Select Committee on Science and Technology Minutes of Evidence


Memorandum by British Nuclear Fuels Ltd

EXECUTIVE SUMMARY

  BNFL is a global "high-tech" company, and with its leading position in the UK's nuclear industry, inevitably finds itself affected by a significant number of International Agreements. We welcome the Committee's inquiry and believe it raises a number of important issues that could fundamentally affect the UK's prosperity and social values. BNFL's key points are summarised here with more detail later in this document. We also provide responses to the questions by the Committee towards the end of this submission.

  The Inquiry has the following terms of reference:

    "How satisfactory are the existing arrangements for incorporating scientific advice and other scientific input into the negotiation, application and implementation of international agreements; and how could these arrangements be improved?"

  BNFL wishes to make the following points in response:

In setting International Agreements, all factors need to be taken into consideration—Scientific, Political and Ethical.

  It is essential that International Agreements that seek to promote far-reaching or complex collaborations are based on a broad range of considerations. Factors such as the financial cost of implementation, social and ethical issues, and the scientific and technical analyses should all be integrated to achieve the optimum overall benefit. Striving to achieve a target, which may be technically feasible in isolation of other considerations, could result in little or no benefit at disproportionate cost.

It should be transparent and understandable how scientific, political and ethical considerations influenced the final outcome.

  Having argued for balanced and integrated decision-making, it is nevertheless important that all the considerations are initially assessed in isolation. We must avoid the situation where a decision made for political or other reasons is subsequently presented as having a predominantly scientific rationale. This can lead to a "bogus" scientific concept becoming established in the public consciousness. The scientific evidence should ideally be compiled in the early stages and independently published or refereed. The aim should be for "open decision" making with a clear & transparent trail of how each consideration was weighted in the final outcome.

Steps should be taken to ensure all the scientific input is from an objective source.

  The scientific evidence needs to acknowledge where residual uncertainty remains, but also to ensure that the significance or context of the uncertainty is considered. Adopting measures in response to an uncertainty can result in substantial expenditure to avoid a potential risk that only has minor consequences. It is virtually impossible to prove a negative correlation (X will never harm Y), and the cost-benefit of alternative measures should always be a consideration.

  We should acknowledge the legitimacy of special interest groups whose aims can be aspirational or based on belief systems, but being careful to avoid crediting these aims with scientific authenticity where this is not the case. Such groups should be encouraged to present their views on what should be done, as well as what should not, so that the implications of their proposals can be fully considered.

  We should create the circumstances where the scientific evidence can be considered in a rational and dispassionate manner. There is always a temptation to over-readily accept "good" conclusions, and only challenge the "unwelcome". We recommend that greater use be made of the learned bodies in the UK to determine the thoroughness and validity of scientific evidence that underpins a new proposal.

It's vital that those setting International Agreements ensure the UK gets value for money.

  Complying with the terms and conditions of International Agreements inevitably draws down on the wealth and resources of the UK. These are finite and in striving to maximise the benefit for the UK, we should try and set a "level playing field" in terms of cost and outcome. We need to negotiate our commitment on a consistent basis and utilise the scientific evidence on benefit across a wide spectrum of issues and options, eg energy, transport, health.

  When the UK is contributing to or negotiating International Agreements it should ensure that the impact on UK of any legislation will be implementable.

BNFL'S VIEWS ON THE BROADER CONSIDERATIONS

  International Agreements are inevitably complex and often based on a wide range of conflicting considerations. The outcome may appear as a simple target, but the process by which they are defined is usually protracted, and a compromise between both vested interests, and competing benefits.

  It is essential that such Agreements are based on the widest range of considerations, and these are fully integrated to achieve the optimum overall benefit for the UK. It is right and necessary that politics, social factors, environmental issues, ethics, finance and scientific evidence all contribute to the final decision. However it is also vital that each consideration is evaluated separately and independently, so that the weighting or relative importance of these considerations is revealed. The aim should be for "open decision making", with a clear transparent trail of how each element of the decision making process contributed to the final outcome. In this way there is clear accountability, the public can understand which factors influenced the decision , and where appropriate, make challenges through established processes.

  In our view it is of fundamental importance that the scientific or technical evidence is compiled and analysed at the outset. We suspect that there are occasions, or at least it appears so, when scientific evidence is "bolted-on" to a decision already made for political or other reasons. There is a danger that the public incorrectly interpret an Agreement as having a predominantly scientific foundation, and hence a "bogus" scientific concept or correlation can become established in the public consciousness.

