Memorandum submitted by Paul Payne CEng,
CEnv, MIChemE
INTRODUCTION
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.
SUMMARY
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.
ENERGY SUPPLY
SHORTFALL
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.
COSTS
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.
STRATEGIC BENEFITS
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.
OTHER ISSUES
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.)
Security
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.
CONCLUSION
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
OSPAR OBLIGATION TO IMPLEMENT PRACTICABLE
ALTERNATIVES TO FOSSIL FUELS
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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