I'm not sure why I didn't publish this at the time - must have been very busy - it's been here as a draft page for a few years now! oops! Anyway - it's the very detailed submission I made to the IPC or NPD as they subsequently changed it to - not sure what name they're going by now! I like to call it the National Planning Dictatorship... (apologies that my uploading of the pictures in the submission hasn't worked very well I will try to rectify this when I can).
My submission to the National Planning Dictatorship
The
recent corruption of governance report which can be viewed at
http://www.ukace.org/publications/ACE%20Campaigns%20%282012-01%29%20-%20Corruption%20of%20Governance%20-%20Jan%202012
shows that the governments own evidence on the need for nuclear has
been fudged. This corruption is unsurprising given that there are
energy company employees infiltrating our government at all levels
both in terms of having people embedded in the DECC (Department of
Energy and Climate Change) as well as the GDA process never mind the
revolving door policy between big business and the government. What
we have here is a classic case of policy driven evidence rather than
evidence driven policy.
The
Carnegie institute's report entitled “Power moves: exploring power
& influence in the UK” in examining the so-called 2006 energy
review they found that despite consultation
being done 'by the book' certain stakeholders were excluded from
decision-making spaces; disengaged media did little to stimulate
debate; the nuclear industry has been conducting a well-orchestrated
and well resourced campaign to put nuclear back on the agenda with
access to government ministers and officials
that most people at the grassroots level can only dream of.
These
comments have been echoed down the years ever since by our local MP
who asserted to myself and five other campaigners when we met with
him on November 12th 2010 at his constituency
office that “Hinkley C will be built” and more recently by the
prime minister David Cameron as he signed further deals with the
French government to shore up the money to
fund the Anglo-French
nuclear new build agenda.
On
the subject of dis-engaged media the same is still very evident as
there has been and continues to be a virtual media blackout on
coverage of the on-going nuclear catastrophe
at Fukushima Daiichi in Japan. In fact the lack of coverage in
combination with the Guardian on-lines well placed freedom of
information request last year that revealed collusion between DECC
officials and Nuclear industry stooges to 'cover-up' these events
revealed that the media blackout is part of the governments
agenda.
At
the preliminary meeting I attempted to request the right to
cross-examine at the hearings that will form part of these
proceedings. The microphone was cut off pretty much immediately, it
seems because the chair had a problem that o I had already raised
other issues under other agenda items, as was deemed to be the
purpose of the meeting, . I still wish to be able to cross-examine
the applicant and their experts as is my article six right, this
applies to civil as well as criminal cases if this tribunal is to
have any chance of being perceived as fair.
The
claims by both the IPC (now NPD) and the governments National Policy
Statements that the issues of nuclear waste, in terms of storage
both on & off-site, the safety of the reactors and the issue of
need have been 'debated and decided' couldn't be further from the
truth.
The
fact that DECC host an NGO Forum where these issues are vigourously
debated is just one example (if any where needed) that the debate on
nuclear power and nuclear waste is far from over.
Nuclear
Waste & Spent fuel pools the weak link in nuclear new build
policy, plant design and waste management strategy
The
IPC are directed by the National Policy Statements to assume that the
waste will be stored on-site until the availability of GDF. National
Policy Statements state that the IPC should not consider matters that
relate to the management & disposal.
At
the preliminary meeting of the IPC relating to the EDF application
for Hinkley Point members of the public myself included tried to
press the panel for a proper definition of what would & wouldn't
be 'relevant representations' they were pressed quite specifically on
issues that are quite rightly of specific concern to the public both
hear at Hinkley and the general public at large.
The
Planning inspectors report from the UK
Nirex inquiry into
- 1995/96 Public Inquiry into the proposed construction of a 'Rock
Characterisation Facility' (underground Rock Laboratory) at Longlands
Farm near Sellafield, Cumbria was published in 1997.
www.westcumbriamrws.org.uk/documents/Inspectors_Report.doc
After
this inquiry there was NOTHING being done about the issue of long
term disposal until it became a political issue once again when the
government in collusion with the nuclear industry put the prospect of
nuclear new build back on the public agenda again. Nine years
had passed without any efforts being made towards finding
solutions to the issue of radioactive waste, furthermore the lack of
commitment to finding solutions has lead to the practice/policy of
compromising on safety by exceeding the designed density of fuel rods
stored in the pools.
The
Regulator's assessment of GDA spent fuel strategy shows clearly that
both the operators and the regulators are being complacement in their
assessment of the kinds of 'accident' situations that could arise.
The operator's strategy proposes and the regulator assumes that the
fuel store building could have effective filtration & ventilation
systems in the event of an accident, this speaks volumes about the
underlying nature of any accidents that are assumed to be possible or
likely at a reactor. The current situation in Fukushima clearly
demonstrates that it is perfectly plausible that an accident may
disrupt severely the structure of the reactor building where there is
a primary fuel pool as well as the possibility that neighbouring fuel
store buildings could experience the same fate. The EPR at both the
generic & site specific level for Hinkley does not have
back-up water supply or alternative source of water, the defences
in depth all assume that in a LOOP (loss of outside power) event that
diesel backup generators will be adequate and that there will be
enough people around able to implement certain protocols, not all are
automated.
