Leiston-cum-Sizewell Town Council Response to the Environment Agency (EA) consultation for 3 operating permits for SZC following discussion with EA representatives

Leiston-cum-Sizewell Town Council (LTC) has sought clarification from the EA on the following issues and we would like to thank the officers who gave us their time. It is crucial that the EA understands the concerns of this community, given that this parish is the host of the new nuclear plant. The health and wellbeing of our residents and the environment all around us, is of primary importance. Bearing in mind the discussions we have had with the EA, we therefore submit our concerns for the purpose of this consultation.

General observations

This Council remains nervous that despite SZC being the next generation of the PWR (which we acknowledge has an exemplary record at SZB to date), it is still a new design which has not been tried and tested over time.

SZC will be in operation almost into the next century (possibly further) and there are many unknowns, not least the rapidly advancing effect of climate change.

There is a growing urgency for a long-term repository for high level nuclear waste. Plans for deep geological disposal facility in the UK still appear to be at a very early stage. We trust the EA will bear this in mind if the UK continues to increase its dependence on new nuclear.

Emissions to water

1. We understand that the estimated number of fish fatalities is a ‘reasonable worse case assessment with the best available information’, which is of concern. We further understand that should this number increase, it would be a DCO impingement and require mitigation. We are yet to understand what the result of such an impingement would be, especially if mitigation were not possible. Hinkley Point C (HPC) will now install 2 x acoustic fish deterrents but this is not intended for SZC at present. As this was a late change at HPC, there has to be an assumption that SZC might follow suit.

2. This Council has been assured that the EA is an independent regulator and as such has not, and doesn’t expect to, experience a breakdown in trust with the industry. Council noted the permits are held by NNB GenCo who have a long relationship with the EA and not the holding company, SZC Co. But considering the longevity of this plant, this scenario cannot be dismissed, as agencies will change over the many decades that SZC is operational.

3. We have noted that NNB GenCo has assured the EA there will be no reason for a desalination plant when SZC reaches the operational phase. But with water shortages likely to become the norm in future, it is surely not possible to predict whether there will be no requirement during the 60-year operational life of the plant. This could potentially harm marine life in the coming decades and is a further ‘unknown’.

NB: Further concerns will be raised by this Council regarding discharges when an application for the permits required to build and operate a desalination plant for the construction phase is applied for.

Discharge of radioactive waste

1. The EA has assured this Council that they have experience of EPR technology, as it is essentially a PWR like SZB. However, we understand a number of modifications have been made to the design (European, not American), post Fukashima. The new generation of EPRs throughout the world have been beset with problems and delays and it is of concern that there is no real comparison for SZC. Further problems regarding discharges might occur as these plants move forward in their operational phase. Taishan in China and Olkoluto in Finland are the only units operational and only recently online after long delays to their completion for a variety of reasons.

2. This Council has been assured that monitoring will be consistent and of regular enough frequency to detect anomalies in discharges. SZB monitoring is of a high standard and there is no reason to believe SZC will be different. We trust this will continue over the many decades when the plant is operational.

3. This Council has concern regarding the length of time spent fuel rods will be stored on site. An assumption has been made that a Geological Disposal Facility will become available in the long term but this is not yet certain nor what its capacity will be (since there is already a vast amount of legacy waste to be safely contained and SZC will be at the end of the queue). EA has confirmed that a GDF is ‘likely’ to be available in the 2040s and that fuel rods would require a cooling down period, therefore they would need to be stored on site while they cool and won’t be ready for transfer until such time the GDF is available. The lack of certainty with regard to a GDF is still of concern to this Council.

4. Extreme events - flooding, extreme weather, terrorist attack. Despite reassurance from the EA, these events cannot be dismissed. We are assured by the EA that as independent regulators they will continue to learn from the industry worldwide. But with the bias towards renewables and saving energy as we move forward, this expertise might become less forthcoming.

Summary

This summer has seen unprecedented dry weather throughout the UK and particularly in our region – the driest in the UK. Surely, we can now predict that the potable water required as we progress towards construction and operation will add further burden to our water resources which are already under pressure. The availability of potable water for our residents has to take precedent. Despite reassurance from the EA, we question how the water supply can be accurately predicted for the next 75 plus years.

Given that there were still a number of unknowns (eg level of operational noise, light pollution) at the end of the PINS examination and that we know changes are likely during construction and operation (indeed expected, if the operator learns and improves), we require assurances that the EA can review and change licence conditions in the light of new information, circumstances or practices and they will be reviewed routinely. We have so far, had assurance from the EA but these issues all remain a concern due to the uncertainties that will unfold as the project progresses and the plant becomes operational.

Our trust in the regulator

We understand that the issues under consideration are technical and beyond the knowledge of councillors. Therefore, we rely on the EA and other regulatory bodies to protect our environment and our own safety and we do still have grave concerns about the effects of this project on the environment and the long-term safety of people living in this area. We therefore ask that the EA is as rigorous in your considerations and assessments as the law allows.

Thank you for seeking our response to your consultation.