Further supplementary memorandum submitted
by Blackwater Against New Nuclear Group
ADDITIONAL EVIDENCE
AS REQUESTED
FOLLOWING PRESENTATION
OF EVIDENCE
TO SELECT
COMMITTEE, 27 JANUARY
2010 BY CHAIRMAN
ALAN WHITEHEAD
This additional submission takes the form of
a list of criticisms of the contents of the Draft NPS reports
and associated documents which illustrate the quality of these
and provide additional support for the demand that this exercise
is flawed and should not be approved.
The list includes only those criticisms which
have been particularly notable. There are others.
DRAFT OVERARCHING
NPS FOR ENERGY
EN-1
1.1.2 result in adverse impacts outweighing
the benefits.
No suggestion given on how this is evaluated.
1.3.5 generation of electricity from
renewable sources other than wind, biomass or waste is not within
the scope of this NPS.
This excludes some of the options such as tidal,
or wave power which the UK is well placed to benefit from.
2.1.8 applicants should demonstrate to
the IPC that they have considered and planned for the impacts
of climate change on their proposal.
How can they do this for nuclear at vulnerable
sites like Bradwell when they only have 100 year climate projections
and the sites will be occupied for over 160 years?
2.1.14 We need sufficient capacity to
meet demand at all times.
The document makes only passing reference to
planning to reduce energy demand.
3.1 within the context of the overall
strategic framework set by Government, in principle, new nuclear
power should be free to contribute as much as possible towards
meeting the need for 25 GW of new non-renewable capacity. The
Government expects that under this approach a significant proportion
of the 25 GW will in practice be filled by nuclear power.
Nuclear contribution is thus left to decisions
of the market place, not government planning. Alternatives must
be planned if 25GW deemed essential.
The IPC does not need to consider the relative
advantages of one technology over another given the Government's
view that companies should be permitted to determine the individual
projects to bring forward within the strategic framework set by
the Government, taking account of the clear benefits of a diverse
energy mix.
This further shows the weakness of government
planning and also states the importance of diversity, yet having
already limited it in 1.3.5 above.
3.3.10 Over these longer time horizons
demand is likely to rise, particularly as a result of increased
demand.
This does not make sense.
3.4.3 Wave and tidal—the UK has
significant potential for wave and tidal energy, but many of the
technologies for making use of the wave resource and tidal currents
are still at the prototype or demonstration stage, although proven
technology exists for tidal range generation. Para 1.3.5 explains
how this NPS relates to wave and tidal generation.
See 1.3.5 above, where there is no mention of
wave and tidal power.
3.8.7 The figures in this section show that
approximately 40 GW of energy will flow into the midlands and
southeast in 2020 from elsewhere in the country. The NPS makes
no attempt to deal with this imbalance of supply with demand.
The transmission losses incurred, and the omission of combined
heat and power due to remote power station locations, will add
to energy inefficiency rather than improving it. This adds to
the national energy need unnecessarily.
4.1.1 (iv) The IPC should take into
account adverse impacts—environmental, social and economic—including
those identified in this NPS and the relevant technology-specific
NPS, as well as local impacts identified in the application or
otherwise. The IPC should ensure it takes account of any longer-term
adverse impacts that have been identified and any cumulative adverse
impacts.
4.1.1 (v) If the IPC is satisfied
that the adverse impacts identified (including any cumulative
adverse impacts) outweigh the benefits of the proposed development
(taking into account measures to avoid, reduce or compensate for
those adverse impacts) consent should be refused.
These statements are not reflected in nuclear
NPS-6 where IROPI is regularly mentioned together with the comment
that all nuclear sites are needed even if significant adverse
impacts cannot be mitigated.
4.2.1 All proposals for projects that
are subject to the European Environmental Impact Assessment Directive
must be accompanied by an Environmental Statement (ES) describing
the aspects of the environment likely to be significantly affected
by the project. The Directive specifically refers to effects on
human beings, fauna and flora, soil, water, air, climate, the
landscape, material assets and cultural heritage, and the interaction
between them. The Directive requires a description of the likely
significant effects of the proposed project on the environment,
covering the direct effects and any indirect, secondary, cumulative,
short, medium and long-term, permanent and temporary, positive
and negative effects at all stages of the project, and also of
the measures envisaged for avoiding or mitigating significant
adverse effects21. When considering a proposal, the IPC should
satisfy itself that likely significant effects have been adequately
assessed, and should request further information where necessary.
The Appraisal of Sustainability for Bradwell
does not follow these directives. Is it realistic to expect a
developer to be more rigorous than DECC and the NPS?
