Leon Flexman's Response to SANE Member

As you know, we are committed to open and honest communication with local people throughout the development of our proposals to build a new nuclear power station near Oldbury-on-Severn. To ensure that we are as pro-active as we can be in this regard we produce a local community update newsletter which is delivered to over 15,000 homes in the Oldbury and Thornbury area as well as to communities on the far side of the River Severn. Following the distribution last month of the fifth issue of this newsletter we have received numerous calls and emails from local people raising queries they have about our proposed project and, as always, we take care to respond to these enquiries in the fullest way we can but at this stage of the project we don’t necessarily have all the answers.

This year we have also been carrying out a programme of talks to local groups as well as instigating a series of regular drop in surgeries – both of which allow local people the opportunity to put questions directly to Horizon’s Oldbury development team. These activities are on-going and are in addition to the public exhibitions and other engagement events we will continue to hold as our prosed project develops.

It is also important to highlight that the new planning regime for nationally significant infrastructure projects requires developers, such as Horizon, to carry out extensive pre-application public consultation ahead of making an application for a DCO, which is effectively the planning permission for a project such as ours. This formal pre-application consultation is a key part of the new planning regime and allows local communities and individuals to review our proposals in detail and enables us to use the public feedback we receive to shape our plans. Our pre-application consultation has yet to begin and will only be carried out once sufficient information exists.

We will set out how we will consult communities at the pre-application stage in a Statement of Community Consultation (SOCC).The SOCC is being developed with local authority input and when finalised will be published in local papers and on our website.

Developing a new nuclear power station is a complex and lengthy process and we are still very much in the early stages. Your emails raise a number of questions which I have answered below as extensively as I can – given that at this stage in the development process many of the studies that will inform our future plans are still on-going or yet to be undertaken.

As you will see I have combined the responses to a number of your questions for clarity.

Flooding Issues

Your question asked why Horizon is seeking to develop a new nuclear plant at Oldbury given the site’s position on a flood plain. You also asked how the proposed development will be protected against possible flooding and how this fits with the EA’s designation of the site and Horizon’s commitment to safety.

Land adjacent to the existing power station at Oldbury is one of 8 UK sites included in the Government's draft Nuclear National Policy Statement (NPS) as being suitable for new nuclear build. We believe that the Oldbury site meets all of the criteria set out by the Government as part of its Strategic Siting Assessment (SSA) for new nuclear development. The existing power station has operated on the adjacent site safely for forty years. If managed correctly, we believe the area can accommodate a new development safely taking into account the flood plain location and the possible effects of climate change and/or a major flooding event.

In addition to demonstrating the safety of our site in the event of flooding, we will have to demonstrate to the satisfaction of the regulators that the measures do not increase the risk of flooding elsewhere in the locality. In fact it is possible that the steps we take may well improve flood protection for the area as a whole.

As part of the stringent planning and licensing process we are required to undertake for our proposed new nuclear power station near Oldbury-on-Severn, we will be carrying out extensive assessment of a range of potential natural events. This includes the requirement to consider events with a probability of up to 1 in 10,000 years, taking account of the possible effects of natural disasters such as tsunamis or storm surges, as well as the possible implications of climate change.

Our proposals to do this are currently being developed in conjunction with the Environment Agency (EA) and Office for Nuclear Regulation (ONR). They are likely to consist of a combination of raising the site level and improving existing flood protection measures. We are aware of the 1607 event you refer to in your questions and such events would have to be fully considered as part of the detailed modelling work.

  

You can be assured that our proposals with regards to flood protection will be assessed extremely thoroughly by the regulators. The ONR continually reviews safety arrangements against world best practice, applying knowledge from lessons learned from around the world before and throughout the operational lifetime of the plant. This includes assessing the probability of incidents with defined consequences and requires that the chance of occurrence is reduced to a level that is As Low as Reasonably Practicable – also referred to as the ALARP principle.

More information on this can be found on the HSE website. In particular you may find its report “The Tolerability of Risk from Nuclear Power Stations” of interest. Go towww.hse.gov.uk/nuclear/tolerability.pdf

Finally, the interim report that has been compiled after the Japanese Tsunami by the UK’s Chief Inspector of Nuclear Installations Dr. Mike Weightman, recommends a review of the flood protection standards in the UK to revalidate them and we agree with that.

Cooling tower issues

You asked if Horizon has ruled out 200m high cooling towers and, if not why not. You also asked if Horizon’s preferred choice of hybrid towers will add to the overall costs of the development.

Last year we announced that Hybrid cooling towers are our preferred option for the proposed new nuclear plant near Oldbury. Circular Hybrid towers, which use fans, are up to 70m in height and are more in keeping with the existing Magnox power station. This decision to state our strong preference for hybrid towers is a key milestone for the Oldbury project and is helping to shape our on-going development work.

With hybrid cooling towers the capital cost is indeed higher than the cost of building natural draught cooling towers. Similarly, running costs for hybrid cooling towers are also more than those associated with natural draught towers, as energy will be required to power the fans, and the maintenance and equipment replacement costs are higher. However, it is important to point out that all of these costs for the cooling towers are a very small percentage of the overall figure of around £8 billion that would be invested into a new nuclear power station at Oldbury.

Natural Draft Cooling Towers (NDCT) are an efficient engineering option but they are just one of the options that we have had to consider. We have never stated they were the preferred option. The best option for the site should balance technical, commercial and environmental factors.

  

As part of the planning and licensing process for nuclear new build in the UK we are required to evaluate all the realistic options for the major aspects of the development and to formally consult with statutory stakeholder groups and local communities on our preferred options.

We won’t rule out natural draft cooling towers until we’ve been through that process and gauged public opinion, but we believe we’ve been as clear as we can be about our preference.

