11 months ago
1750
The Welsh NFLAs have joined campaign group No Nuclear Llynfi in making an appeal to the leadership of Bridgend County Borough Council to consider emergency planning arrangements in advance of a plan to bring a new nuclear power plant to the borough in 2027.
The US developer Last Energy plans to install four 20MW nuclear reactors on the former Llynfi power station site near Maesteg. Last Energy has applied for a site-specific licence from the Office of Nuclear Regulation to deploy the company’s ‘first of a kind’ design at Llynfi. An ONR senior official told the NFLA Secretary that the 2027 deadline was ‘very ambitious’ given the ‘immaturity’ of the design, with none previously built or operated in the UK.
Local Councils will be consulted, including the Borough Council as a planning authority. Last Energy is also currently engaged in community consultation. As well as a site licence from the Office for Nuclear Regulation, the company will also need to secure permits from Natural Resources Wales and ultimately sign off from the Welsh Government.
Regulatory approval is still uncertain, nor is it clear where the money to build the plant will come from as Last Energy claims to be self-financing the development.
The Llynfi site lies within the boundaries of Bridgend County Borough Council, which has historically been a member of the Welsh Nuclear Free Local Authorities. In addition to planning the Council has an emergency planning function, with elected members and officers being jointly responsible for safeguarding the health and well-being of the borough’s residents. The Council is also a constituent member of the South Wales Local Resilience Forum.
The Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR) place a duty on local authorities hosting a licenced nuclear establishment to protect the public in the event of a radiation emergency. This includes having an emergency plan in place and providing prior information to people who live, or work, in the area surrounding the site who may be affected by any radiation emergency. REPPIR states specifically that ‘The off-site emergency plan shall be prepared before the operator carries out work with ionising radiation’.
Last Energy has a uniquely worrying proposal. They intend to replace each of the four 20MW nuclear reactors after six years of generation as the fuel becomes spent but will retain the redundant contaminated reactors with the spent, highly radioactive fuel on site. This cycle will be repeated throughout the operational life of the plant, meaning that after seven cycles as operations end around 2070, there will be twenty-eight non-operational reactors, with all the accumulated spent waste, on site. Campaigners are concerned that this plan presents potential additional health and security risks to the public.
The NFLAs have previously criticised UK emergency planning requirements for nuclear sites as inadequate, being non-compliant with the minimal recommendations of the International Atomic Energy Agency[i]. However, even a typical emergency plan covering a UK nuclear plant if applied to the Llynfi site would extend out to four local schools – Ysgol Gyfun Gymraeg Llangynwyd, Llangynwyd Primary School, Ysgol Calon y Cymoedd, and Bettws Primary School. As children are particularly vulnerable to the effects of radiation, the NFLAs completely support the aspirations of No Nuclear Llynfi for special measures to be taken to protect the pupils.
Ends://..For more information please email NFLA Secretary Richard Outram at richard.outram@manchester.gov.uk
The letter sent to Councillors at Bridgend County Borough Council reads:
Dear Councillors Spanswick and Davies,
We are writing to you in connection with Last Energy’s proposed installation of nuclear reactors on the old Llynfi power station site near Maesteg; in particular, we would like to draw your attention to the importance of emergency planning in connection with any such development. This is something which will be of vital interest to the population of the area.
Bridgend County Borough Council has responsibility for emergency planning, with elected members and officers sharing the joint responsibility for safeguarding the health and well-being of the borough’s residents, and which contributes to the safety of the region as a constituent member of the South Wales Local Resilience Forum.
The Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR) place a duty on local authorities, within which there is a regulated nuclear establishment, to protect the public in the event of a radiation emergency, including having emergency plans in place and providing prior information to people who live, or work, in the area surrounding the site who may be affected by a radiation emergency.
Please note in particular that: “The off-site emergency plan shall be prepared before the operator carries out work with ionising radiation to which the assessment made in accordance with regulation 4(1) applies” REPPIR 9 (9). Last Energy is proposing to start operations in 2027.
