SANE submit their response to the DECC consultation
Response to NPS public consultation (EN-6): Oldbury
Shepperdine Against Nuclear Energy (SANE)
SANE is a group of local residents living around the planned new nuclear site at Shepperdine, near the 50-year-old Magnox power station at Oldbury which is soon to be decommissioned.
SANE includes members who accept the current need for new nuclear, in addition to others who are opposed to nuclear energy in general. However, all are united in their opposition to this proposal, on the grounds that Oldbury/ Shepperdine is uniquely unsuitable for a new nuclear development of the size planned.
We were very surprised that Oldbury remained on the list of potential sites, when Braystones, Kirksanton and Dungeness were all removed for reasons that included (and, in the case of Dungeness, was exclusively) the adverse impact on the environment and landscape. Oldbury/Shepperdine is an estuarine site with limited access to water for cooling the reactor. Accordingly, it is the only one of the nominated sites which must have cooling towers, and is therefore by far the largest and most intrusive of all the planned developments. The Severn Estuary and the countryside which overlooks it are both naturally beautiful and internationally important for their biodiversity.
It is indefensible to put the largest and ugliest of the new nuclear builds in one of the most attractive and sensitive localities on the list, especially when the generating capacity can be provided at alternative sites that are less significant and less vulnerable, and that do not need cooling towers.
Our detailed concerns, and the evidence to support them, are laid out below. The numbers in parentheses refer to paragraphs in the revised Draft NPS for Nuclear Power Generation (EN-6). These concerns amplify the views which we expressed in our initial response to the original Draft NPS, and take account of the revisions made by the Government.
We remain deeply concerned about several generic issues which we highlighted in our earlier response. These include the uncertain risks of storing radioactive waste on site (potentially for up to 160 years); the destruction of local communities; and the disruption caused by building and the influx of the construction workforce. However, these arguments apply to all of the nominated sites.
Instead, we focus here on the specific factors that make Oldbury uniquely unsuitable for a new nuclear development based around either of the reactors that were recently approved in the Generic Design Assessment process.
1. Visual impact
Oldbury is the only site that must have cooling towers, even for the single reactor assumed for each site (7.247). In fact, Horizon (the nominator) have now proposed up to three reactors, which would necessitate three or four cooling towers.
Horizon now claim that their preference is for 70-m (230-foot) fan-assisted ‘hybrid’ towers, rather than the 200-m (660-foot) natural draught towers originally proposed (7.310). However, they have not ruled out the taller option, and could well revert to this, because the hybrid towers are more expensive to build and maintain, and also have the potential to break down mechanically.
Even the 70-m towers, which are around the same height as the existing power station (7.743), would be visually extremely intrusive. The surrounding landscape is predominantly flat and is overlooked by the hills leading to the Cotswold Edge to the East, and by the Forest of Dean and the hills bordering the Wye Valley to the West.
The 200-m towers would not only be the tallest cooling towers in the UK, but would be among the tallest built structures in the country, being comparable with the Post Office Tower and the highest buildings in Canary Wharf; they would dwarf the Severn Road Bridge and match the height of the Cotswold escarpment. They would be visible across a wide area of the Upper and Lower Severn Valley and, with a steam plume, potentially for 50 miles or more.
The Severn Estuary and Vale are attractive in their own right and lie between two Areas of Outstanding Natural Beauty, the Wye Valley and the Cotswolds; the power station would intrude especially on views from the latter.
Given the much greater size and height of the power station, and the attractiveness of the locality, the visual blight (7.33) which it would cause is much greater than at any other nominated site. This cannot simply be dismissed as “a perceptible deterioration in some views” (7.740), especially as there is no feasible means of satisfactory mitigation.
We note that the visual impact would be evaluated more stringently should a full planning application be submitted (7.252). We understand that this is the stage at which bodies such as Natural England and the Campaign for the Protection of Rural England would also provide detailed assessments. However, given the unique scale and impact of the plans for Oldbury, and the fact that potential blights on precious landscapes have already contributed to the removal of three other sites from the list, we are surprised that Oldbury was not similarly ruled out before now.
2. Safety
Our main safety concern relates to flooding, both of the nuclear power station from the Estuary, and of the area inland (7.715) which is drained by a series of large ditches that empty into the river.
The whole of the Oldbury site lies in Flood Zone 3, giving it overall the highest flooding risk of all the nominated sites. We note that high-risk sites have been left on the revised list because it is felt that there are not enough alternative sites with a lower flood risk (7.713); however, this neglects the possibility, acknowledged elsewhere (7.82), that not all the sites may ultimately be developed, or that extra generating capacity could be accommodated in one or more sites with low flood risk.
It may well be possible to protect the vulnerable parts of the power station within the flood defences. However, this will inevitably add to the cost of the project. Even more expensive would be further measures to ensure that building the station and its flood defences would not lead to collateral flooding of the area inland. We have not seen evidence that Horizon appreciate this risk or have thought about how to protect us against this eventuality.
