Memorandum submitted by the Shut-Down Sizewell Campaign (NPS 32)



We make general observations on the difficulties experienced locally around Sizewell over the consultation on NPSs, and on the unfairness to us and to the public in putting out the NPSs for consultation in front of the Justificatory Process. On EN-1, we submit that the neglect of alternative national levels of electricity need and supply in the document make it unnecessarily and unacceptably inhuman and planet-unfriendly. On EN-6 we challenge the exclusion of nuclear waste from consideration in the NPS, on the grounds that it remains an unresolved enigma of huge concern to local people. We challenge the inadequacy and short-sightedness of the NPS in its understanding of coastal processes. We contest the safety of nuclear stations at Sizewell from coastal and climate change events, stressing the problems of offshore dredging that are omitted from the NPS. We criticise the inadequacy of the COMARE-based arguments for safety from radiation risk, and the failure of the RIFE reports to provide necessary information. We argue that the omission from the NPSs of any consideration of terrorism prevents the public from exercising its own judgement over a matter that rightly concerns them deeply.


On all these grounds we find the NPSs unfit for purpose.



General comments

The Campaign observes that there have been considerable difficulties for its members, and for the general public locally too, in deriving enough information to respond to the public consultation on the NPSs for the following reasons, and in responding itself:

The vast amount of documents to scan, assimilate and hunt through - some 1600 pages, we believe

The specialist details on which the NPSs frequently rely to argue their cases

The bias and assumptions on which much of the NPSs base their arguments

The shortness of warning and the poor publicity given to the DECC exhibition and its public meeting

The failure of the public meeting to enable everyone to contribute their views

Too much of the public meeting taken up by presentations from the two DECC staff

The inadequacy of the public meeting to develop the individual's views in any way into community views on EN-1 and EN-6, as a workshop might have done

The inability of the exhibition to air individual views in constructive ways to encourage discussion and wider understanding, isolating each contribution instead and therefore debilitating it

Consultation Fatigue and bewilderment caused by such a plethora of consultations across Government.

We consider that all this goes against the Government's own Guidelines for Good Practice in Public Consultation, and that this renders the NPSs unfit for purpose.


We believe there is a major problem with the Government's logic and fairness, in having this NPS public consultation before ever the public may know and discuss what the Government's final justification is for new nuclear power stations, under the European Council Directive 96/29 Euratom. We consider that this also makes the NPSs unfit for purpose.



Submission on the

Draft Overarching National Policy Statement for Energy (EN-1)


Policies on energy supply and demand, EN-1 Parts 2 and 3

The statement in 2.1.5 that the average global temperatures must be kept to 2˚C ignores the well-attested assessment that such temperature rises will nevertheless impose drastic effects on the populations of oceanic islands and of Bangladesh. It is therefore inhuman to propose a policy for the UK that accepts such problems, without at the same time proposing ways of mitigating them. And the Government have manifestly failed to propose any such mitigation, let alone set about implementing them.


There is a need to separate out the role of nuclear power - to provide electricity alone - from other forms of energy with which EN-1 confusingly conflates it, since this conflation disguises both the rather more limited role of electricity itself, and the very limited importance that large and centralised sources of electricity would have. It has been demonstrated over and over again that varied decentralised micro-energy sources could obviate the need for nuclear altogether. Yet this receives no attention at all in the NPS


In 3.310-3.3.14, the policy is developed that an electricity demand for somewhere between the current 60 GW and a future 110 GW should be developed over the years to 2025. This blithely ignores the effect such a policy will inevitably have, both directly and indirectly, in increasing global temperatures, and it therefore inhumanly ignores the lethal consequences for low-lying countries.


Furthermore, 3.3.23 dismisses increased energy efficiency, smart demand management and opportunities for increased storage and interconnection as ways of reducing demand, yet the NPS's reason - that their effect on large scale infrastructure would be limited - is erroneous, since they and micro-generation could do away in time with large scale infrastructure altogether. 3.3.25 proposes that nuclear power should be in the mix of methods of satisfying that demand, in spite of the self-evident fact that throughout the timeline considered (2010 - 2025) the building of nuclear power stations will be adding hugely to carbon emissions and therefore contributing directly to global temperature rises. Meanwhile the suffering to indigenes and the despoliation of land involved in supplying the uranium for nuclear power is brushed aside.


