THE JUSTIFICATION OF PRACTICES INVOLVING IONISING RADIATION REGULATIONS 2004
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 BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
The Blackwater Against New Nuclear Group (BANNG) is a Citizens-based Organisation (CBO) founded in 2008 at West Mersea, Essex. It has a large supporter base from around the Blackwater estuary, where it is proposed to site a new nuclear power station at Bradwell. 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 has five main aims:
to raise public awareness among the Blackwater communities of the potential consequences for health, environment and safety of proposals for new nuclear development;
to identify key issues of concern and to gather credible and responsible research and information to pursue the case against nuclear development;
to challenge any proposals for future nuclear power at the Bradwell site by presenting robust evidence and arguments to local and national decision makers, regulatory bodies, the nuclear industry, non government organisations, the media and the general public;
to support the early and successful decommissioning and clean up of the existing Bradwell nuclear site as an integral element of the long-term protection and conservation of the Blackwater estuary;
to call for an open, transparent and deliberative decision making process in which local communities are afforded full access to all information and involvement in key decisions affecting them.
BANNG has made formal and well informed responses to each stage of the Government’s consultation process: Strategic Siting Assessment criteria; Justification; Site Nomination. It has provided written evidence to the House of Commons Energy and Climate Change Committee and representatives from the Group have appeared twice before the Committee. BANNG has met with local Councils and is in the process of meeting with local MPs.
The Group has sought to raise the public’s awareness of the Government’s proposals for the Bradwell site (including the storage of highly radioactive spent fuel and intermediate wastes at the site until the end of the 22nd. century) through public meetings, newspaper articles, leaflets and the BANNG Petition. Signatures for the Petition, which is still running, have been collected door-to-door on Mersea Island as well as on the beaches and at local fetes. Collectors have also taken the Petition to Maldon, Southminster and Bradwell Village and Colchester. The BANNG Petition is the only large-scale, face-to-face consultation in the country on how local communities feel about the prospect of a new nuclear complex in their midst. BANNG has found that the overwhelming majority of the thousands of people it has approached are against the Government’s proposals.
Call for a Public Inquiry
BANNG responded to the first stage of consultation on Justification (March, 2009) and, along with many others, called for a Public Inquiry. We have had subsequent correspondence with Owen Jenkins on this subject (from March to September, 2009).
The Consultation Document indicates that the Secretary of State still has the question of a Public Inquiry under review ‘and does not propose to make a final decision on holding an inquiry or other hearing until the end of the process’ (DECC, 2009a, p.12, para. 40). Having considered the Secretary of State’s Proposed Decision, BANNG believes that there are many controversial issues that are not adequately resolved and that require further examination and public discussion.
In calling for a Public Inquiry, BANNG considers the process of consultation on Justification to have been inadequate and unfair. In our previous response, we commented on this and urged a broader and more participative process, and encouraged more deliberative forms of engagement, including a wider range of local community interests (see BANNG, 2009). Sadly, this has not occurred. Justification has been treated as a relatively technical process confined to the realm of experts informed by regulators and consultants. It is true that, as indicated in the Consultation Document (DECC, 2009a, p. 11, para. 33) a consultation event was held on 19 January in London and BANNG was represented at that event. Useful as that was in providing background to the documentation and enabling some stakeholders, regulators and nuclear industry bodies to interact with Government officials, it cannot be considered in any way a substitute for the kind of participative approach we and others have advocated. Indeed, the event was by invitation and relatively exclusive. In any event it was held after the Secretary of State had published his Proposed Decision thereby precluding the possibility of influencing that decision.
Further there has been no open scrutiny of the draft Justification decision. The NPSs were examined by the House of Commons Energy and Climate Change Committee. However, any decision that is made following the Justification consultation will not be subject to similar parliamentary scrutiny.
BANNG, therefore, remains of the view that it is in the public interest that a Public Inquiry should be held after the Justification consultation process ends and before a final decision is made by the Secretary of State. This will provide an opportunity for an open, independent and searching review of the issues involved in the decision whether to justify new nuclear power stations.
The Consultation Document on Justification refers to the parallel consultation on the Energy National Policy Statements (NPSs) and the NPS public engagement. BANNG has three comments to make on this. First, the NPS public engagement is on the NPS, not on Justification so the relevance of the reference to it is unclear. Second, the NPS consultation can, in no way, truly be called an ‘engagement’ for all the reasons we have set out in our response to the NPS (BANNG, 2010). And, third, it is evident that, even compared to that on the NPSs, the consultation on Justification is parsimonious in the extreme and, therefore, there is all the more reason to consider all the issues through a Public Inquiry or other hearing. By referring to the NPS ‘public engagement’ it seems the Government is implicitly accepting the inadequacy of its consultation on Justification.
BANNG is strongly inclined to the view that the consultations on the NPSs and Justification should have been fully integrated and not run in parallel. We say this for three reasons. First, there is strong overlap in the issues to be considered. By separating the processes there is a tendency to dilute the impact of arguments. Second, by running separate processes to a tight timetable and at the same time the burden on respondents is immensely increased. Time and resource constraints make it difficult, if not impossible, to give adequate and thoughtful attention to complex issues. Third, separation has resulted in quite different approaches to each consultation, with that on Justification being both limited and exclusive. In particular, local community interests and representative bodies as well as ordinary citizens have not been encouraged in any way to participate in the Justification consultation. This has the effect of diverting attention from the highly relevant, significant and conclusive decision involved in Justification which, if carried through, deprives local communities from challenging the imposition of highly detrimental practices at the sites listed in the NPS on Nuclear Energy (EN-6).
In our response to the consultation on NPS we have set out why we consider the consultation process to be inadequate and unfair and we wish those comments to be taken into account in the context of Justification. In particular we consider the sheer volume of documentation, the short time-scale in which to deliver responses to two consultations (plus a response to the House of Commons Select Committee), the thinly attended and unresponsive format of local exhibitions and meetings and the biased and relatively closed process preclude organisations with limited time and resources from providing the detailed, informed and comprehensive responses they would wish. Under these circumstances, BANNG is doing its best to provide a substantial and well-evidenced response.
Given that the NPS and Justification consultations have been run in parallel and to a short timescale and are in several respects inadequate, BANNG considers that the most satisfactory way for all the issues around Justification to be examined is through a Public Inquiry. This would give local community interests and representative bodies as well as ordinary citizens an opportunity to participate in the consultation process which they have not been encouraged thus far to do.
