Response to Consultation on Nuclear National Policy Statement

First here is the new campaign postcard that is being launched across the area to try and stop the 2 or 3 new reactors being built along with 3 or 4 200metre cooling towers at Oldbury - 16 miles from Stroud. More of the campaign soon but this blog contains some thoughts re the Government's consultation.....

I've been helping put together a response for the local Green party - and would urge others to also comment at: https://www.energynpsconsultation.decc.gov.uk/ by 22nd February. See background on my previous blog here and below are some thoughts.....interestingly Dr Paul Connett in his talk in Kings Stanley last week also condemned nuclear power. Anyway have a look at this.....I think worth a read as it has many of the arguments against building more nuclear.

Response to Consultation on Nuclear National Policy Statement

I object to the proposals laid out in the DECC consultation documents for new nuclear build, particularly at Oldbury, on the grounds laid out below. I also strongly disagree with the proposal to fast-track the planning process, narrowing its remit (e.g. to consider the 160 year-long local storage of spent fuel), and removing the option for objectors to cross-examine industry and Government experts.

1. Nuclear fails to offer an effective answer to climate change or energy security

1.1 Nuclear power stations are impossible to construct before the predicted energy gap between 2015 and 2020. It is unrealistic to expect that any plant could be ready to generate power by 2020, especially when looking at the building performance at Olkiluoto and Flamanville which are three and two years behind schedule respectively, and seriously over their budgets. I am very concerned that for power stations in the UK to be completed within the timeframe the Government says could be the case (eight years), some serious and possibly dangerous shortcuts in building standards and HSE requirements would be used. For example language misunderstandings exacerbated by the use of foreign contractors to keep costs down has been identified in Finland as a contributory factor in causing errors in construction. And so by implication, safety is not guaranteed.

1.2 The Sustainable Development Commission argued against nuclear power saying it would reduce carbon emissions by just 4% by 2025, and that renewables could be brought in more quickly. Professor Tom Burke CBE says that Government propositions for energy security and reducing climate emissions are invalid. As nuclear now produces a mere 13% of UK electricity (DECC 2008 figures, i.e. only 2.34% of our energy supply) and with UK targets to achieve 34% renewable electricity by 2020, renewables and energy conservation are a much better prospect. Breeder technology would offer a more significant amount of energy, but fast breeder technology means uncontrollable nuclear weapons proliferation. The plutonium-driven fast breeder reactors could make a more significant contribution, but this would, in all likelihood, mean the end of any notion of preventing the spread of nuclear weapons to rogue states and terrorists.

1.3 Electricity produced by nuclear power is not CO2 free, and nuclear power is not greenhouse friendly. While electricity generated from nuclear power entails no direct emissions of CO2, the nuclear fuel cycle does release CO2 during mining, fuel enrichment and plant construction. Uranium mining is one of the most CO2-intensive industrial operations, and as demand for uranium grows CO2 emissions are expected to rise as core grades decline. The life cycle of a nuclear power station, including construction, fuel reprocessing, storage and station decommissioning produces no overall benefit to CO2 levels. It is vital this issue is fully investigated before embarking on building more nuclear power stations. Storm van Leeuwen and Smith research ‘Nuclear power the energy balance’, for example, produced some controversial results which claim that nuclear potentially has a very high carbon impact. They said: "The use of nuclear power causes, at the end of the road and under the most favourable conditions, approximately one-third as much CO2-emission as gas-fired electricity production. The rich uranium ores required to achieve this reduction are, however, so limited that if the entire present world electricity demand were to be provided by nuclear power, these ores would be exhausted within four years. Use of the remaining poorer ores in nuclear reactors would produce more CO2 emission than burning fossil fuels directly."

