SANEs" Response to Public Feedback"---Issued by Horizon Nuclear Power

This is a copy of our reply to Horizon following their recent "Response to Public Feedback"

If anybody requires this by email please contact oldburynuclear@btinternet.com

EIA SCOPING REPORT: ‘RESPONSE TO PUBLIC FEEDBACK’ ISSUED BY HORIZON NUCLEAR POWER MARCH 2010

Shepperdine Against Nuclear Energy has considered the above document (which is attached to this document for reference) and comment on the responses provided by Horizon Nuclear Power below:

Waste

The Government‟s MRWS programme (referred to in Horizon‟s response), and in particular its identification of a suitable site for a national deep geological disposal facility for waste is not at all advanced and there is much uncertainty as to whether this will ever happen. We highlight the following comments from CoRWM*‟s response to the Government‟s draft National Policy Statement for energy (NPS) consultation on the question of whether they agreed that effective arrangements exist or will exist to manage and dispose of waste that will be produced by new nuclear power stations in the UK:

“CoRWM considers that the Government should take into account when making this judgement that, while the current UK process for siting a geological disposal facility (GDF) for HAW is sound, it is at an early stage. Its success depends on finding a combination (or combinations if more than one GDF is needed) of a willing host community and a site that is technically suitable to hold enough HAW. At present, it is uncertain whether the appropriate combination (or combinations) of community and site can be found in this country. This uncertainty applies to existing and committed HAW, as well as to new build HAW, and is likely to persist for many years.”

In their response CoRWM go on to give their reasons for the above statement and in particular we draw your attention to the following:

“It is assumed in the draft NPS documents that spent fuel from new nuclear power stations will be disposed of by emplacement in a GDF. In order to establish a GDF it is necessary to find a site that is technically suitable in an area where the local community is willing to host a GDF. The current siting process in the Managing Radioactive Waste Safely (MRWS) programme is designed to achieve this combination of willing community and technically suitable site (Defra et al., 2008). The process is sound but it is at an early stage (CoRWM doc. 2550). Only one part of the country has expressed an interest in entering the siting process and it has not yet taken a “Decision to Participate”. If and when it does so, there is no guarantee that a technically suitable site can be found in the area, either for a GDF to hold existing and committed HAW and new build HAW, or for two or more GDFs each of which would hold some of these wastes. Surface-based investigations must be carried out to identify potentially suitable sites. If one or more such sites are found, it will only be after underground investigations that will take many years that a decision can be taken as to whether to construct a GDF (or GDFs) (CoRWM doc. 2543).

Government has encouraged other parts of the country to express an interest in entering discussions about hosting a GDF but so far none has done so.”

In the light of this uncertainty, this community‟s concerns can not be re-dressed by Horizon‟s response.

*CoRWM is the independent Committee on Radioactive Waste Management set up by the UK Government in November 2003 and advises Government on Radioactive Waste Management etc.

Health Risks

The COMARE* reports to which Horizon refer in their response statement are out of date and have been superceeded by the more recent and more comprehensive German KiKK study, commissioned by the German government, which looked at all German nuclear power stations and found that children living near to nuclear power stations in Germany have a significantly increased risk of cancer and leukaemia.

COMARE are currently undertaking a review of the KiKK study, as it throws doubt upon their previous research. This review is still in progress and until this has been completed and their report been made available for scrutiny, neither Horizon nor the Government are in a position to confirm that there is “no evidence for unusual aggregations of childhood cancers in populations living near nuclear power stations”. Indeed the most recent evidence suggests quite the opposite.

*COMARE (Committee on Medical Aspects of Radiation in the Environment) is the independent Government advisory group advises the Government on medical aspects of radiation in the environment.

Uranium Supplies

The question of how long the world‟s resources of uranium will last has been a matter of considerable debate, although Horizon‟s suggestion that this is “250 years based on double current production” seems to be off the scale compared to many recent studies including:

Michael Dittmar, from the Swiss Federal Institute of Technology in Zurich “The Future of Nuclear Energy: Facts and Fiction” September 9, 2009, which issues a warning to:

“all Western European countries, Japan and South-Korea which depend to almost 100% on stable uranium deliveries from far away. These countries should take one particular paragraph from the Red Book 2007 NEA press declaration very seriously: “At the end of 2006, world uranium production (39 603 tonnes) provided about 60% of world reactor requirements (66 500 tonnes) for the 435 commercial nuclear reactors in operation. The gap between production and requirements was made up by secondary sources drawn down from government and commercial inventories (such as the dismantling of over 12,000 nuclear warheads and the re-enrichment of uranium tails). Most secondary resources are now in decline and the gap will increasingly need to be closed by new production. Given the long lead time typically required to bring new resources into production, uranium supply shortfalls could develop if production facilities are not implemented in a timely manner.”

