Secretary of State Scoping Opinion June 2014

In order to comply with the pre-application process, EDF are required to produce an Environmental Statement to show that they have investigated and understood all of the aspects that the development of Sizewell C will have on the local habitat and community. Once EDF produced their initial report, Statutory bodies such as the local councils and the environment agency were able to respond and comment on the scope and detail of the environmental statement. The statement and responses were then sent to the secretary of state who assessed them and from the assessment produced an opinion on what topics EDF needs to include, and which areas they need to do more work on. This assessment (SCOPING OPINION Proposed Sizewell C Nuclear Development) was published in June. It is a long report, and the most interesting parts are the appendices of the responses from the statutory bodies. These responses covered broad topics like dealing with the waste and specific issues such as the volume of traffic on the B1122 . EDF are then obliged to take the points made by the secretary of state into consideration when producing an environmental impact assessment which will (hopefully) be a detailed assessment of the impact Sizewell C would have,

The paragraphs below are taken from the secretary of states scoping opinion, a copy of which can be downloaded from here. They highlight some of the issues that are of concern to the statutory bodies.

Scoping Opinion Proposed Sizewell C Nuclear Development

SoS = Secretary of State

ES = Environmental Statement

EIA = environmental impact assessment

Water Use

3.95 The Scoping Report provides no clear details regarding the source of water for the proposed development, both during construction and operation, and for the variety of sources for which it will be required, such as the campus accommodation, main power station site, for the concrete batching plant etc. The applicant’s attention is drawn to the comments of the Environment Agency in respect of water resources.

Waste Storage and Decommissioning

2.100 The SoS notes that the operational life of the Sizewell C power station is 60 years. The life of the spent fuel storage element of the development would be at least 100 years, beyond the life of the operational power station. The SoS recommends that the EIA considers how the spent fuel storage would be maintained throughout the anticipated 100 years life of the facility.

3.18 The Scoping Report refers to a high-level assessment to be undertaken for the decommissioning of Sizewell C power station; however, it is unclear how and where this information will be presented within the ES. No reference to decommissioning has been made within the individual topic chapters. The SoS recommends that the ES structure include for the high-level assessment of decommissioning.

Temporary Structures:

2.95 The SoS notes that there are various aspects of the proposed development that are described as temporary. The ES should clearly describe the elements of the project that are temporary, including the timescales and methodology for their removal.

3.6 It is not clear from the Scoping Report which elements are temporary during construction, at what stage these will be decommissioned and how these will be considered within the proposed ES. The ES will need to ensure that an assessment of all activities associated with the proposed development is included within the EIA.

3.101 The Scoping Report identifies that the construction period, following site preparation, is envisaged to last between seven and nine years. Section 7.12 of the Scoping Report classifies temporary impacts (long-term) if the effects are experienced over a period of no more than five years. The SoS queries how impacts that may occur beyond five years (in the event that they are identified) would be classified.

3.148 The Scoping Report identifies the rail options as temporary development; however, it is not clear when the rail option would be removed in relation to the development of the power station.

Tourism

3.26 The SoS recommends that the socio-economic ES chapter assess the impacts of the proposed development on potential tourism receptors beyond the consideration of tourist accommodation, for example, visitors to the Heritage Coast.

Data Collection and Field studies

3.53 The Scoping Report provides very little information regarding the methodology and scope of the proposed further collection of field survey data and desk study information. The SoS recommends that the methodology for data collection and sources of desk study information be agreed with Suffolk County Council, Suffolk Coastal, District Council and other relevant consultees.

3.64 The Scoping Report paragraph 7.6.3 refers to new geophysical and geomorphological data of the offshore region and the adjacent coastline; however, no detail has been provided regarding the sources and scope of the data.

3.106 It is unclear from this section whether thermal plumes will be assessed in this ES chapter, in addition to the marine quality and sediment chapter. The SoS recommends that full consideration will need to be given to the potential effects of the cooling water system, including scour, increase temperature, and the introduction of any chemicals, as required. Cross-reference should be made between the assessments undertaken for coastal morphology and hydrodynamics and those within the marine water quality and sediments chapter

3.108 The SoS notes that the inter-relationship between coastal geomorphology and hydrodynamics and the marine historic environment is not discussed within the Scoping Report.

3.115 The Scoping Report Section 7.14 identifies the modelled baseline for the cooling water model is the situation without Sizewell B. The applicant’s attention is drawn to the comments of the Environment Agency in Appendix 2 of this Opinion. The Environment Agency disagrees with this modelled baseline, due to the likely overlap between the two operational power stations.

3.121 The Scoping Report does not contain sufficient information regarding the surveys undertaken to date (including methodology) and the methodology of proposed further studies to ascertain whether these are appropriate and adequate. The ES will need to provide detailed information regarding the surveys including methodology, timing, and detail of the equipment used.

3.134 Section 8 of the Scoping Report does not include timings for the proposed further surveys nor does it specify the proposed methodologies/best practice standards to be followed for the majority of the topic areas.

Flood Risk

3.109 This section should draw on the FRA to include consideration of tidal flood risk and the potential for breaching/overtopping of the proposed flood defences under present and projected sea level scenarios. The potential impacts of flood defences and coastal protection

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From the Environment Agency response:

3.8 Spent Fuel and Radioactive Waste Management

This section refers to storage of spent fuel but makes no reference to other alternatives for dealing with spent fuel (e.g. reprocessing). This is not covered in the section on alternatives. The EIA should include this topic area.