Commercial issues

You asked if the Horizon is seeking subsides from the UK tax-payer and what level of profit per KWh generated the company is seeking from Oldbury.

Firstly, Horizon is not seeking subsidies from the UK tax payer for nuclear power, all we require is a level playing field with other forms of low-carbon generation. As you are no doubt aware, the UK’s old coal, oil and nuclear power stations are coming to the end of their lives, which means that the country needs lots more power generation capacity to meet demand. In fact the Government estimates the UK will need 59GW of new capacity by 2025. In comparison we currently have 85GW of power station capacity.

The Government wants as much of that new capacity as possible to come from low carbon energy to meet the target of reducing greenhouse gases by 80 per cent from 1990 to 2050. It estimates that renewable energy will contribute up to 33GW and it wants nuclear to make up as much of the remainder as possible.

Nuclear power is the only proven technology capable of delivering large quantities of low carbon power that is available almost constantly. If you judge all the major low carbon technologies on an equal basis it is also the most economical in terms of the cost per unit of electricity generated.

As already stated in an answer above, Horizon will potentially be investing £8 billion in a new nuclear power station at Oldbury and will be seeking a return on this investment. Final investment decisions are still some years away and so we are not in a position to expand on this further.

Policy issues

You raised a number of issues with regards to recent decisions by the German Government with regards to nuclear power and asked what the implications are for Horizon’s German shareholders.

We can’t comment on behalf of our shareholders but they have said publicly that the situation in Germany has no direct impact on the new build programme in the UK. We are continuing with our development activities.

Health & wellbeing

You asked a number of questions with regards to possible links between living close to nuclear sites and instances of childhood leukaemia.

Safety and Health are our absolute top priorities and on radioactive health issues we will take our lead from the experts. The Health Protection Agency and the Independent Government advisory group COMARE (Committee on Medical Aspects of Radiation in the Environment) are the independent authorities in the UK).

COMARE’s studies strongly support the scientific consensus that the levels of radiation around nuclear power stations are much too low to cause leukaemia clusters. In its Fourteenth Report, published last month (May 2011), COMARE concluded that it saw no evidence to support the view that there is an increased risk of childhood leukaemia and other cancers in the vicinity of nuclear power plants in Great Britain.

For more information go to: http://www.comare.org.uk/press_releases/documents/COMARE14report.pdf

Page 36 -55 include COMARE’s review of the German KIKK study. 

Recent Events in Japan

You asked a number of questions with regards to the events in Fukushima and the subsequent decision by the Japanese Government to cancel nuclear new builds.

Without first-hand knowledge it is not appropriate for us to comment on the details of the event or the on-going response from the Japanese Government, however we’re watching the situation closely as is everyone in the nuclear industry worldwide.

The UK has very different circumstances to Japan – we don’t have magnitude 9 earthquakes and Oldbury is not near a tectonic fault line. We will use the very latest reactor technologies with very different design features. Even so the Chief Nuclear Inspector, Dr. Mike Weightman has been asked by Government to produce reports looking into the events at Fukushima so that any lessons learned can be incorporated into the safety regimes governing existing and future plant in the UK.

In his ‘interim’ report Dr Weightman has said there is no reason for new build proposals to be put on hold. The report also contains 26 recommendations designed to ensure no learnings are missed and we will shape our proposals around these recommendations.

  

The safety regime in the UK is extremely stringent. As outlined elsewhere in this response, developers have to undertake assessments for a wide range of natural phenomena including earthquakes and tsunami, as well as man-made threats. We have to show conclusively that our proposals are robust enough to withstand even the least likely events.

Nuclear waste storage

Following on from recent events in Japan you asked what specific safeguards we are offering the local community on safety with regards to the storage of nuclear waste on site.

We will be required to demonstrate, in our site licence application, that nuclear waste can be safely stored onsite. Those plans are not yet written but the UK has a forty-year-plus record of the safe onsite management of nuclear waste and this is internationally recognised as being robust and effectively regulated.

We will also ensure that our proposals reflect any learnings from the Chief Nuclear Inspectors reports into the events at Fukushima.

In the longer term the Government is developing proposals for the Geological Disposal Facility which will be the ultimate home for intermediate level waste, high level waste and spent fuel. The precise nature of this facility may allow the earlier removal of onsite waste to a central facility which may be a more logistically practical solution than multiple storage at sites around thecountry.

Democracy

You asked about Horizon’s views on the Government’s localism agenda and if its Localism Bill will impact on our proposed development.

The whole purpose of the extensive consultation process we are required to undertake, before a planning application is even made, is to take people’s views on board and a large proportion of those views will come from people and organisations from the area. It is very unlikely there will be a unanimous view of any sort from ‘local people’ however one might choose to define that group. We have many supporters, as well as those with concerns, and those whose views are likely to depend on the details of our plans. In our view our role is to put forward proposals that are well thought out and reflect local people’s ideas and hopes and address their concerns.

Employment

You asked about employment opportunities for local people being guaranteed.

This project will create around 800 permanent jobs which will include everything from nuclear scientists and engineers to admin staff, security guards and gardeners. The construction phase will require several thousand workers, peaking at around 5,000, and a significant demand for local goods and services.

Undoubtedly some of the workforce will be from outside the area, and some from abroad, but we will ensure that there will be jobs and work for local people during construction, operation and

decommissioning of this station. The challenge for everyone involved in nuclear new build is to make sure local opportunities are maximised.

I hope that this response goes someway to answering your queries, if you have any further queries please email oldburyequiries@horizonnuclearpower.com or call our Freephone number 0800 130 3125.

Kind regards

Leon

Leon Flexman

Head of Communications

Horizon Nuclear Power