Representation by EDF (NNB Generation Co Ltd) (EDF (NNB Generation Co Ltd))
- Date submitted
- 27 January 2020
- Submitted by
- Other statutory consultees
Dear Sirs DEVELOPMENT CONSENT ORDER (DCO), SIZEWELL East Anglia Two (EA2) and East Anglia One North (EA1N) Proposals Thank you very much for the opportunity to comment on the DCO for the East Anglia Two (EA2) and East Anglia One North (EA1N) projects. NNB Generation Company (SZC) Limited (SZC Co.) is in the advanced stages of preparing an application for development consent for a new nuclear power station at Sizewell, Sizewell C. Sizewell C will be located in the vicinity of the EA2 and EA1N proposals and as such SZC Co. has an interest in the proposals for both projects. This letter forms part of a comprehensive response from EDF. This letter covers the response to the submitted DCO applications for and on behalf of SZC Co. A separate letter covers the response on behalf of Nuclear Generation Limited (NGL) who are owner and operator of Sizewell B (SZB) nuclear power station. SZC Co. recognises the importance of off-shore wind and has no objection to the principle of the proposed wind farms and associated off-shore and on-shore infrastructure. However, as Sizewell C is proposed to be constructed in the vicinity of EA1N and EA2 and the operational power station would be located at Sizewell there are a number of important considerations, set out below, which need to be taken into account. Sizewell Gap Road and Sizewell C During the early years of construction of Sizewell C, Sizewell Gap Road and Lover’s Lane are intended to be used to transport workers and freight to and from the main development site. Once a separate access to the main development site is achieved the use of Sizewell Gap Road and Lover’s Lane will decrease, however they will both still be required to deliver the development. In the operational phase of Sizewell C, Sizewell Gap Road would be used as a secondary access road to the power station. This would be particularly important for emergency services and the mobilisation of assets from the Emergency Response Centre at the railhead in Leiston. Any development making use of the Sizewell Gap Road and/or Lover’s Lane would need to demonstrate that use of the roads does not compromise safety or the safe construction or operation of Sizewell C. Emergency Planning As operator of the Sizewell C site, SZC Co. will have responsibilities for emergency planning under the Nuclear Site Licence conditions attached to Sizewell C. SZC Co. will have to be sure that any development within the emergency planning zone can be accommodated within the off-site emergency plan. Part of the EA1 North and EA2 onshore proposals fall within the Sizewell Emergency Planning Zone, within which the needs of staff, visitors and residents must be addressed from an emergency planning point of view. SZC Co. and EDF have discussed this matter with SPR and is happy to continue to share the expertise of its emergency planning team. Operational Impact on Sizewell C Station a) SZC Co. will need, at all times, to be able to demonstrate on going compliance with the provisions of its Nuclear Site Licence for SZC. It is of crucial importance that SPR has regard to this requirement in their promotion of EA1 North and EA2 through the DCO process. We therefore continue to expect SPR to engage in discussions to ensure, where appropriate, there would be no adverse impact on the day-to-day running, security and nuclear safety of Sizewell C once it is operational. b) SZC Co. will continue to expect to have the opportunity to properly consider and comment on, when available, the technical detail of the SPR proposals, with particular reference to the onshore operational assets which are key to the nuclear safety case for Sizewell C. These assets include the access route to Sizewell C (Sizewell Gap Road) and adjacent utilities, the overhead 400kV lines and any aspects of the proposed development which could impact on these key assets, eg drainage and methods of work. Offshore Issues Although the proposed SPR export cables would pass to the east of the proposed Sizewell C offshore cooling water structures, the Order Limits of the proposed development will overlap with the Order Limits of the proposed Sizewell C development. Protective provisions should be included to protect Sizewell C and its associated development through the construction and operation of the new nuclear power station, particularly the cooling water infrastructure. Further, the proposed SPR export cables would cross the line of the Greater Gabbard and Galloper cables before turning to the west and making landfall to the north of Thorpeness. As a consequence, marine issues previously raised by EDF (with reference to Sizewell B and Sizewell C) in connection with the Galloper Wind Farm Project are also relevant here, with the added complexity that the Galloper cables are now in situ. The SPR cable corridor includes within it the majority of the Coraline Crag formation (calcareous sand rock outcrops). In relation to the construction and operation of Sizewell C, SZC Co. are particularly concerned that the protection afforded to the Sizewell shore by the Coraline Crag between Sizewell and Thorpeness should not be compromised. SPR have been made aware of the need to avoid potential disturbance to the Coraline Crag and associated seabed morphologies when considering actual cable routes, cable laying methodologies and subsequent maintenance requirements. Protective provisions should be included in the SPR DCO to ensure that, after SPR have carried out their detailed pre-construction surveys to determine the southern extent of the Coraline Crag formation, this is achieved in practice. Protective Provisions In the interests of nuclear safety and to ensure that the proposed developments do not affect the construction and operation of Sizewell C, SZC Co. will require provisions to be included within the DCOs for both wind farms. In Combination Effects Whilst it is understood that the start dates for EA1 North and EA2 are indicative, it is likely that construction of EA1N and EA2 would coincide with the construction phase of Sizewell C. SZC Co. acknowledges that the Environmental Statements submitted with both applications consider the in combination effects and SZC Co. has had a number of meetings with SPR to exchange environmental information and assist SPR in this regard. Co-operation with SZC Co. Given the nature of the proposed projects, we hope that SPR will continue to work closely with SZC Co. and other stakeholders on its more detailed proposals as it is vital that all the developments are coordinated through their respective planning and construction phases. In principle, SZC Co. will always be willing to discuss such issues, so long as the important considerations listed above are fully taken into account. Yours faithfully Richard Bull