Memorandum submitted by Ian Critchley
GENERAL VIEWS
1. The nuclear industry is presently in
the process of being dismantled, and whilst it will be some time
before the more recently constructed plants become due for decommissioning,
it is only a matter of time before its contribution to the net
national demand for electricity becomes marginal.
The industry is not attractive to young people
and recruiting quality staff has almost become impossible, as
young people see no future in nuclear power. Nuclear dismantling
is a new business, and it is very different from nuclear power
plant operation.
The only way that operational capability can
be retained is to attract young people who see nuclear plant operation
as a potential career, and this can only happen if there is a
commitment to retaining nuclear power for the long term. If this
does not happen, a return to nuclear in the future will be very
much more difficult simply as there will not be the right mix
of skills of knowledge to support an industry on any meaningful
scale.
The industry has done itself no favours over
the last generation. The public remains suspicious and ignorant
due to the misleading "facts" peddled by self-appointed
nuclear "experts" and the so-called green lobby who
also have to resort to lying and distorting the truth to make
their case against nuclear power.
The culture within the industry has however
changed markedly over the last 10 years, and safety has become
paramount alongside conservative decision making over production
and environmental protection. Whilst there is some way to go before
British plants are operated on a level with the world's best in
terms of operational excellence, the movement is in the right
direction and continues.
If we were able to go back to the early days
of the industry knowing what is known now with the values that
we now have, nuclear power would be perceived very differently
and we could have a very safe means of generating electricity
with almost no discharges to the environment, relatively small
quantities of waste and a safety record that would be the envy
of every other industry. The industry didn't live up to its promises
for a variety of reasons that we are now able to learn from.
There is an opportunity to create a new nuclear
industry that benefits from the learning of the last 50 years
and could become such an ideal, but only if the opportunity is
taken before the window closes and capability is lost forever.
The knowledge needed to make the ideal a reality resides in the
experience of people who in a few years will be gone without being
replaced.
This would point to making a commitment to
nuclear power generation now so that a career in nuclear returns
to the minds of our next generation of engineers and scientists.
The alternative is to lose the capability.
2. The reality of this of course is that
it will be an expensive investment over the lifetime of several
governments that the country cannot back out of once it has started.
The political will and courage to make such a long-sighted investment
will always be a challenge for politicians.
A nuclear industry can never be completely detached
from government control for a number of good reasons—financial,
waste disposal and security to mention but a few of the most obvious.
Private industry and competition can do a lot to make the industry
financially self-sustaining, but it cannot be allowed to become
a monster that is controlled by profit. Government control must
therefore be retained, but there is already a model in existence
in the Nuclear Decommissioning Authority that could easily be
extended.
This would point to committing to nuclear
power generation that remains under government control with a
similar model to the NDA.
3. The alternatives to nuclear power for
large-scale generation without CO2 emissions do not
provide the means to avoid nuclear power. Wind, tidal and solar
power all have their own technical and reliability problems, but
the main one is simply one of scale. They do of course have their
place in a healthy diversity of generation options. The New Electricity
Trading Arrangements (NETA) do not provide for a sensible electricity
supply strategy, as it does not recognise the obvious difference
between base load and non-base load. They favour plants that can
be switched on and off with no notice, which is simply not how
nuclear plants can be operated.
This points to the need for a healthy diversity
in a national electricity generating strategy that recognises
the unique aspects of nuclear power plants. Such a strategy must
treat base load differently from non-base load in trading arrangements,
and accept that safe and reliable nuclear generation comes at
a cost in return for the benefits of pollution avoidance and security
of supply.
4. Nuclear waste management requires a pragmatic
single national approach instead of the dithering that besets
it at present. There are not many options, it is high time one
was chosen. Deferring a decision on a national repository for
our grandchildren to see through is nonsense. Reprocessing spent
fuel should remain an option only if there is a very clear benefit
in sustaining future fuel supplies, which at present it does not.
Reprocessing has hitherto created additional waste and cost for
no benefit. This however does not preclude the option of long-term
safe storage of spent fuel that retains the option to retrieve
it in the future for reuse should future generations wish to do
so, but requires that appropriate storage is invested in and its
ongoing costs accepted.