As
I write there is a grave situation in Japan whereby the spent fuel
pools in the reactor buildings most notably the pool of reactor 4 are
hanging on by a thread. These pools were high up in the air, the
building is mostly destroyed and on the verge of collapse and the
threat of more quakes that will affect the plant are expected. All of
the equipment for handling the fuel was destroyed during the initial
quake and the prospect of the catastrophic release of all of the
radioactivity held in these pools is still very much with us. If this
pool loses it's coolant (a process which has initiated more than once
since this crisis began) then the common pool which has over 6,000
assemblies. The consequences are beyond our conception - to say that
the impacts are global in scale and that the pools couldn't be
approached for at least 50 years to undertake any mitigation is an
understatement.
The
Weightman report – conspicuous by the
fact that this review of the incident & it's consequences was
carried out far before the incident is brought under control claims:
Although
the report goes onto confirm that zirconium fires in the spent fuel
pools “would
significantly increase the rate of
release and mobilisation of radioactivity
from the ponds, with effectively no
barriers against release of radioactivity.”
[emphasis added]
the
report then attempts to play down the risks by talking about them as
if the danger has passed -
“there was a great deal of
uncertainty about whether zirconium fires
were a likely outcome [...] it is
still probably impossible to say
definitively if there would
have been a zirconium fire in
any of the ponds if the fuel
had become uncovered. This is an
area where further research may
be warranted.” [emphasis
added]
The
report then goes onto find that
“it
should be possible to show that
some racking arrangements are less
susceptible than others and may
represent good practice in the
future.” and that “a reliance on racking
arrangements should be a long way
down the hierarchy of measures taken
to protect the fuel, with keeping
fuel covered by water (even boiling
water) being demonstrably more effective.”
Also
“There
is no strong evidence of significant
fuel damage from shaking or debris
falling on the fuel. Visual
inspections of ponds do not show
any apparent damage in Reactor Unit
4, although examination will not be
complete at this time”
This
is at best an understatement!, at worst deliberately misleading.
Right now the seismic rating the reactor 4 building is Zero! There
doesn't even need to be further earthquakes (which there will be) to
further endanger this pool. Videos from Tepco that are freely
available on the internet http://www.youtube.com/watch?v=5Pk_K8lJ55c
showing clearly debris in the fuel pools and also evidence of fuel
melting. The weightman review claims that high caesium levels in the
pool are reflective of high caesium levels across the site rather
than being as a result of melted fuel, despite the fact that elevated
caesium concentrations in the pool are what
you look out for as evidence of fuel melting...
The
Weightman review is not worth the paper it is written on & I
include references from it here as examples not just of the cognitive
dissonance demonstrated, by the government, the nuclear industry and
those involved in it's regulation. But also as evidence that the
design of this whole examination process for this application is
direct contravention of mine and every other interested
parties' article six rights to an
“independent & impartial tribunal”.
We
are expected to leave these matters to the government the industry &
the regulators yet all of this process so far is demonstrably partial
to the interests of nuclear new build, and the investor confidence of
the stock market and the whims of the industry & it's policy
makers.
Mine
and my children's lives are at stake as is
the future survival of all life and I will not be written off as a
statistically acceptable 'health detriment' by this and previous
governments utilitarian justification of nuclear new build. The
continuation of this industry is not justified let alone nuclear new
builds, and those of us who are well enough informed to understand
the risks we are faced with do not find the risks tolerable.
The
Weightman report goes onto conclude that
““Stress
Tests” being carried out in the
UK should demonstrate whether the UK
spent fuel ponds are passively “safe”
by design, and in some cases
whether it is ALARP to impose
relatively straight forward minimum cooling
times or racking configurations to
ensure that with a total loss
of active cooling (possibly even a
catastrophic loss of water inventory)
the fuel should remain substantially
intact”
'Passively
safe by design' is a joke that is not all funny. The spent fuel pools
contain a higher quantity of radiotoxic inventory than that held in
the reactor pressure vessels where the fission process has been so
carefully contained. These pools have no back up water supplies, for
catastrophic loss of coolant or LOCA, no secondary containment beyond
the primary containment provided by the water, no independent power
supplies and the best that the so-called watchdogs here can suggest
is rack rearrangement?
this
is clearly unacceptable in light of the current situation unfolding
in Japan.
Since
2002 way before the frankenstein resurrection of the UK's nuclear
policy and also before the events at
Fukushima began, experts have been raising concerns about spent fuel
pools and their lack of a containment building and vulnerability to a
loss of cooling. These concerns were being raised long before the EPR
reactors were designed but despite this these concerns haven't been
taken seriously by the industry, or been incorporated into design of
G3 reactors such as the EPR or the Westinghouse AP1000. Just one
spent fuel pool of existing operational plants are estimated to
contain between 20 to 50 million curies of Caesium 137 (let
alone the multitude of other radionuclides 60+).
