Science & Technology CommitteeWritten evidence submitted by the Department of Energy and Climate Change (Risk 00)
This submission has been prepared for the Committee’s inquiry into risk assessment, communication, perception and tolerability in relation to energy infrastructure, focusing on nuclear power by the Department of Energy and Climate Change.
Introduction
1. The Government has committed to delivering a low carbon and affordable energy mix of renewables, new nuclear and clean gas and coal which will provide continuous low carbon generation and reduce the UK’s dependence on fossil fuel imports. In common with other countries, the UK faces two great risks: the prospect of dangerous climate change which will have unprecedented impacts on global security and prosperity, and challenges to energy security as our current generation of power stations closes and ensuring supplies of energy which are resilient to volatile fossil fuel prices.
2. DECC’s ultimate goal is to deliver clean energy for the future and tackle dangerous climate change. In line with the priorities set out in the National Security Strategy we identify and assess risks to energy assets and networks including from terrorism, cyber attack, international military crises, and natural hazards and major accidents. Working in partnership with industry and regulators we take action to reduce vulnerabilities, and put in place plans and arrangements to respond and recover in the event of infrastructure failure.
3. We believe that nuclear power stations have a vital part in our energy strategy to help ensure a diverse mix of technology and fuel sources, increasing the resilience of the UK’s energy system. Nuclear power is a proven technology able to provide continuous low carbon generation and is forecast to be the lowest cost form of low carbon generation. These potential benefits mean that new nuclear power stations have an important role to play in the UK’s energy future.
4. The Department of Energy and Climate Change (DECC) has a key role to play in several aspects of the UK’s civil nuclear activities. Through the establishment of nuclear regulatory bodies covering safety, security, transport and environmental protection, the Government has set in place the organisations essential to ensure the nuclear industry in the UK is appropriately regulated in compliance with European and international requirements. The regulatory regime applies to current nuclear installations and will apply to any future installations.
5. To further enhance this regime the Government has created the Office for Nuclear Regulation, which will combine the safety, security and transport aspects of regulation for the nuclear industry. DECC, through the Nuclear Decommissioning Authority, is responsible for the decommissioning, clean-up, waste management and eventual disposal of the civil nuclear liabilities created during the public ownership of the nuclear industry. To facilitate new nuclear build in the UK the Government has taken a number of actions: developing the National Policy Statement on sites for new nuclear power stations; Regulatory Justification; Waste and Decommissioning finance arrangements; and Generic Design Assessment of proposed reactor systems.
6. The unprecedented events at Fukushima Dai-ichi in Japan focussed global attention on nuclear power, specifically in relation to its safety and security. Safety is and will continue to be our number one priority, both in relation to existing facilities and potential future plants. Some countries such as Germany, Italy and Switzerland have decided to phase out nuclear power. Alongside other countries such as France, Finland, China and the US, the UK Government has decided to continue with our policy that nuclear has a role in the energy mix now and will continue to do so in the future.
7. Recent polls, including a populus survey conducted in August this year show that support for nuclear power in Britain has risen over the past year, despite the events at Fukushima. A recent Nuclear Industry Association (NIA) YouGov poll (November 2011) has also shown that 77% (risen from 68% in the summer) of those polled agree that “Britain needs a mix of energy sources to ensure a reliable supply of electricity, including nuclear power and renewable”.1
8. Our response to the Committee focuses on DECC’s role in communicating nuclear policy, which includes new nuclear, safety and security, non-proliferation, emergency planning, managing radioactive waste and touches on the themes of the inquiry rather than addressing the specific questions point by point.
Government’s Role in Communicating Nuclear Policy
9. The role for Government is to communicate the role of nuclear in the UK as an essential part of the energy mix, and the benefits that it brings. In particular: that it is a safe and reliable low carbon technology which will help to mitigate the impacts of climate change, help to meet our ambition to be less dependent on imported fossil fuels, and help in providing UK consumers with cost-effective electricity.
