Stop Hinkley submission to the Government 2007 nuclear consultation

Introduction

The forcibly relaunched Nuclear Consultation by the Government seriously underplays the many risks from a new generation of nuclear power.

We note a series of concerns about the Government's document laying out its favoured position over nuclear power. We feel it misinforms the public on nuclear risks and does not present fairly the position of critics. The 2006 energy consultation was derailed by the High Court in February for being " unfair and misleading ". The previous 2003 Energy Review, which did not recommend nuclear was well informed and did not suffer the disadvantage of heavy Downing Street influence as we believe occurred in the 2006 review.

Some examples of underplayed risks from nuclear power in the 2007 consultation paper:

1. A quoted one in 2.4 billion year risk of a meltdown in current UK nuclear reactors: lacks credibility given the extent of reactor core corrosion in existing reactors like Hinkley Point B (28% forecast for 2009) and Oldbury (34.5% current value) Nuclear consultant John Large has said this could escalate to a fuel fire and escape of fissile gases (http://www.largeassociates.com/3154%20Graphite%20AGR/R3154-Graphite%20FINAL%2028%2006%2006.pdf). Regulators state a fuel-clad melt risk at Oldbury is a mere one in 1,000 (NII documents received through the FoI Act, 2006). Only one UK reactor currently, Sizewell B, has 'secondary containment' to slow down the release of fissile gasses into the environment following an accident.

2. " New reactors will be built more safely with 'passive' safety systems": The Westinghouse AP1000 has reduced its costs by cutting out 75 percent of safety systems considered essential for the last built Westinghouse, Sizewell B. It has replaced these with a simplistic water tank above the reactor to douse it in the event of overheating. The AP1000 has no secondary containment and bosses railed at regulators' suggestions that designs should include safety containment as this would add £100 million to each reactor's costs (November 2006, NII offices, Bootle).

3. Terrorist risks were underplayed with the suggestion that new reactors may be proof against large aircraft crashes: The AP1000 is demonstrably 'tinnier' than existing reactors: their CEO boasted they had saved 50% on concrete costs. The European Pressurised Reactor, currently being built in Finland was last year subject to a leaked high level memo which was interpreted by nuclear consultant John Large that it could not withstand the impact of a terrorist aircraft crash: 'Operational Risks and Hazards of the EPR when subject to Aircraft Crash', June 2006 (http://www.largeassociates.com/3150%20Flamanville/R3150-aircraft%20impact%20-%20FINAL.pdf)

4. Health risks to the public were downplayed with references to so called safe radioactive doses to the public but no mention was made that the CERRIE Government committee said 'radioactive dose' is now a meaningless term as different isotopes act differently on different people and not in a uniform way. The COMARE Government committee study of 2004 misleadingly was said to show no adverse health effects on the public within 25 kilometres of nuclear power stations but this research averaged the figures over a radius of 25 kilometres from nuclear plants, which would allow large populations from unaffected towns to swamp the figures from smaller areas, often rural nearer to the sites. Cancer clusters have been shown to occur at much closer distances, as studies our group has commissioned have shown ( www.llrc.org ). The COMARE paper did however show extra cancers near nuclear weapons sites, overlooked in this consultation paper.

5. " Reprocessing will not be needed therefore risks from transporting spent fuel are reduced" : The Oxford Group of academics said that due to the increased planned building of nuclear plants worldwide, there will be reduced availability of uranium fuel. Reprocessing may be the only option to keep reactors supplied with otherwise sparse fuel, thus increasing the hazards from transportation and the risk of materials reaching terrorists. Moreover the flip side of not reprocessing dangerous spent fuel is storing it at reactor sites for up to sixty years. This would create an unacceptable security risk to local populations.

  1. TO WHAT EXTENT DO YOU BELIEVE THAT TACKLING CLIMATE CHANGE AND ENSURING THE SECURITY OF ENERGY SUPPLIES ARE CRITICAL CHALLENGES FOR THE UK THAT REQUIRE SIGNIFICANT ACTION IN THE NEAR TERM AND A SUSTAINED STRATEGY BETWEEN NOW AND 2050?

  2. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON CARBON EMISSIONS FROM NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  3. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SECURITY OF SUPPLY IMPACT OF NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  4. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE ECONOMICS OF NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  5. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE VALUE OF HAVING NUCLEAR POWER AS AN OPTION? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  6. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SAFETY, SECURITY, HEALTH AND NON-PROLIFERATION ISSUES? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  7. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE TRANSPORT OF NUCLEAR MATERIALS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  8. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON WASTE AND DECOMMISSIONING ? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  9. WHAT ARE THE IMPLICATIONS FOR THE MANAGEMENT OF EXISTING NUCLEAR WASTE OF TAKING A DECISION TO ALLOW ENERGY COMPANIES TO BUILD NEW NUCLEAR POWER STATIONS?

  10. WHAT DO YOU THINK ARE THE ETHICAL CONSIDERATIONS RELATED TO A DECISION TO ALLOW NEW NUCLEAR POWER STATIONS TO BE BUILT? AND HOW SHOULD THESE BE BALANCED AGAINST THE NEED TO ADDRESS CLIMATE CHANGE?

  11. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON ENVIRONMENTAL ISSUES? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  12. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SUPPLY OF NUCLEAR FUEL? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  13. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SUPPLY CHAIN AND SKILLS CAPACITY? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  14. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON REPROCESSING? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

  15. ARE THERE ANY OTHER ISSUES OR INFORMATION THAT YOU BELIEVE NEED TO BE CONSIDERED BEFORE TAKING A DECISION ON GIVING ENERGY COMPANIES THE OPTION OF INVESTING IN NUCLEAR POWER STATIONS? AND WHY?

  16. IN THE CONTEXT OF TACKLING CLIMATE CHANGE AND ENSURING ENERGY SECURITY, DO YOU AGREE OR DISAGREE THAT IT WOULD BE IN THE PUBLIC INTEREST TO GIVE ENERGY COMPANIES THE OPTION OF INVESTING IN NEW NUCLEAR POWER STATIONS?

  17. ARE THERE OTHER CONDITIONS THAT YOU BELIEVE SHOULD BE PUT IN PLACE BEFORE GIVING ENERGY COMPANIES THE OPTION OF INVESTING IN NEW NUCLEAR POWER STATIONS? (FOR EXAMPLE, RESTRICTING BUILD TO THE VICINITY OF EXISTING SITES, OR RESTRICTING BUILD TO APPROXIMATELY REPLACING THE EXISTING CAPACITY)

  18. DO YOU THINK THESE ARE THE RIGHT FACILITATIVE ACTIONS TO REDUCE THE REGULATORY AND PLANNING RISKS ASSOCIATED WITH SUCH INVESTMENTS? ARE THERE ANY OTHER MEASURES THAT YOU THINK THE GOVERNMENT SHOULD CONSIDER?

 

1. TO WHAT EXTENT DO YOU BELIEVE THAT TACKLING CLIMATE CHANGE AND ENSURING THE SECURITY OF ENERGY SUPPLIES ARE CRITICAL CHALLENGES FOR THE UK THAT REQUIRE SIGNIFICANT ACTION IN THE NEAR TERM AND A SUSTAINED STRATEGY BETWEEN NOW AND 2050?

These are very important challenges but they can be met without using nuclear power. Even in this document, though buried at a late stage, there is an acknowledgment that a new generation of nuclear power stations in the UK would save only five per cent of our carbon emissions. Moreover the delay in implementing a nuclear programme would also delay these insubstantial carbon savings while resources would be drawn away from more quickly achievable and cheaper solutions:

The risks might be argued to be worth the cost if nuclear power could have a substantial impact in slowing global warming. But even some industry experts doubt that's possible. To reduce carbon dioxide emissions by 1 billion tons annually, the level set by some scientists as a goal for nuclear power, the world would need to build 21 new 1,000-megawatt nuclear plants per year - about five of those annually in the US - for the next 50 years, according to a report by the US Keystone Center: ( http://www.keystone.org/spp/documents/FinalReport_NJFF6_12_2007(1).pdf ) endorsed by the Nuclear Energy Institute ( www. nei .org) . The US industry reached that level in the 1980s. But even under its most optimistic assessment, the Energy Information Administration ( www.eia.doe.gov ) recently projected that only about 53 nuclear power plants would be built there by 2056. At that rate, this would not even replace the existing nuclear capacity expected to be retired during that time . This slow rate takes account of huge Federal subsidies which are said to be not forthcoming in the UK so we could assume the rate of nuclear growth here would be even slower with subsequent tardiness in any help to greenhouse emissions.