Indeed 3.5.1 promotes the contrary myth that "[n]uclear power stations are low carbon", disarmingly ignoring the huge carbon cost of nuclear build and uranium supply during the only window of opportunity there is to avoid a 2˚C rise and runaway climate change.


3.5.3 blandly refers to the Government's so-called "debate at national level" in 2006. This debate was notoriously partial, avoiding altogether the exacerbating effects on climate change over the next few years of a new build nuclear programme. It was also dismissive of the many authoritative assessments and proposals available of the way policies might, if there was a Government desire for them to do so, enable the provision of a satisfactory level of electricity, using only benign renewable sources without nuclear.


That debate was posed by the Government (and is still posed in the NPS) against a background it had carefully avoided disturbing, of "business as usual" and indeed of material and economic growth. None of these is justifiable on a planet already suffering from the consequences of Western overgrown business and growth, nor is there any justification for the additional suffering the planet's varied inhabitants will suffer if the UK maintains such selfish targets.


Far more thrifty and planet-friendly alternatives to our electricity needs and supplies are available, yet the NPS ignores these, without even considering seriously the obligation the UK has to be more planet-friendly. The precedent of a paradigm change to reduce energy use exists in the emergency measures put in place by a resolute UK Government in order to win the second world war, yet the NPS does not even begin to discuss the possibility, let alone the desirability, of such measures now, when the crisis is a far more severe global one, instead of an acute but local territorial one.


Such severe neglect on the part of the NPS EN-1 renders it unfit for purpose.





Submission on the

Draft National Policy Statement for Nuclear Power Generation (EN-6)


Nuclear waste in EN-6, Part 3

The statement in 3.8.20, "that Government is satisfied that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations", flies in the face of reason, of the evidence, and of the Government's own investigations on this matter.


No sound plan for disposing of any high activity waste anywhere has ever been produced by any country, let alone agreed anywhere. As 3.8 variously describes, the Government's MRWS White paper reviewed the various plans and processes, but its title - that of only "managing" the waste - is tantamount to admitting it cannot dispose of it. Furthermore, CoRWM 1, which was set up by Government to look into merely managing (not at all of disposing of) the waste, clearly stated it was unable to say anything about waste from new nuclear build, except that its Recommendation 4 implied that an intensified programme of research and development would be needed to reach any firm proposals about management of all waste.[1] Yet this has not yet been provided on anything like the scale necessary to decide anything.


The Sixth Report of the U.K. Royal Commission on the Environment of 1976 (The Flowers Report) recommended that "There should be no commitment to a large nuclear programme . . . until the issues have been fully appreciated and weighed in the light of wide public understanding".[2]. Yet 34 years later the public still fed propaganda about nuclear waste. The Flowers Report's use of the past tense "have been appreciated and weighed" makes nonsense of the NPS's claim above that the Government is satisfied that arrangements "will exist".


The types of nuclear fuel proposed for new nuclear stations, and their higher burn-up, will produce even nastier waste materials than Sir Brian Flowers ever examined, providing further reason to doubt the validity of the Government's satisfaction. Moreover, 5.4.1 D2 states (in spite of the Government's satisfaction) that knowledge on how to manage nuclear waste is so uncertain that it may be necessary temporarily to store this spent fuel waste on the sites of new stations for 160 years, more or less, to enable an adequate cooling period for it to elapse before the waste can be moved elsewhere. Given the start date of the stations as 2025, this means some waste will have to remain in the locality, with all the risks and problems that may entail (discussed further below under Flooding and Coastal processes) until 2185, or until 2200 if it turns out to be more, rather than less. For this to be excluded from local discussion, by Government edict based only on its fantastical satisfaction described above, is unacceptable.


Article 6 of the IAEA Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management (2001) states that "[e]ach contracting party ... must ensure ... it makes information on safety .... available to members of the public".[3] The UK is a contracting party but it has not done this, and it cannot do this, because it does not yet know how to make nuclear waste safe. To exclude such issues from the IPS, and therefore from the public debate, is unacceptable.