10. DECC primarily communicates this through its policy statements and consultations, whether that is on the energy mix and nuclear’s role, or specific nuclear policy such as the Nuclear National Policy Statement or policies on waste and decommissioning. More on this is in the section below.
11. It would be unrealistic to aim for consensus, but we believe it is important that our policy towards nuclear should win widespread understanding, confidence and respect. We aim to do this by:
(a)
(b)
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12. There is an onus on the nuclear industry to build a reputation that instils trust and confidence and provides reassurance on the safety of the nuclear industry, particularly post-Fukushima. However there is a clear role for Government to ensure that the regulatory regime is fit for purpose and to engage with local communities and the public to communicate that nuclear is a reliable and safe form of energy.
13. In the case of Fukushima, it was important that we established the facts before making any decisions on policy. In this regard, the Secretary of State asked that the Chief Nuclear Inspector Dr Mike Weightman report on the lessons learned from Fukushima and the implications for the nuclear industry and new nuclear. This was an independent report.
14. In light of this, we have re-emphasised the importance of the safety of nuclear power and the ongoing need for nuclear as part of the energy mix. Separately, Dr Mike Weightman has presented his reports to media, key stakeholders and the public and the Secretary of State has placed these reports with Parliament.
Specific Nuclear Policy
15. The Government has conducted a number of public consultations which have provided clear facts and evidence-based information on nuclear power to raise awareness of nuclear, both the benefits and the risks. In particular the last administration conducted an extensive consultation in 2007 which led to the Government’s decision in the 2008 Nuclear Power White Paper that nuclear should be part of the energy mix. Government is taking facilitative actions to enable the marketplace to come forward with nuclear energy that will help provide long-term energy security.
16. The policy of these facilitative actions and nuclear policy is communicated through a variety of mechanisms as set out below.
Regulatory Justification
17. The EU Basic Safety Standards Directive requires member states to justify new radioactive practices, that is, to assess whether their benefits outweigh the health detriment they may cause. Justifying two reactor designs, the AP1000 and EPR, was one of the facilitative actions necessary to allow new nuclear power stations to be built in the UK. The Government held three public consultations which respectively covered: the process; the application for each of these designs, submitted by industry; and the Secretary of State’s proposed decisions. The application and the decision documents addressed in detail the issues around the impact of radiation on health, the operation of the regulatory regime intended to keep radiation doses received by people below certain levels, and the Secretary of State’s reasons for concluding that the regulatory regime did this effectively. The Government’s Responses to these consultations made clear concerns raised by the public and stakeholders on health issues related to nuclear and the Secretary of State considered these concerns at length in his decision documents.
18. The decisions were approved by the House of Commons by a majority of 520–27 for the EPR and 517–26 for the AP1000.
The National Policy Statements
19. The Nuclear National Policy Statement provides the primary basis for making decisions on applications to build nuclear power stations, and sets out a list of sites potentially suitable for the building of new nuclear power stations up to the end of 2025. The NPS was subject to an Appraisal of Sustainability, which analyses the environmental, social and economic impacts of its implementation. The NPS was also subject to a Habitats Regulations Assessment, which assesses the impact of the NPS on the integrity of European natural habitat sites. The NPS sets out the potential impacts of building new nuclear power stations, and the Government’s assessment of the potential for mitigating these at the sites in question. The NPS and its associated documents were the subject of a series of public consultations, which included public meetings and exhibitions at all the proposed sites, and public meetings in regional centres. These meetings gave people the opportunity to raise concerns about the impact of nuclear power stations and for officials and regulators to respond. The Government also published detailed responses to the consultations, covering all the points raised. The Nuclear NPS was approved by the House of Commons by a majority of 267–14.
20. The Nuclear NPS also gives planning guidance on health impacts and assesses individual sites and in doing so documents the concerns that residents raised at each site and the Government’s response. This included concerns raised about risk, such as risks of flooding, or risks of health impacts. This gives clarity on how perception of risk has affected the assessment of whether individual sites are potentially suitable or not.
