Please reply to the Chairman, Charles Barnett, Tudor House, St James Street Dunwich IP17 3DU
The Shut Down Sizewell Campaign (SDSC) is a NGO numbering about 300 members, funded by private subscription and centred on the Sizewell Coast, with the aim of ridding the area of the nuclear power stations there. It keeps in touch by means of a newsletter and the regular meetings of a core group.
SDSC opposes all five of the proposals in this consultation , as described specifically below, primarily because the premises in the SRF consultation document under “Background”, “Why now”, “What has changed this year”, “Understanding the risk” and “What is a radiation emergency” are unsound.
They are unsound because:
- Suffolk Resilience Forum (SRF) is a part of Suffolk County Council (SCC), which has shown itself to be biased in favour of nuclear power in order to acquire whatever it can get from the industry, and therefore to have an interest in minimising the dangers of the industry; meanwhile a democratic deficit exists between SCC’s members and their constituents, whose views on emergency planning have been largely ignored
- SRF admits to working in conjunction with the Health and Safety Executive and the Office of Nuclear Regulation (ONR) – branches of a Government that has repeatedly announced its determination to encourage and enable nuclear power, and therefore has its own bias and inevitably influences its various departments
- SRF, in working with the ONR, admits it is likely to use the lower risk profile advocated by the International Atomic Energy Agency (IAEA), whose bias in favour of nuclear power and whose information–bending treaty with the World Health Organisation render it unfit for purpose
- SRF admits that it is influenced by the ONR in deciding the extent of its Detailed Emergency Planning Zone according to a criterion of “reasonably foreseeable scenario” which is altogether unjustified.
- SRF admits it accepts changes to national guidance on terrorism when these unjustifiably belittle the terrorist risks to Sizewell, as we show in detail below
- SRF admits it is guided by the Weightman Report, that was produced in a hurry and before it was possible to assess Fukushima properly, and that could not adequately tackle the emergency planning implications of Fukushima because that was not in its brief and because emergency planning was for its greater part not statutory (personal communication with Mike Weightman)
- SRF admits it believes that the main cause of Fukushima was a tsunami, whereas the evidence for this is presently being severely challenged; meanwhile it is obvious that human error in maintaining long-term corporate complacence was largely to blame, which TEPCO has recently agreed was the case
- SRF admits that the tests to ensure the Sizewell site can withstand natural disasters similar to Fukushima were carried out by the operators themselves, and therefore are subject to bias
- SRF’s undertaking to assist Sizewell operators to publish the risk assessment reports on the SRF’s website is so far (30 March 2013) unrealised, as far as we can see from that website, and therefore adds a spurious air of confidence to its “Understanding the risk”
“Reasonably foreseeable scenario”
Fukushima involved loss of coolant from both reactors and spent fuel, the meltdown of reactor components and of spent fuel, hydrogen explosions resulting from these, and massive releases into the ocean of radioactively contaminated water. There is no justification at all in SRF’s document for excluding these as reasonably foreseeable, while wide experience shows there is very good reason to foresee them happening at Sizewell, since they have happened often to nuclear plant.
Even if we leave out of consideration spent fuel fires, there have been 23 accidents involving reactor core meltdowns among the world’s 443 nuclear power plants that have been running for a total of 14,767 years. http://www.chinadialogue.net/article/show/single/en/5808 That is one accident every 624 reactor years. It is of no consolation for the operators of Sizewell B to claim their design requirements for their station are for a very much less frequent occurrence of meltdown than that, because the design requirements for those 443 nuclear power plants were for a much less frequent occurrence of meltdown too – once in every 20,000 years, that is 32 times less frequent than the eventuality. Those design requirements have not been fulfilled, and there is no reason to suppose that Sizewell B’s design requirement will be fulfilled either.
It is well known (although it is not mentioned in SRF’s document) that Sizewell B’s containment is not proof against large aircraft accident, accidental or intended, and that its fuel ponds have no protective containment against even against much lesser amounts of violence.
To claim, as ONR’s Dr Paul Smith claimed during the recent SRF exhibition, that the civil nuclear police at Sizewell will inevitably and invariably prevent a terrorist attack and therefore prevent that from being a reasonably foreseeable scenario, is risible. Eleven years of Afghanistan have not begun to prevent terrorism, and now Mr Cameron has warned us that there may be ten more years of Mali before we can expect respite, with the extra risk of the French-operated Sizewell reactor being attacked in response both to France’s provocation in Mali and to British assistance there.
Fukushima-scale emergencies at Sizewell are therefore fully reasonably foreseeable scenarios, so the fairy tale world of the SRF’s consultation is not fit for purpose.
