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Memorandum submitted by the Nuclear Consultation Group (NPS 90)
A Executive Summary
A1 The National Policy Statements relating to nuclear energy (EN-1 and EN-6) are confusing, tendentious and poorly integrated
A2 The consultation process leading up to and including that on the NPSs does not support a coherent, practical or fair framework for the Infrastructure Planning Commission to assess planning applications for new nuclear power stations
A3 The volume of documentation, the number of simultaneous consultations, the short deadlines and the format of response make it difficult, if not impossible, for local communities, NGOs, CitizensÕ based groups and a wider public to participate effectively in the consultation process
A4 The inherent bias in favour of pro-nuclear positions in both process and content of the NPSs severely disadvantage groups and individuals who question or oppose the development of new nuclear power stations
A5 The criteria and constraints on siting limit the IPC to considering only ten sites which imposes an unfair burden of risk on those communities close to the sites
A6 The discretionary criteria relating to flooding and coastal processes provide inadequate guidance to the IPC. These criteria should be unambiguous and applied to exclude sites which are vulnerable to flooding over the next 200 years
A7 Long term on-site storage of spent fuel and other radioactive wastes from new build is a matter of public concern and raises technical, social and ethical issues which are not addressed in the NPSs
A8 Satisfactory arrangements for the long-term management of radioactive wastes do not exist and there is no evidence that they will exist in future
A9 Local communities have not been offered the opportunity to consider whether they wish to host spent fuel and waste stores into the far future
A10 There should be a presumption against permitting a site where the impacts on environment and ecology may lead to irrecoverable damage
A11 The principle of Imperative Reasons of Overriding Public Interest should not be restricted to promoting nuclear energy at all cost but should also be applied to to protecting significant environments from destruction
A12 Stronger guidance is needed on what degree of coastal change would make a site unacceptable and what levels of mitigation would be needed to prevent unacceptable damage
A13 The Ôsemi-urbanÕ demographics criterion is drawn too tightly and does not limit the radiological consequences to the population. The NPS should adopt a ÔremoteÕ demographics criterion and define clearly the area it covers to ensure it minimises radiological consequences in the event of a serious accident or incident
A14 The NPS should give much stronger guidance on the emergency planning policies and procedures that must be in place to ensure adequate information is provided to the public. The NPS should also set out the guidelines for an emergency implementation plane that ensures rapid and coordinated response
A15 Overall, the NCG finds the nuclear NPSs as unfit for the purpose of providing a framework within which the IPC can take fair, balanced and measured decisions on the location of new nuclear power stations
Evidence to the House of Commons Energy and Climate Change Committee from the Nuclear Consultation Group
1.0 Introduction and Purpose
1.1 The Nuclear Consultation Group (NCG) [1] has been especially concerned with the processes of consultation on nuclear energy in the UK. In its 2008 Report (Dorfman, ed. 2008) it provided a wide ranging critique from a variety of perspectives and has subsequently commented on the inadequacy of the consultations on new build. In particular the NCG has responded to earlier stages in the consultation process, on Strategic Siting Assessment (NCG, 2008) and on the Justification of New Nuclear Power Stations (NCG, 2009). The GroupÕs concerns about the consultation process so far will be found in those documents.
1.2 This evidence is in two parts. The first part (section 2.0) draws attention to the inadequacy of the consultation process as a means for debating and influencing the form and content of the NPSs. The second part (section 3.0) is concerned with the presentation and analysis of some of the issues covered in the various documents. In particular, the NCG finds the statements on such issues as the management of radioactive waste, the site selection process, flooding and coastal processes, environmental impacts and mitigation issues contentious and inadequate.
1.3 Overall, the Group finds the draft NPSs relating to nuclear energy confusing, tendentious, vague and poorly integrated. They do not encourage effective and democratic participation and engagement. Rather they appear to be a highly elaborate exercise to achieve premature legitimation for a predetermined policy, namely, the rapid deployment of new nuclear power stations on a limited number of existing nuclear sites. In terms of the CommitteeÕs objective the NCG considers the NPSs do not provide a coherent and practical framework for the IPC to assess planning applications.
1.4 The purpose of the following evidence is to demonstrate why the NCG considers the NPSs to be inadequate both in terms of process and substance.
2.0 The Consultation Process Ð Biased and Unfair
2.1 Together with the earlier stages in the decision making process for nuclear new build, the consultation on the NPSs appears to us to be hurried, burdensome, constrained, limited and pre-emptive. We set out our criticisms below.