A government report from the year “A Technological Roadmap for Generation IV Nuclear Energy Systems” points out that the known conventional uranium resources will only last between 30-50 years. Thus, a new conventional nuclear power plant which might be operational in 2020 might only obtain uranium fuel up to sometime between 2040 and 2050.

The IAEA report “Analysis of uranium supply to 2050”. The authors of this report quantify the uranium deficit with respect to the RAR numbers and for different scenarios about the future use for nuclear energy. The estimated deficit is given in units of million of tons of uranium. Many details about the potential contributions of uranium from a large number of unconventional resources are presented in this report and the remarks about sea water uranium are of particular significance to your response:

“Research on extracting uranium from sea water will undoubtedly continue, but at the current costs sea water as a potential commercial source of uranium is little more than a curiosity.”

However, our concerns are not only over whether the world‟s uranium resources are sufficient to support a programme of nuclear new build, but also:

The fact that nuclear energy will leave this country heavily reliant on supplies of uranium from other countries. Whereas a programme of renewable energy would mean we become totally self-reliant.

The carbon intensive process of mining and transporting uranium. Which seems to be a matter not being given proper consideration in the decision making process to proceed with this nuclear new build programme. This is a very serious and material consideration which should be taken into account. This, particularly when added to the total carbon footprint of the construction, waste management and decommisioning process, calls into question the whole claim that nuclear power is actually „low carbon‟.

Requirement for cooling towers at Shepperdine, Nr Oldbury

It is clear that the requirement for cooling towers is of serious concern to many many people in this area. Many peoples views on this have been made at various stages, in particular see for example the statement made by Lord John Cope in the House of Lords on the 9th March 2010*.

It is vital that Horizon complete their “studies” to clarify their design options as soon as possible and we question why this is taking so long. Based on the information provided thus far it is obvious to us that neither solution proposed is acceptable.

The natural draft towers will be amongst the highest of their kind in the world and the highest structure in the UK outside London! Against their back drop they will heavily dominate this area spoiling every view across the Severn Vale, spoiling 2 separate Areas of Outstanding Natural Beauty (The Wye Valley and The Cotswolds). No amount of landscaping can possibly mitigate the devastating damage of these hugely dominant structures and the sooner Horizon accept this the better. We can not understand why Horizon have not already ruled this option out for this reason. It is not really necessary for any further detailed assessment; it is blatantly obvious to everyone in the area that the size of these towers will be visually unacceptable!

The forced draught towers will, we understand be significantly less efficient and significantly more expensive. So much so we believe they will call into question both the sustainability and economics of the project. From the public meeting held by Horizon last month we all learned that this is not their preferred option for financial reasons. Horizon need to get on with their “studies”, decide whether or not this option is sustainable/viable and be open on this issue as soon as possible.

Furthermore we also maintain that the noise impact generated by the forced tower fans on the residents of Shepperdine and other communties close by will be unacceptable.

We note that you will be fully assessing the effects of the water vapour plumes and look forward to seeing this assessment in the near future.

*http://www.publications.parliament.uk/pa/ld200910/ldhansrd/text/100309-gc0001.htm#10030975000024

Cumulative Impact of Other Infrastructure Projects for the Area

We note that the decommissioning of the existing site and the possible Severn Barrage scheme will be considered as a part of your EIA studies. Although we consider that it does not need much further study to see that the combination of the decommissioning and the Horizon new build schemes alone will give rise to impacts that will be completely intolerable to the local community.

Furthermore, with regard to any Severn Barrage scheme, it is difficult to see how this can be done effectively until the details of such a scheme are known. We consider that any proposal for Oldbury should be delayed until the picture is clearer on this nationally significant project.

Previous end state consultation carried out by the existing power station

We find Horizon‟s dismissive comment on the 2006 End State Consultation quite strange, particularly the suggestion that:

“The consultation was on the "end state‟ of the land and not on what should happen to the land once the „end state‟ had been reached. This means that it was focused on getting the land to a desired state that could be reused for any purpose deemed suitable in the future.”

