Application for Development Consent by NNB Genco (EDF Energy) for Hinkley Point C Nuclear Generating Station and Associated Development
Written Representation on behalf of the Blackwater Against New Nuclear Group (BANNG) made by Professor Andrew Blowers OBE, Chair of BANNG
Unique Reference No. 10013947
In my preliminary statement I indicated that BANNG wished to comment on three aspects that relate to most or all of the eight sites identified in the NPSs. We believe these aspects apply also specifically to Hinkley Point and should be considered by the National Infrastructure Directorate (NID).
1. Flooding and Coastal Processes
A particular concern is that the NPSs are based on forecasts of sea level change up to 2100. It was concluded that all sites have the potential to be adequately protected from flood risk, including the potential effects of climate change. In the case of Hinkley Point the NID will need to be satisfied that the site can be protected up to 2100 on the basis of current projections of the credible maximum scenario in the most recent projections and that the operator has made adequate provision to ensure that this is so. The NID must also be satisfied that the operator could achieve further measures of flood management at the site if future climate change predictions show they are necessary.
Beyond 2100 the situation becomes more speculative although there are several scenarios giving various projections of possible changes in sea levels and associated storm surges and coastal processes. The post 2100 period when there will still be activity on the site relies on periodic reviews of the situation. The intention is that operators may be required to implement further measures if projections show they are needed.
BANNG has little confidence that the potential situation on the coast beyond 2100 has been thoughtfully considered. In the first place predictions (which, as the Government indicates, are really speculations) of sea level rise vary considerably. Predictions of a rise of 2m and beyond have been made and even a 2 metre rise would have devastating consequences on a low-lying coast. Continuation of global carbon emissions at current levels (which, surely, must be included as a worst case scenario) could lead to a rise in temperature of 60C and consequently high sea level rise by the end of the century. This would make extreme weather events like floods and droughts more frequent. The NPSs did, at least, recognise the potentially catastrophic consequences in coastal conditions consequent on climate change. We detect a difference in the assessment of flood risk between EN-1 and EN-6. The aims of policy according to EN-1 are ‘to direct development away from areas at highest risk’ and, where new energy infrastructure is ‘exceptionally, necessary in such areas, policy aims to make it safe without increasing flood risk elsewhere and where possible, reducing flood risk overall’. There seems to be a contradiction between the language of impending disaster in EN-1 and the reassuring notion in EN-6 that the risks when specifically applied to nuclear plants in vulnerable coastal locations are considered to be manageable.
It is recognised in EN-6 that ‘predictions of 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’. It is conceivable that costs of mitigation and the ability to undertake the management may, in certain circumstances, be well beyond the scope of any operator or its successor. BANNG therefore urges the NID to withhold a permit to develop the Hinkley site unless it is convinced there is credible and substantiated evidence that the operator or its successors can undertake, manage and fund the mitigation measures that may be necessary to protect the site and neighbouring coastline under the maximum credible scenarios of sea level change in the years up to and beyond 2100.
2. Management of spent fuel and radioactive wastes
BANNG notes the statement of policy on radioactive waste management in EN-6 that the Government ‘is satisfied that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations. As a result, the IPC should not consider this question. However there may be planning issues relating to the on-site management of radioactive waste which it is appropriate for the IPC to consider as part of the development consent application’.
BANNG considers that there are issues relating to on-site management especially beyond 2100 which are within the NID’s remit and which must be considered before a planning consent may be given. It is quite possible that interim stores of highly active wastes will still be present on site in 160 years from the start of generation of a new power station (60 years operation plus 100 years for cooling of fuel). EN-6 indicates that the very earliest a national repository could receive wastes from new build would be around 2130. But, disposal would occur over many years once initiated. It is quite possible that nuclear activity of some kind is likely to be present on the site until towards the end of the next century. And, as we have seen, predictions of site conditions in the far future are extremely uncertain.
In any case, there is no certainty that a repository will be available since there is as yet no site available and no concept yet agreed. A suitable site for a repository would need to be found using the principle of voluntarism, that is an expressed willingness of a community to participate in a site selection process. Although some interest has been shown, no community has, as yet, agreed to participate in a siting process and, even if an area should come forward the site must satisfy stringent criteria and continue to achieve public acceptance. Nor is it clear what wastes will be accommodated since the original intention was for it to take legacy, not new build wastes. New build as at Hinkley would create more wastes over an indefinite time period and raise different issues to legacy wastes which already exist and, therefore, are unavoidable. Among these issues are technical aspects such as the methods of storage and the management of the different high burn-up fuel of new reactor designs which are not addressed in the NPSs. Given all the qualifications which currently surround long-term waste management policy we face a situation where, at Hinkley Point, wastes maybe present on site indefinitely.