There are many problems associated with nuclear power (see http://www.mng.org.uk/gh/no_nukes.htm ) and many of them are serious. No other source of electricity has so many drawbacks.

If there was no alternative, we might have to consider using nuclear power. But there is now abundant evidence in several different reports that our current and future needs for electricity can be met from renewable sources with sensible conservation measures, and without using nuclear power. Recent reports to that effect are listed on http://www.mng.org.uk/gh/scenarios.htm with summaries and links for downloading. Those marked ' UK ' describe scenarios that are directly relevant to the UK but other reports in the list are also relevant to considerations of future energy supplies in the UK .

Currently, Germany gets 13% of its energy from renewable sources, the sector is booming and Angela Merkel would like to commit Germany to a target of 27% by 2020 ( http://www.guardian.co.uk/environment/2007/aug/13/renewableenergy.energy ). By contrast, the UK obtains only 2-3% of its energy from renewable sources and, with current policies, is unlikely to achieve more than 5% by 2020 (ibid.). It does look as if we need to adopt some of the policies that have proved effective elsewhere.

If nuclear power was much cheaper than the alternatives, it could be argued we might need to consider using nuclear power. But the weight of evidence is that, when all the hidden costs are added in, it is one of the most expensive sources of electricity (see bullet point 4 in http://www.mng.org.uk/gh/no_nukes.htm ). This relative disadvantage of nuclear power is likely to increase as the costs of renewable sources of energy are brought down by economies of scale and refinements in technologies.

If nuclear power provided greater security of supplies than the alternatives, we might need to consider using it. But the evidence points in the other direction. Contrary to what Malcolm Wicks MP has said, nuclear power is not a 'home grown' source of power: all raw nuclear fuel is currently imported into the UK . The vulnerability of nuclear plants and nuclear transports to terrorist attack has implications for security of supplies. In the non-nuclear low-carbon scenarios described in the TRANS-CSP report from the German Aerospace Center (see http://www.trec-uk.org.uk/reports.htm ), there is an overall reduction in imports of energy into Europe compared with the situation now, an overall increase in the diversity of sources of electricity, and a corresponding increase in the resilience and security of electricity supplies.

Nuclear power currently enjoys a large hidden subsidy in the form of limitations on liabilities arising from Chernobyl-style disasters, or worse (see answers to Question 4). This subsidy is not acceptable and should be removed forthwith.

Alternative models:

Energy Conservation

The 2003 Energy Review and the Energy Savings Trust ( www.energysavingtrust.org.uk/ ) have both said that the UK could save thirty per cent of its energy at nil net cost with a correlated reduction in carbon emissions.

Utilities could take on much more responsibility for reducing energy demand, in supplying low energy light bulbs and energy audits on homes, offices and factories.

New and existing buildings should come under legal obligation to be built to Zero Energy Development standards, as modelled by the BedZed development in Sutton: (http://www.bioregional.com/programme_projects/ecohous_prog/bedzed/bedzed_hpg.htm).

Localised Energy Systems

The current centralised grid system relies on large units of generation often hundreds of miles from the consumer. This model can be wasteful because as much as two-thirds of the original power source is lost from generation to consumption. The 2003 Energy Review saw district based systems as a progressive vision but this seems lost in the current drive towards big centralised nuclear and other generating plants.

The Sustainable Development Commission hailed the localised approach as one of the key points in its recent report, 'Nuclear Won't Fix It' (http://www.sd-commission.org.uk/pages/060306.html), saying we could lose this opportunity for fifty years if we don't take it now. The approach was popular when outlined by Bridget Woodman, Research Fellow at Warwick University at a Stop Hinkley/Forum 21 public meeting in Watchet in March 2006. Woking Council have achieved a 72 per cent reduction in carbon emissions by setting up a localised system where offices and council buildings are heated and provided with electricity from local sources, especially Combined Heat and Power Units (CHP).

London 's authority has taken up this challenge too and plans to introduce a decentralised network where home and office-based solar panels and wind turbines can feed back into the district grid system.

Renewable Energy

The myriad forms of renewable energy do not need elaboration in this response. But our group fears that it could be easier for civil servants to accept just one or two large-scale approaches to energy policy such as nuclear, coal and gas as opposed to facilitating a patchwork of interdependent and complimentary smaller-scale approaches.

Wind-power could complement and overlap with power from solar panels, waves or tidal lagoons, all perhaps peaking at different times of the day and year. All of these could interact with biomass which could be a stand-by option.

The UK seems to have a wealth of natural resources, as the windiest country by far in Europe and that with the second highest tidal range, in the Severn Estuary, ideal for tidal barrages, espoused by environmental groups such as Greenpeace, FoE, WWF, Somerset Wildlife Trust.

Tradable carbon quotas

An idea is fast taking shape whereby individuals are able to trade on the amount of energy they consume and carbon they emit. Those consuming less can profit from those using more. Carbon targets could be achieved by gradually reducing the overall availability of carbon quotas.

Non-electricity energy

One reason that nuclear would only reduce our carbon emissions by at the most eight per cent is that most energy goes into heating buildings and powering transport. As suggested earlier, buildings could be much more effectively insulated and CHP units installed as part of district schemes. Council tax could be adjusted depending on home energy audits.

On transport there could be stricter taxing of fuel, not to raise cash for the nation's coffers, but to help change the travelling behaviour of the public. Investment in public transport would be the corollary. This approach should particularly apply to air travel, the fastest growing sector. If fuel taxation is considered too difficult in an international market (although a quarter of international flights start or finish in the UK ) then airport tax could be sharply increased.

International Cooperation

The 'Contract and Converge' model seems the most appropriate way forward to achieving fairness between rich and poor countries, allowing poorer countries to 'catch' up with the wealthy West, while we gradually reduce our greater impact on the climate and therefore as a consequence on the Third World. It would be inappropriate to prescribe nuclear power for all other counties as a model to help climate change, therefore we should not apply it to the UK .

 


2. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON CARBON EMISSIONS FROM NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

Nuclear power has been lauded as a carbon-neutral technology. However this is not true, taking the full life-cycle of the nuclear process. Mining, processing and transporting uranium ore for fuel all produce carbon emissions. Seven percent of Australia 's carbon emissions come from its uranium mining, which has formed the largest man-made hole on earth. The building and decommissioning of nuclear power stations, production and enrichment of fuel and the treatment, transport and containment of nuclear waste which has to be kept for hundreds of thousands of years will all contribute to carbon emissions. As high grade uranium ores run out, which is predicted to happen within the next 50 years, the amount of carbon dioxide generated to support nuclear power production will increase massively. The greater the take-up of nuclear power, the harder the ore will become to extract, requiring ever more fossil-energy.

Helen Caldicott in "Nuclear power is not the answer" (ISBN-13 978-1-59558-067-2) quotes research showing that " The use of nuclear power causes, at the end of the road and under the most favourable conditions, approximately one-third as much carbon dioxide (CO2) emission as gas-fired electricity production." The use of poorer ores as a source of fuel for nuclear reactors " would produce more CO2 emissions than burning fossil fuels directly." In other words, " nuclear reactors are best understood as complicated, expensive, and inefficient gas burners." (above, p. 6).

In the light of the evidence presented by Helen Caldicott, the claim that CO2 emissions from nuclear power are "similar to the carbon dioxide emissions from wind power" (para 44 of the preamble) is, frankly, not credible. Any confidence that we might have in such claims is undermined by the nuclear industry's long history of misleading the public about costs, safety and other aspects of nuclear power.

