Sizewell C Proposed Nuclear Development Stage 1 Pre-Application Consultation
Initial Proposals and Options Consultation Documents
Response from the Blackwater Against New Nuclear Group (BANNG)
Introduction – Main Concerns
The Blackwater Against New Nuclear Group is a Citizens’ Based Organisation established in 2008 to oppose any proposals to develop a new nuclear power station on land neighbouring the former Bradwell Magnox NPS on the Essex coast. It draws its support mainly from around the Blackwater but also has supporters from further afield in Essex and elsewhere. BANNG’s purpose it to raise public awareness through the media and campaigns and to respond to consultations and other reports and to consult with government, local authorities and MPs, NGOs, the nuclear industry, regulators and other bodies involved in new nuclear development. BANNG has produced 17 detailed response papers (see attached list – Appendix 1), contributed papers to journals and newspapers, held several demonstrations and public meetings and delivered a petition containing 10,000 signatures collected face-to-face to the Minister of State for Energy in Whitehall.
BANNG is concerned about the prospective development of Sizewell C for several reasons. One, is that the Sizewell project is directly linked to Bradwell as a result of a condition entered into by EDF, the owner of both sites. Under this condition EDF is obliged to sell the Bradwell site to another operator. However, the sale would only need to occur after EDF achieves planning approval to build two reactors at Sizewell in Suffolk. This means that effectively Bradwell is a back up for EDF in the event the company does not get permission to build its planned four reactors (two at Hinkley Point and two at Sizewell) in the UK. It appears that the present situation is that the Bradwell land is available for sale but that no purchaser has come forward. As things stand, if Sizewell is given permission to go ahead this would potentially leave the way clear for an operator to apply to develop at Bradwell. To be clear, BANNG is opposed to both Sizewell and Bradwell as sites for new nuclear power stations. Given the implications for Bradwell of a decision on Sizewell, BANNG urges EDF to declare its present intentions for the Essex site.
BANNG’s main concerns about the Sizewell site are similar to those it has for Bradwell. There are four main issues which we believe should preclude consideration of both these sites. First, is the issue of flooding and coastal processes. The precarious location of the proposed Sizewell C on a coast vulnerable to erosion will be of increasing concern as climate change impacts on sea-level rise and coastal processes. Our second issue is the long-term management of highly radioactive wastes and spent fuel. We do not believe management of such wastes on site into the far future and perhaps indefinitely has been sufficiently understood or considered. Thirdly, we are concerned about the arrangements for emergency planning. We believe that emergency planning procedures and implementation need far more considered attention than they receive in the documents. Finally, our fourth issue, is the massive environmental impact both in the short- and long-term arising from the imposition of a major industrial activity on a primarily rural area of important habitat conservation, landscape protection and recreation. The scale of development will, in our judgement, provide environmental insult that will utterly transform the area of east Suffolk between Aldeburgh and Southwold.
BANNG identifies four main issues of concern in the development of Sizewell C. These are: the vulnerability of the site to erosion and flooding resulting from coastal processes and sea-level rise; the problem of managing dangerous nuclear wastes on the site in the long-term; the absence of effective emergency planning procedures; and the scale of environmental damage arising from a massive industrial complex in a rural area. We consider each of these reasons sufficient to preclude development of the site for a new nuclear power station and we urge EDF to withdraw its proposals.
BANNG is also concerned at the very limited and biased nature of this consultation by EDF. Some of the key issues have already been determined by Government and are not open for discussion. These include the issue of whether the UK needs a new nuclear power station and the specific choice of Sizewell as one of eight sites. BANNG has opposed both the policy and the siting strategy in earlier consultations and reluctantly accepts that these are not open for review at present. Similarly, we are concerned that policy for long-term management of radioactive wastes is not open for debate. We believe the policy is unclear and undetermined. We recognise that site-specific planning issues are open for discussion though it is difficult to disinter these from wider policy considerations. Overall, whether Sizewell goes ahead very much depends on how acceptable it is in terms of ecological impact, coastal degradation, liability to flooding and safety, all issues with regional, local and site-specific implications.
The emphasis and tone of the documents presents a very positive and optimistic view of the development of Sizewell C. There is considerable emphasis on the purported economic benefits and environmental mitigation and enhancements that will be undertaken including transport improvements. The problems of radioactive waste management and the inadequacies of emergency planning are overlooked or minimised. Although Sizewell C is described as ‘one of the biggest and most technologically complex projects ever built in the UK’ (EDF, 2012a, p.36) the overall impression is of a benign intruder settling comfortably into the local landscape and economy bringing jobs and wealth and environmental enhancements. Sizewell C might equally be portrayed as a monstrous invasion bringing disruption, congestion and pollution and leaving a dangerous legacy on a vulnerable coast for generations to come.