1.4 Uranium supplies. As all the uranium used in commercial nuclear fuel is imported into the UK, it is important – on equity and sustainability grounds - to assess the environmental, radiological and other health impacts of procurement of the uranium that will be imported for future nuclear fuel. Inexplicably, the 200 page ‘Appraisal of Sustainability: Radioactive and Hazardous Waste’, which is part of the Nuclear NPS consultation, makes no mention of the dangers and management challenges of uranium procurement and processing. This is particularly curious, as in another report (Technical Advice to inform proposed Regulatory Justification decisions on new nuclear power stations, IDM68 2009.11), prepared as technical support to the Justification decision documents, this issue is addressed: “Although the authors understand that the approach taken by the Government is that a Regulatory Justification decision takes account only of activities in the UK, this technical advice reviewed the radiological consequences of the entire fuel cycle for nuclear power generation using current reactor designs”. The authors report an analysis performed for Sizewell and include a table that shows the radiological dose detriment from the nuclear fuel cycle. Almost 92% of the detriment is directly attributable to the mining and milling of uranium. The UK has not examined fully within any major forum the issues arising from uranium mining. Inspectors have made calls at both of the last two public inquiries into nuclear facilities (Sizewell B 1983-85 (3) and Hinkley Point C 1988-89 (4)) that this should be done. Without a full evaluation of the impact of uranium mining, including an Appraisal of its Sustainability, the Nuclear NPS is not fit for purpose. I understand Dr. David Lowry has submitted a dossier of problems encountered in the major uranium mining countries - Australia, USA, Canada, Kazakhstan and Namibia, to the first Justification consultation.

1.5 The economics of nuclear new-build are highly uncertain. There is little, if any, justification for public subsidy, but if estimated costs escalate, there’s a clear risk that the taxpayer will have to pick up the tab. Nuclear power will divert funding away from the real long-term solutions which are energy efficiency and renewable energy. Nuclear power was developed through massive state subsidies as part of a nuclear weapons development programme. These R&D costs are not included in conventional nuclear power costings. Indeed in the UK, these expenses were hidden from Parliamentary inspection in the post-war public accounts as ‘Repairs to Public Buildings’. The nuclear power programme died off in the 1990s, through the policies of Mrs Thatcher, who although a staunch supporter of nuclear, insisted on privatising it. The City took a look at the books and did not like what they saw, so decided not to buy into it. There is a finite amount of money available to meet the costs of global warming. Energy conservation is at least seven times as effective in reducing CO2 emissions than nuclear power. Studies suggest that photovoltaic cladding on every house in Britain would reduce the demand on domestic properties more than the electricity generated by the proposed nuclear stations, and at a fraction of the cost. We believe it is very important that further research is carried out on this matter.

Leading investment analysts Citigroup pulls no punches in their recent report explaining the financial risks to companies pursuing new build. It also explains how new build isn't possible without taxpayer subsidies. Philip Hunt, Minister of State at the Department of Energy and Climate Change said on January 21st that the British Government will not use taxpayers’ money to subsidise the construction of new nuclear power plants. In an online question and answer session with The Guardian newspaper, Lord Hunt said the Government had made it “absolutely clear” that the cost of new nuclear power plants must be met in full by the commercial companies themselves, including the cost of decommissioning and waste management. Energy Collective 22nd Jan 2010: http://theenergycollective.com/TheEnergyCollective/57202

The Government spending watchdog says it is still not convinced new nuclear power stations will be built without public subsidies. See Ecologist 22nd Jan here.

1.6 A combination of demand management using smart meters, local grid enhancements to assist with the localisation of generated power from a combination of PV, tidal, estuary schemes, onshore and offshore wind, biomass and combined heat and power (CHP), etc., offer a very different scenario for the UK both in terms of its supply and of its demand for electricity.

A new nuclear programme would give out the wrong signal to consumers and businesses, implying that a major technological fix is all that’s required, weakening the urgent action needed on energy efficiency.

Since the 1975 oil crisis, Denmark has proved convincingly that economic growth equal to that achieved by the UK is possible and with no more emissions being emitted than before 1975. Therefore it is possible for the UK to adopt the same measures to considerably reduce its base load requirements and peak load levels, which would make success with renewable energy vastly more achievable and offer employment and business development opportunities for a much wider and larger number of the workforce than that offered by nuclear.
2. Unacceptable risks from nuclear power

2.1 Emergency plans would be unable to protect the public from a major release of radiation caused by an accident or terrorism.

