SANEs Submission to DECC

The DECC draft National Policy Statement for Energy and its nomination of a new nuclear power station at Shepperdine, near Oldbury-on- Severn, South Gloucestershire




Response from Shepperdine Against Nuclear Energy



Shepperdine Against Nuclear Energy is a newly formed group of approximately 100 local residents living close to the nominated site referred to in the DECC documentation as ‘Oldbury’ but is infact within the village of Shepperdine to the north of Oldbury-on-Severn. Our group is growing in numbers and includes residents from the villages of Shepperdine itself, Oldbury, Rockhampton, Nupdown, Falfield and the nearby town of Thornbury.



Our group has been formed as a direct consequence of this consultation; its chairman is Reg Illingworth to whom all correspondance should be addressed (address supplied to DECC seperately for confidentiality purposes).



Shepperdine Against Nuclear Energy strongly objects to the DECC public consultation process, the draft Nuclear National Policy Statements for Energy (NPS) in general and the specific nomination of Shepperdine and this statement sets out our reasons.



A. Consultation Process



The consultation process has presented this community with some considerable difficulties in responding effectively for the following reasons:



1. The DECC NPS documentation runs to some 1600 pages and as a result is totally impossible for the general public to digest and respond to. This community has had absolutely no assistance with this from either its local council or from the DECC. As a result the whole process has totally overwhelmed those that have tried to respond and this has led to a total lack of public engagement. Many of our members feel that this has been done deliberately to avoid public participation and the DECC do not want to hear what the local community has to say.



2. The one local DECC exhibition and public meeting was held only 2 weeks before the consultation deadline of the 22nd February and far too late to assist local people in understanding and responding.



3. To make matters worse, Eon (now promoting this scheme under the name of Horizon Nuclear Power) ran their own massive consultation at the same time as the DECC consultation and thus many local people have directed their concerns to either Eon or the IPC. Running the two consultation processes side by side has distracted this community from this important DECC consultation and has caused considerable local confusion. It is difficult enough for local people to understand what the NPS is for, its purpose in the planning process and the brand new proposed IPC process in relation to the planning consent for these developments. To then try and understand how the NPS will affect them from a 1600 page document and respond accordingly is well beyond the public. If you then add to that the launching of another consultation by Horizon no reasonable individual had a chance of understanding this consultation.



4. A Community consultation on the end state of the soon to be decommisioned power station at Oldbury was undertaken in 2007. This survey established that the majority of local people did not want a new nuclear power station built here and that they wanted the site returned to its natural state. The local community was therefore shocked to learn from this consultation that the government has chosen to ignore the consensus view. Many people felt that this, together with the extremely overwhelming nature of the DECC documentation, was a clear indication that the government was not interested in the views of this community.



5. The DECC has not undertaken any publicity over this consultation beyond the villages immediately adjacent to this site and the town of Thornbury. There have been no exhibitions or meetings held by DECC across the river in the towns of Chepstow and Lydney which are very close to and look out over the proposed site. Nor has there been any exhibition/meeting held in the city of Bristol which is only approx 10 miles from the site.



6. We also comment that the exhibition and meeting held in Thornbury has been far too late for us to make any contribution to the Parliamentary Scrutiny Committee for Energy and Climate Change (ECCC), unlike many of the other nominated sites. We insist that DECC draw this fact and our views in this statement to the attention of all of the ECCC members. It is vital that the ECCC are given proper time to consider our views before it reports on the outcome of its scrutiny.





In summary we feel that this consultation has been fundamentally flawed and has not given this community a fair chance to express its views either to the DECC or the ECCC.





B. General Objections to the draft Nuclear National Policy Statement



1. Site Selection Criteria The NPS refers to ‘semi-urban’ criteria which must be met in the DECC selection process. DECC have since advised, at local public meetings, that it is a requirement of the safety regulators that nuclear power stations are built away from centres of population for safety reasons. We therefore question the semi urban criteria altogether because semi-urban is what it is ie in populated areas! See also our specific concerns on this in relation to the Shepperdine site.



