In Summary…
In our view the operator, in conjunction with the regulators, should conceive a generic site that encompasses impacts in non-coastal locations, including estuarial sites.
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.
The GDA must recognise that prospective availability, capacity and time-scale of
a GDF are incredibly vague at present. Consequently, proposals for managing
long-lived ILW and spent fuel must assess the possibility of indefinite on-site
storage or storage at another site. At Step 3 we would expect detailed, credible
and robust plans for storage of wastes based on reasoned assumptions and
convincing evidence.
The GDA must provide some indication of time-scales for decommissioning and
an assessment of whether it is feasible and sustainable to undertake it in view of
the generic site characteristics.
Supply of cooling water is clearly one of the major issues facing a GDA. The
limitations and constraints must be clearly spelled out at this early stage. These
are: water from the open sea must be accessible within a short distance from the
plant; shallow water and estuarial intakes must be avoided; long distance
transfer to access deep water must be ruled out; cooling towers must be avoided
on low lying coastal sites. If any of these conditions applies when applied in a
specific context, then the site must be removed from any further consideration.
There are understandable concerns among the public about the Chinese involvement
in developing a UK HPR1000. These concerns are both commercial and political. It is
important that reasons of commercial confidentiality and economic development do
not compromise the ability of the UK’s regulators effectively to scrutinise all aspects
of the safety systems.
We understand that the Generic Design Assessment (GDA) is a long process and there will be many opportunities for comment. We anticipate engagement both with the regulators and the operators during the course of the next few years. Therefore, our comments at this point are intended to focus on our main concerns about the project and relate to specific chapters in the submission.
Chapter 3 Generic Site Characteristics
Relationship of generic to specific
Although the GDA is, by definition, generic, the design is to an extent constrained by
generic siting characteristics. Moreover, the UK HPR1000 is, at present, destined for
a specific site in the UK, namely the Bradwell site on the Essex coast. Therefore, it is
anticipated that the generic siting characteristics will take this into account. At this
stage it is indicated that the design is applicable to coastal sites for access to sea water
for cooling. It is unclear whether the design might also be applicable to estuarial sites
with shallow water and marine protection regimes.
The following comments on generic siting made in our response to the GDA for the
AP1000 and the UK EPR (BANNG Paper No. 6, 2010) may also be applicable in this
case:
“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’ (GDA, AP1000, 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.”
In our view the operator, in conjunction with the regulators, should conceive a
generic site that encompasses impacts in non-coastal locations, including
estuarial sites.
Risk of flooding from consequences of climate change
We consider that sites which are liable to be inundated within 200 years as a result of
seal level rise, coastal processes and storm surges should be excluded from further
consideration. Flooding of sites is not just a site-specific issue. Given that the GDA
designs assume coastal locations and the nominated 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. Forecasts of coastal change reveal that, for example, parts of the Dengie
peninsula on which Bradwell B is proposed will be permanently below sea level
within the next century. The government considers that it is not practicable to
consider the situation beyond 2100. In other words, assessments of safety and
integrity of coastal sites cannot feasibly be made beyond the next century. Taking the
Bradwell B example and assuming it starts generating in 2030 with an operational
lifetime of 60 years followed by, perhaps, fifty years storage on site before a GDF is
available it will be at least the middle of the next century before the site is fully
decommissioned and cleaned up. Estimates of time-scale are, of course, uncertain but
these are broadly in line with current government forecasts. And this is a highly
optimistic picture. Decommissioning is likely to be a protracted exercise, a GDF may
not be available for new build spent fuel and site deterioration may set in well before
the site is cleared. It is highly probable there will be nuclear activity on floodable sites
for up to two centuries. Indeed, this may be a conservative estimate.
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.
Chapter 23 Radioactive Waste Management and Fuel storage
It is difficult to comment in any detail on proposals for radioactive waste management
since these are indicative outlining the general principles underlying a safe and secure
management system. The system has not been designed though it will be based on the
Fangchenggang plant.
It is not possible to comment at this stage on emissions to air and discharges to sea
since this is a site specific issue and tidal flows, currents, depth of water and refresh
rates will be significant factors.
It is understood that long-lived solid radioactive wastes (ILW) and spent fuel will be
managed on site. It is assumed that wastes will be securely managed in interim stores
and eventually disposed of in a geological repository. Again, details on volumes,
methods, transfer, treatment and timing of waste management in stores are
unavailable and are a matter for comment at Step 3. At that point a more detailed and
robust explanation of proposed ILW storage will be required. As for spent fuel stores,
an operational lifetime of 100 years is quoted, extending forty years beyond
anticipated reactor shut down. 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). Location, capacity and design of the SPIS are unknown at this stage.
On government estimates, a repository if available, would not be ready to receive new
build wastes until the national inventory of legacy wastes has been dealt with. It is
questionable if the GDF will have sufficient capacity to deal with the unknowable
inventory of new build spent fuel.
