JULY 2022 Update
Why Say No to Sizewell C
EDF’s unproven EPR design destined for Sizewell C
The only EPRs in operation for any length of time, are the 2 in Taishan, China, which were built to Chinese regulatory standards. Taishan 1 had to be shut down in July 2021 after only 30 months of operation due to a build-up of radioactive gases inside the reactor. The cause of the problem has still not been identified. In June 2022, the Office for Nuclear Regulation advised that the last contact they had had with the Chinese nuclear regulator was back in January 2022!
In addition, a potentially serious vibration problem has been identified when testing the EPR at Olkiluoto, Finland which, after more than 16 years in construction, is slated for commercial operation in December 2022. TASC understand that rather than dealing directly with the cause of the problem, ‘dampers’ to reduce the vibration will be fitted, undertaken with no guarantee that this will be a long-term solution. As for the Flamanville, France EPR project, construction started in 2007 and it is still not in operation.
Despite the obvious doubts about the EPR technology, this hapless UK government is still planning to invest public funds into Sizewell C. Many commentators have criticised the government’s nuclear policy, even the Daily Telegraph!
It was also encouraging to hear that Lord Deben, the Chair of the UK’s Climate Change Committee, described the Sizewell C project as ridiculous and questioned EDF’s competence.
Threats to terrestrial flora and fauna
The Sizewell C nuclear site, situated in the heart of Suffolk Coast and Heaths Area of Outstanding Natural Beauty, is constrained on 3 sides by precious wildlife sites, the 4th boundary being the Sizewell B nuclear power station. To the east is the Heritage Coast county wildlife site with rare, vegetated shingle habitat, the entirety of which along the boundary of the Sizewell C site will be removed to make way for construction of the Sizewell C sea defences. To the west, is the Sizewell Marshes Site of Special Scientific Interest (SSSI) which is currently managed by Suffolk wildlife Trust. Despite the SSSI being a pristine ecological treasure including rare fen meadow and wet woodland habitat providing homes to many rare species of flora and fauna, 6 hectares will be permanently lost to concrete, including some as part of the base of the nuclear platform. Sizewell C’s northern boundary will be with the internationally important RSPB Minsmere nature reserve, home to many rare and common species. RSPB Minsmere has various designations including: Ramsar site; Special Protection Area; Special Area of Conservation; SSSIs, that recognise its ecological importance.
All these wildlife areas are under severe threat from Sizewell C. These threats are explained in greater detail on the RSPB website and in DCO submissions from Suffolk Coastal Friends of the Earth including early stage ‘Written representations’ and at the end of the examination period.
Devastation of the marine environment
The Sizewell C cooling water system will suck in 2.5 billion gallons of sea water daily throughout its planned 60 years of operation and with it, a huge number of assorted fish and other marine creatures, some of which will be ‘impinged’ on the mesh covers over the intake pipes and returned to the sea via the fish return and recovery system, resulting in millions of soft bodied fish injured or killed. However, hundreds of millions of juveniles, small and long, thin fish will, each year, be sucked through the mesh [‘entrained’] to their deaths in the 3km of pipes, before being disgorged with various chemicals, back to the sea with the sea water, which, by then, is 10-12°C hotter forming a polluting soup.
Despite an Acoustic Fish Deterrent (AFD) being part of the proposed mitigation measures to reduce fish mortality at Hinkley Point C (HPC), one has not been proposed by EDF for Sizewell C, a move TASC see as demonstrating EDF’s disregard for its impacts on the marine environment. Indeed, EDF now want to renege on its agreement to install an AFD at HPC, leading to a public enquiry that ended in June 2021 following which a confidential recommendation was made by the planning inspector to George Eustice, the Secretary of state for DEFRA. Surprisingly, the decision of that enquiry has yet to be announced but could have implications for Sizewell C.
EDF have paid government agency CEFAS £millions [£17.5m in 2015-2018] to support EDF’s environmentally destructive plans. TASC have shown that the DCO documentation fails to adequately assess the numbers of fish that will be killed, including many species protected for commercial and conservation purposes. TASC has made suitably robust representations on this matter to the planning inspectorate and, among others, the Secretary of State.