Parallel processes are too demanding
2.2 Since the end of 2008 there have been several consultations requiring response from interested stakeholders and citizens. These have included consultation on the Strategic Siting Assessment (SSA), on Justification and on the Nomination of Sites for new nuclear power stations. In the current round three consultations are running in parallel, namely, the HoC ECC Committee (submissions by January 15), the draft Energy NPSs (February 22) and the Consultation on the proposed decision on Justification (also February 22). Meanwhile there are other related processes which also require attention, in particular the Generic Design Assessment (GDA) conducted by the regulators of the proposed power station designs. It is clearly unreasonable to expect sufficient attention to be paid simultaneously to three separate consultations each requiring a particular approach, knowledge and expertise. This problem is compounded by,
Volume of Material Impossible to Manage
2.3 The sheer weight of material available for the NPS consultation is intimidating. Apart from the substantial documents on the Energy NPSs (EN-1 and EN-6 for nuclear but four other volumes for the full suite) and the Consultation document, there are further large documents on Habitats Regulations Assessment, Appraisal of Sustainability, Alternative Sites study together with a formidable array of technical appendices, site reports, summary and consultation comments. The documents associated with the Nuclear NPS are listed on pp. 40-42 of the Consultation document (DECC 2009a). Of course, a fully informed appraisal would need to refer to a range of other documents, including the White Paper Low Carbon Transition Plan (TSO. 2009), policy documents on radioactive waste management (from, for example, the Committee on Radioactive Waste management (CoRWM) and the Nuclear Decommissioning Authority (NDA) and possibly technical reports from agencies such as the Environment Agency (EA), Natural England etc and from the regulators. One estimate suggests that a respondent focusing on a specific site would still need to read 1674 pages of text to be reasonably informed about the proposals and issues (Roche, P. 2009).
2.4 Although some of the documents can be supplied in hard copy on application, some of the technical material is only available online. For those with poor computing and printing facilities for downloading or with no computer mere access to material is at best time-consuming and at worst access is effectively denied. Even when access is achieved, it is quite difficult to be sufficiently selective in perusing technical material. These documents are not the most accessible or entertaining reading, more usually written in a laboured, turgid form of technical prose that requires intense concentration and takes time to assimilate. Given that the consultation period lasts for only fifteen weeks, including the Christmas/New Year break, the demands put upon an assiduous respondent are burdensome indeed.
Process Disadvantages Community and Anti-nuclear Groups
2.5 Government policy expects the industry to deliver as large a fleet of new nuclear power stations as quickly as possible. The consultation process is clearly designed towards that end as we make clear below.
2.6 First, the consultation process is fast, leading through site selection, justification, NPS, GDA and planning permission within the space of less than four years (2008-11) with the first new stations commissioned by 2018 (see timeline diagram in DECC January 2009 p.67). Given previous UK experience, if achieved, this would be astonishingly fast. The rapid and sometimes simultaneous consultative exercises together with the accelerated infrastructure planning process are the means to legitimate the policy.
2.7 Second, the decision making process is sequential and cumulative. There is a sequence of decision points which, once taken cannot be revisited. Thus the Strategic Siting criteria are now fixed and the NPSs once adopted will be applied by the IPC. This narrows the scope for deliberation as the process moves from the generic to the site specific. The problem for local communities is that key decisions will have been taken before they become involved. For example, policy on radioactive waste management will be settled and local communities may not have the opportunity to challenge its application at site specific level. By the time decision making reaches the individual site the scope for challenge and change will be severely limited.
2.8 Third, the consultation process itself is not participative. Very little effort is made to engage the public and local stakeholder groups beyond thinly attended public meetings and exhibitions. The mode of consultation is formal requiring answers to preconceived questions or written comments. Typically the publicity for consultation events is low key and attendances and response levels are low with the vast majority of the local population unaware that a consultation is taking place. The responses are published but rarely is any analysis performed and no attempt is made to seek representative information on the values and views of the local population. The transcripts provided by DECC of the consultation exercise are revealing and give voice and vent to the pent up frustration felt by many at the inadequacy of the whole process. The objective seems more geared towards satisfying minimum requirements than undertaking a genuinely interactive engagement. Certainly, these consultations are often regarded by local communities as having little real importance or impact on the decision making process.
2.9 The various aspects of the consultation process outlined above leave local communities at a considerable disadvantage. It is difficult for them to cope with the speed, volume and complexity of material and the method of consultation. Citizen Based Groups (CBOs), NGOs, individual citizens and even local councils find it difficult or impossible to find the time, commitment, experience and knowledge to achieve effective involvement let alone impact on the decision making process itself. In addition they tend to come into the process during the latter, local stages by which time the scope for influence has been considerably narrowed. By comparison the nuclear industry and government officials have considerable capacity in terms of resources, skills and privileged access to ensure input on all aspects and at all stages.
2.10 The NCG considers the consultation process is markedly skewed in favour of those interests promoting nuclear development. The documentation draws almost exclusively on sources prepared by the nuclear community or those associated with it. There is an entire absence of more sceptical literature, notably from the social sciences which is rich in sources and evidence to counter the claims of nuclear advocates. By contrast to the well resourced nuclear industry, local communities and citizens are far less able to influence the approach, content and recommendations of the nuclear NPS and associated documents. Consequently the NCG concludes that the process is unfair and does not support an equitable framework within which the IPC can take decisions on new nuclear power plants.
