1.  Friends of the Earth Scotland welcomes this opportunity to provide written evidence to the Trade and Industry Committee inquiry into matters arising from the recent Government decision to accept nuclear material from Georgia.

SUMMARY

  2.  FoE Scotland believes that in the interests of security the material should not have remained in Georgia. However, the choice of Dounreay and the decision to reprocess the irradiated material does not serve the Government's stated aim of removing the threat of proliferation and will cause unnecessary cost and environmental pollution.

CHOICE OF SITE

  3.  In the interests of security it is the of view of FoE Scotland that the material should not have remained in Georgia. However, Dounreay's past and present problems should have ruled out Dounreay from the outset.

  4.  FoE Scotland has no confidence in the ability of the operator to undertake activities safely: the history of accidents, leaks and cover-ups indicates that no confidence can be placed in the UKAEA to conduct future activities at the site in a safe manner. A case in point is the continuing discovery of highly radioactive particles on the Dounreay foreshore. A seabed survey, completed in September 1997 turned up 34 such particles alone. As a result, the Scottish Office has placed a two kilometre fishing ban around the facility. The source of the particles has not been identified. As it has been accepted that this contamination could conceivably be". . . related to the authorised disposal of liquid and waste . . . " from the site (SEPA, Decision by SEPA on the application from UKAEA to dispose of radioactive waste from Dounreay, Second Consultation, November 1997 Volume 1), it follows that more particles may arise from any authorised discharge of liquid waste. This is wholly unacceptable, and this alone should warrant the suspension of all unnecessary discharges, until the source of the particles can be positively identified.

  5.  Public opposition to the reprocessing of overseas material is strong. An opinion poll commissioned by FoE Scotland showed 84 per cent of Scots opposed reprocessing of foreign spent fuel (Market Research Scotland, December 1995). A referendum carried out in December 1995 by the Electoral Reform Society of all 14,000 people on the Electoral Register in Caithness showed 65.5 per cent opposition to reprocessing foreign spent fuel.

DECISION PROCESS AND ANNOUNCEMENT

  6.  The NII have made it quite clear that "before irradiated nuclear fuel is brought onto the site there should be demonstrable means for its reprocessing or disposal" (NII Site Inspections Quarterly Report for UKAEA—Dounreay 1 January to 31 March 1998). This is quite clearly not the case with Dounreay. Prior to the arrival of the shipment from Georgia no reprocessing work had been carried out at the site for some 18 months. In fact, as a result of leaks and other operational and safety difficulties all three of Dounreay's reprocessing facilities are currently inoperable. Further the Fuel Cycle Area (crucial for both reprocessing and processing) was unable to handle irradiated materials such as spent fuel. No discharge authorisation has been granted.

  7.  It was clear from SEPA Board meetings that the regulator had been given little choice. Further, that members of SEPA's North Board even went as far as to put forward an amendment to a motion stating that: "The SEPA North Board does not support the Agency's acceptance of the Government's decision to agree the transfer of fissile material from Georgia to Dounreay, but that in interests of nuclear non proliferation the material is moved to and held in a secure location". (Report from the North Regional Board 24 April 1998 to SEPA Agency Board 12 April 1998).

 INTERNATIONAL CONTEXT

  8.  FoE Scotland believes HM Government has a role to play in reducing nuclear weapons proliferation.

  9.  FoE Scotland believes that agreements such as the Non-Proliferation Treaty and the functions, aimed at reducing proliferation, of bodies such as the International Atomic Energy Agency should be strengthened both financially and legally.

POSSIBILITY OF SIMILAR DECISIONS IN FUTURE

  10.  FoE Scotland notes the existence of the Sukhumi research facility in the Abkhazian region of Georgia. The last inventory in Sukhumi was in 1992, at which time it "housed 2kg of highly enriched uranium". (Financial Times 23 April 1998).

  11.  At Sepa Main Board (12 May 1998) members questioned the Chair as to whether SEPA had received written confirmation from HM Government that this situation had indeed been a "one off" and that it in no way set a precedent. This further reinforces the belief that SEPA are being undermined by HM Government.

