Memorandum from Braystones Concerns Group (NWN 15)



1 Job opportunities, economy and economic diversity in West Cumbria.

2 Economic/infrastructure viability of West Cumbria for nuclear power generation.

3 Ability of West Cumbria to host multiple nuclear construction personnel.

4 Braystones -greenfield site, landscape value and cultural heritage.

5 Braystones -coastal, environmental and biodiversity impact.

6 Braystones coastal flood defences.

7 Safety and Emergency Plans for Sellafield and Braystones. Industrial blight.

8 Industrial hazard/proximity to Braystones residential property. Safety, services.

9 Concentration of nuclear facilities in West Cumbria: more even distribution.

10 Braystones site suitability, public and political support.


1. Whilst jobs are welcome in West Cumbria, the overall effects of multiple nuclear developments would have many negative effects. What is frequently referred to as an area of outstanding natural beauty, would be greatly defaced by such extensive nuclear industrial sprawl. This would have a detrimental effect on the visitors perception of West Cumbria as a tourist destination. At a time when the area is desperately trying to diversify its economy, tourism jobs would simply be displaced by more 'nuclear' jobs, thus not actually increasing real jobs with the numbers being promised. It would greatly increase the economic stranglehold that the nuclear industry has on the area and would discourage many other discerning businesses that might otherwise have chosen West Cumbria. (A 45m cheese factory planned for Workington in West Cumbria did not go ahead in 2007, because of plans by Studsvik to build a radioactive waste processing plant at Lillyhall.) There are already a number of nuclear developments proliferating in West Cumbria, with Copeland and Allerdale councils trying to coax the public into accepting even more.


2. West Cumbria is not an economically suitable region for multiple reactor builds, as grid connectivity would prove particularly difficult and costly in such a remote area. West Cumbria is not where energy production is most needed. Any multiple reactor builds should be sited close to centres of high energy demand, where more suitable infrastructures and grid systems already exist. The recent devastation from flooding in West Cumbria has highlighted the wholly inadequate infrastructure throughout the region, which already struggles to service existing industrial demand. Repair and replacement of crucial bridges is currently estimated to take years. The southern sector of the main arterial route through Copeland has been de-trunked and is literally the width of a single vehicle in places. Road closures due to accident or maintenance can require alternative diversion routes 120 miles long. Major road improvements take at least 10 years to provide. If the Braystones site was developed, it would seriously compromise the existing Emergency Arrangements for the Sellafield site.


3. During construction of the proposed new nuclear builds, Copeland would be inundated with tens of thousands of migrant workers. This would completely overwhelm the inadequate infrastructure, housing and public services. During the massive influx of construction workers for THORP in the 1980's, there was an unacceptable increase in public disorder, crime and road accidents and Copeland never received the promised infrastructure upgrades. In the aftermath there was devastating unemployment, to the extent that it was noted in parliament that this must never be allowed to happen again.

4. The Braystones site is the only undisturbed greenfield site that is not adjacent to an existing nuclear site. It would destroy prime, ancient greenbelt farmland, which affords highly valued views across the Irish Sea towards the Isle of Man, Ireland and south west Scotland. The site is of great archaeological potential and is adjacent to one of the most important Neolithic sites in Northern England at Gibb Tarn. Public enjoyment of the Grade II listed Victoria Jubilee Tower in Braystones would be greatly degraded by the overwhelming close proximity of 80 plus meter reactors.