2.2 Nuclear power has too many serious safety incidents. “Operators of Britain's nuclear power stations reported 1,343 incidents to the Health and Safety Executive since 2001. The authority’s inspectors classified 773 of them as posing no threat, while 563 were safety anomalies. But seven incidents, five of which were related to power plants operated by British Energy, have been listed as harmful. The most recent occurred last year at Dungeness B, after British Energy had been taken over by French nuclear giant EDF, when there was found to be "non-compliance or inadequacy" in its safety arrangements. The most serious incident was a leak at Sellafield in 2005 which went undetected for months. No one was injured when around 80,000 tonnes of acid containing 20 tonnes of uranium and 160kg of plutonium leaked from a broken pipe into a sealed concrete holding.” See Daily Telegraph 26th Jan here.

Reactor designs being discussed lead to additional concerns. For example, the French ‘European Pressurised Reactor’ proposed will use intensive ‘high burn-up fuel’ increasing the risk of high quantities of radiation in a serious accident. This fuel is so hot and radioactive it will also need to be stored on site for 160 years, long after the power company has ceased generating electricity, creating an additional local hazard.

2.3 Long-term waste – no long-term solutions are yet available, let alone acceptable to the general public; it is impossible to guarantee safety over the long-term disposal of waste. Some wastes have radioactivity that remains dangerous to human and animal health for 250,000 years. We have not got the right to dump that problem on our descendants for what will be a relatively short term by comparison with the term needed to store the wastes safely. We have no idea of future generations having the resources to do this, and surely the resources to do so would need to be reserved indefinitely for them. No government to date has experience in such planning or I suspect the intention to do so. I note that the Nuclear Waste Advisory Associates (NWAA), a group of experts with over 200 years of collective experience of the issues involved in nuclear waste, have submitted detailed written evidence to the House of Commons Energy and Climate Change Select Committee Inquiry into the new suite of National Infrastructure Policy Statements. They argue that the national nuclear policy statement indicating the Government’s intention to support new nuclear power stations in the UK is ‘not fit for purpose’. In particular:

- Four former members of the Government’s own Committee on Radioactive Waste Management (CoRWM) – two of whom are members of NWAA - have previously written to the Secretary of State to say that in their opinion, “It is unknowable whether or not effective arrangements (for the long term management of new build waste) will exist....” - The generic scientific grounds upon which the last attempt to dispose of radioactive waste at during the Rock Characterisation Facility programme in 1997 have not been resolved and are therefore still pertinent to the situation today. - Technical problems associated with a disposal facility are legion and most are recognised by the Environment Agency, thereby making any assertion of confidence in the disposability of radioactive waste premature. - Health impact assumptions from exposure to ionising radiation in UK are imprecise and the means by which they are calculated is more by ‘educated guesswork’ than by scientific evaluation. - Nuclear Decommissioning Authority assessments of the disposability of new build nuclear fuel have yet to be carried out by the lead environmental regulator, the Environment Agency, which means confidence expressed by Government is potentially misplaced and certainly premature. - Reliance on experience abroad is no grounds for generating confidence as in Finland and elsewhere; disposal of waste is in its infancy and far from proven. - No assessment has been made of the acceptability of radioactive waste management from the mining and milling of imported uranium, which Government consultants reveal currently produce over 90% of the ‘radiological dose detriment’ from the uranium fuel chain for modern reactor fuel. The document concludes, “In short, the Government’s conclusion “…that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations” is not supported by the evidence.” The Nuclear National Policy Statement is, therefore, not fit for purpose.

