22.07.24
Dear Simon and Sizewell C team,
The Office for Nuclear Regulation (ONR) has recently published documents that support the granting of a nuclear site licence (NSL) to Sizewell C. One of those documents, the External Hazards Reassessment report (https://www.onr.org.uk/media/1hwjiad5/sizewell-c-nuclear-site-licence-proportionate-reassessment-external-hazards-2024.docx), refers to the site safety case with specific reference to flood defences.
This report (see paras 52, 56, 57, 76 and 77, as well as the diagram in Appendix 3) refers to ‘overland flood barriers’ that were never considered in the DCO and were therefore never assessed for their environmental impact nor assessed for the potential impact on neighbouring properties. As you can see from Appendix 3 at the end of the document, the proposal includes two twenty-foot-high structures, the southern one stretching across the Sizewell Gap and the northern one potentially stretching from the Northern Mound to a location on Goose Hill. Paragraph 76 states “Overland flood barriers – SZC Ltd has committed to install overland flood barriers [emphasis added] should climate change be worse than is reasonably foreseeable [51], to protect the site from extreme still seawater level; see Appendix 3 Figure 1. The role of the overland flood barriers is to ensure that water surrounding the site is less than the platform height, ensuring that the SZC site remains protected...”.
TASC would also advise that SZC Ltd are also proposing new ‘milestones’ – see Table 4 in para 75 – one of which is that spent nuclear fuel will remain on site until (at least) 2160. During the DCO examination, TASC challenged the 2140 site lifetime set out by the developer, but our claims were rejected although they have now been vindicated. The confirmation of the 2160 site lifetime is important as it means that the need for the adapted sea defences and the overland flood barriers are more likely to be required as a result of the impacts from climate change.
Looking at the proposed location of the northern flood barrier, this would have major implications for RSPB Minsmere. We have referred the matter to the RSPB who confirmed that they were unaware of these proposals. The proposed southern overland flood barrier appears to be located on land outside the ownership of Sizewell C Ltd.
TASC would be grateful if the EA would:-
- Advise whether the developer has already made you aware of the proposed overland sea defences,
- If so, please confirm when you were notified,
- Advise whether you have seen environmental impact assessments for both the southern and northern flood barriers,
- Advise whether you have seen assessments of the impact on neighbouring properties,
- Have you considered whether the proposals are feasible and will be capable of keeping the site safe until the 2160s and possibly beyond.
- If the EA has access to these assessments, TASC would be grateful for sight of them.
TASC look forward to hearing from you.
Yours sincerely,
Chris Wilson on behalf of TASC
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Letter to EAST SUFFOLK COUNCIL on Flood Barriers https://tasizewellc.org.uk/enquiry-to-east-suffolk-council-on-flood-defences-07-24/
