Memorandum submitted by Friends of the
In a nuclear reactor heavy metals are split
open to produce fiercely radioactive "fission products".
In addition, plutonium, the raw material for many nuclear weapons
is also created. In the early days of the nuclear industry there
was some feeling that revenue could be made from these materialsbut
now it is widely recognised that they are a liability. Vast sums
of money need to be spent to stop them coming into contact with
people and initiating cancer. These materials are nuclear wastes.
In the past, it was believed that the waste
materials could simply be disposed of by burying them deep underground.
However, when the science of this proposal was put to the test,
at the Nirex Inquiry, in 1995, it failed. Waste policy is now
in disarray and the only logical response is to limit waste production
by phasing out nuclear power and to refocus the nuclear industry
to manage existing waste.
Far from arguing for this phase-out, DEFRA,
in its consultation paper "Managing Radioactive Waste Safely"
merely invokes discussion around the status quo. Whilst the calls
for dialogue are to be welcomedthey do not signal serious
refocusing of the nuclear industry. Neither have they been time-tabled
to recognise the urgency with which the nuclear industry must
In addition to the need to stop increasing the
amount of radioactive waste by continuing to run nuclear reactors,
the hazard posed by existing nuclear waste must be minimised.
Obtusely, BNFL in Cumbria do the opposite. BNFL, in its plutonium
separation plants dissolve nuclear waste in hot nitric acid creating
a mobile liquid solution of fission products that could cause
an accident forty times worse than Chernobyl.
The DEFRA consultation document consideration of hazard simply
omits any reference to the liquid fission product hazard. This
is grossly irresponsible.
BNFL separates plutonium from fission products
making it much more vulnerable to theft. This plutonium stockpile
represents the most serious threat. It is to be welcomed that
the consultation document has finally put the management of separated
plutonium onto the Government's agenda. However, the failure to
register the question of continued plutonium separation as one
relevant for debate further demonstrates the narrowness of the
The organisational structure of the present-day
waste management system derives from the 1976 "Flowers"
committee report from the Royal Commission on Environmental Pollution
The commission concluded:
"We should not rely for energy supply on
a process that produces such a hazardous substance as plutonium
unless there is no reasonable alternative."
"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 wastes for the indefinite
Over twenty years later in March 1997 the Secretary
of State for the Environment rejected the nuclear industry's application
for a Rock Characterisation Facility, a precursor to a deep waste
repository for radioactive wastes. Quite apart from the particularly
poor characteristics of the Sellafield site favoured by the industry,
the proposal was also rejected on the basis of the poor science.
The decision letter said the Secretary of State "remains
concerned about the scientific uncertainties and technical deficiencies
in the proposals presented by Nirex (the nuclear industry waste
management body), which would also justify refusal of this appeal".
This means that the RCEP requirement that the problems of plutonium
and high level waste should be sorted out before new-build is
considered has not been met.
Further new build is currently the subject of
a parallel Energy Review by the Cabinet Office's Performance and
Innovation Unit. The fact that the DEFRA consultation doesn't
mention the implications of the RCF decision on new build demonstrates
a fundamental weakness in the document in that it fails to address
the cause of the problem.
Given the fundamental problems associated with
long-term waste management and thus the inevitable burden that
we place on future generations by producing radioactive wastes,
the Government must make a commitment to build no new nuclear
power stations and to phase out existing stations as soon as possible.
The infrastructure of the Sellafield plutonium
separation site, now owned by BNFL, was set up following the Second
World War to provide plutonium for nuclear weapons. The technology
was then applied to the plutonium from nuclear power stations,
and THORP reprocessing plants. It was argued that plutonium could
be used in specially designed reactors ("fast breeder reactors"),
but despite forty years and £4 billion of research,
these reactors have proven a spectacular failure and their development
has been abandoned save in the former Soviet bloc.
Despite this BNFL has continued to separate
out plutonium. In 1990 Britain's plutonium stockpile was estimated
at just under 30 tonnes.
It has doubled to 60 tonnes in just 10 years
and is set to reach 100 tonnes by 2010.
British Energy in its evidence to DEFRA state:
"If Government policy deemed plutonium as
a waste requiring treatment on an early timescale, it would undermine
still further the rationale for reprocessing ie that it results
in the production of potentially re-useable nuclear fuel. In such
a situation it would be nonsensical for BE to continue with reprocessing
and the creation of a further liability."