á It is impossible for NGOs, CBOs and ordinary citizens to cope with simultaneous consultations within a short space of time
á The volume of material is unmanageable and much of it difficult to access and assimilate
á Little attempt has been made to engage local stakeholders and the public in a more participative process enabling them to influence the content of the NPSs
á The speed, timing and format of the consultation process advantages nuclear industry and government bodies which have time, resources, expertise and access to make an effective response
á The experience of the consultation process has left local communities, groups and individuals who oppose the GovernmentÕs proposals frustrated and disillusioned
2.11 Consequently the NCG believes the consultation process is seriously flawed and that a new and more participative process should be undertaken in an effort to restore public confidence in Government decision making
2.12 In the following section some of the substantive inadequacies of the NPS will be set out.
3.0 The National Policy Statements Ð Inadequate and Unfair Basis for Decision Making
3.1 Here we focus particularly on the key documents relating to new nuclear energy, namely NPSs EN-1 and EN-6, the Consultation document and the Alternative Sites Report. Reference will also be made where relevant and by way of illustration to specific reports on the Bradwell site. A detailed critique of the the NPSs will be provided in response to the consultation which closes on February 22nd. In this evidence we shall confine ourselves to some key issues. These are: the siting process; the problem of managing radioactive wastes; flooding and coastal processes; environmental impacts; and demographics and emergency planning.
Siting - post hoc rationalisation of preordained conclusion
3.2 It has been clear from the outset that the choice of sites for new nuclear stations would be likely Ôto focus on areas in the vicinity of existing nuclear facilitiesÕ (TSO. 2009, p.33). The reasons were purely pragmatic Ð these are sites where land is available, infrastructure exists and they are in places where some familiarity with the industry might be expected to reduce resistance from local communities (it must be said this latter point is an assertion that, in our view, is not supported by empirical evidence). The NPSs are unequivocal that nuclear power stations should be built on these sites since Ôneed has been demonstratedÕ (Ibid, p.14).
3.3 Furthermore, the documents make it clear that there are no sites other than the ten listed. In an elaborate exercise of masterful rationalisation the Alternative Sites Study uses historic studies, views of energy companies and a complex screening exercise to identify around 270 sites, rejecting all but three as ÔNot worthy of further considerationÕ (Atkins, 2009, pp. 43-63). Analysis of the three sites at Druridge Bay, Owston ferry and Kingsnorth indicates a number of constraints which would make deployability by 2025 problematic. Of the initial eleven sites nominated, one, Dungeness, was not listed and there are reservations about the practicability of deployment of the two listed Ôgreenfield Ô sites at Braystones and Kirksanton (DECC, 2009a, p.49).
3.4 The IPC may only consider those sites listed and Ôshould be guided in considering alternative sites by whether they are in the locations identified in the NPSÕ (EN- 1, DECC, 2009d, p.37). The development of the sites depends on the investment decisions of the market. Consequently, the actual number, timing and location of new nuclear power stations is unclear. Unlike the target of 30% renewable capacity by 2020 (EN-1), new nuclear capacity is undefined and unrestrained. The NPS states that Ôit is essential that this NPS has sufficient sites to allow nuclear to contribute as much as possible towards meeting the need for 25GW of new capacityÕ (EN-6, DECC, 2009c, p. 13).
3.5 It should be noted that the ten sites listed are, in the main, at considerable distance from major urban centres and therefore they require long distance grid connections. Further, it may prove impossible to utilise the waste heat in distributed systems of power supply (see EN-1 pp. 38-9).
3.6 In terms of siting new nuclear power stations, the NCG considers the NPSs are inadequate and incoherent on the following grounds:
á The approach to siting new nuclear stations is unplanned and vague leaving the market to decide thereby creating uncertainty on the timing, number and locations of new stations. It is unclear what level of nuclear capacity is anticipated or can realistically be deployed.
á The constraints on siting imposed have ensured that no alternatives to the ten listed sites will be considered by the IPC. This imposes an unfair burden of risk on communities close to these sites
á The selected sites are sub-optimal in terms of transmission costs and energy efficiency.
á The need for new nuclear has not been convincingly demonstrated and it may prove impossible to deploy a large number of stations by 2025. Alternative strategies of renewables and energy efficiency are likely to prove more effective and should be more vigorously pursued in EN-1.
Coastal locations Ð on a vanishing coastline
3.7 The ten sites listed are all on or close to the coast where there is availability of cooling water. Some of them (e.g. Bradwell, Hartlepool) are within flood zone 3, high probability of > 0.5% annual flooding. Given the pragmatic reasons for site selection it is unlikely that the ten sites are the only or the best possible sites for new nuclear power stations. The Strategic Siting Assessment (BERR, 2008; DECC, 2009b) and the Alternative Sites Report (Atkins, 2009) must be seen as means of post hoc rationalisation in limiting and justifying the choice of sites. Equally, it may be concluded that, apart from Braystones and Kirksanton, such vulnerable sites would not have been selected were it not for the presence of nuclear facilities (Blowers, 2009).