Managing Radioactive Waste
21. DECC is committed to delivering a solution for safe and secure disposal of higher activity radioactive waste, both for legacy and future nuclear wastes. Without credible mechanisms for long-term management of nuclear wastes, the new-build programme will be jeopardised. Government must be satisfied that effective arrangements will exist to dispose of waste from new nuclear reactors.
22. The Government’s policy for dealing with higher activity waste is through geological disposal, coupled with safe and secure interim storage until a Geological Disposal Facility (GDF) is operational. DECC and the NDA’s Radioactive Waste Management Directorate (RWMD) are driving forward the Managing Radioactive Waste Safely (MRWS) programme to implement this policy.
23. The principles of voluntarism and partnership are key in this, working with willing communities to find a suitable site for a GDF. The voluntarism approach involves working closely with local communities to explain the realities of geological disposal, answer questions, address concerns and tackle issues openly in order to deliver stakeholder confidence that decisions are taken for the right reasons and developments will be safe and beneficial to the local community. In particular we have been working closely with the west Cumbrian MRWS Partnership, led by local authorities who have already expressed an interest in the programme, to develop and deliver several rounds of extensive local stakeholder engagement activities, including DECC and NDA officials participation in regular open meetings and community events to explain government policy and answer stakeholder questions and concerns.
Nuclear Safety
24. DECC is accountable to Parliament for safety at nuclear power stations and other licensed civil nuclear sites in the UK. The Secretary of State receives advice on nuclear safety issues from the Office of Nuclear Regulation, currently an agency of the HSE pending legislation to create a separate statutory body.
25. The operation of the UK’s nuclear safety regime is delivered through the ONR who undertake licensing and the day-today regulation of nuclear sites throughout the UK. In its 2009 report on the UK system the IAEA IRRS report noted that “the UK has a mature and transparent regulatory system and advanced review process, which is backed up by highly trained, expert and experienced nuclear inspectors”. The report also noted the UK’s ability to effectively manage safety in the nuclear industry now and in the future, through the proposed establishment of the Office of the Nuclear Regulator, as it stated that “once again the UK are showing world leadership—an encouraging example to all in the world preparing for the challenges of the future”.
26. With the move in October 2011 of the transport regulator for radioactive material from DfT to ONR, DECC has also become accountable to Parliament for the transport of radioactive material by road rail or inland waterway.
27. Through ONR’s reporting and international safety standards, DECC is able to reassure the public and parliament of the UK’s safe and secure nuclear industry. However, it is within ONR’s remit and that of nuclear operators to ensure they are transparent and open in their policy and communicating this to the public. This is a specific recommendation in Dr Weightman’s report of the lessons learned from Fukushima.
Nuclear Security
28. DECC is responsible for the overall effectiveness of the security regime for the UK’s civil nuclear sites. It is crucial that all nuclear facilities and nuclear material are protected against “extreme hazards” including criminal or malevolent acts because of the potential risk to public health and safety, and the environment. Security arrangements are kept under constant review as part of a continuous process to ensure existing arrangements are robust and effective and flexible to respond to any indication of a terrorist threat on a UK nuclear installation or nuclear material in transit. Security arrangements comply with international standards—the Convention on the Physical Protection of Nuclear Material and the recommendations in International Atomic Energy Agency’s regularly updated guidelines, especially the information circular INFCIRC225.
29. DECC works closely with the Office for Nuclear Security (part of the ONR), the independent security regulator, as well as the Civil Nuclear Police Authority and the Civil Nuclear Constabulary (a specialised armed police force), to ensure that security measures at UK civil nuclear sites and for nuclear material in transit are effective. The Nuclear Industries Security Regulations 2003 makes provision for the protection of nuclear material, both on sites and in transit, against the risks of theft and sabotage, and for the protection of sensitive nuclear information.
30. All civil nuclear operators are required to have site security plans setting out the security arrangements for the protection of nuclear sites and nuclear material on such sites. The arrangements cover, for example, physical protection features such as fencing and turnstile access, the roles of security guards and the Civil Nuclear Constabulary, the protection of proliferation-sensitive data and technologies and the trustworthiness of the individuals with access to sensitive nuclear information and material. These arrangements will apply to new nuclear build operators.