Compared to wind-power, nuclear is considered to produce fifty per cent more carbon per kilowatt produced. Several groups have highlighted the fact that a doubling of nuclear capacity would bring about a five per cent reduction in carbon emissions, while the Government's target by 2050 is a sixty per cent reduction. Moreover there would be a necessary time-lag in building new reactors which would not help the UK 's 2010 targets and only marginally, if at all, those of 2020. Finland 's emissions have actually risen while their new reactor is being built, possibly as people there believe the climate problem has been 'fixed' so take no other avoiding action.

In 2003 the government believed we could reduce carbon emissions by 60% by 2050 without nuclear power. Patricia Hewitt (Sec of State for Trade and Industry) said "If we achieve a step change in both energy efficiency and renewables we will be able to move beyond 2020 to 2050 without the need for a generation of nuclear power stations." Nothing has changed since then.

Even if ten new nuclear power stations were built, they would only reduce total carbon emissions by about 5%. This is because only 30% of emissions come from electricity generation - another 60% come from transport, industry, homes, waste and agriculture. Nuclear has no effect on these at all.

Building new nuclear power stations takes a long time - even the first would not be up and running until 2018. We cannot afford to wait that long, especially for such a tiny and expensive saving of carbon emissions. Emissions need to be cut now.

Support for nuclear undermines the real solutions to climate change. Patricia Hewitt 2003: "It would have been foolish to announce... that we would embark on a new generation of nuclear power stations because that would have guaranteed that we would not make the necessary investment in both energy efficiency and renewables. That is why we are not going to build a new generation of nuclear power stations now." To ensure we deal with climate change we need to change the way we generate and use energy now. Waiting for nuclear in 15-20 years time will be too late, and will keep the focus on electricity instead of addressing all carbon emissions. Already this government is watering down targets for energy efficiency and renewables.

In its energy review in 2003 the government itself identified ways of achieving a 30% reduction in energy demand. In fact, energy efficiency could reduce UK emissions by up to 40% by 2050 and a further 20% cut could be achieved through proven and safe technologies like wind, solar and combined heat and power programmes.

Woking Borough Council has cut its carbon emissions by 70% through energy efficiency, combined heat and power and renewables operating through private grid networks. (http://www.woking.gov.uk/environment/climatechangestrategy)

Paying to put in place energy efficiency measures is a permanent way to reduce demand for energy. At least twice, and maybe seven times, as much carbon dioxide can be saved through energy efficiency than nuclear power for the same cost - and the efficiency savings are permanent.

If 25% of central heating boilers were replaced with Combined Heat and Power units over the next 15 years, they would provide the equivalent of six new nuclear power stations worth of energy.

Policies the government could and should implement which would reduce demand, increase efficiency and encourage renewables include: improving public transport, reducing car use and tackling the growth in air travel, reducing food miles; making old buildings more energy efficient and ensuring that new build is carbon neutral; increasing micro-generation and local generation from renewables and decreasing reliance on the national grid, and building more efficient power stations for example Combined Heat and Power.




3. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SECURITY OF SUPPLY IMPACT OF NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

If the government does go for nuclear, the earliest power stations won't be operational until 2018, which is too late to deal with any energy gap. However, with renewables, efficiency and demand reduction and gas, there is no gap. The problem is the government implementing these measures while spending its money and energy on new nuclear build.

If for example the French designed EPR reactor should be built, the UK will become dependent not only on imported and increasingly scarce uranium for its fuel but also on French imported fuel elements. France might take the view in the future that with uranium in short supply they could hold back on exports to the UK of the fabricated fuel elements, favouring the home 'market'. On the other hand big price increases could make us pay dearly for the imports.

Faults and outages :

Hinkley Point B at the age of 31 years has been out of commission for four months this year due to previously undetected corrosion in boiler tubes. The expected life of a new generation of nuclear power stations is sixty years. But if unexpected faults arise then long outages may become necessary (due to the radioactive working environment) and security of supply is interrupted. If parallel outages in identical reactors are necessary (Hunterston B was also out of commission for the same period) this causes potential disruption to the national grid. Hinkley B and Hunterston B are now necessarily operating at sixty percent output to reduce strain on the brittle boiler tubes.

With ever larger reactors (the proposed EPR is rated at 1600 MW) the risks to supply are a gamble compared with decentralised systems discussed earlier.

All uranium is imported: nuclear power is certainly not a 'home grown' source of energy as Malcolm Wicks has suggested. Australian uranium mines have been subject to flooding and one large open mine is due to close.

The vulnerability of nuclear plants to terrorist attack (and likewise for trains and ships carrying nuclear materials) has implications for the security of electricity supplies from nuclear sources.

The TRANS-CSP report from the German Aerospace Center has described in detail how Europe could meet all its needs for electricity, make deep cuts in CO2 emissions and phase out nuclear power at the same time. In the scenarios that they describe up to 2050, there would be an overall reduction in imports of energy compared with the situation now (notwithstanding their proposals to import solar energy), there would be an overall increase in the diversity of sources of energy (notwithstanding their proposal to phase out nuclear power), and there would be a corresponding increase in the resilience and security of electricity supplies. The report may be downloaded via links from http://www.trec-uk.org.uk/reports.htm .

Regarding the statement that "Nuclear power is most economic when run continually, so it is well placed to meet the need for baseload capacity in the UK" , a much better alternative is concentrating solar power (CSP) with heat storage and the use of gas a stop-gap source of heat (see http://www.trec-uk.org.uk/csp.htm ). It can provide any combination of baseload power, intermediate load or peaking power -- which means that it is much more useful in matching supplies to constantly varying demands than an inflexible source like nuclear power.

 


4. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE ECONOMICS OF NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

It is always cheaper to save energy than to generate more, and according to the Rocky Mountain Institute, every pound invested in efficiency displaces nearly seven times as much carbon dioxide as a pound invested in nuclear power.

The track record of the nuclear industry in completing to time and budget is poor. For example, the last nuclear power station to be built in the UK was Sizewell, and during its planning and building its capital costs doubled from £2 billion to £4 billion at today's prices.

It is estimated that the cost of providing security against terrorism for nuclear power plants is around £50 million per year.

No free market economy has developed nuclear power. When the Conservative Government privatised the newest part of the UK nuclear industry in 1996 it did so by selling eight nuclear power stations for the price of one, Sizewell 'B'. It could not hope to sell off the already ageing Magnox reactors which were kept in State hands.

Even without the huge construction costs of the AGR stations, British Energy (BE) could not withstand market forces, which led to reduced electricity prices, and it went belly-up in 2002. The rescue package took two years and much ministerial and civil-servant time to fully resolve. It required the state owned BNFL to stump up the front-end and back-end costs of BE operations, in respect of subsidised fuel fabrication and spent fuel reprocessing. The cost of the latter was estimated at £300 million per year. Annoyingly BE never wanted its spent fuel to be reprocessed, preferring the much cheaper (and less polluting) dry-storage option. But this useless process was perpetuated, we believe, to keep BNFL's books also appearing healthy. The Treasury also accepted part of the future cost of BE's reactor decommissioning as part of this unfortunate deal.

The project to decommission the Magnox reactors and Sellafield site seems to rise every time it is examined. The Nuclear Decommissioning Authority last year announced a hike in costs from £56 billion to £70 billion, not ruling out further escalation. This massive project does not include the cost of British Energy reactors, whose liability on the public recently rose to £5 billion, nor the MoD decommissioning of nuclear submarines and land-based plant, nor the cost of managing all the nuclear waste in perpetuity. One report estimates these totalling an unimaginable £160 billion (Bilateral meeting after CoRWM Round Table meeting, Bristol , January 10th 2006 ).

