Further memorandum submitted by the Stop
Hinkley Campaign
Stop Hinkley is the main local group campaigning
against the continuing operation of nuclear power stations at
Hinkley Point in Somerset, and the proposals for two new reactors.
We have been active since the 1980s, when the last proposal for
a Hinkley "C" power station was made, and were influential
in the closure of the old Magnox Hinkley "A" plant,
which stopped generation in 2000.
COMMENTS ON
OVERARCHING ENERGY
POLICY STATEMENT
(EN-1)
1. Need for new nuclear
The revised NPS (p.8) mentions the recently published
"2050 Pathways" analysis commissioned by DECC. It does
not point out, however, that one of the scenarios in this analysis
envisages a situation where no new nuclear power stations are
built and the UK is instead supplied by, among other things, an
increased proportion of renewable energy.
The NPS also fails to refer to any other analyses
which show how it is possible for the UK to keep the lights on—and
progress towards its low carbon targets—without nuclear.
An example of this is the research published by the "No Need
for Nuclear" campaign[3].
Based on government demand figures, this analysis shows that the
country could meet its expected demand for electricity in the
period up to 2050 with a mixture of rising efficiency savings
coupled with renewables, both small and large scale, and fossil
fuels either used as CHP or fitted with carbon capture and storage.
The report "Zero Carbon Britain 2030"[4]
produced by the Centre for Alternative Technology (CAT) also shows
how Britain can meet the vast majority of its electricity and
heat demand by 2030 with a range of renewable sources. CAT has
specifically responded to the DECC 2050 Pathways analysis, pointing
out, for example, that on offshore wind power it falls short of
even the expectation of the Department-supported Offshore Valuation
Group[5].
2. Intermittency
The revised NPS describes nuclear power as producing
"continuous low carbon generation" and renewables as
"intermittent" and therefore less reliable. However,
nuclear does not have the flexibility of other centralised generation
options, such as gas, which would enable it to work effectively
alongside renewables, nor is it reliably continuous. Britain's
most modern nuclear power station, at Sizewell, was out of action
with an unexpected fault for six months this year (March-September)
and its breakdown also contributed to blackouts across the country
in May 2008[6].
By the same token, increasing proportions of variable renewable
generation, including wind power, are being successfully integrated
into grid networks comparable in size to the UK, for example in
Spain and Germany. In Spain, wind power alone has recently achieved
a record by meeting more than 50% of the country's electricity
demand[7].
COMMENTS ON
NUCLEAR POWER
POLICY STATEMENT
(EN-6)
Radioactive waste disposal
The revised NPS asserts that radioactive waste, including
high activity spent fuel, can be successfully handled based on
international experience (Vol. 2, p.18). However, other countries
facing a similar issue have still not reached the stage of constructing
an operational geological disposal repository. Sweden, for instance,
which has been cited by DECC and the nuclear industry as its role
model, has not even got to the stage of receiving regulatory approval
for its plans. Britain is even further behind, having yet to find
either a clear volunteer community or an acceptable geological
formation. There is therefore no certainty that a disposal route
will be operational at any given point in the future, either for
existing legacy wastes or for the "new build" intake.
Long term storage at the proposed nuclear new build
sites raises major issues of climate change, societal changes
and sea level rise, as well as the continuing integrity of the
waste itself, over periods potentially as long as 160 years. It
is essential that the Infrastructure Planning Commission is enabled
to consider these issues, including the eventual disposal of the
waste, when it comes to examine individual applications for power
stations.
COMMENTS ON
APPRAISAL OF
SUSTAINABILITY OF
NUCLEAR NPS
1. Intermittency
The AoS of the revised Nuclear NPS states (p.39)
that "generation capacity would need to triple because more
capacity would be needed to account for the intermittency of renewables".
This assertion fails to take into account either the experience
of other countries where large proportions of variable renewable
capacity are already installed (see above) or the conclusions
of studies such as that by David Milborrow for Greenpeace—"Wind
Power: Managing Variability", July 2009[8]—which
shows how a "range of technological developments could allow
for a steadily increasing use of wind power and the phasing out
of conventional carbonised fuels as backup technology".
2. Carbon saving
The AoS asserts (p.41) and elsewhere that, even taking
into account construction and uranium fuel supply emissions, nuclear
power emits carbon dioxide in the range of 7-22 grams CO2/kilowatt
hour of electricity generation. This is contested. An assessment
of 103 lifecycle studies of the nuclear fuel cycle by Benjamin
Sovakool from the National University of Singapore[9]
has shown that, even when only the most methodologically rigorous
of these studies were selected, the average lifecycle emissions
from nuclear plants amounted to 66 grams CO2equivalent/kWh of
electricity generation. Although this is less than the estimate
of 112-166g CO2e/kWh reported by Storm van Leeuwen and Smith[10],
it is three times the nuclear industry's upper estimate, and far
worse in terms of carbon emissions than all the renewable alternatives,
including solar PV.
COMMENTS ON
THE NPS CONSULTATION
PROCESS
Stop Hinkley is particularly concerned that the poor
level of public engagement experienced when the first energy NPS's
were issued—over the winter of 2009-10—is likely to
be repeated this time round.
Despite the fact that eight specific locations for
proposed nuclear power stations are listed in EN-6, there has
been no publicly advertised meeting in the vicinity of Hinkley
Point at which local people can raise their concerns about the
revised documents. This was one of the issues which Jim Duffy,
Stop Hinkley Coordinator, raised in the evidence he gave to the
ECC in early 2010 during its previous hearings on the original
NPS's (see www.publications.parliament.uk/pa/cm200910/cmselect/cmenergy/memo/nps/m3902.htm).
It is clear that nuclear power is the subject of the greatest
concern to the public among all the issues raised in the suite
of NPS's and full public engagement is therefore essential.
December 2010
3 www.noneedfornuclear.org.uk Back
4
www.zcb2030.org Back
5
http://offshorevaluation.org Back
6
http://news.bbc.co.uk/1/hi/7422817.stm Back
7
http://www.sustainablebusiness.com/index.cfm/go/news.display/id/19220 Back
8
http://www.greenpeace.org.uk/media/reports/wind-power-managing-variability Back
9
Energy Policy 36 (2008) pp 2940-2953 Back
10
See www.stormsmith.nl Back
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