John Busby 

Response to the Government’s consultative document

“The Future of Nuclear Power” 

30 August 2007 

The following is my response to the Government’s consultative document “The Future of Nuclear Energy”. 

Q 1 – To what extent do you believe that tackling climate change and ensuring the security of electricity supplies are critical challenges for the UK that require significant action in the near term and a sustained strategy between now and 2050? 

ANSWER: Fossil fuel depletion will have a drastic effect on the economy unless steps are taken to adopt an energy leaner lifestyle, although the consequent reduction in carbon emissions will ameliorate the effect on climate change. Unfortunately the models used by the Hadley Centre and Stern are deficient as they take no account of the passing of the global oil peak and the coming peaks in natural gas and coal production. Although alleviating climate change by reducing carbon emissions is a serious and urgent global challenge, the progressive decline in the availability of fossil fuels will present a greater problem for the world. There is now an All Party Parliamentary Group on Peak Oil and Gas so that an awareness of peak oil and gas may now be engendered. 

Q 2 – Do you agree or disagree with the Government’s views on carbon emissions from new nuclear power stations? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: Disagree. The Government’s views are ill founded. The carbon emissions from the nuclear fuel cycle have been understated by the industry in an attempt to bolster the weak case for nuclear power. The carbon emissions from the mining of uranium and the manufacture of nuclear fuel would be significant if recourse to low grade ores is attempted. Also decommissioning and the processing of nuclear waste will require fossil fuels as it occurs mostly after the fission is at an end. Because the energy expended in extracting uranium from the lower grades exceeds the net energy resulting from a subsequent nuclear fuel cycle, a recourse to nuclear power would be futile and is therefore unlikely. As primary uranium production is falling and the secondary sources from ex-weapons material are ending in 2012, the nuclear renaissance will stall and any savings in carbon emissions an illusory hope. 

Q 3 – Do you agree or disagree with the Government’s views on the security of supply impact of new nuclear power stations? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: Disagree. New nuclear power stations are expected to be based on Generation III and III+ types, the first example being the prototype Areva EPR under construction in Finland. Delays and manufacturing problems have increased its capital cost and its performance is unknown. Failing supplies of natural uranium to France will lead to losses of supply due to an over dependence on nuclear generation (78%). Japan has closed seven stations built on an earthquake fault line. The USA depends for half of its nuclear fuel on diluted ex-weapons HEU from Russia, while  Russia itself suffers from a shortfall in primary production and will have to rely on the ex-weapons programme to fuel its planned expansion. The UK is becoming increasingly dependent on imported fossil fuels, particularly gas and while the security of supply is rapidly being eroded it cannot be relieved by a 100% importation of nuclear fuel. There is no source of carbon-free electricity, other than wind and sea-current sources, as the adoption of so-called "clean coal" technology would require the consumption of up to 50% more coal and is an unlikely prospect. Contrary to claims by the industry the looming shortage of uranium represents the biggest challenge to its restoration.

Q 4 – Do you agree or disagree with the Government’s views on the economics of new nuclear power stations? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: I agree with the Government's analysis if, it as it appears to be presented, that nuclear power will need guaranteed carbon credits for it to be viable. The problem with this is that as fossil fuels deplete, the ability of the "dirty" generators to compensate for the poor economics of the "clean" progressively reduces. Although EdF/Areva, being mostly French state-owned need no subsidy, the demand by EdF for guaranteed carbon credits over the operational life of a claimed 60 years is equivalent to one and is an admission of non-viability. This shows that the claims of the nuclear lobby that there is no need of subsidy is undermined by the demands of the most likely developer. 

The new designs of water reactor, notably the Westinghouse AP1000 and the European EPR, are yet to be tested. There can be no reliable evidence on the economics of nuclear power from the new designs until they have been in service for a number of years. An analysis of the UK nuclear programme from its inception in 1956 until Sizewell B has been decommissioned shows that the consumer/taxpayer has and will have paid around three times for electricity than would have been the case from other sources. The missing consideration is the need for a bond to be raised by the developer able to cover subsequent liabilities. Had this been a requirement when British Energy was privatised, when the business went into insolvency the nuclear liabilities would not have been passed to the government. In the event the annual levy on generation lapsed. 

Q 5 – Do you agree or disagree with the Government’s views on the value of having nuclear power as an option? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: Disagree. Nuclear power provides only a 20% contribution to electricity generation and its contribution cannot to any great extent replace the loss of energy from oil for transport, from gas for generation, domestic heating and industry and from coal for generation. That is not to say that an energy strategy relying on "clean" coal or wind, sea currents and biomass can fill the gap. The challenge to the Government is to nurture a low energy lifestyle, which means the importuning of unwarranted uses of energy such as Formula One and motorised water sports. 

Q 6 – Do you agree or disagree with the Government’s views on the safety, security, health and non-proliferation issues? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: Disagree on safety issues. The Government should by now have closed all the AGR's as a steam leak over hot graphite could generate CO and hydrogen and could explode as did Chernobyl and the disintegrating moderator blocks are likely to block safety rod channels stopping them from being fully dropped when needed for an emergency reactor shutdown. Revenue seems to be the pre-eminent consideration. 

Q 7 – Do you agree or disagree with the Government’s views on the transport of nuclear materials? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they?  

ANSWER: Agree. 

