JAPANESE EARTHQUAKE AND TSUNAMI: IMPLICATIONS FOR THE UK NUCLEAR INDUSTRY INTERIM REPORT
HM Inspector of Nuclear Installations May 2011
COMMENTS ON BEHALF OF THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
Purpose of this Response
The Blackwater Against New Nuclear Group (BANNG) is a Citizens Based Organisation primarily concerned to prevent further expansion of nuclear activities at the Bradwell site in Essex. Its aim is to protect the people and environment of the River Blackwater estuary and its surrounding area, now and in the future, from the risks and dangers of radioactivity by preventing the further development of nuclear activity in the estuary. An integral element of this is to support the early decommissioning and clean up of the existing closed Magnox reactor on the Bradwell site. However, BANNG has also taken a broader view on the development of new nuclear stations and has responded in depth to eleven of the government’s consultations covering strategic site assessment, national policy statements on energy, justification, financing of decommissioning and waste disposal, justification, disposition of plutonium stocks and generic design assessment (GDA). We have made a response on the GDA which covers issues relevant to the Interim Report on Japan and this is attached for reference (BANNG, 2010).
We have taken the opportunity presented by the Interim Report of the Chief Inspector of Nuclear Installations (Weightman Report) to register our concerns about the vulnerability of coastal sites such as Bradwell and the neighbouring communities in the event of a serious accident. We are particularly concerned about the potential impacts of flooding and coastal processes, the problems of managing radioactive wastes on site into the far future and the inadequacy of emergency planning procedures in the event of a serious accident. These are all issues which we have raised on many occasions in our responses to Government. The Japanese disaster provides a tragic demonstration of the catastrophic consequences that might befall nuclear power stations and radioactive waste stores located on vulnerable sites.
Interim report – overall tone and conclusions
We are disappointed with the overall tone of the Report. Its analysis provides a detailed and alarming picture of the combination of natural forces (the tsunami) and failure of safety systems (inadequate cooling mechanisms in particular) which led to the shutdown of a substantial portion of Japan’s nuclear electricity production, the evacuation of a large surrounding population and radiological impact on workers and the environment. However, in drawing lessons for the UK, the Report emphasises the differences between UK plants and safety systems and the impossibility of the Japanese circumstances being replicated here. This supports a narrative that argues for review of safety systems and improved safety measures but basically does not challenge existing policy for the building of new nuclear power stations mainly in low lying locations. There is an air of business-as-usual in the Report that, in our view, goes some way to reinforcing the complacent siting policy being pursued by the Government. We would urge the final report to take a more considered and responsible tone in emphasising the very serious consequences that could occur in the event of an accident at coastal locations.
It is self-evident that the conditions experienced last March at Fukushima could not happen here. That is not the point. The point is that catastrophic accidents can and will happen somewhere, sometime. We have already experienced a number of major catastrophes (Magdanek in the Urals, Chernobyl and now Fukushima), some near misses (e.g. Sellafield, Three Mile Island) and a host of incidents some significant (Sovacool, 2010, 2011) for it to be evident that accidents, though exceptional, are also ‘normal’ (Perrow, 1999). Accidents are inevitable in systems as complex as nuclear power stations especially when potentially combined with exceptional natural forces. The fact that such systems must be routinely maintained over very long time scales in changing natural and social conditions increases the risks. Over time it becomes increasingly difficult to predict and, therefore, to protect people and the environment against the effects of a combination of adverse circumstances. An uncertain future becomes eventually an unknowable future.
We recognise that, for the present, the Government is intent on developing new nuclear power stations. However, the lessons of Japan should urge far greater caution in siting these stations on coastal sites where conditions in the far future are impossible to foresee. We find the statement in the Interim Report that ‘There is no need to change the present siting strategies for new nuclear power stations in the UK’ (p.68) unreasonable, irresponsible and incredible. We urge that this statement be reviewed and revised in the final report.
Problems with coastal locations
A combination of overwhelming natural forces and failure of safety systems is altogether possible at some time at coastal locations. In our submission on the GDA we pointed out that nuclear facilities and notably nuclear wastes would be stored on sites for an indefinite period. We were concerned that the design assessment was ‘vague and speculative’ on the issue of managing spent fuel and other wastes on site into the far future in conditions that are unknowable. We were also concerned that the GDA’s ‘generic site’ concept focused on coastal locations and was, therefore, inapplicable to non-coastal locations, such as those on estuaries like Bradwell. This mirrors the Government’s claims (in its NPSs) that there are no realistic alternatives to the eight coastal sites currently considered to be potentially suitable for new nuclear stations. In our GDA submission we commented on the issue of flooding at coastal sites and the equivocal response of the Environment Agency to the problem of effective protection through an indefinite lifetime. We concluded that the continuing viability of sites is a generic issue and any circumstances which threaten the integrity of such sites must be taken into account. We urged that ‘Sites that are liable to inundation within the next 200 years must be ruled out’ (BANNG, 2010, p.10). We reiterate that position.
