RESPONSE FROM THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
(BANNG Paper No. 46)
Introduction – General Observations
The Blackwater Against New Nuclear Group (BANNG) is a local community citizens’ group opposed to the development of a new nuclear power station at the Bradwell site. We are also concerned with the decommissioning of Bradwell A and during the last twelve years have been involved in a number of issues relevant to the site. We are actively engaged with the Bradwell Local Community Liaison Committee (LCLC) and we have regular meetings with local councils, the regulators and the developers of the proposed Bradwell B. BANNG is also represented on the BEIS and ONR National NGO Forums. We have also been represented at NDA Stakeholder Summit meetings and are involved in discussions with the NDA about stakeholder engagement processes. The scope of our interest and concerns in the NDA’s operations and policies can be seen from several BANNG papers to be found on our website, banng.info (in particular BANNG Papers Nos.11, 13, 15, 17, 19, 20, 21, 23, 24, 26, 27, 29, 30, 31, 36, 37). Our response to the NDA’s previous draft strategy will be found in BANNG Paper 28. We have developed a wide experience and expertise in many of the issues presented in the Draft Strategy.
There are several general points we wish to make concerning the Consultation:
- The NDA has accomplished the difficult transition from operational to decommissioning activities. We do not support any revival of commercial operations, whether in MOX processing facilities, reprocessing or involvement in new nuclear technologies. We consider the NDA should be fully and solely committed to its stated mission: ‘to clean-up the UK’s earliest nuclear sites safely, securely and cost-effectively’. Management of the UK’s massive and complex nuclear legacy is a task that requires single-minded dedication free from distraction.
- Consequently, we consider the NDA should not be associated with support for further creation and proliferation of new nuclear power stations which by their nature produce hugely problematic levels of highly active wastes which, as numerous observations throughout the consultation document indicate, have no known ultimate time limit or destiny, quite apart from causing huge current expenditure and unfathomable future costs. Cleaning up the existing legacy is one thing, creating further dangerous waste-producing establishments is quite another.
- We support the underlying concepts presented in the consultation. We believe an Integrated Waste Management Strategy based on risk and the waste hierarchy provides a more flexible, safe and potentially cost-effective approach to waste management and is to be preferred to an approach based on rigid classification and inflexible strategies. That said, the assumptions behind strategies must be continually reappraised to avoid the approach becoming ossified.
- We welcome the potential development of a more inclusive and open engagement strategy. In our view, in the past the NDA has relied too heavily on its site stakeholder groups. Prof. Andy Blowers, our Chair has been believe, will encourage greater input and deliberation from NGOs. It should be noted that the NDA and NGOs share a common purpose, namely, the clean-up and safe management of the nuclear legacy. This provides the basis for constructive dialogue instead of the tendency for conflict and confrontation which often inhibits relations between pro and anti nuclear interests. However, the basis of the relationship could be undermined if the NDA sympathises or clearly supports new build and its creation of unknowable quantities of wastes with unlimited time-scales for safe management.
- By its very nature the NDA’s work is embedded in principles of intra- and intergenerational equity. Decommissioning and waste management are activities that may place burdens of risk, cost and effort on communities now and in the future. Therefore, strategies must take into account the timescales, distribution and scale of the burden and endeavour to minimise, alleviate and compensate where possible. We consider optimisation, timing and locational considerations should be informed by consideration of their distributional impacts over time and place.
- We fully support a strategy based on considerations of sustainability, in the sense of carbon reduction. We do not support the further development of nuclear power stations which we believe will be unnecessary to achieve net zero targets as well as such plants causing vast carbon emissions by their very construction.
- A final general point. At times the language of the document becomes prolix, managerial and imprecise. This is especially so in section 2. For example, on p.19, ‘We continue to avoid including tactical and operational information in our strategy and instead focus on our high level approach’. What can this mean? Or, ‘We now place greater emphasis on linking our strategic outcomes with tactical and operational information presented in the Mission Progress Report, our Business Plan and Annual Report and Accounts’. Such language makes the Consultation Document sometimes inaccessible, a tendency to interior dialogue. It might be easier if it was grounded in examples and specific statements of values and purpose.
