SGR Response to the consultation on UK Government paper, The Future of Nuclear Power, submitted on 9 October 2007
About Scientists for Global Responsibility
Scientists for Global Responsibility (SGR) is an independent UK membership organisation of approximately 900 science, design and technology professionals. We work to ensure that science, design and technology contribute to social justice, environmental sustainability and the reduction of conflict. The issues raised by energy policy and as outlined in the consultation document obviously have strong links with these concerns.
This response was compiled by Dr Stuart Parkinson (Executive Director) in collaboration with SGR's National Co-ordinating Committee (NCC), which is elected annually by the membership.
We are aware that a number of environmental groups have withdrawn from this consultation process believing that the government has already made up its mind to back nuclear power, and that this process will therefore not be fair. SGR has a lot of sympathy with these views. Nevertheless we have decided to make a submission in the hope that the government is still open to considering seriously views critical of nuclear power.
1. The challenge of climate change and energy security
SGR agrees that tackling climate change and ensuring the security of energy supplies are vital challenges for the UK and other countries. Action now and a sustained strategy for many decades are both needed, and we believe this is best achieved without new nuclear power as we explain below.
2. Carbon emissions due to nuclear power
While we agree that the life-cycle carbon emissions of nuclear power stations are a lot lower that those of conventional fossil fuel power plants, the latest report from the IPCC (IPCC, 2007) acknowledges that there is some dispute over whether these emissions are as low as claimed by the nuclear industry.
Of particular concern is that limits on the supply of high grade uranium ore will require the use of more energy for mining and processing low grade ores, likely leading to significantly higher carbon emissions. If world nuclear power expands, as is currently planned, then this point is likely to be reached during the life of a new UK power station.
3. Security of supply
The consultation paper does not acknowledge that the claimed benefits in terms of security of supply due to nuclear power facilities could be significantly compromised because such facilities are more likely to attract the interest of terrorists. There are also likely to be greater risks due to the more centralised nature of new nuclear power stations. For example, an unforeseen fault mode or safety issue could develop which required the shut-down of all reactors of a given type.
4. Nuclear power economics
In its recent report on nuclear power, the Sustainable Development Commission pointed out that "there is not enough reliable, independent and up-to-date information on the nuclear plants designs available" to accurately estimate the cost of a new nuclear programme (SDC, 2006). Furthermore, the nuclear industry has a poor record of managing costs both in the UK and globally as starkly highlighted by Thomas et al (2007). While there are signs that some sections of the nuclear industry are beginning to improve, the current problems experienced during the construction of the Olkiluoto-3 power station in Finland give major cause for concern, especially as it is of a type under consideration for the UK. For example, its construction is massively behind schedule (two years behind after only two years construction time - Myllyvirta, 2007), and its financing is not under commercial conditions (Thomas et al, 2007). The major financial problems experienced by British Energy in 2002 - when it had to be 'bailed out' by the Government - are also indicative of the problems of this industry. If any financial problems do occur over the very long timescale involved, the Government has no choice but to step in with tax-payers money.
5. Should nuclear power be an option?
We do not share the view that a new generation of nuclear (fission) power stations is a necessary or desirable option for tackling climate change or energy security. SGR believes that these issues are best dealt with by: (a) improving energy efficiency and reducing energy demand; (b) improving the diversity of supply through more aggressive development of new renewables and other low carbon technologies; and (c) seriously investigating novel schemes such as a high-voltage DC electricity grid for Europe and beyond as has been recently proposed (German Aerospace Centre, 2006) which could link the UK to more diverse sources of renewable energy. A recent study by the Tyndall Centre also provides good evidence to support the view that targets more stringent than those proposed in the draft Climate Change Bill could be met without nuclear power (Bows et al, 2006). More ambitious proposals are presented by CAT (2007), and we believe these include concepts which deserve further study. More details on these views are given below and in the Appendix.
6. Safety, security, health and non-proliferation issues of nuclear power
On safety, while the risks of a major accident/incident in the nuclear reactor types favoured for new build in the UK are likely to be very low, they are not zero. We are very sceptical that figures for such risks (as quoted in the consultation document) can be reliably estimated, especially given the complexities of the systems involved. Furthermore such figures do not, and arguably cannot, take account of the risks related to terrorist activity across the nuclear sector, and hence their quotation could potentially lead to complacency. A further complicating issue is that, while the UK licensing authorities have experience in licensing a PWR reactor, they do not have experience of CANDU or BWR types (possible options for new UK plants) which have significantly different safety issues. These include different reactivity coefficient problems, on-load refuelling (with CANDUs) and using primary steam in the turbines (on BWRs).