BANNG is concerned at the limited nature of EDF’s consultation and its tendency to emphasise the benefits while minimising the detriments that will accompany such a major development for generations to come.
Flooding and Coastal Processes
A particular concern for BANNG is that the proposals are based on forecasts of sea- level change only up to 2100. Furthermore, they appear to rely on the central estimates reported by the UK Climate Impacts Programme which range from a 6cm. rise to 0.9m. over a 2009 baseline. It is acknowledged that even these changes will affect water depth, wave heights and storm levels (EDF, 2012b,p.80).
In terms of coastal processes the documents are rather vague referring to longshore movements, cliff erosion and sediment deposition resulting from the complex interaction of tidal flows, waves and storm surges with cliffs, shoreline and sand banks. The impression conveyed is of great uncertainty as to the future development of the shoreline and the need for far more information which needs to be gathered as part of the Water Framework Directive. On the basis of assessments of flood risk, EDF indicate they will make ‘suitable mitigation measures and possible allowance for future flood defence adaptation’ (EDF, 2012a, p.23).
In BANNG’s view much more investigation and far more robust planning is required. In the first instance EDF should identify the range of forecasts of future sea-level rise under climate change. Forecasts have been continuously revised upwards and further higher forecasts are likely to be made. Some studies have also indicated much higher sea-level rise than is forecast in the EDF submission. For instance, Wilby et. al. (2011) give an upper end scenario under the most extreme conditions of up to 4.3m. rise by 2100. It would seem prudent for EDF to recognise the possibility of much higher rises than their forecast and to indicate the adaptation and mitigation strategies they might need to deploy. EDF might well conclude that it is impossible for both technical and economic reasons to provide defence against the improbable eventuality of extreme sea-level rise. At the very least EDF will need to demonstrate that the site can be protected up to 2100 on the basis of current projections of the credible maximum scenario in the most recent projections and that it has made adequate provision to ensure that this is so. At this point there is little indication that EDF has grasped the necessity of doing so.
Beyond 2100 the situation becomes more speculative although there are several scenarios giving various projections of possible changes in sea-levels and associated storm surges and coastal processes. BANNG has little confidence that the potential situation on the coast beyond 2100 has been thoughtfully considered if it has been considered at all. In the first place predictions (which are really speculations) of sea- level rise vary considerably. Predictions of a rise of 2m and beyond have been made and even a 2 metre rise would have devastating consequences on a low-lying coast. The paper cited earlier indicates a possible rise of 5.8m. by 2200. The post 2100 period when there will still be activity on the site relies on periodic reviews of the situation. The intention is that operators may be required to implement further measures if projections show they are needed though it must be doubted if, at that distance in time, any reassurance can be given that there will be the resources, commitment and technology to develop the heroic defence measures that may be necessary.
Continuation of global carbon emissions at current levels (which, surely, must be included as a worst case scenario) could lead to a rise in temperature of 60C and consequently high sea-level rise by the end of the century. This would make extreme weather events such as floods and droughts more frequent. According to the Government’s National Policy Statement on Energy the aims of policy are ‘to direct development away from areas at highest risk’ (DECC, 2009, p. 67) and, where new energy infrastructure is ‘exceptionally, necessary in such areas, policy aims to make it safe without increasing flood risk elsewhere and where possible, reducing flood risk overall’. In the circumstances of Sizewell we conclude it would be folly to develop in the face of increasing uncertainty about climatic and coastal conditions and without credible plans for mitigation, adaptation and site management in the decades beyond 2100.
BANNG considers that EDF should not go ahead with its proposed new nuclear power station at Sizewell unless there is convincing and substantiated evidence that it is possible to undertake, manage and fund the mitigation measures that may be necessary to protect the site and neighbouring coastline together with protection of the population and environment under the maximum credible scenarios of sea-level change in the years up to the end of the next century.