Approach to Strategy
We have commented on the presentation in point 7 above. The NDA Value Framework appears as a high-level, catch-all summary but the factors and values that funnel in to each of the seven group headings are not set out although clues can be obtained from elsewhere in the document. As such it is not apparent from the information that all the factors included are to be considered in the decision making, but as Appendix A, p.157 refers, ‘The nature and significance of identified impacts should be validated in the course of future assessment work when more detailed information is available’. Thus, presumably, the factors to be considered in the Value Framework should be capable of review at any time.
Our Evolving Strategy
This section, too, also suffers at times from its opaque dialogue and illustration. Figure 4, ‘The Integration of our strategies’, comprising four sections prior to mission end, appears to be a very high-level summary, collectively referred to as ‘Critical Enablers’ (see also p.86). The many facets and complexities forming the ‘NDA Value Framework’ are presumably to be incorporated in each of those sections which thus continue to evolve. The key issues the NDA should address are, it seems, capable of belonging under the indicative headings.
However the NDA’s focus during this strategy period ‘will be to develop a better understanding of the interactions between the Site Decommissioning and Remediation and Integrated Waste Management themes’ (p. 21 para 1) which comprise only two of the four sections. Whilst decommissioning and dealing with Integrated Waste Management are obviously acutely important, it is concerning that, as it seems, eyes may be taken off the ball regarding the remaining headings of Spent Fuels and Nuclear Materials which, too, are key issues – thus the key issues are not adequately covered by this strategy.
We commend the commitment ‘to raising awareness of equality, diversity, inclusivity, health and wellbeing’ (p.21) to which we would add ‘intergenerational equity’ (see point 5 of ‘General Observations’). We would question whether part of the NDA’s mission should be ‘to develop the UK supply chain as a global leader in the civil nuclear market’ (p.21). This seems to be contradicted by a later statement in reference to the supply chain, that ‘we should be clear that any assistance or support provided by the NDA or its subsidiaries, do not detract from our mission to deliver safe, sustainable and publicly acceptable solutions to the challenge of nuclear clean-up and waste management, and generate value to the taxpayer’ (p.22). Needless to say we wholeheartedly endorse this approach.
Site Decommissioning and Remediation
While we support the self-evident approach to prioritisation based on risk (intolerable, tolerable, broadly acceptable) we are aware that this can only be a broad statement of intent. Risk is a multi-faceted concept and includes social as well as scientific connotations (for instance, risk perception). It is, therefore, mediated by many, often intersecting, variables, including, radiological risk, employment, wellbeing, institutional risk and so on. Therefore, we support the principle but only as a starting point. Risk issues require scientific analysis and sociological definition including such aspects as acceptability, continuity, anxiety and so on. Therefore, societal, as well as scientific analysis, engagement and explanation are important.
In the case of decommissioning, risk analysis and determination will be important factors in assessing options such as deferred decommissioning. It should also be applied to concepts such as interim and end state use of land, for at each stage different priorities might apply. Incidentally, we do not understand why the NDA should research opportunities ‘for reusing the land we own on behalf of government to support other government priorities such as national infrastructure projects’ (p.28). In the case of Bradwell B we would assume the NDA would adopt a disinterested approach.
The NDA has moved from the deferred decommissioning approach, now being implemented at Bradwell, to the site-specific risk-based approach with Trawsfynydd the lead site for early decommissioning. Among the influences to be considered will be: availability of resources; nature and condition of the waste inventory; applicability of waste hierarchy; condition of the plant; site conditions; potential end uses; stakeholder/community concerns; equity concerns. In certain cases impacts of climate change may become an increasing factor in the longer term. There will also be a variety of highly specific local issues to be considered at each site.