In the case of Fukushima Daiichi it is clear that the height of the protective barrier was inadequate against the tsunami; ‘the predicted values have fallen some way short of the actual values’ (p.36). Fukushima is an ageing plant and the concatenation of circumstances that befell it last March could not have been foreseen or even imagined forty years ago. This clearly illustrates the problems of making predictions in the face of increasing uncertainty. We simply have no idea what the physical conditions on Britain’s coastline will be like during the next century let alone the technological, social, political and economic conditions that may prevail in that far future. Nevertheless the Interim Report confidently relies on the soothing but vacuous pronouncements of the Environment Agency and other authorities. Essentially the advice was that nuclear new build at the nominated sites could potentially be protected from flooding. It is estimated that even a Lisbon 1755 level earthquake which might occur once in a hundred years would only raise sea levels by at most 2m. above high tide level and be accommodated within the other contributors to sea level. However, the Interim Report while accepting these arguments comments that ‘they sometimes lack the level of rigour that might be expected’ (p.40). Despite this reservation the Interim Report concludes that a risk of flooding on unprotected Flood Zone 3 land, such as at Bradwell, ‘is not, in itself, a reason for excluding construction of nuclear plants in such areas’ (p.67). ‘In principle, it should be practicable by design to accommodate such flooding as might be experienced on a particular UK location such as a Flood Zone 3’ (p.67).
We find the conclusion and recommendation relating to flooding rather baffling. On the one hand, the report concludes that flooding risks are unlikely to prevent the construction of new nuclear power stations though detailed consideration may require provision of particular protection (Conclusion 6, p.67). On the other hand, it is recommended that a review of flooding studies is needed to confirm the design basis and margins for flooding and whether there is a need to improve further site-specific flood risk assessments as part of the periodic safety review programme for new reactors (Recommendation 10). We would certainly support this recommendation. But, we believe it should go further. As we indicated in our response on the GDA, we consider siting is both a generic as well as a site specific issue. We consider that the post Fukushima review and the GDA should take into account the fact that all the eight sites ‘potentially suitable’ are on coasts or estuaries and some of them on Flood Level 3 land.
There is a further issue that is wholly ignored in the Interim Report: social stability. It appears to be assumed that social stability and institutional continuity will extend for the foreseeable future, certainly well into the next century when nuclear facilities will still be on site. There is absolutely no basis for such an assumption; indeed, the converse, political and social instability, declining economic performance and the lack of institutional continuity might equally be argued. As we have argued the far future is unknowable. It seems to us perverse and unethical even to contemplate building new nuclear facilities on sites which could be imperiled as a result of natural processes, placing future generations at risk. We believe the final report should be categorical in explicitly recognising the increasing uncertainties and consequent risks to safety of humans and the environment from nuclear facilities on coastal sites in the far future.
Consequences of Accidents – Emergency Planning
The Interim Report sets out the human and environmental consequences of the Fukushima accident. The Report understandably limits its attention to the design and system failures that led to radioactive releases into the environment. The consequences are still ongoing and the full extent of the impacts will only be revealed over a long time. It is known that radiological consequences have occurred on the site and in the surrounding region as a result of airborne and marine releases. As the Report indicates, initially the Japanese authorities implemented a 10km. evacuation zone which was quickly extended to a 20km. radius with a 30km. shelter zone. Radiological monitoring of people and the environment has been conducted and some countermeasures against ingestion instituted. Estimates of the displacement of population suggest that up to 200,000 people may have been affected and it is likely that a substantial number will be unable to return home for some considerable time. Information on likely exposure is unclear. Large areas of the neighbouring environment are likely to have been contaminated.
In many respects the Japanese response appears to have been prompt and effective. In a situation where the country was dealing with the devastation created by the tsunami and resources were overstretched it proved possible to evacuate the population and take countermeasures. The Interim Report suggests there are lessons to be learned for the UK’s emergency planning. It also recommends a review of the UK’s national nuclear emergency arrangements. The Report also notes the parsimonious release of information by the operator of the Fukushima plant and recommends the UK industry and regulators to ‘consider ways of enhancing the drive to ensure more open, transparent and trusted communications, and relationships, with the public and other stakeholders’ (p.63).
While these are laudable recommendations, in our view they do not go nearly far enough. It may be said that detailed emergency planning is not within the brief of this report. However, nuclear safety is not confined just to the prevention of accidents through the design of the plant but also to the protection of the public and the environment from the consequences of an accident should one occur. The potentially affected public need to be informed about the possible consequences of an accident and how to respond. We consider the final Report should adopt a much more rigorous and critical approach to the issue of demographics and emergency planning. In the light of Fukushima we believe changes are needed in the demographic criterion applied to the siting of plants, to the definition of emergency planning zones and to the planning response procedures. In each of these areas we think the Interim report is deficient.