There is no reference in the report to the application of Best Available Technology (BAT) or the waste hierarchy to minimise volumes and activity of radioactive wastes. This needs to be incorporated into the EIA.

7.11 Groundwater and 7.12 Surface Water

Water Resources – There is no clear indication of how water will be sourced – either for construction, or operation.

7.17 Radiological

7.17.4 – It is unclear what the justification is for bounding the radiological impacts of decommissioning to those for routine operational activities. Discharges during operations will be different from those during decommissioning.

7.17.27 – We note that an assessment of discharges will be included in the EIA which we support. A point to consider will is whether discharges will be modelled on a continuous discharge or on a more realistic model (e.g. Pressurised Water Reactor peak discharges during re-fuelling outages).

7.17.58 – It is important that the cumulative impact assessment includes worst case scenarios, such as a refuelling outage at Sizewell B and C at the same time resulting in peak discharges to the environment.

From the Marine Management Organisation response

4.4. References are made throughout the report to baseline studies undertaken, though details of methodologies used and results obtained are only provided in summary. The description of the baseline and survey work is often vague, for example in relation to ornithology and marine ecology. It is therefore difficult to confirm whether all relevant baseline material has been accessed, or whether the surveys undertaken or proposed are adequate.

Section 7.13 – Coastal geomorphology and hydrodynamics

4.15. The Report provides good detail on the approach for the ES and the modelling appears to cover the appropriate scale of change (temporal and spatial). However, there is a lack of transparency in the scoping of issues and no issues have been clearly scoped out. Issues should be clearly scoped in and out of the ES with clear justifications and assessed appropriately to ensure all potential impacts and impact pathways have been identified and assessed appropriately.

 4.16. Specifically, the Report is missing the impact pathways and implications of climate change over the life time of the project such as changing patterns of offshore banks and flood and coastal erosion risk, including the potential for changing beach profiles reducing effectiveness of the beach. Therefore, it is unclear whether all potential impacts and impact pathways have been linked due to the limited project description. More detailed information, specifically on construction and operation, is required to ensure all impacts and impact pathways are identified.

4.17. Consideration needs to be given to modelling extreme events and climate change. Modelling should cover the cooling water discharges, contaminant concentrations, sediment disturbance (e.g. long term dredging) and provide sensitivity analysis to cover inherent variability and uncertainty in calibration and input parameters.

4.28. The types of data being collected are considered to be appropriate however more detail on the survey methods and survey design is required. The descriptions of the methods used to collect the data are very brief and, in the absence of detailed information, it is not possible to determine whether the surveys are appropriate. The approach to the assessment of impacts (including cumulative impacts) is unclear;

4.29. The marine ecology baseline information is brief, often vague and incomplete with no clear references made to whether the statements are based on judgement or 6 Further information is available at

http://www.marinemanagement.org.uk/licensing/how/sample_analysis.htm references. The detail of the surveys is missing and references are not provided in the report and should be clearly documented in the ES where necessary.

4.33. There is little consideration of the impacts on fish and fish populations. The impacts described in section 7.3 of the Report identify long term effects on bird populations but not on the fish themselves which is considered to be a significant omission.

From Suffolk County Council

1.11. Life span of the development/decommissioning

1.11.1. The ES should be clear on the duration of effects for which it is assessing – does the ‘lifetime of the site’ (for example 2.1.9) include the decommissioning phase? How does this also relate to the ISFS and ILW, and their respective design lives (section 3.8)? The design life for the ILW [Intermediate Level Waste] and LLW [Low level waste] stores should also be clarified.

2.18. Radiological

2.18.2. The Scoping Report does not specifically rule out the future use of Mixed Oxide Fuels (MOX) at Sizewell C. The ES should either rule out the use of MOX fuel or comment on the radiological significance and justification for this fuel if it is intended to be used.

2.18.4. Detailed information should be provided as to the integrity of all radioactive material storage and any radioactive waste packaging facility on site. This should include comments on the suitability of storage over the proposed ‘lifetime’ of the site.

2.18.5. Any intended off-site storage of radioactive waste, whether interim or permanent, should be detailed in full, including location and capacity, together with the radiological significance and justification for storing this type of fuel off-site.

2.1.9 We question whether in reality ‘there is sufficient land area within the nominated boundary’ – we believe Sizewell C is only 32ha whereas Hinkley C is 58ha. If EDF need more land this would mean eating into even more AONB land.

Table 5.1 Given that the area occupied by the proposed campus is surely of “high value/sensitivity” why is it still being considered, when alternatives are available? It has often been suggested to EDFE that smaller dispersed sites in centres where the size of population and local infrastructure could better absorb the impact of up to 3000 workers, would be a better way to mitigate the impact of the build. There is no evidence that this suggestion or similar has been seriously researched by EDFE, including the possibility of designing off-site accommodation so that one or more, with a change of use application, could become legacy housing. If it has, the research results should be made available. It is hard to avoid the impression that the campus location is one driven by commercial considerations, with no genuine thought given to the enormous negative impact on the local community. The Scoping Report should cover this question fully.

Response from RWE (Galloper Wind Farm )

Of fundamental concern to GWFL, regarding the Scoping Report, is that although GWF is mentioned on a number of occasions as having potential for cumulative impacts on other receptors it is not acknowledged that the proposed Sizewell C development could itself have an impact on GWF.