Wylfa Newydd Nuclear Power Station

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Wylfa Newydd Nuclear Power Station

Received 22 July 2018
From Michael Cominetti, BA,FCIWEM, C.WEM, CEnv.

Representation

I was an Environmental Regulator, Senior Environmental Consultant and Member of the Devon and Severn Inshore Fisheries and Conservation Authority (Not writing on their behalf) with a passion for environmental conservation and in particular, the banning of the use of Direct Cooling for Coastal and Estuarine Nuclear and Conventional Power Stations because of the severe problem of fish and other aquatic organisms Impinged and Entraped on filter screens etc. Therefore my objection is soley related to the Cooling System proposed for Wylfa Newydd Nuclear Power Station. The main points are:-
* Wylfa nuclear Power station will abstract some 25 BILLION Gallons Per DAY of Seawater, and despite the planned mitigation measures will kill thousaqnds of fish, fish eggs and other aquatic organisms by Impingement and Entrainment on filterscreens and condersors.
* Whilst the Direct Cooling of Estuarine and Coastal Power Stations are considered 'Best Available Technique' by the Environment Agency (Natural Resources Wales) (Report -UK RD33 Cooling Water options for thr New Generation of Nuclear Power Stations) This report
indicates that- in Para 4.3 Choice of cooling Water Systems - 'Greater awareness of the environmental impact of direct CW system and designation of conservation areas could lead to more use of indirect cw systems for coastal locations' Examples of this include 1) Where the environmental impact of the intake and outfall of direct CW system is not acceptable. (not acceptable in my opinion because of fish Impingement and Entrapment) and 2) Where the sea can support a direct CW system for One reactor, but ther is a proposal to develop Two reactors
* The same report also says ''Quanties of fish impinged annually at coastal power stations range from a few tonne to tens or hundred of tonnes per year'' (From personal knowledge Hinkley Point B in Somerset impinges some 750 tonnes per year - 2-05 tonnes every day of dead and dying fish and other aquatic organisms)
* The Jacobs report (Fish survey report 60P08007/AQE/REP/003) indicates ''That total annual catches at the Existing Power Station (now closed) were considered tp be low when compared to other coastal stations, this provides further support to the conclusion that fish abundances within the vicinityof the Wylfa Newydd Development area are low compared to fish populations elsewhere in the Irish Sea (eg Eastern Irish Sea). Whilst I cannot argue with this, I have comment that this indicates to me that Impingement and Entrapment at Wylfa MUST BE AVOIDED in order to PRESERVE fish stocks - after all the fish impinged, especially juveniles and eggs, represent Future stocks and these are subject to natural predation as well.
* All of this can be avoided by the use of an Indirect Cooling system such as proposed by Nuclear Horizon at their Oldbury on Severn Plant - that is Hybrid Low Profile Cooling Towers. I attach a Photo of similar towers at Chinnon B in France (these are NOT fitted with plume abatement). Seawater can be taken through the Existing Magnox system to fill the Indirect Cooling System and then only 'make up' water will be required.
*May I respectfully point out that the UK Government is currently being taken to Court by the European Commission for breaches of Europen Directives including Integrated Pollution Prevention and Control in respect of the Direct Cooling System agreed by the Environment Agency at the Pembroke (South Wales) Combined Cycle Gas Turbine station. Whilst I am aware that this staion discharges to a different water body, i am concerned that the effect of Wylfa could bring about similar action (subject to Bexit).
* The American Environment Protection Agency has agreed that Indirect Cooling is now 'Best Technology Available for coastal and estuarine power stations.
* Naturally I intend to make these points to Natural Resources Wales in response to their consultation on 'Operational Cooling Water Discharge-PAN-002427'
* Finally, I would ask that my submission is given urgent consideration and that Planning Permission is only given for an Indiect Cooling Water System. Naturally I can expand on this brief submissin as required. Thank you.
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