On June 8th Dr David Lambert, Managing Director of Fish Guidance Systems, and eminent fish biologist Dr Andy Turnpenny spoke alongside environmental experts to detail the reasons why an AFD system should be installed at Hinkley Point C. Their full statements are outlined below.
Statement From Dr David Lambert, Managing Director, Fish Guidance Systems
Good afternoon, and thank you for giving me an opportunity to talk today.
My name is Doctor David Lambert. I am an Environmental Scientist, a Chartered Water and Environmental Manager and the Managing Director of Fish Guidance Systems, a company that has been designing, manufacturing and installing fish deterrents around the world for over 27 years.
I would first like to say that the position I am putting forward today, that an AFD is required and should be installed at Hinkley Point C, is not just the position of a single commercial entity but as you have already heard, is also the position of numerous independent experts and organisations across the UK, including an advisory panel to the Welsh government.
I am aware I only have a few minutes to speak, and while I would like to go through many of the points raised by EDF in detail I trust we will be given the opportunity to do so at the appropriate time. At this stage I will simply concentrate on the facts of the case. EDF is proposing to remove the AFD for three unfounded reasons
- It is too difficult and dangerous to install
- It is too difficult and dangerous to maintain
- It is not required from a fisheries conservation point of view.
Dr Andy Turnpenny, FGS’s Fisheries Advisor will make a number of points relating to the fisheries issues, and I am aware you will be listening to a number of experts over the next two weeks who will debate the fisheries side of things in a lot more detail than we can cover now, but I do think it is necessary to emphasise a few points before I comment on the engineering and safety aspects that EDF has highlighted.
I think to start with it’s important to stress that the vast majority of fish can hear, and do respond to an AFD. Hearing is not limited to a few special species of fish and as a result, while an AFD can deflect 90% of the fragile hearing specialists, such as herring, sprat, and shad, it will also reduce the total number of fish entering a cooling water system by around 60% across all species. This therefore benefits the whole species assemblage, and in turn the internationally important populations of marine-associated birds that rely on a fish diet in the vicinity of Hinkley.
The UK Environment Agency’s Best Practice Guides state that, in order to prevent fish from being drawn into cooling water systems, and being damaged or killed, an AFD should be installed in combination with a fish return, and in the case of the new nuclear sites, including here at Hinkley Point C, in combination with Low Velocity Intake Heads.
The implementation of all of these techniques is fundamental to Best Practice, and is the basis for accepting direct seawater cooling as Best Available Technology for the new nuclear plants around our coast.
In addition, we need to bear in mind, as already noted by the Environment Agency, the low velocity Intake Heads are new and their ability to provide any mitigation is unproven. Their predicted reduction in fish entering the cooling water system is just theoretical.
Associated with this, even Cefas, which has been supporting EDF throughout this removal process, has concluded in one of its own reports, and I quote “Because of the usual high water turbidity at Hinkley Point and the consequent absence of visual clues, any mitigating effect of the low-velocity intake is only likely to be realised if it is combined with some form of artificial stimulus (e.g. an acoustic fish deterrent) to induce fish to swim away from the intake structure.”. …and the report goes on to say… “For these reasons low-velocity intake and AFD need to be considered as a combined mitigation measure.”
EDF has stated in its submissions that it was committed to the AFD when it was applying for the DCO, but the optioneering phase concluded that the final system to be installed was significantly larger than it was expecting.
This brings me onto the real reason for this whole process.
EDF states its concerns are safety driven but also acknowledges in its submissions that there have been multiple concerns about the cost, which implies a commercial decision.
If money isn’t the issue, why doesn’t EDF commit to working to best practice, and use its expertise to resolve the safety concerns?
EDF has stated in its submissions that its strong preference was to overcome the Health and Safety concerns regarding the installation and maintenance of an AFD, and EDF has its own R&D Department, with 60 full time researchers, 24 PhD students and 15 different nationalities. It states on its website “Research, development and innovation are at the heart of EDF”, yet EDF has not used any of its researchers, or collaborated with any expert suppliers, to innovate and solve the eminently solvable problems to overcome the H&S concerns.