3.8 Two of the SSA criteria relate to the coastal location of sites. These are flooding, storm surge and tsunami and coastal processes. Both EN-1 and EN-6 recognise that these coastal sites are Ôat greater risk of floodingÕ (EN-6, DECC, 2009c, p.32) without mitigation and that mitigation measures may have consequential impacts on coastal change. However, the documents conclude that Ôat the strategic level the risks are considered to be manageableÕ (p.32). Nonetheless, the NPSs are evidently cautious and the IPC is urged to Ôtake account of the credible maximum scenario in the most recent marine and coastal flood projectionsÕ and to ensure that mitigation would Ôbe achievable at the site for the duration of the life of the station and the interim spent fuel storesÕ (pp. 33-4). However, it is recognised that Ôpredictions of climate change impacts Ôbecome less certain the further into the future the assessments are for, and it is not practicable to consider beyond 2100 at this stageÕ (EN-6 p.51). It is quite possible that interim stores of highly active wastes will still be present on site in 160 years from the start of generation of a new power station (60 years operation plus 100 years for cooling of fuel). In other words, nuclear activity of some kind is likely to be present on sites until towards the end of the next century.
3.9 The Environment Agency, on the matter of flooding and mitigation is, to say the least, highly qualified and tentative, concluding for the Bradwell site as follows,
ÔThe Environment Agency has advised that it is potentially reasonable to conclude that a nuclear power station within the nominated site could potentially be protected against flood risks throughout its lifetime, including the potential effects of climate change, storm surge and tsunami, taking into account possible countermeasuresÕ (p.66).
3.10 Nonetheless, the Government considers this feeble assessment is sufficient to conclude that the Bradwell site passes the flood risk criterion. In reality, beyond 100 years where prediction of sea level rise and coastal change becomes frankly speculative, it is impossible to give any useful guidance at all. It appears to us incredible that coastal areas where flooding and coastal changes are likely to occur within the next 200 years should be considered for inclusion in the list of sites for new nuclear power stations.
3.11 On the issue of flooding and coastal processes the NCG considers that:
á The criteria relating to flooding and coastal processes should be exclusionary
á Sites which are clearly vulnerable to inundation over the next 200 years should be excluded
á Mitigation measures should not be contemplated where serious damage is likely to affect neighbouring coastlines or the marine environment.
3.12 We conclude that guidance provided in the NPSs is too flexible and open to interpretation. We believe stringent and unambiguous criteria on flooding and coastal processes should be applied to exclude the location of power stations on inappropriate sites.
Radioactive Wastes Ð Placing burdens on the future
3.13 A feature of the new nuclear power stations is that spent fuel will remain in storage on site and is likely to remain there a hundred years or so after shut down. Although radioactive wastes are covered in EN-1 (including Appendix G), EN-6 and elsewhere in the documentation (DECC, 2009 c and d) the emphasis is on the positive benefits of power generation rather than the negative disbenefits of the waste that inevitably accompanies it. From experience of the consultation so far it is evident that the public, local communities and some politicians, including MPs, are unaware that the proposals are as much for long term management of highly active wastes as for a nuclear power station.
3.14 In the NPS for nuclear energy (EN-6) the Government claims that it Ôis satisfied that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stationsÕ (DECC, 2006c, p. 25) and that the IPC will not need to consider this question. In a letter to the Secretary of State four members of the first Committee on Radioactive Waste Management pointed out that the GovernmentÕs statement was misleading for three reasons (see letter attached to which there has not yet been a reply). First, the long-term solution of disposal recommended by CoRWM required an intensified programme of research and development before it could be implemented. This programme has not yet been undertaken. Second, a suitable site for a repository would need to be found using the principle of voluntarism, that is an expressed willingness of a community to participate in a site selection process. Although some interest has been shown no community has, as yet, agreed to such participation. Third, the recommendations applied only to legacy not to new build wastes. New build wastes would create more wastes over an indefinite time period and raise different issues to legacy wastes which are unavoidable. Among the issues are technical aspects such as the methods of storage and the issues raised by high burn up fuel which are not addressed in the NPSs. CoRWM was clear that the proposals for legacy wastes would require a new process which Ôwill need to consider a range of issues including the social, political and ethical issues of a deliberate decision to create new nuclear wasteÕ (CoRWM, 2006, p.14). Yet, in the NPS, new build has been conflated with legacy wastes in terms of meeting scientific and social requirements and, moreover, it appears that no separate process will be required to test and validate its proposals for managing waste from new build.
3.15 As for the communities near the ten potential sites selected for new build they are having highly radioactive waste stores imposed on them for an indefinite period without being able to challenge the governmentÕs interpretation of policy. CoRWM was clear that its recommendations on voluntarism Ômust be applied to new central or major regional stores at new locations if the are to inspire public confidenceÕ (CoRWM, 2007, p.10). As it stands communities hosting sent fuel stores will be given no opportunity to consider whether they wish to volunteer to host a long term radioactive waste facility. In the absence of an acceptable method or site for disposal, these wastes may remain in store indefinitely on sites that by the end of the next century are increasingly likely to be inundated by rising sea levels and storm surges.
