The UK & Ireland Nuclear Free Local Authorities (NFLA) submits today its views on the Environment Agency consultation (1) on the next stage of Generic Design Assessment for the HPR1000 new nuclear reactor design being proposed for the Bradwell B site in Essex. The design is being put forward by the Chinese nuclear utility CGN in cooperation with EDF Energy and Chinese company GNI in a consortium called GNSL – General Nuclear Systems Ltd.
After the failure of the Toshiba design for Sellafield Moorside, and the Hitachi design for the Wylfa and Oldbury sites, there now only remains the EPR design approved by nuclear regulators for the Hinkley Point C and the Sizewell C site, and this HPR1000 design for Bradwell B. Apart from the technical complexities that need to be overcome for both designs, the other core challenge will be finding the many billions of pounds they will cost. This comes at a time when renewable energy projects are getting ever cheaper and more easily realisable – a core factor in the NFLA’s response.
The NFLA Secretariat attended a robust webinar between the Environment Agency, the vendor and nuclear policy NGOs including the Blackwater Against New Nuclear Group at which there was real frustration that many of the difficult nuclear safety issues within new nuclear reactors was not being dealt with in the Generic Design Assessment process, but put off to the final licensing of the reactor site.
In its consideration of the Environment Agency consultation, NFLA note:
- NFLA notes that the National Infrastructure Commission recommended that the Government should: “Not agree support for more than one nuclear power station beyond Hinkley Point C, before 2025”. In this context there is no need for either Sizewell C or Bradwell B.
- The Committee on Climate Change’s 6th Carbon Budget Report reports that the costs of decarbonisation have fallen far faster than even advocates of clean technologies expected. Renewables and energy storage costs have plummeted, there are very good reasons to think hydrogen, heat pumps, and electric vehicles can follow suit. Again, there is no need for new nuclear to plug any gaps in the energy system.
- It is of real concern to the NFLA that the GNSL submission up to 2018 did not contain the level of information the Environment Agency needs in order to carry out a detailed assessment.
- The UK HPR1000 will not be replacing a comparable reactor or reactors. For instance, the two Bradwell reactors were only 129MW each whereas a single UKHPR1000 reactor (1,180MW) would be more than 4 times the capacity. Thus, if comparing the old with the new it would be producing 4 times the discharges and 4 times the solid waste.
- Given that new reactors are expected to have a life of 60 years, it could mean that it may be 200 years before some of the spent fuel from new reactors can be disposed of in a deep underground radioactive waste repository.
- In the consultation the Environment Agency says “all exposures to ionising radiation of any member of the public and of the population as a whole resulting from the disposal of radioactive waste are kept as low as reasonably achievable (ALARA), taking into account economic and social factors. We do this by requiring designers and operators to use BAT.” NFLA believe that it is entirely reasonable to expect electricity to be generated with zero exposure of the population to cancer-causing ionising radiation, and the Best Available Technique for doing just that is to use renewable energy sources in combination with energy efficiency.
- NFLA note that the AP1000 reactor has higher gaseous emissions – far more important than liquid emissions in terms of radiation doses to local people – than other similar reactors, and it looks as though the UK HPR1000 could be even worse.
- As such, the Environment Agency should not be promoting the development of new nuclear reactors like the HPR1000.
NFLA Steering Committee Chair, Councillor David Blackburn, said:
“The reductions in the costs of renewable energy and the ease with which they are being developed are clear indications that the need for new nuclear is reducing year on year. The huge costs of Hinkley Point C also mean that any further new nuclear reactors are only likely to happen with an effective huge public subsidy. In responding to the Environment Agency, NFLA have pointed out real concerns over the level of gaseous emissions from the HPR1000 reactor and the increased levels of highly radioactive waste they would add to. Our view is that there is no need for a new nuclear reactor at Bradwell and as such this generic design assessment should be concluded.”
Ends – for more information please contact Sean Morris, NFLA Secretary, on 07771 930196.
Notes to Editors:
(1) Environment Agency consultation on its GDA of the HPR1000 being proposed at Bradwell B