ENVIRONMENT AGENCY GENERIC DESIGN ASSSESSMENT
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 BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
The Blackwater Against New Nuclear Group (BANNG) is a Citizens’ Based Organisation (CBO) formed in 2008 with the aim, ‘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 has already responded in detail to various consultations on Strategic Siting Assessment, Nomination of Sites, Justification, National Policy Statements on Energy (EN-1) and Nuclear Energy (EN-6) and the Fixed Unit Price for Waste Management. We have also presented written and oral evidence to the House of Commons Energy and Climate Change Committee on the NPSs. A full list of our responses is given in the Annex. They contain matters relevant to this response. We have maintained contacts with DECC, CoRWM and attended workshops held by the regulatory authorities in respect of the GDA. We have consulted local authorities and other decision makers. Part of our work has been to raise public awareness of the issues presented by proposals for one or more new nuclear power stations in the Blackwater estuary.
In responding to this consultation BANNG has three primary concerns. The first is the nature of the consultation itself and its lack of accessibility to or engagement with a wider public. The second is a concern that the GDA is, in part, premature leading to possible problems of pre-emptive decision making. The third is a substantive concern that the GDA fails to take sufficiently into account the site specific issues that are raised in the application of generic principles. In particular, there remain areas of great uncertainty that should be recognised and act as a constraint on the consenting process at individual sites. The following response deals with each of these concerns in turn.
It should be noted that our response relates to both the reactor designs considered. We note there are some characteristics that are specific to one or other design but our concerns relate to both unless indicated otherwise (our references refer for convenience to the AP 1000 document unless otherwise indicated). Our response is not organised in terms of the questions presented in the documents but we shall refer to individual questions where appropriate.
2.0 GDA Consultation Process – Technocratic and Inaccessible
In previous consultation responses BANNG has strongly criticised the inadequacy of the consultation processes used so far. Despite obvious efforts we consider earlier government consultations have failed to achieve greater openness, transparency and participation. We consider them to have been too burdensome, unmanageable, inaccessible, unfair and failing to engage with a wider public. We consider that this consultation is similarly flawed.
We recognise that the GDA is a very technical process and that the regulators have made a considerable attempt to engage with some stakeholders. The workshops held for stakeholders have been helpful and demonstrated a willingness to achieve openness. But, the audience has been very restricted, confined to groups and interests which already have some command of the subject. In this situation nuclear interests tend to be predominant.
The consultation documents state that, ‘We want to hear from members of the public, industry, non-Governmental organisations (NGOs) or any other organisation or public body (p.11). Despite the claim to seeking a wide audience, the nature and format of the consultation is inaccessible, forbidding and technocratic. It is likely to elicit responses from industry and competent government bodies but it is difficult to see how a wider public including those most likely to be affected by proposals for new nuclear power stations will be embraced. An opportunity has been missed to engage with the general public and with local communities around proposed nuclear sites and BANNG believes this is a serious omission.
The GDA contains matters of considerable public interest and on which a wider public needs to be informed. In particular there is widespread ignorance among the public as to the nature of the proposals. There is little conception of the overall scale and impact of the proposals. The public is unaware that it is proposed to store spent fuel and ILW on sites for a period possibly of around 160 years.
We consider it is in the public interest to provide the general public and particularly the communities around the listed sites with a clear understanding of the scale, nature and impact of the processes envisaged in the development of the AP 1000 or the UK EPR. In order to achieve an effective public consultation, BANNG believes the regulators should undertake a process that seeks to inform, engage and encourage a response to the GDA from a wider public including local communities potentially affected by proposals for new nuclear power stations. We suggest this is done before any final decision is taken on the acceptability of the proposed designs.
3.0 GDA Process – premature and pre-emptive
We note that the EA has issued draft interim statements of design acceptability subject to ‘GDA Issues’ (3 for the AP 1000 and 2 for the UK EPR) for both the designs under consideration. We note also that even after acceptance ‘parts of the design may continue to be developed and technical issues could arise that need to be addressed’ (p.19). We also understand that the acceptability is conditional on the outcome of this consultation.
