Memorandum submitted by Cumbrians Opposed to a Radioactive Environment (NPS 62)

 

 

CORE [Cumbrians Opposed to a Radioactive Environment] is grateful for the opportunity to comment on the NPS and we ask that our written submission is given due consideration by the Committee.

 

As a local environmental group, CORE has campaigned since 1980 on nuclear issues - specifically focusing on the commercial operations undertaken at Sellafield. These include the reprocessing of spent reactor fuel, environmental discharges and contamination, radioactive waste management, nuclear transports and local health detriment. The comments we submit to the Committee are therefore largely confined to that element of the combined National Policy Statements that relates to nuclear power.

 

1. We make the following points on the process to date:

 

 

· The sheer volume and complexity of the consultation documents defies a properly reasoned response being made by the due date

 

· We do not believe that we, and communities nationwide, have been given the fullest opportunity to participate at a sufficiently early stage of the development of the Policy Statements.

 

· We are concerned that the Infrastructure Planning Commission (IPC) will be left to resolve issues of major import without public challenge or input, and that the unexplored and contentious question of on-site storage of high burn-up reactor fuel at new power station sites is not within the IPC remit.

 

· We contend that it is premature for the Government to preliminarily conclude that effective arrangements will exist to manage and dispose of future wastes produced by reactors from the new-build programme. Given the unresolved issues surrounding the MRWS programme on existing wastes, it is dangerously irresponsible for Government to postulate that, on nuclear waste disposal, the IPC 'need not consider this question'.

 

· The MRWS programme is specifically designed and trailed to encourage public input throughout the programme - the value of such participation being wholly undermined by premature IPC approval for developments.

 

 

 

 

2. On the plans for the development/expansion of nuclear power in the UK, we comment:

 

· We perceive little merit in making a worthwhile contribution to the consultation on new build on the grounds that Government decisions have already been made.

· That as a means of mitigating carbon emissions, nuclear power will deliver too little too late to be of benefit;

 

· It will bring additional environmental detriment locally and nationally;

 

· Its inclusion in UK's energy mix will act as an unjustified distraction to national effort on the vital development of renewable energies;

 

· That there can be no confidence whatsoever that the industry's historic failure to deliver projects on time and to budget will not be repeated;

 

· That the likelihood of an increase in health detriment (as evidenced by recent US and German studies) has been inadequately addressed by Government and that

 

· The late publication (after the NPS and Justification consultation deadlines) of COMARE's report on the German KiKK study on childhood leukaemia around nuclear power stations precludes public scrutiny and response.

 

 

 

On new-build plans for West Cumbria, we make the following site-specific points:

 

· We note that none of the three nominated sites in West Cumbria 'fits the bill' in terms of the Government's initial guidelines on locations for new-build - namely that a) sites should preferably be licensed nuclear sites, b) that sites should be located close to the demand for electricity and c) that sites should possess the necessary transmission infrastructure.

 

· It is well documented that all aspects of West Cumbria have been dominated by the nuclear industry (Sellafield) for the last half century. This dependence upon one industry has lead directly to a stagnation of non-nuclear enterprise in the area.

 

· New-build in West Cumbria will not only perpetuate this domination for a further 60 years or more but will also ensure the area's continuing dependence on the vagaries of one historically unreliable industry, at the same time deterring non-nuclear investment in the region.

 

· The damaging prospect of one or more new nuclear power stations in the regional is already recognised by Government - as described in its Draft National Policy Statement for Nuclear Power Generation (EN-6) which acknowledges that the development of individual West Cumbrian sites could have negative effects on the local infrastructure and that 'these negative effects may become more significant if more than one nuclear power station is developed in the region'.

 

· Cumbria County Council's Emergency Planners have already warned, in terms of emergency planning capabilities, of the inadequacy of local infrastructure systems to deal with events outside those currently scoped for the Sellafield site itself.

 

· Written evidence presented to the 1996 NIREX Rock Characterisation Facility (RCF) Public Inquiry by local authority planners confirmed that the long-established nuclear presence in West Cumbria - and its indelible environmental legacy of commercial operations (nuclear wastes, radioactive discharges and health detriment) - was shown to have acted not only as a deterrent to new non-nuclear enterprise and investment being attracted to West Cumbria but also as a deterrent to holidaymakers.and the expansion of the tourist industry in West Cumbria.

 

· It is well documented that, central to the aspirations of Britain's Energy Coast West Cumbria (BECWC), nuclear expansion is to be the mainstay of the regeneration plans. Such underpinning will be detrimental to attracting the non-nuclear investment and employment that has been sought with urgency by West Cumbria's local authorities and others over the last decade.

 

· As nominator of West Cumbria's Kirksanton site, Germany's RWE has confirmed that development of that site will result in the removal of the long established and viable Haverigg windfarm. - undermining both Government assurance that nuclear development will not damage renewable programmes and the claim by Britain's Energy Coast Plan that it will cater equally for renewables as little more than lip service.

 

 

January 2010