Although this reference in included, in the
consultation its implications are not drawn out. As well as producing
separated plutonium, reprocessing is responsible for 70 per cent
of the intermediate level waste that is generated in the UK.
It has central implications for the UK waste management burden
and its omission from the list of issues on which the Government
seeks opinions is extraordinary.
Given the inherent dangers associated with separated
plutonium and the liquid high level waste generated as a bi-product
of the production process, plutonium separation should be out
as a matter of urgency.
The UK stockpile of plutonium is over sixty
It takes less than ten kilograms of his material to make a nuclear
In April 2001. Fred Barker and Mike Sadnicki both members of the
Radioactive Waste Management Advisory Committee (RWMAC) published
a 230 page report funded by the American "MacArthur Foundation.
This report, which considers in detail the management strategy
for separated plutonium, is not referred to in the consultation
document. Barker and Sadnicki evaluate the options for producing
a plutonium waste form through incorporating the plutonium with
high level wastes compared to using it in a nuclear reactor (also
to produce a waste form). They concluded that, even allowing for
the revenue that would be generated from electricity production,
the reactor route is more expensive than the waste incorporation
Straight treatment of plutonium with liquid
high level waste would be an obstacle to the urgent need to treat
the liquid high level waste stocks.
Therefore Barker and Sadnicki instead recommend the use of the
Sellafield MOX Plant to produce a plutonium waste formeither
low spec MOX
(mixed oxide) or specially designed ceramicwhich is treated
to increase its proliferation resistance. The four treatment routes
considered are all based on the use of the "Transtor"
container. This container is bulky and so in itself limits the
proliferation threat, but only to a limited degree. Further resistance
is achieved by adding spent AGR fuel which contains fission products
(high level waste) and/or by using the ceramic route rather than
the low spec MOX route. The advantage of the ceramic is that it
would be specially designed to make plutonium separation difficult.
These options are not referred to by the DEFRA
report which suggests either a deep level of ignorance or a politically-motivated
omission. Either way the public is not being well served over
this matter of such great importance.
Current evidence indicates that it is out of
the question that plutonium would become a valuable resource.
In this sense its designation as waste is only a matter of time.
However, given the proliferation threat presented by the stockpile,
it is imperative that DEFRA relinquishes its disingenuous approach
and instigates the action necessary to treat the plutonium as
a material that has no use and must be managed in order to minimise
the threat that it presents.
MOX fuel is an expensive and dangerous fig leaf
for the incredibly hazardous process of plutonium separation (reprocessing).
It introduces profound nuclear proliferation risks and thus Friends
of the Earth is fundamentally opposed to the operation of MOX
The Sellafield MOX Plant should not be commissioned
for MOX production, but instead should be converted for plutonium
treatment to reducerather than increasethe proliferation
risk it presents.
The import of radioactive wastes is referred
to on page 36 of the consultation document where it is stated:
"It is a Government requirement that the
products and wastes produced from this work (the import and chemical
treatment of spent nuclear fuel) are returned to the country of
origin. This work does not therefore have any direct impact on
the management of UK radioactive wastes."
This is untrue.
(i) Low level radioactive waste arising from
the chemical treatment (plutonium separation) of spent nuclear
fuel at Sellafield in Cumbria is sent to the nearby Drigg facility
(ii) The plutonium from the THORP plutonium
separation plant is due to be sent to the Sellafield MOX Plant.
Operation of this facility would increase plutonium contaminated
waste arisings for the Sellafield site by roughly one third.
None of this overseas derived plutonium waste would be returned
to the customers.
(iii) The consultation document itself refers
to the possibility that intermediate level waste derived from
plutonium separation work would be retained in the UK.
It is deeply troubling inaccurate information
has been presented on such an important matter. Friends of the
Earth's call for an end to plutonium separation includes within
it a call for an end to the import of used nuclear fuel for this
The future of the nuclear industry is in the
multi-billion international cleanup market.
In 1976 a commitment was made by BNFL that the
nuclear wastes it imported would be returned. At paragraph 3.8
of the DEFRA document
the possibility of modifying this commitment through calculation
of amounts of wastes that are radiologically equal is mooted.