In terms of timing, it will be important to assess the comparative risk between early decommissioning (removes risk from site, clean-up and benefit to community and future generations) and deferred decommissioning (reduced radioactivity, less worker risk). As a general principle, BANNG considers that the processes and timing of decommissioning at each site should be periodically reviewed in the light of developing local circumstances and its status revised accordingly.
BANNG is naturally concerned about the implications for Bradwell, the lead site for deferred decommissioning, now placed in care and maintenance. At Bradwell techniques were developed to retrieve, condition and package ILW. No mention is made of the FED dissolution process which involved discharging contaminated/radioactive waste into the tidal Blackwater estuary. This was intended as a demonstration project which could be implemented at further sites. It aroused great alarm and concern and BANNG’s concerns were instrumental in the withdrawal of the dissolution process (see BANNG Papers Nos. 21, 24, 26 and 31). We are concerned that your Consultation does not indicate the lessons learned and the intention not to repeat such a reckless experiment in such a sensitive location.
We believe that the FED dissolution process demonstrates that the NDA needs to be open and transparent with stakeholders and the public:
- the original consultation on the optimisation of FED Dissolution Facilities, did not even include Bradwell A as it had already been decided to undertake the FED dissolution experiment there – it was BANNG that insisted that it be on the Agenda;
- the original characterisation of the waste as 100% ILW – on which the decision to use dissolution with nitric acid was based – was changed to one third ILW when severe problems with the process occurred;
- the 15% of radioactivity that could not be captured by the dissolution process was discharged into the Blackwater estuary with the LCLC and the public being assured by the NDA that these discharges would be of a ‘benign liquid’, ‘an aqueous discharge of a clean salt solution’.
The unsuccessful project cost a vast amount of taxpayers’ money. The NDA concluded that at the other Magnox sites ILW would be packaged and stored, which is what BANNG claimed right from the start should happen.
The case study in the Consultation Document goes on to state that Bradwell ‘has helped to demonstrate that interim storage of waste in a dedicated facility is neither as complex nor as expensive as previously thought, albeit dependent on site-specific factors including the views of local stakeholders’. What is not made clear is that Bradwell has, in effect, been transformed into a regional interim ILW storage facility importing from elsewhere. In addition to the ILW store, deferred decommissioning results in the graphite cores of the reactors remaining on site at least until the end of this century.
BANNG would question the viability, safety and security of the Bradwell site in the long term. By the end of the century, and certainly beyond, climate change will cause sea level rise of at least a metre and resulting flooding, storm surges and coastal processes might well render the site unsustainable and utterly unsuitable as a radioactive waste management facility. BANNG believes the deferred decommissioning status of Bradwell should be reviewed. The continuing use of the site for radioactive waste management is not only a danger to future generations in itself, it also suggests a precedent for future operations in the form of a new nuclear power station at the adjacent, but equally vulnerable site. Magnox should involve local stakeholders and communities in the decision making process on the future management and status of the site. We consider the NDA should review its perception of the level of concern presented by the Bradwell site with a view to giving it higher priority in line with Question 5 on p.32.
Land Quality Management
We consider the aim must be to ensure that land is decontaminated and, therefore, available for a variety of end uses. In the case of deferred decommissioning it may be necessary to clean up and restore land progressively as buildings, structures and services are removed. The ultimate removal of reactor graphite cores needs to be considered both in terms of how destruction/disposal of the graphite will ultimately be undertaken along with an overall plan of site restoration. Demolition, clearance and decontamination and restoration should be undertaken as an integrated project with a clear end state. Long-term degradation, dilapidation and dereliction must be avoided. It is important to recognise the tendency to neglect sites over the timescales involved.
Air and water quality should be incorporated into the strategy.
