24th April 2006
Stroud District Green party's submission to the Health & Safety Executive re nuclear licensing
1. General comment
We would like to strongly object to the fact that only one month has been given for comment on this issue. The Stroud District Green party have in the past few months completed submissions to the Energy Review, the NDA's strategy and CoRWM processes alone to say nothing of other consultations taking place that we wish to have an input. In the light of this we would seek that before any changes take place to the licensing process, the HSE must organise a further round of consultation under appropriate Government guidelines.
2. Concern re direction of consultations
We are also very concerned by a number of developments:
- documents released under the Freedom Of Information Act reveal nuclear industry lobbying for reactor pre-licensing arrangements in which all major issues (environmental, security, safety and waste) are dealt with behind-closed doors. This would leave local authorities, the public and Parliament with little oversight at a public inquiry (i).
- guidance from the Office of Civil Nuclear Security that says that objectors will be prevented from seeing detailed reactor plans at planning inquiries. Instead the attorney general will select an "appointed representative" to argue their case instead (ii).
- the Draft Nuclear Industries Security (Amendment) Regulations which would extend the obligations to protect sensitive nuclear information(iii) to cover any person in the UK who has information about nuclear sites this represents a worrying attack on public participation in nuclear decision-making. Stroud District Green party made a submission to the DTI on this point earlier this year. Under the proposed security regulations anyone who may have access to sensitive nuclear information - through legal actions or local authority work, emergency planning or general safety/security work, will be have to be vetted (approved) by the Secretary of State as being of suitable character and integrity.
We do not see how greater certainty over licensing and a shorter planning processes might work in practice and how the levels of scrutiny and safeguards can be maintained and improved?
3. Pre-licensing process and new designs (Section 5.0. and 7.0.)
It is imperative that the Nuclear Installations Inspectorate (NII) be allowed to retain all its existing powers to research and vet new designs and insist on strengthening any weaknesses before granting a licence. The Pre-Licensing approach suggested by British Nuclear Fuels Ltd looks very much like a short-cut to this necessarily lengthy process with obvious benefits to the industry but none to the community. We also consider that as a matter of course support is given for the current NII policy is upheld that all modifications made in reactor design are in the direction of greater safety.
Electricite de France's announcement that it would build ten reactors here subject to shorter planning processes was unacceptable but reflected in previous forcasts given by City analysts. The nuclear industry must be answerable to a transparent, thorough and robust mechanism of accountability. This should continue to include wide-ranging analysis of the local requirement for the plant with the availability for cross-examination, in the public arena, of industry experts - this should include health issues, safety issues and security issues. It is even in the interest of the Government and the industry to observe this protocol as the public will resist and resent any sense that a nuclear power station is being foisted on them. There will be outrage at the idea we can just debate the colour of the front door.
4. Lessons learnt from previous licensing experience of nuclear power plant (section 8.0.)
We do not consider the licensing process anything like transparent enough. Any licensing process should be open to much greater public involvement. We have moved on a long way from the 1950s and it is clear that reactor licensing which excludes public input is no longer acceptable. It should not be possible to 'sign off' on a design without public comment. This should be clear from the beginning of the process so that those applying for their designs to be considered will be clear on the processes expected in the UK.
5. Regulatory strategy (section 9.0.)
Safety cases resulting from applications for the NII to accept new reactor designs must be published and a suitable period allowed for public comment before the HSE accepts them. If necessary, safety cases should go through a series of consultations if major issues are unresolved at draft publication stage. It is also important that even if an issue is discussed at design stage, for example spent fuel storage, then the HSE must also allow for that issue to be discussed thoroughly at any public inquiry - along with site specific issues.
Philip Booth, on behalf of Stroud District Green Party
(i) Guardian 21st January 2006
(ii) Terror fears draw veil over nuclear plants, by Richard Norton-Taylor, Guardian 6th May 2005.
(iii) The Draft Nuclear Industries Security (Amendment) Regulations. DTI December 2005