2. Deployability to meet the ‘energy gap’ Given experiences in other countries we maintain that Nuclear power stations are impossible to construct before the predicted energy gap between 2015 and 2020. Claims made by the promoters of the various nominated sites are considered over-optimistic considering the building performance of these new generation nuclear power plants elsewhere in the world including at Olkiluoto and Flamanville which are three and two years behind schedule respectively and badly over budget.



3. Nuclear power will not help combat climate change. The Sustainable Development Commission has already argued against nuclear power saying it would reduce carbon emissions by just four percent by 2025 and that renewables could be brought on more quickly. Furthemore as nuclear now produces a mere 13% of UK electricity (DECC 2008 figures) and with UK targets to achieve 34% renewable electricity by 2020, renewables and energy conservation are a much better prospect.



4. Unacceptable risks from nuclear power:



• Emergency plans are currently and will continue to be unable to protect the public from a major release of radiation caused by an accident or terrorism. This is made worse by choosing to locate these new power stations in semi-urban areas.



• The reactors proposed for these new generation power stations will use intensive ‘high burn-up fuel’ increasing the risk of high quantities of radiation in a serious accident.

• The highly toxic waste is so hot and radioactive it is believed to take 160 years to cool down and will need to be stored for up to 160 years, long after the power stations have ceased generating electricity, creating additional local hazards. As no suitable location has been found for its eventual ‘disposal’ and none will exist for at least many decades, if at all. The adjacent local communities will be left with this toxic waste legacy. Furthermore the draft NPS removes our fundamental right to have our say on this matter within the planning process. The NPS directs the IPC that it need not consider this issue further and this is totally unacceptable.

• Government policy, quite rightly, requires that any community which might eventually host a long term deep geological store for the storage of the highly toxic waste produced by these new nuclear plants do so on a completely voluntary basis. We feel that the communities now being required to host this waste until such facility exists should also be given the same respect. By nominating Shepperdine in the NPS and removing the consideration of this issue within the planning process, the government is denying this community of its rights in this matter and expecting it to host this waste on an involuntary basis!

• Health risks are associated with nuclear power stations. In particular we highlight the link to childhood leukaemias as found in many recent studies including the Green Audit 2001: “Cancer Mortality and Proximity to Oldbury Nuclear Power Station in Gloucestershire 1995-1999". This found a childhood leukaemia cluster in Chepstow a statistically significant cluster similar in intensity to the notorious Seascale cluster. Chepstow is just down stream from the existing Oldbury power station.

Furthermore, the recent KiKK German Government study 2008 found more than double childhood leukaemias near every nuclear power station – effect as far as 50 kilometres.

It should be noted that the NPS seeks to prevent the IPC from considering the health risks further in the planning process and we object to this specific point as it will prevent this community, who will be subjected to these risks for many generations to come, from having any further say in this matter.



C. Objections to the Nomination of Shepperdine, nr Oldbury



The southern shore of the Severn Estuary already has the highest concentration of nuclear power stations in the UK, with Hinkley Point, Oldbury and Berkeley (decommissioned 15 years ago but still standing).

The communities around the Vale of Severn have become accustomed to the existing power stations.



However, with Oldbury now approaching the end of its lifetime, it is clear that many of the key arguments used to justify its location here over 40 years ago are no longer valid. Moreover, the proposal created by the NPS will result in the construction of significantly larger new power station (at least 4 times the site area of the existing power station) at Shepperdine, some 2.5 km from Oldbury and this raises several important new concerns:



1. Ecological damage: loss of fragile habitats that are valued and protected at national and international levels.



2. Visual impact across a wide area of the Severn Basin and affecting two separate Areas of Outstanding Natural Beauty.



3. Local climatic changes created by the cooling towers needed for this new generation of power station in this particular location affecting the local populations down wind of the site.



4. Flooding risk, affecting the site itself and potentially collateral flooding of neighbouring areas due to the construction of flood defences to protect the new station.



5. Unsuitability of the site for the long-term storage of large amounts of nuclear waste.



6. Harm to the local neighbourhood during construction of the new station, especially as this will overlap with the significant works involved in the decommissioning of Oldbury.



7. Potential conflicts with the UK's long-term energy strategy, namely interference with plans for the Seven Barrage.



8. Proximity to large populations including the city of Bristol, the towns of Thornbury, Chepstow and Lydney all of which have grown significantly since the old power station was constructed.