The Sustainable Development Commission said they were “very sceptical” about the Government’s statement that it is “satisfied that effective arrangements had been made for nuclear waste”, in evidence to the Energy and Climate Change Committee. “If we haven’t gone far enough down the line of actually constructing a process to deal with the legacy waste, should we be adding to the problem by commissioning new reactors?” asked Greenleaf: See Ecologist 15th January here.

2.4 Although the government is apparently committed to building new nuclear reactors, health risks are shown to be associated with nuclear power stations in the following studies: Somerset Health Authority 1983,1985, and1989, indicating extra childhood leukaemia in West Somerset. In 2008, a major four-year health study found large increases in infant cancers near all German nuclear power stations. The study (called KiKK, the German acronym for child leukaemia near nuclear reactors – Kinderkrebs in der Umgebung von KernKraftwerken) had been confidently commissioned to show no such health problems, but instead it revealed the opposite. It reported a 2.2-fold increase in leukaemia risks and a 1.6-fold increase in embryonal cancer risks among children under five living within five kilometres of all German nuclear power stations. See CND 22nd Jan here.

“Contradicting expectations, the KiKK data show with high statistical power a strongly increasing risk for childhood malignancies with residential proximity to any of the 16 German nuclear plants. The steepest rise in risk occurs within 5 km, but significantly elevated risk extends to 50 km. Tests for plausible confounders found none, nor is chance a plausible explanation.“ Download here.

See also the Low Level Radiation Campaign at: www.llrc.org/index.html

2.5 Nuclear Power is not insured. UK nuclear power stations carry £140 million of public liability insurance, and the Government would contribute an equal amount, but after that it is unknown what liability would be expected of the taxpayer. Surely this needs to be quantified and formally agreed long before any permission is granted for building works.

2.6 International security – if the UK brings forward a new nuclear programme, we surely then cannot deny other countries the same technology. This significantly increases the risks of accidents, radiation exposure, proliferation and terrorist attacks. 9/11 demonstrated the acute vulnerability of the structures of western civilisation to attack from terrorists motivated by suicidal 'religious' convictions. We cannot hope that humane and rational considerations would inhibit terrorists from using the same technique on one or more nuclear plants. It would be consistent with the modus operandi of Al-Qaeda to carry out this kind of high profile action. It is a moot point whether a jumbo jet would breach containment, but it would certainly disrupt the coolant circuits sufficiently to cause releases, and a critical incident (major meltdown) cannot be ruled out.

2.7 Nuclear power stations are vulnerable to flooding as sea levels rise. The proposals are for new plants to be built near the sea, for cooling and waste discharge purposes. Sea level rise due to global warming will add a huge amount to the decommissioning costs.


3. Breaching the Aarhus Convention

3.1 The Environmental Law Foundation in their submission to the Energy and Climate Change Select Committee note that they have possibly breached the Aarhus Convention in the way in which these ‘consultations’ have been carried out.

3.2 Friends of the Earth have said that the NPSs fail to set out an integrated framework for sustainable infrastructure development and have identified a series of serious flaws including:
• Telling the IPC not to consider the carbon impacts of applications that come before it. The NPS should require the IPC and Committee on Climate Change to work together to ensure the UK's electricity sector decarbonises quickly, and in line with the UK's carbon budgets;
• Wrongly instructing the IPC to assume that all forms of energy infrastructure are ‘needed' - which threatens to lock the UK into high carbon energy infrastructure;
• Failing to follow European legal requirements on Strategic Environmental Assessment (SEA);
• Failing to consult properly;
• The energy NPSs are incoherent, badly written and some of the English is simply incorrect.

FoE concludes, "The Government's draft National Planning Statements on energy are fundamentally flawed. The consultation was insufficient, the alternatives were inadequately explored, and the policies are poorly justified. And because they fail to assess the carbon impact that the proposed development will have they threaten to undermine UK Carbon Budgets. Friends of the Earth has written to Ed Miliband warning him that these proposals are probably unlawful and could lead to a challenge in the courts."

Maintaining there is no need for nuclear power, we object to putting Gloucestershire residents and future generations to these risks.