Select Committee on Environmental Audit Written Evidence

Memorandum submitted by Paul Payne CEng, CEnv, MIChemE


  1.  The Environmental Audit Committee has invited the submission of views to this inquiry from members of the public. The views expressed herein are my own, and do not represent any organisation to which I am affiliated or employed by.

  2.  Professionally, I am a chemical engineer with Chartered Engineer and Chartered Environmentalist status. I have worked in the chemical and nuclear industries for 26 years, mainly in the areas of effluent and waste management (including back end nuclear fuel cycle). I have made submissions to various regulator, UK government and EU consultations on aspects of energy policy, the nuclear industry and sustainable development.

  3.  My overarching view is that the development and deployment of sustainable renewable energy sources is imperative, but this must replace existing fossil fuel capacity, not (as the Energy White Paper implies) retiring nuclear capacity. Furthermore, increased nuclear capacity is not an option: it is a necessity. Nuclear capacity should be increased in order to meet what should be an increasing demand for electricity from all sectors, and to replace existing fossil fuel capacity at the earliest opportunity.


  4.  In order to adequately address climate change, electricity demand needs to grow as direct use of fossil fuels is significantly reduced in all sectors.

  5.  In addition, the use of fossil fuels for electricity generation needs to be minimised.

  6.  Therefore there is a need for deployment of significant new carbon free generating capacity, which necessitates new nuclear build alongside new renewable build.

  7.  The use of historic cost performance as a yardstick for new nuclear led the Energy White Paper to incorrect conclusions regarding nuclear new build.

  8.  Building a new fleet of nuclear power stations would not pose any serious additional threat from terrorism or proliferation.

  9.  Technical solutions to legacy nuclear waste disposal exist now: new nuclear build should not be delayed whilst the political implementation of these solutions is debated.


  10.  Climate change is affected by all fossil fuel use, not just electricity generation. It is therefore imperative that the transport sector addresses significant reduction in the use of oil based fuels, and not by replacement with gas. Direct use of gas for heating and similar uses also needs to be targeted for significant reduction. In both cases, this will increase the need for electricity generating capacity as petrol and diesel transport systems and gas fired domestic and space heating systems become electrified. In the event that hydrogen fuel cells can be safely implemented to replace petrol and diesel for cars, this will further add to the required generating capacity.

  11.  Future generating capacity projections must be revised to allow for these increased requirements. Financial and regulatory measures should be instigated to encourage and implement significant reduction in fossil fuel usage in all sectors.

  12.  This will have the effect of increasing electricity demand whilst reducing generating capacity. As the only practicable sustainable means of closing the shortfall, new nuclear capacity is required alongside optimised deployment of renewable generating capacity.


  13.  In considering comparative costs of differing technologies, the energy white paper was at best flawed (and at worst, deliberately biased to achieve a preconceived answer) in that the cost of new renewable capacity was taken to be at the lower end of its cost range, whereas nuclear was taken to be at the higher end.

  14.  With the exception of wind turbines, renewables are generally immature, emerging technologies. It is therefore unrealistic at this point in time to assume that they can be delivered at the lowest projected cost. As with all emerging technologies, it is most likely, at least initially, that deployment will come in at the high end of the cost range. Initial deployment would be concurrent with, if not later than, the requirement for nuclear new build.

  15.  Conversely, nuclear is a mature, established technology. Use of the high range cost was justified by past experience. It is unrealistic to base predictions of nuclear new build costs on historic projects. The Magnox and AGR fleets were all built as one off, virtually prototype designs and in an era when project management was a discipline in its infancy and just about every public sector project experienced significant cost and programme overruns. Current advances in project management, financial control and accountability, coupled with mature technology and the benefits of multiple build would ensure greatly improved cost and programme performance in delivering new nuclear build compared to past projects.

  16.  In any event, both renewable and nuclear build are required to fill the shortfall resulting from retiring nuclear and fossil generating capacity coupled with increasing electricity demand.


  17.  The primary strategic benefits of new nuclear build may be summarised as:

Security of supply

  18.  The scenario presented in the Energy White Paper where around 75% of UK energy supply relies on imported gas poses a realistic threat to security of supply. This arises both from potential changes in political alignment or stability of the states possessing the reserves, or through whose territory the pipelines run, and from vulnerability to terrorist action of large, unprotectable soft targets. Interruption or loss of supply would impact on the UK within days at most, and potentially within hours. Since nuclear plant is only refuelled intermittently at long intervals, interruption to uranium supply could take in excess of 12 months to impact on generating capacity, providing ample opportunity to arrange alternative supply or diversified capacity.

Substantial reduction in greenhouse gas generation and other environmental impacts

  19.  Continued mass use of carbon rich fossil fuels for electricity generation, heating and transport will continue to discharge unacceptable and potentially dangerous levels of greenhouse gases into the environment. As well as Kyoto obligations, UK is also bound by the OSPAR convention to seek to avoid future use of such fuels where clean alternatives. Annex 1 presents this argument.

