Memorandum submitted by People Against
Wylfa B
The draft national nuclear policy statement
is based on sweeping statements and unfounded prejudgements. It
is difficult to believe how the Department of Energy and Climate
Change has released such a blinkered and faulty policy statement.
This consultation is not a genuine one. As in the
case of each consultation on nuclear power since the second energy
review in 2006, this consultation has favoured nuclear power in
a totally unbalanced manner. Although Greenpeace won a High Court
action against the government in spring 2007 on the consultation
faults of the second energy review, the government has consistently
whitewashed nuclear power. Following the judgement in favour of
Greenpeace in the High Court, Tony Blair immediately emphasised
it was merely a matter of correcting the consultation process
and that the need for nuclear power stood. He then went on to
undermine the further consultation process by making pro-nuclear
statements. It is important to note all this as background since
it has created the faulty context for the draft national nuclear
policy statement.
Nuclear power is justified in this statement
by underlining its development is a matter of national need. Our
nation in PAWB is Wales, and the main voice for our democracy
is the National Assembly. In June 2007 in response to a question
by Mick Bates AM on nuclear power, Rhodri Morgan AM, Wales' First
Minister at the time said there was no need for new nuclear power
stations in Wales since we have plenty of other energy sources
to make us more than self sufficient. This view was repeated many
times by Rhodri Morgan and Jane Davidson AM, the Assembly government's
Environment Minister. During the summer of 2009, Jane Davidson
wrote to the Department of Energy and Climate Change pressing
for a public enquiry into the justification process for nuclear
power on the basis of her concerns about the doubly hot and radioactive
nuclear waste that would be produced from new reactors. It is
the Assembly government's aspiration to develop Wales as a centre
of excellence for the various renewable energy technologies, and
it fears that could be totally undermined if nuclear power were
developed. Therefore, there is no need for nuclear power in Wales.
The Department of Energy and Climate Change needs to recognise
Wales' national identity and its new democracy and stop acting
as a colonial master. Wylfa should be removed from the list of
possible sites for new nuclear reactors, as this dirty, expensive
and dangerous technology is not needed in Wales.
Alongside the lack of respect to Wales' national
needs, there is absolutely no analysis in your statement of the
social and linguistic effect building a new nuclear power station
would have on Anglesey's Welsh speaking communities. In the 2001
census, Anglesey's percentage of Welsh speakers was a little over
60% of the whole population. Gwynedd only has a higher percentage
of Welsh speakers. The effect of building the original Wylfa station
in the 60s was the Anglicisation of the northern and eastern communities
of Anglesey. Gordon Brown said that as many as 9000 people were
needed to build a new nuclear power station. If this figure is
correct, can you imagine the social and linguistic impact such
an influx of workers would have on Anglesey? Your draft statement
is therefore fundamentally flawed with no socio-linguistic analysis.
Consequently, Wylfa should not be included as a possible site
for building new nuclear reactors.
We would like to draw attention to some points
in the draft national nuclear policy statement. You say in 2.3.1
without any irony:
"Nuclear power is low carbon, economic,
dependable and safe".
This is a completely sweeping statement. We
shall deal later with the clauses which state that nuclear power
is low carbon and economic. The government's view that nuclear
power is safe and dependable has to be challenged. We would like
to remind you that over 350 farms in the uplands of North Wales
are still subject to animal movement restrictions as a result
of the Chernobyl nuclear disaster. The health effects of this
disaster will be felt in European countries for many years again.
It is only a matter of luck that there have not been very serious
results to accidents in the British nuclear industry. We refer
to an accident at Wylfa in July 1993, when a fuel grab fell into
the reactor core. Radioactivity was released into the atmosphere
and Nuclear Electric was prosecuted for that offence in Amlwch
Magistrates Court. They were prosecuted further in Mold Crown
Court for safety breaches by the Nuclear Installations Inspectorateand
ordered to pay a fine and costs of £500,000. Safety standards
at Sellafield are not satisfactory. As recently as October 2009,
the NII wrote to Sellafield Ltd. warning them that the possibility
of a serious accident there was far too high. You should remember
the liquid nitric acid leak containing plutonium and uranium from
THORP in Sellafield undetected between August 2004 and April 2005
and equivalent to half an Olympic swimming pool. This happened
despite the presence of closed circuit television. You should
also bear in mind the substantial leak of radioactive water from
Sizewell A and the following prosecution. A leak which lasted
14 years at Bradwell nuclear power station ultimately led to a
prosecution by the Environment Agency.
It is said in 2.3.5:
"Nuclear fuel fabrication is a stable and
mature industry."
A sentence like this calls into question the
whole credibility of the national nuclear policy statement. It
is incredible that the 200 page "Appraisal of Sustainability
: Radioactive and Hazardous Waste" doesn't even mention the
dangers and management challenges of mining and processing uranium.