EDF has stated it is hazardous to run cables out to the intakes 3km offshore, and yet it has multiple offshore wind farms in the UK and elsewhere that are significantly further offshore, Saint Nazaire in France is more than 12 km from the shore. It can run out cables to these facilities, which cover a far greater area than the proposed Intake Heads, and yet implies it can’t be done at Hinkley. Why is this?
EDF repeatedly raises the issue of danger to divers working on the installation and maintenance of the AFD system. We are all committed to minimising the risks associated with work offshore. FGS works with all of its clients to minimise any risks that may be associated with its systems. But EDF has maintained that the only way to carry out the work is by using divers. From its testimony it claims there are no suitable ROVs.
I’ve been advised by independent ROV engineers that ROV units are already available that work in similar high velocity conditions. Zero visibility can be overcome with augmented reality systems, something that I understand the ROV industry is confident it can achieve, and a technology that EDF’s own R&D engineers are seen to be wearing in the photograph on its own website.
Even if EDF doesn’t consider that a suitable ROV is currently available, if it is truly committed to innovation and environmental protection it should be able to work with experts to develop a suitable ROV that would answer the vast majority of the safety concerns and could not only support Hinkley, but also at Sizewell and any other sites that EDF choses to develop.
I want to also rebut another comment that flows through the statements, that AFD systems are novel. As I said during the introduction, FGS has been manufacturing and installing AFD systems at sites around the world for over 27 years. They were installed on Doel Nuclear Power Plant’s water intake when the technology was just a few years old, but Electrabel, the owners and operators of the plant at that time, saw the benefit the system would bring, even though at that stage they could have been considered novel. After 25 years deployment at that site, 27 years continual development by FGS, they are now proven technology.
I do acknowledge the concern that an AFD system hasn’t been deployed 3km off shore before, but EDF rejected the offer to work with FGS and demonstrate its suitability 4 years ago. However, even without the engagement of EDF and NNB FGS has continued to develop and improve its systems over the last four years, developing the Active Pressure Compensation Unit, which is already in use in another project and is ideally suited for deployment at these offshore intakes, with the potential to significantly increase the service interval beyond the required 18 months stated by EDF, and thereby reduce the time, the cost and risk associated with the maintenance of the systems.
The AFD system available from FGS meets all the requirements that EDF has published for the AFD. There will be a need to carry out further detailed design, to incorporate any requirements that the EA / MMO or other regulators require on redundancy. But this can be done.
We note EDF’s requirement to retrofit the Intake Heads for the AFD needs to be completed by the end of this year, ready for the installation of the Intake Heads next summer, and I can confirm that FGS is committed to working with EDF and NNB to meet this requirement. There is a huge amount to do, in what is now a very small amount of time, but FGS is willing and able to play its part.
The UK Government is holding itself aloft on the world stage on its commitment to upholding environmental standards, and the introduction of the Animal Welfare Sentience Bill in the Queen’s speech a few weeks ago means government departments will need to give full consideration to the welfare of animals, including fish, in their future measures and policies. That’s not just today, but over the next 60-year life span of the plant.
We trust over the next few weeks the inquiry will conclude in line with all the other independent experts who have reviewed the requirements for an AFD, that an AFD must be installed at Hinkley Point C.
I would like to thank you for hearing us today and we would be pleased to answer any questions you may have now, or throughout the rest of the inquiry.
Thank you.
Statement From Dr Andy Turnpenny
Good morning.
My name is Dr Andy Turnpenny. I am a fisheries biologist and Fellow of the Royal Society of Biology.
I am speaking today as a scientific adviser to Fish Guidance Systems, a company which I co founded in 1994 but from which I retired in 2015 and in which I must stress I no longer have any financial interest.
