(BANNG Paper No. 33)
The Blackwater Against New Nuclear Group (BANNG) was established in 2008, ‘to seek to protect the people and environment of the River Blackwater estuary and its surrounding area, now and in the future, from the risks and dangers of radioactivity by preventing the further development of nuclear activity in the estuary.’ During the ensuing decade BANNG has raised public awareness, communicated to supporters from the Blackwater communities and beyond, responded to many consultations notably on the National Policy Statements for Nuclear Energy (NPSs) and engaged with stakeholders nationally and regionally. In various statements and papers we have set out the case against further nuclear development at the Bradwell site on grounds of safety and security, environmental protection and sustainable development. Please see the list of BANNG responses to Government and other consultations attached as Appendix 1.
It is not intended to rehearse the detailed arguments against the development of a new nuclear power station at Bradwell but to note that they provide a relevant background and context for objections to the planning application for investigative works.
BANNG considers that the application must be refused on the primary grounds that the site is wholly unsuitable, unsustainable and unacceptable for the development of a nuclear power station and its associated spent fuel stores, cooling water infrastructure and other ancillary structures. Consequently, it is concluded that the intrusive, disruptive and potentially damaging preliminary site investigations cannot be justified.
Our objections to this application are set out below:
1. The proposal is insubstantial
It is stated that ‘preliminary intrusive ground investigations are proposed on land adjacent and to the east of Bradwell Power Station, near Bradwell-on-Sea, Essex, to inform the design of a potential new nuclear power station on the site.’ This statement conveys the impression that the design is not yet developed and would be dependent on the limitations of the site. However, the size, scale and layout of the proposal must be established in broad outline, at the very least. The most basic information about the ultimate proposal has not been indicated in the application. It is believed the intention is to develop the UKHPR1000 with twin reactors with a combined generating capacity of 2,300MWe to a design derived from the Fangchenggang reactor under construction, but not yet operating in China. No models or representations of the proposed reactors and other facilities have been presented and, therefore, it is difficult to envisage what is actually proposed at the site. The most basic information about the intended development has not yet been revealed. BANNG has repeatedly asked for information and elicited no response. It is fair to conclude that the design is at a very early stage and, therefore, that the need for the preliminary investigations cannot be substantiated at this stage.
2. The proposal is premature
Following from the previous point, the application is arguably premature since it presumes there is acceptance of a successful approval at the Bradwell site. Maldon District Council has indicated it will ‘strongly support the principle of the development of a new nuclear power station at Bradwell-on-Sea’. With Essex County Council, Maldon has also declared it will ‘ensure the greatest benefit from any new facility, as well as mitigating any potential negative impacts’ (Report of Chief Executive to Council, 29 October, 2015).
The application demonstrates a number of negative impacts such as flooding, ecological disturbance, amenity damage and archaeological destruction but provides no intimation of how these impacts can or will be mitigated if the development of a power station occurs. The development, including highly radioactive spent fuel and other radioactive wastes, is likely to have a presence on site well into the next century by which time coastal conditions will inevitably have deteriorated. It is improbable that mitigation will be technically feasible or economically viable. Unless it can be demonstrated that the operations on the site can be safely and securely sustained into the far future, permission for investigative works should not be given.
3. The proposal is unjustifiable
The project is justified on the basis that the country’s need for nuclear energy is so urgent that the economic benefits outweigh the environmental detriments. It is unlikely that there will be a need for nuclear energy by the time that Bradwell B is ready to begin generating. Although government policy requires nuclear energy as part of the energy mix the policy is outmoded and may be subject to revision. Regardless of policy, Bradwell B is unlikely to provide a sufficient rate of return to the developer in an energy market where alternative forms of electricity production are able to fulfil future supply at a far more economic rate. Moreover, nuclear energy is a far more dangerous technology and its impacts persist into the far future making it environmentally unattractive by comparison with competitors.