Dr David Lowry published an important report "Uranium exploitation
and environmental racism: why environmental despoliation and the
ignorance of radiological risks of uranium mining cannot be justified
by nuclear fuel production". It is appaling that such important
work has not even been considered by DECC. Dr Lowry's work can
be accessed on the Nuclear waste Advisory Board website at www.nuclearwasteadvisory.co.uk/uploads
It is claimed as following in 2.3.9:
"Nuclear power is proven technology. Nuclear
power is also a proven technology that can be deployed on a large
scale".
No nuclear power stations have been built in
Britain since the second half of the eighties at Sizewell B. The
gap has been even greater in the USA where no new nuclear power
stations have been built since the late 70s. In spite of the talk
of nuclear technology's maturity, a generation has passed without
building a single new station. Looking at Finland's experience
where the state power company is building an EPR reactor with
the French nuclear company, Areva, at Olkiluoto, progress is very
slow. Building commenced in 2005 hoping for the station to be
ready by April 2009. The work is now over three years behind schedule
and the original cost of 3.2 billion euros has shot up to 5.8
billion euros. It is a similar story in Flamanville, Normandy
where another EPR is being built. There, it is acknowledged that
the timetable has slipped by two years. It is blind optimism on
the government's part to believe that nuclear power can be developed
on a large scale considering the slowness and cost of the two
nuclear projects in Finland and France.
We draw your attention to 3.8.17 as follows:
"It is possible to envisage a scenario in
which onsite interim storage might be required for around 160
years|.However this is based on some conservative assumptions,
and there are a number of factors that could reduce, or potentially
increase the total duration of onsite spent fuel storage".
PAWB like all anti-nuclear campaigning movements
are very concerned about the storage of nuclear waste on the sites
of possible new nuclear power stations. It is known that this
waste would be twice as hot and radioactive as waste produced
from present nuclear stations. We direct you towards work by Hugh
Richards, the Secretary of the Wales Anti Nuclear Alliance and
member of the Nuclear Consultation Group in the form of two reports,
"Burying the Truth" and "Too Hot to Handle"
which outline the completely unknown territory the British nuclear
industry would be entering by using high burnup uranium fuel in
new reactors. We also recommend you closely study Hugh Richards'
excellent response on behalf of the Wales Anti Nuclear Alliance
to the draft national nuclear policy statement. There is worse
to follow.
These sentences in 3.8.20 are astonishing:
"The Government is satisfied that effective
arrangements will exist to manage and dispose of the waste that
will be produced from new nuclear power stations. As a result,
the IPC need not consider this question.".
This is the type of unfounded statement which
brings the government and its servants in DECC into disrepute.
It is also a premature statement as the Environment Agency has
not reviewed the NDA assessments on the waste arrangements of
the two reactors under scrutiny., namely the EPR and AP1000. The
Environment Agency will not be able to conduct this review until
May or June 2010, well past the end of your consultation period.
I quote from a letter by Hugh Richards to DECC which proves that
this consultation is completely flawed:
"spent fuel requires 100 years cooling before
disposal and will have to stored in on site interim stores for
a span of 160 years, while the nuclear regulator GDA Step 3 reports
on EPR and AP1000 reactors require further work or additional
information on "the safety of the long term storage of the
fuel before final disposal focussing on the role of the levels
of burnup".
(Nuclear Directorate Generic Design Assessment—New
Civil Reactor Build Step 3 Fuel design Assessment of the EDF and
Areva UKEPR Division 6 Assessment Report No.AR09/041P).
How can the government claim to be satisfied
with waste management and disposal arrangements when other bodies
such as the Environment Agency and the NII have not completed
assessing these arrangements?
Another matter which doesn't get enough attention
in your statement is the emergency procedures in the case of a
serious accident at Wylfa. A PAWB member raised this in the meeting
at the Wylfa visitor centre held by DECC on 9 January 2010. The
site of the Wylfa nuclear power station is on an unique island
location. Anglesey is linked to mainland Wales by the Menai and
Britannia bridges. It is a common experience at various times
of day throughout the year to be held up in traffic leading to
the bridges. Can you imagine the chaos by both bridges if a serious
accident happened at Wylfa forcing the island's population to
flee to the mainland? Since you have not seriously looked at emergency
arrangements and Wylfa's unique location, Wylfa should be removed
from the list of possible sites for building new nuclear reactors.
The government is remarkably apathetic in its
attitude towards the effect of an accident at Wylfa at 4.8.4:
"In the event of an incident there could
be a risk to health from exposure to radiation for workers and
the public ... It is Government's view that these impacts are
unlikely to arise. If they do they are likely to be limited due
to the existing safety and environmental regulatory mechanisms".
