The Justification of Practices Involving Ionising Radiation Regulations 2004
Consultation on the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations
Response to the Consultation from Blackwater Against New Nuclear Group (BANNG)
Introduction – Purpose of this Response
The Blackwater Against New Nuclear Group is a Citizens’ Based Organisation (CBO) focused on the Blackwater estuary in Essex where the proposed Bradwell nuclear power station is located. The purpose of BANNG is to seek 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. BANNG considers that any further nuclear development at the Bradwell site cannot be justified.
BANNG understands that Justification is a generic process and that specific site considerations are to be taken into account during the planning stage. However, we also note that once the Secretary of State has made his decision on Justification the issues considered cannot be revisited. We consider that a number of these issues are both generic and specific. BANNG’s response is argued from a local perspective but relates to the generic issues. The Bradwell site is one of several proposed coastal sites which share a number of common characteristics and, therefore, observations made from one site can be applied generically to a range of sites.
BANNG takes no position with respect to the case for new nuclear power stations set out by government in its White Paper on Nuclear Energy (BERR, 2008) or that made by the NIA in its application for justification of building a fleet of new nuclear power stations in the UK (DECC, 2008b). But, BANNG considers the development of new nuclear power stations at existing sites to be unjustifiable for three reasons:
The economic and environmental detriments at the proposed sites far outweigh any socio-economic benefits
It is irresponsible to develop new nuclear power stations and radioactive waste stores on coastal sites liable to inundation from the impacts of rising sea levels and storm surge
There has been little effort to involve and engage communities likely to be most affected by the detrimental impacts of new nuclear power stations and waste stores.
BANNG has already covered many of the objections to new nuclear build in its response to the consultation on Strategic Siting Assessment criteria (BANNG, 2008). The arguments are applicable both to the SSA and Justification processes.
Socio-economic and Environmental, Detriments
BANNG is not in a position to comment on the Economic Assessment presented in Chapter 7 of the application (DECC, 2008b). However, we would observe that there are considerable uncertainties and that, from experience, there is a tendency for nuclear projects to suffer from appraisal optimism and routinely to overrun costs and construction deadlines. The costs of managing wastes, decommissioning and clean up are very difficult to predict over the very long time-scales involved. Moreover, the opportunity costs of investing in nuclear capacity rather than alternative forms of energy supply or energy conservation could be very high and consequently weaken the case for Justification based on economic benefit.
The NIA in its application claims that there would be ‘significant socio-economic benefits to the local economy resulting from a new nuclear power station’ (DECC, 2008b, p.102). Specifically new nuclear stations will provide around 500 high skill, long term and stable jobs that would be ‘especially valuable in the remote rural communities that host nuclear power stations’ (Ibid, p.102). It is not clear why these benefits would be ‘especially valuable’ in such locations. It is unclear why a massive industrial complex provides more valuable economic benefit in a remote rural location than in, say, a declining industrial area. The claim of benefit to remote areas suggests a rather rhetorical attempt to justify existing locations; it is an assertion, not a justification based on clear evidence. In any case nuclear is not the sole source of potential employment benefits since there will be jobs associated with alternative forms of energy production.
A balanced analysis requires some assessment of socio-economic detriments especially as experienced and perceived in the areas surrounding nuclear power stations. These are likely to be caused by the negative image and anxiety created by nuclear activities associated with radioactive risk. It must be recognised that new build involves high level waste stores which introduce further and longer term risk to most of the favoured sites. This may act as a deterrent to inward investment and have a detrimental impact on existing economic activities such as tourism, fishing and farming. Furthermore, a new build project may have a blighting effect on property values.
The balance of economic benefits and detriments is likely to vary across the area impacted by a new nuclear station according to accessibility, economic activity and so on. They are also likely to vary over time. Whereas the benefits will be mainly associated with the construction and operation of the power station, the detriments are likely to persist well beyond closure so long as radioactivity remains on the site.
The detriments, when measured over time, are likely to be substantial but are difficult to quantify. There has been very little in-depth research on the social and economic implications of major new build. There has been a tendency to rely on the simple assertion that new nuclear will bring a positive benefit in terms of jobs and wealth creation and, consequently, is likely to be welcomed in those communities which have already experienced the benefits of nuclear investment. The research into public perceptions and attitudes that has been accomplished is not related specifically to new build. The study on Living with Nuclear Power (Pidgeon et al 2008 ) portrays the multi-faceted, complex and ambiguous perspectives experienced by local people. It is clear that work is needed on perceptions of economic benefit and detriment.
BANNG considers that the economic and social detriments over the long-term likely to be experienced by the local communities surrounding new nuclear power stations and waste storage facilities must be taken into account in the assessment on Justification. Independent and in-depth research is necessary to determine the balance of benefit and detriment over time.
As we noted in our submission on SSA criteria, over the past few decades environmental conservation has achieved much higher priority and the protection of natural resources, habitats and coastal area has become especially significant. Many of the existing nuclear sites are in locations that are either within or close to areas that are designated as of international or national ecological importance or which possess amenity, cultural or landscape value. The development of mega nuclear power stations and waste stores would seriously compromise the quality and sustainability of such environmentally sensitive areas. Over time the risks to environments are likely to increase as the effects of climate change on sea levels causes inundation to low lying areas in the vicinity of the nuclear power stations.
