Memorandum submitted by Dr Rachel Western
Dr Western is the Nuclear Researcher for
Friends of the Earth groups in Cumbria and also a member of "Nuclear
Waste Advisory Associates".
Her academic background is in the science
and policy issues associated with nuclear waste management; and
she has worked for the nuclear waste agency (Nirex), and also
for Friends of the Earth (HQ).
This paper focuses on the imperative requirement
of avoiding radionuclide creation in the programme to avoid carbon
Radionuclides are created when uranium is used
to produce nuclear energy. These radionuclides present a threat
to "DNA" the blue-print for life.
However, predicting the degree of harm that
would be caused by the creation of such radionuclides is extremely
The majority of text is contained in the Appendix,
which provides the evidence base for the contention that the prediction
of harm due to radionuclides is extremely problematic.
In addition to the discussion of radionuclide
harm, brief reference is also made to the KPMG report that concluded
that Subsidies would be required if nuclear power stations were
to be built. This conclusion must be compared to Government policy
? which states that nuclear power stations should not be built
if they require subsidy.
(1) What are the factors that ought
to be considered in setting the level for an Emissions Performance
Standard (EPS) and what would be an appropriate level for the
UK? Should the level be changed over time?
(A) The level should not be set such that
the creation of radionuclides is required.
(2) What benefit would an EPS bring
beyond the emissions reductions already set to take place under
the EU ETS?
(A) Extreme care should be taken to avoid
(4) Could the introduction of an EPS
pose any risks to the UK's long-term agendas on energy security
and climate change?
(A) If it was decided to meet Carbon Targets
through the introduction of nuclear power, this would be likely
to create a false sense of security
Professor Andrew Blowers of the Open University,
and former member of the UK government's Committee on Radioactive
Waste Management (CoRWM) has commented:
" [Nuclear power] would provide the illusion
of a solution to the problems of global warming and energy security
which required no fundamental changes in production or consumption.
It is this business-as-usual aspect of nuclear that is its most
insidious characteristic. The danger is that by focusing
on nuclear we refrain from recognizing the scale of the challenge
we face and shirk our responsibility for dealing with it".
(5) What is the likely impact of an
EPS on domestic energy prices?
(A) In August 2010 it was reported that:
"all the intellectual spare capacity
in the government is focused on the deficit and the budget cuts,
and there is very little capacity left to look at other political
It was reported that this was having a particularly
severe impact on DECC (the Department of Energy and Climate Change).
In July 2010, the Telegraph reported that: "KPMG
says nuclear power `won't happen'"
The article concerned a study by KPMG for RWE npower that states
that new reactors will not be built if the Government maintains
its commitment not to provide taxpayer support for new reactors.
The study says it is still uneconomic for utility companies to
invest the billions of pounds required in new reactors under the
current financial framework.
It may be seen that if it were decided to meet
Carbon Targets through the introduction of nuclear power, this
could have very severe impacts on energy prices.
THE PROBLEMATIC NATURE OF PREDICTING HARM
DUE TO RADIONUCLIDES
In September 2001, at the start of the: "Managing
Radioactive Waste Safely" (MRWS) programme the Environment
Minister, Michael Meacher stated:
"The legacy of a wrong decision could
There are about 90 different chemical elements
(for example Hydrogen element "No 1" to Uranium element
Lumps of these elements may be broken down and
broken down and broken down until an object about 10 -8 centimetres
big is reached that cannot be broken down any further in the same
way. Breaking this object down any more would produce fragments
that no longer shared the properties of the element.
The name for the smallest object that still
retains the properties of the chemical element is an "atom".
The number of the chemical element (see above)
refers to the number of positive lumps (or "protons")
at the centre (or "nucleus") of the atom.
The centre of the atom also contains neutral
particles (or "neutrons").
The centre ("nucleus") of an atom
may be unstabledue to the "wrong" balance of
positive and neutral particles.
Such unstable centres (or "nuclei")
are known as
In the process of becoming stable radionuclides
release particles and/or energy. The particles and energy released
are able to damage DNA ( deoxyribonucleic acid.)
DNA is the "blue-print" for life.
If it is damaged, cancer (either fatal or non-fatal); or alternatively
birth defects may result.
The process of becoming stable through the release
of particles and energy is known as "decay".
The term "half-life" refers
to the time that it takes for 50% of the original quantity of
a given radionuclide to break down.
What is a "Sievert" ?
