Observations on
Wylfa Newydd DCO PAC 3, Exhibition Events and Consultation Bus, May/June 2017
1. Potentially material flaws in the Public Notice published 19.05.2017
1.1.1 Horizon Nuclear Power and Hitachi Limited published a Public Notice in The Guardian newspaper on 19th May 2017, regarding their Proposed Application for a Development Consent Order (DCO) for Wylfa Newydd. The Notice stated, in numbered paragraph 3, an intention to submit a DCO Application for a new nuclear power station on Anglesey in the third quarter of 2017. Hitachi intend to install two newly modified UK Advanced Boiling Water Reactor (UK ABWR) design nuclear reactors at Wylfa. It would be the first ever deployment of this reactor design in the UK.
1.1.2 Potentially material flaws may exist in that Public Notice. Six notable flaws are explored below, under numbered subsections and relevant headings.
1.2 Interim storage buildings for radioactive waste and spent fuel
1.2.1 In the first instance, at numbered paragraph 4(a)(ii)(A) of the Public Notice, Horizon-Hitachi have indiscriminately lumped together materially discrete elements of the buildings (purposed with distinctly differing functions) proposed for the storage of nuclear waste at the Wylfa Newydd site.
a. Indecipherable amalgamation of discrete elements in a Public Notice has the effect of obscuring matters of significant public interest, which should otherwise be readily identifiable by the wider public. The Applicants propose the construction of essentially two different types of nuclear waste storage buildings, for distinctly different purposes. In the interest of convenience, the following extracts summarise chapter B14 in PAC 2 Preliminary Environmental Information (dated August 2016).
(i) A primary radioactive waste building, located in or adjacent to the main reactor island, which would be designed to house:
? buffer storage tanks, plus packaging facility for wet-solid Intermediate Level Waste (ILW: Table B14.3);
? spent fuel pool for dry solid High Level Waste (HLW: Table B14.4), and for the spent fuel assemblies periodically discharged from each reactor (Table B14.5);
? facility for packaging HLW into stainless steel canisters, after cooling for 10 years (Table B14.4); and,
? facility for packaging spent fuel assemblies into spent fuel casks, after cooling for 10 years (Table B14.5).
The radioactive waste building would be constructed at the same time as the main reactor island. The radioactive waste building would be emptied following permanent reactor shutdown at the end of planned 60-year reactor operating life span, and decommissioned alongside the twin reactors within 20 years of end of electricity generation by Wylfa Newydd (paragraph B14.70).
(ii) Separately, possibly two interim waste storage buildings, located elsewhere on the Wylfa Newydd site, which would be designed to house:
? ILW storage facility, to receive and hold packaged ILW (Table B14.3);
? HLW decay storage facility, to receive and hold HLW steel canisters (Table B14.4); and,
? spent fuel storage facility, to receive and hold spent fuel casks (Table B14.5).
The construction of interim waste storage buildings would commence after the reactors have started operating, and are expected to become available for use within 5 to 10 years of the twin UK ABWRs starting up at Wylfa Newydd. The interim waste storage buildings would be designed accommodate the entire lifetime inventories of packaged radioactive wastes. The buildings would be designed to be safely operated and maintained for appropriate management of the accumulated radioactive waste and spent fuel inventories for an interim period, while awaiting final removal to a geological disposal facility elsewhere (as and when available). The Applicants envisage interim storage for a further period of up to 140 years, following the end of electricity generation by Wylfa Newydd, until a geological disposal facility becomes available and ready to accept the accumulated radioactive waste inventories. The interim waste storage buildings would be decommissioned only when eventually emptied, in around two centuries’ time.
b. Plainly, on the face of it, lack of clarity on materially discrete significant development elements in a Public Notice risks confusing and misleading the wider public. Clarity and transparency should be paramount in a Public Notice, not something deducible only by the reasonably informed or upon reading through highly complex supporting documents.
c. Considering the circumstance and context in this instance, confusing or misleading information is arguably capable of rendering the Public Notice flawed.