City analysts have suggested that reactors will not be built by commerce without some Government subsidy. Currently there is no restriction on new build but, tellingly, no company has taken the opportunity. The areas they point to are:

. shortening the licensing and planning process which can add costs by their duration but also by 'surprise' interventions requiring safety modifications etc;

. fixing the price of electricity with a mechanism such as a nuclear obligation, requiring electricity companies to buy a proportion of their electricity from nuclear generators;

. help with decommissioning costs;

. help with long-term nuclear waste management

Even if companies suggest they will 'pay their way' as EDF are promising, the taxpayer will be blackmailed into stumping up again if companies 'lose their way' as with British Energy in 2003. We will not be able to walk away from radioactive hulks of reactors even if companies go broke.

Sanders Research agrees with the Government's analysis, in the consultation preamble, that nuclear power will need guaranteed carbon credits for it to be viable. " The problem with this is that as fossil fuels deplete, the ability of the "dirty" generators to compensate for the poor economics of the "clean" progressively reduces. Although EdF/Areva, being mostly French state-owned need no subsidy, the demand by EdF for guaranteed carbon credits over the operational life of a claimed 60 years is equivalent to one and is an admission of non-viability. This shows that the claims of the nuclear lobby that there is no need of subsidy is undermined by the demands of the most likely developer ."

(http://www.sandersresearch.com/index.php?option=com_content&task=view&id=1318&Itemid=105)

Federal Subsidies in the US :

The anticipated US renaissance, with 28 new reactor applications expected over the next fifteen months, may be less robust than it looks. Even if the projects are successful and building proceeds at breakneck speed, the lead times are so long and costs so high that it's unclear that the US can build enough nuclear plants to make a dent in greenhouse-gas emissions by 2050. Moreover they're so financially risky, experts say, that the only reason building plans are under way is that the federal government has stepped in to guarantee investors against loan defaults.

"Clearly, [nuclear power companies] are not so confident or they wouldn't want the federal government and taxpayer to be guaranteeing the loans," says David Schlissel a long-time nuclear industry analyst with consulting firm Synapse Energy Economics in Cambridge , Mass.

The industry says it needs the aid to get nuclear power rolling again. Under the Energy Policy Act of 2005, the industry already is getting an estimated $12 billion in tax breaks and other largess. The Price-Anderson Act, a law dating from the 1950s, caps the industry's liability at about $10 billion in the event of an accident, even though studies show that a major nuclear meltdown could easily run 50 times that.

Now, the Senate version of a new energy bill includes a provision that could provide tens of billions of dollars more in federal-loan guarantees. On 25 th September, the Energy Department announced it would provide up to $2 billion in federal risk insurance for the first six new nuclear-plant projects, protecting them against losses from regulatory or legal delays.

" In my view, these kinds of taxpayer subsidies are vital to the industry, and they wouldn't be building any of these new nuclear plants without them," said Doug Koplow, president of Earth Track, a Cambridge, Mass., consulting firm that analyzes subsidies for all forms of energy, including biofuels. The nuclear industry gets Federal subsidies of about $9 billion a year, he calculates, only coming behind oil and coal in federal energy aid. That amount could go far higher if companies were to begin defaulting on guaranteed loans.

The nuclear industry has already put Congress on notice that it could require loan guarantees of at least $20 billion for planned projects - and more later, NEI officials told The New York Times in July. The reason is that nuclear power plants are far more expensive to build than coal- or gas-fired facilities. For example: On 24 th September, New Jersey-based NRG Energy Corp. filed its application with the Nuclear Regulatory Commission to build two reactors in Texas at a cost between $5.4 and $6.7 billion. Christian Science Monitor, 28 th September (http://www.csmonitor.com/2007/0928/p01s05-usgn.html?page=1)

When all the overt and hidden subsidies are taken into account, nuclear power is much more expensive than any other source of electricity. Some figures on costs from the New Economics Foundation are quoted in "Is it all over for nuclear power?" ( http://www.mng.org.uk/gh/renewable_energy/NS_nuclear_article.htm ). The source of those figures is the NEF report "Mirage and oasis" ( http://www.mng.org.uk/gh/scenarios/nef_energy_june_2005.pdf , PDF, 1.2 MB).

There is a very full account of costs in Helen Caldicott's book (ISBN-13 978-1-59558-067-2). To be competitive with other sources of power, nuclear power requires permanent support from tax payers or permanent support by means of market mechanisms or hidden subsidies. By contrast, most renewable forms of energy need temporary support until costs are reduced by economies of scales and refinement of technologies, and no further support after that.

One of the biggest of several hidden subsidies for nuclear power is that it is only required to pay a small fraction of the cost of insuring fully against claims from a Chernobyl-style disaster, or worse: "... in the United States, the Price-Anderson Act limits the nuclear industry's liability in the event of a catastrophic accident to $9.1 billion, which is less than 2% of the $600 billion guaranteed by the Congress. In any case, $600 billion is considered to be a gross underestimate." (Helen Caldicott, p. 32).

Subsidies in other countries:

There are similar limitations on liabilities in other countries around the world, including the UK . " In France , if Electricité de France had to insure for the full cost of a meltdown, the price of nuclear electricity would increase by about 300%. Hence, as opposed to conventional wisdom, the price of French nuclear electricity is artificially low." (ibid. p. 32). Full insurance against nuclear disasters would completely demolish any economic case for nuclear power.

Finnish utility Teollisuuden Voima Oy (TVO) has stated that it has no intention of sharing the costs resulting from delays in the construction of the Olkiluoto 3 nuclear reactor with the plant's supplier Areva . Analysts have estimated the cost of the overruns at 1.5 billion Euros, half the reported 3 billion value of the project. The plant is now not expected to open until 2011, compared with the initially scheduled date of 2009 (6 years instead of 4). So it is 50% over budget and taking 50% longer than planned. Forbes 28th Sept 2007 ( http://www.forbes.com/markets/feeds/afx/2007/09/28/afx4165822.html )

Other hidden subsidies include:

•  The costs of providing protection against terrorist attack for nuclear plants, and for trains and ships carrying nuclear fuel and nuclear waste.

•  The hidden or future costs to us all arising from the fact that any such protection can only ever be partial.

•  The cost of decommissioning nuclear plants. An estimate in 2006 by the UK Treasury for the cost of decommissioning the UK 's old nuclear power stations was GBP 90 billion.

•  The costs born by national governments in that ultimately they must underwrite the risk that any nuclear company may fail, as evidenced by the way the UK government had to bale out British Energy in 2005 at a cost of GBP 5 billion.

•  The costs arising from nuclear waste that will be dangerous for many thousands of years. These costs will be born by future generations but they will receive no compensating benefit.


5. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE VALUE OF HAVING NUCLEAR POWER AS AN OPTION? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

The preamble to this question lays stress on risks and uncertainties about the way the world and energy markets may develop with corresponding uncertainties about which sources of energy will be most appropriate in the future. Those kinds of uncertainty are a very good reason for using technologies with short lead times and avoiding a technology like nuclear power which has, as the Government acknowledges, very long lead times. By the time a nuclear power station has been built, it may easily be a white elephant. Renewable sources can be brought on stream very much more quickly, which means that there is much less chance that any one installation will turn out to be a costly embarrassment.

Regarding the point about security of supply in para 69 of the preamble:

•  As previously mentioned, the TRANS-CSP scenarios provide for a reduction in imports of energy into Europe compared with current systems, they provide for greater diversity of sources of electricity than what we have now, and there is a corresponding increase in the resilience and security of electricity supplies.

•  As previously mentioned, the vulnerability of nuclear plants and nuclear transports to terrorist attack has implications for security of supply.

With regard to the point about reducing carbon emissions in para 69: as previously mentioned, it is abundantly clear from several different reports (see http://www.mng.org.uk/gh/scenarios.htm ) that we can achieve the necessary deep cuts in CO2 emissions without using nuclear power. The nuclear power cycle produces far more CO2 than is claimed by the industry. There are several other sources of electricity with much lower CO2 emissions.

