Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by British Energy


  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.


  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.


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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