BANNG is most concerned that a number of technical issues may not be resolved before acceptance is granted. We also consider there is a serious deficiency in some of the design proposals, lacking either sufficient information on which to base a judgement or revealing uncertainties that are unlikely to be resolved before a final regulatory acceptance is granted. We believe this to be especially the case with respect to the long-term management of radioactive waste on sites and notably the GDA Issue on the ‘Disposability of spent fuel following longer term interim storage pending disposal’ (p.146). There are other areas, too, where we feel deficient knowledge is unlikely to be replenished prior to authorisation. Therefore, there is a danger of premature decision-making. We provide further details of these concerns in the following section.
A related difficulty is the sequence of decision-making. We understand it is intended to sign off the GDA during 2011 leaving some issues to be resolved. However, nuclear operators may well apply for permission to develop before the GDA is concluded and certainly before the GDA Issues have been satisfactorily dealt with. It is certainly possible to envisage a situation where permission is granted and development and construction begins before the GDA is fully complete and its implications for siting new power stations remain uncertain. This would be a case of pre-emptive decision-making.
There is also the possibility that preliminary work on prospective sites could be undertaken in anticipation that the GDA issues will be resolved and the designs given approval. This might encourage development which might imperil or destroy important habitats, landscape and historical features. Should design approval not be granted these losses would have been unnecessary. A situation of qualified design approval is likely to encourage investment which carries a momentum which will prove financially and politically hard to resist and thereby render confirmation of approval imperative.
BANNG considers the level of uncertainty and the lack of information or knowledge on some issues are serious deficiencies unlikely to be resolved before final acceptance is required. This is compounded by the possibility that decisions to develop could be taken in advance of finalisation of GDA issues. There is, therefore, the potentially alarming prospect of pre-emptive decision-making leading to premature legitimation of siting new nuclear reactors. BANNG considers that final GDA acceptance must occur prior to the commencement of any proposals for permission to develop.
4.0 GDA – an inadequate basis for implementation
We recognise that the GDA consultation is, by definition, about generic issues. However, there are obvious relationships between the generic and specific which cannot be disentangled and which need to be considered together. BANNG is concerned about the relationship of generic issues to specific sites. In this regard we consider the GDA is inadequate in three respects. Firstly, there are issues of how generic principles are translated into site specific projects that affect all sites. Secondly, there are those issues which may have differential impacts affecting some sites but not others. And, thirdly, there are some site specific issues which have generic implications but which are not considered in the GDA. We deal with each of these in turn.
4.1 Inadequacy of GDA with respect to Management of Solid Radioactive Wastes
This concerns the proposed management of solid radioactive wastes and spent fuel. We have comments relating to both Questions 6 and 7.
Question 6: Do you have any views or comments on our preliminary conclusions
on solid radioactive waste?
It is proposed to manage long-lived solid radioactive wastes (ILW) and spent fuel on site. There are two problems here. The first is that the methods of management are not specified in detail and may be subject to variation. It is assumed that wastes will eventually be disposed of in a geological repository and, in the meanwhile, will be appropriately managed. ILW will be immobilised and encapsulated and stored on site or possibly moved to another (regional or central) store until a repository becomes available.
Beyond this the design details are vague and the regulators are clearly unsatisfied with the level of information provided. In the case of ILW they require ‘more information on the potential for degradation of ILW over the longer term that might affect disposability and safe storage’ (p.85). More information will be required on proposed storage facilities. In particular the risks to workers, the environment and to the population arising from encapsulation, waste transfer and transport needs to be assessed and there is precious little information on these matters. The regulators regard the management of these wastes as a key issue and will be looking in more detail at the plans in its Step 4 assessment. Indeed, it may be said that the information supplied in the consultation document is vague and far too flexible.