Overall, on grounds of safety, specifically related to the risk of flooding of the site itself and of nearby communities, Oldbury is also an outlier from the other sites on the list.
3. Damage to the environment and biodiversity
The high density of nationally and internationally recognised habitats and Sites of Scientific Interest that would be affected by a new nuclear power station at Oldbury is alluded to in 7.733. The ecological consequences at any of the nominated sites remains unknown, but because Oldbury will discharge its effluent into a shallow tidal estuary rather than the open sea, the impact is likely to be greater here than at other sites.
The Severn Estuary is potentially vulnerable to discharges of hot water and biocides from the power station. Horizon state that the volumes of hot water returned to the river will be less than if there were no cooling towers. This is a meaningless argument; they give no information about how these volumes might compare with those discharged by the existing station, or how this will affect water temperature and quality in the Estuary or upstream in the river.
Hinkley would also discharge hot water and biocides into the Estuary, but much lower down and into massively larger volumes of seawater. Its own impact would therefore be much less; however, there could be cumulative effects of the discharges from both power stations on marine and estuarine life in the Severn.
We appreciate that the environmental impact would be considered in greater detail following a full planning application. However, the limited capacity of the Upper Severn Estuary, as compared with the open sea or even the Lower Severn Estuary, and the consequentially greater risk of damage to marine and estuarine life, must mean that this is a particularly unfavourable site.
Failure of information provision and public consultation at Oldbury
In addition, we would like to express our dissatisfaction with the consultation process, and to provide evidence that this has failed to reach significant numbers of the people who will be most affected by a new nuclear power station at Oldbury.
The Government’s own consultation process has been complicated, off-putting and intimidating. Even to those with a scientific background, the documents are voluminous and technically detailed, and a real challenge for non-experts to get to grips with.
Key specifics about the Oldbury site – notably the unique needs of the cooling and the particular environmental and flooding risks of this shallow estuarine locality – should have been made crystal clear from the outset, so that local people could have enough information with which to reach a balanced decision.
In fact, these issues have not been brought out, and indeed have until recently been concealed by Horizon. At their first major ‘public engagement’ event in Thornbury in spring 2010, Horizon showed an artist's impression of a single-reactor power station – but deliberately omitted the cooling towers from the drawing. It was only some months later, after SANE had publicised images of cooling towers, that Horizon produced their own images. These were in leaflets which Horizon claimed to have delivered to all residents in the surrounding area. In fact, these did not reach houses in Rockhampton, the nearest significant population to the site.
Since Christmas 2010, we have organised meetings and placed advertisements in the local paper showing to-scale images of the planned site with either size of cooling towers. Following this, many people have told us that they were previously unaware of how large the development was planned to be, and that they had assumed that the new station would be a like-for-like replacement of the old Magnox reactor.
A timely example came from a meeting of the Sixth Form of Castle School in Thornbury this morning (20th January), where a show of hands demonstrated that only three of the 200+ young people present claimed to be aware of the size of the planned power station. These are the people who will have to live with the new station and its consequences. Horizon have recently made overtures to Castle School by sponsoring a calendar and promising money for a new science laboratory. Regrettably, Horizon declined the offer to take part in a proper debate at the school this morning, and instead will be making a presentation in February – which of course is after the public consulation will have closed.
It is unfortunate that Horizon did not feel able to discuss the case for and against the power station in an open forum so that these young people can make up their own minds about their plans for Oldbury, and even more unfortunate that the youngsters will be unable to register any objections that Horizon’s presentation may provoke.
All this is solid and disconcerting evidence of a striking failure of information provision and public engagement. This is all the more significant because Oldbury is by far the biggest and most intrusive of all the new nuclear developments. It follows that the true extent of public unhappiness about the plans for Oldbury will only be known when accurate information has been properly disseminated and its reception verified.
Conclusions
We take comfort from the statement (7.246) that “the conclusion that the site is potentially suitable does not mean that an individual application for development at that site would be granted by the IPC.” However, we believe that this development should not be allowed to proceed to that stage.
Oldbury is, quite simply, wholly inappropriate for a new nuclear power station of the size stipulated in the Generic Design Assessment.
Assuming that there is a genuine need for new nuclear, there are other much more suitable sites that could provide this capacity.
Oldbury should be taken off the list of potentially suitable sites forthwith.
The Government is no doubt aware of the risks to its credibility and reputation that are associated with how it handles the many sensitive issues around nuclear power, and the need to balance energy provision against the country’s environmental heritage.
To persist with the development at Oldbury will raise grave questions about the Government’s stewardship of our countryside and protected environments – and could easily turn into a public relations disaster for the “greenest government ever.”
Professor Gareth Williams, MD ScD FRCP
For Shepperdine Against Nuclear Energy