3.16 While public support in general for nuclear power changes over time, there is consistently a large majority concerned about the risks associated with nuclear waste. It is fair to say that local communitiesÕ opposition to new nuclear power stations is considerably strengthened and reinforced by proposals for on site nuclear waste storage facilities. It is recognised that risks continue into the far future and will impose burdens of cost, effort and risk on many future generations. The lack of concern about intergenerational equity issues in the NPS proposals is very striking. In the urge to create power stations for the present, the interests of the future are neglected.
3.17 On the issue of radioactive wastes, the NCG considers the NPSs flawed for the following reasons,
á There is little emphasis given to the fact that new nuclear power stations will be accompanied by long term on-site storage of highly active nuclear wastes which is a matter for public concern
á Long term on-site storage of wastes from new build raises distinctive technical (including handling high burn up fuel), social and ethical issues that are not addressed in the NPSs
á Despite the GovernmentÕs assertion, satisfactory arrangements for the effective long term management of new nuclear wastes do not yet exist and there is no evidence that they will do so in the near future
á Local communities around the listed sites have not been offered the opportunity to consider whether they wish to volunteer to host a long term highly active waste storage facility
á Little consideration has been given to the risks imposed on the far future which will be exacerbated by locating waste stores on sites vulnerable to inundation and coastal change
3.18 For these reasons on the question of radioactive waste the NCG considers the NPS documents are inadequate and misleading.
Environment and Ecology Ð a necessary sacrifice?
3.19 The Nuclear NPS and associated Habitats Regulations Assessment (HRA) and Assessment of Sustainability (AoS) reports refer to a range of issues and criteria relating to environment and ecology. These embrace international and national designated sites of ecological importance, and areas of amenity, cultural heritage and landscape value. Although it is recognised that there will be adverse impacts, it is considered that disruption and disturbance to important habitats and ecosystems can be potentially ameliorated or lessened through mitigation measures. No matter what the impacts, the need for nuclear power as determined by government policy, is seen as sufficient in itself to override the desirability of conserving environment and ecology. In the case of Bradwell, for instance the ÔGovernment has concluded that there is an Imperative Reason of Overriding Public Interest that favours the inclusion of this site in the Nuclear NPS despite the inability to rule out adverse effects on European sites at this stageÕ (EN-6, DECC, 2009c, p.71). Given the readiness evident in the NPS to invoke IROPI it appears that, in the urgency to achieve nuclear power stations at ten sites, (almost) anything goes.
3.20 Only in the case of the adverse effects on the integrity of the internationally designated areas at Dungeness was it Ônot considered that mitigation of impacts related to habitat loss would be possibleÕ (Consultation Doc.. 55 p.79). Although this is the reason given for not listing Dungeness it is also clear that Dungeness might well have failed on other grounds. There were concerns over whether it could be protected from flood risk and coastal processes and this would have posed Ôa challengeÕ if Dungeness had remained in the frame (EN-6, 34 p.75 and 40 p.76). The delisting of Dungeness could be construed not as an isolated case but as a precedent. Other sites, to a greater or lesser degree, manifest similar problems of potential environmental damage and flood risk, for instance, Bradwell is in a much higher flood risk zone than Dungeness. It may be questioned why they, too, were not delisted.
3.21 The answer is that the NPS is vague, unspecific and constrained thereby encouraging the retention of the ten listed sites. It is vague in that adverse effects cannot be ruled out and detailed studies are needed on mitigation measures. It is unspecific in that no guidance is given on the degree of environmental impact that would rule out a site or the level of mitigation that would be needed to retain a site. For example, the Bradwell HRA (DECC, 2009e) lamely concludes that, ÔOnly at the project level HRA can a conclusion of Òno adverse effect on site integrityÓ be made with any confidenceÕ (3.69 p.43). And it is constrained in that it is made abundantly clear that, only in the most exceptional circumstances, should a site be rejected, so imperative is the overriding national interest for the development of nuclear power. On this point the Government is quite clear; the ten sites should be made available even though Ôpotential adverse impacts on Natura 2000 sites cannot be ruled outÕ (EN-6 A33 p. 276).
3.22 The strong line on IROPI, which suffuses EN-6, is at some variance with the approach stated in EN-1 where the IPC is given a stronger steer on matters of climate change and impact. For example,
ÔThe IPC should not normally consent new development in areas of dynamic shorelines where the proposal could inhibit sediment flow or have an adverse impact on coastal processes at other locationsÕ (4.20.10, p.63).
3.23 In EN-6 guidance is at once both permissive, leaving the IPC some discretion on the basis of evidence at the local level, but also highly restrictive in its emphasis on the need to approve sites for new nuclear energy. This tension between discretion and restriction pervades the whole document and reinforces NCGÕs view that the NPS has the implicit function of ensuring sufficient existing sites to fulfil the GovernmentÕs commitment to nuclear energy regardless of the serious environmental consequences that may ensue both now and in the future.