The harm caused by exposure to radionuclides
is described in terms of:
the energy (per unit weight ) of the exposure
It can be thought of in terms of the overall
"punch" associated with the radionuclide bombardment.
of "harm" to one kilogram is called one "Sievert"
In a nuclear reactor uranium is pounded by small
particles called "neutrons" and as a result a
vast number of "radionuclides" are formed.
When uranium (chemical element "92"
) is exposed to neutrons in a reactor there are three different
processes that result in the creation of radionuclides.
absorb a neutron and turn into a heavier
element such as neptunium (element "93") or plutonium
(element "94"). These very heavy elements are known
split into two separate atoms. The products
of this split form two smaller atoms from the larger uranium.
These smaller atoms are known as "fission products".
They are particularly radioactive.
In addition, the reactor materials themselves:
may take up neutrons. The radionuclides
formed by this process are known as "activation products".
It may therefore be seen that nuclear waste
production is an intrinsic part of the usage of nuclear fuel to
Radionuclides and Damage to DNA
The reason that radionuclides are harmful is
that they are unstable and as they breakdown (or "decay")
towards a form that is stable they release particles and energy
that can cause severe damage to "DNA" (deoxyribonucleic
acid). DNA is the genetic "blueprint" for life and a
particular concern associated with DNA damage is that it can result
For example, the National Radiological Protection
Board (NRPB) (now part of the Health Protection Agency, the "HPA")
"a single radiation track (the lowest
dose and dose rate possible) traversing the nucleus of an appropriate
target cell has a finite probability, albeit very low, of generating
the specific damage to DNA that results in a tumour initiating
Exposure to radiation can be harmful from outside
or from inside.
There are a number of reasons why it is difficult
to predict to predict the harm that would arise due to the radionuclides
that would be created by "new-build" reactors. There
is of course the obvious reason that many of the radionuclides
will be dangerous for hundreds of thousands of years into the
future; and so clearly making predictions on the necessary timescales
would be extremely problematic.
However, another reason which does not
appear to have registered sufficiently strongly with either the
nuclear industry or the regulatory communityis that although
it is the radionuclide which causes the harm, this radionuclide
is carried held within a chemical compoundwhose behaviour
is determined by the surrounding chemical environment. These chemical
effects can result in extraordinary degrees of variation in the
predicted contamination levels.
Prediction of Degree of Harm
The February 2009 Environment Agency (EA) "Criteria
for RadWaste Disposal" document
the Environment Agency's viewin quantitative termsof
the risks associated with radionuclide exposure.
The Environment Agency start from a baseline
(per yearto the person at greatest risk)
of developing either:
and state that this level of risk would arise
from an exposure of:
20 micro Sieverts per year,
Risk levels depend on the chance of something
If the chance of being exposed to the radionuclides
was less than one, then:
the "one in a million" baseline would
be matched with an exposure level that was higher than 20 micro
In late 2007 the German "KiKK" study:
(KiKK stand for Kinderkrebs in der Umgebung von
KernKraftwerken"Childhood Cancer in the Vicinity of
Nuclear Power Plants")
reported a 1.6-fold increase in all cancers
and a 2.2-fold increase in leukemias among children living within
5 kilometres of all German nuclear power stations.
"Childhood cancers near German nuclear
power stations: the ongoing debate"
Published in "Medicine, Conflict and Survival"
1 July 2009 (on-line)
This article indicates that the issue of just
how dangerous exposure to radionuclides is still a matter of some
It is a matter of much concern and upset that
the particular illness that was found near the German nuclear
power stations was leukaemia and solid cancer in children under
five years old.
"Spent nuclear fuelhow dangerous
is it? A report from the project `Description of risk'"
SKB ReportTechnical Report TR-97-13 (March
On page 21 of this report at para 3.5.2: the
following two figures are provided:
(1) the lethal dose is given as 5,000 "milli-Sieverts";
(2) a dose rate of one million "milli-Sieverts"
per hour is quoted
(one year after one tonne of waste fuel has been
taken out of a reactorwhen standing at one metre distance
from the waste fuel rod)
From these two figures it is then calculated
To stand one metre from:
one tonne of waste fuel,
one year after its removal from the reactor
would kill you in twenty seconds.
On page 23 of the NDA "Disposability"
report for Westinghouse "AP1000"
a weight of approximately 600 kilograms per "AP1000"
fuel assembly is quoted. (see Table B4)
The figure quoted for the weight of an "EPR"
fuel assembly is also roughly 600 kilograms.
(See page 29Table B9).
One fuel assembly of either "AP1000"
or "EPR" type fuel weighs roughly half a tonne.
