Mr. Paul McDonald:

I thank the joint committee for the opportunity to appear before it today to discuss issues pertaining to the development at the Hinkley Point C nuclear power plant and the UK new-build programme. I am joined by Mr. Paul Shortt from the Department and by Dr. Ciara McMahon and Dr. Micheál Lehane, from the Environmental Protection Agency, EPA.

The Irish Government has been aware since 2009 of the UK's plans to build nuclear power stations at sites judged as potentially suitable. The UK Government identified up to eight locations for the construction of new nuclear power plants by 2025, five of which are on the Irish Sea coast and the remaining three are on the east coast.

Ireland has been recognised for some time by the UK as a stakeholder in any nuclear development proposal. When the UK initially decided to embark on plans to build a new fleet of power stations, Ireland was one of the stakeholders consulted as part of that process. Following strategic level environmental assessments, the UK concluded in 2009 that there would be no likely significant transboundary effects for Ireland arising from the new build programme. The assessments showed that while in the event of a significant unintended release of radioactive emissions, for example, as a result of a major accident, there would be a possibility of transboundary effects the probability of such an event was rated as extremely low due to the robustness of the regulatory regime.

This assessment was considered by the then Department of the Environment, under the technical advice of the Radiological Protection Institute of Ireland, RPII, prior to its merger with the EPA, and it was determined that there was no reason to contradict the conclusion that there were not likely to be significant transboundary effects. These matters were conveyed to the Government in a memo dated 17 January 2011 and the decision arising was that the existing bilateral engagement supported by ongoing contact at regulator level was the most effective mechanism through which to raise and seek to have Irish concerns addressed. This was conveyed to the UK Government in a letter from the then Minister for the Environment, Deputy Ó Cuív, to his counterpart on 24 January 2011. This letter further states that having regard to these considerations, the Government of Ireland is of the view that the appropriate and most productive way forward would be to avail of the aforementioned mechanisms of consultation rather than to seek a formal transboundary consultation. This proposed way forward was accepted by the UK and remains the adopted position. It should be noted that under the EURATOM treaty, the UK was required to satisfy the European Commission that the development at Hinkley would not result in the radioactive contamination of the water, soil or airspace of another member state. In this context a Commission opinion, issued in February 2012, considered that in normal operating conditions, discharges of liquid and gaseous radioactive effluents were not likely to result in exposure of the population of another member state.

The Government then asked the Radiological Protection Institute of Ireland, RPII, to prepare a report on the potential radiological implications for Ireland from the proposed suite of new plants. A principal finding of this report is that the routine operation of the proposed nuclear power plants will have no measurable impact on Ireland or the Irish marine environment. This report continues to inform Irish engagement on the UK new nuclear build programme. The Irish established position is that while we are not a nuclear energy producing country, we acknowledge the right of states to determine their own energy mix but we expect that where a state chooses to develop a nuclear power industry, this will be done in line with the highest international standards with respect to safety and environmental protection.

In terms of current engagement and recent development, there are now twice yearly meetings of the UK-Ireland contact group on radiological matters. This forum has been existence for a number of years. The meetings are attended by representatives from central Departments of both the UK and Irish Governments and their respective colleagues from the regulatory and environmental protection agencies. As part of the process of engagement between the two Governments, officials from Department of Communications, Climate Action and Environment and radiological experts from the EPA have visited numerous UK nuclear related sites in recent years, including Hinkley Point and Sellafield. What we gain through this process is access to the UK experts and an opportunity to visit the various sites. The issue of the UK new build programme is a standing agenda item at these meetings and arising from these discussions a letter was received from the UK Department for Business, Energy and Industrial Strategy in December 2016 concerning the UN Convention on Environmental Impact Assessment in a Transboundary Context - generally referred to as the Espoo Convention. In this letter, the UK reiterated its view that the development at Hinkley was not likely to cause a significant adverse impact on the environment of another state and that, therefore, the UK was not required to undertake trans-boundary consultation. It further stated that following a recommendation from the Espoo committee, the UK was seeking our opinion as to whether notification would be useful at the current stage for the development at Hinkley Point C. The Department responded by letter dated 2 March that such notification would be useful and set out the basis for this view and adding that having the opportunity to formally comment on the UK new build programme is extremely valuable in allaying public concerns in relation to the programme.

The new build programme and specifically Espoo related matters were discussed at the meeting of the UK-Ireland group on 27 April, following which, on 28 July 2017, a further letter was received from the UK by the Department of Housing, Planning and Local Government - the lead department in relation to Espoo - in which the UK stated that while it maintained its position that it did not breach the Espoo Convention, it recognised the value of constructive engagement and in that spirit it was providing an opportunity to comment on the current environmental information in relation to potential transboundary impacts. The letter further stated that if likely significant adverse transboundary effects are identified on the basis of scientific evidence, it would then look at how the regulatory regime might address any identified effects. A consultation process was then initiated by the Department of Housing, Planning and Local Government through the local authority network and this process was recently completed.

On emergency preparedness, in the unlikely event that there is an accidental discharge from a nuclear power plant in the UK, the Irish regulatory authorities are well primed to deal with such an eventuality. The UK and Ireland have agreed and developed an early-warning notification system to alert Irish authorities of any problems in nuclear facilities in the UK. This system is regularly tested and discussed through the UK-Ireland contact group to ensure that it remains robust and fit for purpose. Ireland has also developed a detailed national emergency plan for nuclear and radiological accidents, NEPNA, to make provision for preparedness and response to nuclear and radiological emergencies taking place both inside and outside the State. Officials from Irish Departments and agencies who will have a role in the event of such an emergency take part in international exercises to evaluate and improve our response arrangements and capabilities with regard to nuclear and radiological emergencies.

In 2017, Ireland participated in a large-scale exercise held by the International Atomic Energy Agency to test our operational arrangements of the convention on early notification of a nuclear accident. The outcomes from this Convex exercise will inform an update to NEPNA which will then be established on a statutory basis to ensure that Ireland's preparedness and responses to nuclear and radiological emergencies remains first rate.