Unsustainable consumption of mains water
Repeated assessments by the IPCC predict that the UK will experience longer, more serious periods of drought and that there will be greater pressures on the availability of drinking water as the impacts of climate change are realised. At the end of the DCO application in October 2021, EDF was unable to demonstrate the availability of a guaranteed mains water supply for the planned huge Sizewell development, despite planning Sizewell C for over 10 years. During this period of a decade or more, and throughout the Development Consent Order process, many local residents and NGOs expressed concerns about Sizewell C’s use of mains water in one of the driest parts of the country. This apparent incompetence demonstrated by EDF, is further highlighted by their plans to have tankers bring in water during the early stages of construction, adding more disruption and pollution to the local area. The 10–12-year construction period will require up to 4 million litres of mains water per day. The following 60-year period of operation will use an average of 2.2 million litres per day. In a desperate attempt to show that construction work can commence, EDF, in the last few weeks of the examination decided to propose using a desalination plant to supply water for construction, yet only months earlier EDF had discounted use of desalination as being too environmentally damaging.
During the DCO examination, EDF assured critics and opponents that the desalination plant would be removed before operations began. However, as mentioned above, EDF have reneged on promises made before at HPC. After closure of the DCO examination, government department, BEIS, asked EDF to confirm if the desalination plant could be used for Sizewell C’s operation i.e. for a total period of 72 years or more. To construct and operate a £20+billion plant over such a long period of time while being entirely reliant on a desalination plant, surely is beyond credibility. However, EDF have responded by advising that, in their opinion, they could have a permanent desalination plant and, if they do, it could be built on Sizewell A land (which would result in a car park being built in the AONB on Pill Box Field) or underground on a site in Goose Hill (again in the AONB).
Sizewell C’s carbon debt
EDF’s greenwashing campaign often includes claims for carbon savings when, or if, Sizewell C becomes fully operational around the mid-2030s. However, EDF’s figures are calculated by comparing with electricity generated by burning gas. TASC believe this is an attempt to deliberately mislead, as the UK government have already committed to electricity generation being net zero by 2035, so there will be no gas on the grid to offset against.
EDF’s DCO application in May 2020 stated that the carbon debt just from construction i.e., excluding the carbon footprint of the fuel was 5.74 million tonnes. In January 2021, EDF then Increased this to over 6.24 million tonnes. A few months later, EDF then claimed the carbon debt had fallen to 3.8 million tonnes, which appears to indicate that EDF either don’t have a clue or do not want to disclose a true calculation. However irrespective of the true carbon debt, a zero-carbon grid by 2035 will mean there is no payback of this huge carbon footprint. In any event, if the UK diverted proposed nuclear funding into renewables, insulation of buildings and reducing energy that is currently wasted now, carbon reductions could be made in the next few years. This would bring about a far cheaper and more rapid reduction in the use of gas rather than waiting for 12/15 years for Sizewell C to be deployed.
The cost of Sizewell C
Prior to the DCO examination, EDF estimated the cost for building Sizewell C to be £20 billion but have refused to provide a revised figure that would incorporate all the changes proposed during the examination, e.g., new jetty; temporary desalination plant; construction of 28 kilometres water transfer main; new railway crossing at Darsham; increasing the scale of the now 1.5-metre thick, 60-metre-deep reinforced concrete cut-off wall to be installed around the perimeter of the proposed licensed site; and potential permanent desalination plant. In addition, the cost of building materials have risen considerably since the £20 billion estimate was published.
In May 2022, EDF announced its latest estimate for the cost of HPC as £26 billion, an increase of £3 billion from the January 2021 estimate and a massive 44% increase from the £18 billion cost slated when construction started in 2016. At the start of HPC’s construction, EDF predicted that HPC would be operating by 2025 but EDF’s latest estimate is 2027. No-one will be surprised if time delays and costs are increased in the future. In 2018 the UK government and the Nuclear Industry Council signed the Nuclear Sector Deal agreeing that the cost of nuclear power plants would decrease by 30% by 2030. Yet, even EDF’s lesser claim that Sizewell C will be 20% cheaper seems improbable, particularly because of the more difficult ground conditions, the small site size and constraints imposed by building next to an operating nuclear power station, Sizewell B, and with the various protected landscapes surrounding the Sizewell site. EDF’s other European EPR projects at Olkiluoto, Finland and Flamanville, France, have both cost 3-4 times their original budgets and been delivered at least a decade later than originally planned. Flamanville 3 is still not in operation 15 years after construction started!