The
weightman reports asserts that “It
was established that there does not
appear to be a general consensus
on the plant conditions required to
cause ignition, or the amount of
cooling time that the spent fuel
requires to eliminate the possibility
of its zirconium cladding igniting.
Therefore, there was a great deal
of uncertainty about whether zirconium
fires were a likely outcome.”
”http://www.hse.gov.uk/nuclear/fukushima/final-report.pdf
This is fraudulent
as it is deliberately misleading. The lack of consensus around
zirconium fire doesn't centre around the possibility of the cladding
igniting but rather around the inability to
“define
a generic decay heat level (and therefore decay time) beyond which a
zirconium fire is not physically possible.” [emphasis added]
http://www.thebulletin.org/files/WhatAboutTheSpentFuelAlvarezJanFeb2002.pdf
The
weightman review states that there are no implications for the UK new
build programme but the on-going situation at the Daiichi spent fuel
pools suggests differently.
Spent
fuel strategy
The
primary pool that has been put forward for the GDA process is
110m²(although in the preconstruction report EDF withhold under
commercial confidentiality
the volume of the pool) designed to hold six reactor cores, roughly
480 (high burn up) fuel assemblies.
This is the same size as the pool design from Olkiluoto,
where the claim is that the inventory that can be accommodated
is six to seven years worth of spent fuel. Yet in the submission to
the UK regulator 10 years worth of storage is claimed for the same
size pool.
http://www.nuclearconsult.com/docs/information/waste/Spent_Nuclear_Fuel%E2%80%93the_Poisoned_Chalice.pdf
In
other places the pool is claimed to be 250m (the justification
decision). More obfuscation.
Interim
spent fuel storage according to the timeline provided by EdF is not
intended to begin construction until the plant has been operational
for 7 years and the construction is estimated to take three years so
the interim spent fuel storage couldn't be received until ten years
worth has accumulated in the pools of the reactor. This raises the
question of what will happen to spent fuel assemblies generated
during the three year interim spent fuel storage construction? This
is assuming that the regulatory bodies ignore the concerns we the
public have already raised about this issue of how densely packed the
primary pool is.
See
below for letter of compliance Gannt chart
![]()
(chart
reproduced from R10-017 The Case for Disposability of Spent Fuel
and ILW)
According
to the PCSR the purification pump of the reactor building can be used
to back-up the purification pump of the spent fuel pool. This might
be fine under normal operational conditions but is questionable in
the event of a beyond design basis event as has happened at
Fukushima. The reactor Boron and water make-up system is relied upon
to borate the water 'in the event of a leak' again this assumes that
the cause of the leak is not a beyond design basis event. In the
assessment of accidental drainage of the pool two initiating
events aren't considered
It
doesn't seem unreasonable to surmise that either of these might be
possible if the initiating event is a beyond design basis event.
The
design for the interim spent fuel features a back-up water supply
although it is not clear where this would come from as the design
seems to be generic rather than site specific. There doesn't seem to
be any cooling or purification back-ups and there is definitely no
tertiary containment the only significant barrier is the water which
in the event of a loss of that shielding leaves no other barrier
between the spent fuel and the environment. Gordon Edwards in his
letter to the former Japanese ambassador
Akio Matsumura explains:
“Most
nuclear engineers and nuclear regulators have developed a “blind
spot” about the catastrophe potential associated with the spent
fuel bay because of years of neglect. Such considerations have never
played a significant role in their training as nuclear engineers or
in their many subsequent years of experience in the field of nuclear
safety analysis.
As
a result we have backup pumps, backup electrical supply systems, and
backup cooling systems for the core of the reactor, but no backup
pumps or electrical supply or cooling system for the spent fuel bay.
We have extravagant containment systems for the core of the reactor,
but no comparable containment systems for the spent fuel pool.
This
absence of backup systems for the spent fuel pool is testimony to the
lack of effort and lack of forethought that has been devoted to the
spent fuel bay. Nevertheless, the radioactive inventory in the spent
fuel pool is often much greater than that in the core of the
reactor, and a prolonged loss of coolant — or even loss of
circulation of coolant — will lead to overheating of the fuel and
extensive fuel damage. This will result in significant releases
of radioactive fission products into the atmosphere due to the
inadequate or even non-existent containment provided for the spent
fuel pool.”
Furthermore,
the on - site interim storage of spent fuel is potentially
incompatible with EPR design see below for excerpt from the Areva/EDF
case for disposability of spent fuel & ILW:
R10-017
The Case for Disposability of Spent Fuel and ILW
3.4
Spent Fuel Interim Storage
The
storage of spent fuel for 100 years is potentially in
conflict with the existing design assumptions concerning the
on-site storage of spent fuel. This issue needs clarification and
further assessment and it is noted by RWMD that options exist to
allow the cooling period to be reduced. Issues to be addressed will
include consideration of burn-up, improved estimation of the
radionuclide inventory in spent fuel and the effect on heat output
from spent fuel. [emphasis added]
What
were Areva's design assumptions concerning on-site storage of spent
fuel?