In 1996 Friends of the Earth prepared evidence
for the Radioactive Waste Management Advisory Committee on the
international shipment of radioactive waste in the context of
UK national policy. This evidence is available to the committee
on request. Through analysis of the scientific documentation concerning
groundwater return times, plutonium solubility and chlorine chemistry,
it was concluded that:
"It is presently not possible to calculate
radiological equivalence. To date the calculations put forward
by BNFL are not robust and would serve to underestimate intermediate
level waste doses. As a result, far from being broadly neutral
such an approach would be detrimental to the UK."
This conclusion was reached even before the
conclusions of the Nirex Inquiry Inspector were available.
call for views on the link between waste substitution and the
availability of a long-term management strategy. Whilst this is
to be welcomed, DEFRA do not appear to be aware of the more fundamental
failings of the integrated toxic potential approach that is proposed.
The UK should not become the world's nuclear
dustbin as it would under a substitution approach. Countries should
take responsibility for their own nuclear wastes. Given that the
UK is unable to implement a long-term approach for its own wastes
it is of even greater importance that the Government adopts a
genuine return of waste policy and refuses the suggestion of substitution.
The consultation document starts with what is
either a political intent to mislead or evidence of extraordinary
complacency. The executive summary starts with the statement:
"More than 10,000 tonnes of radioactive
waste are safely stored in the UK"
This is not the case.
In 1996 the Nuclear Installations Inspectorate
(NII) published an audit of the management of solid wastes at
The two volume report produced was a catalogue of neglect and
incompetence which demonstrated that these wastes are in fact
held in extremely hazardous forms.
There is a programme in hand to recover the wastes and stabilise
thembut after five years it is not complete. This is despite
the recommendation from NII that BNFL "increase the rate
of progress of retrieval".
A similar set of problems was subsequently reported for sludges
and liquid wastes at Sellafield.
More recently in October 2001 the New Scientist
drew attention to the hazards associated with the liquid high
level waste tanks also at Sellafield. There are 21 concrete and
steel tanks containing more that 1,500 cubic metres of high level
If a plane were to crash into these it would release enough radioactivity
to cause two million deaths.
The problems associated with the Sellafield tanks have also been
mentioned in work carried out for the European Parliament.
The outlook for on-site employment at Sellafield
is one of steady long-term decline. Not even scenarios which assume
additional reprocessing activities reverse this trend.
Research carried out for Friends of the Earth has shown that for
German plutonium separation contracts alone £400 million
could be freed up by shifting from reprocessing to storage.
Similar sums are available for Japanese contracts. This money
should be used by BNFL to invest in developing their already considerable
safe waste management, on-site storage decommissioning and clean-up
capacity. That is where the market demand isnot in reprocessing.
Overall there is a $300 billion international clean-up market
in which Friends of the Earth believes BNFL could play a cutting
edge role. Already NII is driving forward some leading work in
the development of passive safety. DEFRA do not give an indication
of the important economic initiatives that could be taken to achieve
a real contribution to safety. It is essential that this is donerather
that attempting to perpetuate the myth that nuclear wastes are
presently safely stored.
On 17 March 1997 the Secretary of State rejected
Nirex's application for a Rock Characterisation Facility (RCF)
a precursor to a Deep Waste Repository (DWR). Quite apart from
the site issues related to the particularly poor characteristics
of the Sellafield site chosen by Nirex as their favoured site,
the Nirex proposal was also rejected on the basis of the poor
science of the Nirex case. The decision letter stated:
"Further the Secretary of State also remains
concerned about the scientific uncertainties and technical deficiencies
in the proposals presented by Nirex, which would also justify
refusal of this appeal."
In terms of developing a way forward, the most
important point to recognise is that the rejection was not simply
the rejection of a poor site, but instead reflected deeply seated
generic problems with the proposal that will affect waste management
options at any site. It is now appropriate to recognise that the
long held commitment to early deep disposal has irrevocably broken
down and that proposals for interim surface based approaches must
be put in hand. The lesson of the Nirex decision is that the whole
concept of deep-level irretrievable disposal of nuclear waste
is flawed. Waste should be held in storage as we do not have sufficient
knowledge to limit the quantity of radionuclides that could return
to contaminate local populations, if deep-level disposal is undertaken.