Other solid waste should be minimised through
design and good practice, and as far as possible should by recycled
within the industry. This needs to be the subject of a unified
industry that is geared up to recycle its own waste. Where solid
waste has to be disposed of, a consistent industry-wide approach
should provide for it. This essentially means either a single
nuclear waste storage facility, or local on-site facilities at
each location. In either case, the waste should be conditioned
and made ready for permanent passive disposal prior to storage.
As with spent fuel, the waste should be retrievable in case it
becomes necessary to maintain its passive storage condition.
This points to the need to set a new industry
up with a collective solid waste management strategy and disposal
regime that opts for immediate final disposal with retrievability.
Spent fuel should be retrievable to retain the option to reuse
it in the future.
CONSULTATION PAPER
QUESTIONS:
A. Generation gap
1. I defer to the knowledge of others who
have studied the subject for the assessed size of the gap. It
is important to note however that there is a gap, and to some
extent its size is of little relevance in deciding whether or
not commit to new nuclear build. There is a risk that the existing
plants will have to be taken out of service sooner that planned
for technical reasons to do with graphite erosion that cannot
be repaired. This will have the effect of creating the gap sooner
in a climate of increasing electricity demand and a growing requirement
for supply reliability to support a computerised society.
B. Financial costs and investment
2. I refer to my comments above. The country
needs a secure base load generating capability that comes with
reliability and minimal environmental impact, over which government
should retain strategic control. This is worth paying a premium
for, and should be topped off with a range of responsive plant
operated by private industry that includes a significant proportion
of renewables operating in a competitive environment.
Government should own the provision of base
load, and private industry should be free to supply non-base load.
This puts the relatively small (compared with nuclear investment)
investment decisions and risks associated with renewables with
the private sector.
The costs of new nuclear build and operation
if allowed to stand alone from the existing industry should be
reasonably accurate. Past experience shows us that the cost of
waste management and decommissioning is very difficult to assess,
as are the unforeseen costs that arise from uncertainties. New
plants are designed for decommissioning and the technical aspects
of their disposal are more predictable. The legacy we have at
present is the product of a different era and no planning for
plant lifecycles. Decommissioning of any new facilities should
be addressed in a national radioactive waste strategy that must
come with a new-build programme. This would bring far more predictability
into the costs of new build over its lifecycle.
Hidden costs are invariably associated with
waste management, which again if planned in as part of the investment
should be reasonably predictable. The cost of security is higher
than at any time in the past but is not a significant factor as
plants can be designed for security, and a security force is necessary
for any industrial site.
Other hidden costs have historically arisen
from regulatory demand for safety enhancements that increase an
already generous safety margin and come at grossly disproportionate
cost for the negligible or no benefit delivered. The industry
and regulators understand this better now and work together more
effectively to avoid such instances.
I do not believe that renewables can deliver
reliable large-scale generation. Common sense tells us that such
units are subject to the unpredictability of the weather, climate
change and extreme operating conditions, which render their operating
capability a hostage to fortune. The units cannot be built on
a large scale other than number with the obvious visual impact
that nobody enjoys. The maintenance burden and poor load factor
simply makes renewables a non-runner for a reliable supply.
Micro-generation should be encouraged on the
obvious basis that every little helps. Where energy can be recovered
without excessive cost, it should be encouraged as this puts the
cost with the immediate user with minimal additional environmental
impact in terms of fuel and waste. Solar water heating should
also be considered as a contributor as it avoids electricity and
other fossil fuel usage, and collectively would reduce electricity
consumption by a significant amount if householders and business
users could afford to install it.
Micro-generation at isolated locations should
be supported as self-sufficiency avoids the need to provide grid
and mains connections at disproportionate cost, with minimal environmental
and visual impact. Apart from solar panels and heat recovery systems,
micro-generation in communities does not make economic or environmental
sense where installations are obtrusive. Eg Encouraging 100 householders
in a village each to erect a windmill is not sensible whereas
encouraging a farmer on a remote hillside to erect a windmill
would be.