Management of Spent Fuel and Radioactive Wastes
The management for the long-term of highly active radioactive wastes and spent fuel is a problem without at present a publically acceptable or scientifically credible solution. Government declares that ‘it is satisfied that effective arrangements will exist to manage and dispose of the wastes that will be produced from new nuclear power stations’ (DECC, 2010, p.18). Therefore, the question is not an issue in the development of individual sites. In BANNG’s view the Government’s statement is no more than an aspiration that may not come to fruition. There is as yet no site for the presumed geological repository nor an agreed scientific concept for disposal of new build wastes and there may never be. The search for a site is presently focused on West Cumbria and the local communities have recently decided not to proceed in the search for a suitable site. The long-term strategy for waste management has been cast into great uncertainty and it is far from clear that either local communities will be found to volunteer or that, if they do, there is viable geology in the area to accommodate a colossal underground repository. Nor is it clear what wastes will be accommodated since the inventory must be defined and could be restricted to legacy wastes (such as the spent fuel from Sizewell B) and not take new build high burn up wastes of an indefinite quantity accumulating over an unforeseeable period.
We believe that the lack of an agreed management policy impinges on the implementation of new build and is an issue that must be taken into account by EDF in planning the development of the site. The Consultation Document provides only very general information on its plans and is virtually silent on the management of wastes beyond the end of this century. The power station, if it goes ahead, is likely to operate for sixty years but spent fuel and wastes will continue to be stored well after that ‘until a UK Geological Disposal Facility is available and the spent fuel is suitable for final disposal’ (EDF, 2012a, p.14). The interim spent fuel store (ISFS) would ‘be designed for a life of at least 100 years which could be extended if necessary’ (Ibid, p.16). The same process would also be available for ILW although the Document claims (wrongly it would seem) that the site could be cleared apart from the ISFS within 20 years of shut down (Ibid, p.15). Clearly, considerable volumes of highly active wastes will be on site until well into the next century and, if the repository does not materialise or is unavailable for new build wastes, they may be stored on the Suffolk coast indefinitely in what may become very difficult circumstances.
What is hardly mentioned in the documents is that, for all intents and purposes, a long- term waste management facility will be created vastly increasing the volumes and radioactivity already present on the site arising from the shut down Sizewell A and the operation of Sizewell B. Along with the stores may come encapsulation plants, waste management processing and packaging facilities. There may be a need for repackaging and replacement of the facilities over such long time-scales. It seems to us disingenuous of EDF to make so little mention of the prospect of waste management operations on the site stretching into the far future. It is imperative that EDF provides detailed plans for the management of these wastes and of the measures it envisages to protect the facilities from natural and human processes.
The safe management of stores for the indefinite future places a considerable burden of cost, risk and effort on future generations. There is an implied expectation that there will be the resources, the skilled workforce, the commitment and resolution that will be needed to manage the wastes safely and securely on site in what may be almost intolerable conditions of inundation and storm surges. This puts a blind faith in institutional continuity and social stability which is at odds with the chaotic possibilities that may be envisioned . The point is that the future state of the coast and of society in the far future is unknowable and, therefore, we should proceed cautiously on the basis that the worst might happen and plan for that rather than casually allow the future to look after itself. It is irresponsible to consider leaving spent fuel and other highly dangerous radioactive wastes on a site which might prove impossible to defend from natural forces.
On the issue of managing radioactive wastes, BANNG concludes:
· it is not necessarily the case that effective arrangements will exist to manage highly radioactive wastes in the long-term;
· arrangements for the long-term storage of wastes on site are unclear;
· the time-scale for the long-term management of wastes on site is unknown;
· it is unrealistic and irresponsible to assume institutional continuity and social stability will persist into the far future;
· it is unethical to place burdens of cost, effort and risk on future generations to cope with the continuing management of wastes in deteriorating conditions.
In BANNG’s view it would be difficult, if not impossible, to maintain long-term, interim stores into the far future in conditions which are progressively deteriorating. In our judgement it is inconceivable that indefinite long- term interim storage is viable in such a location.
On the issue of radioactive wastes, BANNG concludes that EDF has not provided sufficient information or detail to justify its claim that wastes can be safely stored well into the next century and, in the absence of a long-term solution, possibly indefinitely. BANNG considers it irresponsible and unethical to impose unknowable risks on future generations by placing highly active wastes on such a vulnerable coastal site. We consider EDF should not proceed with its proposals for development unless and until it can provide robust and credible plans for the long-term management of these wastes on the Sizewell site.
The accident at Fukushima in 2011 drew attention to the issue of emergency planning during a major crisis. The whole area within 20km. of the plant was evacuated and a sheltering area was declared up to 30km. The population evacuated has not returned. The dislocation caused by the earthquake and the flooding by the following tsunami resulted in partial melt down of three reactors, hydrogen explosions, exposure of spent fuel ponds and consequent release of radioactivity into the terrestrial and marine environments (ONR, 2011). Subsequently across the world there were safety checks, reviews and some shut downs and ‘stress tests’ were applied to reactors in the EU. The specific circumstances of the Fukushima accident arising from natural forces and inadequate design and protection systems are unlikely ever to be replicated. However, accidents resulting from a combination of natural forces and technical failings in complex systems are possible and have occurred repeatedly over the years (see Sovacool, 2011 and Perrow, 1999).