Therefore in answer to Question 6, BANNG considers the response by the regulators to be complacent and inadequate. In our view the regulators should call for a much more detailed and robust explanation of proposed ILW storage together with details of the methods and facilities required and indicate that this should be supplied as part of the current assessment and not delayed until Step 4.
Question 7: Do you have any views or comments on our preliminary conclusions
on spent fuel?
Here, too, the regulators are concerned about disposability following long-term storage. Spent fuel will be managed on site pending its removal to the proposed national repository. The designers do not anticipate any new issues that ‘challenge the fundamental disposability of the wastes and spent fuel expected to arise from operation’ of either the AP 1000 or the UK EPR (p.100). However, the regulators stress that they expect to see well before any new nuclear stations begin operation some further information ‘on the properties of high burn-up spent fuel following long term storage’ (p.101). Among these properties are the longer cooling times required and the larger footprint high burn-up fuel may require both in storage and in disposal (Richards, 2008).
We are concerned at the lack of clarity and information on the issue of high burn-up spent fuel. The regulators ‘recognise that detailed and definitive information may not be available until there is direct operational experience’ but expect much earlier than that ‘to see evidence of sufficient progress to provide reasonable confidence that any issues are likely to be manageable’. BANNG regards this response as totally inadequate and equivocal. It should be axiomatic that more than merely ‘reasonable confidence’ is necessary in the management of spent fuel prior to its creation.
BANNG believes that detailed design proposals for the management of spent fuel must be prepared and accepted before authorising the operation of new nuclear power stations. ‘Reasonable confidence’ in spent fuel management proposals is an inadequate requirement. The regulators must have full confidence in the proposals for safe management of spent fuel before proceeding to approve the designs.
There is also a lack of clarity about spent fuel management strategy. There is little specific information on conditioning, storage and transportation to a repository. Rather, a general outline of proposals is offered. The AP 1000 design envisages spent fuel assembly storage in a pool for up to 18 years followed by dry storage below ground. Spent fuel will remain in store for a period of up to 100 years enabling heat decay to a level acceptable for disposal. By contrast the UK EPR strategy appears to support 10 years initial pool storage followed by either wet interim pool storage or dry interim storage in metal casks or in purpose designed vaults. The variety of possibilities suggests that spent fuel management is at a rather rudimentary and provisional stage of development. There may also be other possibilities (not covered in the documents) such as central or regional stores which would raise issues of transportation, transhipment and siting.
BANNG recognises that the regulators are concerned about the disposability of spent fuel following interim storage. BANNG endorses this concern. However, this is not the only matter of concern. BANNG considers the whole section in the documents on spent fuel to be most unsatisfactory, unclear and provisional. We believe more detailed information, greater clarity and fully justified plans on the management of spent fuel are required before the GDA process proceeds any further.
4.2 Inadequacy of Time-scale envisaged in the plans
The question of time-scales is the second problem with respect to the management of radioactive wastes on site. The management of solid ILW and spent fuel is predicated on the eventual development of a disposal facility. The ILW store for the AP 1000 is designed to accommodate 60 years of operational waste with a total design life of 100 years (p.90). This presumably means that stores will need to be refurbished or new stores built to accommodate wastes accumulating on site for up to 160 years. For spent fuel it is assumed the store will be available for up to 100 years to enable sufficient heat reduction required before disposal.
It must be said the whole issue of time-scales for storage is ambiguous. Phrases such as ‘up to 100 years’ lack credibility unless they are related to the anticipated time-scales of reactor operation and subsequent storage. In its NPS on Nuclear Energy (EN-6) the government concedes that wastes may be stored on site for a period of around 160 years (DECC, 2009, p.24), that is until towards the end of the next century assuming the first reactors come on stream around 2020 (60 years operation and 100 years for cooling of final spent fuel arisings suggests around year 2180). Should there be daughter power stations the presence of spent fuel at sites could be much longer.