Preamble to the response to questions
This response intends to address the questions set out in the Justification Response Form. However, BANNG wishes here to make some overall observations on the substance and process of the consultation on Justification which we wish to be taken into account.
BANNG notes that in his consideration of Justification, the Secretary of State has ‘sought to consider the full range of detriments that might be set against the stated benefits’ (DECC, 2009b, p.18, para.2.2). We welcome this approach, particularly as the case against Justification is strengthened when all the detriments (in addition to those relating to health) are taken into account.
In sum, our view is that the benefits in terms of security of supply and carbon reduction are not significant and can be more cost effectively and safely achieved by other means. One estimate suggests that with 10GW of new nuclear, the carbon saving would be 4% (2006, Sustainable Development Commission). Even with a larger capacity of, say, 15 GW, as is apparently being planned by the industry, the carbon benefit would still be relatively modest. This we believe can comfortably be secured through energy efficiency and conservation along with the development of alternative, renewable technologies.
In terms of security of supply, the UK relies on imported supplies of uranium which are likely to become increasingly expensive. With the advent of an international ‘nuclear renaissance’, these supplies may also become harder to obtain and supplies may need to be sought from states with unstable regimes and from low-grade ores that require energy-intensive extraction.
Whatever view one takes of the benefits, in our view they are vastly outweighed by the detriments, in particular to health, the problem of security and the risks and ethical considerations from the need to manage radioactive wastes on site for an indefinite period, certainly extending up to the end of the 22nd century.
BANNG concludes that the benefits from new nuclear are small and can be achieved by other means and that they are vastly outweighed by the range of detriments that are included in the assessment. We, therefore, consider that the Secretary of State should not confirm his proposal to justify the practice of generating electricity by either the EPR or the AP1000 reactors.
Responses to the Consultation Questions
[Note: In our responses we shall treat the two designs together since our comments are applicable to either. We shall refer both to the document for the EPR (DECC, 2009c) and that for the AP1000 (DECC, 2009d) which are, in most respects and for our purposes, the same.]
Question 1 Chapter 3 (Radiological Health Detriment) sets out the evidence for
the potential radiological health detriment arising from the class or
type of practice. It also sets out the Secretary of State’s current
views based on that information. Do you agree or disagree with the
views presently held by the Secretary of State on these matters?
BANNG does not agree with the Secretary of State’s views about the detriment to health. BANNG believes that a fundamental flaw with the Consultation is that it is being undertaken when the number of proposed new reactors and on-site, long-term spent fuel stores is unknown. It cannot, therefore, be known what the radiological health detriment from an undetermined number of reactors will be. The Justification consultation is taking place on ‘new practices’ and the proposed new reactors are not operating anywhere in the world and cannot, therefore, be called a proven technology.
BANNG believes that the benefits from new nuclear build are small and can be achieved by other means – energy efficiency and conservation and the development of alternative, renewable technologies. (This view is fully developed in our response to Question 5.)
Comparing radiological health detriment of the EPR with other nuclear power stations
On the matter of comparison of health detriment of the EPR with other nuclear power stations, in paragraph 3.40 (DECC, 2009c, p. 28), we are told that ‘Several respondents to the consultation felt that more information was needed on the expected radioactive discharges from new nuclear power stations and how these would compare to discharges from existing nuclear power stations’. This seems straightforward: people wish to know the difference between current radioactive discharges (i.e. in 2010) and those expected from new power stations (i.e. from new, unproven reactors).
Although there is a fairly long section on comparisons, BANNG believes that the consultation documents do not provide this information. We note that the new practices ‘should make no significant difference from the point of view of detriment’ (para. 3.41) and that ‘increased burn-up is a feature of the development of PWR fuel, that by the time new nuclear power stations are operating, many existing PWR reactors are likely to [be] achieving the same burn-up level, and that there is very little difference between existing and new nuclear power stations when operating at the same fuel burn up’ (para. 3.45). This tells us nothing about the difference in radioactive discharges that can be expected from future power stations. As the advice on which the statements are based comes from a company comprised of former BNFL Senior Managers, the response is naturally biased in favour of attempting to claim that there will be virtually no difference.
BANNG considers that it is not possible to determine the detriments from these new practices until the number of reactors to be deployed and the level of radioactive discharges from them is known.
Effictiveness of the Regulatory Regime
Our response addresses more extensively the safety record of the nuclear industry and the effectiveness of the regulatory regime under Question 4 (Safety and Security) but we wish to make further comments here.
We note that it is claimed that ‘The UK has a strong safety record with no events having occurred relating to a civil nuclear power station with off-site consequences’ (DECC, 2009c, p. 40, para. 3.99). In our response to Question 4, we refer to an NII restricted report that catalogues 1,676 breaches of safety at nuclear installations in the UK from 2001/02 to 2007/08, half of which were judged by inspectors to have been serious enough to have had the potential to challenge a nuclear safety system (which would, no doubt, have had catastrophic off-site consequences). We also refer to a recent court case involving a leak of radioactivity from a sump at Bradwell for around 28 years, which was discovered in 2004 during decommissioning and kept quiet for 4 years before the Environment Agency brought a prosecution in 2008.
In our response to Question 4, we draw attention to the Joint Regulatory Statement on the EPR Pressurised Water Reactor from the UK (HSE), Finnish (STUK) and French (ASN) regulators which stated their serious concerns about the safety systems of the AREVA EPR. We note, too, that the UK and US regulators have serious concerns about the Safety Shield Building of the Westinghouse AP1000 reactor.
As the regulators have quite rightly made public their serious concerns, we believe that the Justification consultation should not have taken place until these had been resolved and that it is irresponsible for the Secretary of State to claim he is content with the safety of the new practices.