The detriments at the Bradwell site far exceed any notional benefits from a new power station. Quite simply the site is unacceptable and unfit for the purpose of a new nuclear power station. It is inconceivable that the power station will be granted all the necessary permits or that the developer, in the full knowledge of the problems with the site, will wish to continue for long in the process. The planning application establishes unequivocally that the site is already vulnerable to inundation and, as trends of sea level rise and climate change develop, the power station and spent fuel store will be increasingly imperilled. In the circumstances the detriments far outweigh any putative benefits to such an extent that the concept (introduced in the NPSs) of Imperative Reasons of Public Interest (IROPI) could not conceivably be applied to override the environmental objections to the site.
In view of the lack of any acceptable justification for the proposed development it is considered that the application for permission for investigative works be refused.
4. The proposal is incomplete
It is presumed the total project will comprise: two reactors; construction areas and offloading facilities; infrastructure facilities including transmission towers higher than at present; flood defence and coastal protection measures; cooling water infrastructure (intake and outfall) and possibly cooling towers; radioactive waste management facilities for storage and encapsulation; road and rail infrastructures. This amounts to a massive industrial complex which would, if realised, totally transform the Blackwater estuary. The application is limited to the site as defined on the map accompanying the application. However, it does not include investigative works for some facilities that will be required on the seaward edge of the site boundary nor those beyond the site boundary which may also be developed as part of the complex. In particular new transmission towers, cooling facilities and transport infrastructures, including docking facilities, will be an integral part of the development. There is no information provided in the application as to what facilities will be needed. These will impinge on areas both landward and seaward of the site and will almost certainly impact on the terrestrial and marine environment of the Blackwater estuary. These impacts will extend beyond the jurisdiction of Maldon DC. It may be questioned whether the planning application should also have been submitted to Colchester Borough Council which shares the seaward end of the estuary with Maldon and has an interest in impacts on the marine ecology and environment from radioactive discharges and infrastructural developments impinging on the estuary.
Therefore, it is considered that the application is deficient in that it does not fully include all the investigative works necessary to inform the suitability of the site and its environs for the provision of supporting infrastructures for the complex.
5. The site is liable to flooding
Perhaps the main reason for rejecting the application is that it makes clear the site is unsuitable for a major nuclear power station and radioactive waste store. It must be recognised that a power station if permitted and built will operate until around the end of this century and that dangerous spent fuel will continue to be stored on site for cooling for at least fifty years beyond the station’s shut down before being moved to a geological disposal facility, should one exist.
Two-thirds of the site is located on the tidal floodplain of the Blackwater estuary and, undefended, would be flooded at high tide. With current sea defences there is a level of risk of flooding if defences fail or if there is an extreme event. The Flood Risk Assessment indicates flooding to more than 3m. could occur with an Annual Exceedence Probability of 0.5% with a defence breach event. While this level is unlikely to occur during the period of investigative works, should there be a breach the consequences are likely to be severe.
The application naturally only focuses on the contemporary flood risk. It may be argued that this risk, though low, is not one that is even acceptable for the purposes of investigative works taking place over one year in the near future. The probability of severe flooding in the event of a breach or overtopping becomes far higher if calculated for the much longer term. This assumes the contemporary situation projected forwards. However, the situation is far from predictable and will inevitably worsen as the impacts of climate change impose sea level rise, storm surges, coastal processes and erosion on the fragile coastline. The Essex coast is sinking which adds to the impact of sea level rise. It is clear that projections of sea level rise will continue to increase. It is anticipated that the UK Climate Projections which in 2009 indicated a relative sea level rise of 1.9m. by 2100 will be revised upwards by 20-30% when the new projections are released in 2018 (POSTNOTE, 2017). And the trends continue upwards. The situation beyond 2100 is indeterminate but it is likely that during the next century the nuclear facilities, including wastes, remaining on the Bradwell site will be severely threatened with inundation and coastal change. It will be impossible to demonstrate with any confidence that the site will be resilient against changes of the magnitude that are likely.
It is evident that the site is already vulnerable to flooding. The future situation into the next century is unknowable and there can be no grounds for deploying hazardous radioactive facilities on such a site for such a long and indeterminate time-scale.