In this consultation local residents living within a 5 mile radius of the site were asked to decide on their preference from the following options:

“Option A  - A Landscaped site; involving the removal of all buildings and structures to 1m below ground level, the removal of all materials, land remediation for unrestricted use, landscaping and sowing the site to grass (potential for recreational or agricultural future use)

Option B - Site left to nature; involving the removal of all buildings and structures to 1m below ground level, the removal of all materials, land remediation for unrestricted use and leaving the site to be reclaimed by nature (potential for recreational or agricultural future use)

Option C - Site left for redevelopment; possibly leaving some buildings, the removal of all materials, the remediation of accessible land as required for unrestricted use and leaving the site bare for subsequent development (potential for commercial, educational, leisure/ mixed development)

Option D - Leaving the site under partial institutional control; possibly leaving some buildings for reuse, removing some materials and leaving part of the site for the disposal of waste or non-fossil fuel power generation resulting in some restrictions on access and/or use (non controlled areas left with the potential for a range of future uses)

Option E -  Leaving the site under full institutional control; leaving some buildings, leaving some/ most materials resulting in limited or no access (implied future-use such as material/ waste storage and/ or non-fossil fuel power generation)”

This gave the respondents a choice between different end states and detailed future uses for each end state scenario. It is obvious that the respondent would choose the end state on the basis of the acceptability to them of the specified future use for each end state! By definintion the survey therefore resulted in a clear representation of local opinion on how they wished to see the land used in the future. We can not see how Horizon can possibly consider this survey in any other way.

The report published on this consultation clearly showed that a far greater proportion of respondents favoured options A and B than options D or E. It is quite clear that the results of this consultation, which respresented the clear views of local residents, have been totally ignored. Horizon‟s comments dismissing this earlier consultation are unacceptable and merely serve to demonstrate that no one is genuinely listening to the concerns of this community.

Impact of temporary workers on this community during construction

Whilst it is noted that Horizon will be looking into the options for workers‟ accomodation and transport during the construction of the proposed development, this does nothing to alleviate the concerns of this community.

It is impossible to fully mitigate the effects of such a large influx of workers to the area and our concerns remain unabated by the comments made.

Impact on local transport infrastructure

We also note that Horizon are currently carrying out a Transport Options Study which is looking at a range of options, including road, river and rail transport for bringing in materials and construction workers to site. However, again this does little to alleviate our concerns.

Groud Investigation Studies

We note the brief comments made which confirm that the recent investigations have revealed similar ground conditions to the existing station. However, this does not alleviate our concerns particularly bearing in mind the long history of ground subsidence problems experienced at the existing station.

It would be more helpful to the community if the ground investigation report could be provided.

Connection to the National Grid

The response provided provides us with no new information.

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 many 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.

Although Horizon‟s response states that “National Grid… will be carrying out their own consultation process in due course”, this has given rise to further confusion as we all learned from Horizon‟s public meeting last month that they seem to believe that consent is not required for these works and therefore public consultation will not be necessary. Clarity on this matter is required urgently.

Flood Risks

We note that there is a requirement to protect the site from a 1 in 10,000 year flood event. Given that the site carries clear evidence of historic flood damage from the effects of catastrophic tsunami flooding from the early 1600s, it is difficult to imagine what flood protection measures can be provided to protect the new power station from a tsunami.

Not withstanding this, the site is in a high level risk flood zone and we have serious concerns that the extensive flood defence measures required to protect the new station and its road access will significantly add to the devastating impacts of this proposal.

Furthermore, the risk of collateral flooding resulting from the flood defences required at the site preventing effective drainage of surface water from further inland needs to be fully assessed. The implications of this can not be overstated.

National interest outweighs other considerations in the siting of the new nuclear power stations in the draft NPS statement

The response from Horizon does not respond to the concerns expressed on this issue. It would be more helpful if they could explain how they believe that the draft NPS allows the IPC sufficient means to decide whether Visual Impacts (for example) will over ride the National Interest.

Site Access

The site access is already an issue. Horizon are using Shepperdine Road as access to the site compound currently located beyond Job‟s Green Farm. They have recently applied for planning permission to keep this compound for a further 4 years. We feel that they should be constructing a new access road from the existing power station road immediately to reduce the number of lorries and heavy plant from using Shepperdine Road, which is totally unsuitable for such traffic. April 2010


You can see Horizons original responses at http://www.horizonnuclearpower.com/downloads/horizon-env-ecoping-report.pdf