Just back from pancake races in Whiteshill - photos next week - sadly only third this year in the adult race.....anyway to the business of this post.....I've written about the two nuke consultations here and the NPS one can be found here on my blog. This post is about justification - and I've adapted lots from work by Greenpeace who have been able to spend more time on this than me.
Photo: Artist impression of how Oldbury new nukes could look
Justification is a regulatory requirement for new practices under EU law - it must be done before reactors can be approved. It is based on radiological protection principles. No practice involving exposure to ionising radiation should be allowed unless it produces benefits to individuals or society that outweigh the health detriment it may cause. The consultation closes on 22nd Feb and results are likely to be out before the general election. It is a key decision that is crucial if nukes are to be built.
Action to date?
In early 2009 the Nuclear Consultation Group, a group of academics, called for the Government to hold an inquiry into Justification. Their view is that the Government's consultation process does not allow for full examination of all aspects of a nuclear programme to be scrutinised. To date the Government has not given a clear response on this. In fact in the consultation on the draft Justification decision on new reactors it states:
40. The Secretary of State has not concluded at this stage that it is necessary to hold an inquiry or other hearing as part of the Regulatory Justification process. However, the Secretary of State will keep this under review in considering the responses to this consultation and does not propose to make a final decision on holding an inquiry or other hearing until the end of the process (see here).
The Secretary of State can call for an inquiry - similar to that used for planning inquiries. And indeed at the only meeting called on the draft Justification decision folk were told by DECC that: 'We are particularly interested in hearing views from anyone who thinks holding an inquiry will improve the quality of the Secretary of State’s decisions’ on Justification.'
What I've sent is below - it is basically adapted from Greenpeace and other campaign groups like Stop Hinkley. If you have time please make similar points to Owen Jenkins, DECC, Justification Assessment Centre via email: email@example.com
• I ask the Secretary of State to hold an inquiry on the draft Justification decision after the consultation process closes but before he makes a final decision. An inquiry is essential because there has not been open scrutiny of the draft Justification decision. The draft Nuclear National Policy Statement is at least being examined by the Energy and Climate Change Committee. Yet any decision made following consultation on the draft Justification decision will not be subject to Parliamentary scrutiny.
• I am very concerned that there is no opportunity to test the assertions upon which the evidence in the draft Justification decision is based. I understand Article 6 (7) of the Convention allows for a public hearing ‘where appropriate’.
• I am very concerned that once Justification has been finalised the questions concerning the benefits and disbenefits of nuclear energy will not be capable of reconsideration - particularly the health impact.
• We have concerns because the draft Justification decision and accompanying documents do not fully inform the public or concerned stakeholders of the full impacts of nuclear power - particularly on health. An inquiry would improve the quality of decision making by allowing for cross examination of evidence on the potential health impacts of routine operations, accidents or terrorist attacks on reactors, spent fuel stores and examine waste disposal. For example with reference to health I would like consideration given to:
(i) “Leukaemia incidence in Somerset with particular reference to Hinkley Point”. Dr Cameron Bowie, Somerset Health Authority 1983, ’85, ’88. The three reports studied leukaemia incidence in West Somerset, finding a 24 percent excess in those aged under 24 years, suggesting a link to Hinkley Point.
(ii) “Leukaemia in young children living in the vicinity of German nuclear plants”. Kaatsch, 2008 International Journal of Cancer (KiKK report). A very large German Government study showed more than doubling of leukaemia in children living within 5 kilometres of nuclear power stations with an effect as far away as 50 kms. Created a public outcry and many pregnant women moved away from nuclear plants.
(iii) The difficulty with the conventional approach to radiation risk is that the model does not allow sufficiently for internalised radioactive particles. The International Commission on Radiological Protection who advise on this, base their predictions on Hiroshima survivors but a single blast of radiation should be treated differently from long term exposure to inhaled particles. So experts predict low, statistically insignificant health effects. When these turn out to be higher than expected in epidemiological studies, they wrongly say it cannot be connected to the radiation. This is an unscientific approach, based on expected outcomes not on real outcomes. The Committee Examining Risks from Internal Emitters (CERRIE, 2004) reported that radioactive ‘dose’ is now irrelevant, so radioactive discharges in millisieverts will not accurately predict whether individuals will be harmed. They also recommended that regulators should recognise that children are particularly vulnerable.
• An inquiry should not only look at the potential detriments/benefits of new build programme but should also allow for discussion of non-nuclear options e.g. renewables. There should be a fair consideration that looks at overall costs, impact on carbon, risks and deliverability.
• It does not seem right that there has only one meeting on this draft Justification decision over the whole consultation period - and that was in London. Local communities - those most at risk of health impacts - have not had the same opportunities to discuss this matter as they have with the draft Nuclear National Policy Statement. It is worth noting that DECC, in their meetings around the country on the nuclear national policy statement, has (to date) not discussed the draft Justification decision or explained what its impact would be.
• It is completely unacceptable to ask people to fully comment on the thousands of pages on the Nuclear National Policy Statement (and make submissions to the Energy and Climate Change Committee) and at the same time expect them to be able to respond properly to the very lengthy draft Justification decision. An inquiry would provide some remedy for this.
• Many local authorities - who will have to oversee emergency planning in the event of an accident at a nuclear plant - are also unaware or unable to respond to the draft Justification decision because of the scale of work required for the six energy related national policy statements. Again an inquiry would at least help with this.
Cllr. Philip Booth