On all these grounds, the NPS's consideration of nuclear waste is not fit for purpose.




Coastal Processes, EN-6, Part 5.4.1 D2

This looks ahead only to 2100, because "it is not practicable to consider beyond 2100 at this stage". Above however we have shown that the NPS predicts that some hot higher activity nuclear waste may have to be stored on the coast at Sizewell until 2200. So there is a gap of a century during which hot waste that has already been dumped on the coast may have to remain there, at the mercy of all coastal and climate vicissitudes, although the Government have no idea whatever what those vicissitudes may be. That is throwing all precautionary principles to the winds, and of itself - independently from all other considerations - it makes this NPS unfit for purpose. To prevent the public from having a say on such a matter goes against natural justice.






D1 & D2 Flooding, tsunami, storm surge and coastal processes at Sizewell, EN-6, Parts 5.14.18 - 5.14.37

We take these together because to separate them, as the NPS does, unrealistically minimises their synergism when such phenomena operate either variously over long periods, or more calamitously all at once. The paragraphs in these sections of the NPS offer an unrealistically benign view of the future stability of the Sizewell coast, based on inadequate data, largely derived from computer modelling and aimed at supporting insubstantial hypotheses. These ignore much hard evidence to the contrary that the coastline is extremely vulnerable even within 100 years, let alone over the 200 years for which planning for the safety of the waste is necessary. This evidence may be obtained from such sources as the Marinet Group of FOE.[4]


The NPS wishes one to accept the view that absence of evidence is evidence of absence, while there is quite enough evidence to require one to subject it all to detailed examination on a local level by local people interested in their own local safety, instead of excluding it from what local folk may consider at all. Even if the jury is out at present on some of the issues involved, four glaring problems face the protection of any nuclear station and its waste store at Sizewell from the sea and from flooding:

Engineering, such as is deemed to be necessary and possible to protect the station, will by its very nature simply deflect the energy of the sea elsewhere. All along the coast to north and south are valuable assets and communities that would receive such deflected energy, in ways we cannot predict but that would surely happen.

As is made very clear from the Marinet evidence, there is a large added risk to the stability of the Sizewell coast, and to the extent to which it will erode, from the exacerbating effects of offshore aggregate dredging. There is an ever-increasing amount of this dredging taking place at present to the north of the site, from whence is supposed to arrive the sediment intended to replenish the Sizewell beach (in reduced quantities already, the NPS acknowledges). Yet there are additional dredging proposals that bring the threat markedly closer and more directly to Sizewell, most worryingly those for the area 430 UMD/MX, less than eleven miles offshore from Sizewell and directly opposite the Dunwich sandbank. This sandbank is accepted as being a major defence for the Sizewell beach. If its material gravitates towards the hole caused by the dredging in area 430 that is likely to occur well before 2100, that must gravely reduce the defences for the nuclear waste on the beach well before 2200. None of this is mentioned in the NPS.

The problems with the Minsmere sluice, blithely referred to in 5.14.21 as being capable of mitigation, should not be taken in isolation, but together with all the other destabilising influences on the Sizewell coast. The fact is that the entire coastal fringe of which Sizewell is a part and which extends back behind the site to the south west and west and several miles to the north, is over a period of 200 years at the mercy of both fresh water from the Minsmere river and of marine incursions too, interacting in unpredictable ways, so that the future stability of the site is anyone's guess. As confirmation of this, the enormous engineered causeway to the north of the site proposed by EDF is a hubristic attempt to provide a dam against the opposing waters; while all it would do in practice, of course, would be to deflect the water's energy in other unknown directions, with unknown consequences.

Although the NPS confidently quotes authoritative projections of coastal climate change effects from all sorts of up-to-date sources, this merely masks the uncertainty about the accuracy of each projection. It also masks the trend that is constant over all the successive projections - that they become more dire as one forecast replaces another in time. That trend is certainly reliable, and it means we cannot possibly know how vulnerable the Sizewell site will be in the future; we can only say it will be worse than we think.