  20.  Fossil fuel extraction processes release toxic substances in to the environment, including heavy metals and fugitive hydrocarbon emissions. Maritime accidents also continue to result in periodic heavy pollution of coasts and their fragile ecosystems.

  21.  For these reasons, it is environmentally unacceptable to implement an energy policy which does not, at its core, seek to significantly reduce the use of fossil fuels.

  22.  Nuclear generating plant discharges virtually nothing directly to the environment during operation and only relatively small quantities of stable, well contained solid waste.

Improved safety due to significant reduction in extraction, transportation and storage of hazardous fossil fuels

  23.  Extraction and processing of fossil fuels into a useable condition is a hazardous business. Globally, major fires and explosions still result in frequent loss of life and significant economic damage. By contrast, 50 years of commercial nuclear generation has only seen one (Chernobyl) serious accident resulting in loss of life and significant release of radioactive material to the environment.

Reliability of baseload generating capacity

  24.  It is widely recognised that the major renewable energy source (wind) is not sufficiently reliable to provide baseload capacity without excessive redundant capacity across the country (with the attendant cost and environmental penalties of providing such). Given the unacceptability of fossil fuel generation, outlined above, and the immaturity of most other renewables, nuclear is the only available option to provide reliable baseload generation. Nuclear reactors consistently operate at high availability and high load factors.

  25.  Additional strategic benefits would also arise from new nuclear build:

    —  medium term employment and economic stability around the selected sites. These are generally in rural areas where the input of well paid technological jobs is of great value to the community;

    —  UK plc would be able to maintain and demonstrate a sound technology base from which to grow the economy;

    —  expansion of the nuclear generating base would enable the UK to re-enter the international arena for research in to fast reactor technology. The addition of fast reactors would dramatically improve the sustainability of the nuclear fuel cycle and convert the existing stockpile of depleted uranium into a valuable commodity.


Legacy wastes

  26.  Many people confuse the issue of legacy wastes, ie those currently in existence and arising from initial development of the nuclear fuel cycle and of weapons, with future new build. These issues are clearly distinct and must be considered separately. It is incumbent on the Government to promote and defend this dissociation to the public and the Media.

  27.  Legacy waste stocks are unique in that most of the activities which generated those wastes happened in the past or will continue to happen only until the remaining Magnox and AGR fleets are closed and decommissioned. Much of the older wastes have arisen or are stored in conditions which would not arise under current practises or with current reactor technology.

  28.  The technology to retrieve and process legacy wastes safely into stable forms, and to dispose of them, exists. What is needed is the political will to select a disposal route and to robustly present that to the public and the Media.

  29.  Whilst it is imperative that a disposal route is decided for legacy wastes, this should not be allowed to impact on the decision for new build. Sizewell B was successfully divorced from the legacy wastes issue; there is no reason why, given the political will, that new build could not also be so divorced.

Future waste from new build

  30.  What is apparent is that nuclear waste arisings from the postulated new build will be significantly lower in volume than from past reactor designs. Advances in fuel performance have dramatically reduced waste arisings. Light water reactors use significantly less raw material to build (and therefore to potentially become contaminated or activated) than gas graphite reactors.

  31.  It is, however, incumbent on the Government and the generating companies to determine a firm fuel and waste disposal strategy to cover realistic lifetime arisings of radioactive waste (spent fuel and other arisings) prior to proceeding to new build. As well as providing political capital and allaying any public concerns, this would enable more accurate financial provision for waste disposal and decommissioning, which then needs to be built into the electricity pricing structure. (The same would also be true for fossil capacity: hitherto, waste disposal has been by free dumping into the environment and with redundant buildings left standing. Continued future use needs to incorporate waste capture and disposal, plus decommissioning costs.)


  32.  Two major concerns cited against new nuclear build are acts of terrorism and proliferation due to the availability of plutonium.

  33.  Of necessity, nuclear plant is physically robust and therefore relatively hardened against terrorist attack. It is, perhaps, a sad fact of life that terrorists target what they can, and use what they can. Experience has shown that there are far easier, more effective, higher profile terrorist targets in the country than nuclear installations. There are also many ways to contaminate large areas and render them at least temporarily uninhabitable, other than the use of nuclear material. The terrorist threat is therefore no more significant with nuclear plant than without it.

  34.  UK has now over 50 years experience of operating a nuclear fuel cycle (almost 50 years commercially) and transportation, processing and storage of plutonium. A significant proportion of that time has seen regular active terrorism across mainland Britain. Whilst there is clearly no room for complacency, it has been demonstrated that the UK has the necessary will and capability to continue to do this without risk of proliferation or loss of plutonium to terrorists.

  35.  Indeed, the use of MOX fuel in a fleet of thermal nuclear reactors could consume more plutonium than it generated, providing a net reduction in the UK plutonium stockpile.