This means that standing next to one
of either of these fuel assemblies could kill you in about a minute.
Although extensive measures are taken to avoid
people coming directly into contact with waste fuel rods (and
so being killed more or less immediately) the fact is that nuclear
power stations do routinely release radionuclides into the air
and the seaand it is know that these can cause cancer.
Putting numbers to the cancer rates is an area
of much controversy.
There is also the fact a significant proportion
of the radionuclides created will be dangerous up to one million
years into the future. Such timescales are beyond our imagination.
In addition to this there is the fact that nuclear
power is the Siamese Twin of nuclear weapons. The same metals
(plutonium and uranium-235) are used, and also many of the same
techniques. If we continue on into the 21st Century with yet more
nuclear reactors, there is a danger that they will be used against
An obvious reason why it is difficult to calculate
the levels of harm that would arise due to the synthesis of radionuclides
in the proposed reactors is that many of the radionuclides will
be dangerous for hundreds of thousands of years into the future.
Clearly making predictions over this timescales would be extremely
It is the radionuclide that causes the harm.
However, generally speaking
radionuclides do not "travel solo" but exist in combination
with other chemical elements to form chemical compounds.
The behaviour of these chemical compounds depends
the chemical elements included;
how they are joined together;
the amount of electrically charged ("ionic")
whether the surroundings are watery or
oilyor solid or gas;
whether the surroundings are simple or
(ie. is the compound just one amongst a "smorgasbord"
of othersor is the chemical system quite simple); and
the surrounding pressure.
These chemical effects can result in extraordinary
degrees of variation in predicted radionuclide behaviour.
(This phenomenon is discussed further below.)
The "Committee Examining Radiation Risks
of Internal Emitters" (CERRIE) was an independent Committee
established by the Government in 2001, following concerns about
the dangers to health associated with radionuclides once they
were inside the body.
In October 2004, the Committee produced a final
report and a Press Release.
In the Press Release,
the Chairman of the Committee, Professor Dudley Goodhead (OBE)
"The main finding of the Committee's
Report is that we have to be particularly careful in judging the
risks of radioactive sources inside the body. The uncertainties
in these internal radiation risks can be large"
Even the process of mining the uranium is dangerous.
Michael Barnes QC who was the Inspector for the Hinkley ( C )
Inquiry at the end of the eighties concluded:
"I recommend that if future proposals
are put forward for further nuclear facilities which would involve
the importing of uranium the applicants should use their best
endeavours to present information to any future inquiry on conditions
for workers and the public in the countries concerned who might
be affected by the mining and processing of uranium for the project.
David Lowryof "Nuclear Waste Advisory
Associates" (NWAA) has written a paper on Uranium mining
looking at the issues of risk and despoliationand also
at the issue of "environmental racism". The paper can
be found on the NWAA web-site.
Further information can be also be found on
the "WISE" web-site on uranium issues:
The Government propose that a future programme
of RadWaste Burial would serve to keep the syntheised radionuclides
from nuclear power out of harms way for timescales far into the
Such an approach has been advocated by the nuclear
industry for many years. For example in November 1978 (just over
thirty years ago) Dr L E J Roberts, Director of the Atomic Energy
Research Establishment at Harwell in Oxfordshire gave a lecture
to the British Nuclear Energy Society (BNES) on the issue of long
term management of the most intensely radioactive wastes "high
level wastes"(or "HLW").
In April 1979 this talk was made available as
On page 19 (Fig 4) a cutaway drawing of the "conceptual"
design of an underground RadWaste burial facility is shown.
The present-day idea for RadWaste Burial is
more or less the same now as it was in the Seventies.
During the intervening period work has been
undertaken in order to establish the degree to which leaks from
such a Burial facility would be contaminated. In the 1990s, the
work that had been carried out to date on this issue was scrutinised
at a Planning Inquiry in Cumbriawhere it was planned to
initiate excavation works for a RadWaste Burial facility.
This Inquiry was an extremely rigorous process,
involving as it did "Proofs of Evidence", supporting
references, witnesses and cross-examination. The Inquiry lasted
for 66 days (from Sept `95 to Feb `96) and was presided over by
a Planning Inspector, who had the assistance of a Technical Assessor.
The Inspectors report was delivered in March
Overall, the Inspector concluded that the Nuclear
Industry should not be given the go-ahead to begin their planned
"in [their] current state of inadequate
The Government accepted the Inspectors conclusions,
and the planned Excavation programme did not go ahead. In the
subsequent period very little additional research work was done.