The reasonably foreseeable scenarios described above are most likely to require the application of massive quantities of water to deal with them. It is inconceivable that this could happen without major releases of contaminated water into the sea as happened at Fukushima. That this will lead to marine and coastal contamination of Aldeburgh, Felixstowe, Harwich and possibly the Thames Estuary, as much of the suspended partuicles are deposited out in the extensive estuarine systems to the south of the Sizewell site. This is convincingly described by Tim Deere-Jones in his submission to the House of Commons Select Committee “Issues related to the discharge to sea of liquid/aqueous radioactive wastes from proposed new build NPS
Although that submission primarily addresses new build nuclear power stations, its conclusion inter alia “draws attention to the fact that [those] data gaps, failures and inadequacies must inevitably militate against the construction of accurate hypothetical models of radiation exposure pathways and dose rates to the public”. Furthermore, its section 19 concentrates on Potential marine ourcomes of Fukushima type LOCA, and its conclusion identifies “the absence of discussion of post LOCA highly radioactive pollution of marine waters (Fukushima)”.
None of the reasonably foreseeable scenarios resulting from such marine and coastal contamination are considered in SRF’s consulation, yet the public health and environmental consequences of them make emergency planning essential. For so long as the detailed monitoring of such data along the East Anglian coast remains an unfulfilled need, adequate emergency planning is impossible to implement. For this reason too SRF’s consultation is not fit for purpose.
Political significance of this consultation
The Campaign mistrusts the purpose of this low-key and provincial consultation, because its misplaced complacence will probably invite similar complacence in many of the public’s responses to it. This in turn will adversely prejudice the setting of any subsequent and wider consultations on emergency planning. We draw attention to the email to you of 22 March 2013 from Sean Morris of the Nuclear Free Local Authorities, entitled “Nuclear Emergency Planning – national review and Sizewell local consultation”, although the precise interpretation of it is our own.
Your five proposals
Proposal 1 In spite of the incomprehensible final sentence in your review – about an “increase where immediate response arrangements are applied” – we take it you are arguing that a reasonably foreseeable radiation emergency requires no more than a 4km Detailed Emergency Planning Zone.
We reject that entirely. The experience at Fukushima is relevant to East Suffolk, so we urge that the Detailed Emergency Planning Zone is extended to at least 30 Km.
We realise that present day emergency planning is incapable of attempting anything like this, so we advise that it is scrapped and something more appropriate is put in its place. In mitigation of the difficulties (real mitigation, which means alleviation, not “skirting around” as Government currently uses it), we urge that Sizewell B is shut down at once and its decommissioning begun without delay, and that no nuclear new build is undertaken.
Proposal 2 As well as rejecting your use of IAEA guidance for reasons shown above, we reject your reliance upon the Sizewell B Public Enquiry. It finished 28 years ago, before terrorism became the risk it is now, and before Fukushima made clear the continuing uncertainty at Sizewell B about adequate water supplies in the case of LOCA to its reactor or cooling ponds. We also reject your assertion that “We will prepare to be able to promptly implement similar countermeasures ….” whatever that means. Either you are able to implement something, or you’re not.
If, as we urge, you have a DEPZ of 30 km, that will bring about a major development of realism, both in the public and in SRF, forming a basis upon which you can build your further emergency planning.
Proposal 3 Your assumption – that experience of flood events is relevant to radiation events – reduces the validity of the argument behind this proposal, which you seem to admit at the end of the same paragraph. However, the Fukushima experience disagrees with your statement that people should not have to stay indoors for longer than 48 hours. Little point in discussing this further.
Proposal 4 The basis of your so-called “information” is so unreal that the first need is for SRF to do an overall reality check, in order to assess to what extent at present its attitudes are constrained by politics and by what may not be talked about.
Proposal 5 That you are considering precautionary evacuation of certain vulnerable groups cautiously raises the lid of a can of worms. Before you can make any useful decisions about such matters, and indeed about emergency planning for radiation emergencies at all, there needs to be open and wide-spread discussion of the reality of them, impossible so long as your present fantasies grip you. Only imagine one narrow road leading away from Leiston, with self-evacuating vehicles hurrying one way, anxious parents the other, and those parents’ children being evacuated by you on a nearby but different way out of Leiston! And realise that you haven’t even begun the huge task to which you are assigned.
The best thing you can do straight away is to lessen the risk, by urging the shutting down of Sizewell B and saying no to any new nuclear build.
Please acknowledge receipt to the address at the start of this submission.
On behalf of the Shut Down Sizewell Campaign 31 March 2013