3.24 On the issues of environment and ecology NCG considers the NPSs on nuclear energy are inadequate as a framework for the IPC for the following reasons:
á The guidance on environmental impacts is too permissive. There needs to be a presumption against consenting a site in situations where the adverse impacts on ecosytems, habitats, landscapes and amenity would lead to irrecoverable damage
á There should be stronger guidance on what measures of mitigation must achieve in order to prevent unacceptable damage to environment and ecosystems
á Stronger guidance is required on the level of potential coastal change arising from climate change that would render a site unacceptable. Sites in flood zone 3 should be excluded.
á The principle of Imperative Reasons of Overriding Public Interest should not be routinely invoked to promote nuclear energy whatever the consequences for environment and ecology. IROPI should also be used to defend and protect environments that are unique, significant or irreplaceable
á Overall, on the matter of environment and ecology, the NPS should offer clearer, unambiguous and balanced guidance to the IPC
3.25 The NCG concludes the guidance on environment and ecology is inadequate and too weighted in favour of granting consent rather than inviting a more balanced assessment of the needs of development and environment.
Demographics Ð how big is the risk?
3.26 The demographics criterion is one of only two that are exclusionary though it is assessed again at development consent stage to take into account any changes (for example, in reactor design or population) that may have altered the acceptability of the risks to the local population. The demographics criterion has been so constructed that all ten sites pass the criterion and the criterion cannot be revisited by the IPC.
3.27 The objective is Ôto limit the radiological consequences to the public in the unlikely event of a serious nuclear accidentÕ (EN-6, DECC, 2009c, p.43). The criterion adopted is Ôsemi-urbanÕ derived from a complicated and (as presented in SSA criteria) unintelligible formulation that weights distance from the plant with population to produce a cumulative weighted population within the vicinity up to a distance of 8km. It is unclear how the parameters are derived and justified (see the critique in BANNG, 2008, 2009). Be that as it may, the outcome is neither fish nor fowl. On the one hand, the criterion indicates that ÔremotenessÕ is no longer necessary; on the other ÔurbanÕ locations are ruled out on grounds that a substantial population might be endangered. But this makes little sense. It seems to NCG that nuclear power stations are regarded either as a potential threat to local populations and, therefore, should be in remote places, or, they are no longer deemed to be so threatening and, therefore, may be sited close to populations where the demand for electricity is based and where they avoid long distance transmission and can take advantage of the potential for CHP (EN- 1, 2009d, p.39).
3.28 By adopting a semi-urban criterion the Government has recognised the potential risk to local populations from an incident or accident. What has not been recognised is that substantial populations may be at risk, particularly if a more realistic notion of the area that might be affected were used. To take Bradwell as an example, within 8 km there are substantial settlements including West Mersea (8000) only 4km away. Not far beyond, around 15km. is the large town of Colchester (100,000) and within 25-30km. the population is around a third of a million. The semi-urban criterion can hardly be said to minimise the risk to population but it serves the purpose of ensuring that the ten listed sites are not excluded on grounds of population density. A more satisfactory, comprehensible and logical approach would be to state what levels of population within specific zones were acceptable in terms of radiological risk from accidents or other incidents.
3.29 A related issue is the protection of the public in the event of an accident. The scale of an accident will vary but it is necessary to plan for the biggest credible scenario which might involve a very large population within a wide area of the plant (as, for example, was the case at Three Mile Island in 1979). Preparedness involves the following steps: clear and realistic identification of emergency planning zones; adequate provision of information to the public; planning for eventualities including the possible evacuation of large populations. Present planning is deficient on all counts. Emergency Planning Zones are too tightly drawn to the immediate vicinity of power stations; the public are unaware of the warnings, procedures and precautions that are needed in the event of an accident; and evacuation of large populations is likely to prove impossible.
3.30 In the NPSs emergency planning is a matter for local consideration relying on existing regulations and guidelines to be drawn up and implemented by nuclear operators and emergency services. The Government Ôdoes not generally believe that it is possible to determine the ability of a site to meet emergency planning obligations at a national level..Õ(EN-6 4.12.3 p.42). The NCG finds this quite inadequate and unreasonable and unlikely to reassure the public put at risk. The NPSs are incredibly vague and insubstantial on the matter of emergency planning. Ultimately, it may prove impossible to protect the population in the event of a major emergency. In the NCGÕs view it would be more prudent to adopt a cautious approach by defining more clearly the nature of the potential risks and setting out some clear, detailed and generic guidelines on what procedures, plans and policies must be in place. It is surely not reasonable to leave these matters entirely to local determination on a site specific basis.