The Environment Agency has advised that ‘it is reasonable to conclude that a nuclear power station within the nominated site could potentially be protected against flood risks throughout its lifetime, including the potential effects of climate change, storm surge and tsunami, taking into account possible countermeasures’ This highly qualified advice needs to be set against the context of the uncertainties that lie beyond 2100. It is unclear just how the wastes will be managed, in what kind of facilities and how much operational effort will be needed and for how long.
A long period of interim storage extending well into the next century presents fundamental problems. It may be assumed stores will be built to last 100 years. Beyond that period it will be necessary to build new or replacement stores quite aside from the repackaging or encapsulation that will be necessary. It may prove particularly difficult and expensive to maintain spent fuel stores over very long time-scales. The creation of a central or regional stores, recognised as a possibility will raise further problems of transportation. The safe management of stores for the indefinite future places a considerable burden of cost, risk and effort on future generations.
There is an implied expectation that there will be the resources, the skilled workforce, the commitment and resolution that will be needed to manage the wastes safely and securely on site in what may be almost intolerable conditions of inundation and storm surges. This puts a blind faith in institutional continuity and social stability which is at odds with the chaotic possibilities envisioned in EN-1. The point is that the future state of the coast and of society in the far future is unknowable and, therefore, we should proceed cautiously on the basis that the worst might happen and plan for that rather than casually allow the future to look after itself. It is irresponsible to consider leaving spent fuel and other highly dangerous radioactive wastes on a site such as Hinkley Point which might prove impossible to defend from natural forces.
On the issue of managing radioactive wastes, BANNG concludes:
· it is not the case that effective arrangements will necessarily exist to manage highly radioactive wastes in the long-term
· arrangements for the long-term storage of wastes on site are unclear
· the time-scale for the long-term management of wastes on site is unknown
· it is unrealistic and irresponsible to assume institutional continuity and social stability will persist into the far future
· it is unethical to place burdens of cost, effort and risk on future generations to cope with the continuing management of wastes in deteriorating conditions
in BANNG’s view it would be difficult, if not impossible, to maintain long-term interim stores into the far future in conditions which are progressively deteriorating. In our judgement it is inconceivable that indefinite long- term interim storage is justifiable.
For all these reasons BANNG believes that it is not possible to claim that indefinite storage of radioactive wastes at the Hinkley site can be managed safely and securely. Consequently, we believe that Hinkley is not a suitable site for the long term management of waste facilities and that consent should be refused for that purpose
Emergency planning processes and procedures
BANNG is concerned that the emergency planning processes and procedures in the event of a major incident at the Hinkley site will prove inadequate and do not provide adequate information or protection to the public within the vicinity of the site and in the surrounding region. The scale of an accident will vary but it is necessary to plan for the biggest credible scenario which might involve a very large population within a wide area of the plant (as, for example, was the case at Three Mile Island in 1979). Preparedness involves the following steps: clear and realistic identification of emergency planning zones; adequate provision of information to the public; planning for eventualities including the possible evacuation of large populations. Present planning is deficient on all counts. Emergency Planning Zones are too tightly drawn to the immediate vicinity of power stations; the public are unaware of the warnings, procedures and precautions that are needed in the event of an accident; and evacuation of large populations is likely to prove impossible.
The Detailed Emergency Planning Zone (DEPZ) is basically confined to the area immediately surrounding the plant. Its extent appears to be a matter for the local emergency planning authority. Beyond this is the ‘extendibility scenario’ which considers various emergency arrangements including evacuation. The purpose of the extendibility scenario 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. This 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.
A further issue is how the public will be informed about what to do in case of an emergency. The public will be provided with specific information which will include information on ‘the behaviour which members of the public should adopt’. 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. In any event the rise of new social media adds a further complication in that it facilitates very rapid communication among those who use it but carries the possibility of misinformation, conflicting information and inappropriate instructions. Hence, the warning system indicated in the NPS seems to be supremely inadequate. Again, in the interests of openness it would be more reasonable if it was conceded that the warning system, though helpful, was unlikely to be successful in every conceivable circumstance.
Finally, substantial populations may have to be evacuated in a major emergency. Around 100,000 people were removed from the area within 20km. of the Fukushima Dai-ichi plant in the period following the earthquake and tsunami. The logistics of moving such large numbers in terms of route capacity, organisation and control, reception centres and recovery procedures all require detailed, credible and robust planning and resources. Furthermore, the plans and procedures that may come into operation need to be explained to the public and exercises undertaken to demonstrate they are implementable.
On the issues of emergency planning BANNG believes that in the interests of protecting present and future publics the NID should have the assurance that effective measures are in place.
The NID needs to be satisfied that Government’s objective ‘to limit the radiological consequences to the public in the unlikely event of a serious nuclear accident’ can be met.
The NID should require should require from the developer the provision of adequate and intelligible information for the general public and from the relevant authorities a plan of coordinated rapid response together with an implementation plan.
We urge the NID to ensure that a credible and implementable statement from the emergency planning authorities on emergency planning is in place before proceeding to grant a permit for the development of a new nuclear power station at Hinkley Point
3rd May 2012