As to demographics the report notes the UK’s ‘prudent approach’ in siting new designs in ‘semi-urban’ locations. ‘It ensures that in the unlikely event of a major radiological release the number of people that may be affected would be limited, and facilitates the implementation of any necessary emergency countermeasures to protect that population’ (p.68). We have commented in previous submissions about the paradox of the semi-urban criterion – if it is safe enough to site a power station in a semi-urban area why is it not safe to place one in an urban area? If it is not safe to put one in an urban area then why choose a semi-urban rather than a remote area? In effect the designation ‘semi-urban’ attempts to limit the population at risk. However, unless the geographical impact of an accident was very limited, the number of people potentially affected at many of the sites chosen for new nuclear stations could be very large indeed. If the area of the Fukushima evacuation zone were to be applied to, say, Hartlepool, Oldbury, Bradwell or Sizewell then the potentially affected population could be in the hundreds of thousands. For reference we append a map which superimposes the impacted area if a similar scale accident occurred at Bradwell (Appendix). Given the widespread impact of the Fukushima accident the semi-urban siting criterion for new nuclear power stations should be abandoned. This would effectively rule out most, if not all, the sites deemed potentially suitable for new nuclear stations.
The area of impact suggests there is a need to reconsider the definition of emergency planning zones. We have previously described the emergency planning arrangements as ‘incredibly vague and insubstantial’ and we remain of this view. The Detailed Emergency Planning Zone (DEPZ) is very tightly drawn and within this potassium iodate tablets are pre-distributed. Beyond this is an ‘extendability scenario’ which considers various emergency arrangements up to 15km. including evacuation. The purpose ‘is to make the local authority and others involved in emergency planning aware of factors which may influence the choice and timing of emergency countermeasures’ (DECC, 2010, p.22). This statement provides no useful information or reassurance about precisely what factors or countermeasures are envisaged. Moreover, there is no information provided on the nature and potential consequences of a release of radioactivity for which countermeasures are needed. In terms of public information it should be made clear under what circumstances and over what distance survival is possible. It should also be stated that there will be situations in which there is little or no chance of survival. This is not intended to alarm the population but to recognise the common public perception of the low probability but high consequence of a major nuclear emergency.
We are also concerned that the guidance to the public is inadequate and expectations of behaviour which the public should adopt are unrealistic. It is scarcely credible that in conditions of emergency the public will behave in an orderly, disciplined and rational way; there may be panic, bewilderment and misunderstanding. Furthermore, within the DEPZ the public will be informed by an automated telephone messaging system while in the extendibility zone they ‘will be alerted by the local media’. It cannot be assumed that everyone will have immediate access to these warning systems or that they will operate with efficiency and swift timing or that they will be fully comprehended in conditions of elevated anxiety. The warning system suggested seems to be supremely inadequate. Again, in the interests of openness it would be more reasonable if it were conceded that the warning system, though helpful, was unlikely to be successful in every conceivable circumstance. In our view there needs to be much more detailed information and guidance on the nature and probabilities of major emergencies arising from releases of radioactivity. There needs to be more reliable and effective means of informing and warning the public. Emergency planning procedures should be honest about the risks and sufficiently flexible to react capably in changing circumstances.
We consider emergency planning and implementation to be a generic and strategic issue, not one that should be left mainly in the hands of local emergency planning authorities. Although there will be local differences in topography, population and land use which influence the local implementation of emergency plans, there are also key elements which should be common to all plans. These include such matters as the speed, timing, nature of response, provision of resources and facilities, coordination and monitoring arrangements. Far too much is left for later consideration at local level. In the wake of Fukushima it should be axiomatic that emergency planning be given a much higher priority and be an integral element in the safety and design assessment for new nuclear power stations. Much greater attention needs to be paid to informing the public so that they may be prepared and able to respond appropriately in the event of an emergency. The lack of detail, direction and realism at the generic level on emergency planning is a serious omission precluding any realistic discussions or debate about the probability and feasibility of public protection in the event of an emergency. We urge that the final report on implications of Fukushima places much greater emphasis on the shortcomings of current planning processes and procedures and emphasises the urgent need for national guidelines to achieve common and consistent standards of protection for the public.