Q 8 – Do you agree or disagree with the Government’s views on waste and decommissioning? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: Agree in part, but the risks, complexity, difficulty and predicted costs of legacy waste disposal and decommissioning can only be estimated, as has partly been done by the NDA. It had been hoped that revenue from Thorp and MOX would reduce the liabilities, but they have only been increased by leaks and poor performance. Spent fuel and plutonium can only be recycled with renewed investment in enrichment and processing. The unknown contents of the legacy silos and pools show the incompetence of successive managements of Sellafield and provide little confidence that in future things will be different. Far from being a "valuable resource" the waste inventory will remain a liability for years.  The materials of the closed reactors will have been irradiated and subject to deterioration and they must be decommissioned. The Government through the NDA has injected some realism into the subject and has earmarked several billions of pounds of taxpayers’ money for the decommissioning and waste disposal. There seems little point in adding to the burden with the unknown requirements of a new generation of reactors.        

Q 9 – What are the implications for the management of existing nuclear waste of taking a decision to allow energy companies to build new nuclear power stations? 

ANSWER: The implication is that a considerable capital sum should be lodged as a bond up front by the developers to cover future liabilities. 

Q 10 – What do you think are the ethical considerations related to a decision to allow new nuclear power stations to be built? And how should these be balanced against the need to address climate change? 

ANSWER: The ethical consideration is that it should be admitted that there is no possibility of meeting the expectations resulting from economic growth of the current ilk. The public should be made aware of the depletion of fossil fuels and the consequences. To pretend that nuclear power will contribute to our energy needs rather than absorb capital needed for insulation and energy saving measures is inappropriate. The ethical questions of the eventual total depletion of fossil fuels (which can never be replaced) are compounded with those related to the environmental impact of carbon emissions. 

Q 11 – Do you agree or disagree with the Government’s views on environmental issues? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: Disagree. The main global problem is not climate change – it is the depletion of resources. 

Q 12 – Do you agree or disagree with the Government’s views on the supply of nuclear fuel? What are your reasons? Are there any significant considerations that you believe as missing? If so, what are they? 

ANSWER: Uranium occurring in ores of a sufficient grade only occurs in a few countries, notably Canada and Kazakhstan, though even in the latter, resort to in-situ leaching is necessary. In Australia the average ore grade is a mere 0.045% and without co-products uranium mining there will decline. Exploration continues apace but no new deposits of a sufficient size to replace the soon to be gone secondary supplies have been located. Production is failing in Canada due to the flooding of the new Cigar Lake mine and in Australia due to the flooding of the soon to be abandoned Ranger open pit mine, compounded by the running down of the current underground Olympic Dam mine. The feasibility study of the Olympic Dam mine as an open pit has been delayed a year, so that production if it ever starts will not be until 2015. 

In the longer term, developments in nuclear fuel cycle technology, such as hydrogen production in a high-temperature gas-cooled reactor and actinide destruction in a sodium-cooled fast reactor are the outcomes of a so-called Generation IV Roadmap supported by ten countries. The use of fast reactors for the "holy grail" of plutonium fuel breeding from depleted uranium has apparently been set aside by the need to sustain transport with hydrogen and treat the long-life transuranics from uranium-fuelled reactors. 

Q 13 – Do you agree or disagree with the Government’s views on the supply chain and skills capacity? What are your reasons? Are there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: The UK is in the process of dismantling its nuclear power capability. We are no longer capable of designing new power reactors and these have to be procured from abroad. If Areva is chosen as the preferred builder, then a fuel cycle capability will not be needed as the fuel will originate in France. There are therefore security of supply issues which rule out suggestions that nuclear power is "homegrown" or "indigenous" - it will be totally reliant on others as is the primary supply of uranium. 

Q 14 – Do you agree or disagree with the Government’s views on reprocessing? What are your reasons? As there any significant considerations that you believe are missing? If so, what are they? 

ANSWER: Reprocessing is an essential element in the fast breeder cycle, were it ever to be successful. The plutonium "bred" in the U-238 blanket surrounding the plutonium-fuelled fast reactor has to be separated out to be able to supply the new fuel fabrication plant with a fresh supply of plutonium. In the USA reprocessing is illegal, so the expertise is in the UK, France and Japan. The experience of it at Sellafield offers no reassurance of success. There are no "vast" energy resources in the form of “spent” nuclear fuel, without an equally vast expenditure in re-enrichment. The "resources" (or liabilities) at Sellafield would only fuel 2 or 3 reactors for their anticipated lifecycles. There is little alternative to performing a modicum of waste processing and placing it in a repository.  

Q 15 – Are there any issues or information that you believe need to be considered before taking a decision on giving energy companies the option of investing in nuclear power stations? And why? 

ANSWER: A review of the uranium supply situation is needed as the so-called IAEA "Red Book" is based on a misconception that rising prices will open up new reserves. 

Q 16 – In the context of tackling climate change and ensuring energy security, do you agree or disagree that it would be in the public interest to give energy companies the option of investing in new nuclear power stations? 

ANSWER: Disagree. They are unlikely to do so without a hidden subsidy like guaranteed carbon credits. 

Q 17 – Are there other conditions that you believe should be put in place before giving energy companies the option of investing in new nuclear power stations? (for example, restricting build to the vicinity of existing sites, or restricting build to approximately replacing the existing capacity).  

ANSWER: None needed – they will be unlikely to invest without some financial assurances, which the government denies it will provide. 

Q 18 – Do you think these are the right facilitative actions to reduce the regulatory and planning risks associated with such investments? Are there any other measures that you think the Government should consider?

ANSWER: None needed – it is highly unlikely that any new stations are built, especially if some of the French lights go out. 

End of my response to the consultative document “The Future of Nuclear Power”.