The events of September 11 highlight the fact that surface based
approaches also have their problems. This demonstrates at a fundamental
level the fact that further production of nuclear materials should
cease as soon as possible.
The generic problems associated with disposal
relate to the lack of sufficient scientific understanding of the
quantity of radionuclides that would be released from a repository.
The Inspector at the RCF Inquiry noted that such deficiencies:
"relate(s) to the practicability of the UK deep disposal
In particular the Inspector drew attention to:
"the profound novelty and complexity of
the deep disposal, multi-barrier concept.
These uncertainties cover scientific problems
in all areas. The Assessor noted:
"There is a general need for the Nirex science
programme to be advanced on all fronts"
"new data are required in almost all areas
of work pursued to date"
In reference to the March 1997 decision, DEFRA
"This decision called into question whether
at that time an underground repository for the disposal of radioactive
wastes could be scientifically justified or publically acceptable.
This led to a completely new look at radioactive waste management
policy in the UK."
This frankness is welcomed as is the intention
by Government to open up a wide ranging debate on this important
The events of September 11 have spotlighted
the vulnerability of nuclear facilities to similar attacks. Particularly
vulnerable are plutonium stores, liquid high level waste stores
and nuclear reactors. In addition untreated (raw) intermediate
level wastes present particular concerns. All of these waste forms
must be treated to reduce the risk that they present from either
deliberate or accidental impact from aeroplanes. At the British
Nuclear Energy Society conference on 7 November 2001, Friends
of the Earth announced that they were undertaking an internal
review of our position on above-ground storage given the threat
of deliberate attack.
As part of this review we will be seeking urgent
evidence from the nuclear industry that it is taking the necessary
stepsie waste conditioning and nuclear phase-out to minimize
the threat presented by above ground facilities. In addition as
part of the DEFRA waste review the industry must input data on
the relative risks presented by above ground storage and underground
disposal. Underground disposal carries the risk of that the inevitable
release of radioactivityeventually back to the human environmentwill
be far higher than foreseen. The advantage of storage is that
it allows for repair if such a problem were to arise, but it carries
with it the risk of collision and dispersion through that route.
Nirex are researching so-called "phased-disposal"
which has the advantage that it incorporates a period of storage
and thus remediation options whilst avoiding the collision risk
because the waste is held underground. However the storage period
is only planned to be for two hundred or so years and so it does
not seriously address the problems associated with disposal. All
of these issues must be addressed as part of the Government's
Friends of the Earth welcome the initiatives
that have been taken by Nirex to incorporate public input
through transparency and dialogue following the 1997 RCF decision
and the 2000 Nirex Internal Inquiry.
These include stakeholder meetings on retrievability, focus group
meetings on partitioning and transmutation and the funding of
Lancaster University on many projects concerning the involvement
of the general public.
Given the severe shock dealt to Nirex by the Nirex Inquiry decision
the Company has taken far reaching measures to learn from the
past and put in hand changes that are designed to make it more
responsive to ethical and societal needs. How far it can go along
this route whilst constrained by its current ownership remains
to be seen.
In contrast Friends of the Earth experience
of the BNFL stakeholder dialogue process, is that BNFL has shown
little regard for the input of its participants. This is signalled
by its determination to use UK plutonium in MOX fuel
and its proposal to build up to twenty new nuclear power stations
There was no real interest from BNFL in other solutions to problems.
This created a bad feeling which contaminated the whole process
and gave the feeling that it was just a cynical PR exercise on
the part of BNFL.
Friends of the Earth is disappointed that DEFRA
has not taken the initiative to instigate a wider public debate
about radioactive waste management and a broader response to the
current consultation. The decision to publish the document on
12 September, just one day after attack on the World Trade Centre,
suggests that DEFRA are willing to see a tightly circumscribed
debate with a low level of public involvement. Furthermore the
reference in the consultation document and the Press Release
to a wish list of techniques to achieve public involvement carries
very little weight if these techniques are not actually used.
It is already two months into the consultation, the Christmas
break is approaching and to date no plans have been announced
concerning how DEFRA intend to promote a wider debate. Informal
approaches have been made with a view to further meetings, but
it appears that DEFRA are only in the very early stages of developing
their ideas and it seems very unlikely that a wider public debate
will be started by the March 2002 deadline.