The NIA concludes that its analysis, ‘shows that the environmental impacts in the identified areas, both individually and in aggregate, would be small. Most impacts would be comparable with or less than those of other large-scale electricity generation’ (DECC, 2008b, p.112). BANNG wishes to challenge this statement on two grounds. First, we do not consider the impacts would be small. The footprint of a new nuclear power station and its associated infrastructures, waste stores, transport routes, transmission towers and power lines etc. is substantial and highly intrusive. The whole complex is likely to have a dominating and detrimental impact in tranquil, rural landscapes. The requirements for cooling water will have substantial detrimental effects on marine ecosystems. Second, we challenge the view that impacts would be comparable to other forms of electricity generation. Nuclear power produces radioactivity which through routine or accidental emissions and discharges to land, air and water can have deleterious impacts on humans and environments. A serious incident could have devastating consequences. Moreover, radioactivity will remain present on sites for a very long period, well beyond the shut down of reactors. The detrimental environmental impact of nuclear power over space and time is likely to be far greater than impacts arising from other systems of electricity generation. In addition the siting of new nuclear stations in environmentally sensitive locations increases the environmental detriments.
BANNG concludes that the long term risks to sensitive environments posed by the proposed development of new nuclear power stations and waste stores in existing locations cannot be justified
Impacts of Rising Sea Levels and Storm Surges
In our submission on SSA criteria we suggested the criteria on flooding and on tsunami, storm surge and coastal processes were inadequate and should be both redefined and exclusionary. We note that, in its response to the consultation on SSA, the government has made no changes to the criteria apart from a shift in categories, placing flooding with tsunami and storm surge and identifying coastal processes as a separate criterion. In our view the substantive issues with respect to the vulnerability of coastal locations have not been adequately addressed. In terms of Justification BANNG is strongly of the view that siting new nuclear power stations and high active waste stores in sites liable to inundation cannot be justified in any circumstances.
This view is based on two considerations; sea level rise and the length of time radioactivity will remain on site.
Sea level change.
There is a marked trend for forecasts to indicate increasing sea level rise. Indeed, in the very short time (four months) since we submitted our SSA response, forecasts have indicated further increases in sea levels. British Energy when undertaking consultations at individual sites relied on the most severe high emissions scenario published by the IPCC, which at the time, including an allowance for storm surge, indicated a rise of 0.9 – 1.7 metres by the end of the century. The most recent suggestions from climate scientists meeting in Copenhagen in March 2009 indicate a mean rise of 1.2m. ranging up to 2m. The worst case storm surge scenario after the 1953 floods was 4.5M. In addition, the coast in southern and eastern England is sinking through isostatic readjustment. The point is that forecasts suggest worsening conditions at a number of sites and consequently an increasing possibility of inundation. Based on earlier forecasts it has been predicted that, by the end of the century, Bradwell and Oldbury will be liable to inundation and Dungeness and Sizewell to erosion (CoRWM).
We believe the continuing upward trend in forecasts of sea level rise and the associated uncertainties call into question the viability of new power stations at several existing sites. There is a need for worst case scenarios to be prepared which are based on the latest forecasts of sea level change and the impact of storm surges. There is little evidence in the application that such work is being undertaken. BANNG considers that the possibility that several sites may become unviable makes the proposal for new power stations at these sites unjustifiable.
Time-scales for nuclear activity
Our view that several sites will become unviable is reinforced when the time-scale over which nuclear activities are likely to remain on site are considered. The nuclear industry’s time-scale appears to be focused on conditions until the end of the century. British Energy indicates that this time-scale ‘covers the lifecycle for consenting, construction, operation and decommissioning of the candidate designs’ (British Energy, 2007, p.4). This suggests a start up date of around 2020 followed by 60 years operation and removal of spent fuel and site clearance within 20 years. This looks an impossibly optimistic scenario at both ends of the time-scale. It is unlikely that all, if any, new stations will be commissioned by 2020. In any case there may be proposals for further stations to come on stream later. There is absolutely no precedent for clearance and clean up within the tight time-scale apparently envisaged. It is far more likely that the time-scale will be extended until well into the next century and possibly beyond. There is, as yet, no long-term solution for the management of radioactive wastes and they could remain in store on site for many decades beyond shut down. Decommissioning and site clean up are heavily dependent on the commitment of sufficient human and financial resources to the task. There is every reason to expect that decommissioning will be a long process as it is proving to be with the first generation of nuclear power stations. Therefore, it will be difficult to justify new build unless it can be satisfactorily demonstrated that nuclear facilities will remain safe, secure and viable for a period of at least two centuries.