Once again, this is a premature statement. Nuclear
regulators in Britain, France, Finland and the USA are not satisfied
by the safety features of the EPR and AP1000. How can the government
be so confident in its statements when nuclear inspectors are
asking basic questions about the safety features of both reactors
currently being assessed? We further note that the earliest date
to complete assessment of EPR and AP1000 will be June 2011. It
could easily be later than that considering the lack of inspectors
working at the overstretched NII.
Another matter raised at the meeting in the
Wylfa visitor centre was the content of the German KiKK report.
It is the German consortium of RWE and E.ON who are interested
in building new nuclear reactors at Wylfa. Why should this German
consortium be allowed to build at Wylfa while building new nuclear
power stations is contrary to government policy in Germany? The
German government accepted the findings of the KiKK report which
show that cancer levels among children are substantially higher
near each nuclear power station in Germany. Within 5km of each
station, an increase of 61% is recorded in solid cancers and an
increase of 120% in leukaemia. These conclusions were reached
on the basis of information collected between 1980 and 2003. The
government's policy statement does not seriously address the correlation
of nuclear power stations and cancer levels in the population.
The government should carefully consider the KiKK report and examine
the link between the nuclear industry and incidence of cancer.
The issue of earthquakes in North West Wales
was raised by a member of PAWB at the meeting in the Wylfa visitor
centre. On July 19, 1984 the strongest earthquake of the 20th
century in Britain measuring 5.4 on the Richter scale was recorded.
The earthquake's epicentre was beneath Llanaelhaearn on the north
side of the Llyn peninsula, Gwynedd. Its effect was felt strongest
in North West Wales, but was also felt throughout the rest of
Wales and in parts of England, Scotland and Ireland. It was a
completely unexpected earthquake, and it also occurred at a completely
unsuspected location. Not only did it occur at an unusual depth
of 18km, but its location did not correlate with the major mapped
faults straddling the Menai Strait (namely the Berw fault in South
Anglesey; the Dinorwic fault, along the Menai Strait; the Upper-Dinlle
fault, from Caernarfon to Bangor) or with the Mochras fault (along
the Cardigan Bay coastline into Tremadoc Bay). Neither the EN-6
statement nor the Applicants Scoping Report contain any information
at all on the potential, the risk, or the magnitude of further
earthquakes anywhere between the Menai Strait and the Holyhead
Deep in the Irish Sea. Historically, an earthquake (estimated
magnitude 4.9 on the Richter scale) is known to have occurred
on 9 November 1852 in the Irish Sea half way between Holyhead
and Ireland. If the government and all the applicants posess an
up to date seismic assessment of the Menai Strait- Anglesey—Irish
Sea region, why has it not been made public right away. If such
an assessment has not yet been completed or carried out, then
there is absolutely no sound basis for including the Wylfa site
within the national policy statement for further large nuclear
power reactors.
We wish to close our submission by returning
to the government's claim that nuclear power is a low carbon and
economic option. We wish to refer you to work by a leading member
of PAWB, Dr Gerry Wolff from Menai Bridge, Anglesey. Dr Wolff
is the author of "Nuclear Subsidies", a report
prepared for the Energy fair group. Dr Wolff's central argument
is that the nuclear industry survives through various public subsidies.
If these subsidies were withdrawn, life would be very difficult
for the nuclear industry. Without further generous subsidies,
new nuclear power stations will not be built. Dr Wolff's report
contains a very positive section outlining how various renewable
enrgy technologies can not only meet all of Britain's electricity
needs, but also all of its energy needs. This section refers to
a number of reports and academic papers on the subject. PAWB also
believes that we have a historic chance to contribute towards
the battle against climate change. This is the fast and effective
way to cut carbon emissions into the atmosphere. Nuclear power
is not a fast, credible or effective way to counter climate change.
A copy of "Nuclear Subsidies" by Dr Wolff was
sent to every MP in November 2009. The report can be downloaded
from:
In conclusion, PAWB believes that the National
Nuclear Draft Policy Statement is a woefully flawed and one-side
document. Your consultation in Anglesey was not satisfactory.
There was some advertising of your meeting at Wylfa visitor centre
on 9 January in the local press. However, the location for your
exhibition and meeting at Wylfa showed an unfair bias towards
the nuclear industry, its employees and ex-employees. It is intimidating
for people who oppose the nuclear industry to have to go to a
site which is usually avoided. On the other hand, Wylfa employees
and ex-employees were on comfortable home ground. Wylfa is at
the northernmost tip of Anglesey, 25 miles away from the bridges
over to the mainland, thus discouraging people from Gwynedd to
attend the meeting. A neutral more central location should have
been arranged.
Nuclear power is an exceptionally expensive,
dangerous and health threatening technology which should not have
a place in the technological developments of the 21st century.
The government and whichever government is elected after the general
election should abandon its pursuit of nuclear power as a means
of generating electricity.
January 2010
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