The GDA is predicated on the eventual development of a disposal facility. 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’ this amounts to no more than a claim. It is highly unlikely that spent fuel
will be cleared from the site within 100 years; therefore, provision will need to be
made for transfer of some of the spent fuel to a replacement store or to another site.
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.
The GDA must recognise that prospective availability, capacity and time-scale of
a GDF are incredibly vague at present. Consequently, proposals for managing
long-lived ILW and spent fuel must assess the possibility of indefinite on-site
storage or storage at another site. At Step 3 we would expect detailed, credible
and robust plans for storage of wastes based on reasoned assumptions and
convincing evidence.
Chapter 24 Decommissioning
Radioactive waste management is an integral part of decommissiong; therefore, the
comments on the previous chapter are relevant here. Again, the plans and proposals
are set out in such a general way that forbears any detailed comment at this stage.
This applies to two issues in particular.
There is no assessment of the two options of immediate dismantling and safe
enclosure followed by deferred dismantling. Clearly it is a question of resources and
technology. We might presume a public preference for immediate dismantling and
clean up though in practice the difference may not be great since, as indicated above,
spent fuel and other waste stores and reactor cores will not be available for immediate
dismantling. We suggest that the feasibility of both options is assessed in terms of
cost, radioactivity, volumes and clean up.
There is no indication of time-scales beyond the vague statement that
‘Decommissioning should be carried out as soon as reasonably practicable, taking all
relevant factors into account.’ The timing of the decommissioning should be
rigorously justified. Should decommissioning need to be deferred, then this should be
explicitly justified in the safety case and strategy as appropriate. Unless some idea of
time-scale is given the statement is rendered practically meaningless. As already
indicated the time-scales of activity on site are likely to be determined by the
management of wastes in store and the (non)availability of a GDF.
The GDA must provide some indication of time-scales for decommissioning and
an assessment of whether it is feasible and sustainable to undertake it in view of
the generic site characteristics.
Chapter 26 Environment
At this stage we have no comments on the environmental impacts as these are clearly
at a rudimentary level of analysis and can be dealt with during Step 3 or as part of the
planning permit stage. We do, however, have comments on the cooling water system.
It is assumed that the generic site is coastal and the preferred cooling system is a
once-through circulating water system.
It appears that a site where cooling water may be abstracted from and discharged to
the open sea is envisaged. This assumes a depth of water close to the power station
sufficient to deliver the volumes of cooling water required. Tidal flats or shallow
water extending for some distance out to sea would require pipelines some kilometres
long. This might be difficult to achieve technically and economically and might
increase maintenance, safety and security issues by extending the footprint of the
power station far out to sea. Similarly, estuarial locations with shallow waters, risks to
marine life and livelihood, including fishing, and slow refresh rates would appear to
be ruled out as sources for cooling water. The alternative of cooling towers raises
issues of feasibility and visual impact on low-lying coastal areas.
Supply of cooling water is clearly one of the major issues facing a GDA. The
limitations and constraints must be clearly spelled out at this early stage. These
are: water from the open sea must be accessible within a short distance from the
plant; shallow water and estuarial intakes must be avoided; long distance
transfer to access deep water must be ruled out; cooling towers must be avoided
on low lying coastal sites. If any of these conditions applies when applied in a
specific context, then the site must be removed from any further consideration.
Chapter 27 Security
We do not wish to comment on the security issues at this point but intend to do so
when we have had the opportunity to consider the matter in more detail. We note that
the chapter emphasises the congruence between the UK and China’s security systems
and requirements. Clearly, the security systems will have to satisfy the most stringent
requirements.
There are understandable concerns among the public about the Chinese involvement
in developing a UK HPR1000. These concerns are both commercial and political. It is
important that reasons of commercial confidentiality and economic development do
not compromise the ability of the UK’s regulators effectively to scrutinise all aspects
of the safety systems. At a more strategic level there are concerns about the
involvement of the Chinese state (in the form of CGN) in highly sensitive UK
infrastructure. It is axiomatic that control over security must be exercised by the UK
and that the Chinese state will not be able to interfere with the operation of nuclear
power stations in UK territory. Reassurance on these sensitive matters will be a
necessary condition for public acceptability of the development of Chinese reactors in
the UK.
Andrew Blowers, OBE, Chair,
On behalf of Blackwater Against New Nuclear Group
August 30 2018
References
BANNG (2010) Environment Agency Generic Design Assessment AP1000 Nuclear
Power Plant Design by Westinghouse Electric Company LLC. UK EPR Nuclear
Power Plant Design by Areva NP SAS Electricité de France SA . Consultation
Document. Response by Blackwater Against New Nuclear Group (BANNG) Paper
No.6, October