5. The stretch of coast between Sellafield and Whitehaven is 'Undeveloped Coastal Area' of 'High Landscape Value' containing many environmentally sensitive habitats. The River Ehen is an important salmon and trout fishery and is unpolluted by industry: it skirts the proposed Braystones site and would be vulnerable to pollution from such a major industrial complex. The upper reaches of the river are Freshwater Mussel breeding grounds and are given SSSI protection. Significant numbers of River Lamprey found in the River Ehen are particularly sensitive to industrial pollution and it's habitats are nationally declining under threat from industry. The species is given SACS protection in Britain. Several times a year the river floods south onto the flood plain known as the 'Boggles'. This is an environmentally sensitive habitat for Wildfowl, Natterjack Toads, Bats, Deer, Badgers and Barn Owls. Any pollution arising from the RWE site at Braystones would contaminate this area. The rare suite of kettle-holes located at the SSSI Silver Tarn would be highly vulnerable to the close proximity of such large scale industry. Medicinal leeches are harvested from water at the north end of Braystones. The marine cooling systems for new reactor builds near Sellafield would disturb the unique, accumulated radionuclides on the sea bed, releasing them into the environment. The proposed massive 'heat dump' into the Irish Sea by multiple reactor sites, could adversely affect marine environment temperatures.


6. The sea flood defences for the proposed RWE site at Braystones rely on a sand and shingle spit that didn't exist 250 years ago. Reference to pre-1750 maps reveals a dramatically different coast line. It is reasonable to assume that the site would need to be quarantined and kept under surveillance for several hundred years. Given the predicted climate change and rising sea levels, reliance on current flood defences would be flawed. RWE suggest that there are concrete and masonry rivetments local to Warborough point and the sand and shingle spit along which the railway runs. This is not the case and can be clearly observed on a site visit.


7. The RWE development would effectively trap the residents of Braystones and Beckermet between the sea and two major hazardous nuclear complexes. The site would engulf the road north out of Braystones, leaving two remaining roads, which are frequently impassable due to heavy flooding. In the event of an accident at either the Sellafield or Braystones sites coinciding with flooding, residents would be left with no Emergency Evacuation Route. Braystones and Beckermet residents would suffer the most extreme industrial blight of all the communities affected by new nuclear build, being sandwiched between two nuclear sites. Reference to a map of the area is recommended to understand the exact location of the RWE proposal north of Braystones in relation to Braystones, Beckermet, Nethertown and Sellafield.


8. Many Braystones residents' properties would be abutting the site boundary. Following the Bunsfield fire, there will be many concerns from residents and the HSE about building a major hazardous industrial complex in such close proximity to existing residential properties. The current regime at Sellafield of armed police challenging pedestrians walking close to the perimeter fence, would presumably be similar at the Braystones site. The close proximity of such major industrial construction and operations would greatly compromise residents' rights to the peaceful enjoyment of their properties. The proposed transporting of large plant components via a marine off-loading facility, over the beach, the beach bungalow community and the rail line raises many serious safety concerns. Disruption to public rail services would be unacceptable at a time when road traffic congestion would need to be alleviated. Many Braystones residents on low income are particularly reliant on the rail service.


9. The proposed high concentration of nuclear reactors in Copeland is unacceptable. Sites that may otherwise have been situated in Scotland seemed to have simply been displaced into the single borough of Copeland. The proximity of so many reactors to the most sensitive nuclear site in Europe should be questioned. The people of West Cumbria have borne the major burden of the nuclear industry for more than 60 years. The responsibility for nuclear power should now be shared more fairly across Britain.


10. The Braystones development is not supported by the local public or local councillors (Councillors Norman Clarkson and David Southward) as was demonstrated at several public meetings (also County Councillor Tim Knowles in a letter to the Whitehaven News 30 April 09). Even the local MP, a prominent supporter of Nuclear Power, declared in the Whitehaven News in November 09, that there is no public support for the Braystones or Kirksanton sites and has shown a strong preference for developing the existing Sellafield complex. DECC have conceded that the Braystones site fails several of their own criteria but claim that it is of overriding national interest to include Braystones in its list of reactor sites, due to a shortage of sites. There are sufficient existing nuclear sites to potentially generate at least 28GW of power. Given the many engineering, safety, environmental, economic and infrastructure obstacles posed by the Braystones site, it is hard to believe that other more suitable (brownfield) sites do not exist. Greenfield sites should only be considered near centres of high energy demand, to avoid transmission losses.


5 January 2010