4.2.2 While not required by the EIA Directive,
the IPC will find it helpful if the applicant also sets out information
on the likely significant social and economic effects of the development,
and shows how any likely significant negative effects would be
avoided or mitigated. This information could include matters such
as employment, equality, community cohesion and well-being.
Comment as above.
4.4.3 Given the level of need for energy
infrastructure as set out in this NPS, the IPC should have regard
to the possibility that all suitable sites may be needed.
Straightjacket for IPC?
4.6.5 Under guidelines issued by BIS
(then DTI) in 2006, any application to develop a thermal generating
station under Section 36 of the Electricity Act 1989 must either
include CHP or contain evidence that the possibilities for CHP
have been fully explored.
This section of the report states the importance
of combined heat and power but this importance is not reflected
in the choice of sites for nuclear.
4.8.6 Applicants should use the latest
set of UK Climate Projections to ensure they have identified appropriate
measures to adapt to the risks to the proposed infrastructure.
These projections extend for 100 years, whereas
sites will need to be secure for 160 or more years.
4.8.10 The IPC should satisfy itself
that there are not critical features of the design of new energy
infrastructure which may be seriously affected by more radical
changes to the climate beyond that projected in the latest set
of UK climate projections, taking account of the latest credible
scientific evidence on, for example, sea level rise.
Inadequate planning, as above.
4.8.12 Adaptation measures can be required
to be implemented at the time of construction where necessary
and appropriate to do so.
Adaptation measures must be required would be
more acceptable.
4.10.3 The IPC should work on the assumption
that the relevant pollution control regime will be properly applied
and enforced. It should act to complement but not seek to duplicate
it.
This appears to be contradicted by:
4.10.8 The IPC should not refuse consent
unless it has good reason to believe that any relevant necessary
operational pollution control permits or licences or other consents
will not subsequently be granted.
Evaluation of pollution controls compliance
must carried out to do this.
4.18.9, 10, 11, 12, 13 These relate to the
importance of protecting designated conservation sites but then
states that these designations should not be used to refuse development
consent. Yet Dungeness has been classified as unsuitable for these
reasons. Consultation on draft National Policy Statements for
Energy Infrastructure, Dungeness Summary P 71.
4.18.17 Other species and habitats have
been identified as being of principal importance for the conservation
of biodiversity in England and Wales and thereby requiring conservation
action. The IPC should ensure that these species and habitats
are protected from the adverse effects of development, where appropriate,
by using conditions or planning obligations. The IPC should refuse
consent where harm to the habitats or species and their habitats
would result, unless the benefits (including need) of the development
outweigh that harm.
More direction here.
DRAFT NUCLEAR
POWER NPS EN-6
2.3.1 Nuclear power is low-carbon, economic,
dependable, safe, and capable of increasing diversity of energy
supply and reducing our dependence on any one technology or country
for our energy or fuel supplies. Excluding nuclear power as an
option for generating electricity would make it harder and more
expensive to meet our emission targets. It could also jeopardise
the security of the UK's energy supply.
The claims here are contestable.
3.6.2 The potential for delivering CHP
from a nuclear power station is constrained by the need to minimise
the radiological consequences to the public in the unlikely event
of
a serious nuclear accident. Consistent with the
SSA demographic criterion applied to
the siting of new nuclear power stations sites
are likely to be located away from major
population centres, which may limit the viability
of CHP schemes.
This is in conflict with the desire for CHP
and illustrates the government's confusing demographic criteria.
3.8.18 Based on domestic and international
experience the Government is satisfied that interim storage facilities
are and will be safe and effective, and will remain so for as
long as is necessary, for example through building of new stores
and periodic refurbishment of stores if needed, until geological
disposal is available for use. In the event that geological disposal
facilities are not available to accept radioactive waste in accordance
with the indicative timetable set out above, the Government is
satisfied that interim storage will provide an extendable, safe
and secure means of containing waste for as long as it takes to
site and construct a geological disposal facility.
This states indefinite storage beyond 160 years
is possible.
4.2.9 The Government has also concluded
that nominated sites in lower flood zones should not be considered
as reasonably available alternatives to those in the higher flood
zones. This is because the NPS sets out that all the sites listed
in this NPS are needed in order for the Government to meet its
objectives on climate change and for the UK to become a low carbon
economy.
All sites needed, again.
