APPENDIX 12
Supplementary Memorandum submitted by
the United Kingdom Atomic Energy Authority
RESPONSE TO WRITTEN QUESTIONS FROM THE COMMITTEE
Question 1
It would be helpful to have a note setting
out actions taken by UKAEA in response to points raised inDr Walker's
report.
Dr Walker's report was one of a number of useful
inputs to UKAEA plans for upgrading the fuel and waste plants
in the Dounreay Fuel Cycle Area (FCA).
UKAEA considered the findings of Dr Walker's
report together with its own study of the condition of the fuel
cycle and related plants, and a review of the plants carried out
by NNC under contract. As a result, a major improvement programme
was prepared for both the fuel cycle and waste plants and is now
being implemented. The planned upgrades have been prioritised;
the most urgent tasks have been identified for 1998-99, and appropriate
sums included in the budget. Thirty-eight projects have already
been completed, and 119 are in progress.
The table attached summarises the key concerns
contained in Dr Walker's report, and the actions taken by the
UKAEA to improve performance in these areas. The Committee is
asked to note that:
1. The detail and prioritisation of the improvement
programme will be reviewed in the light of the HSE/SEPA Audit
of Dounreay undertaken during June 1998, and expected to report
shortly.
2. NII expressed satisfaction with the progress
to date, in both the written and oral evidence to the TIC hearing
in Thurso on 15 June.
3. Safety of the Dounreay plants is subject
to continual review by UKAEA and NII, to ensure public and occupational
safety.
DR WALKER'S OBSERVATIONS
PLANT DESIGN
AND ENGINEERING
CONDITION
1. Containment
Improvements planned in all buildings identified
by Dr Walker, for example the clearance of the D1203 "amber"
area, the decommissioning of lab 33, containment of process pipework
and the DC3 roof bulge in D1206 are all underway.
Overall four projects are already complete and
20 projects are in progress.
2. Ventilation
Standards for each plant have been documented
to allow specification of appropriate systems, for example the
reviews of ventilation in D1200 are complete and the improvements
to the space extracts in D1203 and the upgrading of fans in D1206
and D1234 are underway.
Overall three projects are already complete
and 15 are in progress.
3. Shielding
Plans for removal of radiation sources, and
improvement of shielding quality, for example the cleaning of
the D1204 pond and the removal of radiation sources from various
areas in D1206 are underway.
Overall one project is complete and eight projects
are in progress.
4. Instrumentation
Instruments have been identified for improvement/replacement,
for example the Criticality Detection and Alarm System (CIDAS)
has been replaced.
Overall one project is complete and 16 are in
progress.
Long-standing temporary shielding
See (3) above.
Waste management strategy
No further ILW is planned to be disposed to
the wet silo after the end of 1998. Much waste cleared from active
handling facilities and Waste Posting Cell now operational, as
are both 6021 flasks. Detailed waste strategy under development.
Outstanding Post Operational Clean out (POCO)
A number of POCO tasks are now underway, eg
the clear-out of the legs of the caves in D1217.
Lab 33
The decommissioning process has now begun.
Operating plant in care and maintenance
The recent decision on the future of commercial
reprocessing means that some plants are no longer required and
will undergo POCO, then decommissioning.
Safety cases
The programme of safety case review and revision
has been accelerated.
Project categorisation
A new system of prioritisation has been introduced
in the UKAEA; safety-related projects have the highest priority.
Maintenance procedures
More than 6,000 maintenance instructions have
been produced and are in place, leaving only a handful still to
be completed.
Suitably Qualified and Experienced Persons (SQEPs),
Duly Authorised Persons (DAPs) and training
A new UKAEA policy on SQEPs and their training
has been introduced.
Authority to Operate (ATO) holders and Safety
Working Parties (SWPs)
The number of ATO holders has been increased.
SWPs are now incorporated within the line management structure
advising the Group Manager.
Nuclear Site Licence Conditions and the Corporate
Safety Instructions (CSIs)
Descriptions have been prepared of how Licence
Conditions are met within UKAEA's safety systems.