I have been a specialist in the subject of fish entrapment in cooling water intakes from the day I joined the Research Division of the Electricity Generating Board some 44 years ago in August 1977. Since that time I have authored many well known scientific papers and reports on the subject, including Environment Agency Best Practice guidance on fish screening in 2005 (known as Science Report SC030231) and the EA’s key 2010 Evidence Document on Cooling Water Options for the New Generation of Nuclear Power Stations in the UK (SC070015/SR3).
In 2007 I was appointed to the BEEMS Expert Panel, which was set up to advise on Marine Ecology issues for the Nuclear Build programme. I served on the Panel until its disbandment in 2018. My particular focus, along with colleagues Steve Colclough of the Environment Agency and Prof Mike Elliot of Hull University, was on fish protection. Subsequently I was appointed as an expert adviser to the EDF’s Cooling Water System Working Group for Hinkley Point C, attending multiple meetings in Paris and London. In both these roles I worked harmoniously with the Appellant for over 10 years to ensure that the EA’s Best Practice guidance was followed on all their NNB projects. In particular, I was a leading figure in development of the fish protection strategy for HPC. When I retired from BEEMS, I felt satisfied that the progress in fish protection developed over a lifetime’s scientific work and international experience, was properly represented in the approved design for HPC’s cooling water system as specified under the Development Consent Order.
I am therefore at this point utterly dismayed at the Appellant’s proposed withdrawal from the Permitted design as per the subject of this Public Inquiry.
To clarify my position, it is my view that EDF should fully acknowledge during the course of this Inquiry the following eight points:
1. That their intention not to use an Acoustic Fish Deterrent, or AFD at Hinkley Point C will result in a non-BAT compliant (Best Available Technology) development. More about that in a minute. LVSE+FRR without AFD do not constitute Best Practice.
2. Again, acknowledge as they did in their earlier technical reports, that the proposed use of an LVSE intake design without an AFD system would not be effective in waters with the near-zero visibility found at Hinkley, as fish will fail to react to an unseen threat.
3. Acknowledge that they have not used exhaustive efforts to keep up to date on technical advances with AFD technology and diverless underwater servicing technology.
4. That the majority of fish (56%: Table 18, TR456) expected to be drawn into the HPC intakes are fragile species such as shads, herring and sprat, for which AFD has been proven up to 95% effective, whereas by their own predictions, near 100% mortality can be expected for these fish in the fish return system (FRR) and therefore no protection will be provided
for these fish.
5. That the frameworks for fish stock assessment and management in which Cefas excel are wholly inappropriate when assessing impacts at the local level. The former MAFF Fisheries Laboratory acknowledged and acted on this as far back as the Sizewell B Inquiry in the 1980s by adopting a smaller framework for local assessment. As the Environment Agency and Severn Estuary Interests will demonstrate in the course of this Inquiry, a plethora of more recent evidence only strengthens the need for these more locally framed assessments.
6. That while they are predicting fish kills at HPC entirely on the basis of historical B-station catch rates, there remains considerable uncertainty when extrapolating this to an intake 3km offshore and of a completely different design and depth setting.
7. That past catch records from the Hinkley stations cannot provide a reliable guide to what will happen over the next 60 years, given the marked year-on-year changes in fish communities that are occurring as a result of climate change and warming. This is particularly true for example for shad, a highly protected species under UK law which favours warm-water, and which also has the potential to become more prominent in the Severn basin as a result of ongoing efforts by the Environment Agency and conservation bodies to restore connectivity and habitats in its rivers.
8. Finally, EDF should acknowledge that as a result of their intention not to fully implement Best Practice at Hinkley, their use of direct seawater cooling may not be considered BAT. The only logical alternative would be to follow the US Environmental Protection Agency model and install cooling towers instead. The reasons for this are fully set out in the Environment Agency’s 2010 Cooling Water Evidence Report No. SC070015/SR3. To ignore this advice puts in jeopardy the BAT status of direct seawater cooling at any future UK sites.
In view of the considerable uncertainties in the Appellant’s fish prediction and assessment methods, and of future changes in fish community composition within the Severn Estuary and Bristol Channel, a precautionary approach is needed and I would urge the Inquiry NOT to find in favour of the Appellant.