4.6.1 The AoS identified that the potentially
suitable sites share the following landscape issues: the sites
are generally in less populated areas that may have value for
visual amenity and as landscape resources; they are coastal/estuarine
sites; and that the scale of the facilities means that the scope
for visual mitigation is quite limited. In addition, because of
the timescales involved, there is some uncertainty over future
land uses once sites are decommissioned.
This is not the case at Bradwell due to the
proximity of the north coast of the estuary, less than 2 miles,
and the importance of employment in holidays, tourism and sailing
in the estuary. The value of visual amenity is important to these
industries.
4.6.3 Visually-intrusive cooling towers
can increase a nuclear power station's visual impacts on the landscape.
However, with the exception of Oldbury, cooling towers are not
the preferred option proposed by the nominators for cooling.
This is untrue, Iberdrola, currently the most
likely site developer, in their letter of interest in Bradwell,
sent to DECC March 23rd 2009, clearly stated their wish to construct
up to three reactors including cooling towers as required for
reactors 2 and 3.
4.7.1 The AoS identified that there are
likely to be positive effects of local economic
significance, although these are less significant
at the regional scale except where there are clusters of potentially
suitable sites for new nuclear power stations, particularly in
the south-west and north-west of England.
The AoS omits mention of negative economic effects
which are likely to occur.
4.8.7 Given the potential for positive
employment opportunities as a result of the development of new
nuclear power stations the IPC should give significant weight
to the effect of employment on human health and well being.
More of the same.
4.13.1 The objective of Government's
policy on demographics and the siting of nuclear power stations
is to limit the radiological consequences to the public in the
unlikely event of a serious nuclear accident. This policy is a
measure of prudence over and above the stringent regulatory requirements
imposed on nuclear operators to prevent such accidents.
This prudence does not extend to credible emergency
plans for the 15,000 on West Mersea who are regularly cut off
by tides. If the stringent regulatory requirements are indeed
sufficient then the power stations can be placed closer to where
they are needed.
5.6.5-10 Covers demographics at Bradwell
and the need for any emergency planning to be covered at the time
of an application. This implies that effective plans are possible
even over 160 or more years. In the case of West Mersea this seems
unlikely. Who would pay for this? The site operator? What if major
expenditure is required after decommissioning but during the indefinite
interim waste storage period?
5.6.28 The Environment Agency has advised
that it is potentially reasonable to conclude that a nuclear power
station within the nominated site could potentially be protected
against flood risks throughout its lifetime133, including the
potential effects of climate change, storm surge and tsunami,
taking into account possible countermeasures. The Environment
Agency have noted in making this assessment that it is likely
that any new development at Bradwell would be built on higher
or raised ground so reducing the need for protection.
This statement is extremely weak and could be
considered unreasonable due to the compounded number of potentials.
It is not helped by the reliance on 100 year projections
to deal with a 160+ year problem.
5.6.31 This site passes this criterion.
This is because, based on, in particular, the advice of the Environment
Agency and the findings of the Appraisal of Sustainability, it
is reasonable to conclude that a nuclear power station within
the nominated site could potentially be protected against flood
risks throughout its lifetime, including the potential effect
of climate change, storm surge and tsunami. This takes into account
the potential identified by the Environment Agency to protect
the site and to mitigate risks although, as with all sites, the
potential effects of any mitigation on the surrounding area will
have to be carefully considered as part of a flood risk assessment
should any application be forthcoming.
The environment agency carries the can for this
woolly statement which has now been hardened up to look better.
5.6.56-62 Cover the potential impacts on
the sites of international importance covering almost all of the
Blackwater Estuary and around the Dengie Peninsula. These areas
immediately border the proposed site and extend within it.
57. The Appraisal of Sustainability findings
on sites of international importance are taken from the Habitats
Regulations Assessment137. Taking into account the strategic nature
of the plan and the information available, the Habitats Regulations
Assessment at this strategic level cannot rule out potential adverse
effects on Dengie SPA/Ramsar site, Blackwater Estuary Ramsar Site,
Colne Estuary SPA/Ramsar site and the Essex Estuaries SAC, through
impacts on water resources and quality, air quality, habitat and
species loss and fragmentation/coastal squeeze and disturbance.
The designation identified fall immediately adjacent or slightly
within the site boundary and the Habitats Regulations Assessment
finds that there is a risk that development activities encroach
into these designated areas, for example the potential for a marine
landing facility, cooling water infrastructure and upgraded coastal
protection measures could all have adverse impacts.