Interface management
Team-building initiatives have been carried
out. A number of contractors have been recruited into UKAEA (see
Question 8).
Question 3
It would be helpful, following Q28, to have
the details of the existing contracts for reprocessing irradiated
fuel, indicating the source, nature and length of the contract,
the volumes concerned, any irradiated fuel still to be delivered
to Dounreay, and arrangements for return of waste in each case.
It would also be helpful to have a note on the significance in
volume and technical terms of the carbide fuels (Q35).
The attached table[9]
lists all existing contracts for reprocessing irradiated fuel
at Dounreay showing the source of the fuel, the nature of the
contract and processing time involved, the amounts of fuel, whether
any has yet to be delivered and the arrangements for return of
waste in each case.
Carbide Fuels
Most of the fuel awaiting treatment at Dounreay
is in the form of uranium-plutonium oxide. The remainder is uranium-plutonium
carbide. 1.7 tonnes of the carbide fuel is irradiated; the rest
is unirradiated (0.7 tonnes)*. For comparison, total quantities
of irradiated and unirradiated fuel awaiting treatment at Dounreay
are 14 tonnes and 12.8 tonnes respectively.
Carbide fuels were developed for fast reactors
because they offered the prospect of higher power generation in
a smaller volume and therefore better economics than the more
normal uranium-plutonium oxide fast reactor fuel.
The Georgian material does not include any carbide
fuel.
Carbide fuel needs to be reprocesseddirect
disposal is not a realistic option because the chemical reactivity
of the carbide material could produce flammable gas in a repository.
However, they are more difficult to reprocess than oxide fuels.
To date, no-one has reprocessed either irradiated
or unirradiated carbide fuel on more than a laboratory scale.
Three options have been identified for processing the carbide
fuel:
(a) blend with larger quantities of oxide
fuel, and co-process through the normal route;
(b) convert to oxide in a furnace, and then
reprocess through the normal route used for oxide fuels;
(c) use an alternative dissolution process.
These options are currently being evaluated.
Should option (a) prove to be safe and technically acceptable,
installation of a new dissolver would make it possible in principle
to carry out this work in D1206 at Dounreay without additional
plant.
*Note. In addition, there are 4.1 tonnes
of unirradiated uranium carbide breeder material. This contains
natural/depleted uranium. The current intention is to oxidise
the material to stable uranium oxide, suitable for storage and
disposal.
Not printed.
Question 4
It would be helpful to have an indication
of the likely end-users of the fuel to be produced from the LEU
and irradiated HEU.
The unirradiated HEU from Georgia will be used
to make uranium targets for irradiation in Materials Test Reactors
to produce molybdenum 99 radioisotopes which decay ultimately
to produce technetium 99, an important diagnostic source used
in nuclear medicine. The end users are doctors worldwide treating
patients who are suspected of having cancer. Only technetium-99
produced from HEU is licensed for worldwide use as a diagnostic
in nuclear medicine, as it avoids potential side effects from
other radioactive materials.
The HEU recovered from the irradiated HEU once
reprocessed, unirradiated LEU and recovered LEU will be blended
at Dounreay to produce fuel elements for Materials Test Reactors
(ie the type of reactor used to irradiate the targets as described
above), in Western Europe or Canada.
Attached is a letter from Dr S E M Clarke, of
the Department of Nuclear Medicine at Guy's and St. Thomas' Hospital
Trust, confirming the value of technetium 99.
Thank your for your fax and our subsequent telephone
conversation. I can confirm that the processed molybdenum is vital
in the production of 99m Tc used for 90 per cent of Nuclear Medicine
diagnostic procedures in the UK. Nuclear Medicine imaging is available
in most hospitals in the UK and is used to investigate a wide
variety of disease processes including bone problems for spread
of cancer to the bones, clots in the lungs, heart disease, kidney
disease in both adults and children, and thyroid problems.