1.2.2 In the second instance, there arises a question over inclusion of interim waste storage facilities in the proposed DCO Application.
a. Given the obvious direct and intimate connection with the main reactor island NSIP, it is plain why the radioactive waste building (paragraph 1.2.1(a)(i) hereof, referring) could be treated as part of a generating station NSIP, and could therefore be included in the proposed DCO Application.
b. However, Horizon-Hitachi would not appear to have identified (in the supporting documents) direct instruction in Government policy, or express requirement under relevant statutory measure, commanding the inclusion of interim waste storage buildings/facilities (paragraph 1.2.1(a)(ii) hereof, referring) in a DCO Application for a nationally significant electricity generating project, the location of facilities in question not withstanding (whether on- or off-site).
1.3 Marine works (cooling water system, marine off-loading facility and breakwater structures)
Numbered paragraph 4(a)(ii)(C) in the Public Notice states categorically that Horizon-Hitachi intend to seek consents for marine works under a DCO. The assertion is repeated at paragraph 1.6.5 in the PAC 3 Main Consultation Document (dated May 2017).
a. On the face of it, the Notice risks misleading the public as to appropriate consents jurisdiction for the marine components. All proposed marine works, including a marine off-loading facility (MOLF), would be situated in tidal waters, demarcated on the landward side by the Mean High Water Spring Tides.
b. Moreover, it is confounding to discover the Applicants’ submission on page 14 of the Overview Document in contradiction of the Public Notice. Namely, these works require separate marine licences from Natural Resources Wales.
c. Apparent failure to distinguish appropriate jurisdictions gives rise to manifest confusion in the public mind and, as such, is capable of rendering the Public Notice flawed.
1.4 Environmental Statement
In numbered paragraph 7, the Public Notice admits environmental impact assessments have still not been completed.
a. Consequently, even at PAC Stage 3, the public are left uninformed as to the full implication of all significant environmental effects, not withstanding Notice paragraph 8 regarding the Preliminary Environmental Information (published during PAC Stage 2).
b. It flouts the fairness principle for it to be acceptable for Horizon-Hitachi to magic final environmental impact assessment reports at the last minute (say, at the time of its formal DCO Application). And, it affronts legitimate public interest expectation. These assessments ought to be fully available amply in advance of a DCO Application. Otherwise, the public are deliberately denied sufficiency of time for proper consideration of complex assessments, at the same time as labouring under the constraints of DCO Examination time limits. While doubtless to the advantage of the Applicants, a drip-drip tactic comprises manifest disservice to the public.
c. In essence, paragraph 7 constitutes little more than a promissory note. It fails to confirm contemporary availability of the environmental statement. At the very least, such failure renders the Public Notice premature. And, may be said capable of tainting the Notice as potentially flawed.
1.5 Area of Outstanding Natural Beauty (AONB) and the designated North Anglesey Heritage Coast: the shoreline at Porth-y-pistyll
Horizon-Hitachi remain conspicuously silent in the Public Notice on direct physical damage, under the proposed DCO Application, to the shoreline sections of the AONB and the associated Heritage Coast designation at Porth-y-pistyll.
a. Given public sensitivity on such impacts, it is puzzling Horizon-Hitachi could not countenance bringing this expressly to public attention in their Public Notice.
b. By virtue of salient omission, the Public Notice may be rendered materially flawed.
1.6 Site of Special Scientific Interest (SSSI): Tre’r Gof
Horizon-Hitachi have also omitted from the Public Notice reference to risk of long term deterioration, and even complete loss, of the Tre’r Gof SSSI as a result of residual impact of the proposed DCO Application.
a. Information on this potential outcome lies buried in a pithy sentence on page 107 of the Stage 3 Main Consultation Document.
b. Such explicit omission of potentially severe direct risk to the integrity and sustainability of a protected site may be capable of rendering the Public Notice materially flawed.
2. Other deficiency
2.1 Stage 3 Exhibition Events: location, duration and content
2.1.1 There were no events arranged in towns and villages beyond North West Wales, despite numerous invocations of North Wales as a whole in the Overview Document (pages 7, 20, 21, 35, 36 and 39, referring). Horizon-Hitachi restricted all six venues to Anglesey (albeit, appearing twice in Cemaes). Even so, on the day of each event, additional publicity sign posts within reasonable vicinity of the venue were nowhere to be seen, to catch the public’s attention.