6. Damage to the historic environment
The Dengie peninsula contains a rich archaeological heritage and a range of historic buildings and other features from various periods. Some of these, notably St Peter’s Chapel and the Othona fort are of incomparable significance. The landscape contains grazing marshland recovered from the sea from the late middle ages onwards. It is a rich and precious heritage set in a marginal and fragile context. Local planning policy is committed to conserve and enhance the historic environment. Substantial harm to designated heritage assets must be avoided. It is accepted that direct damage to assets within the site would be low, though not negligible. Opportunity would be taken for a geo-archaeological survey.
The impact of the proposed development on the historical development of the Dengie would be devastating. Destruction of fragile heritage assets within the site would be almost impossible to avoid. The impact of a massive, industrial complex on a rural, tranquil, low lying, understated landscape would be transformative. It would be impossible to conserve and the loss would be irrecoverable. The wild, spiritual isolation and modest scale of the area outside the site boundary containing St Peter’s Chapel would be juxtaposed with the jarring and discordant mass of the nuclear station.
Investigative works at this site might reveal the richness of the heritage present there thus reinforcing the case for conservation and enhancement. However, while some individual assets might be conserved, the wholesale destruction of the Dengie’s landscape and environment would be unavoidable. On these grounds the planning application should be rejected.
7. Damage to Ecology
It should be noted, as indicated above, that parts of the infrastructure development, notably cooling water apparatus and docking facilities, though integral to the proposed development are partly outside the application. There will be impacts on the coast and marine ecology which are not considered here and which affect neighbouring authorities. These impacts include potential damage to fish stocks and oyster beds. It is considered that a complete investigative survey should include the marine environment.
The site and its landward surroundings contains five designated areas – Dengie Ramsar, Dengie Special Protection Area, Blackwater Estuary Special Protection Area, Blackwater Estuary Ramsar and Essex Estuaries Special Area of Conservation. In addition there are nearby the Dengie National Nature Reserve and the Blackwater Estuary SSSI. In common with most estuaries, the area is a fabulously rich and precious complex of ecosystems, including salt marshes, reedbeds, ancient grazing marshes and deciduous woodlands and provides an abundant environment for native and migratory birds, fauna and invertebrates. The saltmarshes alone contain ‘outstanding assemblages’ of rare flora and the area supports nearly 7% of the world’s overwintering Brent Geese. Many examples of important species are cited in the Ecological Appraisal.
The application provides a detailed appraisal of the measures that would be taken to minimise disturbance and disruption on the site and to conserve the ecology and environment. Meticulous attention to detailed conservation, for example, by employing ornithologists and ecologists to ensure adequate protection of Bearded Tits, are among the methods intended to ensure the integrity of the site is maintained or restored. While this is commendable and necessary to defend the site against the intrusive works, it demonstrates the scale of destruction that would be caused if the power station were to be constructed. We consider the interference with the ecology of this precious environment is hard to justify when set against the wholesale destruction that would occur in the event of a power station being permitted at Bradwell.
It is difficult to conceive of any circumstances in which such permission could be granted and, therefore, it follows that the application for investigative works is gratuitous and should be refused.