9. Upgrading of National Grid infrastructure which will involve the complete replacement of the national grid power lines serving the existing station for several miles.



10. A known history of subsidence problems which has led to considerable and serious problems at the existing power station site.



We do not consider that the measures of mitigation suggested in the NPS will adequately address these problems. For these reasons, the Shepperdine site is totally unsuitable and it is inappropriate for a new power station of the scale proposed by the NPS to be situated at Shepperdine. We therefore object to the nomination of Shepperdine within the NPS and insist that it is removed before designation.





Specific concerns



1. Ecological damage



The southern shore of the Severn Estuary from the Old Severn Bridge to Sharpness is already spoiled by the existing nuclear power stations at Oldbury (whose shell will remain for many years after decommissioning) and Berkeley, where the superstructure still stands 15 years after shutdown. Building a new station at Shepperdine would industrialise a continuous 5-km stretch of the shoreline –and constitute the highest density of nuclear power stations in the UK and perhaps in the world.



This part of the Severn Estuary includes an important suite of habitats that are recognised nationally and internationally as in need of protection. Shepperdine lies within 5 km of three UK-designated Sites of Special Scientific Interest (Severn Estuary, Upper Severn Estuary and Lower River Wye). At international level, the Severn Estuary is designated a Special Area of Conservation, strictly protected under the EC Habitats Directive; a Special Protection Area; and a Wetland (Ramsar) Area.



The mitigation measures suggested in the NPS and proposed by Horizon are simply the recreation of the lost habitats. This is woefully inadequate. The protected areas are already fragile and under threat and will be irreparably damaged by construction of the station and associated flood defences; by the deep-water dock needed to bring in large reactor components; and further inland, by alterations to the road network and its associated flood protection.



None of the UK or EC environmental protection designations existed 45 years ago, when the proposal for the Oldbury power station was considered and approved. None of the 9 other sites currently under consideration has a comparable concentration of protected environments that would be damaged by the construction of a new power station.

2. Visual impact



The existing Oldbury power station is visible across a wide area of the Severn Estuary and Basin, Forest of Dean and Cotswold Escarpment. The station proposed for Shepperdine would generate three times more power than Oldbury. The reactor building itself would be bigger and, most significantly, there would have to be 3 or 4 cooling towers, because the station's demand would outstrip the capacity of water from the river to cool the reactor safely and the resultant output would be too hot so that the consequential plume into the river would be too harmful.



The cooling towers proposed would be either 70 m or 200 m high, depending on whether cooling was actively assisted (with internal fans) or passive.

In either case, the new station would be an eyesore, significantly more obtrusive than the Oldbury and Berkeley stations which already blight this stretch of the Estuary and the Severn Way.



The 70m high fan assisted towers will be significantly less efficient and therefore render this site far less sustainable than other sites not requiring cooling towers. So much so that it is considered that this option will prove non-sustainable as is inferred in the NPS statement regarding the exclusion of the Owsten Ferry site.



We also maintain that the impact of noise generated by these fans on the residents living in Shepperdine and other villages close by will be unacceptable.



Furthermore, the 200m high gravity towers would be the highest structure outside the city of London in the UK, twice the height of the cooling towers constructed at Didcot power station and against its backdrop they will be higher than the pylons of the Old Severn Bridge and the hills of the Forest of Dean and the Cotswold Escarpment. These towers and the associated plumes of steam would be visible for up to 50 miles, spoiling the view across the local area as well as into two separate Areas of Outstanding Natural Beauty (Wye Valley and Cotswolds). Both these areas are significant internationally appreciated tourist attractions.



The mitigation measures suggested in the NPS and proposed by Horizon consist merely of ground-level landscaping and tree planting, and changing the alignment and/or colour of the cooling towers. The DECC concedes that "not all effects will be mitigated". This is a complete under-statement and we suggest that no measures can possibly mitigate the damage done by these hugely dominant structures.



This is a beautiful area that has already been damaged by the two existing stations. The Shepperdine station would greatly expand the area spoiled in this way and in the words of one local resident “will make the existing power station look like a country cottage by comparison”.