The main source of molybdenum at the present
time is from Canada and there have been two occasions over the
past six years when the supply of molybdenum to Europe including
the UK has been at risk due to industrial action in the Canadian
company. I was involved with writing letters to the Department
of Health at the time of the first incident and I know that the
second episode was discussed in the European parliament. Alternative
sources of molybdenum are therefore essential to ensure a secure
supply for clinical purposes.
Question 5
It has been suggested that D1206 would require
"reconfiguration"in addition to the investment
in a new dissolver and plant upgradeto deal with the irradiated
HEU from Georgia since it normally deals with MOX fuels. It would
be helpful to have clarification.
The UKAEA will treat the very small quantity
of irradiated HEU from Georgia (0.6 kg) either in the D1206 reprocessing
plant or by a laboratory process in D2670 (the Marshall Laboratory).
A few straightforward changes to the arrangements
for cutting up the assemblies and removing the fuel prior to dissolution
would be required if the Georgian material were processed in D1206
together with some changes to the chemical process for dissolving
the fuel.
Question 6
It would be helpful to have a note on the
future reprocessing of irradiated HEU targets, indicating where
it is to be carried out; with what product; and the nature (length,
finance, conditions etc) of the contract with the ECN reactor
at Petten.
THE TARGET
PRODUCTION CYCLE
Dounreay plants fabricate HEU into targets which
is sent to the reactor at Petten in Holland. The targets are irradiated
in the ECN reactor. After irradiation, the reactor operators separate
targets chemically into three main products:
(1) Molybdenum 99 radioisotopes which are
used to produce technetium 99 for use in medical diagnosis.
(2) Radioactive waste which is retained by
the reactor operators.
(3) The unburned uranium-235 including some
residual waste which is returned to Dounreay for re-use. Any resultant
waste from processing will be returned to the reactor operators.
UKAEA also supply purified HEU metal to AECL
Canada who fabricate their own targets.
THE CONTRACT
WITH ECN
UKAEA has a contract with ECN (Holland) for
the manufacture of up to 5,000 targets. ECN raise purchase orders
against the contract as the demand on them requires. The contract
itself is for an unspecified period but there are mutual break
clauses at 10 months notice. The price paid by ECN covers transport
costs, target manufacture, recovery of HEU and leasing the HEU,
and profit.
Of the current order for 2,394 targets, 1,890
targets containing 9.6 kg of HEU have been delivered to ECN and,
of that, 3.7 kg irradiated HEU has already been returned to Dounreay
for recovery.
The remaining production and a further order
for 2,268 targets depends on the outcome of the current NII/SEPA
safety audit at Dounreay.
Question 7
Following the exchanges in oral evidence,
it would be helpful to have a response from UKAEA on its latest
views on the balance of advantage between reprocessing and storage.
OPTIONS FOR THE TREATMENT AND DISPOSAL OF
PFR FUEL
INTRODUCTION
1. In his evidence to the Trade and Industry
Committee on 15 June, Dr John McKeown, Chief Executive of UKAEA,
outlined some primary factors which led to UKAEA proposing to
continue to reprocess Prototype Fast Reactor (PFR) fuel at Dounreay
rather than attempting to make a case for long-term storage. This
note summarises the strategic factors which support this policy.
OPTIONS CONSIDERED
2. In broad terms, three types of treatment
can be considered for PFR fuel[10]:
(a) Surface storage followed by direct disposal;
(b) Surface storage followed by reprocessing;
or
(c) Early reprocessing followed by storage, reuse
and disposal of the materials arising.
(a) Surface storage followed by direct disposal
3. Surface storage followed by direct disposal
is an option being pursued for spent fuel from thermal power reactors.
Countries such as Sweden and Finland have proposed long-term storage
for irradiated thermal reactor fuel to allow the radioactivity
of fuel to reduce prior to direct disposal in an underground repository.
In the UK, Scottish Nuclear Ltd proposed in the 1990s to build
dry-storage facilities at Torness for its irradiated fuel, with
the aim of eventual direct disposal. However, UKAEA understands
that currently the majority of spent fuel from thermal power reactors
in the UK is scheduled to be reprocessed.
4. A key factor in determining the feasibility
of direct disposal is the nature of the fuel and the amount of
fissile material it contains.