Studies on the impact of radiation on health
The Committee on Medical Aspects of Radiation in the Environment (COMARE) will not submit its latest review of the incidence of childhood cancer around nuclear power stations with reference to the German Kikk Study until after the Justification consultation has taken place (Kaatsch et al 2008). BANNG believes that when the COMARE review is published it should be subject to public examination. We believe that, in the event of such an examination, the evidence from other epidemiological studies must also be taken into account, for example the meta-analysis of 136 nuclear sites conducted by Baker and Hoel (Baker and Hoel, 2007). The 2004 Report from the Committee Examining Radiation Risks of Internal Emitters (CERRIE) must also be taken into account. This found that there could be large uncertainties in official dose estimates from inhaled and ingested radionuclides and urged policy-makers and regulators to adopt a precautionary approach when dealing with exposures to internal radiation (CERRIE, 2004).
BANNG considers that the Justification consultation is premature for two reasons:
· it should not have taken place until the regulators are satisfied that all the problems they have identified with the proposed new practices have been dealt with and the Generic Design Assessment has been fully completed;
· it should not have taken place until COMARE has submitted its review.
BANNG believes that a Public Inquiry would both allow the public to have confidence that the Generic Design Assessment has been fully and properly completed and allow an open and transparent debate on the uncertainties about radiological health detriments through cross examination of the evidence.
Concerns about the radiological health detriment from nuclear power stations in the communities around Bradwell
Much of the opposition to any new nuclear reactor at Bradwell, Essex, rests upon continuing anxiety about the past and future health risks to local populations, as attempts to establish the truth about such risks remain very difficult for ordinary members of the public. Some evidence suggests that there are excess levels of cancer (i.e. above the national average to be expected for a similar population) and higher levels of breast cancer mortality in the Blackwater area arising from the Bradwell power station (Busby and Bramhall, 2002). More recently, the German Kikk study indicates a possibility of higher levels of leukaemia among children living near to nuclear power stations (Kaatsch et al, 2008). BANNG recognises the theoretical and practical problems involved in establishing the nature, incidence and consequence of health risks from nuclear facilities. However, the very complexity of the issue and the suggestive nature of the findings of the research indicate that there are real and valid reasons for concern on the part of the public.
There is also continuing debate about what a safe, low dose of radioactivity might be and the impact of low-level radiation on health which needs to be aired in public.
Given the uncertainties about the radiological health detriment from previous and existing nuclear power stations, BANNG believes that the Government should adopt the Precautionary Principle by not justifying the new practices.
Accumulated health risks to exposed populations
We discuss the health detriment that will be imposed on the future generations expected to deal with the management of highly radioactive waste stores in our response to Question 4.
The consultation documents do not refer to the accumulated health risks to exposed populations which are now expected to host generations of nuclear power stations and highly radioactive spent fuel stores. The 10 sites chosen have nuclear power stations that continue to operate or that ceased operations in the recent past. If new stations are built, the local populations will have been and will continue to be subject to exposure of controlled and uncontrolled doses of radioactivity for many decades. The radiological health detriment arising from the storage of highly radioactive spent fuel at each new site for around 160 years is not discussed in the consultation. Perhaps this is because it cannot be known what will happen over that time period. After all, people living in 1850 could not possibly have envisaged what the world would be like in 2010.
Prior to any development of a new power station and waste store at a specific site, BANNG believes that research must be undertaken to establish the impact of accumulated effects of exposure of populations to controlled and uncontrolled doses of radioactivity over a very long period of time.
BANNG disagrees with the view that the Secretary of State ‘is not bound to consider practices which occur outside the UK’ (DECC, 2009c, para. 3.120). The UK’s nuclear footprint elsewhere in the world is already large and causes detriment to the health of indigenous workers and to environments in other countries. The footprint will increase in the event of nuclear new build.
While current suppliers may have safety regimes in place for uranium mining, this may not be true of suppliers in future. With a significant increase in nuclear build worldwide anticipated, there is the danger that uranium supplies from countries with adequate safety regimes in place for uranium mining will diminish. The UK may then be in the position of having to find supplies from countries which do not have these adequate safety regimes. In the event of uranium having to be obtained from low-grade ores, there will be further health risks to workers and devastation of landscapes.
The potential for terrorist attack and the serious radiological health detriment from this are given short shrift in Chapter 3. There must be a real risk that new nuclear power stations and, perhaps especially, their on-site, long-term, highly radioactive spent fuel stores will provide targets for terrorists. In the event of a successful terrorist attack, the effects of radiological health detriment would be catastrophic and affect a very large area. As stated above, the regulators, not only in the UK but in Finland, France and the US, have serious concerns about the safety systems of the proposed new designs. It is difficult to understand why a Justification Decision can be made before it is known if they would withstand the effects of terrorist attack.
BANNG believes that Justification of the new practices should not be taking place until the public can be assured that the new designs have adequate safety systems to withstand the effects and potential for serious radiological health detriment of a terrorist attack.
Question 2 Chapter 4 (Radioactive Waste) sets out the evidence on the potential
detriment caused by radioactive waste arising from the class or type
of practice. It also sets out the Secretary of State’s current views
based on that information. Do you agree or disagree with the views
presently held by the Secretary of State on these matters?
BANNG does not agree with the Secretary of State’s view that the risk of health detriment from radioactive waste is very small and will remain so up to the point of disposal. We also believe there are matters relevant to the potential detriment that are not considered. We have also set out our views on radioactive wastes in our response to the consultation on the NPS on nuclear energy.
It remains the case that there is no established long-term management route for intermediate and high activity wastes. It is accepted that, in so far as it has to be managed, spent fuel is regarded as a waste. Current policy, following the recommendations of the first Committee on Radioactive Waste Management (CoRWM 1) supports geological disposal as the best available approach within the present state of knowledge. However, CoRWM’s recommendations only apply to legacy wastes. CoRWM also stated that a separate process was required for new build and would need to consider ‘a range of issues including the social, political and ethical issues of a deliberate decision to create new nuclear wastes’ (CoRWM, 2006, p.14). Among these issues would be the size of the potential inventory and the time-scales for disposal. No such process has been undertaken or is in prospect. Instead, the Government claims it is technically possible to dispose of new build waste through geological disposal and that ‘no new issues arise that challenge the fundamental disposability of the spent fuel expected to arise’ (DECC, 2009d, para. 4.42). We would challenge this statement on a number of counts: technical, social and ethical.
Technical Issues. First, we consider that technologically, the new practices present new and different challenges that have yet to be resolved. We are dealing with what, in effect, are new and untried practices including the management of spent fuel for which there is no established long-term solution. We are especially concerned that the new high burn-up spent fuel presents risks and problems of management that must be fully examined before authorisation or justification can be contemplated. The total radioactivity build up is much greater and occurs over a longer time-scale than that from existing practices. We consider that the proposed practices raise a series of unanswered questions concerning risks, costs and detriments that require detailed analysis and consultation.