A further problem is the availability of a national repository. Although the government has stated that ‘it is satisfied that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations’ (Ibid) this amounts to no more than a claim. As we have stated in our submission on the NPSs, this statement is misleading for three reasons:
‘First, the long-term solution of disposal recommended by the Committee on Radioactive Waste Management (CoRWM, 2006) and accepted by government (Defra, 2008) required an intensified programme of research and development before disposal could be implemented. This programme has not yet been undertaken. Second, 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 such participation. Third, the recommendations applied only to legacy not to new build wastes. New build 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 high burn-up fuel which are not addressed in the NPSs.’ (BANNG, 2010a, p.20).
There is, therefore, at this point no certainty that a repository will be available to receive the spent fuel and solid ILW or even that deep geological disposal will continue to be the favoured solution. It must be recognised that it is quite possible that wastes may remain on sites indefinitely, certainly longer than 160 years.
BANNG believes the time-scales indicated for the management of radioactive wastes and spent fuel on site are vague and speculative. It is quite possible that spent fuel and ILW will remain on site for an indefinite period. The design proposals for spent fuel and ILW management are not presented in sufficient detail and with supporting evidence necessary to demonstrate that these dangerous wastes can be managed on site indefinitely. In the light of the fundamental inadequacy of proposals for the long-term management of solid radioactive wastes the GDA should not proceed.
4.3 Differential impact of design proposals on specific sites
The inadequacy of the ‘generic site’ concept
Question 9: Do you have any views or comments on our preliminary conclusions
on the impact of radioactive discharges?
We come now to those generic issues which may have differential impacts affecting some sites but not others. It is not sufficient simply to leave all the details to specific site evaluation. Generic principles that are developed without regard to some general site characteristics may be too unspecific. Conversely, attempts to make generic principles fit every specific eventuality would obviously destroy the concept of the GDA. It is important that the GDA ensures that generic design features are generally capable of being implemented at all sites.
For this reason the GDA offers the concept of a ‘generic site’ for which an assessment of the impact of radioactive discharges can be made. The generic site is defined by the regulators as follows: ‘The characteristics of the generic site should be appropriate to sites in the UK where nuclear power stations might be built and will define the “envelope” of applicability of any statement of design acceptability that we might issue’ (p.108). The idea is to confine the development of generic principles within the constraints of what are ‘realistic’ siting options.
The two proposed designs under consideration have approached the generic site issue differently. Westinghouse have proposed a definition based on information from five coastal sites – Dungeness, Hartlepool, Heysham, Hinkley and Sizewell. From these they compile data on population, exposed groups, habitats, meteorology, terrestrial environment, coastal environment and non-human species to provide an indication of radiological impact.
The Areva EPR proposal for the generic site assumes a coastal site and includes data on population and exposed groups and habitats, non-human species, meteorology, terrestrial environment and coastal environment.
We note that, in both cases, the regulators consider the definitions ‘are appropriate to use in its assessment of radiological impact at the GDA stage’ (p.110). There are two issues of concern here.
1. Exclusion of non-coastal sites. One is that by confining the generic site to coastal locations all other types of location are excluded. This would exclude sites on large rivers such as Owston Ferry on the River Trent which was identified as a potentially suitable site for new nuclear in the Atkins study of alternative sites (2009).
2. Exclusion of Estuarial Locations. By focusing on coastal sites, the generic site does not include estuarial sites where impacts may be more severe through cooling water discharge impacting on marine ecosystems. Impacts on the terrestrial environment are also likely to be different to those experienced in coastal locations. It is noted that the AP 1000 generic site is derived from five coastal sites and does not include either Bradwell or Oldbury, estuarial locations with quite different characteristics to coastal sites.