With regard to para 70, it is nonsense to suggest that "By excluding nuclear as an option ... meeting our carbon emissions reduction goal would be more expensive. " When all the hidden costs of nuclear power are properly accounted for, it is already one of the most expensive sources of electricity. The gap will widen as the costs of renewable sources of electricity fall.


 

6. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SAFETY, SECURITY, HEALTH AND NON-PROLIFERATION ISSUES? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree

1. A quoted one in 2.4 billion year risk of a meltdown in current UK nuclear reactors: lacks credibility given the extent of reactor core corrosion in existing reactors like Hinkley B (peak average 28% forecast for 2009) and Oldbury (35% current value). Regulators state a fuel-fire risk at Oldbury is a mere one in 1,000. Only one UK reactor currently has 'secondary containment' to slow down the release of fissile gasses into the environment post accident.

2. New reactors will be built more safely with 'passive' safety systems: The Westinghouse AP1000 has reduced its costs by cutting out 75 percent of safety systems considered essential for the last built Westinghouse, Sizewell B. It has replaced these with a simplistic water tank above the reactor to douse it in the event of overheating. The AP1000 has no secondary containment and bosses railed at regulators' suggestions that designs should include safety containment as this would add £100 million to each reactor's costs.

3. Terrorist risks were underplayed with the suggestion that new reactors may be proof against large aircraft crashes: The AP1000 is demonstrably 'tinnier' than existing reactors: their CEO boasted they had saved 50% on concrete costs. The European Pressurised Reactor, currently being built in Finland was last year subject to a leaked high level memo that it could not withstand an aircraft crash.

4. Health risks to the public were downplayed with references to public doses but no mention that the CERRIE Government committee said 'radioactive dose' is now meaningless as different isotopes act differently on different people and not in a uniform way. The COMARE Government committee study of 2004 misleadingly was said to show no adverse health effects on the public within 25 kilometres of nuclear power stations but this research averaged the figures over 25 kilometres when cancer clusters have been shown to occur at much closer distances. It did however show extra cancers near nuclear weapons sites, overlooked in the consultation paper.

Health

Health effects of low level radiation: Perhaps the most worrying aspect is the continued wall of secrecy surrounding the industry. A committee examining cancer risks from radiation was gagged by Government lawyers (Sunday Times 1st August 2004 ). So the committee's report, warning of greatly increased risks to those living near nuclear power stations, was watered down. Even so, the Committee Examining Radiological Risks from Internal Emitters (CERRIE) still said there was an error in current health risk calculations "of at least one order of magnitude". Professor Dudley Goodhead, leading the committee, said chillingly that all decision-makers should take note, particularly where children in affected local populations could be concerned.

A more recent COMARE report (Committee on Medical Aspects of Radiation in the Environment) suggested that living within 25 kilometres of nuclear power stations proved no threat to public health. But the report used a crude method circling the plants to a bigger distance than one would expect to find health effects from air and sea-borne radioactive particles, which also encompassed large populations. The net effect was to swamp out any significant figures in blighted towns downwind and downstream from the plants, rendering its conclusions meaningless. Our own sponsored research has shown an increased rate of breast cancer, both mortality and incidence, in the nearest large town to Hinkley Point, Burnham-on-Sea. Mortality was double according to Office of National Statistics figures examined by Dr Chris Busby of Green Audit over a five year period. South West Cancer Intelligence Service figures showed breast cancer registrations were 21 percent higher than expected over a thirteen year period to 2002. See www.llrc.org for details.

Our group examined studies by Somerset Health Authority (Dr Cameron Bowie, Somerset Health Authority, Leukaemia Incidence in Somerset with particular reference to Hinkley Point. 1983, '87, '89) which suggested that radioactive discharges from the power station could account for leukaemia excesses in the young population nearby. Dr Cameron Bowie's conclusion was that accidental releases might have triggered the cancers, including one statistically unexpected case in the same low population ward as the power station.

So we commissioned Green Audit to look again at local cancers. Dr Chris Busby used Office of National Statistics figures to study the mortality rate of four cancers in 150 wards near Hinkley Point. In April 2000 (Dr Chris Busby, Green Audit. Cancer Mortality and Proximity to Hinkley Point Nuclear Power Station in Somerset , 1995-1998. www.llrc.org ) he found that breast cancer mortality was almost double the national average in Burnham-on-Sea, just five miles downwind from Hinkley, but also adjacent to fifty hectares of mud-flats. Dr Busby's hypothesis was that discharged radioactive particles would settle on the sea-bed, which when exposed at low tide would yield the particles through the action of the wind. People living near the beaches would then inhale the deadly atoms.

A follow-up doorstep survey) by Burnham group, Parents Concerned About Hinkley, asked residents in North Burnham about their health patterns. Out of the one third of the population surveyed, breast cancer again featured prominently with a three-fold excess and leukaemia double the national average. (Dr Chris Busby, Green Audit. Occasional Paper 2002/5 Cancer in Burnham on Sea North: Results of the PCAH Questionnaire. www.llrc.org

Continuous pressure on the local Primary Care Trust (PCT) brought about a study undertaken by South West Cancer Intelligence Service (SWCIS) who also found a dominance of breast cancer registrations in the town, a third up on the national average and a quarter up over four adjoining wards along the contaminated coast. Additionally a doubling of expected leukaemia cases was found. (Dr Julia Verne, South West Cancer Intelligence Service. Cancer Incidence in Burnham North & South, Highbridge and Berrow 1990-1999.)

Many reasons were found by SWCIS and the PCT for the cluster excluding the most likely, the proximity of Hinkley and its radioactive sea and air-borne discharges. Predictions by the International Commission on Radiation Protection suggested the dose exposure was too low. We and others have challenged the reigning authority on the health risk from low doses of radiation (www.llrc.org).

The Committee on Medical Aspects on Radiation in the Environment (COMARE) also commented on the phenomenon but got mixed up in its understanding of the doorstep survey, coming to the wrong conclusions, which it partially withdrew (COMARE Statement on Green Audit Occasional Paper 2002/5 Cancer in Burnham on Sea North: Results of the PCAH Questionnaire). However it maintained the study was faulty.

In 2005 COMARE published research (COMARE 10th report: The incidence of childhood cancer around nuclear installations in Great Britain. www.comare.org.uk) into childhood cancer and leukaemia incidence near nuclear installations. Although it found excesses near the weapons plants of Harwell, Aldermaston and Burghfield, together with the military dockyard at Rosyth, and nuclear plants at Dounray and Sellafield, it exonerated nuclear power stations. Closer study of the research showed that a wide 'net' had been thrown by COMARE, which studied health impacts to a range of 25 kilometres (15.5 miles) from power stations. This inclusion of sometimes quite large populations unlikely to be contaminated by the discharges as they were inland and outside a reasonable distance, meant that COMARE had whitewashed the cancer figures in more modest populations nearer the reactors and, more importantly, the washed up discharges.

In the meantime another Government committee, the Committee Examining Risks from Internal Emitters (CERRIE) in 2004 (CERRIE Final report. www.cerrie.org/reports) said that there were wide uncertainties in cancer risks from radioactive discharges up to a factor of ten-fold. A minority report by Dr Busby was voted down after Whitehall lawyers at the last moment said individual committee members could be sued if it were published by the committee. The report said the uncertainties were 300 fold or more. The former Environment Minister Michael Meacher, who set up this committee with an ethos to publish internal differences of scientific opinion, railed against this intrusion (Dr Chris Busby, Green Audit. CERRIE Minority Report 2004. Sosiumi Press).

In late 2005 the French radioprotection agency, IRSN (Institut de Radioprotection et de Surete Nucleaire (IRSN). Health consequences of chronic contaminations by radionuclides. DHRP 2005), supported Dr Busby's conclusions that certain isotopes were potentially many times more damaging than previously thought and might also trigger non-cancerous illnesses.