On security, the potential terrorist threat to nuclear installations is clearly much greater now than when previous nuclear power programmes were being considered (Rogers, 2006). While it is likely that new reactors would be better protected against attack than some other nuclear and non-nuclear hazardous installations, a new nuclear power programme including the whole fuel cycle would create further risks. We are especially concerned that the unpredictable nature of terrorist activity combined with the long timescales associated with managing nuclear facilities poses risks that are very difficult to deal with. Given that the potential consequences of a 'successful' attack would be so disastrous (e.g. Barnaby, 2005), we judge this to be too greater a risk to take. Clearly, other forms of energy generation do not pose such risks.
On health issues, it is claimed by some working in this field that the risk from radioactivity ingested or breathed in is higher than in the officially accepted model, which is based on studies of risks from external sources (ECRR, 2003). Some of the studies quoted in the ECRR report appear to support this view. This area needs more open scrutiny.
On nuclear proliferation, with civilian nuclear programmes having the potential to be diverted for military purposes, as the current concern over Iran clearly demonstrates, we are very concerned about the potential effects of a UK decision in favour of new nuclear build on the international arena influencing other countries to do so. Given also that the UK parliament (on the recommendation of the government) has recently voted in favour of replacing the Trident nuclear weapons system, our nation's stance across nuclear issues has real potential to undermine international efforts to prevent proliferation. Furthermore, as discussed above, the long timescales relevant to nuclear power make it especially difficult to ensure that UK facilities themselves will not at some stage become a direct proliferation risk.
8. Nuclear waste and decommissioning
While estimates of the additional volume of radioactive waste arising from a new nuclear power programme are relatively low (~10% increase over that due to existing facilities), the increase in the radioactivity does give serious cause for concern. For example, one estimate indicates that, ten years after final fuel removal from such a programme, levels of radioactivity could be 9 times that due to existing waste (Table 12 of SDC, 2006b). We acknowledge that such calculations are complex, vary over time and are dependent on a range of assumptions, but nevertheless we believe such analysis gives real cause for concern. Furthermore, given the slow progress towards agreeing and implementing a management programme for existing waste arisings (for reasons related to technology, environmental integrity and public acceptance), as exemplified by the deliberations of Committee on Radioactive Waste Management, we believe it is premature to make decisions which will create more highly problematic waste.
While partitioning and transmutation (in a reactor or accelerator) of long lived actinides to shorter life nuclides as a means of reducing the very long term risks from radioactive waste is being studied in some countries, this is not sufficiently proven to allay present concerns about nuclear waste disposal.
In economic assessments of waste management and decommissioning, it is assumed that there will always be a real rate of return on funds put aside for long term future activities: this assumes ongoing economic growth, which may not in fact be the case. It also assumes that present estimates of costs of waste management and decommissioning will remain in line with other costs. The costs of skilled labour and of energy (major components in implementing final disposal) could escalate well beyond the growth in GDP on which the real rate of return is predicated. Even though the rate of return assumed is only 2.2%, this does effectively substantially discount the apparent costs at the time the funds are invested. (For example, at the relatively low 2.2% assumed, over 100 years - a timeframe possible for some fuel disposal options - the costs are discounted by a factor of ~9). This method of discounting long term future costs to their present worth is questionable.
10. Broader ethical issues
The ethical issues related to the decision to opt for new nuclear power are far broader than implied by the discussion in the consultation document. We have highlighted a number of these issues in our responses to other consultation questions above (e.g. #6, #8).
In general, while SGR is extremely concerned by the potentially huge impacts of future climate change, we believe that including new nuclear power in the mix poses too many risks for too few benefits. As mentioned in response #5, we believe that other low carbon paths, as discussed and/or advocated by, e.g., Bows et al (2006), German Aerospace Centre (2006), SDC (2006a) are more desirable (see Appendix). We are particularly concerned that efforts by the UK government to, for example, improve energy efficiency of buildings, control the growth of private car use and of aviation, expand the use of combined heat and power, develop and implement more energy storage technologies, and develop and expand renewable energy have been especially poor. This, we suggest, is where the focus of the ethical debate should be.
We also believe a serious debate needs to begin on the introduction of tradable personal carbon quotas (within a reducing national carbon budget). Such a measure would bring home to people the cost of carbon intensive activities, and would give major incentives for reducing energy demand and/or improving energy efficiency.
The debate over energy is also closely related to wider debates over consumption and economic growth. As an example, we believe an ethical debate is urgently needed over the priority currently devoted to raising GDP, despite the many shortcomings of such an approach (e.g. Dresner, 2002). We believe a good quality of life can be achieved with significantly lower levels of consumption and mobility, and that future generations should not be exposed to risks (from nuclear waste or climate change) as a result of our profligate energy consumption.
11. Other environmental impacts of nuclear power
Any major change to the energy infrastructure is bound to have environmental impacts. Systems which can be dismantled and removed quickly at the end their useful life have a considerable advantage over those, such as nuclear power, which require long timescales for decommissioning and dismantling.