In October 2009, the European UnionJoint
Research Centre released the following Reference Report:
"Geological Disposal of Radioactive Waste:
Moving Towards Implementation"
Chapter Two of this Report (pp 10-21)entitled:
"The Technical Concept of Geological Disposal"
identifies nearly forty outstanding research areas.
In November (2009) Francis Livens, Professor
of Radiochemistry at the University of Manchester and a Member
of the "Committee on Radioactive Waste Management" (CoRWM)
"In recent years we have recognised where
we do not have relevant expertise,
[concerning radioactive waste management]
and that is a first step towards dealing with
these pressing problems.
We are starting at a very low base along what
will be a long and complex journey. "
Nuclear Reactors are intrinsically linked with
nuclear weapons. Al Gore commented in March 2009:
"For the eight years that I spent in
the White House every nuclear weapons proliferation problem we
dealt with was connected to a reactor programme. People have said
for years that there are now completely different [nuclear] technologies.
OK, but if you have a team of scientists that can build a reactor,
and you're a dictator, you can make them work at night to build
a nuclear weapon. That's what's happened in North Korea and Iran.
And in Libya before they gave it up. " 
On 24 March, Jacqui Smith at the Home Office
warned of the risk of terrorists using nuclear weapons.
and the Home Office referred to a strategy of "prevent, pursue,
protect and prepare".
Nuclear power stations create plutonium
thus the fact that the Government is actively seeking the synthesis
additional plutonium when the Home Office have raised nuclear
concerns is incongruous.
On 17 March 2009 Gordon Brown gave a speech
on nuclear proliferation,
in which he spoke of "capping the production of weapons useable
fissile material". However, there is no question of the fact
that the plutonium from nuclear power stations could be used to
make nuclear weapons.
Bombs can also be made out of Uranium-235, and
a "dirty bomb" (that disperses radionuclidesbut
isn't made out of a nuclear explosive) could be made out of something
that simply contained radionuclides. Euratom (the nuclear part
of the European Union) has a research programme,
which is currently looking at:
"Malevolent uses of radiation or radioactive
The web-site states:
"With new security challenges facing
society, there is a need to develop robust and practical approaches
in response to the malevolent use of radiation or radioactive
materials, in particular to minimise the impact of nuclear and
In October 2009 a nuclear scientist working
on the Large Hadron atom collider in Switzerland was arrested
as it was suspected that he was helping al-Qaeda.. He had worked
in the UK at the Rutherford, Appleton laboratory in Didcot, Oxfordshire.
The first serious reactor accident in the world
took place in the UK, when one of the Windscale
There was also a very serious accident in Chernobyl in the Ukraine
In March 1978, an accident happened in a PWR
at Three Mile Island, Pennsylvania 240 kilometres from New York.
This accident is of particular concern as the "PWR"
reactor type is of the type proposed by EdF.
Tuesday 16th March 2009
Pub: Macmillan (1992)
36 Source: Professor Andrew Blowers of the Open University,
and former member of the government fs Committee on Radioactive
Waste Management (CoRWM). See Nuclear or Not? Does Nuclear
Power Have a Place in a Sustainable Energy Future? David Elliott
(editor) [Palgrave, 2007] Preface (page xviii). Back
Business Green 17th Aug 2010
Sunday Telegraph-18th July 2010
See also-Platts 19th July 2010
Press Release (19th July 2010) ttp://rd.kpmg.co.uk/mediareleases/22235.htm
Nuclear News (19th July 2010)
"Government looks for Public Consensus on Managing Radioactive
Waste"-DEFRA Press Release-12th September 2001, 132/01 Back
A joule is a unit of energy Back
See for example "Radionuclide content for a range of irradiated
fuels"-Contractors Report to Nirex
EEUK, Contract Number: TE2769/74 Doc No: Pcdocs395337v5 Reference
Number: 17503/74/1 Rev. 2
3rd Sept 2002
5.5 PWR, high burnup U fuel ( pp 89-100) Back
The plutonium-once created in the reactor-may also absorb neutron
(s).or break up into two other atoms Back
The initial fission products comprise the chemical elements zinc
(element number 30) to dysprosium (element 66) Back
Two particular activation products of concern are "carbon-14"
and tritium (a radioactive form of hydrogen.) Back
"Risk of Radiation-Induced Cancer at Low Doses and Low
Dose Rates for Radiation Protection Purposes"
(1995) (National Radiological Protection Board)
29 August 2008
Volume 6 , No. 1
For example if there are radionuclides in the atmosphere. Back
For example if radionuclidea have been taken in by breathing,
eating or drinking-or even in a cut. Back
"Geological Disposal Facilities on Land for Solid Radioactive
Wastes. Guidance on Requirements for Authorisation" (Feb
[Ref 111 in DECC doc] Back
page 46 ( para 6.3.10) Back
page 47 ( paragraph 6.3.1) Back
page 47 (para 6.3.15) Back
Environment Agency Disposal Guidance (Feb `09) page 47-para 6.3.17 Back
(NB-"micro"-means one millionth) Back
also para 6.3.17-page 47 Back
page 198 Back
milli = one thousandth-(for defintion of "Sievert" see
"Technical" section at the start of this document) Back
(by reference to Figures 3-8a and b ( See pp 22-23) Back
"AP"-Advanced Passive Back
"Geological Disposal Generic Design Assessment: Summary
of Disposability Assessment for Wastesand Spent Fuel arising from
Operation of the Westinghouse AP1000 "
NDA ( Oct
"EPR"-European Pressurised Reactor Back
"Geological Disposal Generic Design Assessment: Summary
of Disposability Assessment for Wastes and Spent Fuel arising
from Operation of the UK EPR"
NDA Technical Note no.