Site Interim and End States and Land Use
Similar principles apply to those considered above. A strategy of interim and end states is especially significant for those sites where deferred decommissioning is applied, as in the case of Bradwell. The timescale envisaged here extends at least until the end of this century. The ultimate end state of greenfield status appears to be dependent on the availability of a disposal facility to accept the ILW stored at the site as well as a method for dealing with the graphite cores. Over such a long timescale the strategy may become compromised, increasingly provisional, flexible and pragmatic. However, it is important that the ultimate return to greenfield status does not become a chimera. The principle of sustainable development – not burdening the future – must be observed by making commitments explicit and placing clear responsibility for their fulfilment. Therefore, milestones, in terms of interim states, need to be spelled out clearly. The land use strategy must be developed in cooperation with local planning authorities and subject to public consultation. Therefore, site stakeholder groups (or their successors) will have a continuing and significant role in identifying opportunities and requirements as time goes by. Sooner or later the site, or parts of it, will be deregulated. This may well be seen as a stage in a continuing staged process of successive interim states but clearly opening up the possibilities for a variety of end uses. By this stage local communities will be fully involved in developing strategies.
In a case such as Bradwell it will be difficult to envisage a precise end state so far away. Indeed, it would be presumptuous to constrain opportunities and choices for the future generation. However, it would be helpful to identify the broad options. Given the site’s rural and coastal location restoration to agricultural and recreational uses might be envisaged. Any development of the site as brownfield land should be limited.
Consequently, we do not agree with the following statement:
‘We commit to encouraging the reuse of brownfield land over the development of greenfield land.’
The vast bulk of spent fuels are consolidated at the Sellafield site, thereby concentrating the risk and avoiding dispersal. BANNG is broadly in agreement with the strategy and supports the priority given to ensuring the safety and security of these materials. We recognise the continuing effort to seek innovation in the management of these materials especially in systems of safe long-term storage since disposal in a GDF may not be available in the foreseeable future. We also recognise the need to consolidate spent AGR fuel at Sellafield and believe this material should be declared waste immediately since there is no acceptable further use for it.
We do not consider that the NDA should continue to supply advice and information ‘to third parties involved in the UK’s nuclear new build programme (p.47)’. New build contradicts the principle of waste prevention, the primary preference in the waste hierarchy.
Plutonium: BANNG has commented on the management of plutonium in BANNG Paper 11. It is recognised that management of Plutonium is a government priority and that the UK’s large stockpile (circa 140t.) and complexity is a formidable challenge for long-term management requiring a skilled workforce over several decades.
Therefore, we support the strategy of putting all civil plutonium beyond reach. This strategy will be easier to achieve if plutonium is declared a waste and the potential option of reuse is discarded. On security and anti-proliferation grounds we support the policy of making commercial arrangements to retain keeping foreign-owned plutonium in the UK where the small increment can be added to the UK stockpile and safely managed.
Uranium: This comprises a variety of forms, radioactivity and management routes. Uranium seems to be a relatively neglected area of policy. The quantities are huge (54,000t.) and most of it is presently concentrated at one site (Capenhurst). As with plutonium the possibility of reuse should be abandoned and the material should be conditioned and kept in safe and secure long-term storage. At present this bulk waste is languishing, presumably safely, in store but a decision on management for the long term will have to be made eventually.
Integrated Waste Management
This is an important, perhaps fundamental, change of approach. Insofar as we understand it, IWM involves the following key features: it offers a flexible and evolving approach to the definition of the myriad types of radioactive waste; it is a risk-informed approach; the risk hierarchy is applied to optimise the waste management routes; and waste management approaches may change over time in response to technological and societal developments. In short it departs from the more rigid, classificatory and management route specific approaches that have characterised waste management in the past.
We support the concept and principles of IWM so far as we understand them. We hope that in its search for flexibility, cost-effectiveness and innovation the NDA does not lose site of strict adherence to giving absolute priority to the principle of minimising risk and maximising safety.