The
public are being done a grave dis-service here as what is going on is
more deliberate misleading of the public, the below tabulates
information relating to the current 'baseline inventory' this is all
of the historic legacy waste and weapons grade uranium
& plutonium that it is envisaged will need to be part of final
disposal. Note 4 of the table below indicates that this 'baseline
inventory' may change in the future – what is meant by that
statement is that it may be expanded to include new build waste...
This
is preposterous given that all research to
date carried out by CoRWM and NIREX before them, is related to the
final disposal of LEGACY WASTE only and explicitly
states that the research doesn't relate to future wastes.
This
graph shows clearly at a glance why the technical
considerations
for storage of high-burn up are different from legacy waste, the
heat generated, timescales involved and corrosive ability of
high-burn up are all far in excess of the far from benign legacy
wastes that we've already generated.
To
further complicate matters there are numerous issues relating to the
storage packaging and disposal of high burn up fuel that are anything
but resolved:
“Various
boron containing absorbers have created operational
problems, reacting with the spent fuel pool water to generate
hydrogen34, or breaking down in the high gamma field of
spent fuel, releasing silica and boron into the pond35.
The resulting soup blocks filters and reduces visibility of the fuel
cells. [...] A few dry cask storage systems have received licenses
for high burnup spent fuel in the US, but these are only for a
maximum of 20 years of storage. It is instructive that, although two
of these dry cask storage systems are made by AREVA, EDF have
themselves opted for interim pool storage in their UK ‘justification’
application,36 and state elsewhere that the interim
storage pool fuel racks would cover an area of approximately 250m ”
Our
future safety
“will
depend on the effective and continuous removal of the huge
thermal power of high burnup spent fuel. This will require additional
pumps, back up electricity supplies and backup water supplies: all
systems vulnerable to mechanical failure or deliberate disruption.”
pg 9
The
chart below reproduced from the link above shows how the high burn-up
fuel proposed for the EPR reactor here at Hinkley will require 30
years in a pool rather than the 5 currently required by
current legacy waste.
The
environment agency after consulting on EDF's spent fuel strategy
initially concluded that they:
“needed
more information on the longer term storage of the fuel to understand
whether there is any potential for degradation of the fuel over the
longer term that might affect its disposability. This is consistent
with the ONR requirement for a satisfactory demonstration that spent
fuel can be stored safely for the necessary period of time without
significant degradation. At the time of our consultation we said that
our conclusion was subject to the potential GDA Issue: a)
Disposability of spent fuel following longer term interim storage
pending disposal.” pg29
https://consult.environment-agency.gov.uk/file/2037374
This
hesitance seemed prudent given that
and
yet
in the same report the regulators switch from their hesitant position
above to concluding that
“Further
information was provided by EDF and AREVA in regard to the proposed
storage facilities to support the safe long-term storage of the spent
fuel and to ensure that the fuel does not degrade over the long
storage period. ONR reviewed this information in its Step 4
assessment. We continued to work with ONR on these matters, and this
work informed our decision. We are satisfied with the information
provided and have closed out the issue on disposability.” pg 29
https://consult.environment-agency.gov.uk/file/2037374
Just
what evidence have EDF provided in order to give these assurances?
The only document I've been able to find is one named within the EA
assessment, it is not clear from the assessment whether this document
is the further evidence or whether the further evidence remains
unnamed. Given that there are numerous concerns within the industry
about the degradation of high burn up fuel during storage as well as
no GDF facilities anywhere in the world, but points made in the
IAEA's own literature above?
The
above extract from the EA assessment demonstrates that another
government department (the ONR), responsible for pushing the
governments nuclear agenda through has
stepped in and influenced the Environment Agency's own original
assessment. Further evidence that all of the process is anything but
impartial.
Given
the Radioactive Waste Management
Directorate of the Nuclear Decommissioning Authority's underinformed
and overoptimistic assessment and letter of compliance process the
people of Sedgemoor and West Somerset can
expect little more than the future operator
of the proposed site to do little more than to walk out of that
station in 2080 and leave my children the future people of Sedgemoor
& West with an interim storage facility that has the accumulated
3,400( pg 16
https://consult.environment-agency.gov.uk/file/2037374
)
high burn up fuel assemblies still in wet storage and therefore
unpackaged and therefore not ready for so-called final disposal.
The
2008 managing radioactive waste safely white paper claims that:
“Through
the Generic Design Assessment process (Ref. 17) the nuclear
regulators will assess the safety and security, and the environmental
impact, of power station designs, including the quantities and types
of waste (gaseous, liquid and solid) that are likely to arise, and
the ability to store and dispose of solid wastes (Ref. 18). The NDA
will be involved in this work specifically to consider disposability
of wastes being proposed at an early stage.”
http://mrws.decc.gov.uk/assets/decc/mrws/white-paper-final.pdf
The
Nuclear Decommissioning Authority have rubber stamped Areva/EDFs case
for the disposability of the spent fuel and
ILW concluding:
It
all sounds authoritative enough until you look at the words in the
quote that I have emboldened - 'future
refinements; assumed ; better understanding' these
words demonstrate that right now the appropriate
technical knowledge of the radioactive
inventory of the EPRs high-burn up waste and MOX waste is unknown
and that there are, as I've pointed out previously, issues around the
packaging of the waste.