The NIA’s application appears to us to be vague and complacent with respect to protection against the impacts of climate change. It is based on the belief that nuclear plant can be defended and adapted to mitigate the impacts of sea level rise and storm surge. However, it would appear this claim is limited to the next century. British Energy states that for each of its sites ‘work to secure site viability through the 21st. century is likely to be entirely feasible using existing engineering knowledge and techniques. Each of these sites is therefore viable for replacement nuclear build’ (Ibid, p.4). BANNG would contest this claim on the basis that new forecasts suggest increasing site vulnerability. The impact of defending nuclear sites on neighbouring coastal areas must also be taken into account. Beyond the next century uncertainties increase and the prospects of maintaining viability of sites will diminish. Therefore BANNG concludes:
Forecasts of sea level change and storm surges indicate a deteriorating situation at several coastal sites preferred for new nuclear build. It will prove increasingly difficult to protect nuclear facilities for the long time-scales they are likely to remain hazardous. Consequently, the location of a new fleet of nuclear power stations at coastal sites cannot be justified.
Consultation and Engagement
Need for more local participation
As a CBO representing the views and concerns of citizens facing the possibility of a new nuclear power station, BANNG is concerned at the lack of effort to engage local communities in the Justification process. We have a number of concerns.
The process requires greater local input
The process itself is remote, obscure and inaccessible. It appears to be conceived as a technical and bureaucratic internal dialogue between the applicants (the nuclear industry), government (as Justifying Authority) and, presumably, regulators and other interested stakeholders. Although it is a generic process, inputs from a local perspective may prove insightful. Yet, there is a general lack of awareness of the process. We have discovered, for instance, that some local authorities either are unaware of the process or do not think it relevant to them. Yet, justification raises issues of the utmost importance to communities which may eventually host new nuclear power stations.
The process should be more proactive and participative
BANNG considers much more effort is needed to ensure that a wide range of stakeholders and citizens organisation are informed and involved in the Justification process. We are not entirely clear how the process has been promoted but would
observe that reliance on websites or formal communications (to local authorities, for instance) is insufficient.
The form of participation is also important. It is insufficient to invite responses to the consultation document. To gather a fuller perspective it is necessary to undertake in-depth research on community and stakeholder views and attitudes and to hold deliberative events.
The process should encourage relevant stakeholders to participate
There is a tendency for stakeholder participation to be selective, relying on certain categories of stakeholder. These include local authorities, regulatory and advisory bodies and nuclear interests. Expert input tends to come from consultants engaged in nuclear issues and local perspectives are provided by site stakeholder groups who are not necessarily representative of local opinion and whose remit is focused on decommissioning rather than new build. Organisations such as BANNG tend not to be invited or urged to participate. A balanced perspective on the many issues raised by Justification would require a much broader participation than is likely to occur.
Therefore, BANNG urges government to broaden the basis of participation in the Justification process by including a wider range of local community interests and encouraging more deliberative forms of engagement.
Need for greater openness and opportunity to participate
BANNG is concerned that the Justification process may appear premature and that its outcome is largely predetermined. It seems premature in the sense that the decision on Justification will be made before other relevant processes, notably the GDA, have been completed. In any case, the timetable for consultation is very compressed with a decision expected by the end of 2009 (see DECC, 2009, Figure 1, p.67). The process seems predetermined in the sense that, as Justifying Authority, the Secretary of State acts as both judge and jury in the case. The government has declared its singular intention to promote the development of new nuclear power and it is therefore unlikely that the Secretary of State, will deny his own policy. Indeed, it may be said that the Secretary of State’s role prevents an open and disinterested process and thereby undermines public confidence in a fair outcome.
BANNG believes it is in the public interest that the process of Justification is opened up to wide-ranging and independent debate. We, therefore, call for an inquiry to be held as provided for in the regulations. We recognise that the decision whether to hold an inquiry depends on the circumstances of each individual case. However, we note that an important consideration may be the extent to which the public have an opportunity to engage in the process. For reasons we have set out in this response we consider that the opportunities for engagement in the Justification process are very limited.
BANNG considers it to be in the public interest that an inquiry should be held to provide an opportunity for an open, independent and searching review of the issues involved in the decision whether to justify new nuclear power stations.
Blackwater Against New Nuclear Group, March 19 2009
BANNG (2008) Consultation on the Strategic Siting Assessment 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 (BANNG), November
BERR (2008) Meeting the Energy Challenge: A White Paper on Nuclear Power, Department for Business, Enterprise and Regulatory Reform, CM 7296, TSO, January
British Energy (2007) Climate Change and Replacement Nuclear Build, November
DECC (2008a and b), The Justification of Practices Involving Ionising Regulations 2009, Consultation on the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations,
– 2008a Volume 1: Consultation Document
– 2008b Volume 2: Appendix B: Copy of the Application
Department of Energy and Climate Change, December
DECC (2009) Towards a Nuclear National Policy statement, Government response to consultations on the Strategic Siting Assessment process and siting criteria for new nuclear power stations in the UK; and to the study of the potential environmental and sustainability effects of applying the criteria, Office for Nuclear Development, January
Pidgeon, N., Henwood, K., Parkhill,K., Venables, D. and Simmons, P. (2008) Living with Nuclear Power: A Mixed-methods Study, SCARR, Cardiff University and University of East Anglia, September