Response to Consultation on Nuclear National Policy Statement

Dear Sir

I object to the proposals laid out in the DECC consultation documents for new nuclear build, particularly at Oldbury, on the following grounds. I also strongly disagree with the proposal to fast-track the planning process, narrowing its remit (eg 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 not 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 very optimistic that any plant could be ready by 2020 especially when looking at the building performance at Olkiluoto and Flamanville which are three and two years behind schedule respectively and very badly over budget.

1.2. The Sustainable Development Commission argued against nuclear power saying it would reduce carbon emissions by just four percent by 2025 and that renewables could be brought on more quickly. Prof 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 ie 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 3 Fast Breeder technology means uncontrollable nuclear weapons proliferation. The plutonium-driven fast breeder reactors could make a more significant contribution, but this would mean kissing goodbye to any notion of preventing the spread of nuclear weapons to rogue states and terrorists, because there would be so much plutonium around, there is no way we could keep it from falling into the hands of terrorists.

1.3. Electricity Produced by Nuclear Power (NP) is not CO2 free. "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." (ref: http://www.oprit.rug.nl/deenen)

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 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 which shows he 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. Calls have been made by Inspectors 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. Nuclear power will suck 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 the 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 90s, ironically not so much through the activities of the green lobby as through the policies of Mrs Thatcher, who although a staunch supporter of nuclear, insisted on privatising it. When the City took a look at the books, they did not like what they saw, and 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 7 times as effective in reducing CO2 emissions than NP. PV cladding on every house in Britain would produce more electricity than NP at a fraction of the cost. 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.

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. 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. There are no plans are in place for its eventual ‘disposal’. Some nuclear wastes have radioactivity that remains dangerous to human and animal health for 250,000 years. What ethical right do we have to dump that problem on our descendants for the sake of a few years worth of electricity? 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 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’ form 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”.

2.4. Health risks are associated with nuclear power stations shown in the following studies: Somerset Health Authority 1983,’85,’89: extra childhood leukaemia in West Somerset and the KiKK German Government study 2008: more than double childhood leukaemia near every nuclear power station – effect as far as 50 kilometres. See also the low level Radiation Campaign: http://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 would happen. Ironically, the planning Inspector ruled that there could be a wind farm near Hinkley point nuclear power station because a blade might break off... and damage the power station.

2.6. Nuclear Power Stations are vulnerable to terrorist attack. 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 do 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.

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

Philip Booth





On behalf of Stroud District Green Party