Office for Nuclear Regulation,
Bootle, Merseyside. L20 7HS
10 June 2014
Dear Chief Inspector,
We have recently obtained a copy of the Office for Nuclear Regulation’s 31-page Project Assessment Report (PAR) issued 23rdApril 2014,which is entitled ‘Determination of Sizewell Radiation (Emergency Preparedness and Public Information) Regulations 2001 REPPIR – covering Sizewell A and B off-site emergency planning area.’
In this connection we note that on 1st April this year, the ONR announced that it is now a separate organisation, free from the HSE, and, so it says, is independent of government .
The upshot of PAR is to ‘increase’ the emergency planning area around Sizewell from its previous 2.4Km to 2Km to 3Km, depending upon the inhabitants’ affected post codes …. A post code lottery.
This pathetic ‘increase’ is the result of REPPIR requirements to observe ‘a reasonably foreseeable radiation emergency’ coupled with technical assessments by the operators of Sizewell A and B – technical reports that say limits around A (425m) and B (234m) should be used as the foundation of defining the extent of the need for local off-site emergency planning under REPPIR (Regulation 9)
It is interesting to note that these limits are based on ?-redacted in PAR why? And what is the science and reasoning behind the chosen limits?
These technical assessments were accepted by the ONR at a recent private, limited, meeting locally with Sizewell A and Sizewell B, when even the Sizewell Stakeholder Group were denied attendance – even as observers ….
So much for ONR’s much vaunted transparency ….
It is obvious from a close reading of the REPPIR regulations that they are totally inadequate to deal with a real accident at Sizewell, and the ONR should not use them as a cover for doing virtually nothing to protect the local populace, (if that is possible). Why did you?
Rather, the ONR should have taken cognisance of the International Atomic Energy Agency’s guidance which is based on (Page of 22 PAR). to consideration of extreme accidents’, c.f Chernobyl, Fukushima. It is obvious that the ONR (with, no doubt, the backing of the government) has completely ignored the reality of an extreme accident at Sizewell because, (post Fukushima), to so do, would require an emergency plan reaching out to at least 20km – an impossible area to implement population evacuation in the event and in the short time vitally necessary?…..
We think it is vital that the ONR revisit their revised proposals and base them on IAEA’s accidents. Will you?