We consider that IWM is a set of principles dealing with complexities that are not easy to grasp. We recommend that the NDA strives to expound the meaning and application of IWM in a language that non-technical and non-specialist audiences can comprehend. This is an important change and it is, therefore, important that it is fully understood by government, regulators and public. It would be worth reviewing and revising Ch. 7.0 to ensure the strategy is communicated with greater clarity.
We have already noted the IWM approach and broadly agree. This involves characterisation of wastes in terms of radiological risk and assigning waste management pathways that are appropriate. Risk analysis will involve uncertainty and complexity compared to the relative simplicity of the classificatory system. Initial assessment will determine the relevant route to take through the waste hierarchy. For the vast bulk of wastes requiring management, the various forms of treatment – sorting, segregation, reduction, decontaminating, processing, conditioning and immobilisation – will be applied to ensure the appropriate packaging or containerisation for the variety of storage and disposal routes.
The IWM approach is more complex and will probably require increased skills and effort in the early stages of management but possibly will be cost-efficient in the long term as waste streams will be highly specific rather than consolidated within a broad category. Under the classification system a broad range of wastes would be treated in the same way whether in storage or a disposal facility. To be effective IWM requires management facilities designed specifically for numerous waste streams.
While we support the approach as one that relates risk specifically to management we would make the following comments:
- 1. Too much refinement of waste streams based on risk could prove unnecessary and costly;
- 2. There will be some ‘difficult’ waste streams such as those retrieved from Sellafield ponds and silos where it may prove impossible either scientifically or technologically to apply a risk-based approach. Such waste streams are complex and in a form that requires a dedicated management route;
- 3. The IWM approach will require a wider range of management approaches and facilities. It will be necessary to determine how far the benefits in terms of risk management justify the potentially higher costs of the new management regime;
- 4. The social implications of the new approach should be considered in terms of such issues as location of facilities, methods of management and public and stakeholder engagement;
- 5. The need for skills, facilities and resources to be sustained must be recognised and firm plans for institutional continuity made. This is especially so for storage facilities which ‘must be provided and maintained until suitable disposal facilities are available’;
- 6. Intergenerational issues must also be considered in terms of benefits and costs to future generations;
- 7. It must be emphasised that this approach is developed for the management of legacy wastes and should not be advanced as a justification for the management of new build wastes. Waste prevention is, it must be emphasised, at the base of the waste hierarchy;
- 8. There needs to be greater clarity on the distinction between storage, disposal and the issue of retrievability. While storage is defined as holding wastes ‘with the intention of retrieval’, it is not clear what ‘final’ disposal means and how to interpret ‘retrievability’.
The Consultation Document poses the question: Do you think our overall disposal vision is clearly articulated and do you support our key messages? Our provisional answer is ‘No’. We are, of course, fully aware of the proposals for a deep Geological Disposal Facility (GDF) and are following the progress – or lack of it – towards its deployment. Realisation of this plan is a long way off, if it ever materialises. However, the whole radioactive waste management programme and the ambitions for new build are predicated on the availability of a repository within the next generation or two. A safety case has to be made, a site has to be identified and issues of volume, transportation, surface stores, etc. settled. Meanwhile the focus is on safe and secure storage.
The GDF vision is clear in general terms but is, as yet, obscure in depth and detail. The ‘overall disposal vision’ is, to put it bluntly, opaque. What seems to emerge from the Consultation Document is the idea of ‘near-surface’ disposal. Two near-surface disposal concepts are identified – a surface vault facility, and a deep vault facility such as disposal silos. This would deal with some of the High Active Wastes which require a degree of containment and isolation. It appears to resuscitate the idea of short-lived and long-lived ILW facilities which were proposed in the 1980s at Billingham for long-lived ILW and at four sites (Elstow, Bradwell, Fulbeck and Killingholme) for short-lived. Those projects were eventually withdrawn after public and political protest (recounted in Blowers et al The International Politics of Nuclear Waste, Macmillan, 1991) and the nuclear waste disposal saga moved on to the Sellafield RCF in 1990s and MRWS process in West Cumbria in the early part of this century, where it seems about to have its third reincarnation.