Prepared on behalf of the Blackwater Against New Nuclear Group (BANNG) by Professor Andrew Blowers, OBE, Chair of BANNG and member of the First Committee on Radioactive Waste Management (CoRWM)
13 November, 2017
POST (Parliamentary Office of Science and Technology) Rising Sea Levels, Postnote, No. 555, June
LIST OF RESPONSES MADE BY THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG) TO GOVERNMENT AND OTHER CONSULTATIONS ON NUCLEAR ISSUES AND OTHER PAPERS
BANNG (2008) Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK, Response on behalf of BANNG, November (BANNG Paper No.1)
BANNG (2009a) ‘Have Your Say’ Government Consultation on Nomination of Sites for New Nuclear Power Stations, Response to the Consultation by BANNG, May (BANNG Paper No.2)
BANNG (2009b) The Justification of Practices Involving Ionising Radiation Regulations 2004, Consultation on the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations, Response to the Consultation from Blackwater Against New Nuclear Group (BANNG), March (BANNG Paper No.3)
BANNG (2010a) Consultation on Draft National Policy Statements for Energy Infrastructure: Draft Overarching National Policy Statement for Energy (EN-1); Draft National Policy Statement for Nuclear Power Generation (EN-6) and Associated Documents, Response of the Blackwater Against New Nuclear Group (BANNG), February (BANNG Paper No.4)
BANNG (2010b) House of Commons Energy and Climate Change Committee, Inquiry into Energy National Policy Statements, Evidence on Behalf of the Blackwater Against New Nuclear Group (BANNG), January (BANNG Paper No.5)
BANNG (2010c) Environment Agency Generic Design Assessment AP1000 Nuclear Power Plant Design by Westinghouse Electric Company LLC: UK EPR Nuclear Power Plant Design by Areva NP SAS EDF; Consultation Document, Response by Blackwater Against New Nuclear Group (BANNG), October (BANNG Paper No.6)
BANNG (2010d) The Justification of Practices Involving Ionising Radiation Regulations 2004. Consultation on the Secretary of State’s Proposed Decisions as Justifying Authority on the Regulatory Justification of the New Nuclear Power Station Designs Currently Known as the AP1000 and the EPR, response to the Consultation by the Blackwater Against New Nuclear Group, February (BANNG Paper No.7)
BANNG (2010e) The Energy Act 2008, Consultation on the Financing of Nuclear Decommissioning and Waste Handling Regulations, Consultation on a Methodology to Determine a Fixed Unit Price for Waste Disposal and Updated Cost Estimates for Nuclear Decommissioning, Waste Management and Waste Disposal, Response of the Blackwater Against New Nuclear Group (BANNG), June (BANNG Paper No.8)
BANNG (2011a) Planning for New Energy Infrastructure, Consultation on Revised Draft National Policy Statements for Energy Infrastructure, Response of the Blackwater Against New Nuclear Group (BANNG), January (BANNG Paper No.9)
BANNG (2011b) The Energy Act 2008, Consultation on Revised Funded Decommissioning Programme Guidance for New Nuclear Power Stations and Consultation on an Updated Waste Transfer Pricing Methodology for the Disposal of Higher Activity Waste from New Nuclear Power Stations, Response from the Blackwater Against New Nuclear Group (BANNG), March
(BANNG Paper No.10)
BANNG (2011 c) Management of the UK’s Plutonium Stocks, Consultation on the long-term management of the UK-owned Separated Civil Plutonium, Response from the Blackwater Against New Nuclear Group (BANNG), May (BANNG Paper No. 11)
BANNG (2011d) Japanese Earthquake and Tsunami: implications for the UK nuclear industry interim report by HM Inspector of Nuclear Installations May 2011, Comment on Behalf of the Blackwater Against New Nuclear Group (BANNG), August (BANNG Paper No. 12)
BANNG (2011e) Managing Radioactive Waste Safely: desk-based identification and assessment of potential candidate sites for geological disposal, Public Consultation, Response of the Blackwater Against New Nuclear Group (BANNG), September (BANNG Paper No. 13)
BANNG (2012a) Essex County Council’s Waste Disposal Document: Preferred Approach, Public Consultation, Response of the Blackwater Against New Nuclear Group (BANNG), January (BANNG Paper No. 14)
BANNG (2012b) Geological Disposal of Radioactive Waste In West Cumbria? Public Consultation, Response of the Blackwater Against New Nuclear Group (BANNG), March (BANNG Paper No. 15)
BANNG (2012c) Application for Development Consent by NNB Genco (EDF Energy) for Hinkley Point C Nuclear Generating Station and Associated Development, Written Representation on behalf of the Blackwater Against New Nuclear Group (BANNG), May (BANNG Paper No. 16)
