Lydd Airport: Nuclear regulator forced to review aircraft crash risk
The nuclear regulator, the Office for Nuclear Regulation, acknowledges that if a large aircraft were to accidentally crash onto the Dungeness nuclear site it has the potential to cause its most severe ‘Target 9’ accident, killing more than 100 people. Over the last 5 years its rationale for not objecting to the proposed expansion of nearby Lydd Airport is an assertion that the probability of such an accident is low enough to be ignored. This is despite the development introducing larger, heavier planes than the small aircraft which operate from Lydd today. Finally, the ONR now admits that it may have “got it wrong”. As a result it has decided to set up a technical advisory panel to take a grass roots review of the model as well as consider a proposal to introduce a minimum separation policy as the only robust way of managing this large scale accident risk.
July 24th 2012 (Lydd Airport Action Group)
The nuclear regulator, the Office for Nuclear Regulation (ONR), acknowledges that if a large aircraft were to accidentally crash onto the Dungeness nuclear site it has the potential to cause its most severe ‘Target 9’ accident, killing more than 100 people.
Over the last five years its rationale for not objecting to the proposed expansion of nearby Lydd Airport is an assertion that the probability of such an accident is low enough to be ignored. This is despite the development introducing Boeing 737s and Airbus 320s which have greater potential to cause a large radiological release on impact than the small aircraft which operate from Lydd today. For these large passenger jets, the runway is only 60 seconds flying time from the power stations and positioned such that a failed take off or landing could leave the aircraft heading towards the nuclear site.
Finally, under the weight of compelling evidence, the ONR now admits that it may have “got it wrong”. It acknowledges that the mathematical model which it uses to assess the probability of an accidental aircraft crash may be inadequate and applied in error to the Lydd Airport situation. As a result it has decided to set up a technical advisory panel to take a grass roots review of the model, including its application to this airport. It is understood that the panel will assess evidence presented by a range of experts including physicist, Dr Roberto Trotta from Imperial College London, commissioned by LAAG, as well as consider a proposal to introduce a minimum separation policy (minimum distance between an airport and a nuclear site) as the only robust way of managing this large scale accident risk.
Rationally, the Secretaries of State should not determine this planning application until after the advisory panel has completed its review and the ONR has applied its findings to this particular case. Yet the ONR’s response to a recent government consultation on Dr Trotta’s research revealed that it has not considered any of the evidence presented on this subject and that it is maintaining its original position not to oppose LyddAirport’s planning application. It now suggests that even if the panel proves that the probability of a nuclear accident after expansion is unacceptably high, it can solve the problem by shutting down Dungeness B.
Leaving aside the economic impact of prematurely closing the largest employer in the region, LAAG’s nuclear advisor, Large & Associates, has submitted evidence which proves that shutting down Dungeness B would not remove the risk to the public as the radiological hazard associated with heavy aircraft crashing onto the nuclear site remains for decades after the power stations cease operation.
This means it would be unsafe for the Secretaries of State to determine these planning applications until after the advisory panel has reached its conclusions and the ONR has provided a detailed response to all the evidence submitted. The regulator has a mandate to err on the side of caution in situations where the probability of the event is uncertain and the outcome extreme. Therefore, unless the ONR can prove that the public would not be placed at risk by the proposed expansion of LyddAirport, it has an obligation to object and the Secretaries of State have no choice but to oppose this planning application.
Lydd Airport Action Group
Notes to editors:
History of planning application and LAAG’s nuclear case
- Lydd Airport’s planning application was submitted to Shepway District Council in December 2006 (Y06/1647/SH & Y06/1648/SH) for a 444m extension to its runway and a new terminal to increase its passenger numbers from < 3000 in 2005 to 500,000 passengers per annum (ppa). (Note in 2011 there were ~500 passengers). This planning application represents Phase1 of the airport’s Master Plan objective to increase passenger numbers to 2million passengers per annum (2mppa).
- Four rounds of supplementary environmental information were submitted between December 2006 and January 2010 as the information provided in the original planning application was inadequate and incomplete. Nuclear safety was addressed by LAAG throughout this consultation process with the support of independent consultants.
- Shepway District Council determined in favour of the planning application on March 3rd 2010. The Secretary of State for Communities and Local Government (DCLG) announced a public inquiry in June 2010 because of the controversy over: the unlawful nature of the Council’s decision, the adverse impact the development would have on protected habitats which surround the airport and the nuclear safety issues engendered by the airport’s close proximity to the Dungeness nuclear power complex. The Public Inquiry took place between February 15th, 2011 and September 16th, 2011.
- During the 2011 public inquiry the following experts gave evidence on behalf of LAAG on the causes and consequences of an aircraft accident at the Dungeness nuclear complex and the inadequacy of the Byrne model used to determine the probability of an accident: John Large, Large & Associates, Dr David Pitfield, Transport Studies Unit, Loughborough University, Malcolm Spaven, Spaven Consulting and Mrs Trudy Auty, a consultant with over 25 years of industrial experience.
- LAAG commissioned an additional critique of the Byrne model in early 2012 by Dr Roberto Trotta (Imperial College London) in response to the UK nuclear industry failing to address accidental crash damage as part of its European stress test (safety evaluation). This safety evaluation of all European nuclear power plants was conducted in the wake of the Fukushima accident. Crash damage was mandated as a parameter to be addressed by the European Commission but not all countries, including the UK, examined the hazard. The ONR’s UK report was published on January 4th 2012. Dr Trotta’s critique was submitted to the Department for Communities and Local Government (DCLG) and the Department for Transport (DFT) on April 2, 2012 – the two government departments responsible for determining the planning application. The consultation on Dr Trotta’s report and the new planning regime was announced on April 24th, 2012. A further consultation was announced on May 31st with all submission responses required by June 25, 2012.
- The operator of Dungeness B, EDF/British Energy opposed LyddAirport’s planning application because of the increase in the risk of an accident at Dungeness B caused by the introduction of heavy commercial aircraft taking of and landing at LyddAirport.
- The runway extension will allow the commercial operation of large aircraft such as the Boeing 737 and Airbus 320 which weight over 70 tonnes fully loaded. Currently 99% of activity (movements) atLyddAirport is dominated by light aircraft (aircraft weighing < 5.7tonnes)
- Lydd airport is located on an ecologically sensitive site near Dungeness on Romney Marsh, Kent. The airport is surrounded by protected habitats and is particularly renowned for birds – a major RSPB bird reserve is located between LyddAirport and the Dungeness nuclear power complex and the airport is located under one of the main migratory bird routes in the south of England.
- In terms of man made constraints, Lydd Airport is located less than 3 miles from the Dungeness nuclear complex and lies between two army ranges – Lydd Army Range <2 miles away at the southern end of the runway and Hythe Army Range ~ 8 miles to the north. The Lydd Range has a 4000ft height restriction and the Hythe Range 3200ft. The Dungeness nuclear complex has a 2000ft height restriction and aircraft taking off and landing from LyddAirport are restricted to flying within 1.5nm of the complex. As a result of these restrictions runway access is restricted, there is an Instrument Landing System (ILS) only on one runway and that ILS is 5 degrees offset. LyddAirport is the only civil airport in the UK with a 5 degree offset ILS.
- If LyddAirport’s development proceeds, no other regional airport in Europe, and possibly the world, will be as close to a nuclear power complex.
- Lydd Airport is owned by Sheikh Fahad al-Athel.
- LAAG is an action group formed in 2004 to oppose the large scale development of Lydd airport. LAAG has ~3000 active members.
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