The documents acknowledge the different characteristics of high burn-up fuels but suggest that these do not constitute ‘such different technical issues compared with nuclear waste from legacy programmes as to require a different technical solution’ (Ibid, para. 4.37). But there are no details of the spent fuel pools and racking, the additional onsite storage facilities, encapsulation plants, emplacement methods or the specification of the shielding to be employed at each stage. Indeed, no decisions have been disclosed about how the operators intend to store the fuel (wet or dry) over the 100 year cooling period required by the NDA before disposal. There is no information on how interim stores that have to last 160 years on sites vulnerable to inundation by rising sea levels are to be protected throughout that period from terrorist attacks.
Our conclusion on the technical issues is that there is insufficient information, on practically all aspects of spent fuel management, including long-term, interim storage and disposal, to justify the Secretary of State’s view on radioactive waste detriments.
Social Issues. The Decision documents state that the Secretary of State is satisfied ‘that the interim storage of spent fuel can and will be carried out in a manner which causes a very low level of health detriment’ (DECC, 2009d, para. 4.57). They also state that he is satisfied ‘that there is a robust process in place to identify a suitable site, and that a GDF will be incorporated into the existing robust regulatory regime’ (Ibid, para. 4.82). In BANNG’s view these are premature judgements. The process for achieving a long-term solution is in its very early stages and there can be no certainty that a repository site will be identified, let alone secured and implemented. As the Justification Decision documents point out there is, as yet, no deep repository developed anywhere in the world for the disposal of high activity wastes. While Finland has made some progress and the process is, at present, moving forward in Sweden and France, the Yucca Mountain project in Nevada, USA has been suspended. In most other countries, including Germany, Japan and Spain, progress towards a repository for higher activity wastes has been slow and intermittent. On this basis BANNG considers there is no long-term management solution for radioactive wastes that is sufficiently advanced or credible to enable justification for a new build programme.
It has now been established, and accepted by Government, that on-site interim storage may be required for around 160 years from the commissioning of a new nuclear power station. It is quite conceivable that spent fuel and other wastes will remain on site indefinitely since no final solution is in prospect and may never be. Even if a repository were to become available, and used for new build wastes, it is still conceivable that sites will not be finally cleared and restored for a period of at least 200 years. It is specious to call storage for 160 years ‘interim’. By most people’s reckoning this is certainly long-term. It should at least be referred to as long-term interim storage.
A long period of interim storage extending well into the next century presents two fundamental problems. One is that it is 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 in the Decision documents (DECC, 2009d, para. 4.50), 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.
The second problem is that the sites for new nuclear stations will become increasingly vulnerable. All the listed sites are in coastal or estuarial locations where forecasts of sea-level rise, storm surges and coastal processes indicate an increasing possibility of severe inundation. The trend in forecasts is towards more frequent and severe events and higher sea-level rise within the 100 year range. Beyond this, uncertainty increases and the situation is likely to get progressively worse. The combination of worsening conditions and longer time-scales for storage could lead to an unmanageable and dangerous exposure to radioactivity for areas near the new build sites, a situation likely to worsen over time. It is noticeable that Chapter 4 of the Decision documents makes no mention of the problem of vulnerability of coastal sites and the consequent increasing risks of health detriments this may cause.
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 long- term interim storage is justifiable.
We would challenge the claim that ‘effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations’ (DECC, 2009b, para. 3.8.2). As we have observed in our response to the nuclear NPS, the statement is misleading for three reasons. First, the long-term solution of disposal recommended by CoRWM1 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 wastes would create more wastes over an indefinite time period and raise different issues to legacy wastes which already exist and, therefore, are unavoidable.
CoRWM1 was clear that any proposals for new build wastes would require a new process which ‘will need to consider a range of issues including the social, political and ethical issues of a deliberate decision to create new nuclear waste’ (CoRWM, 2006, p.14). The Decision documents conflate new build with legacy wastes. Athough the future size and timing of a new build programme is unknown and unplanned, it is claimed that a repository would have the capacity to co-locate legacy and new build wastes. There seems to us no evidence to support this assertion. Moreover, there is no acknowledgement of the fact that the ‘robust process’ to identify a site for a repository applies only to legacy wastes. Thus, new build has been conflated with legacy wastes in terms of meeting scientific and social requirements and it appears that no separate process will be required to test and validate proposals for managing waste from new build.
In the absence of a process for identifying a long-term solution for the management of radioactive wastes from new build, we do not agree with the Secretary of State’s current view that these wastes present a very small risk of health detriment.
Ethical. In the Decision documents the Secretary of State maintains his dismissive stance on the ethical issues surrounding radioactive wastes. He relies on the comparative argument claiming that ‘the detriments likely to arise from not taking action on climate change by investing in low-carbon forms of energy such as nuclear raise more significant challenges for future generations than the detriments likely to arise from the management and disposal of radioactive waste’ (DECC, 2009d, para. 4.145).
We disagree. In our view nuclear energy is likely to be, at best, a relatively short-term option to deal with an emerging energy gap and the need for carbon reduction. Its contribution to both these problems is likely to be small and, we would argue, attainable by other means. But the long-term implications of embarking on a new nuclear programme in terms of risks from radioactive waste are very substantial. We do not think radioactive waste should be considered alongside climate change. Radioactive waste is long-lived and dangerous per se. In terms of the dread it provokes, the dangers of proliferation it harbours and the risks of disease and death it contains, it deserves to be treated independently. Climate change and radioactive waste are difficult to compare not least because of the very long time scales involved with radioactive waste.
It is clear that climate change and nuclear energy raise fundamentally different ethical issues. By suggesting that nuclear new build should be discussed in terms of the need to address climate change, the Government is framing the discussion in a particular way, one that is likely to privilege the case for nuclear energy.
We are concerned that the Secretary of State appears to understate burdens of risk, cost and effort in managing radioactive wastes that a new build programme will impose on future generations. The plant operator is unlikely to be in existence in 100 years, let alone 200 years. It is, therefore, impossible to gauge all the health detriments except to note that monitoring, retrieval, encapsulation and emplacement will be undertaken in the far distant future by generations that will have received no benefit from the practice. These activities will take place in coastal locations that will be increasingly liable to inundation as a result of rising sea-levels and associated storm surges and coastal processes.