LEGAL AND FINANCIAL FRAMEWORK OF THE ARRANGEMENT

  12.  FoE Scotland is concerned that the decision to bring material to Dounreay and Government's insistence that part of it be reprocessed has undermined the role and independence of statutory regulators such as the Scottish Environment Protection Agency and HM Nuclear Installations Inspectorate. Both have serious, well-founded concerns about Dounreay's ability to reprocess irradiated spent fuel.

  13.  FoE Scotland understands that the US will pay an estimated $2 million (£1.25 million) cost of transport (Independent 22 April 1998). However, there are likely to be significant UK public expenditure implications if the option to reprocess is actively pursued given that none of the reprocessing facilities are operable. As a result of recent incidents on site this cost has substantially increased.

EVENTUAL USE TO BE MADE OF THE MATERIAL

14.   Unirradiated HEU

  FoE Scotland notes that 4.3kg of the Georgian shipment consisted of unirradiated Highly Enriched Uranium (HEU) which is to be processed in Dounreay's Uranium Recovery Facility, D1203. FoE Scotland accepts that the production of medical targets is one method of dealing with HEU. FoE Scotland believes that the aim of non-proliferation would be better served if the material was neither reprocessed or processed into targets. Without prejudice to the statements above FoE Scotland believes that if UKAEA are to be permitted to process the unirradiated material that it should be down-blended to LEU. Targets (for use inside research reactors) can be made from LEU and the majority of research reactors across the globe have been converted in order to do this.

15.   Irradiated spent fuel

  FoE Scotland is greatly concerned that the remaining 0.8kg of irradiated spent fuel which arrived with the same consignment is to be reprocessed. FoE Scotland reaffirms its belief that reprocessing is not a sustainable activity. Reprocessing results in 85-fold increase in the volume of solid radioactive wastes ultimately requiring disposal. This significant increase in volume has even been noted by the Secretary of State for Scotland, Donald Dewar: "the end product from reprocessing the 800 grammes would be highly enriched uranium . . . and two cemented drums of intermediate level waste (ILW)," (Herald, 24 April 1998). Reprocessing increases the problem of disposal particularly as there currently exists no proven ultimate disposal method for ILW.

  16.  On top of releases of radioactivity into the environment (via liquid and gaseous discharges) reprocessing also results in more complex waste streams and all the work required therefore to deal with such.

17.   Proliferation risks

  Reprocessing extracts weapons usable material. The very production of this material and refusal to down-blend means reprocessing is a proliferation risk. This risk has been noted by the US Government and was a major reason why it chose not to send spent fuel rods to Dounreay in 1995. So concerned are the US that reprocessing is a proliferation risk that it has been prepared to pay countries not to ship materials to Dounreay.

  18.  The pro-reprocessing Dounreay Action Group believe materials brought to Dounreay, for non-proliferation reasons, should be "down-graded" (ie down-blended) (Caithness Courier, 20th May 1998).

  19.  In terms of the need for the recovery of HEU it should be noted that there is no national or international shortage of this material. An estimated 1,800 tonnes of HEU are currently stockpiled around the world, which includes eight tonnes in Britain. (The World Inventory of Plutonium and HEU, Scotsman 24th April 1998).

20.   Economic justification

  On 23 February 1996, SEPA completed a second consultation exercise into an application by UKAEA to reprocess spent fuel at Dounreay. SEPA are expected to make a decision in October/November. Apart from the environmental and safety issues, one of the most crucial aspects on which SEPA will base its decision is economic justification. SEPA recognises that "there should be clear economic justification for reprocessing overseas material" (Minutes of SEPA North Regional Board Meeting 24 January 1997). This need for economic justification was re-iterated as recently as 12 May 1998.

  21.  FoE Scotland notes that, prior to the arrival of the shipment from Georgia no reprocessing work had been carried out at the site for some 18 months. In fact, as a result of leaks and other operational and safety difficulties all three of Dounreay's reprocessing facilities are currently inoperable. Further the Fuel Cycle Area (crucial for both reprocessing and processing) was unable to handle irradiated materials such as spent fuel.