5. Most commercial reactor fuel is in the
form of metallic uranium (Magnox) or ceramic uranium oxide (AGR,
PWR), containing less than 5 per cent U235 andafter use
in the reactora small proportion of plutonium. The low
fissile material content of this fuel means that it poses a relatively
minor security risk and raises relatively little concern relating
to criticality.
6. By contrast, the Dounreay PFR used uranium/plutonium
oxide or carbide fuel. The plutonium content ranges from 20-33
per cent.
7. Approximately 50 per cent of the PFR
fuel is unirradiated and is classified as a special nuclear material
which is subject to the highest levels of security on non proliferation
grounds. The majority of the PFR fuel is irradiated and, although
requiring proper security measures, is categorised at a lower
level of security than unirradiated fuel, as it is more difficult
to use for non peaceful purposes.
8. Studies have confirmed that surface storage
of both irradiated and unirradiated PFR fuel would be technically
feasible for timescales of 50 years or more, with tight security
arrangements and storage arrangements designed and monitored to
prevent the possibility of criticality.
9. Direct disposal of irradiated or unirradiated
PFR fuel following a significant period of secure surface storage,
would require demonstration over a timescale extending to half
a million years or more that:
a critical mass would not form and
start a chain reaction as a result of the contents of fuel elements
coming together in the repository due to the long-term degradation
of barriers intended to contain the material.
there is not an unacceptable risk
that the plutonium could be recovered for non peaceful purposes.
This is more significant for unirradiated PFR than for irradiated
fuel, as the material could be more easily used for non peaceful
purposes.
a containment system could be established
and demonstrated to prevent the release of unacceptable amounts
of radioactivity into the environment whilst the spent fuel remained
radioactive.
10. Direct disposal of the unirradiated
PFR fuel at Dounreay (which amounts to 12.8 tonnes) poses particular
difficulties in that it is special nuclear material which requires
secure confinement for very long periods of time to avoid diversion
for non peaceful uses.
11. Direct disposal of irradiated PFR fuel
faces the same challenges in making a safety case and avoiding
criticality, however security considerations are less significant
as the radioactivity makes it more difficult to use for non peaceful
purposes.
12. Whilst in principle the irradiated PFR
fuel could be diluted and packaged with other materials for safe
direct disposal, this process has not yet been demonstrated. In
the event of the safety case for disposal of PFR fuel identifying
factors which preclude the material being accepted for a UK national
repository, the whole costs of a separte repository for PFR would
fall on the UKAEA and thus on the the UK taxpayer.
13. The total quantity of plutonium in PFR
fuel amounts to only a small percentage of the total stock of
civil plutonium in the UK, putting into perspective the risks
of following a unique to PFR solution. Since the UKAEA plutonium
is only a small percentage of the UK civil stock, UKAEA considers
it to be an unacceptable commercial risk to pursue what may be
a unique solution for this material.
(b) Surface storage followed by reprocessing
14. It would be feasible to store PFR fuel
for a period of 50 years or more with the aim of eventual reprocessing.
However, this option would be inconsistent with the principle
of sustainable development since it would require future generations
to reconstruct reprocessing facilities similar to those currently
available at Dounreay, to discharge this generation's responsibilities.
(c) Early reprocessing followed by
storage, reuse and disposal of the materials arising
15. Reprocessing spent PFR fuel results
in four main products:
(i) Plutonium and uranium;
(ii) Low Level Waste (LLW) for disposal at
Dounreay or Drigg;
(iii) Intermediate Level Waste (ILW) in a
form appropriate for storage and subsequent disposal to an eventual
UK national repository;
(iv) High Level Waste (HLW) for interim cooled
storage in vitrified form followed by disposal to an eventual
UK national repository.
16. Reprocessing would convert the UKAEA
PFR fuel into forms which are the same as those produced by reprocessing
fuel from Magnox and AGR reactors in the UK. This would allow
UKAEA to be part of a UK-wide solution which would share costs
with the other UK nuclear operators. Separation of plutonium from
PFR fuel would allow the UKAEA's plutonium to be managed with
the rest of the UK's national civil stock, whether reused in MOX
or other types of advanced reactor fuel, or dealt with via an
agreed, common disposal route.