BANNG considers the concept of ‘generic site’ focusing on coastal locations as derived for the GDA to be inadequate in that it is inapplicable to potential alternative sites to those listed in the NPS or to listed sites that are located on estuaries. The regulators should consider whether to require a generic site that encompasses impacts in non-coastal locations. Alternatively, if the generic sites as defined by the designers continue to be deemed appropriate, the GDA should recommend that non-coastal and estuarial sites should be dropped from further consideration.
The Issue of Cooling Water
Question 10: Do you have any views or comments on our preliminary conclusions
on the abstraction of water?
We note the statement: ‘We have assumed for GDA that the cooling water intake will be from the open sea and that the abstraction will not require licensing (p.121). We also note the conclusion in the GDA consultation documents that the ‘proposal to abstract cooling water only from the open sea is unlikely to require an abstraction licence from us’ (p.121).
It is clear that the designs under consideration for the GDA apply only to sites where cooling water is abstracted from and discharged into the open sea. They do not apply to estuarial locations such as Bradwell which is listed as a potential site in the NPS. As we have pointed out in our response on the NPS consultation, abstraction of cooling water from a shallow estuary is a very different proposition indeed from abstraction from the open sea:
‘A new EPR station of 1.65GW would require a daily intake of 6.22 million tons of cooling water, more than three times the volume required by the former Magnox station on the Blackwater estuary. This volume represents 10% of the total estuary volume of exchange water each tide. Temperature rises of up to 100C are forecast on the south shore in the vicinity of the power station, with a 10C to 20C increase elsewhere. This rise in temperature in the River Blackwater is likely to have a much greater impact on its ecosystem than was the case with the previous station. The larger cooling system will also have to be treated with more biocides to prevent fouling of pipework. These biocides, such as chlorine, sub-react in water to form more complex and potent biocides with increased half-life. Such biocides are likely to further affect the ecosystem on a larger scale than before. The increased volumes and velocity of water will also cause greater scouring of the riverbed, resulting in much larger dead areas than occurred with the previous smaller Magnox station.
It takes ten days to totally refresh the water in the estuary, a very low refresh rate when compared to the open sea. This low refresh rate, together with one tenth of the estuary daily tidal volume passing through the reactor, means that the incidence of damage from cooling water circulation would be far greater than in the open sea, and far more significant than previously experienced. The damage to the marine environment and the fishing and oyster industries dependent upon it is likely to be extensive. It is unlikely that the impacts on the marine ecology could be successfully mitigated’ (BANNG, 2010b, p.3).
It is unlikely that the Blackwater estuary has sufficient capacity to supply cooling water for even one station. If further new power stations are proposed it is likely that cooling towers will be necessary. This would introduce new design issues and potential impacts which are not considered in the GDA analysis.
The GDA fails to take account of the issues of cooling water abstraction in estuarial locations and its likely impacts. It also fails to consider the possibility of cooling towers and their potential impacts in locations where there is insufficient water for straight through cooling. BANNG considers the designs considered in the GDA are inadequate in their application to estuarial locations and that the regulators should indicate that such locations should be removed from the list of potential sites.
5.0 Relevant issues not considered in the GDA
Finally, there are some site specific issues which have generic implications but which are not considered in the GDA. We are concerned with one such issue in particular, the problem of flooding at sites. The consultation documents comment on this as follows:
‘New nuclear power stations are likely to need new or enhanced flood defence structures. A flood defence consent will be needed to construct these but, as flood defence is necessarily site-specific, we have not considered this matter during GDA’ (p.23).
BANNG does not agree that this is just a site-specific issue. Given that the GDA designs assume coastal locations and the listed sites are almost all coastal or estuarial, the issue of flooding is relevant to all sites and, therefore, should be regarded as a generic issue.