12. Supply of nuclear fuel
As said in response #2, we are concerned that the limited supply of high-grade uranium ore will have significant implications for the life-cycle carbon emissions and energy use of nuclear power stations - especially under conditions of global nuclear power expansion. If, in response to depletion of uranium resources, there were to be construction of Generation IV ('fast') reactors, this would very likely increase security and proliferation risks due to wide use of a plutonium fuel cycle. We are very sceptical that such risks could be reliably managed over the long-term.
13. Skills capacity
There are already major concerns about skills shortages within science and technology, especially in the physical sciences and engineering whose skills are particularly in demand in the energy sector (e.g. SGR, 2006). A new nuclear power programme would likely compete for skills and resources with other parts of the energy sector, not least renewable energy and energy efficiency, which may undermine their potential role in helping to tackle climate change and improve energy security. SGR is concerned that the current attention being devoted to nuclear power by government, professional institutions and industry is at the expense of these alternatives (e.g. Parkinson, 2007).
14. Reprocessing of nuclear waste
The government's position that spent fuel from any new nuclear power stations would not be reprocessed has clear advantages in terms of reducing the risks of proliferation. However, it does imply the burial of large amounts of plutonium and other long-lived actinides with possible risks to future generations. This reinforces our concerns related to new nuclear power.
15. Other issues
Two other issues we believe should be raised: insurance for nuclear accidents; and energy R&D.
We note that the nuclear industry only has limited liability in the case of a major accident, with public funds having to be made available for any (potentially very high) additional costs. This is a form of subsidy which we believe needs to be made explicit in overall economic assessments.
Following privatisation of the electricity supply sector, UK spending on energy R&D fell by nearly 90% (RCEP, 2000). The energy industries generally are reluctant to do research unless the pay-back is seen as certain and relatively short term. While recent initiatives from government and industry of support for renewable energy and energy efficiency are welcome, they remain much too small to lead to the necessary development of the sector. This urgently needs to be addressed and we are concerned that the attention being devoted to nuclear power is in part responsible for this.
16. Do you agree with giving energy companies the option of investing in new nuclear power?
For the reasons given above, we believe that energy companies should not be given the option of investing in new nuclear power. We believe that tackling climate change and achieving energy security are best achieved through alternative measures (see #5, #10).
In the longer term, the choice of technologies should be made on the basis of information available on the overall technical and environmental risks.
18. Facilitating nuclear power
We note the large number of facilitative actions which are being pursued by the government to allow new nuclear power to become an option in the UK. These are related to particular issues of safety, security, waste management, environmental impact, planning, licensing etc and are a major aspect of the long lead times for nuclear plant. Many of the alternative technologies (wind, biomass, Combined Heat and Power, solar etc) can be installed in much smaller modules and do not require such involved procedures (see Appendix).
Measures which could reduce carbon emissions much quicker than a programme of new nuclear power stations include statutory requirements that all cost-effective energy efficiency measures are installed on homes when they change hands, and that all the most inefficient homes (particularly those with non-cavity walls) are rapidly upgraded (the German programme on energy improvements is a good example). Solar hot water systems, which would be much cheaper when installed as standard at the time of building, should be mandatory on all new build.
Technologies which are close to commercialisation and which have specific advantages in the present context include marine current turbines which exploit tidal power, and can be deployed in a number of areas round the UK coast to even out the delivery of power over 24 hours and for which the output is totally predictable. The modular nature of these devices allowing a progressive build up of capacity is an advantage.
A European high-voltage DC (HVDC) electric network (German Aerospace Centre, 2006) could connect countries and regions where renewable energy sources provide power at different times, so improving their overall utility. Solar energy in Mediterranean countries would complement UK renewable energy sources (and vice versa). Concentrating Solar Power (German Aerospace Centre, 2006), where solar energy is focussed to drive a heat engine, is technically proven (systems having operated in the USA for many years). On the timescale by which a significant tranche of nuclear power stations could be installed, it is likely that costs of solar photo-voltaics will have fallen significantly. Although setting up an HVDC network would require extensive international negotiations, it would seem possible in principle to do so before 2020.
There are technologies available which could increase the capacity of the electricity grid system to absorb a high proportion of intermittent renewables (CAT, 2007), i.e. far more than the government's 20% renewables target for 2020. These technologies include electric vehicles (and, in practice, plug-in hybrids - hybrid vehicles which can be charged from the grid with sufficient energy for most daily mileages) which could be charged off-peak and on an interruptible tariff, so could be cut-off if there was a risk if overall demand exceeding supply. Highly insulated buildings with a high thermal mass in the structure or in the heating system could also be supplied on such a tariff. CAT (2007) also proposes existing hydro-electric schemes could be used in a pumped storage mode.
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