This transfer of burdens of cost, effort and worker radiation dose to future generations violates the principle of intergenerational equity and cannot be justified.
Question 3 Chapter 5 (Environmental Detriment) sets out the evidence on the
potential environmental detriment arising from the class or type of
practice. It also sets out the Secretary of State’s current views based
on that information. Do you agree or disagree with the views
presently held by the Secretary of State on these matters?
BANNG is concerned with the way environmental detriments are dealt with, or rather not dealt with, in the Decision documents. We have three concerns.
1. Impacts on Environment. It is stated that environmental impacts of new nuclear power stations are comparable with those of other forms of electricity generation and that they are manageable. We do not agree. Nuclear generation is not comparable but is highly distinctive. It creates dangerous radionuclides which, through routine, accidental or deliberate release can affect humans and the environment. Moreover, radioactivity will remain present on sites for a very long period, well beyond the shut down of reactors. Sites for nuclear power stations tend to be relatively rural and remote and more intrusive as is the case with the 10 listed sites and their demand for cooling water is higher than other large-scale electricity generating systems. 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 the event of a serious accident, the environmental consequences could be catastrophic. We find the Secretary of State’s view that the risks can be managed and minimised (DECC 2009d, para. 5.56) complacent and overly tolerant of the nuclear industry in view of the poor safety records of past management, including that at Bradwell which we have referred to in our NPS response and again under Questions 1 and 4 of this response.
2. Impacts from Environment. It is not only a matter of impacts on environment from nuclear activities but of impacts back from environment of nuclear activities. Changes in environmental conditions over the long time-scales of nuclear activities may threaten the safety and security of the power station and radioactive waste stores. This is especially possible in the coastal locations listed for the deployment of new stations. Yet, the Application states that the impacts of climate change ‘would not materially affect the very low risks from new nuclear power stations as reactor technologies are robust enough to withstand extreme events’ (Ibid, para. 5.11). Given the very long time-scales involved and the increasing uncertainties about environmental changes in the far future it is, in our view, quite impossible to justify the claim. It is possible to envisage a scenario in which whole coastlines erode or become inundated thereby making the defence of nuclear power stations and waste stores a costly, heroic and possibly futile task.
3. Environmental Detriments. In our response on the NPS we have challenged the idea that environmental detriments can be sufficiently mitigated or compensated for. We do not consider Imperative Reasons of Overriding Public Interest (IROPI) should be invoked in favour of nuclear power whatever the adverse environmental consequences. We note that the Decision documents consider that environmental impacts are site-specific in nature and ‘can only be measured at and after the stage when sites are identified and development consent sought and, therefore, fall outside the scope of a Regulatory Justification decision’ (Ibid, para. 5.64). We are disturbed by this decision to exclude these impacts from consideration, on two grounds. First, many of the impacts have a strategic and generic context and are not simply site-specific. For example, impacts on internationally and nationally designated areas can be treated at a strategic level as, indeed, they are in the documentation relating to the nuclear NPS. Other issues, such as the demand for cooling water, landscape impacts and, above all, flood risk seem to us to be matters of concern common to all or most sites. By omitting these at this stage the Secretary of State is reducing the scale of the detriments that need to be considered in Justification.
Our other ground for concern is that by relegating these issues to a later stage, it disenfranchises some stakeholders and citizens from effective participation at an early stage. This problem is compounded by the detachment of Justification from the NPS process. There are points at which the processes become intertwined, at least from the perspective of respondents. We have a situation where environmental impacts are not part of the equation in Justification but are considered only at a later stage when strategic decisions have been taken.
To put these concerns into perspective, we would repeat the comments on sea- level rise and flood risk which we made in our earlier response on Justification. These are generic issues applying, to a greater or lesser extent, to the 10 listed sites. There is a marked trend for forecasts to indicate increasing sea-level rise. British Energy, when undertaking consultations at individual sites, including Bradwell, 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. Indications from climate scientists meeting in Copenhagen in March, 2009 give 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 Sizewell to erosion.
We have stated in earlier submissions that 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. This must be seen as a significant environmental detriment.
In terms of environmental detriments BANNG considers that:
· all potential environmental detriments, including biodiversity, landscape, air quality, soils, water quality and flood risk should be considered within the scope of a Regulatory Justification decision and be subject to examination at a Public Inquiry or other hearing;
· in terms of flood risk, locating new nuclear power stations and high active waste stores in sites liable to inundation cannot be justified.
Question 4 Chapter 6 (Safety and Security) sets out the evidence on the
potential impact of the class or type of practice in terms of safety
and security. It also sets out the Secretary of State’s current views
based on that information. Do you agree or disagree with the views
presently held by the Secretary of State on these matters?
Please also refer to our response to Question 1 (Radiological Health Detriment).
BANNG appreciates that the Secretary of State acknowledges ‘the extent of the risk of detriments to health and the environment that would result from a major accident or terrorist attack at a nuclear power station’ (DECC, 2009c, para. 6.34). However, BANNG does not share the Secretary of State’s belief in ‘the strong record of the nuclear industry in the UK’ (DECC, 2009c, para. 6.34) to mitigate the risk. We, along with others, believe that the regulators are relatively open in their work and attempt to carry out their duties as assiduously as they can but that they are aware of their limitations.
There is ample evidence of very serious breaches of safety at nuclear facilities in the UK. BANNG does not believe that the public should be asked to live with further dangers from new nuclear power stations and their radioactive waste stores for a relatively small carbon reduction benefit, when this could be found from energy efficiency and conservation and development of alternative and benign, renewable technologies.
In June, 2009, it was revealed by The Observer that Mike Weightman, the Chief Inspector of the Nuclear Installations Inspectorate (NII) had written a restricted report for the HSE. The report disclosed that between 2001/02 and 2007/08 there were 1,767 leaks, breakdowns and other ‘events’ reported at all the UK’s nuclear plants. Half of these were judged by inspectors to have been serious enough ‘to have had the potential to challenge a nuclear safety system’. Among them was an accident at Sizewell A in January, 2007, when 10,000 gallons of radioactively contaminated water leaked from a pipe carrying cooling water to a spent fuel storage pond. It was reported that Sizewell was 10 hours away from a major nuclear accident. It appears that the NII’s resources were too stretched to prosecute the operator.