31. The UK is committed to nuclear security and to learning from others. In October, an IAEA International Physical Protection Advisory Service (IPPAS) Mission visited the UK to assess our compliance with the International Convention on the Physical Protection of Nuclear Materials and the IAEA’s guidelines on nuclear security The IAEA concluded that the state of civil nuclear security arrangements was sufficiently robust; both in the context of the legal and regulatory framework and how it is implemented at the Sellafield nuclear site and the port of Barrow used for nuclear shipments. The IPPAS Mission team identified many examples of good practice and a number of valuable recommendations and suggestions. DECC is working with the nuclear regulator, Sellafield Ltd and NDA to use this “CONFIDENTIAL” report to ensure that we continue to develop and improve our civil nuclear security regime.
Nuclear Non-Proliferation
32. DECC leads on a number of individual non-proliferation policy areas to support international measures to reduce the threat of proliferation of weapons of mass destruction, largely through its commitments as a signatory to the Treaty on the Non-Proliferation of Nuclear Weapons (NPT) and those arising under the G8 Global Partnership. DECC is also the lead Department for the nuclear and radiological elements of the Global Threat Reduction Programme (GTRP), the UK’s principal programmes of co-operative overseas assistance on nuclear security and wider non-proliferation.
33. It is inevitable that any international developments regarding activities associated with actual or potential weapons of mass destruction will capture, and hold, media attention. DECC works hard with its international partners and agencies to help ensure that press releases and other information on the global efforts to promote safe and secure nuclear operations and materials, and the commitments to which states must adhere, is made fully available, and is accurate. In this regard the website of the IAEA is a major tool. Moreover both DECC’s own website and that of the FCO, and the website of the Export Control Organisation (ECO) in BIS provide respectively, clear information about the UK’s non-proliferation activities and guidance to firms about nuclear sensitive exports.
34. The UK’s GTRP programme publishes an annual report on its activities (online at www.decc.gov.uk/gtrp). DECC’s Press Office also handle one-off matters, such as the UK’s ad-hoc contributions to the IAEA’s Nuclear Security Fund or the signing of bilateral Nuclear Cooperation Agreements.
Emergency Planning and Radiation Monitoring
35. DECC is the lead Government Department in the response to an emergency with off-site effects from a licensed civil nuclear site in England and Wales. As such, one of its responsibilities is to ensure that information is available to the public and media regarding the implications of a nuclear emergency. DECC also contributes to the wider National Risk Assessment (NRA) process led by the Cabinet Office.
36. Under REPPIR (Radiation (Emergency Preparedness and Public Information) 2001) Regulations, nuclear site operators and carriers must share their assessments of reasonably foreseeable hazardous events relating to their work with the nuclear regulator (the Office for Nuclear Regulation). They must also provide people living or working near to nuclear sites with certain prescribed information regarding the potential risks posed by ionising radiation.
37. DECC publishes information on its website regarding the risks posed by ionising radiation. The website (www.decc.gov.uk) contains facts sheets with information on the characteristics of ionising radiation and the effects of exposure to it on human health and dose comparison data. The Health Protection Agency’s website provides further, more detailed, information on the potential health implications, including cancer risks from exposure to radiation. In addition, DECC’s Radiation Incident Monitoring Network (RIMNET) provides gamma monitoring data for inclusion on the publicly accessible EURODep European Union database. DECC also plans to publish regular monitoring updates on its own website shortly.
38. Site operators provide such information in a variety of forms at regular intervals not exceeding three years, often in the form of a calendar. Site operators also make the information available to the wider public by placing copies in libraries, civil centres and other public buildings.
39. In addition, there is information with local communities through Emergency Planning Consultative Committees. These Committees provide a forum for organisations with responsibilities for preparing emergency arrangements in response to events at local licensed nuclear sites to consult, co-operate and co-ordinate these arrangements.
December 2011
1 NIA press release: http://www.niauk.org/NIA-Press-Releases/Industry-poll-shows-continuing-support-for-nuclear.html