Despite being 83% owned by the French government, EDF have confirmed they are not willing/able to fund the construction of Sizewell C, resulting in our government contriving a special funding scheme (the Regulated Asset Base or ‘RAB’). RAB means that electricity customers will effectively be subsidising the Sizewell C finance costs by paying a nuclear surcharge in their electricity bills during the 10+ years building of Sizewell C and beyond. The inevitable cost overruns will also have to be picked up by electricity customers and/or UK taxpayers. The UK government have already put UK Plc on the hook for a £100 million investment into Sizewell C, committed £1.7 billion for a large nuclear project and have now said that they are planning to dip further into the public purse by taking a 20% stake in Sizewell C, a level of investment that EDF have stated they would match. EDF have said they hoped UK pension funds would meet the other 60% of the costs of construction.
The UK government are trying to persuade us that new nuclear can be cost effective by using the RAB financing model. However, SNP’s Alan Brown has said of the government’s own figures, “their impact assessment for the nuclear finance bill shows capital and finance costs of one new nuclear station could cost £63bn.”
The UK government have supposedly carried out a Value for Money for Sizewell C but conveniently redacted all their figures when details were published. We believe the lack of transparency speaks volumes.
EDF have made great claims about the level of community funding that Sizewell C will bring to East Suffolk through their DCO commitments. However, these payments are a token gesture to compensate for the damage EDF will inflict on the environment and on the people of East Suffolk. Also, EDF fail to mention, as they are financially destitute, this ‘compensation’ will be paid by ourselves through the RAB nuclear surcharge, electricity bills and UK government funding Sizewell C from our tax payments.
Exposing EDF’s claims for net biodiversity gain from Sizewell C
EDF persist in repeating claims that Sizewell C will produce a 19% Biodiversity Net Gain (BNG) even though these claims were shown to be highly flawed when addressed at the DCO examination, where it was shown that EDF’s calculations understated the value of what will be lost and overstated potential gains, some of which would take decades to materialize and would run the risk of not happening. It should also be noted that the BNG calculation takes no account of the devastation that Sizewell C will have on the marine environment.
The reality of EDF’s claims that the Sizewell C site is safe
EDF make claims that the site is safe based on the fact that there has been no impact on Sizewell A and B over the last 60 years but fail to mention that the existing A and B stations are both sited on a raised part of the hard local crag formation, 5-10 metres above ordnance datum, whereas the crag formation in the Sizewell C site is some 5-10 metres below ordnance datum and overlain with made-up ground, peat, sand and shingle. EDF’s claims denote a dangerous complacency that ignores: the fact that Sizewell C will need to be kept safe until, at least, the 2190s; the predicted sea level rise and storm surges resulting from climate change; the longer history demonstrating that there have been substantial periods of significant erosion on the Suffolk coast in the past; Sizewell has been protected in the recent past by the offshore Dunwich-Sizewell banks but their effectiveness (even their existence) as a protection to the coast at Sizewell, could disappear due to the impacts of climate change. TASC believe that the site is highly unsuitable, too small, and inappropriately located for such a huge and potentially dangerous development.
EDF have only modelled their flood risk assessments up to 2140, claiming that the site will be fully decommissioned by then. However, based in information supplied by the Office for Nuclear Regulation, the highly radioactive spent fuel will still be stored on site after 2140 and full site decommissioning is not expected to be completed until decades later. The flood modelling has also been criticised for not including storm surges of sufficient magnitude or regularity and for perversely concluding that wave impact would be lessened if Sizewell C lost the protection of the offshore Dunwich-Sizewell banks.
Despite Sizewell C having been planned for over a decade and despite the importance of the need to protect the proposed site from the impacts of climate change, at the close of the DCO examination EDF had not completed the design of the Hard Coast Defence Feature (sea wall) that is needed to protect the Sizewell C site until the 2190s. TASC understand that even now, June 2022, EDF have not carried out ground tests in the location of the sea wall, these being necessary to establish if the ground conditions are suitable to support such a vast structure and to ensure the sea wall will not be undermined by wave action and storm surges far into the next century.
EDF have only recently applied for permission to carry out soil tests that are needed to determine whether the cut-off wall, a critical element of the construction project, without which Sizewell C is unlikely to be built, can be constructed safely. Leaving such a crucial part of the construction project until after more than 10 years of planning, calls into question the competency of EDF to run the Sizewell C project. It also points to EDF’s couldn’t-care-less attitude to the stress that local residents have had to endure in dealing with five consultations over 11 years of preparation and a DCO examination that involved 22 significant changes.