Bradwell itself provides a more recent case. The Environment Agency estimates that from 1976 until it was discovered in 2004, there was a radioactive leak from a sump. This released liquid waste, contaminated with various radionuclides, including tritium, caesium-137 and cobalt-60, seeped into the ground. When discovered in 2004, the leak was kept quiet. The Environment Agency decided, not for the first time for similar offences, to prosecute Magnox South, the operator responsible, in 2008. In February, 2009, the company was fined £400,000 (including prosecution costs) for failure to maintain a sump and for incorrect disposal of radioactive waste. After the court case, the Magnox counsel said: ‘There was never any risk of any harm to the general public and no prospect of the waste ever leaving the licensed site’. However, Dr. Ian Fairlie, former Joint Secretary of CERRIE, reports that tritium is transported extremely rapidly in the environment and is avidly taken up by humans (Fairlie, 2010). As we note above, the Bradwell leak lasted around 28 years. Worryingly, the NII Chief Inspector commented after the court case that the NII could not check everything.
The secrets and evasions surrounding the nuclear industry have made the public mistrustful. The more it finds out about secret reports and the way that the Secretary of State – whose independence in this matter is questionable – is intent on pushing through approval of new nuclear power stations, the more mistrustful it becomes.
In October, 2009, just two weeks before the publication of the consultation documents, the UK regulator (HSE), the Finnish regulator (STUK) and the French regulator (ASN) were sufficiently concerned about the AREVA EPR Pressurised Water Reactor to take the unusual step of issuing a Joint Regulatory Statement including the following:
‘4. The issue is primarily around ensuring the adequacy of the safety systems (those used to maintain control of the plant if it goes outside normal conditions), and their independence from the control systems (those used to operate the plant under normal conditions).
5.Independence is important because, if a safety system provides protection against the failure of a control system, then they should not fail together. The EPR design……..doesn’t comply with the independence principle……’
(V4 Joint Regulatory Position Statement on the EPR Pressurised Water Reactor, HSE, STUK, ASN, 22 October, 2009).
The consultation document published two weeks later stated ‘the Secretary of State notes the preliminary assessments under the GDA process that there are at this stage no safety or security shortfalls that would rule out the construction of the EPR on UK licensed sites’ (DECC, 2009c, para. 6.18). It is of concern that for the purposes of the Justification consultation the Secretary of State is content to believe that ‘at this stage there are no safety or security shortfalls’. If even the French regulator wishes to criticise the AREVA EPR, then the shortfalls must be serious indeed.
There are ongoing problems with the Westinghouse AP1000 reactor, too. The design of the Safety Shield Building does not meet fundamental engineering standards and it is doubted that it would be able to protect the reactor from hurricanes, earthquakes and air crashes. The regulators in the UK and the US are extremely concerned about this.
Although the regulators clearly believe that the two reactor designs are seriously flawed, BANNG notes that they are likely to grant provisional approval with exceptions to be addressed at a later date. BANNG and others believe that the only and proper order of decision making is: approval of the designs; justification of the practices; identification of sites.
Taking the Decision on Justification of these two new practices before the designs are fully approved by the regulators is irresponsible and simply cannot be justified. BANNG believes that the full GDA process should precede Justification otherwise it will not be possible to assess the detriment in advance of decision making on the designs. BANNG believes the public is being asked to take the safety of the new practices on trust and that the only way in which it can be satisfied that the GDA process has been undertaken robustly and fully is to have a Public Inquiry.
Security- Terrorist Attack and Proliferation
Apart from the arrangements for design of the reactors (we note above that both the arrangements and the designs are flawed), the consultation document states that there are a number of specific measures in place to minimise the risks posed by terrorism. These are: an assessment process to identify risks at each nuclear facility; an independent security regulator (the OCNS); the Joint Terrorism Analysis Centre; the armed Civil Nuclear Constabulary (CNC). The documents proclaim that, ‘The OCNS is satisfied with arrangements to guard against terrorism’ (DECC, 2009c, para. 6.23).
Quite aside from the threat to civil liberties posed by a body such as the CNC, the need for draconian defensive measures isolates the nuclear industry from most other energy technologies, especially renewables which achieve a much less offensive relationship to the community. Whatever claims are made about the ability to defend against terrorism, there must always be the possibility, however remote, of a successful breach of security arrangements or attack on facilities.
BANNG considers that the risks of terrorist attack and proliferation have been played down. There is a significant difference between the facilities at the old stations and those proposed for the new and that is that facilities will be required for the long-term storage of highly radioactive spent fuel until the end of the 22nd century, perhaps indefinitely. We believe that this does increase the risk of terrorist attack and proliferation as these stores themselves could become a target. There is no information in the consultation document about the proposed design and construction of these stores.
We note that ICRP Publication 77 states that ‘Waste management and disposal operations are an integral part of the practice generating the waste. It is wrong to regard them as a free standing practice that needs its own justification’ (DECC, 2009, p. 48, para. 41.). As stated previously, BANNG disagrees with this view. However, given that the ICRP does regard waste management as ‘an integral part of the practice of generating the waste’, it should be a requirement of Justification that the design of waste stores which will remain on the sites for at least 100 years longer than the reactors, should be a requirement of Justification. The design of these should be to subject to a process similar to GDA.
BANNG believes that the design of highly radioactive waste stores and other associated facilities should be subject both to a Generic Design Assessment process and to justification.
The consultation document also tells us that the OCNS ‘believes that allowing new nuclear power stations to be built would be unlikely to increase the risks of terrorist attack’ (DECC, 2009c, para. 6.23). BANNG believes that the more nuclear power stations that are built, the higher the possibility of a major accident, terrorist attack and proliferation. A major accident or terrorist attack at Bradwell would have a devastating effect on a very wide area, that could include London. Even if the possibility of a major nuclear accident or successful terrorist attack is considered to be low, should either happen the effects would be catastrophic.
BANNG concludes that the possible detriments arising from a major nuclear accident, a successful terrorist attack and proliferation warrant the further development of nuclear energy unjustifiable.