58. In the wider context, the Habitats
Regulations Assessment also concludes that adverse effects cannot
be ruled out on the Mid-Essex SPA/Ramsar as a whole (for water
quality impacts and impacts on birds) and the Abberton Reservoir
SPA/RAMSAR (for impacts on birds only). Government notes the scope
for avoidance and mitigation identified in the Habitats Regulations
Assessment for sites of international importance, and the need
for more detailed studies should an application for development
consent come forward.
61. Given that the Habitats Regulations
Assessment has not been able to rule out adverse impacts on sites
of European nature conservation importance, the Government has
carefully considered whether it is appropriate to include this
site in the NPS.
62. Annex A of this NPS sets out that
the Government has concluded that there is an Imperative Reason
of Overriding Public Interest that favours the inclusion of this
site in the Nuclear NPS despite the inability to rule out adverse
effects on European sites at this stage.
The IPC is directed to ignore all the listed
site impacts. So it now passes. What is the point of designated
sites? Dungeness?
5.6.85 The nomination described different
cooling technologies and stated a preference for
direct cooling from the Estuary. Some responses
during the opportunity for public comment were received about
whether cooling towers would be necessary at the site. The nominator
of the site has noted that the "direct cooling option will
require long cooling water culverts to reach deep water to obtain
the coolest water and to permit dispersion of the thermal plume
to avoid any significant impact on designated ecological sites"
but has indicated that direct cooling is the preferred option
for the site if it can be achieved. The Environment Agency has
advised that there is access to suitable sources of cooling at
the site.
No mention of additional reactors with cooling
towers as per Iberdrola application.
5.6.86 There were public concerns about
whether local ecology around the site, including the
local oyster beds, could be adversely affected
by the intake and outfall of cooling water from the site and whether
this could impact on the local fishing industry.
5.6.87 The Appraisal of Sustainability
for Bradwell has identified potential effects on water quality
and fish/shellfish populations in nearby coastal waters due to
the abstraction and release of sea water for cooling. Indirect
effects on nationally and internationally designated habitats,
including from the thermal impact of cooling water discharges
have also been identified. The Appraisal of Sustainability considers
this of potential wider significance because of indirect effects
on national and European designated sites.
5.6.88 The Environment Agency has advised
that there is an important spawning site for herring on Eagle
Bank. The Blackwater Estuary provides a major nursery ground for
herring, sprat, bass, and a range of flatfish species. Migratory
trout, smelt, eel and twaite shad are all present.
Some of the risks to the estuary are included
here but the AoS is biased towards mitigation of effects in the
restricted waters of the estuary, which will be impossible given
the huge volumes of water passing through a new system.
5.6.109 Part 4 of this NPS (Human health
and wellbeing) sets out that the risk of an accident resulting
in exposure to radiation for workers, the public and the environment
is very small because of the UK's strict regulatory regime. Part
4 should be referred to for further guidance.
This is not convincing in the light of a recent
prosecution:
BRADWELL OPERATOR GUILTY OF 14-YEAR RADIOACTIVE
LEAK
— guardian.co.uk, Friday 6 February 2009
20.38 GMT
The nuclear power industry suffered an embarrassing
blow today when the operator of the Bradwell-on-Sea plant was
found guilty of allowing a radioactive leak to continue for 14
years.
Magnox Electric Ltd, the operator of the site,
denied some of the allegations but was found guilty of breaking
the Radioactive Substances Act 1993 over the way it dealt with
waste on the premises.
The Environment Agency, which brought the company
to court, said the case demonstrated how the operator had failed
to carry out inspections on a holding tank between 1990 and 2004.
The company pleaded guilty to two separate offences for failing
to maintain the tank.
"Our prosecution sends a clear message
to the nuclear industry that we require the highest standards
of operation at all such sites and will take firm action, even
if the environment beyond a site's boundaries is not affected,"
said Phil Heaton, team leader of the agency's nuclear regulation
group.
Peter Fenn, hearing the case at Chelmsford crown
court, said he would pass sentence on Magnox Electric on 17 February.
Mark Harris, prosecuting on behalf of the Environment Agency,
said radioactive liquid had leaked into the ground because the
tank had been poorly designed and badly maintained.
The most senior figure in nuclear safety had
been forced to defend the regulation of the Essex nuclear power
station in an interview the Guardian published on Monday. Mike
Weightman, chief inspector at the Nuclear Installations Inspectorate,
said it was not possible to "inspect or check every feature
of a complex plant" but he insisted that as soon as the leak
was discovered the safety body did all it could to ensure that
the cause of the problem was identified and dealt with.
This resulted in a fine of £250,000 plus
£150,000 costs.
The leak was only discovered due to the diligence
of a decommissioning worker.