Over the time-scales during which there is likely to be a nuclear presence, covering operational, decommissioning and waste management, the impacts of climate change will increase. We commented earlier on the lack of robust waste management plans for the indefinite time-span that is possible on the sites. This problem is compounded by the possibility of inundation resulting from sea level rise, storm surge and coastal processes. Forecasts of coastal change reveal that parts of the Dengie peninsula on which Bradwell is situated will be permanently under the sea within the next century. According to the government the problems of forecasting change mean that ‘it is not practicable to consider beyond 2100’ (DECC, 2009, p.51). In other words, assessments of safety and integrity of systems cannot feasibly be made beyond the next century whereas it is highly probable there will be nuclear activity on floodable sites for up to two centuries.
The Environment Agency in its commentary on the Bradwell site (and others) in the NPS makes the following equivocal statement:
‘The Environment Agency has advised that it is potentially 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’ (our emphasis)(DECC, 2009, p.66).
We believe that the continuing viability of sites is a generic issue and, therefore, should be covered in the GDA. Any circumstances which threaten the integrity of nuclear operations or waste management on sites must be taken into account. Sites that are liable to inundation within the next 200 years must be ruled out. BANNG considers that the continuing integrity of sites is an issue that must be identified and taken into account in the GDA.
6.0 Summary and Conclusions
We have four major concerns with the GDA consultation. First, is the consultation process itself. Given that the decision on design approval is fundamental to the whole future of new nuclear power it is vital that the wider public and especially those communities around the listed sites who are most likely to be affected by the decision are provided with an opportunity to participate fully in the debate and are able to have an input into the decision making process. In our view the consultation process, despite some effort to open it up, has been overly technical, exclusive and not interactive or participative. In consequence nuclear interests enjoy a position of privileged access while the wider public remains uninformed and unaware of the scale and implications (especially for long term waste management) of the proposed reactor designs. We therefore regard it to be imperative that the regulators proactively seek to inform, engage and encourage a wider and participative consultation before proceeding to take any final decisions on the acceptability of the proposed designs.
Secondly, we are concerned about the nature of the GDA process itself. Throughout the documentation it is clear that the regulators are not in possession of all the information needed to determine whether the proposed designs are acceptable or not. This lack of information is especially evident with respect to the management of radioactive wastes where proposals from the designers are lamentably deficient. And yet the regulators are willing to signal conditional approval in the expectation that sufficient information on these matters will be forthcoming. There is, therefore, a presumption in favour of approval that would be difficult to reverse. And it is likely to encourage preliminary development and commitment of financial resources by companies which, in itself, gives momentum to further development. We consider this presumption is not justified and, therefore, that the decision to approve is pre-emptive and likely to lead to a situation of premature legitimation. BANNG is concerned that the regulators have too readily conceded interim statements of design acceptability in advance of sufficient information on the ‘GDA Issues’ to which the decision is subject. We urge the regulators to make an unambiguous declaration that GDA approval will not proceed unless and until detailed, credible and verifiable information and evidence is provided to enable a robust safety case to be made.
Thirdly, we are concerned that the uncertainties are such that much of the necessary information is not, at present, obtainable and is unlikely to be so for some considerable time. In our response we have focused on the issue of radioactive waste management which is clearly of great concern to the regulators also. The documents reveal a palpable lack of information on how wastes will be managed. It is unclear how the wastes will be stored (wet or dry, surface or underground), what packaging and encapsulation facilities are envisaged and what transfers and transport might be required. It seems likely that wastes will remain on sites for a long time although there may be regional or central stores, on which no comment is made. In terms of time-scales, the proposals seem hopelessly vague. Although there is a likelihood of storage on site for up to 200 years (and possibly indefinitely) the proposals do not appear to look beyond about 100 years. There is an expectation that ultimately a repository will be provided to take the long-lived solid wastes. As things stand, there is no site in prospect and there may never be. The safer assumption must be that, in the absence of a long term permanent solution, wastes will remain in store on sites placing a burden on future generations.
BANNG urges the regulators to suspend the GDA process until such time as there is adequate information provided on how the wastes arising from new build will be managed and there is in place a long term management solution that is scientifically robust and socially acceptable.