22.   The case for dry storage

  Ministers would appear to have been advised that reprocessing the spent fuel currently at Dounreay is "a necessary part of the decommissioning process" (Scottish Office Press Release 1168/98, 5 June 1998). This is not the case. UKAEA have in fact costed dry-storage of the Prototype Fast Reactor at between £188 million to £241 million while reprocessing was costed at up to £206 million. (UKAEA, Social and Economic Effects of Dounreay's Projected Programme of Work 1995-2005, 15 September 1995). Furthermore, "a dry storage option is considered technically feasible but is estimated to have somewhat higher costs than reprocessing" (UKAEA, PFR Fuel Management Options—Issue 1—FWTF(95)P43 September 1995). However, neither report include estimates of the costs which will be incurred in order to prove a safety case for the Fuel Cycle Area (now shut) or any of the three reprocessing plants (all of which are inoperable). These additional costs are likely to add a further £200 million to the bill for reprocessing (Herald 6 June 1998). There are currently 13.5 tonnes of fast reactor spent fuel and 0.6 tonnes of research reactor spent fuel stored at Dounreay. FoE Scotland believes there no reason why research reactor fuel (including that from Georgia) cannot be dry-stored along with the PFR spent fuel.

  23.  The Government indicates that "further investment" will be required to reprocess the Georgian spent fuel (Scottish Office Press Release 1168/98, 5 June 1998). FoE Scotland believes that this additional expenditure cannot be economically or environmentally justified. Further, that the Government's intentions will place undue pressure on the NII to prove a safety case for the FCA and reprocessing facilities and SEPA to approve UKAEA's application for revised discharge authorisation.

  24.  FoE notes that Dounreay are attempting to use the Georgian material to persuade the NII to lift its ban on reprocessing. Managers at Dounreay said the shipment was "vital, timely support" for their case. "To fulfil the Government's aim of reprocessing it, we need to get a licence from the NII" said one official. "If we can do the Georgian stuff, you can do the other overseas contracts as well". (Observer 26 April 1998).

  25.  FoE Scotland believes that such material should be stored above ground where the condition of the material can be monitored and the prospect of its isolation from the environment improved. FoE Scotland holds that the increased volumes of radioactive waste that will result from reprocessing are a detriment to society, adding to the waste burden and increasing costs to the taxpayer.

PHYSICAL SECURITY AT DOUNREAY

  26.  Reprocessing spent fuel produces fissile material (HEU and Plutonium) that could be used to fabricate nuclear weapons. Accumulations of such weapons-grade material represent a proliferation and therefore a security risk. FoE Scotland believes that even in the UK the security of weapons-grade material cannot be guaranteed even under the terms of EURATOM.

RECENT DEVELOPMENTS WHICH UNDERMINE HM GOVERNMENT'S DECISION

  27.  It should be noted that since the arrival of the material from Georgia a number of developments have taken place further undermining HM Government's decision:

  28.  Resignation of UKAEAC Chief Constable, Tony Pointer over a disagreement over security.

  29.  SEPA has issued UKAEA with an enforcement notice following inconsistencies dating back to 1996 in monitoring and reporting emissions of radioactive iodine, strontium and plutonium from the main stack of the FCA.

  30.  Contractors working on site in May dug through the power supply to the Fuel Cycle Area (FCA) causing ventilation, cooling and backup systems to fail and leaving the entire FCA without power. Dounreay was recently criticised by the NII following deficiencies during a training exercise based on a criticality scenario in the FCA. (NII Site Inspections Quarterly Report for UKAEA—Dounreay 1 January-31 March 1998) The NII have now issued a directive banning the use of the FCA. The Procurator Fiscal is now investigating the possibility of criminal proceedings.

  31.  Publication of Material Unaccounted For (MUF) inventory indicating that 170 kg of HEU was unaccounted for.

  32.  Government announcement ending commercial reprocessing on site.

  33.  Announcement that an additional 9 kg of LEU was also delivered to Dounreay from Georgia without the knowledge of ministers. LEU does not pose a proliferation risk.

CONCLUSIONS

  34.  Any inquiry into the fate of the Georgian material cannot be taken in isolation from all the other activities at Dounreay.

  35.  A full independent study of the entire site and operations over the years should be instigated.

  36.  Now that the material is in the UK it must be securely stored and not reprocessed.

  37.  The deal, far from confronting issues of non-proliferation, has gone against existing polices and regulations, and is not the best option on proliferation grounds.

11 June 1998