owner of the spent fuel. Recently Dounreay has sought further contracts with Australia and Germany. The Government’s own Radioactive Waste Management Policy White Paper (Command 2919) states at paragraph 145 that ‘radioactive was tes should not be imported into the UK except for the recovery of re-usable materials, provided that is the genuine prime purpose’. One focus of the inquiry is whether this test has been satisfied in respect of current and planned activity at Dounreay.&qu ot; Greenpeace can see no reference within the proposed authorisations that SEPA has sought to establish whether reprocessing is the genuine prime purpose of any of the UKAEA’s supposed customers. Indeed, in the case of both Germany, as highlighted by RWMAC, and Australia there is considerable evidence to the contrary. PFR Reprocessing Against a backdrop of a growing international stockpiles of separated plutonium Greenpeace believes that there is no rationale to support the continued reprocessing of spent fuel from the Dounreay prototype reactor in D1206. For PFR spent fuel management, the UKAEA’s view that reprocessing is the best option is not sustainable. The Royal Society, in a report published this month (February), warned: "The current stock of civil plutonium in the UK is about 54 metric tons (MT). It is forecast to rise to over 100 MT by 2010. We are disturbed by the current la ck of strategic direction for dealing with plutonium." According to the Society: "the existing stock of separated plutonium is far larger than would be needed to initiate any advanced reactor programmes which may be developed within the next few decades." "It is worth noting", concludes the Royal Society: "that by 2010 the predicted UK stockpile will account for about two-thirds of the predicted global separated plutonium inventory." To continue separating plutonium from spent nuclear fuel clearly makes no sense and can only further add to the growing threat of swelling international plutonium stockpiles. With the breakdown of the D1206 mixed oxide fuel reprocessing plant and an estimated £20 million repair cost, reprocessing no longer compares favourably with the cost of storage and direct disposal, even using the UKAEA’s figures. Arguments, given legitimacy in the SEPA decision document, that "plutonium resulting from PFR reprocessing activities at Dounreay could be used as a fuel" betrays the scant attention paid to the question of whether the plutoni um is actually needed or indeed desired. Currently, separated plutonium has no net value. It is a liability requiring expensive anti-proliferation protection. It is further worth noting that although BNFL has applied to bring on line the Sellafield MOX plant, there is no market in the UK for MOX fuel. Only Sizewell B could readily accept MOX fuel, and even then at only one third of its core, British Energy, its operators, say they have no plans to use MOX fuel. MOX fuel further leads to additional complications in reactor operation and ultimately waste management and disposal. There is no clear rationale for continued PFR reprocessing and any emissions associated with the practice should be rejected by SEPA. NII safety review Additional questions arise over the economic justification for reprocessing of any kind at Dounreay from the NII’s decision to conduct full safety reviews of Dounreay’s two reprocessing plant. Dave Turton of the NII has acknowledged tha t the plant are old, commenting: "A lot of the fuel cycle area is by no means new." The NII will block any reprocessing at Dounreay until it is satisfied that the plant can meet modern safety standards, arguing: "Plant improvements will be sought where they are required and where it is reasonably practicable to do so." "Adequate safety cases will be required before agreement is given both to the receipt and reprocessing of Australian materials reactor fuel in D1204 and to the operation of any new dissolver for D1206." The NII safety review clearly raises the possibility of expensive repairs to both reprocessing plant which date from the 1950s, which could clearly have a major impact on the economic for any future reprocessing. SEPA should delay any d ecision on reprocessing discharges until the NII review is complete. Decommissioning As there has been no public consultation on the proposed programme of decommissioning. It is impossible for Greenpeace to assess the justification for the emissions resulting from decommissioning work, or whether any alternative pro posals, which might result in lower or zero emissions have been considered. Discharge limits In accepting that discharge limits should closer reflect the so-called stated need to discharge SEPA unfortunately appears satisfied to allow the claimed need to discharge to be based on the maximum design throughput of all of the plant on site and that all plant are operating simultaneously. It further allows an additional operating margin over the sum of the plants design capacity. This is extremely difficult to sustain. It is inconceivable that all plant will operate at maximum desig n levels simultaneously, and there is no clear rationale demonstrated for employing an operational flexibility multiplier for setting discharge limits. In a letter to Llew Smith MP (2 September 1997), Environment Minister Michael Meacher has said he wants "to make progress on the question of reducing nuclear discharges to the marine environment." He also told Radio 4’s Today programme of the need for "much tougher rules for sharply reducing discharges to sea of radioactive and hazardous waste." The UK Government will not meet its objectives if SEPA's proposed authorisations are approved.
****** In conclusion, Greenpeace believes that while SEPA has made some significant improvements in approaching Dounreay’s application for revised discharges, it is too little too late. The Dounreay nuclear site is one of the worst nuclear contaminated sites in western Europe and presents this generation and future generations with the expensive and dangerous problem of rendering its legacy safe, there can be no reason able grounds for allow the UKAEA to import radioactive material onto the site, and any authorisations granted by SEPA should be solely for the purpose of decommissioning, and only after a genuinely open public consultation.
Greenpeace
Mike Townsley
mike@townsley.demonco.uk |