Memorandum submitted by the Department
of Energy and Climate Change (DECC)
BACKGROUND TO
THE DRAFT
NUCLEAR NATIONAL
POLICY STATEMENT
(NPS) AND ASSOCIATED
RELEVANT DOCUMENTS
The draft Nuclear NPS, taken together with the
"Overarching National Policy Statement for Energy: A Framework
Document for Planning Decisions on Nationally Significant Energy
Infrastructure" (EN-1), provides the primary basis for
decisions taken by the Infrastructure Planning Commission (IPC)
on applications it receives for the energy infrastructure.
This draft NPS also lists 10 sites that the Government
has judged to be potentially suitable for the deployment of new
nuclear power stations by the end of 2025. The list of sites in
the draft Nuclear NPS is the output from the Government's Strategic
Siting Assessment (SSA) process. Sites have been assessed against
flood risk and coastal erosion including the potential impacts
of climate change.
The Government has also conducted an Appraisal
of Sustainability on the draft Nuclear NPS. The role of the Appraisal
of Sustainability is to help to ensure that the draft Nuclear
NPS takes account of environmental, social and economic considerations,
with the objective of contributing to the achievement of sustainable
development. It has been undertaken in such a way that incorporates
the requirements of the Strategic Environmental Assessment Directive.
This includes a consideration of flood risk. There are Appraisal
of Sustainability Reports covering the draft Nuclear NPS in general,
as well as Appraisal of Sustainability reports on each of the
sites.
REGULATORS—ROLE
IN EXISTING
AND NEW
SITES
As with other major energy infrastructure the
regulators play an important role in ensuring the safety, security
and protection of people and the environment in relation to the
design, construction, operation and decommissioning of nuclear
power stations and the transport of nuclear material. Annex C
of the White Paper on Nuclear Power summarises the primary responsibilities
of those organisations involved in the regulation of nuclear power
generating stations.[62]
The UK has two primary regulators for nuclear
power stations:
— The Health and Safety Executive (HSE)
who regulate the safety and security of UK nuclear power through
their Nuclear Installations Inspectorate (NII), who are responsible
for all safety issues; and through the Office of Civil Nuclear
Security (OCNS), who cover both physical security and security
of information and IT systems. The NII examines the safety justifications
against all external hazards including those in relation to flood
risk and climate change. As part of the site licensing process
for new nuclear build, these aspects will be considered. For existing
sites, the safety cases for external hazards are reviewed through
the periodic safety reviews, which are undertaken by the site
licensees as a requirement of their site licence. Appropriate
levels of engagement with the Environment Agency are made during
these assessments. The NII outlines its position in its Safety
Assessment Principles for Nuclear Facilities, p38, reference:
http://www.hse.gov.uk/nuclear/saps/saps2006.pdf). Further, more
detailed guidance is contained within the NII technical assessment
guide for External Hazards http://www.hse.gov.uk/nuclear/tagsrevision.htm
— The Environment Agency who are responsible
for regulating the impact of nuclear installations in England
and Wales on the environment.[63]
In this they cover nuclear specific issues such as radioactive
waste disposal (including discharges to air and water) together
with non-nuclear matters such as, water abstraction, flood management
and conventional waste. In relation to flood and coastal risk
management and climate change the Environment Agency, as a statutory
consultee for planning application, is responsible for strategic
overview, Its consenting authority role includes:
— works in, over or under main rivers,
or likely to affect the integrity of tidal defences;
— raising ground levels in the floodplain
beside a main river; and
— coastal works that fall outside of the
scope of those consented by local authorities.
The nuclear licensing regime enforced by the
NII requires that new nuclear power stations are located, constructed,
operated and decommissioned with the long-term impacts of climate
change in mind. The NII requires existing and new site licensees
to ensure their sites are safe against sea-level rise and storm
surge throughout the life of the nuclear power stations, including
during decommissioning. This includes sites that are being decommissioned
and are managed by the Nuclear Decommissioning Authority (NDA).
PERIODIC REVIEW
Both existing nuclear licensed sites, those
sites which are being managed by the NDA and new nuclear licensed
sites are subject to periodic review by the regulators and through
this their capacity to withstand potential climate change will
remain under consideration throughout the life of the nuclear
power station.
Once licensed, as part of the site licensing
conditions, the licensee must review their safety case at regular
intervals (typically on a 10-year basis). This review will take
the most recent climate change projections into account and allow
the necessary modifications to flood defences and/or operating
arrangements to be undertaken. The objective of the review is
to compare the safety case of the site against modern standards
to see if there are reasonably practicable improvements that could
be made, to demonstrate that the plant is safe to continue to
operate, including spent fuel and radioactive waste storage for
the next defined period (typically 10 years) and to identify any
life-limiting factors. Failure to comply with any of the site
licensing conditions (including participation in the periodic
review) could ultimately result in a direction to undertake activities
that would bring the plant into a compliant position.