CONCLUSION ON
THE NOMINATED
SITE AT
BRADWELL
5.6.121 Given that the site meets the
SSA criteria, and having considered the evidence from, inter alia,
the public, regulators, the Appraisal of Sustainability and Habitats
Regulations Reports, the Government has concluded that the site
is potentially suitable.
5.6.122 This assessment has outlined
that there are a number of areas which will require further consideration
by the applicant, the IPC and/or the regulators should an application
for development consent come forward, including amongst other
things flood risk, seismic risk, the impact on biodiversity and
the potential impacts of cooling technology. However, the Government
has concluded that none of these factors is sufficient to prevent
the site from being considered as potentially suitable as part
of the SSA.
No mention of negative economic impacts.
COMMENTS FROM
THE APPRAISAL
OF SUSTAINABILITY
FOR BRADWELL
COPY OF
SUMMARY OF
KEY FINDINGS
A number of the strategic effects identified
for Bradwell will be similar across all the nominated sites, including
positive effects for employment and well being. However a number
of potential strategic effects have been identified that are of
particular note for the nominated site at Bradwell. These are
discussed below:
There are potential negative effects on three
national and internationally protected nature conservation sites,
including the Essex Estuaries and Blackwater Estuary; effects
on water quality and fish/shellfish populations in nearby coastal
waters due to the abstraction and release of sea water for cooling.
Part of the site is in flood zone 3 and therefore
at a higher risk from coastal flooding.
There are both hard and soft flood defences
already in place, but these may require upgrading over the lifetime
of a new power station. This could have potential effects on erosion
and visual appearance of the coastline. These effects are significant,
but mitigation opportunities are likely to be available following
further study.
A new nuclear power station would be set in
the context of the existing nuclear power station at Bradwell,
but the surrounding area is predominantly undeveloped and there
is limited potential for mitigation of the adverse impact on the
local landscape. There are no significant adverse effects anticipated
on nationally designated landscapes.
Potential setting effects upon nearby scheduled
monuments and listed buildings, and the West Mersea Conservation
Area, could also be of regional or national importance, depending
on distance and sight lines. The impact on the setting of Othona
Roman fort and St. Peter's Chapel would be of exceptional significance.
However, mitigation could be applied by siting
the proposed facility close to the existing power stations on
the western side of the nominated site. Detailed assessment will
be required at the project level Environmental Impact Assessment
stage.
There remains some uncertainty relating to the
significance of some effects and the most appropriate mitigation.
It is expected that the mitigation measures will be refined iteratively
as part of the development of the proposals for the nominated
site, and will be assessed further in the project level Environmental
Impact Assessment.
1.19 To provide a standardised approach to the
appraisal of the nominated sites, the assumptions about generic
design characteristics have been summarised into a base-case.
The base-case was used to guide the assessment for each site,
except in cases where a nominator has provided further detail
at variance to the base-case. For example, if a nominator is proposing
cooling towers instead of abstracting water for cooling, this
has been considered in the assessment.
This is not true, Iberdrola have stated they
expect to need cooling towers when they construct reactors 2 and
3.
2.3 Bradwell lies some 40km to the east of Chelmsford
and 4km from the town of West Mersea across the Blackwater River
and Estuary. It is 2km from the village of Bradwell-on-Sea, with
the hamlet of Bradwell Waterside adjacent to the west. Other nearby
settlements on the Dengie peninsula includes Tillingham, Southminster
and Burnham-on-Crouch to the south and Ramsay Island to the west.
Tollesbury village lies 4km across the estuary to the north west,
and the town of Maldon lies some 15km to the west up the estuary.
The site lies to the east and south of Bradwell "A"
power station, and comprises open agricultural land (largely arable),
the former Bradwell Bay airfield, an existing electricity sub-station,
a farmstead (Weymarks Farm), other agricultural buildings and
areas of foreshore.
This section omits mention of Colchester 15km,
Brightlingsea 10 km, Clacton-on-Sea 17km, Southend-on-Sea 27km.
Chelmsford is only 30 km away, not 40.
2.4 The nomination is for a nuclear power station
development incorporating:
At least one nuclear reactor
The nomination includes three reactors.
4.65 The site is located next to the Blackwater
Estuary. There are three identified Shellfish Waters in close
proximity, located in channels that feed into the estuary: Strood
Channel, Tollesbury Channel and Salcott Channel. A large area
of the Blackwater Estuary itself, adjacent to the site, is marked
as designated Shellfish Waters on a 1999 schedule but it is not
shown on the 2007 maps. There are Bathing Waters at West Mersea,
3km to the north of the site. The quality of these Bathing Waters
has not been classified.
