Wednesday 1 April 2015

Hinkley Point C P.R. works finally suspended

Haven 't had time to blog for months been so busy with campaigning but I just had to blog this -

Time to celebrate - EDF have suspended work on HPC!!! spread the word Fucking whoop!

  it's a bittersweet moment - I would dance around my house in celebration if I could, but as I can't I'll just sit here & think of all the beautiful trees & Skylarks & Badgers & Bats that Gree-D-F trashed to convince you all it was going to go ahead - wonder if they'll sue their PR firms for bad advice?

I was wondering how long they'd be prepared to continue to spend money on their phantom works just to keep up their false appearances. Don't get me wrong they've done plenty to trash the land out there but they never did get started on those preliminary works. Their update talks as if they've finished them but the fact is they never really  started, despite being granted permission back in 2010. The section 106 agreements (community bribes sorry CON(m)pensation) aren't due to be 'triggered' until they dewater the site - something that they haven't done and that they can't & wouldn't do without a contract (& a lot fewer legal challenges). I knewe for defineite they were in trouble quite a while ago when some good friends of mine in the construction industry began regaling me with tales of people being paid to stand around at hinkley being paid to do nothing, whilst other less fortunate stories were about people going out there to work & not getting paid.

As my friend Theo Simon so eloquently put it the HPC project is now collapsing under the weight of it's own Bullshit

I'm sure the slime bags at DECC's Office for Nuclear Development  are trying to finds some way to persuade the chinese to take over the site, heard a rumour that Hergen's selling his Granny to help raise the money - the 'Golden Share' bit like something out of Willy Wonka eh?

 So now can we concentrate on getting out with the OLD nukes & in with the reNEWables? oh yes & the not small matter of their where does Vincent De Rivaz & Hergen Haye live again? I'm sure it'd fit nicely under there homes & I'm sure there's many a fracking firm who'd give them their very own deep borehole...

Thursday 15 January 2015

Sellafield Cover-Up

"Top civil servants and nuclear administrators colluded to prevent MPs from challenging a massive sweetener to a private business taking over the running of Sellafield, internal documents in the hands of The Independent on Sunday reveal. The documents, obtained through the Freedom of Information Act, also disclose that the Government pushed through the handover at breakneck speed because it feared that the “unstable management arrangements” of the controversial Cumbrian nuclear complex risked its safety."

 "The documents have come to light only as a result of persistent pressure from Dr David Lowry, an independent environmental policy and research consultant" -  Well done David!

oh and this is of interest to those of you in Somerset
 "Other confidential documents, received after two Freedom of Information Act applications, divulge that three local councils in Somerset asked for £750,000 to fund a planning officer and legal advice from companies that want to build nuclear power stations in their areas, raising questions about conflicts of interest, and that the officially neutral NDA considered coming out in favour of new reactors."

 - three councils.. Sedgemeoor,West Somerset Somerset County Council by any chance?

My submission about Hinkley C to the National Planning Dictatorship

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 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 public can have no faith that the policy is sound, and no faith in the government officials, civil servants and industry stooges who have from the outset colluded to create this so-called nuclear renaissance.

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.

Even back in 2007 there was evidence of the “dislocation between processes and outcomes, Prime Minister Tony Blair was reported as saying “this will change the consultation. This won’t affect the policy at all.” (Guardian, 23 May 2007).”

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.
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:
In  the  recovery  phase,  TEPCO  have  worked  to  provide  additional  support  to  the  structure  of  Reactor  Unit  4’s  pond  but  this  appears  to  be  precautionary  against  further  seismic  activity.”

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.”
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 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?

Both designs put forward to the UK regulators here got their own take on rack rearrangement - the designs for both pools have both got increased fuel assembly density in the pools relative to the designs put forward in both Finland & France
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.” ” 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 todefine a generic decay heat level (and therefore decay time) beyond which a zirconium fire is not physically possible.” [emphasis added]

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.

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
  • breaks in pipes connected to pools upstream of the two isolation valves of the cooling system and of the drainage lines of compartments.
  • break of the transfer tube
It doesn't seem unreasonable to surmise that either of these might be possible if the initiating event is a beyond design basis event.

Whilst protection against internal explosion will be “afforded by the use of preventative measures” shaking from aircraft hit considered in pre-construction safety report but not the associated fire from aviation fuel.

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
This hesitance seemed prudent given that
Fuel behaviour is another source of technical long term changes, i.e. the fuel can develop cracks and brittle fracture could occur, in particular with high burnup fuels” pg 5
As there is no final disposal facility for spent fuel in current operation, it is not possible at present to define final disposal acceptance criteria in detail.” pg 6

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

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.
Activity and decay heat of high-burn up fuel is 'pushing the envelope' with respect to dry cask design and safety requirements so in a bid to keep operator costs down the U.S. federal government are taking on the dry storage of the waste until it is ready for final disposal, it is suggested by the nuclear consultation group that this is what may happen here pg 12

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 ) 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.”

The Nuclear Decommissioning Authority have rubber stamped Areva/EDFs case for the disposability of the spent fuel and ILW concluding:
RWMD has concluded that ILW and spent fuel from operation and decommissioning of an EPR should be compatible with plans for transport and geological disposal of higher activity wastes and spent fuel. It is expected that these conclusions eventually would be supported and substantiated by future refinements of the assumed radionuclide inventories of the higher activity wastes and spent fuel, complemented by the development of more detailed proposals for the packaging of the wastes and spent fuel and better understanding of the expected performance of the waste packages.” [emphasis added] pg 8

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
" 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..

According to the Preconstruction Safety report the underwater fuel storage rack and the fuel pool cooling systems both enjoy exclusion from the 'passive single failure criterion' on the grounds of 'low pressure & temperature' and 'strict inspection requirements' The PTR cooling system, the automatic isolation function of the drainage lines of the reactor and fuel buildings are both reliant on 'the mains diesel' and the PTR third cooling train is to be backed up by a final emergency diesel generators in plant states D,E & F

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 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!)

Ignoring the issue of mechanical failure of the diesel generators – what is the plan for when there is no fuel for them? Can the government guarantee an uninterrupted supply of Oil in 60 years time? Or a hundred years time? Or a hundred and fifty years time? The evidence suggest not when they are being advised now to expect fuel supply interruptions within the next five years.

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
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.

Despite the troubles besetting the existing Sellafield plant (so far produced only 13 tonnes of fuel in 8 years instead of the 120 tonnes per year it claimed it would produce, production is also ten years behind schedule), the cost to the taxpayer so far has been £1.34 billion and a further £800 million in running costs is expected this decade *

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).

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.

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.

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

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.

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

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.

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.

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.
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.

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.
  1. 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
  • - the vexatious questions posed by software copyrights

  1. 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.