Yet
here we are in 2012 with the application in and yet still we the
public can expect no detailed information about the contaminants we
are likely to be saddled with forever. It is far too easy when
conceiving these timescales for so-called experts and those in power
to make decisions accountability for which will be impossible when
the true costs are counted by future generations.
The
IAEA state that:
“due
care should be given to the long term stability of all
its components and especially those which are safety related. If it
is not possible to guarantee long term stability of all the storage
system components for the planned storage operation period, there has
to be an adequate maintenance and repair concept incorporated into
the facility design, especially with respect to radiation
protection.”
The
following is an excerpt from the nuclear
consultation group paper spent nuclear fuel the poisoned chalice
“The
Committee on Radioactive Waste Management (CoRWM) recorded the view
that it would take around 65 years after a repository opened to
emplace the legacy backlog.24 In the view of the former CoRWM chair,
Gordon MacKerron this suggests:25
"...new
build wastes would not start to be disposed for around 100 years from
now - if all goes well. Things of course may not all go well and it
will take further decades to emplace new build wastes beyond this 100
year period. Consequently, some new build waste would need storage
well beyond 100 years from now, possibly for as long as 150 years.”
CoRWM
have a preference for the early closure of the legacy fuel
repository, but the government position is ambivalent:26
“Closure
at the earliest opportunity provides greater safety, greater security
from terrorist attack, and minimises the burdens of cost, effort and
worker radiation dose transferred to future generations.
……..however…….. it is likely to be at least a century until
final closure is possible, which the UK Government believes provides
sufficient flexibility for further research to be undertaken to
achieve public confidence and approval...”
The
above extract demonstrates quite clearly that these issue are
anything but issues that are just for the government, regulators and
their advisors. These are not just technical matters and political
matters, but these are ethical matters and matters that have huge
implications for human survival. Even at the 'highest' levels of
political & technical power there is no agreement.
To
complicate matters further over the timescales involved for interim
storage and so-called final disposal we are talking generations of
people and potentially 30 successive governments.
The
arrogance of technocrats, beauracrats and
politicians is not just staggering it is immoral and unethical The
IAEA claim that “The
IAEA Safety Fundamentals [34] incorporate, to a large extent, the
obligations that apply to spent fuel management in general. Of
particular importance are the obligations with regard to the
protection of human health and the environment, the
protection of future generations, the protection of third
party countries across national borders, and the avoidance of undue
burdens on future generations.” [emphasis
added]
If
any of these ethical consideration were really being taken seriously
then new nuclear build would not be being entertained. As the
Scottish would say if you don't see the bottom don't wade..
All
of these so called defensos in depth all
have the same vulnerability – they all rely on diesel generators
which are prone to mechanical failure and external disruption as has
happened in Japan. Furthermore there is no assessment of the
availability of fuel for back up generators
over the next 160 years or longer. The UK taskforce on peak oil and
energy security's projections for just the next five years advise
government to be prepared for fuel supply interruptions, furthermore
their report, when discussing the state of oil supply vs
demand states:
“In
future, the principal growth in demand will come from the non-OECD
countries (the so-called ‘developing world’). The non-OECD
countries comprise the vast majority of the world’s population
(some 5 billion people of the world’s current population of 6
billion), so the consequences of a steady growth in per capita
oil-demand in these nations need no further elaboration.”
This
growth in demand for non-OECD countries absolutely does need further
elaboration for what is implicit in that statement is not an energy
decent as can be implied from a first glance of Hubberts peak where
there is a relatively gentle slope up & down from the peak as
below
The
consequences that the task force don't wish to elaborate are that
when you add the effects of an exponentially growing population whose
per capita consumption of energy is growing too then we maybe looking
at a cliff rather than the gentle slope of energy descent
British
scientist, Sir Crispin Tickell The Future and Its Consequences: The
British Association Lectures 1993, The Geological Society, London, p.
20-24 cited in
http://www.eralearning.com/geodest/Chap27Myths.html
said “we have done remarkably little to reduce our dependence on a
fuel which is a limited resource, and for which there is no
comprehensive substitute in prospect."
It
seems that neither the government, regulators or the industry are
taking peak oil and climate change very seriously for if they were
they wouldn't be attempting to create wastes which require a level of
technology as well as social, political and economic stability well
into the next few centuries? (never mind the millenia that the waste
requires isolation for!)
What
will be the consequences for humanity when we have a bunch of
facilities containing deadly waste that require fossil fuels energy
for cooling and no more fossil fuels?