Chernobyl

Since the Chernobyl disaster, there has been much discussion about the health impact of those contaminated. Reports, which seem to play down the cancer, non-cancer and genetic effects have been criticised in the press and in literature (Dr Chris Busby, Green Audit, Dr Yablokov, Russian Academy of Sciences. " Chernobyl : 20 years on, Health Effects of the Chernobyl Accident, ECRR 2006"). Suspicion is added to by events such as the imprisonment of Dr Uri Bandaghevski in Belarus after he found that children had died of and were suffering from heart disease linked to their absorption of radioactive caesium.

My family's personal experience of living in Belarus post-Chernobyl is of a health-stricken nation with many examples of thyroid growths (in my sister-in-law's office all the staff have thyroid pathology) and other health detriments. In 2002 a Minsk maternity ward admitted ten women almost simultaneously with full-term stillbirths. This otherwise rare condition is widely considered to be linked to low level radiation. Those who can, use Geiger counters to measure their family's food for radiation and try to avoid food from the more contaminated Gomel region near the Ukraine border. Our own four year-old daughter in 2001 tested positively for caesium and strontium in her blood when she was investigated for suspected leukaemia. Although Eileen is British-born we suspect she carried these radioactive isotopes from my wife during pregnancy.

We conclude that radioactive discharges from nuclear plants are linked to local cancers and possibly other non-cancerous illnesses. Building a new generation of reactors will add to the health burden and consequent personal misery carried by local populations.

Nuclear Safety

In two of Stop Hinkley's public meetings during the 2006 Energy Review ( Nuclear energy? No need ! public meeting, Taunton Library 29th March 2006 . Future Energy - What will You Pay For? public meeting, Trinity Hall, Bridgwater, 3rd April 2006) Hugh Richards, a campaigner from Wales Anti-Nuclear Alliance (WANA) explained how the nuclear industry is reducing safety measures in its reactors in order to save building costs and make reactors more saleable. He gave the example of the Westinghouse AP1000 reactor. This plant, favoured by the UK nuclear industry has never been built. It evolved from the smaller AP600 model, which also has not been built. The larger capacity reactor is designed to be housed in the earlier small plant.

About 75 percent of the safety systems considered essential to the last Westinghouse built in the UK , Sizewell 'B', have been omitted from the design. The cables, pipes, valves and extra concrete which the UK regulators insisted on in the 1970s and 1980's have been replaced with a spray system inside the reactor followed by a dousing system in the form of a large tank of water perched on top of the pressure vessel which are meant to cool down an overheating reactor. The system ridiculously identifies the reactor as the 'Advance Passive' or AP type.

As the large volume of steam generated by dousing the overheating pressure vessel must be allowed to escape, there is no secondary containment in the design. All previous modern reactors have the dome-shaped feature, which contains fission products and gasses should they leak from the reactor in an accident. This is a very serious public health issue.

We are not at all convinced that an industry bent on resurrecting its long dormant sales by taking such drastic shortcuts should be allowed to build a series of ten such untried plants.

We note with interest that state-owned Electricite de France (EDF) (Channel 4 News 12th April 2006) are prepared to invest millions in order to build, with no UK subsidy, their own version of the Pressurised Water Reactor in the UK. They can see a 'killing' can be made by constructing in a country which seems bent on building not one but reportedly ten reactors at once. It is also interesting that EDF are building the first of their new models in far-away Finland , not on their own soil. Finland unfortunately pushed through the plans, hardly touched by any kind of rigorous licensing and planning process. An EU ruling in September seemed odd in that a £400,000 advance from the French Government was not considered illegal in terms of competition law and has been challenged by European renewable energy producers.

Current practice

We are alarmed at current nuclear operations at our local reactors in the West Country. Oldbury nuclear power station near Bristol is operating with one of its twin reactors in a severely corroded condition, whilst the other is closed, awaiting reports and sampling tests but is even more corroded. Both have the graphite reactor core bricks depleted to the extent of 35 per cent (Correspondence between BNFL and NII produced as FOI request). A report by Manchester University ( Manchester University . Analysis of Reactor Graphite Strength, Dec 2002) commissioned by the Nuclear Installations Inspectorate, said that at this level of corrosion, the bricks maintain only fifteen per cent of their original strength. The risks of localised overheating and a fuel fire were acknowledged by the NII in two TV documentaries on Oldbury in September 2005 (BBC, The West This Week, 5th September 2005 ; ITV, West Eye View, 6th September 2005).

Hinkley Point 'B' is similarly afflicted but despite being the later generation Advance Gas Cooled Reactor (AGR) type, has developed 'three or four cracks' in the crucial reactor core bricks, according to the Station Director when pushed on the question in a Site Stakeholder Group meeting (Mr Les Francis, Station Director, Hinkley Point Site Stakeholder Group Meeting, October 2005). Although the cracks had been known about since 2003, there had been no release of information to the public or even the Local Community Liaison Committee which preceded the Stakeholder Group.

The secrecy inherent in the industry from its former military links holds a tight grip on its current proceedings. It is still very difficult to obtain information relating to the safety of local populations, while the industry runs the reactors on the tightest of safety margins more expected in Soviet Russia or the Third World . A current request on Hinkley's reactor cracks by our group under the Freedom of Information Act has been deferred by the Nuclear Installations Inspectorate as releasing the information may constitute a problem on health and safety or commercial sensitivity grounds (Email from NII to Stop Hinkley, 12th April 2006). Astonishingly we were told we will not receive information on the width, length or location of the acknowledged cracks for security reasons (Telephone call to NII inspector 29th March 2006). It is difficult to imagine how a terrorist could benefit from such precise details but they are crucial to us in our understanding of the safety risks involved in the ongoing operation of this reactor.

General

If the nuclear industry believes that the risk of catastrophic accidents is acceptably low, then it should be prepared to take out the full cost of insuring against such accidents, without the limitations on liability that currently apply. The Government should ensure that full insurance against accidents without any limitations on liability is a requirement for every nuclear plant and all associated operations.

If the risk of a catastrophic nuclear accident is indeed as low as is suggested in para 74, then it hard to explain why there was a core meltdown at the EBR fast breeder reactor in the USA in 1955, a partial core meltdown at the Fermi fast breeder reactor in the USA in 1966, a partial meltdown at Three Mile Island in the USA in 1979, a catastrophic explosion and release of large amounts of radioactive materials at Chernobyl in 1986, a near meltdown at the Greifswald nuclear power plant in Germany in 1989, and a near meltdown at Sweden's Forsmark nuclear power station in late July, 2006.

Human error is unavoidable and all current safety systems rely on humans.

It is highly misleading to say that "The UK has not had an incident at a civil nuclear power station where there has been an offsite release of radioactive material". Radioactive releases are a permanent feature of the plants needed to run the nuclear industry. Several such releases are listed under the first bullet point in http://www.mng.org.uk/gh/no_nukes.htm .

Radioactive contamination of the environment has been shown to correlate with increased rates of childhood leukaemia and other kinds of cancer (see above and answers to Question 11).

In February 2005, British Nuclear Fuels Ltd reported 30kg of plutonium as 'unaccounted for' during the last financial year in its annual audit of nuclear materials. We have no means of knowing whether this was merely an 'accounting error' as suggested by BNFL or a genuine loss of nuclear material. Either way, it is clear that slack controls provide ample scope for highly-dangerous radioactive materials to find their way -- via bribery, theft or hijacking -- into the hands of terrorists or unfriendly foreign governments.

The technology for nuclear power has much in common with the technology needed for the production of nuclear weapons. The "Janus-like character of nuclear energy " (Kofi Annan) adds to the problem of reducing the number of nuclear weapons in the world or preventing their proliferation. If we are trying to persuade countries like Iran to give up nuclear power, we are in a very weak negotiating position if we have nuclear power (and nuclear weapons) ourselves.


7. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE TRANSPORT OF NUCLEAR MATERIALS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

A report by Dr John Large for Greenpeace in 2002 showed that the scenario of a terrorist attack on a nuclear train loaded with nuclear spent fuel could disperse fissile material well beyond the two kilometre zone allowed for in the REPPIR arrangements. Even with 'extendibility' the plume could disperse radioactivity beyond the allowed for ten kilometre range to 100 kilometres and require 600,000 people to seek shelter and up to 30,000 to need evacuation. (http://www.largeassociates.com/reppir.pdf)

Terrorists can easily create a 'dirty bomb', dispersing large amounts of radioactive materials over a large area, by exploding a conventional bomb close to a body of nuclear fuel or high-level radioactive waste. Since these materials are carried on railway trucks throughout the UK , it is not possible to provide all-time protection against that kind of terrorist attack. As a bare minimum, it would mean placing an armed guard on every nuclear transport and somehow ensuring that no bombs could be planted anywhere on or near the tracks where those transports run. Given that terrorists only need to succeed once but the authorities have to succeed all the time, it is surprising that terrorists have not already taken advantage of this large and unpluggable hole in security.

The inadequacy of current systems was demonstrated very clearly when, in July 2006, a reporter from the Daily Mirror managed, very easily, to plant a fake bomb on a flask of nuclear waste in a railway siding (see http://www.mng.org.uk/gh/renewable_energy/daily_mirror_nukes1.htm ).

 

 

8. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON WASTE AND DECOMMISSIONING ? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

The nuclear industry has suggested that the amount of nuclear waste produced by a generation of new build would amount to only ten per cent of the existing and future legacy waste. However this is misleading. CoRWM has said that this refers to the proportion of all existing waste which mostly comprises bulky Low Level Waste (LLW). In terms of High Level Waste or Spent Fuel, new build would produce three times the existing amount in volume and five times the amount in radioactivity (Bilateral meeting after CoRWM Round Table meeting, Bristol , January 10th 2006 ).

Before CoRWM reported on the nuclear waste issue, its Chair, Gordon McKerron has said ( Bristol Jan 2006) that there is no solution to the waste problem only different forms of management. This crucial disclosure was already obvious to many.

A former CoRWM member, Pete Wilkinson has slammed the Government rush to bury nuclear waste in a Guardian article, 12 th September 2007 : " A year after the CoRWM report, the government is still ignoring the advice from its own committee. It has eagerly accepted what it sees as the solution of deep geological disposal, but it has done little to address the vital prerequisites CoRWM called for: an intensified research programme to address uncertainties about storage and disposal, and a security-led review of storage."

No country has 'capped off' on its buried nuclear waste due to fears of packaging corroding. No country seems sufficiently confident to give an early date for capping off. So we are left with, in reality, a long-term storage scenario. The Government seems keen to have a 'solution' available to it, which would ease the way forward for new build but this seems technically impossible. Moreover, building more reactors undeservedly saddles future generations with escalating amounts of highly dangerous waste. If the waste is stored, they must manage the waste, observing for leaking packages and repacking the waste safely. This is a highly onerous task for generations who may not have proceeded down the nuclear route. If the waste is buried in Deep Repositories, it will inevitably leak into the environment, spilling fissile material into aquifers, which will surface somewhere, sometime. Again this delayed time-bomb is too much to ask our unborn children to bear.

At the Yucca Mountain Repository in the USA , a court has pronounced the waste must be protected for one million years. Recently a surprise discovery of a fault line underneath the proposed Spent Fuel Storage area has been discovered, forcing a rethink on the project.

Spent Fuel

The nuclear industry has been suggesting that the highly radioactive spent fuel from its new reactors would be housed locally on site for the predicted sixty year lifetime of the reactors. This is a departure from the current practice of sending the fuel rods to Sellafield for reprocessing, with the exception of Sizewell 'B's spent fuel. The planned local storage of this fuel is most unwelcome by our group and is bound to be a cause for concern amongst local communities. The reactor sites are already perceived as potential terrorist targets, with particular exposed areas especially vulnerable. Adding to this vulnerability by creating a deadly toxic store would be the height of irresponsibility.

•  Some radioactive waste will remain dangerous for one million years or more (plutonium has a half-life of 250,000 years) No human institution has ever survived that long. It is impossible to guarantee safe management of this material for that length of time.

•  Radioactive waste is one of the 'hidden' costs of nuclear power: it is a subsidy paid by future generations to us now, with no offsetting benefit for those people who are yet to be born (see also the answer to Question 10).

•  In Chapter 5 of "Nuclear power is not the answer", Helen Caldicott describes in some detail the totally inadequate nature of proposals to store nuclear waste in Yucca Mountain in the USA . Problems of corrosion, leakage, ingress of groundwater, and the long-term instability of all geological formations are the same throughout the world, including the UK .

 

 

9. WHAT ARE THE IMPLICATIONS FOR THE MANAGEMENT OF EXISTING NUCLEAR WASTE OF TAKING A DECISION TO ALLOW ENERGY COMPANIES TO BUILD NEW NUCLEAR POWER STATIONS?

The Chair of the CoRWM committee (Bristol 2006) said that this equation had not been calculated or forecast by the committee and, although they took no particular view on new build, this would add to the inventory of waste requiring long-term management with ethical questions involved.

Since there is no satisfactory solution to the problem of storing existing nuclear waste for thousands of years, it is quite unacceptable to add to that problem (see answers to Question 10).


 

10. WHAT DO YOU THINK ARE THE ETHICAL CONSIDERATIONS RELATED TO A DECISION TO ALLOW NEW NUCLEAR POWER STATIONS TO BE BUILT? AND HOW SHOULD THESE BE BALANCED AGAINST THE NEED TO ADDRESS CLIMATE CHANGE?

There is no way of storing high-level nuclear waste safely for thousands of years and it is totally immoral to bequeath this legacy to hundreds of generations into the future.

The preamble to Questions 8, 9 and 10 suggests that the fight against climate change may provide a justification for creating more nuclear waste. This line of reasoning is entirely false because there is abundant evidence that we can make the necessary deep cuts in CO2 emissions without using nuclear power (see answer to Question 1).

Likewise, the argument that nuclear power would provide a relatively inexpensive way to cut CO2 emissions is spurious. When all the hidden costs are added in, nuclear power is one of the most expensive sources of electricity (see answer to Question 1).

 

 

11. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON ENVIRONMENTAL ISSUES? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

With regard to para 103 of the preamble, it is highly misleading to make a comparison between the amount of land needed for a nuclear power station and amount of land needed for a wind farm with similar capacity. Only a small fraction of the land occupied by a wind farm is actually needed for the wind turbines and most of the land can continue in use for grazing or other kinds of agriculture. The tracks needed for access to wind turbines are frequently the same as the tracks needed by farmers to move farm machinery around their land. In any case, many wind farms are being and will be built out at sea.

In the preamble to this question, there is no mention of the persistent leakage into the environment of radioactive materials from nuclear installations. Sellafield discharges two million gallons of radioactive water into the Irish Sea every day at high tide. This includes a cocktail of over 30 alpha, beta and gamma radionuclides. BNFL admits that radioactive discharges in the 1970's were 100 times those of today. As a result of these discharges, which include around half a tonne of plutonium, the Irish Sea has become the most radioactively contaminated sea in the world. Caesium-137 and Iodine-129 from Sellafield have spread through the Arctic Ocean into the waters of northern Canada and are having a bigger impact on the Arctic than the Chernobyl accident. Sellafield's gas discharges of Krypton can be measured in Miami .

There is evidence that in areas affected by radioactive contamination from the nuclear industry there have been statistically significant increases in the incidence of childhood leukaemia and other kinds of cancer (see www.llrc.org and http://www.llrc.org/health/subtopic/menai.htm ).

This kind of contamination of the environment with radioactive materials is totally unacceptable. Given the nuclear industry's record of mismanagement and accidents (see answers to Question 6), there is no guarantee that there will not be similar releases of radioactive materials into the environment in the future.

 

 

12. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SUPPLY OF NUCLEAR FUEL? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

It has been calculated that, if enough nuclear fission reactors were built to meet most of the world's demand for electricity, exploitable sources of uranium would be exhausted in about fifteen to twenty years (see Energy Beyond Oil by Paul Mobbs, Matador, 2005, ISBN 1-905237-00-6). If countries like India and China start using nuclear power on a large scale -- and there are good indications that this will happen -- it likely that the UK would experience increasing difficulties in obtaining the nuclear fuel needed for any new nuclear power stations that may be built.

