Memorandum submitted by the PAWB (NPS 38)


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 sixties 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


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 January 9, 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 twentieth 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 November 9, 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 January 9 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 twenty first 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