2.1.2 With the seven one off events lasting six hours each, is it any wonder Horizon-Hitachi’s enthusiasm for venturing into wide public spaces should seemingly resemble a fly-by-night sales pitch? The Applicants failed yet again to arrange prolonged displays of exhibition panels in prominent public places, in all the principal towns and villages across North Wales, presenting the full scope of information highlighted at paragraph 1.4 in the previous Comment (submitted in response to PAC 2 Community Exhibition Events, dated 13.10.2016).
Having attended one PAC 3 Exhibition Event, Horizon-Hitachi’s Events further warrant inclusion of the following additional display boards, presenting clear information on:
• radioactive waste production, storage packages, storage structures, on-site storage duration, storage risk, and the history of Wales/UK search for a final geological disposal facility;
• major nuclear incident emergency preparedness measures; seasonal wind directions and speeds; and, marine currents around Anglesey and the North Wales coast;
• truncation of an Area of Outstanding Natural Beauty and the North Anglesey Heritage Coast at Porth-y-pistyll; and,
• the precarious status of the Tre’r Gof Site of Special Scientific Interest, at Wylfa Head on Anglesey.
2.1.3 Anyone visiting the PAC 3 Exhibition Events would have witnessed excessively narrow selective information on large display boards, table maps and schematic landscape graphics on proposed alterations to roadways, the proposed workforce campus, site layout, and the like; as well as a 3-D bird’s eye view flight animation over the A5025 alterations, the proposed Nuclear Power Station layout, and the Wylfa Newydd Development Site.
Horizon-Hitachi did not display any large information boards for the visiting public, showing:
• the sections of the Area of Outstanding Natural Beauty and the North Anglesey Heritage Coast impacted directly by the proposed marine off-loading facility at Porth-y-pistyll;
• modelled degradation states of the Tre’r Gof Site of Special Scientific Interest at Wylfa Head;
• site/area seismology, incidence history, event projections, and outcomes/implications;
• historical extreme weather events at the site, and outcomes;
• extreme weather event projections modelled for the site between the years 2025 and 2225 (based on a 60-year reactor life span, followed by a 140-year on-site radioactive waste storage period), and implications;
• meteorological and marine currents charts modelling footprints of radiation plumes in the event of serious breach in reactor containment, or serious incident in the interim storage facilities for the accumulated inventories of high level radioactive waste and spent fuel discharged from the twin reactors;
• emergency preparedness and public protection measures in the event of serious nuclear incident at Wylfa Newydd;
• indicative site appearance at various stages of reactor decommissioning;
• post construction photomontages of Porth-y-pistyll viewed from the sea; the site viewed from the Porth-y-pistyll coastal footpath; views from Tre’r Gof site; and the like;
• the identity of lead investor and status of any co-investors in the Wylfa Newydd project; the primary reason for reactor choice; the level of guaranteed capital finance currently in hand, and the amount of current shortfall; the status of proposals and certainty of timescales for bridging the shortfall;
• the identity of lead operator and any operating partner(s); the status of arrangements for any proposed operating consortium; and,
• Horizon’s business experience to date in reliably, safely and successfully managing and running any trade or enterprise (small or large), anywhere.
2.2 Stage 3 Consultation Bus and locations
2.2.1 Horizon-Hitachi have resorted to an ice-cream van sized “Consultation” Bus, featuring a customer service style counter on one side of the van, for face time with visitors. The Bus schedule totalled six locations in Anglesey, stopping for three hours each time, save for a five hour stop in Menai Bridge (at the Anglesey Farmers’ Market). The Bus also put in a three-hour appearance each in Bangor (out of town centre Tesco Extra Car Park), Caernarfon (town centre Castle Square) and the Conwy Quay.
a. Other than a novel Consultation stunt, does the duration and number of stops echo anything more than another fly-by-night sales pitch?
b. In any case, the nature and extent of information omission, highlighted in paragraph 2.1.3 hereof, is rendered even more acute in an ice-cream van sized Bus.
