I thank the Vice Chairman. My submission centres on Article 37 which is part of the requirement that the UK Government had to achieve compliance with the EURATOM Treaty. My concerns centre on several aspects of that document where it attempts to provide an analysis of the surrounding climatology for Hinkley but also of the possible trajectories that might be followed by planned or unplanned releases of radioactivity from the station.
I want to focus on three aspects which give me some cause for concern regarding transboundary potential for this development. The first is the basis on which the characterisation of climatology is provided in the document. The committee has already received a presentation from me in which I have outlined some concerns about the way in which, for example, three years of wind data is allegedly used to provide the input for characterising the wind environment around the station. This is contrary to accepted climatological practice where normally 30 years of data are used as a fingerprint for climatic aspects in any location. It is rather dangerous to provide and draw conclusions based on a very short-term climatic record.
The second concern I have is in respect of how it has ignored the possibility of ongoing sea level rise in the vicinity of Hinkley. There are tables showing estimates of one in 10,000 year occurrences of high water and low water which, of course, is a concern for the cooling system. The statistical validity of extrapolating from a short-term record to calculate the once in a 10,000 year event is something which is not sound and we can be very critical of any conclusions based on that in terms of their robustness. In particular, it would appear that there is no consideration of the ongoing rise in sea level which is occurring and which is going to occur at this location over the next century. Radioactive waste is intended to be stored on-site for up to a century in this location. The propensity for sea level rise to cause an additional hazard, an additional problem, is vital to consider. In fact, the differences between the once in a year event and the once in allegedly 10,000 year event which is provided by Article 37 is only 1.3 m, and that is really something we cannot stand over in terms of a projected sea level rise alone of over 1 m by the end of this century. We know that sea level will continue to rise by up to 3 m over the next few centuries when there will still be, presumably, a radioactive risk at this location.
The third point is quite important because there is, therefore, a risk of flooding at this location. That risk was known to the UK Government when it produced Article 37 for the EURATOM submission. In fact, it was through a freedom of information request from a national newspaper that the flood risk was identified. The committee will note from the table I provided that Hinkley is designated as having a high flood risk by 2080 by the UK Government itself. That, therefore, can only be avoided by the construction of a floodwalls which would be the last line of defence in the event of flooding and a measure we would question as to whether it is something we should rely on for such a serious location as this.
The third aspect is the extent to which storm surges and possible tsunami events may occur at this location.
The committee may be aware that this is the Bristol Channel, which has a very macrotidal environment where the difference between high and low tide is very considerable - it is about 13 m. The highest astronomical tide is approximately 7 m above sea level as we stand. Add to that an additional risk from a storm surge, and from a possible tsunami, and one has the potential for increased flood hazard being experienced at this location.
There is, incidentally, some record of seismic activity in the Bristol Channel. The highest earthquake for the past ten years - a 4.4 magnitude - was observed as recently as February of this year in south Wales. We know there are historical records of a tsunami which is believed to have been induced by seismic activity in 1607, which was the worst flood event ever experienced in the UK, where 500 km of coast was inundated and 500 deaths occurred. These factors are not mentioned in the Article 37 submission.
My particular area of expertise lies in the atmospheric side of things and I looked quite closely at the atmospheric models that were used to simulate the ongoing dispersal of radioactivity and also in the event of an accident involving the catastrophic release of radioactivity. Here I found that the models being used are very suspect indeed. They are based on models that were developed in the late 1970s and the author of the model used raised a number of caveats about using his model which are highly relevant to this location. He questioned the validity of the model in a coastal location, the validity of the model whereby nearby buildings might impact on dispersion and the model being used in non-uniform terrain and where there might be upwind topography where the dispersion might be affected. In this case, the Mendip Hills are very close by.
My main issue is that the UK Met Office since that time, in fact even before the Article 37 submission was made, has developed its own dispersion model, a model called Nuclear Accident ModEl, NAME, specifically for the dispersion of nuclear hazardous material. This was operational from 1986 and yet the Article 37 simulations are all based on a model which is much older, and very simplistic in comparison to what is available today. There is no prescribed model for use in such circumstances in the European context, but there are recommended models, for example, in the United States Environmental Protection Agency, USEPA, which were available and which have not been mentioned in this proposal at all. One in particular, CALPUFF, is, by and large, the standard model used for such circumstances.
To put it in a nutshell, the criteria here are rather like forecasting the weather based on 1970s technology, which is essentially what is being done here. The more recent models, which make a much more sophisticated use of conditions along the trajectory, have simply been ignored. That is quite important because here we are looking at the possibility of effluent travelling across the St. George's Channel, over a cold sea in summer time, which stabilises emissions and which limits the dispersion of effluent quite successfully under certain stable easterly conditions. That would be the main concern I have.
To reiterate, the reason the model issue is so important is that in the aftermath of Chernobyl, many authorities discarded that traditional old approach to Gaussian or conical dispersion of effluent because it simply did not work. If one looks at the way Chernobyl radiation spread across Europe, such a simplistic model was completely useless in that situation. A much more sophisticated and modern approach needed to be taken and I really regret that that was not attempted in this particular instance.
I mention flooding because we now know that Fukishima has emitted about five to eight times as much radiation as Chernobyl, so it is a problem that was caused essentially by flooding in that vicinity.
In Ireland, we have only recently - in the past six years or so - been able to remove curbs on upland sheep farms in the North of Ireland, for example.
We are looking at long-term effects here, as Ms Uí Bhroin was saying. For that reason we really need a robust analysis and this Article 37 is a tokenistic effort which does not really provide the data. The Irish Government has been shortchanged by this essentially. I would certainly not like to risk accepting this as a robust simulation of what kind of things might happen in the event of an unforeseen accident occurring.
To reiterate what Ms Uí Bhroin said, the whole Article 37 did not consider Ireland. It considered the Channel Islands and France but it did not consider Ireland as a possible receptor for an accident of this nature, which is a serious omission and one which the committee should be concerned about.