Nuclear power may consume more energy than it produces. "Even utilizing the richest ores available, a nuclear power plant must operate at ten full-load operating years before it has paid off its energy debts. And ... there is only a finite supply of supply of uranium ore containing reasonable concentrations of uranium 235. When this concentration falls below 0.01%, the costs of energy production from nuclear power can no longer cover the costs of extraction of uranium from the earth, at which time the nuclear fuel cycle will produce no net energy; below a certain uranium content, nuclear power produces less energy than is needed to build, fuel, and operate the reactor and to repair the environmental damage ." (Helen Caldicott, p. 16).

Unless or until the energy inputs required for all parts of the nuclear cycle are provided without the use of fossil fuels, increases in those inputs will mean increases in CO2 emissions.

 

 

13. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SUPPLY CHAIN AND SKILLS CAPACITY? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree.

Ever since the Chernobyl disaster there have been very few nuclear power stations built. Most of the people with the necessary knowledge to build and run new nuclear power stations are near to retirement or already retired -- and there have been few younger people entering the industry. It would be folly to try to build and run new nuclear power stations without the necessary reservoir of skills .

 

 

14. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON REPROCESSING? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

With regard to the quote from the preamble to this question: "Reprocessing will not be needed therefore risks from transporting spent fuel are reduced": The Oxford Group of academics said that due to the increased planned building of nuclear plants worldwide, there will be reduced availability of uranium fuel. Reprocessing may need to occur to supply reactors with fuel, increasing transportation and risk of materials reaching terrorists. Besides, storing 'hot' spent fuel at reactor sites would create a greater security risk to local populations.

We don't need any of this dirty, dangerous and expensive technology - and that includes reprocessing.

 

 

15. ARE THERE ANY OTHER ISSUES OR INFORMATION THAT YOU BELIEVE NEED TO BE CONSIDERED BEFORE TAKING A DECISION ON GIVING ENERGY COMPANIES THE OPTION OF INVESTING IN NUCLEAR POWER STATIONS? AND WHY?

A major plank in the argument for building new nuclear power stations in the UK is that, notwithstanding the evidence presented in the answer to Question 2, nuclear power is thought to provide a route towards the deep cuts in CO2 emissions that are needed to fight climate change. Before any decision is made to permit the building of new nuclear power stations, we need to consider whether there may be better ways of achieving those deep cuts in CO2 emissions whilst maintaining supplies of electricity.

As indicated in the answer to Question 1 and elsewhere, there is abundant evidence from several different reports that we can meet all our needs for electricity from low carbon sources without using nuclear power. But if we are to catch up with the achievements of Germany and other countries that are ahead of us in bringing renewable sources on stream, we need to be prepared to adopt key instruments such as Feed-In Tariffs that have been used with great success elsewhere.

In addition:

The Government should introduce a vigorous programme of zero-carbon eco-renovation of existing buildings to bring down emissions of CO2 from space heating and water heating (see http://www.mng.org.uk/gh/renewable_energy/ecorenovation.htm ). This is really 'low-hanging fruit' in the bid to cut CO2 emissions but, so far, very little of this potential has been tapped. In principle, it is possible to upgrade most buildings to a standard that is comparable with that of a German "passive house". With high levels of insulation (much higher than the levels of insulation that are normally used in the UK ) and with other measures, it is possible to make very large reductions in the fuels required for heating.

Since gas is the dominant fuel for space heating and water heating, a programme of zero-carbon eco-renovation should achieve substantial reductions in demand for gas. In addition, since some space heating and water heating is still done using electricity, there should also be reductions in the demand for electricity.

Some of the gas that is saved by this programme of zero-carbon eco-renovation may be used to generate backup supplies of electricity in case there is a shortfall from other sources. These backup supplies of electricity should put at rest any worries about possible shortages. It is likely that only a small proportion of the gas saved by the upgrading of buildings would be needed for the generation of electricity and there would still be substantial overall savings in gas consumption.

This two-pronged strategy -- a substantial speed-up in the introduction of renewable source of electricity coupled with a vigorous programme of zero-carbon eco-renovation of buildings -- will enable the UK to make deep cuts in CO2 emissions and provide robust and sufficient supplies of electricity at the same time. It would also enable us to avoid all the many headaches of nuclear power.

 

 

16. IN THE CONTEXT OF TACKLING CLIMATE CHANGE AND ENSURING ENERGY SECURITY, DO YOU AGREE OR DISAGREE THAT IT WOULD BE IN THE PUBLIC INTEREST TO GIVE ENERGY COMPANIES THE OPTION OF INVESTING IN NEW NUCLEAR POWER STATIONS?

For all the reasons given in answers to previous questions, we strongly disagree. Here are some other reasons:

Rising sea levels:

All of the UK 's existing nuclear power stations are on the coast and it appears that the nuclear industry favours building new nuclear power stations on the same sites. Thus any significant rise in sea level could have disastrous consequences both for existing power stations (even after they have ceased producing electricity but are still 'hot') and any new ones that may be built nearby. Significant rises in sea level may seem unlikely but, in a recent article ("Huge sea level rises are coming - unless we act now", New Scientist, issue 2614, 25 July 2007), James Hansen, Head of NASA's Goddard Institute for Space Studies in New York, argues there could be a "runaway collapse" of the Antarctic and Greenland ice sheets leading to rises in sea level that are much bigger than current IPCC predictions. Since climate scientists have already been surprised by the speed with which floating ice shelves in the Antarctic have broken up, it would be unwise to assume that there could not be similar surprises in the speed with which land-based bodies of ice disintegrate.

"Nuclear power stations on the British coast will experience storm surges up to 1.7 metres (5½ft) higher by 2080 because of global warming, a study suggests. The research, commissioned by British Energy, the nuclear plant operator, suggests that new coastal defence strategies may be needed to protect sites from a combination of more extreme weather and higher sea levels. All of Britain 's 15 nuclear plants are near the coast, and the prospect of rising sea levels has raised questions about whether the sites will be suitable if a new generation of reactors is built." (Mark Henderson, The Times, 2007-01-24).

Nuclear power stations built inland would not necessarily fare any better. In recent heat waves, nuclear power plants e.g. in France have been shut down owing to shortages of cooling water and unacceptable damage that would be caused by the discharge of hot water into the environment (see http://www.iht.com/articles/2007/05/20/africa/nuke.php and http://www.huffingtonpost.com/joel-makower/our-nuclear-summer_b_27112.html ). This kind of problem is likely to become worse as global temperatures rise.

 

 

17. ARE THERE OTHER CONDITIONS THAT YOU BELIEVE SHOULD BE PUT IN PLACE BEFORE GIVING ENERGY COMPANIES THE OPTION OF INVESTING IN NEW NUCLEAR POWER STATIONS? (FOR EXAMPLE, RESTRICTING BUILD TO THE VICINITY OF EXISTING SITES, OR RESTRICTING BUILD TO APPROXIMATELY REPLACING THE EXISTING CAPACITY)

No, there should be an outright ban on any new nuclear power stations and an orderly closure programme for existing reactors.

 

 

18. DO YOU THINK THESE ARE THE RIGHT FACILITATIVE ACTIONS TO REDUCE THE REGULATORY AND PLANNING RISKS ASSOCIATED WITH SUCH INVESTMENTS? ARE THERE ANY OTHER MEASURES THAT YOU THINK THE GOVERNMENT SHOULD CONSIDER?

We don't need any facilitative actions or other measures to smooth the path for nuclear power. The Government should be facilitating the development of the many good alternatives.

 

Jim Duffy, Stop Hinkley Coordinator, 1st October 2007

 

Acknowledgements for borrowed material to: From Greenhouse to Green House; No2Nuclear

 

 

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