CONCLUSIONS
17. Surface storage of PFR fuel is feasible
but direct disposal to a UK repository would be a high risk option.
UKAEA judges there is insufficient evidence or experience available
to allow this option to be established as technically feasible
and consequently that it is not consistent with the principle
of sustainable development.
18. Storage followed by reprocessing may
be feasible, but not consistent with sustainable development as
it would require future generations to construct facilities to
process the fuel.
19. Adoption of either of these options
could leave a problem unique to the UKAEA PFR fuel for future
generations to solve. The solution could require very significant
research and development, and the production of a unique safety
case. It would also introduce the potential to require the construction
of facilities unique to this fuel. The costs and risks would fall
to the UKAEA and so to the UK taxpayer.
20. Early reprocessing of PFR fuel would
allow it to be disposed of via the same route as other UK nuclear
materials, greatly reducing the risks, bringing economies of scale,
and avoiding costs associated with a unique solution.
Question 8
Details, as given in the briefing, on the
numbers and specific functions hitherto contracted out and recently
taken back into direct employment, together with an overall view
of numbers of staff and functions contracted out and retained
over recent years, would be helpful.
UKAEA has or is about to take back in house
the following functions and staff numbers following a reassessment
by UKAEA in discussion with NII of the scope of the core competence
UKAEA requires as site licensee.
(a) Seven Radiological Protection Advisors, two
of whom were recruited from AEA Technology who had taken the function
with them under contract at the time of their privatisation in
1996.
(b) Three radioactive material transport personnel
(two drivers and a supervisor) from Johnson Controls Limited (JCL).
These staff had been part of the UKAEA's Facilities Services Division
(FSD) sold in 1995 to Procord, which subsequently became JCL.
(c) Six staff from AEAT who controlled contractors
to UKAEA.
(d) Seven staff from the Management Support Contractors
W S Atkins/AEAT.
(e) 20 operational staff for high security nuclear
work in D2670 (The Marshall Laboratory) which had previously been
operated under contract by AEAT. (five of the staff recruited
have come from AEAT).
Previous "divestments" at Dounreay
were:
284 staff to what became AEAT (privatised
in 1996),
132 people divested as part of the
sale of UKAEA's Facilities Services Division in 1995 to Procord,
and 19 staff divested on the sale
of Plant Decommissioning Services to Rolls Royce Nuclear Engineering
in 1997 in order to increase competition in the decommissioning
market.
Question 9
The Committee has asked for an explanation
of why the UKAEA was unwilling to allow the release of Dr Walker's
Report until 12 June, and specifically which parts of it the Authority
regarded as commercially confidential.
Prior to 12 June neither NII nor any Government
Department requested UKAEA to publish Dr Walker's report.
It is our understanding that NII regarded the
report as a working document intended "to produce a dialogue".
Such documents are understood not to be unique to Dounreay and
are not normally published as their role is to facilitate the
regulatory dialogue.
In its evidence to the TIC on 15 June 1998,
the NII Chief Inspector expressed the view that the Dounreay site
was "not unsafe".
Against this background, UKAEA did not agree
to other requests for the report's publication. The contents were
known to its producer, our regulator, who was protecting the public
safety interest, whilst its style and content could damage UKAEA's
commercial position.
The denial of requests for a copy of the report
must not be equated with complacency about the Dounreay plants.
Improvement measures were being implemented at the time as confirmed
by NII evidence to the TIC that it was "satisfied that Dounreay
management were addressing the problems".
The announcement that UKAEA would not be seeking
any further commercial reprocessing contracts made on 5 June by
Government Ministers changed the status of the report. That is
why the UKAEA agreed to the publication of the report on 12 June
following a Ministerial request.
16 July 1998
9 Not printed.
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10
PFR fuel includes materials arising from the manufacture of fast
reactor fuel, the PFR fuel itself and some associated experimental
fuels.
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