Question 5 Chapter 7 (Carbon Reduction Benefit) sets out the evidence on the
potential benefit through carbon reduction arising from the class or
type of practice. It also sets out the Secretary of State’s current
views based on that information. Do you agree or disagree with the
views presently held by the Secretary of State on these matters?
BANNG believes that there are other ways in which carbon reduction benefit can be achieved without resorting to the building of new nuclear power stations and the creation of yet more nuclear wastes and, therefore, disagrees with the views of the Secretary of State. We believe that no compelling argument is made for the carbon reduction benefit that could be achieved from the proposed new reactors, partly because the actual number of proposed new stations is not known. The draft National Policy Statement for Nuclear Power Generation is based on an assessment of one at each of 10 new sites but makes clear that this does not rule out the building of more than one.
There is no explanation anywhere in the consultation documents of why nuclear power needs to be part of the energy mix, except statements that it is a low carbon source of electricity ‘with emissions across the entire life cycle comparable to those from wind generation’ (DECC, 2009c, para. 7.5). There is no mention that there are other energy mixes that, without nuclear power and along with energy efficiency and demand management, would contribute to meeting the UK’s carbon reduction obligations. These would not leave a legacy of radioactive wastes, require decommissioning or take many years to build – if resources were diverted to them instead of invested in nuclear.
There are many experts who believe that the UK is favourably placed to exploit renewable technologies. Professor David Elliott, an expert on sustainable technology, states that other European countries find it ‘unbelievable that we are not doing as much as we could’ (Elliott, 2008). As a result, the UK is near the bottom of the European league table for renewables. Elliott provides one possible non-nuclear energy mix and claims that there are others: wave power and tidal current turbines could deliver around 25% of our electricity by 2020 if we pressed ahead with them; new houses are to be zero carbon by 2016; if this works and spreads to existing buildings, 25% of electricity could be saved as well as a big part of heat demand; 16GW of electricity could be obtained from large-scale Combined Heat and Power (CHP) plants; 2GW already comes from on land wind farms and this will increase; other options that could contribute 2GW each are: tidal lagoons; geothermal energy; micro- and mini- hydro schemes.
In 2006, Dr. Kevin Anderson, a senior research fellow at the Tyndall Centre for Climate Change Research, claimed that ‘We can easily deal with climate change without nuclear power’ (quoted in Adam, 2006). He notes that currently nuclear energy only provides 3.6% of the UK’s final energy consumption and that replacing nuclear power stations will only save 4 – 8% of the UK’s carbon emissions. He believes that minor increases in energy efficiency could compensate for this. He reasonably concludes, ‘If you’ve got money to spend on tackling climate change then you don’t spend it on supply. You spend it on reducing demand’.
The consultation document (DECC, 2009c) states that the Application takes into account the whole life cycle of nuclear power (number of stations, however, unknown) when calculating carbon emissions. However, the more nuclear power stations that are built globally, the less secure supplies of uranium become (see also our response below to Question 6 – Security of Supply Benefit). It may not be too long before uranium has to be extracted from low-grade ores which would require more and more fossil based energy to fabricate fuel from, thus increasing the carbon emissions of nuclear power. And they may in future have to come from countries such as Kazakhstan and Russie.
It is unreasonable and dishonest to compare the carbon emissions from nuclear power stations with those for wind generated electricity without taking into account that wind turbines (and other renewables) do not run on imported fuel, do not produce extremely dangerous wastes and do not require decommissioning.
BANNG believes that the carbon benefit from nuclear power would be better achieved by renewables, energy efficiency and demand management. It, therefore, urges that the scarce resources available at this time of worldwide recession be invested in these benign sources of electricity.
Question 6 Chapter 8 (Security of Supply Benefit) sets out the evidence on the
potential benefit through security of supply arising from the class or
type of practice. It also sets out the Secretary of State’s current
views based on that information. Do you agree or disagree with the
views presently held by the Secretary of State on these matters?
BANNG is concerned that the more nuclear plants there are worldwide, the more the chances of a major nuclear accident/incident that could have a catastrophic effect on the nuclear industry and thus on electricity supplies. We are also concerned that money invested in nuclear power generation is money not spent on developing renewable technologies. In the event of a worldwide ‘nuclear renaissance, we do not share the Secretary of State’s view that uranium supplies are secure for the long-term.
The UK has lagged behind in the development of renewable technologies and in taking actions at local level that would have ensured security of electricity supply without the need for nuclear power. The so-called looming energy crisis has been known about for a very long time but successive Governments have failed to address it. It is to be deplored that the UK is near the bottom of the EU league table on the development of renewable energy. One of the reasons for this lamentable situation is the favourable treatment meted out to the nuclear industry in the past and which looks set to continue in the future.
Unlike renewables, nuclear power is not a domestic source of electricity as it relies on imported supplies of uranium. Like all imports, these will be subject to price volatility (Sustainable Development Commission, 2006). Although supplies of uranium may currently be readily available, with the worldwide ‘nuclear renaissance’ these supplies may not be sustained. While there are worries that in the long-term the UK will be forced to import gas, etc. from unstable countries, it seems to go unnoticed that in the long-term uranium may need to come from just such countries, for example, Kazakhstan and Russia. It may also increasingly need to come from low-grade ores which require energy-intensive extraction. This would negate any carbon reduction benefit, devastate landscapes and cause potential health risks for workers.
BANNG believes that the Justification of new practices cannot be made on security of supply benefit. With the political will, this could be achieved through the development and use of renewable technologies which do not rely on importing uranium, do not require decommissioning and do not produce dangerous wastes requiring storage for tens of thousands of years.
Question 7 Chapter 9 (Economic Assessment) sets out the evidence on the
potential economic impact of the class or type of practice. It also
sets out the Secretary of State’s current views based on that
information. Do you agree or disagree with the views presently held
by the Secretary of State on these matters?