Last Energy say they plan to have four 20MW nuclear reactors generating electricity, with each reactor being replaced by a new reactor after operating for 6 years. The “used” reactors, with their “spent” (and highly radioactive) nuclear fuel, will be stored on site until decommissioning starts (currently proposed to start 50 years after generation starts). So, after 6 years, as well as the four reactors generating electricity, there will be four non-generating 20MW reactors containing “spent” nuclear fuel in storage on site; by the time electricity generation ceases, there will be twenty-eight non-generating reactors containing “spent” nuclear fuel stored on site waiting to be decommissioned. By way of comparison, Trawsfynydd was a 470MW nuclear power station, so Last Energy’s plans would result in the Llynfi site having a larger megawattage (560MW) of nuclear reactors being stored on site waiting to be decommissioned than Trawsfynydd.
Whilst there is (at present) no central government guidance on emergency planning for Small Modular nuclear Reactors, nor any other site similar to Last Energy’s proposals for Llynfi, it may be useful to compare the site to Devonport, where 13 nuclear powered submarines, each with a 15MW or larger non-generating nuclear reactor are in the process of having their “spent” nuclear fuel removed prior to being decommissioned; in total close to 200MW. The Devonport Emergency Plan is here https://www.plymouth.gov.uk/devonport-offsite-emergency-plan
The Devonport emergency plan has a detailed emergency planning zone (DEPZ) around the Devonport Site, which extends to a minimum distance of 1.5km from the submarine berths, and an outer planning zone (OPZ) which extends to a distance of 5km from the Devonport site.
Similar emergency planning zones centred on the Llynfi site would include four local authority schools – Ysgol Gyfun Gymraeg Llangynwyd, Llangynwyd Primary School, Ysgol Calon y Cymoedd, and Bettws Primary School. As children are more vulnerable to the effects of radiation, as at Devonport, it would seem prudent that each of these schools should have a permanent radiation detection and alarm system, with stocks of Stable Iodine Tablets for pupils and staff, and procedures in place to evacuate the pupils and staff to a point of safety away from Last Energy’s proposed site (bearing in mind that the A4063 and other roads may be closed due to the presence of radioactivity). The school staff would need adequate training to administer iodine tablets to the pupils and to supervise the evacuation of the schools, and the parents and pupils would need to be informed so that consent forms for iodine tablets could be completed in advance.
The Wepa factory [a paper mill], very close to the Llynfi site, would also need similar measures, with responsibility for these measures shared with Wepa.
The creation of these emergency plans, the purchase of radiation monitoring and alarm systems, the provision of Stable Iodine Tablets, the administration involved in consent forms for pupils, the production and distribution of information to local residents, workers, pupils and their families, is going to place a considerable burden upon Bridgend County Council, both financially and in terms of staff workload.
Has any preliminary work been done on the emergency planning for the possibility of this development?
We would urge you to:
- Begin discussions now with Last Energy, the emergency services, the UK and Ireland Nuclear Free Local Authorities (of which Bridgend Council is a long-standing member) and other relevant organisations on emergency planning issues,
- Raise this issue within the South Wales Local Resilience Forum, and
- Seek a commitment from Last Energy to pay in full the costs associated with any emergency planning provision. It would seem manifestly unfair for Borough Council taxpayers to have to pay for emergency plans for Last Energy’s reactors, in the event of them being built, given that Last Energy shall be selling electricity for profit.
Clearly Bridgend County Borough Council needs to consider the implications that such emergency planning would place upon the council when forming its response to Last Energy’s proposals.
Yours sincerely,
Brian Jones on behalf of No Nuclear Llynfi
Richard Outram on behalf of the UK and Ireland Nuclear Free Local Authorities
[i] https://www.nuclearpolicy.info/news/bring-radiation-regulations-up-to-international-standards-say-nflas/