It may well be that near-surface disposal with retrievability is a necessary element of the more articulated IWM strategy. As it stands, it seems vague, yet to be developed. It faces all the issues of the previous efforts in the 1980s, especially finding a site. It is not clear how many sites will be needed, how they are to be considered. Among the issues of concern are:
- All roads lead to Sellafield strategy. Given that LLW are interred at Drigg and that the GDF’s most likely location is in West Cumbria, should the new facilities also be destined for Sellafield? The vast bulk of the materials destined for the potential near-surface facilities are already at Sellafield so there is a logic in seeking to consolidate the key storage and disposal facilities in West Cumbria;
- 2. A strategy of concentrate and disperse. It appears that only one deep vault facility will be needed, initially at least and, therefore, only one location needs to be identified, whether in west Cumbria or elsewhere in appropriate geology or pre-existing mine. As for the surface vault facility it is presumably possible to conceive of more than one. The locational options are, theoretically, wide since they are not constrained by geology;
- 3. Whatever strategy is adopted, it will require an open and transparent siting process, including in West Cumbria.
We would oppose a strategy of siting by stealth. The vague way in which the overall vision has been articulated naturally leads to suspicion of a return to the discredited Decide-Announce-Defend approach to site selection. The NDA must not regress to a pragmatic approach, seeking to identify communities on the periphery, either with existing nuclear facilities or otherwise economic disadvantage. BANNG would urge the NDA to articulate its approach and initiate open consultation of the policy principles before commencing a search for sites.
Liquid and Gaseous Discharges
Among the general principles stated are the following: ‘unnecessary introduction of radioactivity into the environment is undesirable’ and the ‘precautionary principle’ should be invoked to avoid harm. We wholeheartedly agree they must be adhered to. We have already noted (under ‘Decommissioning’) that these principles were disregarded in the case of discharges of radioactivity arising from the dissolution of Fuel Element Debris (FED) effluent into the Blackwater in support of a failed experiment. We note further that the NDA prefers use of ‘concentrate and contain’ over ‘dilute and disperse’. To which we should add that proper consultation with potentially affected communities must take place where discharges are likely to have harmful effects on the environment. In principle, however, we would argue that such discharges must be avoided altogether.
We make the following brief comments on the ‘critical enablers’ identified.
Sustainability. We understand the NDA intends to work further on the scope and meaning of sustainability. We would encourage the NDA to engage in dialogue with those, like ourselves, who have something to say on the subject. Sustainability is a multi-faceted concept that is liberally applied to all kinds of issues and situations to the extent that it becomes gratuitous and meaningless. The same criticism may be applied to ‘sustainable development’ which is usually misapplied for sustainable growth. Some of the dimensions of sutainable development have been explored in a book by BANNG’s Chair, Planning for a Sustainable Environment, which contains a chapter on ‘Pollution and Waste – a Sustainable Burden?’ (Earthscan, 1993).
It is important to consider sustainability/sustainable development in the context of environmental and social aspects. Such principles as ‘polluter pays’, ‘precautionary principle’, ‘intra- and intergenerational equity’ must inform criteria which can be applied to policy. Thus translated, sustainability may be applied to options such as early or deferred decommissioning, storage or disposal, concentration or dispersal and so on.
Consequently, BANNG commends further consideration of the concept of sustainability and its application to radioactive waste management. We would welcome an opportunity for further discussion and development of the concept and recommend the NGO community be involved in this further work.
Wellbeing and mental health. BANNG welcomes the concern for wellbeing and mental health. We would especially emphasise the need to take into account the stress and anxiety that affects communities at existing and prospective nuclear sites.