3.31 On the matter of demographics and emergency planning the NCG has the following observations,
á The NPS should ensure that guidance to the IPC is firmly based on the GovernmentÕs objective Ôto limit the radiological consequences to the public in the unlikely event of a serious nuclear accidentÕ. This means limiting the numbers potentially exposed and ensuring a swift and effective response in an emergency
á The exclusionary Ôsemi-urbanÕ demographic criterion does not meet the GovernmentÕs objective. The NPS should apply a ÔremoteÕ criterion indicating what levels of population within specific zones are deemed to be acceptable in terms of radiological risk in the event of a major accident
á The NPS should give strong and detailed indicative generic guidance on emergency planning policy and procedures. This guidance should require from the developer the provision of adequate and intelligible information for the general public and from the relevant authorities a plan of coordinated rapid response together with an implementation plan.
3.32 The NCG finds the generic guidance in the NPSs relating to demographics and emergency planning confusing, contradictory and lacking in depth or sufficient detail. The Government should consider reviewing these issues in order to provide the IPC with useful and implementable guidance.
4.0 Other Issues and Conclusion
4.1 In this submission NCG has only identified some of the key issues which we feel require attention. There are other matters, for example, socio-economic issues where we feel the guidance is partial reflecting the general bias towards nuclear energy that is evident throughout the documentation. There are also some more technical issues, for example, the need for cooling water, where we feel the guidance is inadequate and needs to be strengthened. These matters will be raised in response to the GovernmentÕs current consultation on the National Energy NPSs.
4.2 It will be clear that the NCG does not regard the NPSs as providing a sufficiently coherent or practical framework for the IPC to assess planning applications for nuclear power stations. We consider the consultation process leading up to and including the NPSs as deeply flawed, biased and unfair. Local communities, groups and citizens who wish to participate are disadvantaged in the time, expertise and resources they are able to devote to responding to the consultation. This imbalance is reflected in the overly pro-nuclear bias in the documentation. In substance the NPSs reflect a process that is hurried, incoherent and unintegrated. The intention of the exercise is clearly set out in EN-1. It is to Ôhelp in terms of removing planning barriersÕ and Ôto deliver faster and more transparent decisions on energy infrastructureÕ (p.5 1.6.1). The nuclear NPSs have limited the decision to ten sites with a requirement on the part of the IPC to deliver as many of these sites as possible. The NPSs provide a post hoc rationalisation of choices already made for pragmatic reasons. They are flawed documents reflecting a flawed process.
4.3 The NCG concludes that the draft NPSs on nuclear energy provide a passport for the nuclear industry to build new power stations on existing sites. As a framework for guiding the IPC the NPSs must be regarded as unfit for the purpose of taking fair, balanced and measured decisions on the location of new nuclear power stations.
References
Atkins (2009) A consideration of alternative sites to those nominated as part of the GovernmentÕs Strategic Siting Assessment process for new nuclear power stations, Prepared by Atkins for DECC, November
BANNG (Blackwater Against New Nuclear Group)(2008) Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK, Response on behalf of BANNG, November
BANNG (2009) ÔHave Your SayÕ Government Consultation on Nomination of Sites for New Nuclear power Stations, Response to the Consultation by BANNG, May
Blowers, A. (2009) ÔWhy Dump On Us?Õ Town and Country Planning, January, pp. 33-37
BERR (2008) Towards a Nuclear National Policy statement. Consultation on the Strategic Soiting Assessment Process and Siting Criteria for New Nuclear Power stations in the UK, July
CoRWM (Committee on Radioactive Waste Management)(2006) Managing our Radioactive Wastes Safely: CoRWMÕs Recommendations to Government, November
CoRWM (2007) Moving Forward: CoRWMÕs Proposals for Implementation, February
DECC (2009a)Consultation on Draft National Policy Statements for Energy Infrastructure, November
DECC (2009b) Towards a Nuclear National Policy Statement, Government response to consultations on the Strategic Siting Assessment process and siting criteria for new nulear power stations in the UK; and to the study on the potential environmental and sustainability effects of applying the criteria, Office for Nuclear Development, January
DECC (2009c) Draft National Policy Statement for Nuclear Power Generation (EN-6), London, TSO, November
DECC (2009d) Draft Overarching National Policy Statement for Energy (EN-1), London, TSO, November
DECC (2009e) Habitats Regulations assessment Site Report for Bradwell, Office for Nuclear Development
Dorfman, P. (ed.) Nuclear Consultation: Public Trust in Government, Nuclear Consultation Working Group
NCG (Nuclear Consultation Group)(2008) Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK, Response to the Consultation on Behalf of the NCG, November
NCG (2009) Consultation on the Nuclear Industry AssociationÕs Application to Justify New Nuclear Power Stations, Response from the NCG
Roche, P. (2009) Consultation on draft National Policy Statements for Energy Infrastructure Edinburgh Energy & Environment Consultancy, December 2009
TSO (2009) The UK Low Carbon Transition Plan, July
January 2010
Appendix
Letter to Secretary of State from Former Members of CoRWM
20 November, 2009
Rt. Hon. Ed Miliband Secretary of State for Energy and Climate Change 3, Whitehall Place, London SW1A 2HD
Dear Secretary of State,
New Nuclear Build and the Management of Radioactive Wastes
We write to you as members of the first Committee on Radioactive Waste Management (CoRWM 1) which presented recommendations on the long term management of solid higher activity wastes to government in 2006. These recommendations were substantially endorsed by government and expressed as policy in its White Paper on Managing Radioactive Waste Safely in June 2008 (CM 7386). We wish to express our concern that our recommendations have been seriously misrepresented in your draft National Policy Statement on Nuclear Energy published on November 9th.