This acknowledges that there is a holiday and
tourism area only 3km away, but no mention of impacts on this
are documented.
5.5 The construction of a nuclear power station
at Bradwell is likely to have localised adverse effects on air
quality in the short term (five to six years), including dust
and emissions from construction vehicles, Heavy Goods Vehicles
(HGVs) and traffic movements generated by the estimated construction
workforce. This has the potential to affect residential properties
in the surrounding area and villages.
If three reactors are constructed this disruption
could continue for 15 to 25 years.
5.9 There is a very low risk of an accidental
release of radioactive emissions from the Bradwell site, which
could have a significant strategic effect on air quality. The
HSE/NII and the EA will consider this matter during their risk
assessments, which will be carried out as part of the consenting
process to ensure that risks to public health and safety through
accidental release of emissions are within acceptable limits.
Whilst the risk is very low, the potential for a large number
of people to be adversely affected means that, at this stage of
assessment, the potential for strategic adverse sustainability
effects has been identified.
The meaning of this is unclear, large numbers
of people could be adversely affected.
Should this mean the site is not suitable?
5.15 Water intake from the coastal waters for
cooling purposes could lead to the incidental mortality of fish
and other aquatic species. Fish, larvae and eggs can be sucked
into condenser units and be subjected to heat before being returned
to the sea. This could lead to loss of fish or invertebrate food
sources and could have an adverse effect on the important bird
assemblages for which the SPA/Ramsar sites are designated. The
design and siting of the intake system should be carefully considered
so as to avoid/minimise depletion of such food sources.
This directive to avoid/minimise is not possible,
for reasons previously presented at HoP. The demand for much larger
volumes of cooling cannot be sustained by the estuary without
major damage to ecology, fish and oysters.
5.25 Whilst there is likely to be significant
positive effects for employment and local communities, the magnitude
of these effects is reduced at a regional and national scale.
An exception to this is likely to be the Isle of Mersea, which
although relatively close to Bradwell, is located on the north
coast of the estuary and has no direct transport links to the
site. On a strategic regional level, impacts are considered to
be positive.
West Mersea is very close to Bradwell. Similar
problems apply to Tollesbury, Brightlingsea, Colchester, Clacton.
5.30 It is commonly perceived that proximity
to a nuclear facility such as a power station would have an adverse
effect on property values. However, the evidence for this is inconclusive
and contradictory. A study of effects in America found that property
values were actually increased in the vicinity of nuclear facilities,
although the authors caution that this finding is subject to several
caveats including being based on a small sample and may be unrepresentative.
It is suggested that in relatively poor areas, or where the local
economy is depressed, the income generated by employment at a
new nuclear facility may have a positive effect on local property
values. For the present appraisal, any effect on property values
is not considered to be strategically significant because it is
limited to the local area.
These comments may apply to areas near Bradwell
on the south side of the estuary, but the north side of the estuary
is currently a relatively affluent area.
5.31 Strategic Effects on Communities: Population,
Employment and Viability: Positive effects of local economic significance
are likely to occur, although these are less significant at the
regional scale. A potential negative effect of regional significance
is the project leading to a shortage of local construction labour
available to other industries. Bias again.
5.56 It is possible that the presence of a nuclear
power plant may lead to increased stress levels in certain individuals,
due to potential perception of risk associated with living or
working near a power station. However, there is little literature
available on this potential impact which suggests that it has
not been a significant problem in the past. In any event, in the
case of the nominated site, people living and working nearby have
had a long time to get used to there being an adjacent nuclear
plant so this is unlikely to be a problem at this location.
This claim is totally at odds with surveys currently
being conducted around the estuary and cannot be regarded as evidence
based information. It is unjustified speculation.
5.58 Strategic Effects on Human Health and Well-Being:
The rigorous system of regulation of routine discharges from the
proposed nuclear power station at Bradwell should ensure that
there are no unacceptable risks to the health of the local population
when the plant is operating normally. There is also a very small
risk of adverse health impacts arising from an accidental release
of radiation but the multiple safety features within modern nuclear
plants makes such an event exceedingly unlikely. Overall, the
likely enhancement in employment, community wealth, housing stock
and other associated neighbourhood infrastructure should improve
community well-being and health generally.
Most of this section is again speculative and
not evidence based. The last part could not be further from the
truth for most of the area.
The first part claiming how safe it is should
justify placing closer to areas of energy need.