Security and resilience. We agree the safety and security of NDA sites is a fundamental requirement and welcome the emphasis now placed by Government and the NDA on cyber security. In this regard we are especially sensitive to the potential for interference from potentially hostile foreign governments involved in our nuclear infrastructure. Both internal and external threats require the utmost precaution. Security is a major factor in urging early decommissioning and removal of vulnerable infrastructures.
We seek further elaboration of the following statement: ‘Over the next five years we will seek to establish and deliver innovative security solutions that provide a more pragmatic and flexible approach to maintaining and supporting a secure working environment’. We are unconvinced that flexibility and pragmatism should be at the heart of security policy.
Research and Development. We firmly support the inclusion of social sciences as an integral part of R and D. Indeed, we consider the social sciences – economics, sociology, geography, psychology – should be regarded as central subjects in policy development, not mere add-ons.
People. We applaud and support the recognition and commitment to diversity, flexibility and commitment to environmental sustainability which is eloquently expressed in the opening paragraph on p.102. It would be good if these attitudes to work force, motivation and difference were embodied as a key part of any mission statement.
Socio-economics. The socio-economic support to communities is obviously to be commended, though questions of its application and distribution are inevitable. The resources must not be regarded as beneficence on the part of the NDA as a direct benefit to communities. Rather, the money is from taxpayers and is deployed to compensate and, sometimes, to placate local communities who bear the risk of nuclear facilities on their doorstep. This should be made clear since there is a danger that these funds may become an inducement or incentive for communities to support or at least accept a continuing nuclear presence.
BANNG believes that the socio-economic funding derived from the taxpayer should be disbursed by a local community body at each NDA site, explicitly set up for the purpose.
We consider attention needs to be given to the purpose of socio-economic support. We do not think it should be to support government development agendas, nor to assist integration with government energy policy which is contentious and disputed at many sites. We do support the NDA’s work on sustainability and especially the comment that ‘most of the NDA’s sites are near to large off-shore wind farms and there are many opportunities to support their development’.
Public and Stakeholder Engagement. BANNG has had the opportunity to make an input into the NDA’s PSE and we will not elaborate here. We do sense that the NDA has become more open, accessible and keen to engage with NGOs. The Stakeholder Summit held each year was an enjoyable event but tended to be exclusive. The NDA now appears to be moving towards a forum for NGOs along similar lines to the BEIS/NGO and ONR/NGO forums. As indicated earlier there is considerable common ground between the NDA and NGOs and, therefore, it is possible to work in a collegial rather than adversarial fashion. It has to be said that the NDA’s perceived support for nuclear activities and new nuclear power can sometimes act as a barrier to ‘the support, confidence and trust we have built with the communities..’. However, on the matter of PSE we believe the NDA has been moving in a positive direction.
Here, we return to our concerns with the Bradwell site. Bradwell was the lead site for deferred decommissioning and placed in a quiescent care and maintenance position. Since then Magnox has shifted to a strategy of decommissioning that applies to each site. Trawsfynydd has become the lead site in progressing straight through to site end state.
Although Bradwell is in the quiescent phase, it is nonetheless a radioactive waste storage site with an ILW store and the reactor graphite cores in passive storage. Further, it has become a regional store with ILW being shipped in from Dungeness A and Sizewell A to occupy surplus space created by reclassification of wastes from the FED process. Further, it is unclear for how long the stores will have to be safely and securely managed at the site and the future of the graphite cores is shrouded in mystery. In short, Bradwell’s progress through decommissioning to de-designation and to end state is unclear. This is a matter of great concern to local stakeholders who have seen Bradwell move from pole position to the back of the queue while, at the same time, becoming an undeclared nuclear waste facility.
BANNG considers that the Bradwell site has been unjustly relegated to the back of the queue while its radioactive risk remains relatively high. We urge the NDA to undertake an early reappraisal of the Bradwell site and to set out the steps and timing by which it will move towards its end state.
Prepared by Professor Andrew Blowers, OBE, BANNG Chair, with contributions from Roger Mullis, Varrie Blowers and Peter Banks
9th November 2020