In concluding the section on radioactive waste management the NPS states: Ôthe 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 questionÕ (paragraph 3.8.20).
We contend that it is unknowable whether or not effective arrangements will exist and that the question of management of these wastes on specific sites should be a matter that the IPC must consider.
The policy stated in the White Paper on Nuclear Energy is Ôthat before development consents for new nuclear power stations are granted, the government will need to be satisfied that effective arrangements exist or will exist to manage and dispose of the waste they will produceÕ (CM 7296, 2008, p.99).
In our view this is a matter of judgement not of ineluctable fact. The CoRWM1 proposals for long-term management of radioactive wastes identified a process towards a long-term solution, recognising that deep disposal should be implemented on the basis of Ôan intensified programme of research and development into the long-term safety of geological disposal aimed at reducing uncertainties at generic and site-specific levels, as well as into improved means for storing wastes in the longer-termÕ (CoRWM, 2006, rec. 4). Moreover, implementation would also depend on finding a suitable site based on the principle of volunteerism, that is an expressed willingness of a community to participate in a site selection process. Neither the scientific nor the social requirements have yet been met and consequently, in our judgement, it is not possible to conclude that effective arrangements Ôexist or will existÕ.
In any case, the policy set out by CoRWM1 and subsequently pursued by government applies to legacy wastes alone. CoRWM was quite clear that its proposals should not apply to new build:
ÔThe main concern in the present context is that the proposals might be seized upon as providing a green light for new build. That is far from the case. New build wastes would extend the timescales for implementation, possibly for very long, but essentially unknowable, future periods. Further, the political and ethical issues raised by the creation of more wastes are quite different from those relating to committed Ð and, therefore, unavoidable Ð wastes. Should a new build programme be introduced, in CoRWMÕs view it would require a quite separate process to test and validate proposals for the management of the wastes arising.Õ (Page 13, Managing our radioactive wastes safely, CoRWMÕs recommendations to Government, CoRWM document 700, July 2006). However, it is clear that government has conflated the issue of new build with legacy wastes and thereby intends the CoRWM proposals to apply to both. No separate process, as suggested by CoRWM1, for new build wastes is contemplated. There will be no opportunity for communities selected for new nuclear power stations to consider whether they wish to volunteer to host a long term radioactive waste facility; it will simply be imposed upon them. As the government recognises these wastes may well be stored on site Ôfor around 160 years from the start of the power stationÕs operations, to enable an adequate cooling period for fuel discharged following the end of the power stationÕs operation.Õ (Draft National Policy Statement for Nuclear Power Generation EN-6, 3.8.17). In the absence of a process or acceptable policy for new build wastes, they may remain on site indefinitely It is quite possible that, as a result of sea level changes, storm surge and coastal processes, conditions at some of the most vulnerable coastal sites will deteriorate thereby making it increasingly difficult to manage the wastes safely. The problems presented by managing wastes in the very long-term will be both generic and site-specific. Consequently we find it hard to understand why the IPC, when considering applications for the development of individual sites, need not consider the question of waste management. Given the levels of public anxiety raised by the issue of nuclear waste and the burdens of risk and management that are imposed on future generations we believe consideration of safe management of wastes at each site should be a primary concern of the IPC. We invite you to confirm that this would be your expectation.
In conclusion we reiterate that we do not consider it credible to argue that effective arrangements exist or will exist either at a generic or a site-specific level for the long -term management of highly active radioactive wastes arising from new nuclear build. We believe the scrutiny of the arrangements proposed for each site must remain within the remit of the IPC.
We are copying this letter to the Chair of the Infrastructure Planning Commission and the Chair of the Committee on Radioactive Waste Management. In the interest of open debate we shall also make these views known to the media.
Yours sincerely,
Professor Andrew Blowers OBE (member of CoRWM1) Professor Gordon MacKerron (Chairman, CoRWM1) Mary Allan (member of CoRWM1) Pete Wilkinson (member of CoRWM1)
cc. Sir Michael Pitt, Chair, Infrastructure Planning Commission Professor Robert Pickard, Chair, Committee on Radioactive Waste Management
[1] The NCG is a network of senior and leading experts in various fields related to nuclear energy policy and politics. It is particularly concerned with consultation processes and has published Nuclear Consultation: Public Trust in Government (Ed. Dorfman, P. 2008). An Annex gives details of the GroupsÕs membership and expertise. |