  BNFL recommends that the scientific evidence is refereed to provide an independent evaluation of the thoroughness and validity of the data and analyses. For significant or potentially contentious issues, we recommend that a Peer Review is carried out, ideally by a learned society or chartered institute. The Royal Society or the Royal Academy of Engineering could conduct these Peer Reviews, or advise who would be appropriate to do so. We should create the circumstances where the scientific evidence can be considered in a rational and dispassionate manner. There is a danger that the reader inevitably concurs with an analysis which reinforces their expectations or which "intuitively" feels right. There is also a temptation to over-readily accept "good" conclusions, and only challenge the "unwelcome".

  The UK also needs to avoid being committed to a course of action just because we have the means to do so. New technologies are constantly becoming available and there is the temptation to agree to their deployment as a measure of our scientific progress. Striving to achieve a target that may be technically feasible in isolation of other considerations can result in little or no benefit and disproportionate cost.

  One particular aspect that deserves scrutiny, both in the initial analyses and the subsequent review, is the consideration of uncertainties. Scientific data inevitably contains uncertainty, and the treatment of this can significantly influence, and under some circumstances, distort the conclusions. The adoption of measures in response to an uncertainty can result in substantial and unnecessary expenditure, often only to avoid a potential risk of minor consequence. It is also virtually impossible to prove a negative correlation (X will never harm Y), and the cost-benefit of such measures must be given careful consideration.

  The wealth and resources of the UK are finite. In striving to maximise benefit for the UK we should try and set a "level playing field" in terms of both cost and outcome. We need to negotiate our commitment on a consistent basis and utilise the scientific evidence on risk and benefit across a wide spectrum of issues and options. This aspect is discussed in more detail below.

  The UK needs to give more detailed consideration of the implications of entering into new Agreements. When the UK is either contributing into or negotiating International Agreements we need to ensure we have fully considered the impact on the UK of any subsequent legislation.

BNFL'S SPECIFIC POINTS

  BNFL welcomes the Committee's Inquiry, our experience has been that it is often difficult to unravel the decision making process, and to understand how balance has been achieved between cost and benefit. We find ourselves implementing costly modifications to our industrial plant and operational practices as a result of International Agreements, and yet it is rare that we are consulted at the information gathering stage. In our experience, measures to reduce the level of radioactive discharges from nuclear installations involve substantial expenditure with little demonstrable benefit to the environment.

  There is a general perception that less quantifiable socio-political issues, are now taking centre stage in decision-making. They include perceptions that radioactivity is in some way uniquely dangerous and insidious, views that no level of radioactive pollutant in the environment is acceptable, and concerns that, whatever the scientific evidence, discharges may impact on other legitimate uses of the environment. These are, in most cases, genuinely and strongly held views, which deserve to be taken seriously into account in the decision-making process. However, we argue that it is important that they are considered alongside the technical and economic arguments in a transparent way so that their full implications in decision-making can be assessed.

  Contrary to public perception, radiation is a relatively weak carcinogen. One simple way of placing this in perspective is to estimate the consequence of exposing a large population to radiation. If, for example, 20,000 people were subjected to a dose of 1mSv (the dose limit for the public and roughly 10 times higher than the exposure of the Sellafield critical group), on the basis of current risk estimates, statistically about one extra cancer death would be anticipated eventually to occur in that population. This would be indistinguishable from the 4,000-5,000 other cancer deaths that would occur "naturally" over the remaining lifetime of those exposed. Even though such numbers may help put radiation risks into perspective, they may still exaggerate consequences as they are based on the linear no-threshold model, where collective doses are calculated by summing minute doses to enormous populations over long periods of time.

  One important implication is that the consideration of such social and political factors and responding to public perceptions will lead to more resources being spent to prevent a statistical fatality (or other consequence of a reducing risk) in one area rather than in another. The UK typically would need to invest as follows to avoid this statistical fatality:

    —  Health Service-of the order of several £100k.

    —  Roads-of the order of £1 million.

    —  Rail-of the order of several £1 million.

    —  Radiological reductions in the nuclear industry-of the order £10 million to £100 million.

  The baseline UK government figure for the value of a fatality prevented is about £1 million. This is used, for example, to determine investments in road improvement schemes as a contribution to reducing the several thousand fatalities on UK roads each year. Significantly lower sums would save real lives in the health sector in the UK, through the increased provision of hospital beds or better treatment of life threatening medical conditions.

  The position is not peculiar to the UK. More detailed studies in the USA and in Sweden for example, have exposed the issue even more clearly by looking at a wide range of life-saving interventions. The implied value of a statistical life from actual regulatory/societal decisions varies over several orders of magnitude.