David
Fleming has given some these issues serious thought and with the
support of others who have also given these issues some serious
thought, he has produced a small book about some of these extremely
serious issues concerning the nuclear life cycle, at the beginning of
his book there is a box entitled nuclear energy in brief I will
reproduce the most relevant points here:
The
world’s endowment of uranium ore is now so depleted that the
nuclear industry will never, from its own resources, be able
to generate the energy it needs to clear up its own backlog of
waste.
It
is essential that the waste should be made safe and placed in
permanent storage. High-level wastes, in their temporary storage
facilities, have to be managed and kept cool to prevent fire and
leaks which would otherwise contaminate large areas.
Shortages
of uranium – and the lack of realistic alternatives – leading to
interruptions in supply, can be expected to start in the middle
years of the decade 2010-2019, and to deepen thereafter.
The
task of disposing finally of the waste could not, therefore, now be
completed using only energy generated by the nuclear industry, even
if the whole of the industry’s output were to be devoted to it. In
order to deal with its waste, the industry will need to be a major
net user of energy, almost all of it from fossil fuels.
An
independent audit should now review these findings. The quality of
available data is poor, and totally inadequate in relation to the
importance of the nuclear question. The audit should set out an
energy-budget which establishes how much energy will be needed to
make all nuclear waste safe, and where it will come from. It should
also supply a briefing on the consequences of the world-wide
waste backlog being abandoned untreated.
There
is no single solution to the coming energy gap. What is needed is a
speedy programme of Lean Energy, comprising: (1) energy conservation
and efficiency; (2) structural change in patterns of energy-use and
land-use; and (3) renewable energy; all within (4) a framework for
managing the energy descent, such as Tradable Energy Quotas (TEQs).
This
book was written five years ago and still the industry &
government are in denial about the situation that we face. It is time
to wake up. The audit that David Fleming calls for is completely
justifiable and should be carried out as a matter of urgency.
Fuel
regime
MOX
EPR
designed to run on MOX as well as high burn up (higher radiotoxicity
fuel) Whilst it is currently claimed that these UK EPR's won't be run
on MOX there are no guarantees possible (other than the assurance of
politicians for what that is worth!) that it won't be in the future.
The
closure of the existing Sellafield MOX plant (SMP) following the
Fukushima Daiichi catastrophe was a
political decision and it is reasonable to think that for the most
part closure involves limited decommissioning/mothballing the plant
rather than decommissioning.
The
government still intend to build a second MOX plant to reduce the UK
plutonium stockpile – with no Japanese Market exactly what will the
government do with this MOX that they produce? I assert that this as
yet unproduced MOX fuel is destined for the as yet unbuilt UKEPR's.
MOX poses serious proliferation risks and the site licenses currently
applied for are for an as yet unspecified fuel regime despite current
claims that the it will just be the LEU high burn up fuel that will
be used. Several times during the GDA process e,g the preconstruction
safety reports etc Areva & EDF have made sure to point out that
their safety concepts, fuel handling regimes etc are all suitable for
MOX as well.
It
seems quite clear from the documents that I have inspected that this
EPR dual fuel regime is a deliberate design to sneak MOX plants into
the UK by the back door so to speak. It won't be licensed
for that now, but what's to stop future governments and political
agendas from backtracking on their commitments? After all that is why
we are all involved in this process now – In the 1970 the flowers
report advised government not to construct new reactors until the
issue of nuclear waste was resolved, that advice is being flouted at
our peril.
There
are numerous other areas that I wish to address but in the
ridiculously short time allowed us by your panel it has been
impossible to produce the detail on all of the areas that I indicated
an interest in at the outset in this process. The following subjects
are possibly incomplete and there are others that I haven't
even begun.
I
therefore reserve the right to comment on and engage in discussion of
all topic areas I originally raised with the IPC as relevant issues
in my initial submission. It is likely that others may have brought
up in their representation points I wish to make also but have not
had time to put in writing so I feel it is important as an interested
party that I am able to discuss these as these proceedings move
forward.
Site
specific aspects of EPR design.
Fluid
mud ingress into the intake cooling water is likely now & into
the future as this is a characteristic of this estuary and the lunar
cycle where there is significant uncertainty although there has been
some speculation about whether a tidal barrage would reduce this risk
there remains huge uncertainty that this would be the case. (cefas
technical report 060)
Site
specific estuarine & coastal hydrogeodynamics
research
into and modelling of the behaviour of contaminated sediments is an
area of huge uncertainties, some of the most recent research is still
very much about trying to couple various aspects such hydrodynamics &
geochemistry in order to create models with a 'better fit' with
reality. Even this research whilst at a more relevant scale than
previous research is still a long way off being accurate at the whole
estuary scale. This means that there is a lot of uncertainty involved
in our understanding of both sediment and contaminant behaviour over
the short term which is then compounded when further uncertainty is
introduced by trying to extrapolate over the longer term (i,e the
claimed lifetime of the station of 60 years).
http://www.severnestuary.net/sep/pdfs/ecsa/09fcouceiro.pdf
The
more other projects that are undertaken in the estuary, the more the
coastal environment is modified and the more uncertain become any
predictions about the impacts during the period of
construction,operation and subsequent
centuries after decommissioning. Coastal environments such as the
Severn estuary are in a delicate balance of dynamic equilibrium, even
the smallest perturbation can have an enormous effect totally
transforming erosion & deposition patterns over very short times,
the more coastal engineering projects are undertaken the more
potential synergy there is between them and their effects, so much
so that it may render individual project modelling meaningless,
although the applicants assessment by CEFAS for EDF try to take
account of such synergies. Estuarine environments such as the Severn
are in a very delicate balance and seemingly small perturbations
can cause large-scale changes over relatively short times creating
net changes in the areas of erosion and deposition.
