Submission by CND To the Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK

November 2008

The Campaign for Nuclear Disarmament (CND) does not believe that there is any justification for the building of new nuclear power stations in the UK. It is not in the public interest to do so. Nuclear power is dirty, dangerous and expensive. It is also not the answer to climate change when we need a rapid and substantial decrease in our carbon emissions which nuclear power cannot possibly deliver. A combination of effective alternative measures, including renewable energy sources and energy efficiency technologies, can help tackle climate change. None of these measures involve the dangers associated with nuclear power. By choosing to pursue nuclear power the UK encourages other countries to do the same, further increasing the unique risks associated with it such as:

1. proliferation of nuclear weapons 2. contamination by toxic radioactive nuclear waste 3. nuclear accidents

CND submitted a response to the first public consultation (The Energy Review 2006) regarding nuclear power. This consultation was judged by a High Court ruling to be ‘manifestly unfair’ and ‘unlawful’[1]. On a national level we declined to be involved in a second consultation as, along with other organisations, we believed that the process was biased and the outcome predetermined. The experience of some of our local and regional group members who did decide to become involved confirmed this. Not surprisingly, Greenpeace’s complaints to the Marketing Research Standards Board were upheld when the board came to the conclusion that the market research company chosen by the government for this second consultation had in fact breached the Code of Conduct. CND is very disappointed with the government’s public consultation process. Nonetheless, in this instance we feel that there are some particularly important issues that have to be raised regarding any siting of new nuclear power stations. Specifically, we would like to raise the following points: Public acceptance The Strategic Siting Assessment (SSA) criteria do not include the issue of public acceptance around a potential new build site. Any engagement process carried out by the nominator of the site with the local community is also not sufficiently described. How is the local community to be defined and who is to decide on that definition? How and by whom will the community’s response be considered?

Local authority/regional development plans How will the siting of a new nuclear power station fit in with local authority and regional development plans? This should also be a criterion of a Strategic Siting Assessment. Other energy uses Consideration should be made of whether other energy plans are a more appropriate use for each site and for the region as a whole – particularly given the considerable time and resources required to build such a nuclear power plant. Moreover, since it may be many years before some sites are built on, a process should allow sites to be re-assessed for alternative use after a certain time period. Spent fuel storage Storage facilities for spent nuclear fuel must also be considered, particularly if spent nuclear fuel is to be stored safely on a site for at least 100 years before any long-term repository might become available. There is still no safe solution for nuclear waste storage since no such repository has yet been built anywhere in the world and plans are still on paper. Moreover, uncertainties around storage will be increased by the likely use of high burnup fuel in new nuclear power stations. This will produce nuclear waste that is much more difficult to deal with, being much hotter and more highly radioactive with an increased potential for worker and public exposure to radiation[2]. Given that a safe storage solution is still forthcoming, and that high burn-up fuel brings with it particular difficulties with regard to storage, spent fuel might need to be kept on a site for even longer than 100 years. In which case any siting assessment would need to take into account the undefined timescale for such storage facilities. Terrorism/accidents Emergency planning as a criterion is given only as a local consideration. Of course any accident or deliberate act which releases radiation into the atmosphere can potentially affect more than just the local population of a site. Depending on atmospheric conditions, radioactive contamination knows no boundaries. As new reactor designs being urged in the UK are untried and untested, there is even more reason to launch a comprehensive and independent assessment and report on the possible effects of a nuclear emergency, whether caused by a terrorist attack or an accident, at either the reactor or the spent fuel stores. Additionally, such an assessment must include transportation routes of nuclear material from or to nuclear power station sites. Site demographics In reference to any discussion related to the demographics around a site, studies must be taken into account that continue to show that there is a higher rate of cancer around nuclear power stations, particularly amongst children[3]. [1] http://www.greenpeace.org.uk/blog/nuclear/breaking-news-another-nuclear-consultation-was-fixed-20081016 [2] http://www.nuclearconsult.com/Too_Hot_to_Handle.pdf [3] Ian Fairlie, Comment: we ignore the evidence on cancer clusters at our peril, New Scientist; 26/04/2008, Vol. 198 Issue 2653, p18-18, 1p