The real impact of the Sizewell C project on local communities
During the decade or more that EDF have been planning Sizewell C, parish and town councils throughout East Suffolk have expressed concerns about the thousands of daily HGV/PGV journeys, and the 10,000 or more daily car/van journeys that will impact the lives and health of residents and businesses, especially in the early years when EDF plan to be building Sizewell C at the same time they will be building the so-called ‘mitigation measures’ i.e. the freight management depot, two park and ride sites, the two-village bypass, new railway line and the new road from the A12 at Yoxford to the Sizewell site. Yet, it was only during the recent 6-month DCO examination process that EDF made proposals to attempt to reduce HGV journeys by bringing more of the 12 million tonnes of aggregate, building materials and equipment by rail and sea, but this involves further damage to the AONB and Heritage Coast with a second jetty and more movements across the beach. Despite the atrocious conditions that residents along the B1122 will experience, EDF have refused to build the ‘mitigation measures’ that would alleviate some of the impact before work on Sizewell C starts. This reinforces the opinion that EDF have little regard to the impact on the environment and local residents.
As businesses struggle to recover from the impacts of Covid-19, many east Suffolk businesses are struggling to operate effectively due to lack of staff. This situation will inevitably worsen if Sizewell C goes ahead as existing businesses will not only find it harder to recruit new staff but will be negatively impacted as they run the risk of losing their existing workforce.
Sizewell C is a security risk
The war in Ukraine with the concerns over the Chernobyl and Zaporizhzhia nuclear sites, highlights the risk that nuclear power plants pose to national security and the potentially catastrophic consequences that could be caused by an aggressor with malicious intent or as collateral damage in a conflict situation. It makes no sense for Sizewell C to be built when there are alternatives that are cheaper, greener, quicker to deploy, and which do not pose a security risk.
The impacts of climate change mean that the Sizewell C site will need a program of managed adaptation to protect the site for its full lifetime, a burden on future generations way beyond its operational period due to the on-site storage of highly radioactive spent fuel. Such a burden is immoral in any event, but in an increasingly unstable world where recent events have demonstrated that nuclear power plants can be a target and a weapon, it is totally unacceptable.
Sizewell C is a risk to the UK’s energy security
Energy ministers have routinely stated that nuclear baseload is crucial for energy security – but this is not the case. In any likely 2050 scenario, baseload demand will be mostly supplied by offshore wind when the wind blows, and by hydrogen-fired back-up when it doesn’t. This dispatchable and mostly decentralised back-up, a function that nuclear stations cannot provide, has game-changing energy security and national security benefits. Solar, hydro, tidal, wave and other renewable energy producers can add to the mix, all of which can be used to produce green hydrogen by electrolysis when electricity supply is greater than demand.
Hydrogen back-up, comprising tens to hundreds of relatively small Combined Heat & Power schemes, located on sites on the lower voltage networks close to population centres, would routinely add to wind and PV supply to match changing demand. The back-up, connected via the gas network to electrolysers and bio-waste gasifiers would supply significant demand, for weeks if required, in the event of major Grid blackouts caused by the like of super- storms, terror attacks etc. In contrast, supply from isolated nuclear stations and their high voltage links are vulnerable to such Grid failures – and are also obvious targets to malicious actions which can have longer-term supply and inertia loss problems, and possible radio-toxic consequences. An event that stops a nuclear power plant operating, is anticipated to have far greater consequences to both electricity supply concerns and wider environmental impacts, than if an event means that several much smaller decentralised suppliers of renewable energy, such as wind turbines, have been stopped.
The UK’s major offshore wind and other renewable resources are highly secure, being indigenous and unstoppable whereas nuclear power stations are reliant on uranium sourced overseas and are therefore vulnerable to political and economic pressures exerted by other nations. 58% of global uranium is currently mined in Khazakstan, Russia and China and Russia currently produces 35% of the world’s enriched uranium for reactors. The UK and her allies will need to compete for uranium supply from friendly producer countries like Australia and Canada. Sizewell C would have a foreign reactor design, foreign developers, foreign operators and probably owners, and rely on foreign-sourced fuel. The claim of ‘home-grown’ nuclear is totally misleading.
As stated above, events in Ukraine in 2022 have demonstrated the risks when nuclear power stations are exposed to munitions in a conflict, particularly aircraft and missile attack. The Office for Nuclear Regulation has advised that military attack is not considered in its external hazards assessment. Future security threats include conventional terrorism, cyberwarfare and Artificial Intelligence. The Defence Secretary says “distance is no protection”.
TASC question why the UK government plans to expose the UK to these risks with a project such as Sizewell C, when there are alternative, safe means of supplying electricity within the 12-15 years that Sizewell C would take to become operational.
Together Against Sizewell C June 2022