This delicate balance of sediments may be disrupted when cooling
water outfall displaces sediments at the outflow.
Flood
risk is predicted to increase over the course of the centuries and it
could well be that current assessments are revised upwards in terms
of risk and predicted surge and sea-levels.
Stability
& deformation of estuarine mud is affected by soil composition
in both in terms of mineralogy, pore fluid type and content and ions
on grains. Given that Bridgwater
Bay is characterised by mudflats and on the whole is currently a
low-energy landscape, this indicates that accumulation of
contaminants in the estuary (as already happens) is likely to happen
further. Liquefaction is therefore of some concern not least
because of the changes to the characteristics above that may arise as
further contaminants build up in the estuarine muds. The
idea of dilute & disperse on which licensing and much of the
design is predicated on is inappropriate for radionuclides all of
which are significantly long-lived and will accumulate in the estuary
as is already evident.
http://www.soilmechanics.us/LiquefactionRelated.pdf
Floodrisk
One
of the most important parts of the site specific design is siting,
height & capacity of the reactor bases – the concrete
platforms that the reactors will have to sit on for more than two
centuries, and the drainage for the site. The siting, height &
capacity of these pieces of infrastructure is one of the most
critical aspects of the whole of the main development. Because this
application has been salami sliced, consent for the preliminary
works has already been given and right now EDF are getting on with
the work of siting these platforms at just14m Above Ordnance
Datum based on an FRA for 2017 with insufficient drainage capacity.
We
know sea-levels are rising and there's still much uncertainty
associated with quantifying these changes. Coastal Nuclear sites are
already vulnerable to climate change, to assume we can defend these
sites indefinitely is hubris.
The
heights specified in the preliminary works application are very
likely to have been underestimated, increasing the vulnerability to
flooding of the site in the future. Given the timescales these
radiotoxic buildings and their waste will have to remain in this
location, it would be criminal to grant a DCO that allows a
development to go ahead were the footings that have already been
begun are sited according to an FRA that will have been superceded
before they are even operational.
The
signs were there at Fukushima when the reactors were sited, but they
were ignored, are you going to ignore them here too?
Our
knowledge of sea-level fluctuations & climate change means it's
imperative that the height of these platforms is based on appropriate
FRAs that extrapolate far into the future & that we don't allow a
rush job & the possible consequences.
On-going
events at Fukushima are a timely reminder of the consequences of
flooding at a coastal nuclear site. The recent government report on
flood risk that was obtained by freedom of information shows that
whilst Hinkley is considered to be at relatively low risk now from
flooding that this risk is set to increase throughout the century
with it being considered a high risk by 2080 (the current estimate
for closure of the EPR) there is no assessment for timescales beyond
this i,e the 150 yr minimum that an interim fuel storage facility is
going to be required for as per current expert advice.
http://www.guardian.co.uk/environment/2012/mar/07/uk-nuclear-risk-flooding
Any
projections of floodrisk at this site have significant uncertainty in
them because the site is dependant on man-made defensos and is prone
to flooding and erosion, all of this is exacerbated further by the
prospect of other developments along the estuary. Just the attempts
in FRA's to account for other known/proposed developments within the
estuary over the next decade adds uncertainty – what about the
synergy of future developments? And all of this on top of constantly
changing climate predictions.
There
is evidence currently that significant amounts of methane are already
being released from the Arctic ocean as has been recorded by a
Russian scientist recently this is evidence
of at least one climate 'surprise' that may have already begun...
I
can find no evidence that this application has modelled the H++
scenario provided by the UKCP09. The H++ scenario provides unlikely
but physically plausible extremes particluarly as they relate to
sea-level rises, and ice-sheet dynamics. Whilst UKCP09 say that “it
is thought very unlikely that the upper end of the H++ ranges for sea
level rise and surge will be realised during the 21st century.”