The NPS is therefore entirely unfit for purpose in this part, in giving an inadequate appraisal of the vulnerability of the Sizewell site. And this is a particularly grave fault, since it will be local people who will suffer first and worst from any damage to the nuclear station or its waste stores, yet the NPS proposes to prevent local people from having any say in such matters.




Health at Sizewell, EN-6, Part 5.14.102-110

In an attempt to rule out of local consideration the effects on local cancer from radiation from Sizewell, the NPS relies upon the 10th and 11th Reports of COMARE. This is not fit for purpose because the model of radiation risk used by COMARE is the ICRP one, which is severely challenged and exposed as being unsatisfactory to explain the incidence of cancers in many cases. The CERRIE Committee majority report agreed that the ICRP assessment of risks might be an order of magnitude wrong in either direction.[5] CERRIE's minority report agreed that it might be two or three orders of magnitude wrong.[6] Furthermore, the European Committee on Radiation Risk proposes alternative models for estimating radiation risk that meet the facts far better in many cases than the ICRP one does.[7]


The figures on which COMARE relies are not available to the public, and there have been difficulties and obstructions facing the public in obtaining figures on which they may rely.[8] Since most UK nuclear stations are on the coast and in sparsely populated areas, even COMARE's jealously guarded samples are small and so of low significance. They rely more on absence of evidence than on evidence of absence. These samples from which COMARE draws its conclusions are dwarfed into insignificance by the huge size of samples used in the German KIKK Study of 20O7.[9] This found significant increases in childhood cancer in direct proportion to how close to nuclear power stations the children lived, and its methodology and power exceed any other study that can so far compare with it. This is very positive evidence of correlation between cancer risks to children and their adjacency to nuclear stations.


At the very least therefore the COMARE reports are not authoritative, therefore unjustifiable as reasons to exclude local people from having a say in the health of their children. So this part of the NPS is not fit for purpose.


The only other study relied upon by the NPS here is the Radiation In Food and the Environment Report (RIFE) 13 on the levels of radiation in various foods near Sizewell, and its conclusions are that its results show that levels of radiation in food are too low to cause cancer. Of course this depends upon what are the real relationships between radiation levels and cancer risk, which is uncertain as described above. However, local people are interested in a possible hypothesis for a pathway between nuclear stations and child cancer that depends upon peaks of radiation emissions (and therefore their deposition on food, which may be consumed by pregnant mothers and cause trouble for the developing foetus) at the time of or shortly before shut-downs for refuelling at Sizewell B.


To test this hypothesis, we sent for RIFE 13 recently from the Food Standards Agency, and received on 15 January not RIFE 13, but RIFE 9, so we are unable to study the figures as pertinently as we would like.[10] However, we notice in tables 5.10(a) and 5.10(b) of RIFE 9 that, of 43 categories of samples taken around Sizewell in 2003 (the year covered by RIFE 9), only one was taken more than twice during the year. That sample is of milk. All of the other 42 categories of samples were taken either only once or twice in the year. This would effectively prevent any correlation being shown between the radiation in the foods and sites on the one hand and the time of a shut-down of Sizewell B on the other. This means that those of us local to Sizewell are unable to make our own observations to satisfy ourselves as to the safety of nuclear power at Sizewell. Not only that, but it seems that the sources upon which the NPS relies to impose radiation upon us locals are those which simultaneously prevent us from obtaining the figures we ourselves need to discuss this.


This is contrary to natural justice and makes the NPS unfit for purpose.



The risks of terrorism at Sizewell, omitted from both EN-1 and EN-6

The Observer of 22 November 2009 reported that "the government is refusing to provide details on five separate security breaches at British nuclear power stations last year". Three years earlier the OCNS annual report was prepared to reveal that among eight breaches of nuclear security that year were the thefts of laptops from parked cars, and inappropriate transmission of restricted information over the internet. The refusal now to reveal details suggests the recent incidents were even more serious than the earlier ones. The presence of a new nuclear station at Sizewell will be an obvious target for terrorists. For the NPS to omit any consideration of this, and for the Government to deprive local people from any opportunity to assess the risks of this by withholding relevant information, make the NPS unfit for purpose.


January 2010













[8] Health Effects and Scrap COMARE