POTENTIAL IMPACTS
OF CLIMATE
CHANGE AND
NEW SITES
LISTED IN
THE NPS
Climate change is likely to mean that the UK
will experience hotter, drier summers and warmer, wetter winters.
There is a likelihood of increased flooding, drought, heatwaves,
intense rainfall events and other extreme events such as storms,
as well as rising sea levels.
The Appraisal of Sustainability states that
the relationship between the draft Nuclear NPS and flood risk
is essentially local or possibly sub-regional where a number of
potentially suitable sites are in proximity to each other. It
also has a number of different effects. The first of these is
the local impact that the individual development may have on the
risk of flooding to land adjacent to those sites. Secondly the
sites themselves may be vulnerable to the risk of flooding from
a number of causes, coastal, storm surge, fluvial, groundwater
and pluvial. Finally flood risk management measures put in place
to mitigate the impacts of flooding on or from individual sites
may impact on coastal process, hydrodynamics and sediment transport,
which in turn may impact on designated habitats. All of these
flood risk effects can occur during the construction, operation
or decommissioning phases. As a result flood risk assessments
need to take a long-term view.
The potential flood risk effects to areas surrounding
development sites could be either negative or positive. Negative
impacts could be that flood risk is increased to the surrounding
area as a result of any land raising required to protect the power
stations or the footprint and layout of the sites which could
impact upon floodplain storage and flood flow pathways. Positive
impacts could also arise, as flood risk mitigation measures constructed
as a result of the power stations could also provide flood risk
protection for new and existing developments in the district.
Similar negative and positive impacts could affect designated
landscapes, for example, sensitive habitats could become more
vulnerable to flooding, or as a result of improved defences—less
vulnerable.
Climate change will increase flood risk from
all causes. Coastal flood risk is likely to increase as a result
of predicted increases in sea level and changes in storm surge.
Changes to the seasonal distribution of rainfall and in the intensity
of extreme rainfall events are also likely to increase flood risk.
Climate change is also likely to result in changes to coastal
erosion.
HOW THE
NUCLEAR NPS ASSESSED
FLOOD RISK
FOR NEW
SITES
The Strategic Siting Assessment of flooding
and coastal erosion used the findings of the Appraisal of Sustainability
site reports, advice from the regulators and comments received
during a period for comment after the nominations were published.[64]
The Government considered flooding issues from
two perspectives. First, the possible threats to the safety of
a new nuclear power station in an area exposed to flood risk.
Secondly, the wider impacts of flood protection countermeasures
on areas surrounding potential new nuclear power station sites.
Overall, the Government assessed whether it is reasonable to conclude,
at a strategic level, that a nuclear power station within the
nominated site could be protected against flood risks throughout
its lifetime, including the potential effects of climate change,
storm surge and tsunami, taking into account possible countermeasures
and mitigations.
For the purposes of this assessment the lifetime
of the station includes allowing for the safe and secure storage
of all the spent fuel and intermediate-level waste produced from
operation and decommissioning until it can be sent for final disposal
in a geological disposal facility (GDF). The time that will be
required for the safe and secure onsite interim storage of spent
fuel and intermediate-level waste is contingent on a number of
factors. It is possible to envisage a scenario in which onsite
interim storage might be required for around 160 years from the
start of the power station's operation, to enable an adequate
cooling period for fuel discharged following the end of the power
station's operation.
In assessing both flooding and coastal processes
the Government has been advised by the Environment Agency and
the Nuclear Installations Inspectorate. Sites were assessed against
the climate change allowances in Planning Policy Statement 25
(PPS25) and then UK Climate Projections 2009 (UKCP09) findings.
This advice looked at the capacity of nominated sites to withstand
flood risk and coastal erosion including the potential effects
of climate change using modelling data that looks ahead to 2100.
Given the principles set out in the waste assessment,
it is possible that there could be waste on site for longer than
the climate change assessment has been able to look ahead. Predictions
of potential climate change impacts become less certain the further
into the future the assessments are for, and it is not practicable
to consider beyond 2100 at this stage. Whilst the assessment has
only covered the next hundred years, the regulators are satisfied
that safeguards are in place, to ensure that only suitable sites
achieve development and ongoing operational consent. Firstly,
the capacity of new nuclear power stations to withstand the potential
impacts of climate change will be reviewed in more detail as part
of the site licensing process and as part of the Flood Risk Assessment
that applicants must undertake in conjunction with their applications
to the IPC. Secondly, any site which was selected for development
and subsequent licensing would be required to periodically update
these projections as part of the site licence conditions in particular
through periodic review. Both these things are discussed in more
detail later.