It is important to have adequate procedures in the unlikely event of a major accident. The Consultation Document provides sparse information on ‘Emergency Preparedness’ beyond the ritual declaration that safety is the overriding priority’ and the following general statement: ‘At all our operating power stations we have well-developed plans to deal with emergencies, including contingency plans in the extremely unlikely event of an unplanned release of radioactive material off-site’ (EDF, 2012a, p.14). EDF is committed to working with the local authorities to ensure there would be appropriate emergency plans. It would be helpful to have more detailed information of EDF’s ‘well-developed plans’ in order to provide some reassurance to the local population.
We understand that the emergency planning authorities in Suffolk through the Suffolk Resilience Forum are currently consulting the public on proposed changes in the procedures. It is proposed to increase the Detailed Emergency Planning Zone to 4km. radius from Sizewell B to include all of Leiston and to define a Precautionary EPZ of 15km. Proposals also include increasing the capacity for accommodation in the event of evacuation, monitoring and precautionary protection arrangements. BANNG considers these are all changes to be welcomed. However, we have observations on some aspects of emergency planning which we feel should be taken into consideration.
On the issue of emergency planning zones we consider the Precautionary Zone of 15km. to be inadequate. We suggest it should be at least 20km. as at Fukushima or possibly as wide as 30km. Within this zone it is important to detail the countermeasures that are envisaged. In terms of public information it should be made clear to those living within the EPZs under what circumstances and over what distance radioactive contamination is possible. It should also be stated that there will be situations in which evacuation will be necessary to safeguard the population from radioactivity. This is not intended to alarm the population but to recognise the common public perception of the low probability but high consequence of a major nuclear emergency.
A further issue is how the public will be informed about what to do in case of an emergency. It is scarcely credible that in conditions of emergency the public will behave in an orderly, disciplined and rational way; there may be panic, bewilderment and misunderstanding. Getting timely and useful information to the public is of the essence. The Revised Draft NPS (EN-6) has something to say on this for the Bradwell site but curiously not for Sizewell. According to the Bradwell information within the DEPZ the public will be informed by an automated telephone messaging system while in the extendibility zone it ‘will be alerted by the local media’. It cannot be assumed that everyone will have immediate access to these warning systems or that they will operate with efficiency and swift timing or that they will be fully comprehended in conditions of elevated anxiety. In any event the rise of new social media adds a further complication in that it facilitates very rapid communication among those who use it but carries the possibility of misinformation, conflicting information and inappropriate instructions. Hence, the warning system indicated in the NPS seems to be supremely inadequate.
Substantial populations may have to be evacuated in a major emergency. Around 100,000 people were removed from the area within 20km. of the Fukushima Dai-ichi plant in the period following the earthquake and tsunami. The logistics of moving such large numbers in terms of route capacity, organisation and control, reception centres and recovery procedures all require detailed, credible and robust planning and resources. Furthermore, the plans and procedures that may come into operation need to be explained to the public and exercises undertaken to demonstrate they are implementable.
On the issues of emergency planning BANNG believes that in the interests of protecting present and future populations EDF and the local emergency planning authorities need to ensure that that effective measures are in place so that the Government’s objective ‘to limit the radiological consequences to the public in the unlikely event of a serious nuclear accident’ can be met.
EDF should provide adequate and intelligible information for the general public and the relevant authorities should develop a plan of coordinated rapid response together with an implementation plan.
Methods of informing, warning and organising the public in the event of an emergency need to be capable of ensuring as far as possible a swift and orderly response.
We expect that a credible and implementable statement from the emergency planning authorities on emergency planning will be in place before proceeding to develop a new nuclear power station at Sizewell.
Environmental and Ecological Impacts
The scale of this project, if carried forward, would be utterly transformative in its environmental impacts. The Consultation Document states that ‘Sizewell C would be one of the biggest and most technologically complex construction projects ever built in the UK’ (EDFa, 2012, p.36). Throughout the documents the proposer emphasises the economic benefits such a massive development would bring and is relatively silent on the massive environmental degradation, disruption and disbenefits that will inevitably follow.