The Flowers report recommended that an independent
body be set up to dispose of nuclear waste. However, in 1982 when
the "Nuclear Industry Radioactive Waste Executive" (Nirex)
was set up the advice of the RCEP was ignored and Nirex's shareholders
are all drawn either from the nuclear industry or its Government
sponsoring body. This failing has caused a fundamental lack of
appreciation of the purpose of a long-term waste management body.
Nirex should not be there to gloss over the difficulties associated
with radioactive waste management. It should develop an ethical
and scientifically rigorous approach to the enormous challenge
presented by long-lived nuclear wastes. Given the intrinsic conflicts
of interest that arise from industry ownership of Nirex it is
imperative that the organisation is made independent. However,
under the polluter pays principle the industry should continue
to fund long-term waste management.
In an amendment to the DEFRA timetable, Nirex
should be made independent at the earliest possible opportunity
in order to give a focus for the DEFRA "Programme for Action".
This should be more than just a funding arrangement but should
also include the incorporation of further Board members and staff
from an environmental background to take a more rigorous approach
to the issues associated with the radionuclide inventory. Currently
Nirex are neutral on the issue of new build. This makes no sense
as the irradiation of more fuel would necessarily add to the amount
of waste that has to be managed and therefore the radionuclide
source term which is utilised in the repository performance assessment.
Appropriately strengthened, and independent Nirex would take a
more logical position on new build and interrogate in far more
depth the alternative options for waste management.
Decommissioning policy in the UK displays the
same complacency that characterises the whole of nuclear waste
management policy. On 4 October 2001 the owners of Tokai-Mura,
a Japanese Magnox reactor, announced their plan to decommission
the reactor within seventeen years.
DEFRA do not report this important development in their document
and appear to be unaware of it even though it has important implications
for the UK.
Given the dangers associated with untreated
waste, it is imperative that raw wastes are conditioned to a passively
safe form as soon as possible. This means that the UK should adopt
the Japanese approach of early decommissioning as part of waste
On 12 September the Environment Minister Michael
Meacher said that the legacy of a wrong decision concerning radioactive
waste could be "catastrophic".
Wrong decisions have already been made and severe vulnerabilities
will remain unless and until Government take firm action to eradicate
the complacency of the past and instigate policies appropriate
to the dangers that nuclear wastes present. This means a phase-out
of reprocessing and existing reactors and the rejection of plans
to build new reactors.
Whilst further research is carried out into
the optimum longer term approach radioactive waste should urgently
be treated to minimise the hazard that it presents and then placed
in interim stores. There is an enormous international market in
this field and the nuclear industry should refocus from electricity
generation to radioactive waste management in order to achieve
reliable future employment.
Whilst the DEFRA document does contain important
initiatives, namely the commitment to dialogue and the recognition
of plutonium as a problem that requires serious attention, it
repeatedly demonstrates a lack of understanding and knowledge
of the problem at hand. This is a matter of deep concern as the
Government will be unable to facilitate the essential consensus
building without itself developing a real appreciation of the
Friends of the Earth
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Plants at Sellafield (UK) and Cap de la Hague (France)" STOA,
August 2001, p 38. Back
"Nuclear Power and the Environment" Royal Commission
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RCEP (1976) p 202. Back
Styche PC, (Authorised by the Secretary of State for the Environment
to sign in that behalf) Government Office for the North West,
17 March 1997, para 9. Back
B204 was also used for a short period for oxide fuel. Back
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DEFRA (2001) p 36. Back
There is no LLW store for overseas LLW due to be returned. DEFRA
is dishonest on this point. (see DEFRA (2001) para 3.8 p 25). Back
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and Sludges at BNFL Sellafield" NII (NW/11/97-250-C-AZLJ). Back
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Murray C et al "Reports on the Nirex Internal Inquiry January-December
2000" Nirex (2001). Back
Dr Rachel Western, Friends of the Earth Nuclear Researcher, is
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consultant to Nirex on projects associated with access to scientific
DEFRA (2001) p 33. Back
P. Brown "UK needs another 20 nuclear stations" The
Guardian, 7 September 2001. Back
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E-mail from Jamie Woolley to email@example.com 22 October
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