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 10 August 2018
From Welsh Ambulance Services NHS Trust


1 Introduction

1.1 The Welsh Ambulance Service NHS Trust (WAST) provides:
• 999 blue light response for medical emergencies in Wales;
• NHS Direct Wales/111 service - telephone health advice and information service available 24 hours a day, every day;
• Non-Emergency Patient Transport Services (NEPTS)
• Special response, for example to terrorist/chemical/biological/radiological/ nuclear/otherwise hazardous incidents, by the Hazardous Ambulance Response Team (HART, based in South Wales with a limited UK mutual aid arrangement) or Special Operations Response Team (SORT) for casualty decontamination which is operated on a recall-to-duty regional basis

1.2 WAST notes that Horizon Nuclear Power (HNP) recognises that demand on ambulance services is already acute, with high levels of demand (circa. 45,000 999 calls nationally per month) and incident demand increasing at between 4% and 5% per annum.
• Red calls (life-threatening calls within 8 minutes) account for approx. 5% of WAST’s 999 incident demand.
• The majority of incidents are Amber - serious, but not immediately life threatening
• The remaining number are Green - lower acuity.

1.3 WAST has no capacity to meet additional demand arising from the construction, operation or decommissioning of the proposed nuclear power station and this statement seeks to register WAST as in interested party in the totality of the development. Whilst WAST supports any development which improves the health, general resilience infrastructure and socio-economic prosperity of Anglesey, it is critical that HNP provides for appropriate mitigation through the provision of all necessary healthcare facilities and section 106 financial contributions to WAST; this is necessary to mitigate the impact of the proposals so that the operational needs and obligations of WAST are fully satisfied enabling it to carry out its functions without extra cost to WAST.

1.4 In addition, it is essential that WAST, alongside the wider emergency services community, is able to access resources to procure services which support the critical operational infrastructure where site developments warrant it. If these issues are not adequately addressed then WAST would be concerned that, not only would it be unable to provide an appropriate service to the proposed facility, but it would also be possible that the quality of service that it currently offers to the existing population of Anglesey would be impacted.

2 Further information required

2.1 WAST has undertaken initial reviews of the DCO documentation and requires further time during the DCO process to review the documents in detail; WAST will need to seek resource from HNP to complete this work. From an initial review of the documentation, WAST has identified three significant risks (in line with the response to PAC2 and PAC3) under which all concerns and questions are categorised, encompassing the construction, operation and decommissioning phases.

2.2 Increase in life threatening or life changing medical emergency/ies created by activities associated with the construction of the main power station site and associated developments.

2.2.1 WAST would expect to receive further confirmation of:

• How injuries on site will be managed, further specifically how casualties requiring hospital treatment will be removed from site.
• The arrangements on site to deal with hazardous environments or difficult to reach locations

2.2.2 WAST welcomes confirmation that the site campus will have a paramedic, an ambulance and on-site healthcare facilities. WAST requires assurance on the capability and availability of these arrangements and detailed discussions on arrangements for responding to hazardous areas, or responses that require multiple paramedics, and handover/site access protocols. Further, the management of hazardous environments does not appear to be covered in the documentation and is a particular area of concern on which WAST would want assurance from HNP to ensure appropriate mitigations are in place.

• The medical arrangements present on site, including operational hours and clinical capability.

2.2.3 WAST notes the proposed provision of on-site campus medical facilities, but further detailed information is required to ensure that this mitigation is sufficient and does not lead to increased demand for WAST.

• Details of HNP major incident plans, including management of multiple casualties
• Details of HNP plans for – fire, pandemic, disorder or protest at site and temporary worker accommodation, and Marine Offloading Facility.
• Details of HNP plans to manage life threatening or life changing emergencies across all associated development sites.

2.2.4 These do not appear to be addressed in our initial review of the documentation.

2.3 An increase in the population base brought about by the provision of temporary workers introducing a higher demand for ambulance services, resulting in needing to meet the physical and mental health needs of workers.

2.3.1 WAST would expect to receive further confirmation of:

• How temporary residents will receive primary and community care, through to complex secondary care (including referrals into secondary care pathways from Healthcare Professionals)
• HNP arrangements for entertaining staff during time off
• HNP policies for managing drug/alcohol misuse issues
• How HNP intends to meet physical and mental health needs of workers, including chronic conditions management
• How HNP intends to manage antisocial behaviour and safeguarding issues
HNP intends to manage the health needs of the workforce living in the wider community
• Mitigation in support of the wider supply chain throughout the region to manage both the effects of direct and indirect workforce on ambulance services
• Impacts of temporary worker families moving to the area

2.3.2 Generally, WAST is supportive of single integrated accommodation sites as they make the provision of medical services and responding easier.

2.3.3 WAST notes that the Health Impact Assessment identifies large magnitude and significant major adverse impacts on medical and healthcare services’ demand and NHS capacity. The HIA identifies mitigation through “appropriate healthcare provision or contribution”. WAST must be involved in the discussions as the NHS Direct Wales service is a key part of the primary care sector, and unmet demand in the primary care sector can impact on the ambulance care pathway.

2.4 Impacts on domestic or routine ambulance services brought about by associated construction activity and developments such as improvements on the highways hindering response times to non-HNP activity; increased frequency and severity of incidents such as road traffic accidents brought about by the increased volume of vehicles their type and size.

2.4.1 WAST would expect to receive further confirmation of:

• Information to support an assessment of how ambulance travel and job cycle will be affected across the immediate and regional areas
• Information to support an assessment of impacts on WAST provision of core 999 services on Anglesey
• Arrangements for translation for non-English speaking staff
• Mitigation to avoid delays to both emergency and non-emergency patient transport across the region, given increased traffic volumes

2.4.2 WAST notes the various proposed highway improvements which, it is stated, should improve access, once completed. WAST will want to see the results of detailed modelling of the impact of proposed highway changes and average road speeds on its ability to respond. As part of this modelling work, WAST will supply up to date demand and performance data.

2.4.3 Other considerations include potential staffing impacts on WAST, wider socio-economic effects on both staff and patients, and partnership working across the breadth of organisations across North Wales. The cumulative effect of this development, alongside all other developments within the area (notably National Grid, Bluestone and other energy projects on both Isle of Anglesey and the mainland) will have a significant impact on WAST. The impact of noise, air pollution and other environmental impacts on the wider island population need to be better understood, and may impact on demand for ambulance services in the future.

2.5 Further information on the effects of these issues will, therefore, also be required in order to assess the full impact on the totality of services provided by WAST.

3 Conclusion

3.1 WAST is a statutory body required by law to manage ambulance and associated transport services. Any factors which are likely to increase its operational obligations need to be fully addressed and financially resourced. All direct and non-direct impacts of the HNP proposals need to be assessed. Further information is required about the effect on WAST's operations and financial and other commitments need to be put in place to ensure that WAST can satisfactorily meet its legal obligations and expectations otherwise imposed.

3.2 As a result, WAST has a duty to ensure it makes all necessary representations in the planning process. WAST reserves the right to expand on or add to any points made in this representation by way of written evidence to the inquiry.