BANNG (2012d) Paper presented to the DECC/NGO Nuclear Forum, ‘Radioactive Waste Management and New Build – Problems and Policies’, October (BANNG Paper No. 17)
BANNG (2013) Sizewell C Proposed Nuclear Development Stage 1 Pre-Application Consultation, Initial Proposals and Options Consultation Documents, Response of the Blackwater Against New Nuclear Group (BANNG), February (BANNG Paper No. 18)
BANNG (2013) Call for Evidence on Managing Radioactive Waste Safely – Review of the Siting Process for a Geological Disposal Facility, Response by the Blackwater Against New Nuclear Group (BANNG), June
(BANNG Paper No. 19)
BANNG (2013) Optimising the Number and Location of FED Treatment (Dissolution) Facilities in Magnox Limited – Credible Options. Nuclear Decommissioning Authority, May, 2013. Response of the Blackwater Against New Nuclear Group (BANNG), June (BANNG Paper No. 20)
BANNG (2013) Optimising the Number and Location of Interim Intermediate Level Waste (ILW) Storage Facilities on Magnox Limited and EDF Energy Sites in England and Wales – Credible Options. Nuclear Decommissioning Authority, May, 2013. Response from the Blackwater Against New Nuclear Group (BANNG), June (BANNG Paper No. 21)
(There is no Paper No. 22)
BANNG (2013) Review of the Siting Process for a Geological Disposal Facility. Response from the Blackwater Against New Nuclear Group (BANNG), December (BANNG Paper No. 23)
BANNG (2014) Comment paper on the preferred option of the Nuclear Decommissioning Authority (NDA) for optimising the number and location of:
Interim intermediate level waste (ILW) storage facilities on Magnox Limited and EDF Energy sites; and FED treatment (dissolution) facilities in Magnox Limited, Comments from the Blackwater Against New Nuclear Group (BANNG), January (BANNG Paper No. 24)
BANNG (2015) Manifestoes and Briefing documents on new nuclear build at Bradwell, FED dissolution and transfer of ILW to Bradwell from Dungeness and Sizewell February (BANNG Paper No. 25)
BANNG (2015) Application by Magnox for an extension to the timescale for the discharging of liquid effluent from the fuel element debris treatment process (FED) into the estuary from 12 months to a further 24 months; Application by Magnox for an option to switch the existing discharges to a new outfall structure when it becomes necessary due to blockages caused by siltation in the existing structure; A radioactive substances application to allow the switch to the new outfall structure when necessary. Response from the Blackwater Against New Nuclear Group (BANNG), September (BANNG Paper No. 26)
BANNG (2015) Call for Evidence – Implementing Geological Disposal: working with communities. Response from the Blackwater Against New Nuclear Group (BANNG), September (BANNG Paper No. 27)
BANNG (2016) NDA Draft Strategy January 2016. Response from the Blackwater Against New Nuclear Group (BANNG), February (BANNG Paper No. 28)
BANNG (2016) Draft Magnox: Socio-Economic Plan, 2016 – 18. Response from the Blackwater Against New Nuclear Group (BANNG), February
(BANNG Paper No. 29)
BANNG (2016) Planning Application Ref. No. ESS/15/16/MAL from Magnox (to vary condition 3 (restriction on importation) of planning permission ESS/43/12/MAL to temporarily suspend condition 3 to allow the importation of packaged intermediate-level waste from Magnox sites Sizewell A and Dungeness A into the Bradwell site’s existing interim storage facility for the period up to 2023). Objections to the Planning Application from the Blackwater Against New Nuclear Group (BANNG), September (BANNG Paper No. 30)
BANNG (2016) Requests by Magnox for: an extension to continue discharging liquid effluent, from the fuel element debris treatment process (FED) at Bradwell, into the Blackwater estuary; an option to switch the existing discharges to a new outfall structure in case the existing outfall becomes blocked by siltation; a Radioactive Substances application to allow the switch to the new outfall structure when necessary. Response from the Blackwater Against New Nuclear Group (BANNG), December (BANNG Paper No. 31)
BANNG (2017) Sizewell C Proposed Nuclear Development Stage 2 Pre-Application Consultation. Response from the Blackwater Against New Nuclear Group (BANNG), February (BANNG Paper No. 32)
BANNG (2017) CGN/EDF Bradwell B Planning Application for Preliminary Investigative Works No. 17/01128. Application to carry out preliminary ground investigations and associated works in connection with a potential new Nuclear Power Station at Bradwell-on-Sea, use existing building as core storage area and form site compound with associated parking area. Comments from the Blackwater against New Nuclear Group (BANNG), November (BANNG Paper No. 33)