  36.  In order to adequately address climate change, electricity demand needs to grow as direct use of fossil fuels is significantly reduced in all sectors. such phase out includes the electricity generating sector. Therefore, UK will see rising electricity demand with falling capacity as older nuclear and dirty fossil fuel capacity is retired.

  37.  The use of historic cost performance as a yardstick for nuclear projects led the Energy White Paper to incorrect conclusions regarding nuclear new build. In addition, the question of providing disposal routes for legacy nuclear wastes has been allowed to become an obstacle, when in fact legacy wastes have no real relevance or comparison to new wastes arising from new build. Technical solutions to legacy nuclear waste disposal exist now: new nuclear build should not be delayed whilst the political implementation of these solutions is debated.

  38.  Building a new fleet of nuclear power stations would not pose any serious additional threat from terrorism or proliferation.

  39.  As such, there is a need for deployment of significant new carbon free generating capacity, which necessitates new nuclear build alongside new renewable build.

Annex 1


A1.1  Citing the OSPAR convention Article 2 clause 1 requires: (emphasis added for clarity)

  The Contracting Parties shall, in accordance with the provisions of the Convention, take all possible steps to prevent and eliminate pollution and shall take the necessary measures to protect the maritime area against the adverse effects of human activities so as to safeguard human health and to conserve marine ecosystems and, when practicable, restore marine areas which have been adversely affected. To this end Contracting Parties shall, individually and jointly, adopt programmes and measures and shall harmonise their policies and strategies.

A1.2  "Pollution" is defined in Article 1 "d" as:

  "Pollution" means the introduction by man, directly or indirectly, of substances or energy into the maritime area which results, or is likely to result, in hazards to human health, harm to living resources and marine ecosystems, damage to amenities or interference with other legitimate uses of the sea.

A1.3  Releases of carbon dioxide from the burning of fossil fuels is widely accepted to be causing global warming by enhancing the "greenhouse effect". These releases are therefore indirectly introducing energy into the maritime area caused by man:

    —  The results of this introduction of energy are widely accepted to include:

—  increased sea temperatures, resulting in:

    —  harm to marine ecosystems;

    —  possible harm to living resources;

    —  rise in sea level, giving rise to flooding of low coastlands, and hence damage to amenities;

    —      change in weather patterns resulting in hazard to human health (including loss of life in high winds), harm to living resources and damage to amenities.

A1.4  Whilst this scenario is not proven, Article 2 clause 2 requires that:

  The Contracting Parties shall apply: the precautionary principle, by virtue of which preventive measures are to be taken when there are reasonable grounds for concern that substances or energy introduced, directly or indirectly, into the marine environment may bring about hazards to human health, harm living resources and marine ecosystems, damage amenities or interfere with other legitimate uses of the sea, even when there is no conclusive evidence of a causal relationship between the inputs and the effects.

A1.5  Article 2 clause 3 stipulates that:

  In implementing the Convention, Contracting Parties shall adopt programmes and measures which contain, where appropriate, time-limits for their completion and which take full account of the use of the latest technological developments and practices designed to prevent and eliminate pollution fully. To this end they shall: taking into account the criteria set forth in Annex 1, define with respect to programmes and measures the application of, inter alia,

    —  best available techniques;

    —  best environmental practice;

    —  including, where appropriate, clean technology;

    —  in carrying out such programmes and measures, ensure the application of best available techniques and best environmental practice as so defined, including, where appropriate, clean technology.

A1.6  There is nothing in this clause which supports the view that it is alright to continue building and operating power stations or road vehicles which discharge greenhouse gases on the grounds that there is no practicable technology to abate the discharge. Rather, the clause does support the view that alternative technologies should be implemented instead.

A1.7  Taking this, for example, into the arena of transport policy, it would be incumbent on the contracting party to implement policies where diesel locomotives were replaced with electric locomotives using electricity generated by non-fossil means.

A1.8  Further, Article 4 requires:

  The Contracting Parties shall apply the measures they adopt in such a way as to prevent an increase in pollution of the sea outside the maritime area or in other parts of the environment.

A1.9  Thus, implementation of such measures as the sequestration and storage of carbon dioxide released from burning fossil fuels in underground reservoirs or deep ocean, which would result in the pollution of those parts of the environment, is not allowable under OSPAR.

A1.10  Thus, in summary

A1.11  The OSPAR convention requires that Contracting Parties shall take all reasonable steps to prevent and eliminate the release of greenhouse gases (in general) including carbon dioxide released from the use of fossil fuels (coal, gas, petrol and other oil derivatives), and shall individually and jointly adopt measures to implement this.

A1.12  The convention further requires that steps and measures implemented are not limited to arguments that back end abatement technologies are not practicable: rather it is required to compare current greenhouse gas producing technologies with alternative technologies.

A1.13  The convention precludes the implementation of back end clean up measures which transfer the pollution from the OSPAR maritime area to any other maritime area or any other sector of the environment.

13 September 2005

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