5.59 The main impacts of the development within
the footprint of the proposed facility would be felt at a local
to regional scale. Potential setting effects upon nearby scheduled
monuments and listed buildings, and the West Mersea Conservation
Area, could also be of regional or national importance, depending
on distance and sight lines. However, the impact on the setting
of Othona Roman fort and St. Peter's Chapel would be of exceptional
significance especially if the development occurs on the eastern
side of the site. However, mitigation could be applied by siting
the proposed facility close to the existing power station on the
western side of the site. Detailed assessment, including consultation
of the Essex Historic Landscape Characterisation, consideration
of Conservation Areas and other heritage assets will be required
at the project level EIA stage.
The location of the development on the site
will have to be spread along towards St Peter's Chapel and Othona
Fort if three reactors are built.
5.68 Strategic Effects on Landscape: The AoS
has identified potential, adverse indirect effects on the local
surrounding landscape and some direct effects on features of the
site. There are no significant adverse effects anticipated on
nationally designated landscape. However, there are likely to
be indirect adverse effects of the development on nearby Special
Landscape areas. In visual terms, the new power station would
be seen in the context of existing power station facilities, prior
to any decommissioning. It is predicted that there will be limited
further potential for mitigation of these local visual impacts,
given the scale of the development, until after decommissioning.
Therefore, overall, impacts are considered to be of minor adverse
strategic significance.
This ignores the probability of damage to tourism
and holidays due to the visual intrusion.
5.76 If cooling water is returned to the sea
at elevated temperatures, this could have adverse effects on both
sediment transport and water quality in coastal waters. Nearby
coastal waters include the Essex Estuaries SAC, the Blackwater
Estuary SSSI/SPA/Ramsar site and the Dengie SSSI/SPA/Ramsar sites.
A more detailed appraisal is required by the developer at the
project EIA level to assess the implications of this thermal discharge.
This process will include an assessment of the impacts of any
discharges to the aquatic environment, including impacts on specific
designated sites under both the Habitats and Shellfish Directives.
This is grossly understating the impacts known
to result from power station cooling water extraction, see press
article below.
NUCLEAR PLANTS SUCKING THE SEA LIFE FROM
BRITISH WATERS, RESEARCHERS CLAIM
From The Times
14 April 2008
Robin Pagnamenta, Peter Stiff and Lewis Smith
The nuclear industry in Britain is killing billions
of fish every year and taking a devastating toll of stocks, an
Oxford University academic suggests.
The impact can be so severe in the worst-affected
regions of the seas around Britain that death rates are equivalent
to half the commercial catch for some species.
Coastal power plants that have cooling systems
that extract water from the sea are to blame for the destruction,
according to Peter Henderson, an environmental researcher. Figures
he has compiled suggest that the damage to fish stocks is much
more severe than records have indicated previously. He calculated
that had the young fish killed in power stations survived they
would have added thousands of tonnes of fish annually to Britain's
stocks.
With a new generation of nuclear power stations
likely to be built over the next 20 years the threat posed to
fish stocks needed to be addressed urgently, he said. The net
impact on fish populations was poorly understood because too few
studies had been carried out.
Dr Henderson is concerned that too little account
is taken of the impact on fish stocks of the deaths of many billions
of eggs and young caused by coastal power plants, both nuclear
and conventional.
The number, weight and species of fish and crustaceans
removed from filters at power plants can be measured accurately,
but it is much harder to assess the impact of the deaths of eggs,
larvae and small fish.
"The number of animals killed is colossal,"
Dr Henderson, an associate lecturer at the University of Oxford
and director of the Pisces Conservation environmental consultancy,
said. "Very small fish get sucked in in very large numbers."
The impact on populations is compounded by the
loss of prawns and shrimps which, like young fish and eggs, form
an important part of the diet of larger animals. At Dungeness
nuclear power station at Romney Marsh, Kent, where huge numbers
of sprats are known to form shoals, the outfall pipes have been
known to become clogged with dead fish. "We are talking as
many as 250 million fish in as little as five hours," Dr
Henderson said.
In the southern region of the North Sea it was
calculated that the mortality of eggs and young was so high for
sole that it had been equal to 46% of commercial fishing. Similarly,
herring mortality off parts of the East Coast was 50 per cent
of commercial landings.
Dr Henderson also identified the English Channel
as a badly affected region because of the number of nuclear power
stations on the coast on both sides of the Channel. Coal-fired
stations and other installations such as those in the petrochemical
industry present similar problems, but nuclear plants are among
the biggest extractors of water.