2.3 Stage 3 Consultation Overview Document (undated)
2.3.1 Horizon-Hitachi have distributed the Overview Document to public libraries in Anglesey, Conwy and Gwynedd, as well as respective Council Offices in Llangefni, Conwy and Caernarfon, and the Anglesey Business Centre in Llangefni. It was also available at Exhibition Events and from the Consultation Bus. Yet this key document stands out as excessively selective in the information communicated to the public. It omits a number of issues of significance and wide public interest, concerning the Horizon-Hitachi proposal for a new nuclear power station at Wylfa, as illustrated below.
2.3.2 It is disingenuous of Horizon-Hitachi to capitalise selectively on a single waste product from electricity generation. On pages 1 and 7 of the Overview Document, the Applicants boast low carbon electricity generation while patently refusing to headline simultaneously a corollary: high nuclear waste electricity generation by Wylfa Newydd. Horizon-Hitachi appear welded to perpetuating a false comforting headline message: the Hitachi nuclear reactors are low carbon – perfect! No worries!
2.3.3 Not a single structure is identified in the schematic graphic spread across pages 1 and 2.
2.3.4 No depiction whatever of removal of sections of the shoreline AONB and the North Anglesey Heritage Coast in the following graphics:
• the indicative power station site layout, on page 9;
• the existing baseline, on page 42;
• completion of earthworks for unit 2, on page 43; and
• permanent landscape setting, on page 44.
2.3.5 No information is provided on where the pre-constructed modular components for the entire Wylfa Newydd build will be sourced, pre-assembled, or built from scratch (page 10).
2.3.6 No information provided on expected date of application for a marine licence for the MOLF (page 14), or the expected MOLF construction commencement date (page 27).
2.3.7 There is no mention whatever of erasure of the shoreline AONB and the associated North Anglesey Heritage Coast, in the section headlined “Marine Works” on page 14. No sea views either of Porth-y-pistyll, pre- and post- MOLF and other structures.
2.3.8 No indicative illustration (aerial and side elevations) of the decommissioned site after 2085, on page 16. This was curiously also missing from the 3-D animation video! The omission contrasts with a Site Campus image produced on page 24.
2.3.9 No schematic graphics illustrating the interior of proposed radioactive waste and spent fuel storage facilities, on page 16, complementing the reactor building graphic on page15.
2.3.10 No accompanying illustrations of the packaged ILW, HLW canisters and spent fuel casks, on page 15.
2.3.11 No disclosure on page 15 of explicit instruction from the Government, or express statutory measure, commanding Horizon-Hitachi to install interim nuclear waste storage facilities on-site in Anglesey, for the purpose of holding 60 years’ accumulated output of spent nuclear fuel, intermediate level waste and dry high level radioactive waste, for up to a further 140 years after the Wylfa Newydd nuclear power station permanently stops generating electricity.
2.3.12 No information disclosed on page 15 on all the alternatives to on-site interim storage of nuclear waste (up until the year 2225), examined by Horizon-Hitachi to any extent. Nor is there disclosure of reasons for rejecting all other specific options.
2.3.13 No explanation provided on signal inconsistency between the duration of the Wylfa Newydd site nuclear licence persisting up to the year 2225 (60-year reactor life span, followed by 140-year on-site nuclear waste storage: pages 15-16), and an absolute assurance on page 2 of the Community Update Issue 19. Namely, that Horizon banks on leaving Anglesey by the year 2117: “We are proposing to be part of the community for around the next 100 years, …”
2.4 Stage 3 Main Consultation Document (dated May 2017)
2.4.1 Not in a position to comment. Lack the time commitments warranted for consideration.
3. Conclusions
3.1 An occurrence of potentially material multiple flaws in the Horizon-Hitachi Public Notice on their proposed DCO Application is one too many to be lightly dismissed. Individually arguable, collectively the flaws appear disquieting, the validity of the Public Notice notwithstanding.
3.2 Significant further apparent deficiency in documentation and relevant information arguably begs the acceptability of Horizon-Hitachi’s deliberate, and excessively, narrow consultation exercise. To what extent would a reasonably informed fair minded bystander expect the Infrastructure Planning Inspectorate to tolerate this state of affairs, at Stage 3?

See attached reply