BANNG can only respond in general terms to most of the matters in the Chapter on Economic Assessment. We note the Secretary of State’s Decision with respect to economics is that ’there are unlikely to be any economic disbenefits arising from new nuclear power stations’ (DECC, 2009d, para. 9.44). We do not agree. As in our previous response 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 on costs and construction deadlines. We note the delays, problems and cost overruns experienced with the EPR currently under construction at Olkiluoto, Finland. There are also design problems being encountered with the AP1000. We also doubt the ability of the market to deliver on time and at no cost to the taxpayer the 15GW of new nuclear capacity within the next 15 years in the UK indicated in energy companies’ plans (DECC, 2009d, para. 9.19). Rather, we fear that costs, competition, lack of skills, problems with the supply chain, renewables and new, low carbon technologies and lack of public confidence will limit nuclear investment to a handful of new nuclear stations at best. The economic costs and opportunity costs of new nuclear seem reason enough to withhold Justification of practices based on economic benefit.
We do not consider that the likelihood of accidents is ‘negligible’. We agree that, in the event of a major accident or terrorist attack, the operator’s liability will be exceeded and the economic costs will fall to the public. Similarly, we are sceptical that investors will, over the long-term, be able to meet the full costs of the nuclear cycle, including waste management and decommissioning, without some form of public assistance.
BANNG considers that the prospective need for subsidy or some form of public support to sustain a new nuclear programme is an unjustifiable use of resources.
Although the Secretary of State’s decision in terms of economics does not rely on demonstrating economic benefit, the Decision documents emphasise the contribution new nuclear power stations can make to local economies. This includes up to 9,000 jobs and widespread investment benefits down the supply chain, within the UK and locally (DECC, 2009d, para. 9.33). We find the whole tone of the argument optimistic and vague. Much more evidence in terms of the nature, permanence and location of jobs is needed. 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. In any case, nuclear is not the sole source of potential employment benefits since there could be jobs associated with alternative forms of energy production.
The documents do not consider detriments experienced and perceived in the areas surrounding nuclear power stations. We have covered these in terms of the Bradwell area in our NPS response. More generally we observe the negative image and anxiety created by nuclear activities especially spent fuel stores which introduce further and longer term risk to areas around the listed 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. BANNG’s own research contradicts this assertion and indicates strong opposition to the proposal for a new nuclear power station and spent fuel store at Bradwell.
BANNG disagrees with the Secretary of State’s opinion that there are unlikely to be any economic disbenefits arising from new nuclear power stations. In particular, we consider the local economic detriments over the long-term must be taken into account in the decision on Justification.
The secretary of State proposes to decide that the new practices considered in the consultation documents are Justified under the Justification of Practices Involving Ionising Radiation Regulations 2004. For all the reasons given throughout this response, BANNG believes that the new practices cannot be justified. We are concerned about process and substance.
As to process we do not regard the public consultation and decision-making on Justification to have been open and transparent. The public consultation has been indequate and unfair. The decision making appears predetermined. Given his open promotion of nuclear power, the Secretary of State cannot be regarded as a disinterested arbiter on whether or not new nuclear build goes ahead and his role as Justifying Authority thereby undermines public confidence in a fair outcome.
In terms of substance, we conclude that the case for Justifying the new practices is weak and full of unknowns and uncertainties. We do not consider the health detriments are outweighed by the benefits and, even less so, when other economic and environmental detriments are included. Indeed, we doubt that there are any benefits to be gained from nuclear energy when its modest contribution to carbon benefit can be more cheaply and safely secured by other means. In particular we consider the detriments in terms of risk, cost and effort to specific communities both now and in the future are unfair, intolerable and unjustifiable.
BANNG believes it is in the public interest that the process of Justification is opened up to wide-ranging and independent debate. We, therefore, reaffirm our call for an inquiry to be held as provided for in the regulations.
BANNG considers it to be in the public interest that a Public 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.
Prepared by Professor Andrew Blowers (Chair) and Ms. Varrie Blowers (Secretary) on behalf of the Blackwater Against New Nuclear Group (BANNG)
22 February, 2010
Adam, D. (2006), ‘Nuclear power cannot tackle climate change’, The Guardian, 17th. January.
Baker, P. and Hoel, D. (2007) ‘Meta analysis of standardised incidence and mortality rates of childhood leukaemias in proximity to nuclear facilities’, European Journal of Cancer Care, 16:355 – 363.
BANNG (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 Blackwater Against New Nuclear Group (BANNG), March.
BANNG (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 Generation (EN-6) and Associated Documents, Response of the Blackwater Against New Nuclear Group (BANNG), February.
Busby,C. and Bramhall, R. (2002) ‘Breast cancer mortality and proximity to Bradwell nuclear power station in Essex’, Green Audit, Occasional Paper 2002/6.
CERRIE (2004) Report of the Committee Examining the Radiation Risks of Internal Emitters, 2004.
CoRWM (2006) Managing Our Radioactive Waste Safely, CoRWM’s Recommendations to Government, November.
DECC (2009a) The Justification of Practices Involving Ionising Radiation Regulations 2004, Consultation on the Secretary of State’s Proposed Decision as Justifying Authority on the Regulatory Justification of the New Nuclear Power Station Designs currently known as the AP1000 and the EPR, Volume 1 Consultation Document, November.
DECC (2009b) Draft National Policy Statement for Nuclear Power Generation (EN-6), November.
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DECC (2009d) The Justification of Practices Involving Ionising Radiation Regulations 2004, Consultation on the Secretary of State’s Proposed Decision as Justifying Authority on the Regulatory Justification of the New Nuclear Power Station Designs currently known as the AP1000 and the EPR, Volume 2 – The Secretary of State’s Proposed Decision as Justifying Authority on the Regulatory Justification of the Class or Type of Practice being: “The generation of electricity from nuclear energy using oxide fuel of low enrichment in fissile content in a light water cooled, light water moderated thermal reactor currently known as the AP1000 designed by Westinghouse Electric Company LLC”, November.
Defra (2008) Managing Radioactive Waste Safely: A Framework for Implementing Geological Disposal, Defra and the Devolved Administrations, White Paper, CM 7386, June.
Elliott, D. A. (2008), How To Get Rid of Fossil Fuels and Nuclear, unpublished paper to BANNG
Fairlie, I. (2010) Factsheet on Tritium at Hinkley Point, February.
Kaatsch, P., Spix, C., Schulze-Rath, R., Schmeidel, S. and Blettner, M. (2008) ‘Leukaemia in young children living in the vicinity of German nuclear power plants’, International Journal of Cancer, Vol. 122 (4), February, pp. 721-6.
Sustainable Development Commission (2006) The Role of Nuclear Power in a Low Carbon Economy, SDC, London, March