Representation by Stowarzyszenie 'Wspólna Ziemia' (Association Common Earth) (Stowarzyszenie 'Wspólna Ziemia' (Association Common Earth))
- Date submitted
- 30 September 2020
- Submitted by
- Members of the public/businesses
It is not clear if any new (additional) nuclear power unit is needed at all in the UK. Currently, as renewable energy sources have already become cheaper than nuclear energy (both as regards installation and power generation), it is necessary to update assessments of alternatives for any and every planned NPP and not to rely on outdated data. It would also be necessary to reassess the electricity demand forecast to substantiate the decision for new nuclear build against other energy policy measures (such as energy efficiency and saving plus deployment of more renewable generation sources coupled with storage). No sufficient proof of safe disposal for spent nuclear fuel (SNF) and radioactive waste (RW) was provided in the documents. Interim storage capacities for SNF are not available, yet, and it has not been made clear if they will be available once Sizewell C will be generating SNF. Also, no information is provided on the geological final repository for SNF and high-level waste (HLW), either about the site, or technology, or timetable of implementation. Before claiming or deciding that the KBS-V3 method will be used for the SNF canisters for final repository, a proof should be provided that copper corrosion will not become a problem in the long-term. Four reactors that are the design basis of the envisaged reactor type (UK EPR) are currently under construction in the OECD countries: one each in Finland (Olkiluoto-3), France (Flamanville-3) and two in the UK (Hinkley Point C1 and C2). Construction of OL-3 and FL-3 are each many years behind their initial schedules and manifold over their individual budgets. The prolonged schedules and numerous and unexpected difficulties they have faced during this phase demonstrate complexity of the EPR design. The design of this reactor type needs to be re-examined also in the light of the Fukushima accident. It is questionable if preserving containment integrity is guaranteed by the proposed safety design and features. Accident analysis was conducted only eight years ago. Since this evaluation, the state of science and technology has progressed a lot. This is reflected in new international and European regulations and guidelines that should be 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 have to be included in the environmental impact assessment, since their effects can be widespread and long-lasting. Site-specific factors, in particular high risk of flooding and other climate change effects, could impact the unit in question. Further, it has not been proved that the unit will be able to withstand terrorist attacks and acts of sabotage. The project flexRISK assesses that in case of a severe accident at the Sizewell C's site, most or even entire Europe could be radioactively contaminated. [- ends -]