Significantly, Shepperdine is the only one of the 10 sites that cannot be safely cooled by seawater and that therefore requires cooling towers. It should also be noted that the DECC has ruled out other sites, including Owsten Ferry, for this reason and we are at a loss to understand why Shepperdine remains on the list of nominated sites.





3. Local climatic changes



The steam plumes from the cooling towers (at whichever height) will create changes to the local climate over the areas down wind of the towers depositing contaminated drizzle/rain on the communities in these locations and this is totally unacceptable to the local residents affected. This matter is not even referred to in the NPS and yet it will be of huge significance to the local communities and wildlife affected by this.



We suggest that the DECC must undertake an impact assessment on this issue alone before the government is able to make their decision to nominate Shepperdine in the designated NPS.





4. Flooding risk



Shepperdine is within a highest risk (category 3) of flood zone. This assessment relates only to tidal flooding from the Severn – where the funnel shape of the Estuary would also concentrate the effects of exceptional water rises such as storm surges or a tsunami. This is the only one of the sites to carry clear evidence of flood damage, from the early 1600s, from the effects of a catastrophic tsunami flooding.



The inland region, including Oldbury, the Naite and Rockhampton, also suffers frequent flooding, but from water running off the hills to the east rather than from the river.



DECC have assessed flood defences as theoretically capable of protecting the station itself and its access routes. However, the environmental and visual impact of planned measures has not been described by the NPS or Horizon in any detail.



Crucially, the risk of collateral flooding – from flood defences at the site preventing effective drainage of surface water further inland – has not been addressed at all.



The risk of flooding of the station itself, and of adjacent communities, is substantially higher than at any of the other nine sites. We do not regard the NPS or Horizon's plans for mitigation as adequate. Flood risk was a factor that caused other potential sites to be excluded from further consideration, and we feel that this should preclude the choice of Shepperdine as an appropriate site.



We also draw attention to the fact that the existing power station was cut off by flooding in 2004 and was inaccessible to staff. This clearly represents a security and/or evacuation hazard, emergency vehicles would have been stranded and out of reach of the plant!



5. Highly toxic nuclear waste storage



In the continuing absence of a geologically suitable site within a ‘volunteer’ community in the UK to host the large-scale long term storage of the highly toxic nuclear waste produced by these new generation reactors, this waste will have to be kept on-site at each of the new power stations. This waste will be substantially more active and therefore more hazardous than that produced by the existing plant at Oldbury.



The NPS requires that the developers provide an above ground storage facility to host this waste adjacent to this plant. Waste could therefore have to be stored above ground on site for up to 150 years.



We are deeply concerned that these facilities would further increase the environmental and visual damage inflicted by the reactor and cooling towers, and would also add a new safety hazard and makes the flooding implications referred to above even more serious.



The NPS seeks to remove this community’s right to have any further say on the question of storage of this highly toxic waste at Shepperdine by directing the IPC that it need not consider this matter in determining the planning consent. By doing this the DECC is imposing this legacy upon us and this is completely unacceptable.





6. Harm done to the local neighbourhood



Damage would inevitably be done to the local area during construction of the new station by traffic, road-widening, temporary accommodation for 5000 largely migrant construction workers, and so on. We accept that this is inevitable at each site ultimately chosen. However its impact in this area should not be under-estimated.



At Shepperdine, this would impact most on an attractive part of the Vale of Berkeley and would damage or destroy communities such as Shepperdine itself, Nupdown, Hill and Rockhampton.



Moreover, disruption and damage would be greater still if a new station were built at Shepperdine at the same time as the Oldbury station is being decommissioned – a process due to start in 2011 and likely to last 12 years.



The area already suffers from traffic congestion both in normal rush hours and also whenever there is an accident on and around the M5/M4 inter- change; an all too frequent occurrence these days. If you add to this the congestion created by the construction traffic together with the de-commissioning of the old power station this area will bear a huge toll









7. Potential conflict with the Severn Barrage



It has not been determined whether the construction of a new power station at Shepperdine could interfere with the proposal to build a Severn Barrage, or vice versa. However, the DECC acknowledges that there could well be adverse environmental and other impacts.



