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 13 August 2018
From Dr David Lowry

Representation

My primary concerns with the proposed Wylfa Newydd nuclear plant arise from the additional security problems any such reactor will create in the UK, both in terms of vulnerability of the reactor complex to malevolent intrusion and/or external attack; and the potential for deliberate misuse of the fissile ( ie explosive plutonium) material created necessarily in the spent irradiated nuclear fuel by operating the reactor.
I intend to demonstrate that plutonium created in the current Wylfa nuclear plant has been historically managed under nuclear “safeguards” arrangements that permit it to be diverted to military misuse by ministerial fiat; and that the new domestic “safeguards” system being developed by the Office for Nuclear Regulation for the post-Brexit environment plans to allow such diversion to be permitted.
I will also set out several plausible and realistic scenarios under which the security of Wylfa Newydd could be successfully breached or disruptively sabotaged – by, inter alia, an aerial armada of advanced drones, by high tech penetrator weapons from off or on shore, by malevolent sleeper infiltrators etc- and outline to consequences for Anglesey and the wide north West of such a failure of security provisions.
None of these issues is addressed in the Horizon application document “Wylfa Newydd Project 5.1 Main Consultation Report.”

I note that this document states:

“Horizon has also taken care to consult on the whole project… This has allowed consultees to have a rounded picture of the impacts of the Wylfa Newydd Project from the outset.”

It also states elsewhere in the same document:

“The NPS EN6 (para 2.7) advises decision makers to avoid unnecessary
duplication and to ensure that planning and regulatory expertise are focussed
on the most appropriate areas. While most consents that will allow the
development of Wylfa Newydd to proceed are included in the application for a
DCO, consents and permits related to nuclear safety, security, protection of
people and the transport of nuclear material are regulated separately.”
I regard it as inappropriate to hive-off such concerns to bodies outside the infrastructure planning process, which permits public input into decision-making. It is unclear to me how any consultation by outside bodies might progress. The PI must address this.

I retain additional concerns over the project proposal, including it is premised upon a National Nuclear policy Statement which is both questionable in its current form ( the Government admits as much in holding consultation on proposals to update it), and manifestly out of date; with the proposed creation of radioactive waste when there is as yet no demonstrated long term method for its management; and the fact the UK Government is planning to find new ways to subsidise Wylfa Newydd, which would have the inevitable consequence of less investment of public taxpayers’ money into sustainable, clean renewable energy technologies and energy efficiency. But I shall leave the detailed argument over these matters to others.

Dr David Lowry
senior international research fellow
Institute for Resource