assuming that the waste fuel had been removed from the reactor
one year earlier and that you were standing one metre away. Back
The exception would be radio nuclides that are part of the inert
(or "noble") gas series. One such example is "radon". Back
See http://www.cerrie.org Back
Press Release, 20th Oct 2004
Professor Dudley Goodhead OBE
Director, Medical Research
Council Radiation and Genome Stability Unit
Goodhead served as Director of the MRC Unit until his retirement
on 30 September 2003. **) Back
"Uranium Exploitation and Environmental racism: why environmental
despoliation and the ignorance of radiological risks of uranium
mining cannot be justified by nuclear fuel production" Response
to consultation on "Justification Application New nuclear
Submitted by the Nuclear Industry Association"
by Dr David Lowry [ Environmental policy and
research consultant ]http://www.nuclearwasteadvisory.co.uk/uploads/5794Uranium%20exploitation%20and%20environmental%20racism,%20submission%20to%20nuclear%20justification%20
"Radioactive Waste-policy and perspectives"
L E J Roberts, Published by the United Kingdom Atomic Energy Authority
(UKAEA) April 1979 Back
McDonald (1997) p277 para 8.56 Back
A very useful source of Background Information on the "Nirex
RCF" decision can be found in an article written by Tom Wilkie
in Prospect Magazine (May 1997) http://www.prospect-magazine.co.uk/article_details.php?id=5050 Back
Authors-W.E. Falck and K.-F. Nilsson
a Committee that advises Government. Back
"Gore on Lovelock, nuclear power and climate change sceptics" Back
"Home Office warns of Nuclear Terror Threat"
UK Parliament 24th Mar 2009
Telegraph 24th Mar 2009
The book "Plutonium-Blessing or Curse" by Herman V.
Henderickx ( Pub: "The Copper Beech" Brussels-Denver
1999) referes to the production of about ten kiliograms of plutonium
per 1,000 kilograms of waste fuel (assuming that the fuel rod
has been in the reactor for three to four years)-[ see page 45.] Back
Speech on nuclear energy and proliferation, Tuesday 17 March 2009
Transcript of a speech given by the Prime Minister, http://www.number10.gov.uk/Page18631 Back
"Managing Plutonium in Britan: Current Options"-Oxford
Research Group "Current Decisions Report" Number 21
(September 1998) pp 9-11 "Will Mixed-Oxide (MOX) Fuel
Make it Easier to Acquire Nuclear Weapons? " Frank Barnaby Back
part of "FP7"-or the 7th Framework Programme Back
See Council of the European Union Press Release -18th December
"Council approves EU research programme for 2007-13"
Updated-16th December 2008 Back
Telegraph 11th Oct 2009
Express 11th Oct 2009
on Sunday 11th Oct 2009
10th Oct 2009
on Sunday 11th Oct 2009
now Sellafield Back
In a "Pile" type reactor uranium fuel rods were bombarded
with neutrons-and transitioned into "fission products"
and plutonium-as is the case for a nuclear power stations; however
no effort was made to use the heat to produce electricity.
purpose of the "Piles" was to produce Plutonium for
nuclear weapons. Back
For more details see the book by Lorna Arnold-"Windscale
1957-Anatomy of a Nuclear Accident" Back