EDF relies on its statement of sustainability to demonstrate a commitment to balance economic and environmental objectives. It states,
‘Sustainability leadership means responding courageously and constructively to the world’s most critical ecological and economic challenges. It means enhancing life today without compromising life tomorrow. It means operating our business in a genuinely sustainable way’ (EDF, 2012a, p.14).
This seems to us a weak definition which elides the basic contradiction between short- term economic development and long-term environmental destruction. This is evident in EDF’s assessment of the positive impacts which ‘include new jobs and making local economies more viable’ as against the negatives which could ‘include impacts on biodiversity and on the surrounding Area of Outstanding Natural Beauty’ (EDF, 2012a, p.12). But EDF’s main social commitment seems to be to deliver jobs, wealth and some infrastructure. It should be noted that jobs might peak at around 5000 falling back post-construction to around 1000. If Sizewell C proceeds it will bring with it a period of continuing economic adjustment and uncertainty which may not create economic stability and sustainability in the long-term. In the long run the environmental deficit is likely to prove permanent, a loss that has to be balanced against the putative short-term gains. Certainly in terms of the far future Sizewell C is likely to leave a legacy of radioactive wastes and a degraded environment on an unsustainable coastline. BANNG believes the long-term environmental degradation and continuing radioactive legacy resulting from Sizewell C will impose a detrimental burden on future generations which will far exceed any short-term economic benefits.
The Environmental Report provides some insight into the potential impacts on wildlife, habitats and landscape that will occur but is not very reassuring about the potential mitigation since much further work has to be done. For example, with reference to local coastal impacts the Environmental Report observes that ‘possible effects on the habitats present in these sites will be considered with regard to the potential changes in coastal processes’ (EDF, 2012b, p.38). Relatively little is known about these processes especially in the long-term and consequently it cannot be concluded that mitigation is possible. Although it is recognised that there will be adverse impacts, it is considered that disruption and disturbance to important habitats and ecosystems can be potentially ameliorated or lessened through mitigation measures. No matter what the impacts, the need for nuclear power as determined by Government policy, is seen as sufficient in itself to override the desirability of conserving environment and ecology. It is only necessary to invoke Imperative Reasons of Overriding Public Interest (IROPI) to justify development. We believe that in the case of Sizewell C the environmental impacts will be damaging and irreversible to the extent that efforts at adaptation or mitigation would have no more than marginal and, over time, diminishing impact. The destructive impacts on habitats, marine life and visual amenity would be of such magnitude that it should be a matter of Imperative Reasons Of Public Interest (IROPI) to avoid them.
We support the view expressed in DECC’s consultation on its National Policy Statement for Energy (EN-1) that development should not normally proceed where the proposal ‘could inhibit sediment flow or have an adverse impact on coastal processes at other locations’ (DECC, 2009, p.63). We conclude that the impacts of such a major project on the coastal environment and marine ecology are likely to be both extensive and permanent and that Sizewell C should not proceed unless and until it can be conclusively demonstrated that impacts can be minimised, precious environments restored or replaced and ecological disruption prevented
Prepared by Professor Andrew Blowers, OBE
on behalf of the Blackwater Against New Nuclear Group (BANNG)
2 February 2013
DECC (2009), Draft Overarching National Policy statement for Energy (EN-1), November
DECC (2010), Revised Draft National Policy Statement for Nuclear Power generation (EN-6), Vol.II, Annexes, October
EDF (2012a) Sizewell C Initial Proposals and Options, Consultation Document, November
EDF (2012b) Sizewell C, Initial Proposals and Options, Environmental Report, November
Office for Nuclear Regulation (ONR) (2011a and b) Japanese Earthquake and Tsunami: Implications for the UK Nuclear Industry, HM Inspector of Nuclear Installations, a. Interim Report, May, b. Final Report, September
Perrow, C. (1999) Normal Accidents: Living with High-risk Technologies, Princeton University Press, first published 1984, New York, Basic Books
Sovacool, B. (2011) Contesting the Future of Nuclear Power, Singapore, World Scientific Publishing
Wilby, R.L., Nicholls, R.J, Warren, R., Wheater, H.S., Clarke, D., and Dawson, R.J. (2011) New nuclear build sites: adaptation options over their full life-cycle, Proceedings of the Institution of Civil Engineers: Civil Engineering, 164, 129-136.
LIST OF RESPONSES MADE BY THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG) TO GOVERNMENT AND OTHER CONSULTATIONS ON NEW NUCLEAR BUILD AND STORAGE OF WASTES ON SITES
BANNG (Blackwater Against New Nuclear Group)(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, 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 (BANNG) (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) (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)