Essex County Council’s Waste Disposal Document: preferred approach
Response from the Blackwater Against New Nuclear Group (BANNG)
This response is submitted on behalf of the Blackwater Against New Nuclear Group (BANNG). BANNG is a Citizens’ Based Organisation formed in 2008 with the aim ‘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’.
BANNG is engaged in raising public awareness of the Government’s proposals for new nuclear developments at Bradwell, which include the long-term storage of radioactive wastes at the site, including intermediate level radioactive waste and spent fuel. To this end, representatives of the group have made presentations to various bodies and local Councils, including the Economic Development and Environment Policy and Scrutiny Committee of Essex County Council. We have held public meetings and staged events and representatives have given evidence to the House of Commons Select Committee on Energy and Climate Change. Further, our Petition containing 10,000 signatures (collected face-to-face) was handed to the Energy Minister earlier this year.
BANNG has responded to thirteen Government consultations, to date, many of which relate to the Waste Disposal Document. Each of these responses was sent to the members of the Essex County Council Economic Development and Environment Policy and Scrutiny Committee (including Councillor Jowers) via the Secretary to the Committee. A list of the BANNG responses is attached for reference.
In all our activities, we have emphasized that the Government does not plan only to construct new nuclear power stations but also to store highly radioactive spent fuel on the site over the long-term. If no national repository is found, this spent fuel could remain at Bradwell indefinitely.
The group has expertise in a range of nuclear issues, most particularly the policies relating to the management of radioactive waste. The Chair of BANNG, Professor Andrew Blowers, OBE, was a member of the first Government Committee on Radioactive Waste Management (CoRWM). Professor Blowers drafted the policy on implementing CoRWM’s proposals which was subsequently adopted as Government policy.
More recently, Professor Blowers has been appointed as Co-chair of the Department of Energy and Climate Change /NGO Forum. The other Co-chair is the Head of New Nuclear Development at DECC.
In this response, BANNG is making brief comments on the sections of the Essex County Council Waste Disposal Document that relate to the disposal of radioactive waste. We would, however, welcome the opportunity to provide a more detailed exposition to Council members and officers.
BANNG is concerned at the relatively brief attention paid in the WDD to the issue of radioactive waste. The former magnox reactor at Bradwell is undergoing decommissioning and is a major source of low and intermediate level radioactive wastes, much of which will remain in situ for a considerable time, possibly for the next century. Bradwell is, therefore, a site for the long-term interim storage of these wastes. For some of these wastes, notably the substantial reactor graphite cores, there is no definite plan for ultimate management beyond the possibility of disposal in a national repository (see below).
The WDD at para. 3.35 states that the storage, treatment and disposal of these wastes is being addressed through an existing planning permission allowing for ILW to be managed and stored before this is exported to the National Repository for Radioactive Waste in Cumbria. It must be stated that there is, as yet, no national repository and there may never be one. There is neither an agreed concept nor an acceptable location for such a facility. A concept is under development but is very far from proven with an agreed safety case. While it is true that there are discussions in West Cumbria about the possibility of hosting a facility, the decision on whether to participate in a search for a site has yet to be taken and is the subject of a consultation which ends on 23 March. Even if there is agreement to proceed with the process of site selection, there is considerable uncertainty about the possibility of finding a scientifically acceptable site for a facility which could be 6 to 11 times the size of the Royal Albert Hall, located up to 1000m. below the surface. Therefore, it is presumptuous at this point to claim that a long-term management route exists for the Bradwell decommissioning wastes.
Para. 3.36 notes the possibility of Bradwell hosting one or more new nuclear power stations which would create further arisings of ILW. In addition and according to the National Policy Statement on Nuclear Energy (EN-6), it is likely that the highly radioactive spent fuel from new reactors would be stored on site. There are no plans to remove spent fuel and other wastes from the site until the repository becomes available, currently anticipated at 2130 but, as noted above, there is no guarantee the repository will be built. There is, therefore, the prospect of indefinite storage of highly radioactive wastes on site.
BANNG has several times drawn the Government’s attention to this problem. The detailed arguments are presented in several BANNG responses to Government nuclear consultations which have been sent to the County Council. We shall be happy to identify these and to present our arguments to the Council. There are two aspects which are especially worrying. The first is that the future integrity of the coast is in doubt as the prospect of sea-level rise together with storm surges and coastal processes increases especially beyond 2100. Bradwell is a very low lying site on a coast which is likely to suffer from increasing inundation making safe management of highly active wastes more problematic. The other aspect is the issue of intergenerational equity. The burden of resources, risk and effort will be passed on to generations in the far future. Beyond a generation or so it is difficult to count on either the institutional continuity or the societal stability that will be necessary to ensure the safe management of radioactive wastes in deteriorating conditions.
BANNG considers the WDD totally evades these major issues. It is not responsible simply to argue that ‘ILW will need to be considered in the context of the future national repository arrangements and not with the WDD’ (3.36). The County Council should express its concern that Essex will be host to the long-term interim storage of highly active radioactive wastes.
The national repository was initially conceived for the disposal of legacy wastes, not those from new build. Moreover, communities are being invited to volunteer to host a repository and will be duly compensated if they do. They also have a right to refuse. Essex is being offered neither voluntary process nor compensation although it will become a de facto site for the long-term management of radioactive wastes. BANNG urges the Council to oppose the long-term storage of spent fuel and other wastes at the Bradwell site and to make its opposition clear to the Government before any proposals are made for new nuclear development at the site.
Written on behalf of the Blackwater Against New Nuclear Group (BANNG) by
Professor Andrew Blowers, OBE, Chair, and Mrs. Varrie Blowers, Secretary
19 January, 2012