It's purpose is “for users wishing to investigate contingency
planning and the limits of adaptation” If we are to believe the
predictions of the new build fantasists all spent fuel accumulated
throughout the 21st century is going to persist well into
the 22nd century, or possibly forever if we draw on
reality and historic observations. Therefore, using H++ to explore
contingency planning would be at the very least a prudent thing to
do. More information about H++ can be found here
http://ukclimateprojections.defra.gov.uk/content/view/1805/690/
We
are teetering on the brink right now of a world-wide
catastrophe because of this industry and the arrogance and folly of
politicians, scientists and technocrats. Two former Japanese
ambassadors are joining with groups across Japan begging the
international community via the United Nations to intervene and help
them with their attempts to deal with the spent fuel pools at the
Fuksuhima Daiichi plant. http://akiomatsumura.com/2012/04/682.html
Now
is not the time to talk about building more and theorising
about how we can control the uncontrollable, it matters not that EDF
have got 30 years of managing spent fuel pools TEPCO had more until
it went wrong – Murphy's law states that
anything that can go wrong will go wrong Fukushima will be the
ultimate lesson in that, we ignored the warnings from TMI Chernobyl
Mayak in Kyshtym . For the last half of the century we have been
holding a tiger by the tail. Last year we lost our grip.
Potential
impacts of granting DCO to an incomplete design
Safety
At
San Ofre in California, premature wear of steam generators currently
closed caused by specific design changes by
plant operator full report produced by industry expert Arnie
Gunderson on behalf of friends of the earth available here.
http://libcloud.s3.amazonaws.com/93/86/5/1285/Fairewinds_FOE_Cascading_Steam_Generator_Fa
ilures_San_Onofre_2012_4_12.pdf
It
seems that these changes were design changes by the operator
attempting to increase the amount of assemblies in the steam
generator to try & get more power out. This is evidence of the
dangers of regulators having a facilitative attitude towards
operators – give them an inch and they take a mile – this far too
cosy relationship between the regulators and the operators
who are just effectively different components of the same industry is
of grave concern for the public.
Time
Even
though the UK government have created a generic design assessment
process this has still not had the desired effect of ensuring that
the build happens on time and on budget, either the GDA process is
going to run over time or it's assessment is going to be incomplete
either in terms of the scope of the assessment or in terms of the
level of scrutiny.
Economic
There
is no such thing as a privately constructed owned and operated
nuclear reactor anywhere, all have used considerable resources of the
states in which they are built this project is no exception. The
government is planning to give extensive public subsidy to the
developers as well as assurance to investors that their investment is
going to show a return, this IPC process is part of that guarantee
and hence not impartial as I pointed out previously, the level of how
biased this process was made clear to me at the preliminary meeting
as I listened to the proceedings and the panels rigidity about the
timescales for the application where it became clear to me that the
desires of the invisible investors were put above an entire,
community, indeed an entire nation and untold future generations of
our people.
Neither
Okilouto in Finland or Flammenville in France have been completed on
time, both are still under construction and both are extremely over
budget. The slippage in the programme seen here already suggest that
things won't be any different here either. OF course we can rely on
the extra time pressures and the bad living and working conditions of
the EDF workforce as exemplified at Flammenville to ensure that
plenty of corners are cut in order to play catch up.
Socio-economic
The
jobs and benefit claimed by EDF that this project will bring are
nothing more than fantasy, of the 5,600 peak construction jobs that
they claim most of these will go to an imported workforce not to
local people. IF there are any local people who do manage to get work
on the construction many of these will be temporary or short-term
contracts, providing little or no job security for these people.
For
every local business that perceives a benefit there will be one who
doesn't for every b&b or shop whose trade is increased because of
the workforce there will be one who loses their trade because of the
disruption and misery that the project will create in the area.
The
transport infrastructure will be notably negatively impacted which
will have a knock on effect for tourism in the locality particularly
the tourism that uses the A39 down into north Devon.
Beyond the construction of this project it's operation will also have
a negative impact on tourism given that holidaying by two gargantuan
nuclear reactors won't be many people's cup of tea....
House
prices in the area will be negatively impacted also, in fact there is
anecdotal evidence that the project is already having a negative
impact on the housing market with many people living closest to the
site struggling to sell their properties already and that is before
construction has begun.
Frivolous
and Vexatious
A
comment about the process -
definition
of frivolous -
1.
characterised
by lack of
seriousness or sense: frivolous conduct.
2. self-indulgently carefree;
unconcerned about or lacking any serious
purpose.
3. (of a person) given to trifling or
undue levity: a frivolous, empty-headed
person.
of little or no weight,
worth, or importance;
not worthy of serious notice: a frivolous
suggestion.
These proceedings and the remit laid
out to them via the national policy statements and amendments to
planning law are a seriously frivolous waste of taxpayers money &
time. They certainly lack the ability to deliver what they should
deliver i,e a independent and impartial tribunal, although if we cut
the cake the way that the government and industry have then they will
deliver exactly what they want: a smoke & mirrors PR.
stunt to give the masses the pretence of a
democratic process.
Definition of Vexatious
-
1. Causing or tending to cause annoyance, frustration, or worry
- Denoting an action or the bringer of an action that is
brought without sufficient grounds for winning, purely to cause
annoyance to the defendant
I have definitely experienced feelings of annoyance frustration and worry defined above as a result of this process, It is
given to us without a hope of us winning purely to tie us up in
beauracratic process that has no democracy or accountability at the
end of it.