Our fourth major concern is the relationship of generic principles to more specific siting issues. It is clearly not possible to divorce the generic and specific and we feel that the GDA has barely taken into account the effect of the generic on the specific or, for that matter, the impact of the specific on the generic. The connection becomes manifest when the features pertaining to all the listed sites are considered. The ten listed sites have one thing in common – they are all at or near the coast or on estuaries. The appetite of large new nuclear power stations for cooling water has proved an overriding siting requirement which requires the large volumes available from the sea. Both designs calculate the impacts of radioactive discharges on the basis of ‘generic sites’ based on coastal locations. In this respect we note that estuarial locations have a more limited capacity and the impacts of cooling water on marine ecosystems in such shallow and enclosed locations is liable to be much greater than if discharges occur to open sea.. Therefore, we recommend that estuarial sites should be withdrawn from any further consideration in the GDA process.
All the sites listed are potentially vulnerable to flooding, storm surges or coastal processes, particularly so in the longer term as global warming impacts on climate change and sea level rise. In effect, climate change is a generic issue applying to all sites. The uncertainties about waste management on site will increase over time just as the impacts of climate change on vulnerable coasts are also increasing. It strikes us as imperative that the GDA analysis takes into account the impacts of climate change and that unless the regulators are fully satisfied that nuclear activities can be safely and securely operated on coastal sites for the indefinite future the GDA should not approve any designs for new nuclear power stations.
Finally, BANNG looks forward to the regulators’ response to these concerns and would welcome an opportunity for further discussion and participation in the GDA process.
Professor Andrew Blowers, OBE,
Blackwater Against New Nuclear Group (BANNG)
12 October 2010
Atkins (2009), A consideration of alternative sites to those nominated as part of the Government’ sStrategic Siting Assessment process for new nuclear power stations, Prepared by Atkins for DECC, November
BANNG (2010a), Consultation on Draft National Policy Statements for Energy Infrastructure. Draft Overarching National Policy Statement for energy (EN-1). Draft National Policy Statement for Nuclear Power (EN-6) and Associated Documents. Response of the Blackwater Against New Nuclear Group, 22 February
BANNG (2010b), House of Commons Energy and Climate Change Committee. Inquiry into Energy National Policy Statements. Evidence on behalf of the Blackwater Against New Nuclear Group, 17 January
DECC (2009), Draft National Policy Statement for Nuclear Power Generation (EN-6). London, TSO, November
Richards (2008), Too Hot to Handle, April
Annex list of previous consultation responses from the Blackwater
Against New Nuclear Group (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 9
2009 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 the Blackwater Against New Nuclear Group (BANNG), March 19
2009 ‘Have Your Say’ Government Consultation on Nomination of Sites for New Nuclear Power Stations. Response to the Consultation by the Blackwater Against New Nuclear Group (BANNG), May 14
2010 House of Commons Energy and Climate Change Committee. Inquiry into Energy National Policy Statements. Evidence on behalf of the Blackwater Against New Nuclear Group, 17 January
2010 Consultation on the Secretary of State’s Proposed Decisions as Justifying Authority on the Regulatory Justification of the New Nuclear Power Station Designs Currently Known as the AP1000 and the EPR. Response to the Consultation by the Backwater Against New Nuclear Group (BANNG), 22 February
2010 Consultation on Draft National Policy Statements for Energy Infrastructure. Draft Overarching National Policy Statement for energy (EN-1). Draft National Policy Statement for Nuclear Power (EN-6) and Associated Documents. Response of the Blackwater Against New Nuclear Group, 22 February
2010 The Energy Act. Consultation on the Financing of Nuclear Decommissioning and Waste Handling Regulations. Consultation on a Methodology to Determine Fixed Unit Price for Waste Disposal and Updated Cost Estimates for Nuclear Decommissioning, Waste Management and Waste. Response of the Blackwater Against New Nuclear Group, June 18