  So long as these variations in expenditure genuinely reflect public priorities, it is quite reasonable and proper that the variations exist. The key question, however, is whether account has been taken of the non-technical arguments in a transparent way, and whether decision-makers and other stakeholders are aware of the full balance of all of these arguments. There does not always seem to be an appreciation that employing resources for risk reduction in one area means that higher risks elsewhere will not be addressed.

  There is a particular concern from some states neighbouring the UK that Sellafield discharges could lead to a loss of confidence in their fishing industries and other suggestions that even the minute doses received by their populations could lead to ill-health. A substantial pressure for further reductions in discharges also arises from the OSPAR Convention to which the UK is a contracting party. This deals generally with reducing pollution to the North Atlantic and, in respect of radioactivity, says that "by the year 2020, the OSPAR Commission will ensure that discharges, emissions and losses of radioactive substances are reduced to levels where the additional concentrations in the marine environment above historic levels, resulting from such discharges, emissions and losses, are close to zero".

  In accordance with OSPAR, the UK Government has published a National Discharge Strategy, to demonstrate how the UK intends to meet its commitments. Since the UK made its initial commitment to OSPAR, BNFL has announced programmes of early closures of Magnox reactor plant and associated reprocessing facilities. Although programmes for closure have been influenced by a variety of factors, meeting OSPAR commitments has been a significant consideration. The total cost of these early closures has been estimated to be around £750 million in direct costs, with even greater longer-term indirect costs arising from unemployment and impacts on the local economies in remote regions. Furthermore, replacement fossil generation to compensate from the loss of nuclear generation will lead to higher carbon emissions.

  Based purely on a scientific and economic evaluation of the data, it is difficult to see how these further reductions can be justified. Application of the ALARA principle requires that radiological doses and risks should be reduced to a level that represents a balance between radiological and other factors, including social and economic factors. The UK therefore finds itself spending a significant proportion of its national wealth on making minor reductions to releases that are already very small, with negligible benefit to the environment and health risk factors.

BNFL'S RESPONSES TO THE DETAILED QUESTIONS

  BNFL has responded to the issues raised in the "Call for Evidence" on the Committee's website in our detailed responses above. We have also responded to the detailed questions as follows:

(a)   How is the need for scientific advice recognised?

  BNFL is not sufficiently familiar with the process of negotiating International Agreements to provide a detailed reply. However it is essential that formal prompts exist to establish the need for scientific advice, and that the full scope is defined at the outset.

(b)   To what extent does scientific information and evidence go through a peer-review/quality control process?

  We see little evidence that a formal process exists to carry out quality checks on the scientific information, but this is vital given the impact this may have on the terms of the Agreement. From our perspective, quality checks ensure there are no errors in the data. However a more broader ranging scrutiny is required where there are areas of judgement or contention, and for this we would suggest a Peer Review is required, either carried out by organisations such as the Royal Society or the Royal Academy of Engineering, or under their supervision.

(c)   How should international agreements deal with scientific uncertainty, having regard to a precautionary approach? Is there a need for consistency between agreements on the treatment of scientific uncertainty, and if so is there sufficient consistency?

  A very important question, without an easy answer. Scientific data always contains uncertainties, but these can originate from a wide range of sources, including measurement variations, intrinsic scatter in the properties of materials, the variability of natural processes and biological responses, and from extrapolation where data is non-existent.

  From our perspective, the treatment of uncertainties can have a major effect on the outcome of an analysis, and the Committee is right to raise this as an important issue. There is a need for consistency, but this should acknowledge that the treatment will differ according to the source of the uncertainty. We recommend that an expert committee address this issue.

(d)   How are competing views on scientific issues addressed and incorporated into agreements and implementation of agreements?

  Again, BNFL is not sufficiently familiar with the process of negotiating International Agreements to provide a detailed reply. However it is inevitable that differing views will be held within the scientific community, and different conclusions will be drawn from the same data. It is important that those charged with assembling the scientific evidence do not have a vested interest, and that scientific experts do not lead this process, but are managed within a team. As mentioned previously, a well-specified Peer Review can provide an impartial summary on the relative merits of competing views.

(e)   What role does the scientific community in the United Kingdom play in contributing to the scientific input used in formulating, applying and implementing international agreements, and how might that role be enhanced?

  The UK is very fortunate in having a vibrant and well-respected scientific community, and superficially it appears they could play a fuller role in contributing to the process of assembling the scientific evidence. The essential step is to acknowledge the need for a scientific evaluation at the outset, and define a scope and process by which this should be achieved. The chartered institutes and learned societies could advise on appropriate representation.

(f)   In areas where the EU has assumed competence to negotiate international agreements, what arrangements are in place to ensure that the EU's position is based on an appropriate scientific foundation?

  We suggest that all the above points could equally apply to Agreements negotiated by the EU.





 
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