3. Financial institutions simply do not
have the knowledge to make investment decisions on nuclear build
as there are to many uncertainties at present. Any financial institution
that takes risk in nuclear investment in the present climate cannot
really understand what it is taking on. The recent fortunes of
British Energy amply show this, and the government had to come
to the rescue twice.
Whilst the provision of funding from private
investors with the promise of reward should be sought, new nuclear
build must remain the responsibility of the government and that
is where the risk has to be taken. Most of the risk is driven
by government through the waste strategy and regulation, and it
is therefore within its own gift to manage such risk whereas the
private sector cannot.
Investment in other technologies is always going
to be more attractive simply because such as CCGT is well understood
and very simple to predict in terms of cost and risk. Without
the incentive to do otherwise, profit will force investment into
the easiest options without regard for what is best for the country.
C. Strategic benefits
4. The main public good would be in the
provision of a secure and reliable supply of electricity with
minimal carbon emissions. If it were implemented properly, electricity
would also be produced at a reasonable cost. Consideration of
the benefits should also be weighed against the alternatives of
not providing such an electricity supply and the costs incurred
by unreliable supplies and ongoing avoidable air pollution. The
short answer is that there is no real choice—it has to be
provided.
The investment involved in creating a "new"
nuclear industry would be considerable and would probably take
more than a generation to pay for itself. It would however be
there in perpetuity.
The affordability of this would largely be down
to the level of investment that could be attracted and how quickly
the plants could be in a position to start earning. A commitment
to a "new industry" rather than bolting on new build
to the back of the existing industry with its historic problems
and uncertainties would make investment far more attractive, particularly
if the government was to guarantee some reward without investors
having to take a huge step of faith on risk from waste strategy
and ever-changing regulatory impacts.
Carbon emission reduction would be significantly
enhanced if nuclear plants were provided with the intention of
underpinning base load, simply as they would displace carbon-generating
base load plants. Whether these plants would be taken out of service
before the end of their lives would be down to their ongoing profitability
where they have to compete in a smaller (non-base load) market.
Nuclear facilities do not pose a threat from
terrorism. They are difficult targets, they are guarded and their
construction does not lend themselves to being damaged easily.
New nuclear build would be at far less risk than the old facilities
which are much more vulnerable, particularly at Sellafield. If
a terrorist organisation wanted to further its cause through a
serious nuclear incident it would need to resort to a large missile
attack or possibly an attack with a very large aircraft packed
with explosives, and the certainty of success would be higher
at other targets than new power stations.
There seems to be little to suggest that terrorist
groups would choose to target a nuclear site mainly as the resources
needed to have any real effect are difficult to obtain, the sites
are in remote locations and contaminating a country that has a
cross-section of people from their own belief system is rather
self defeating. Terrorists go for the outrage factor of causing
mayhem and suffering on easy targets, and they do not appear to
be capable of mounting a numerically large-scale attack. An outrage
on that scale would not draw support from within their own cultures.
5. I refer to my views above. Renewables,
micro-generation and energy efficiency need to sit alongside a
new nuclear industry as part of a diverse electricity generation
system, but should be funded by private industry in their own
(non base load) market. The Energy White Paper lacks this vision—new
nuclear build has to be more than building new nuclear power stations,
it has to be the launch of a new industry that is largely separate
from the old one.
D. Other issues
6. In considering carbon freedom, the construction
of a nuclear power station is not vastly different to building
any other power generating plant of the same capacity. The operation
of a nuclear power station is a different matter depending on
the design of the plant. The AP1000 reactors are water cooled
and do not discharge CO2 coolant like the magnox and
AGR reactors in service at present. The amounts of carbon emissions
should be readily available from existing knowledge of the plants.
The mining of uranium is no more or less carbon
generating than the extraction of other fuels, but the energy
yield for the volumes extracted are far beyond the calorific values
of other fuels. I maintain my point that whilst renewable energy
is desirable from a carbon freedom aspect, the practicality of
constructing, maintaining and operating such plant to generate
the equivalent amount of power is unachievable without disproportionate
effects on society and the environment.
7. I have made my position on radioactive
waste in the views expressed above. A waste management strategy
in essential and must be intrinsic to any new build.
11 September 2005
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