Shepperdine and Hinkley are the only two of the planned power stations that could potentially interfere with other strands of the UK's long-term energy policy, and particularly its use of sustainable natural sources of power.



It is illogical to consider detailed plans for Shepperdine without knowing whether or not a Severn Barrage will go ahead or the details/location of such a barrage. To do so could very well pre-determine the outcome of this hugely important renewable scheme and is definitely not in the long term interests of this country.



8. Proximity to large populations



The proposed site will lie very close to some significant populations including Thornbury (less than 5 miles population circa 12,500), the city of Bristol (approx 10 miles population circa 450,000) and the towns across the river of Chepstow and Lydney, both of which are less than 5 miles from this site.



Given the risks identified earlier (and the DECC admission that these power stations should not be close to large populations for safety reasons) we consider that this site is too close to these communities to be acceptable and therefore it is an unsuitable location for these new generation of nuclear power stations.



As well as the safety risks, properties in the area have already been blighted by the draft Nuclear NPS having included Shepperdine in their list of 10 suitable sites. Many people are unable to sell their homes and will not be able to for many years if this site remains in the NPS when it is designated. Home owners in the area have already suffered enough damage due to the current economic recession and do not now need this blight inflicted upon them.



As well as the many villages close by, which will be devastated by the over-bearing nature of this site both during and after the construction, the nomination of Shepperdine will affect sales of homes for miles around the location including towns like Thornbury, Chepstow and Lydney all of which have many homes with views looking over the site. The Secretary of State should expect a considerable number of claims with respect to this blight made even worse by the fact that this site is located close to several towns.





9. Upgrading of National Grid infrastructure

The National Grid power lines serving the existing power station are of inadequate capacity to serve the proposed capacity for the new power station at Shepperdine. Therefore, not only will new power lines be needed to connect the new station up to the existing grid, but the power lines running out from Oldbury for several miles will need to be replaced. This will involve replacing of the cables and the pylons throughout these lengths.

These works will have a significant impact on the countryside and will add to the huge disruption to this area. Furthermore, it should be noted that none of the residents living along these power line routes have yet been consulted on this matter, despite the fact that the increased capacity will have a serious impact on their health.

10. Known history of subsidence in this area

It is understood that the recent site investigations have revealed that this site lies on deep layers of alluvium with hard clay beneath. This type of bedrock is vulnerable to subsidence. It is also the same sort of ground conditions as exist beneath the existing power station at Oldbury which has suffered from a history of problems resulting from subsidence. This has led to reactor shut downs etc.

It makes no sense whatsover to construct a new larger nuclear power station on the same type of ground as has already proven to be problematic in this respect.

Our concerns are compounded by the fact that a local resident who witnessed recent site investigation drilling being undertaken by Horizon and reports that the drilling had gone down to a depth of over 200 meters and had still not found substantial rock for foundations. We therefore believe that this site has serious ground condition difficulties and suggest that the DECC review the site investigation report before continuing with this nomination.



Conclusions

As we have outlined above we believe that DECC need to re-consider their NPS for energy as it is not fit for purpose in many different ways.

Furthermore for the reasons given above, Shepperdine is an obviously unsuitable site for a new generation nuclear power station.

We believe that the decision to include Shepperdine was weighted by the pre-existing infrastructure at Oldbury (an infrastructure that we now know has to be completely replaced in any case); the fact that the existing Oldbury power station has long been tolerated by the local population; and in the words of the DECC, "the lack of alternatives."

However, for reasons of environmental protection, safety and sustainability, we argue that this setting is now no longer appropriate for a new station especially along the scale of these new generation power stations now proposed by the promoters.

We strongly urge the Government to remove Shepperdine from the list of nominated sites within the NPS and to explore other options for making good the shortfall. We believe this should be met with truly renewable energy which does not rely on the limited supply of uranium from other countries; one which is already showing signs of drying up and the mining and transportation of which is extremely carbon intensive.

This area offers diverse opportunities to harness natural energy from its rich coastal and tidal powers. We feel that the government should make much more effort in focussing on the natural power generation reserves of this area and stop allowing nuclear energy to distract the energy markets attention in this region fr