Consideration of social and ethical issues in assessing safety
The accident at Fukushima was a social as well as a physical phenomenon. It occurred as a result of human miscalculation and it had widespread human impact over a large area which will be felt down the generations. Accidents such as Fukushima raise issues of intra and intergenerational equity, whether the risk to present and future generations and the environment can be justified in terms of the benefits to society of electricity generated by nuclear power. Although these broader considerations are beyond the scope of the Interim Report they do demonstrate the interconnections between technical, scientific and social aspects of nuclear safety. They are relevant to questions of siting, social stability, institutional continuity and the sustainability of skills and resources to maintain systems safely and securely in the long term. Some of them are touched on in the Interim Report. There is the need for availability of personnel able and willing to respond in the event of a severe accident. The report recognises the requirement to maximise the provision of knowledge, technical advice and physical support. And the deployment of armed forces, academics and other personnel ‘in the accident response over long periods requires further consideration’ (p.51). Planning responses require a range of skills and knowledge that deal with ‘the emotional aspects of dealing with severe accidents’ and there is a need for ‘exemplary leadership’ (p.77).
Fukushima illustrates the need for integrating different knowledge streams and skills, including those of the social sciences. In particular, openness and transparency require that a range of perspectives is taken into account. Safety is not just a matter of reviewing and improving the physical design of facilities, it is also a matter of achieving public confidence and trust in the technology. Public trust and confidence cannot simply be assumed, it must be demonstrated through open dialogue and mutual understanding. The view that the communities living close to existing nuclear facilities are sympathetic to new build because of the jobs and investment it will bring is scarcely supported by survey evidence. To the contrary there is some evidence that the converse is true, that the local public are concerned about the risks from nuclear generation and the long-term storage of nuclear wastes at sites liable to inundation. We have discussed this evidence in some of our previous submissions to Government consultations (see, for example, BANNG, 2008, 2009, BANNG, 2010).
The design and development of new nuclear power stations raises issues of intra and intergenerational equity. These ethical concerns have long been recognised and some of the key principles have been set out by the IAEA, OECD and other organisations. The work of the first Committee on Radioactive Waste Management (CoRWM) adopted equity (‘To achieve fairness with respect to procedures, communities and future generations’) as one of its strategic principles and ethical themes were an integral input to its work (CoRWM 2006, 2007). Most recently Germany’s decision to phase out nuclear energy in the wake of Fukushima was influenced by an Ethics Commission on a Safe Energy Supply composed of eminent academics (Ethics Commission, 2011).
We conclude that assessments of design and reviews of safety measures should routinely take into account the relevant social, political and ethical perspectives. These include issues of social stability, institutional responsibility and continuity, public and stakeholder perspectives and ethical considerations on intra and intergenerational equity. We suggest that future reviews, as a matter of routine, are overseen by panels including social scientists, ethicists and representatives of public and stakeholder groups.
Professor Andrew Blowers, OBE,
Emeritus Professor of Social Sciences, The Open University
On behalf of the Blackwater Against New Nuclear Group (BANNG)
16 August, 2011
BANNG (2008) Consultation on the Strategic Siting Assesssment Process and Siting Criteria for New Nuclear Power Stations in the UK, Response to the Consultation on behalf of the Blackwater Against New Nuclear Group, November
BANNG (2009) The Justification of Practices Involving Ionising Radiation Regulations 2004, Consultation of the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations, Response to the Consultation from Blackwater Against New Nuclear Group, March
BANNG (2010) Environment Agency, Generic Design Assessment AP1000 Nuclear Power Plant Design by Westinghouse Electric Company LLC, UK EPR Nuclear Power Plant Design by Areva NP SAS Electricité de France SA, Response by BANNG, October
CoRWM (2006) Managing our Radioactive Waste Safely, CoRWM’s Recommendations to Government, November
CoRWM (2007) Ethics and Decision Making for Radioactive Waste, February
DECC (2010) Revised Draft National Policy Statement for Nuclear Power Generation (EN-6), Vol II, October
Ethics Commission on a Safe Energy Supply (2011) Germany’s Energy Turnaround, Berlin, 30 May
Perrow C. (1999) Normal Accidents: living with high-risk technologies. New Jersey: Princeton University Press (first published 1984, New York: Basic Books).
Sovacool (2010) Critically weighing the costs and benefits of a nuclear renaissance, Journal of Integrative Enviornmental Sciences, 7 (2), 105-123
Sovacool (2011) Contesting the Future of Nuclear Power, Singapore, World Scientific Publishing
Appendix – Bradwell and the Fukushima Disaster (Contamination Map)/
Bradwell and the Fukushima Disaster
This map demonstrates the ranges of potential fall-out danger around the Bradwell nuclear power station site. 10 kilometers was the radius of immediate, high emergency evacuation from the Fukushima site. 30 Kilometers is the radius for long-term, compulsory evacuation of all property surrounding Fukushima. The levels of high-levels of actual fall-out would be determined by the winds at the time of any acceident: primarily blowing from the West to South-West, but often blowing from an Easterly direction during summer.