Water is pumped from the seas in vast quantities,
with British nuclear plants extracting at up to 60 cubic metres
(2,100 cubic ft) per second. The Gravelines plant on the French
north coast pumps at up to 120 cubic metres per second.
Once the water has been used to cool the reactors
it is pumped back into the sea where, having been warmed up, it
attracts a variety of marine creatures, many of which get caught
up in the intake systems and killed. Fish that are too young or
too small to be caught by the 1cm mesh screens—especially
pipe fish and eels—travel through them, as do eggs and larvae,
and pass into the reactors' cooling pipes. Many die after being
heated to 30C (86F), chlorinated and given small doses of radiation.
The toll of fish stocks can be avoided at new
nuclear plants with the introduction of dry-cooling, said Dr Henderson,
who called for this method to be adopted, despite the higher costs,
if another generation of nuclear power plants is built.
Callum Roberts, Professor of Marine Conservation
at the University of York, said that the report, which had not
been subjected to peer review, raised serious questions about
the role of nuclear and other power stations in damaging fish
stocks. "I think it's interesting that the quantity taken
by the power stations is large, especially if you look at the
possible cost in the future [of] prematurely killing these fish,"
he said.
"It has become more significant over the
years because of the decline of inshore stocks and, indeed, of
the decline of some species going so far that they are reaching
the status of becoming endangered, like the eel. We have to look
at this problem."
The Centre for Environment, Fisheries and Aquaculture
Science has been commissioned recently to carry out an environmental
survey of the waters near where four new nuclear plants are expected
to be proposed. British Energy commissioned the survey to check
which fish and other marine animals were found around Sizewell,
Dungeness, Hinkley Point and Bradwell. Researchers will attempt
to establish the quantity of fish in the four areas, how nuclear
plants have affected them in the past and what impact could be
expected if new power stations were built there.
"All of these sites are suitable for new
nuclear power stations," said Sue Fletcher, of British Energy,
who maintained that the industry would "strongly contest"
any suggestion that unsustainable quantities of fish were killed
in cooling systems. A spokesman for Magnox, the operator of a
coastal nuclear plant at Wylfa on the Isle of Anglesey, said that
the group undertook "extensive monitoring activities".
Emily Lewis-Brown, a marine campaigner for WWF,
the wildlife charity, said it was concerned that coastal power
stations represented a frequently overlooked, additional burden
on British fish populations. "There is evidence to suggest
that when power stations stop killing fish, local populations
start doing better," she said.
5.82 Strategic Effects on Water Quality and Resources:
The AoS has identified potential, adverse, effects on water quality
and coastal processes, including sediment transport. Adverse effects
on water resources, including groundwater resources, could occur
through increased demand, particularly during construction. Indirect
effects on nationally and internationally designated habitats,
including from the thermal impact of cooling water discharges
have also been identified. This is of potential wider significance
because of indirect effects on national and European designated
habitat sites.
The work to assess these significant adverse
impacts should be conducted as part of the AoS report. To leave
this until later when an application is received implies these
effects can be mitigated.
6.2 The AoS has explored both adverse and beneficial
potential effects of building a new nuclear power station at Bradwell.
Both beneficial and adverse effects were identified as potentially
significant at the local level and it is recommended that these
need to be further considered by the developer, regulators and
the decision-maker (the IPC), during project level assessments.
The AoS is very biased towards finding beneficial
potential effects and overlooking os minimising adverse effects.
Table 6.2 is supposed to document the Potential
Significant Effects, Adverse and Beneficial, and this table is
the basis for findings in the NPS EN-6 for Bradwell.
Distortions are:
Biodiversity and Ecosystems Potential Significant
Effects
Discharge of heated water into aquatic habitats
could alter ecosystem in Essex Estuaries SAC and Blackwater Estuary
SPA/Ramsar sites.
Abstraction of water for cooling purposes could
lead to incidental mortality of fish and aquatic invertebrates,
with secondary effects on the interest features (particularly
birds of the Blackwater Estuary and Dengie SPA/Ramsar sites).
These adverse effects are grossly understated,
"could lead to incidental mortality", should read "will
lead to incidental mortality". The adverse effects of biocide
use do not appear.
Communities: Population, Employment and Viability
There is no mention under this heading of loss
of employment in tourism, holidays, leisure, sailing, fishing,
oyster cultivation, loss of property values, difficulty attracting
new industries.
The inclusion of the Bradwell site has been
assisted by the bias shown in the AoS, and had the report been
more balanced then it is believed the site would have been excluded
without the need for further consideration.
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