Representation by Manfred Doppler
- Date submitted
- 28 September 2020
- Submitted by
- Members of the public/businesses
It is not clear if a new NPP is needed at all in UK. At this point in time, when renewables have already become cheaper than nuclear energy it is necessary to update the assessment of alternatives for every planned NPP and not to rely on older data. It would have also been necessary to update the electricity demand to substantiate the decision for new nuclear instead of the deployment of renewables. No sufficient proof of safe disposal for spent fuel and radioactive waste was provided in the documents. Interim storage capacities for spent fuel are not available yet, and it has not been made clear if they will be available once Sizewell C will be generating spent fuel. Also no information is provided on the geological final repository for spent fuel and high-level waste, neither on the site, the technology or the timetable. Before the claiming or deciding that the KBS-V3 method will be used for the spent fuel canisters for the final repository prove should be provided that copper corrosion will not become a problem in the long-term. Three reactors that are the design basis of the planned reactor type UK EPR™ are currently under construction, one each in Finland (Olkiluoto 3), France (Flamanville 3) and the U.K. (Hinkley Point C1). OL3 and FL3 are many years behind their initial schedule. The length of the construction period and the many difficulties demonstrate the complexity of the EPR design. The design of this reactor type needs to be re-examined in the light of the Fukushima accident. It is questionable if preserving containment integrity is guaranteed by the proposed safety design and features. Eight years ago an accident analysis was conducted. Since this evaluation, the state of science and technology underwent further development. This is reflected in new international and European regulations and guidelines that should have been taken into proper account. Severe accidents with high releases of caesium-137 cannot be excluded although their calculated probability is below 1E-7/a. Consequently, such accidents should have been included in the environmental impact assessment since their effects can be widespread and long-lasting. Site-specific factors, in particular possible danger of flooding and climate change effects, could endanger Sizewell C. And it has not been proved that the NPP can withstand terrorist attacks and acts of sabotage. The project flexRISK assesses that in case of a severe accident at the Sizewell site, all of Europe could be contaminated.