The Strategic Siting Assessment also considered
potential impacts on site access and egress and the potential
wider impact of flood protection countermeasures on areas surrounding
the nominated sites.
The preliminary conclusion reached by Government
having considered the range of inputs is that all the sites have
been considered potentially suitable against the assessment of
flood risk and coastal erosion including the potential impacts
of climate change. The Government did have concerns about the
ability to protect a new site at Dungeness from flood risk and
coastal erosion throughout its operational lifetime, but the site
was found to be unsuitable against criterion D6: Proximity to
internationally designated sites of ecological importance.
The site assessments flag particular issues
that the IPC must consider further if an application comes forward
for a particular site in addition to the guidance which is given
for the consideration of all applications in the Overarching and
Nuclear NPS.
The Government is consulting on its preliminary
conclusions until February 2010 and will continue to work with
the Environment Agency (and others) to ensure that the Nuclear
National Policy Statement reflects up-to-date assessment of the
strategic flood risk to the site.
INFRASTRUCTURE PLANNING
COMMISSION
The Infrastructure Planning Commission (IPC)
will, from 1 March 2010, deal with applications for development
consent for new nuclear power stations. It needs to decide applications
for development consent in accordance with any relevant NPS, subject
to certain exceptions. Therefore the IPC will need to have regard
to the policy and guidance included in both the Overarching Energy
NPS and the Nuclear NPS on climate change adaptation, flood risk,
coastal change and other relevant issues when considering an application
and make its decisions accordingly. The advice of the relevant
regulatory bodies on these issues is likely to be an important
and relevant consideration for the IPC.
The Overarching NPS gives guidance to the IPC
on climate change adaption when considering proposals for energy
infrastructure projects. The NPS sets out that to support planning
decisions, the Government produces a set of UK Climate Projections
and is developing a statutory National Adaptation Programme. In
addition, the Government's Adaptation Reporting Power will ensure
that reporting authorities (a defined list of public bodies and
statutory undertakers, including energy utilities) assess the
risks to their organisation presented by climate change. The IPC
may take into account energy utilities' reports to the Secretary
of State when considering adaptation measures proposed by an applicant
for a new nuclear site.
The draft Nuclear NPS sets out further guidance
for the IPC when considering applications for nuclear power stations.
Applicants will have to consider the impacts of climate change
when planning the location, design, build, operation and, where
appropriate, decommissioning of new energy infrastructure. The
NPS sets out that in consultation with the Environment Agency
(EA) and Nuclear Installations Inspectorate (NII), applicants
should use the latest set of UK Climate Projections and the Government's
latest national Climate Change Risk Assessment when available,
to ensure that they have identified appropriate measures to adapt
to the risks of climate change.
Applicants will need to apply as a minimum,
the emissions scenario that the Independent Committee on Climate
Change suggests the world is currently most closely following—and
the 10%, 50% and 90% estimate ranges. These results should be
considered alongside relevant research which is based on the climate
change projections.
Any proposed adaptation measures will be set
out within the Environmental Statement (ES) to support the development
consent application, and will cover the estimated lifetime of
the proposed new infrastructure. Should a new set of UK Climate
Projections become available after the preparation of the ES,
the IPC will consider whether they need to request further information
from the applicant.
Where adaptation measures are necessary to deal
with the impact of climate change, the IPC will consider their
appropriateness in terms of their potential impact on other aspects
of the project and/or surrounding environment. The IPC will assess
the project against the potential impact of more radical changes
to the climate beyond that projected in the latest set of UK climate
projections, taking account of the latest credible scientific
evidence from such organisations as the Intergovernmental Panel
on Climate Change or EA, and that necessary action can be taken
to ensure the operation of the infrastructure over its estimated
lifetime.
SKILLS
As part of the Nuclear Site licence, the licensee
is required to have adequate arrangements for the production and
assessment of safety cases. The arrangements should include provisions
for the safety cases to be written, independently assessed and
peer reviewed as appropriate. In all cases, the documents should
be reviewed and approved by Suitably Qualified and Experienced
Persons (SQEP) of an appropriate level within the licensee's management.
Where a Licensee uses contractors to produce whole, or parts of,
safety cases the arrangements should ensure that the contractors
used are appropriate for the work to be undertaken and that the
individuals involved are SQEPs. The arrangements should include
a robust system of control of the whole safety case production
process including the initial choice of contractor, criteria for
assessing the competence of contractor before, during and after
the production of the safety case.
14 January 2010
62 Meeting the Energy Challenge: A White Paper on
Nuclear Power, January 2008, CM 7296, URN 08/525, Annex C,
p 181. Back
63
SEPA in Scotland. Back
64
These sources are available at http://energynpsconsultation.decc.gov.uk
and summarised in Part 5 of the draft Nuclear NPS. Back
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